BP SDEIS App L Site Specific HSSE Cape Vincent

Site Specific Health, Safety, Security, and Environmental Plan
Appendix L
February 2011
Project No. 0092352
Environmental Resources Management Southwest, Inc.

206 East 9th Street, Suite 1700
Austin, Texas 78701
(512) 459-4700
Site Specific
Health Safety Security &
Environmental (HSSE) PLAN
For BP Alternative Energy
Cape Vincent
Wind Energy Facility
Project No. 0057356
Rev 0
12/7/2007
Cape Vincent Wind Energy Project

Project Number: 0057356
Date 12/5/2007
Revision 0 1 0092352\A4363 App L - Site Specific HSSE.doc
Table of Contents
1. Zero Injury Safety Policy
1.1 Performance Measurements
1.2. Policy
1.3. Zero Injury Program Checklist
1.4. Implementation of Zero Injury Techniques
1.5. Safety Committee
2. Responsibilities of BP Alternative Energy

2.1. Corporate
2.2. Project Safety Coordinator
2.3. Project Manager
2.4. Superintendent
2.5. Foremen
2.6. Employee’ Safety Responsibilities
3. Responsibilities of Subcontractors
3.1. Subcontractor Pre-Mobilization Safety Review
3.2. Subcontractor Safety Responsibilities
3.3. Subcontractor Emergency Plan - Area Map
3.4. Subcontractor Safety Questionnaire
3.5. Subcontractor Safety Hazard Notification
4. Orientation / Training
4.1. Orientation / Training #1
4.4. Landowner Orientation
4.5. New Employee / Subcontractor Orientation Log
5. Safe Work Programs

5.1. Substance Abuse Policy (Non-DOT)
5.2. Hazard Communication / Right-to-Know
5.3. Hazardous Materials
5.4. Hazard Communication Training Log
5.5. Fire Protection and Hot Work Permits
5.6. Lock Out / Tag Out / Check Out
5.7. Fall Protection
5.8. Respiratory Protection Program
5.9. Voluntary Respirator Use Form
5.10. Confined Space Program
(a) Confined Space Checklist
(b) Confined Space Classification Table
5.11. Scaffold Standards
5.12. Blood Borne Pathogens
5.13. Electrical
5.14. Environmental

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5.15. Snake / Insect Bites and Dangerous Animals
5.16. Project Signs
6. Accident / Incident Reporting Procedures

6.1. Site Security
7. Disruption Avoidance
8. Stretching Program
9. Severe Weather
10. Additional Policies and Procedures

Date 12/5/2007
1. Safety Performance Measurements and
Zero Injury Safety Policy
1.1 Safety Performance Measurements
BP Alternative Energy (BPAE) have established the following goals to

measure the success of safety performance at the Cape Vincent project:
1. Total Recordable Incidence Rate (TRIR) 2.0

2. Lost Time Incidence Rate 0.0
TRIR is a standard OSHA measurement based on 200,000 man hours of

work. The Lost Time Incidence Rate, also known as Days Away From
Work Case (DAFWC) is not an OSHA measurement. It describes the
incidence rate of injury resulting in lost time and is also based on 200,000
man hours of work.
In support of these goals the following leading indicators will be utilized:
1. Measure the effectiveness of Pre-Task Planning by scoring

each foreman’s card daily
2. Near Miss / Hazard Recognition reporting with real time
trend analysis and reporting to the project team
3. Investigate all property damage and vehicle damage
incidents with reporting to the project team
4. Perform work observations on a scheduled basis to include
all subcontractors of every tier with the results reviewed and
distributed through the Site Safety Committee
5. Perform daily safety assessments with results and
opportunities communicated daily at the POD meeting
While the TRIR goal is 2.0, the project team will strive to achieve Zero
Injuries.

Date 12/5/2007
1.2 Policy
BP Alternative Energy is committed to eliminating worker

injury at every project site and every work place. All
employees are empowered as follows:
1. To conduct their work in a safe manner.
2. To stop work immediately to correct any unsafe

condition that is encountered.
3. To take corrective action so that work may proceed

in a safe manner.
It is the Company’s goal and expectation that no one will

suffer an injury in the execution of our work.
This safety plan captures the Zero Injury culture and the actionable processes which are
expected of every BP Alternative Energy project team member including subcontractors
and customers. To empower every person covered by this plan I pledge with out
qualification, my commitment to worker and work place safety and affix my signature
below as proof.
Signature

Date 12/5/2007
1.3 Zero Injury Program Checklist
Project Name: Cape Vincent Wind Project Date:
Project Manager: Project Supt:
Yes No
Project Start-up Kit
Pre-Job Hazard Analysis
Orientation-Project Wide-First Day, First Hour
Second Orientation - Project Wide - By End of Second Week
Third Orientation - Project Wide - By End of Fourth Week
Daily Stretch Program - Project Wide
Daily Pre-Task Planning & Training - Project Wide
Near Miss Reporting
Near Miss & Accident Investigation Team & Procedure
All High Risk Activities Identified and Updated
Safety Critical Submittals Tracked
Lift Plans for All Critical & Engineered Lifts
Training Schedule Published
Monthly Project Wide Safety Meetings
Daily / Weekly Tool-Box Talks
Daily / Weekly Safety Audits
Project Safety Leadership Team (Committee)
100% PPE-Project Wide-Safety Glasses, Hard Hats, Hi-Vis Vests
Subcontractor Pre-Qualification & Updated Safety Statistics
Pre-Employment/Post-Incident Prohibited Substance Screening
Attach copies of meeting minutes, forms, logs, reports, etc.

NOTE: Submit this checklist along with attachments to Energy Group Director, Safety &
Quality with Monthly Reports.
1.4 Initial Implementation of Zero Injury Techniques

The Environmental Health & Safety Services Group has asked for the full support and
cooperation of the Leadership Team of each operating group in implementing the
attached Zero Injury Safety Policy. Further, the Environmental Health & Safety Services
Group empowers every manager and supervisor to proceed with implementation of those
Zero Injury techniques appropriate to each project. These techniques should be included

Date 12/5/2007
in job-site safety programs as quickly as possible, while maintaining quality of the effort.
Safety professionals will be available to assist with our commitment to support field
operations in our Zero Injury initiative.
All workers engaged on our projects shall be advised during safety orientation sessions
that it is BP Alternative Energy’s expectation that there be NO INJURIES. All workers
shall understand they are empowered to stop the work any time a risk of injury is
recognized, and that they shall immediately report any unsafe condition or take corrective
action personally. Managers and supervisors must investigate every accident or near
miss, and initiate changes that will eliminate the possibility of recurrence.
Achieving our goal of an injury free workplace mandates that we communicate to our
workers our commitment to Zero Injury, and then ask the workers what help and support
their need to work in a manner that prevents injury.
Some of the techniques will require formal action by the Environmental Health & Safety
Services Group to provide proper legal and technical support. There are a number of
techniques that we can begin implementing immediately. A prioritized listing of some of
these techniques follows:
I. Pre-project/Pre-task Safety Planning:
The Energy Group has formed a Safety Leadership Team headed by the group vice
president. This Team functions as the implementation, coordination and prioritizing team
for the group. The Team meets to analyze progress toward the Zero Injury commitment
and to set group Zero Injury technique implementation goals. The Team will
communicate line management’s responsibility and accountability for worker safety.
The Cape Vincent Wind Energy (Cape Vincent) project will establish a project safety
committee for the purpose of coordinating project safety matters. Membership of the
project safety committee shall include BP Alternative Energy and subcontractors. The
project will establish an accident review team, led by the project manager. This group will
be the initial response team for all accidents, incidents, including environmental incidents
and near misses, and is responsible for the investigation and reporting on all incidents.
A complete project safety analysis will be performed by the project manager and
superintendent prior to beginning work in the field. Safety technique implementation
goals will be established. Job hazards and special conditions will be identified to identify
special safety requirements or conditions. Group safety professionals will assist in this
effort.
The project schedule will be developed in contemplation of creating safe working

conditions. This applies to the project schedule, as well as short interval schedules.

Date 12/5/2007
Pre-task safety planning will be completed by all foremen and trades people prior to
beginning any new task assignment. Pre-task Planning cards will be used in this
planning process.
Subcontractors pre-qualification must include an assessment of safety performance and

safety program content. All subcontractors must have programs similar to Zero Injury to
be considered qualified to work on a BP Alternative Energy project. Subcontractors who
are not cooperative with our safety initiative will be excluded.
II. Safety Orientation and Training: BP Alternative Energy
Formal classroom safety training for project managers, engineers, accountants and
administrative staff, foremen and craft workers will be implemented for the project team.
This includes BPAE and BPAE subcontractors of every tier and all visitors. Formal on-
site First Day, First Hour Orientation is required of all persons prior to admittance to the
work site.
All employees will receive safety orientation prior to their first work assignment (First Day,
First Hour). The orientation must include an explanation of our commitment to
eliminating worker injury and that employees are empowered to stop work any time an
unsafe condition is recognized. Production or schedule will never take precedence over
worker safety. Second orientation will occur 2 weeks after hire date and third orientation
will occur 4 weeks of hire date for all above listed personnel. For details on orientation
see sections 3 and 4.
III. Drug and Alcohol Abuse Program:
Studies have proven that a high percentage of accidents on construction sites involve
workers under the influence of alcohol or other controlled substances. Therefore, an
Alcohol and Substance Abuse Testing Program will be implemented on the project. The
program will include pre-employment screening, post-accident / incident testing and
random employee testing, and is outlined in detail in Section 5.1.
IV. Incident Investigation:
All incidents must be promptly reported using a First Incident Report form. This will
provide information to the proper parties to facilitate a coordinated and appropriate
response. Incidents include; personal injury and property damage accidents, near miss
events where personal injury or property damage did not occur but could have, hazard
recognition and events with an environmental component.
Investigations of all incidents will occur as soon as practical with formal documentation
and reporting to the Environmental Health & Safety Services Group, Energy Group and
BP Alternative Energy. Toolbox safety meetings will be used to review incidents. These
talks will discuss actions taken to prevent any future occurrences. Incident investigation
reports must include an explanation of the cause and preventive action taken.
The project team will collect Subcontractor man hour and worker injury safety statistics
related to our project. This information, along with BP Alternative Energy man hour,
miles and workforce safety statistics will be reported to the group Director of Safety &
Quality and BP Alternative Energy site representative by the fifth of each month.
Accident / Incident reporting procedures are outlined in detail in Section 6.

Date 12/5/2007
V. Safety Recognition
Plan Provisions: A program of safety recognition, with appropriate incentives, will be

developed as appropriate for a project.
Eligible Participants:
VI. Short Service Employee Management:
The purpose of Short Service Employee (SSE) Management is to ensure that new or
transferred BP Alternative Energy employees, contractors and subcontractors are
identified, appropriately supervised, trained and managed in order to prevent injury to
themselves or others, property damage or environmental harm.
The intention of the SSE Program is to identify and manage those individuals who are
relatively new to the work in which they will be engaged. These individuals should be
assisted in their growth and knowledge on matters pertaining to HSSE. This includes but
is not limited to:
• Viewing of the BP Immersion Series (Inclusion to SSE program is under review)

• Site or office HSSE British Petroleum orientation
• Selected HSSE training programs such as defensive driving, general safety
requirements, etc.
A Short service employee is an inexperienced worker; defined as anyone with less than
six (6) weeks of continuous employment with present employer at the current project site,
or less than six (6) months in the same or similar job type with the present employer.
This includes BP Alternative Energy employees, contractors and subcontractors.
Vendors/suppliers that do not perform any work activities at the project site other than
routine pick up and delivery are excluded.
While on site locations, a hard-hat sticker with the letters, “SSE-Please Help Keep Me
Safe” should be incorporated as part of assigning new-employees to a location. This will
assist in readily identifying new employees who may need assistance or guidance in
learning site specific HSSE policies, standards and procedures.
Superintendent Responsibilities:
• ensure that a formal on-site safety orientation is developed and implemented

at the site. Ensure this orientation is provided to the SSE by a
knowledgeable, experienced employee prior to SSE’s initial work
assignment.
• assign a mentor to the SSE from among the experienced crew members that
has proper operations knowledge and skills and displays the appropriate
safety leadership and work ethic
• conduct an HSE performance review with the SSE after 4 weeks,
documenting progress to date and areas in need of continued improvement,
counseling SSE on areas for improvement (NOTE: Contractors shall be
evaluated by their own company’s appropriate supervisor or foreman.)
• accept responsibility for the safety of a SSE assigned to his crew or area
through example setting and observation skills.
• ensure Pre Task Planning Cards and Integrated Work Instructions (IWI) are
utilized as a training tool with the SSE.

Date 12/5/2007
• provide daily coaching and feedback to the SSE about safe work practices.
• validate and document that all the above is accomplished
Mentor Responsibilities:
• accept responsibility for the safety of an assigned SSE through example

setting and observation skills.
• teach and coach the SSE in his/her roles and responsibilities and safe work
practices for all assigned duties; review the known potential hazards for the
work to be performed.
• display a positive work ethic and lead HSE by example at all times.
• review the purpose of and how to participate in the development of a proper
pre task plan and how to utilize the integrated work instructions with the SSE.
• observe SSE during each task he/she performs and provide adequate
feedback by using the Safety Observation process techniques.
• provide prior approval for any new task initiated by the SSE.
• be knowledgeable of applicable HSE policies, procedures, standards and
expectations.
• participate in the performance review with the SSE after 4 weeks.
• Mentors shall be responsible for multiple SSE’s.
SSE Responsibilities:
• attend first day, first hour safety orientation upon arrival at their first field
assignment and prior to performing any work and all subsequent safety
training and orientations.
• learn designated roles and responsibilities; adhere to all policies and
procedures taught or shown to him/her.
• learn the location and application of all emergency response equipment (fire
extinguishers, eye wash stations, emergency shutdowns, first aid kits, etc.).
• actively participate in and review the Pre Task Plan and Integrated Work
Instruction for any task they are directed to perform.
• seek assistance and guidance from the mentor when uncertain about any
part of the job or for a task he/she has never performed.
• understand the obligation to stop work that he/she feels is unsafe or does not
understand, or when conditions have changed.
• when required, wear the appropriate level orientation sticker on his/her
hardhat at all times when working as an SSE.
• understand and clarify any concerns during performance reviews.
All SSE’s shall be identified by the appropriate level orientation sticker on their hardhat.
There are 3 levels of orientation numbered 1 through 3. Each sticker has a specific color:
1=Red
2=Light blue
3=Dark blue
All SSE personnel must attend the first day, first hour orientation #1 prior to beginning
work. Two weeks after receiving orientation #1, all employees shall receive orientation
#2. Two weeks after receiving orientation #2, all employees shall receive orientation #3.

Date 12/5/2007
For all SSE’s, applicable Contractor and HSE policies, procedures and standards shall be
discussed, including but not limited to:
• Site or area specific Emergency Response Plans, including location of

equipment/supplies
• Contractor and applicable BP Safety Standards
• BP’s Golden Rules of Safety
• Job Safety Analysis purpose and process
• Job Observation purpose and process
• Worker responsibility to stop the job when appropriate
• Incident and Near-Miss reporting
Each SSE shall be assigned a Mentor who shall be responsible for providing individual
oversight and training. The Mentor shall be knowledgeable of the appropriate BP and
Contractor policies, procedures and standards. No new work shall be assigned to or
initiated by the SSE without prior approval from the Mentor.
Exceptions: Office work groups may adopt the mentor process as needed to provide
adequate guidance to the SSE while minimizing adverse impact to personnel
assignments and scheduling. Consideration may include, but not be limited to, assigning
more than one person to perform the specific duties of the Mentor, allowing the Team
Leader to also act as the Mentor and condensed mentoring process upon demonstration
of skills and knowledge.
The Project Superintendent shall meet with the Mentor to discuss, document and
approve the SSE's professional development after six (6) weeks of hands-on experience.
Discussions can occur earlier, at management’s discretion, based upon the SSE’s
assignments and/or individual progress. Within the first six (6) weeks, the SSE must:
• demonstrate a working knowledge of the applicable site safety policies and

procedures.
• demonstrate safe work practices and be receptive to constructive criticism for
observed practices.
• improve or correct unsafe practices in a timely manner.
• apply accident prevention tools in a pro-active manner.
• the Team Leader and Mentor may agree upon an earlier graduation from SSE
status provided the SSE fully demonstrates all of the above criteria and has
completed all required HSE training.
• Failure to meet any of the above criteria will result in an extension of the SSE
status (by BP approval) or a discipline process according to BP or Contractor
progressive discipline procedure, leading up to and possibly including termination
if warranted by observed unsafe performance.
Documentation shall be retained by the appropriate employer and per their retention
requirements.

Date 12/5/2007
1.5 Safety Committee
The purpose of a safety committee is to bring hourly workers and management together
in a cooperative effort to promote safety and health on the project. The committee will be
formed during project preplanning and will be active at mobilization. This group will be
the initial response team for all accidents, incidents, including environmental incidents
and near misses, and is responsible for the investigation and reporting on all incidents.
I. Committee Membership
Membership of the project safety committee shall include BP Alternative Energy and
subcontractors. The project will establish an accident review team, led by the BP
Alternative Energy project manager.
The safety committee will be comprised of both hourly workers and management
employees. No more than 40 percent (40%) of the committee may be management
employees. Hourly workers will select representatives by peer nomination and/or voting
process for the remaining committee member positions. There will be no less than five
and no more than ten members on the committee at a given time. In addition, the BP
Alternative Energy site safety representative will be an ex officio member of the
committee. Employees of subcontractors are also eligible to serve on the committee as
hourly worker representatives or management representatives.
The committee will be co-chaired by an hourly worker representative and a management

representative.
Members will serve on the committee for the duration of the project. If a committee
member is no longer assigned to the project, then the vacancy must be filled prior to the
next safety committee meeting.
II. Committee Duties
Team Objectives Provide a Forum for the various groups at the site/facility (BP, Contractors and
Subcontractors) to meet and discuss HSSE matters that impact personnel at the
location.
Key Outputs:
Discuss and review these HSSE requirements
Work as a coordinated team to stay engaged in HSSE Management
Discuss emerging HSSE issues, concerns and trends.
Brainstorm solutions to HSSE opportunities for improvement.
Monitor key performance indicators.
Identify HSSEaccomplishments and challenges
Verify effectiveness of HSSE plan activities
Boundaries Have the authority to make recommendations of proposed HSSE solutions

Of through Management of Change , have authority to make or change established
Responsibility HSSE policies, processes or procedures
Have procurement authority
Work within the parameters of the project or site HSSE plan

Date 12/5/2007
III. Committee Meetings and Inspections
The safety committee will meet weekly. A written agenda will be developed and meeting
minutes will be kept. The committee will conduct inspections and work observations
monthly. Results of each inspection and observation are to be documented on a Project
Safety Assessment Form.
Any recommendations given by the committee will receive a response from the employer
within a reasonable time limit.
IV. Work Observations
Work observations are events in which committee members observe a specific work
activity for the purpose of finding health and safety improvements to the work process. A
minimum of one work observation a month will be conducted and a written report of
observation findings, issues and implemented solutions will be prepared.
V. Membership Entitlements
Each member will be allowed one hour to prepare for each meeting. Also, each member
will be permitted time to attend meetings, conduct inspections, perform work observations
and carry out other duties. Members will be paid for these times at the regular proper
rate.
VI. Committee Postings
The following items will be posted where other required jobsite postings are located.
A. A list of the committee members
B. Safety committee meeting minutes
C. Safety committee inspection reports

Date 12/5/2007
2. RESPONSIBILITIES OF BP ALTERNATIVE ENERGY
2.1 Corporate
BP Alternative Energy is committed to the elimination of worker injury throughout our
company's operations. This company-wide commitment to Zero Injury is the only logical
and humane approach to a safe workplace. We are not willing to tolerate any injury to
our own workers, or to the worker of any contractor while engaged on our projects. Any
lesser commitment conveys the erroneous message that accidents are inevitable and
that some level of injuries is acceptable. Meeting this challenge will take time, hard work,
and will require a commitment to safety from all team members on this project.
The health and safety of BP Alternative Energy team members, contractors, and the
general public is the most important part of any work we do. BP Alternative Energy, and
particularly the Cape Vincent Project Team, is committed to safely constructing a quality
project on time and within budget.
Every member of this project team has specific safety responsibilities. These
responsibilities begin with the Project Manager and the Superintendent and extend to the
foremen and crew levels.
Specific safety responsibilities of the project manager, superintendent, foremen, workers,

and subcontractors are listed on the following pages.
All team members at the project are expected to be accountable and responsible in their
safety commitment to a Zero Injury workplace.
The BP Alternative Energy Zero Injury Program Training Manual is incorporated by

reference into this plan. A copy of our BP Alternative EnergyZero Injury Program Training
Manual has been distributed to all Project Managers and Superintendents and is
available for review at the jobsite office.
2.2 Project Safety Coordinator

The primary responsibility of the Project Safety Coordinator is to be a resource for the
Project Manager and Superintendent in the safety effort. The primary duties involve
training/education, working directly with crews and individuals every day providing safety
leadership, motivation, guidance and correction, record keeping, reporting, and serving
as a technical resource for supervisory and field personnel.
Responsibilities:
Assist Project Manager in:

• Researching and writing:
- Site Safety Plan
- Crisis Management Plan
- Emergency Response Plan
- Severe Weather Safety Plan
- Other project specific safety plans as required
• Attending the Project Safety Analysis Meeting.
• Establishing a medical provider with the assistance of the Operating Group
Safety Director.

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• Assist in preparing a map of the emergency route from the project site to the
medical provider.
• Procurement of the Project Safety Start-Up Packet.
• Preparation of Safety 3-Week Look Ahead Schedule.
• Review and implement project start-up package.
• Review the safety procedures with each foreman as required.
• Provide training to the craft workers on safe work procedures.
• Help implement the Zero Injury Program.
• Ensure that the Zero Injury Program is kept up to date.
• Use Nine “High-Impact” Zero Injury techniques.
Assist Superintendent with:

• Procuring proper safety equipment.
• Reviewing upcoming safety hazards and planning an appropriate safety
requirement to eliminate and/or mitigate those hazards.
• Instituting site specific Emergency Response Plan.
• Providing New Employee Safety Orientation.
• Conducting accident investigations.
• Providing care for injured employees.
• Help maintain contact with injured employees.
• Coordinate with insurance carrier.
• Itemize restricted duty list(s).
• Providing information to the Foreman for the weekly “Toolbox” Safety
Meetings.
• Attending Dailey Job-wide Safety Meetings.
• Execution of the SSE Management Program.
Obtain and review subcontractors’:

• Health and Safety Manual.
• Job Hazard Analysis for each phase of work.
• Site specific work plan
• Material Safety Data Sheets (MSDS).
• Designated Safety Coordinator.
• 24-hour contact phone numbers.
• Name of First Aid and CPR trained personnel.
• Obtain and review MSDS sheets for all hazardous materials BP Alternative
Energy brings on site.
Other Responsibilities:
• Obtain minutes of subcontractor weekly “Toolbox” Safety Meetings.
• Lead weekly Safety Meeting with subcontractors’ Safety Coordinators, if
applicable.
• Conduct daily audits and notify Superintendent of results.
• Ensure that all daily audits are completed and signed off.
• Attend weekly Subcontractor Coordination Meeting.
• Attend as many Subcontractor “Toolbox” Meetings as possible.
• Work with BP Alternative Energy Claims Manager on any claims.
• Attend and be a part of the industry safety organizations such as OSHA,
AGC, ASSE, etc.
• Improve personal safety education and training skills.

Date 12/5/2007
• Provide the mandatory Zero Injury, OSHA 30-Hour, Mobile Crane Safety,
Safety Pre-Task Planning & Communication, Disruption Avoidance, Accident
Analysis, Top Driver, Forklift Safety and First Aid/CPR training courses.
• Participate as ex officio member of Site Safety Committee.
2.3 Project Manager

The Project Manager has the overall responsibility for the entire job. This includes
establishing a properly functioning project safety program, with the assistance of the
Group Director, Safety & Quality and the BP Alternative Energy Environmental Health
and Safety Services Group.
Pre-construction phase responsibilities:
Identify a medical provider from the options provided by the Group Director, Safety &
Quality.
Establish:
• Site Safety Plan.
• Crisis Management Plan.
• Emergency Response Plan.
• Severe Weather Safety Plan. Environmental plan
• Other project specific safety plans as required.
Ensure that all personnel know their roles and responsibilities in each plan. Periodically
review and update plans as required.
Conduct a project safety analysis meeting, checking plans, specifications, and

construction methods to identify any special hazards in advance. Attendees should
include, but not be limited to Project Manager, Superintendents, Foremen, Project
Engineers, Field Engineers and Group Director, Safety & Quality.
Define and provide any general conditions safety, with technical assistance from
Operating Group and/or Corporate Safety, to include furnish, install, maintenance and
removal of all general conditions safety equipment, i.e. barricades, guardrails, PPE, etc.
This includes all types of contracts including CM and Owners Representative.
Assess and document Subcontractors Safety Performance & Safety Programs including
obtaining worker injury statistics in standard OSHA reporting format.
Demand that subcontractors’ insurance meets contract requirements and contains

additional insured provision.
Arrange and conduct pre-construction subcontractor safety meeting identifying hazards

and verify that subcontractor safety standards meet BP Alternative Energy and OSHA
standards.
Arrange and attend Zero Injury orientation for all subcontractors prior to their start date.
Obtain the following subcontractor’s safety submittals:

• Written copy of “Site Specific Safety Plan” with a written “Hazardous
Communication Program”.
• A copy of all MSDS sheets for each substance used or anticipated to be
used on the project.

Date 12/5/2007
• Name of the designated project safety coordinator.
• Name of the company safety director or individual responsible for company
safety program.
• Emergency contacts and phone numbers
• Name of person(s) First Aid/CPR certified
• A plan for proper disposal of all substances in a manner prescribed by the
Resource Conservation and Recovery Act and/or other applicable laws and
regulations.
Identify Builders Risk exposures.
Construction phase responsibilities:
Arrange for Supervisor safety training. All Supervisors should be aware of their safety
responsibilities and have the authority to carry them out. Periodic review sessions of
these duties shall be held.
Attend the mandatory Zero Injury, OSHA 30-Hour, Mobile Crane Safety, Top Driver,
Safety Pre-Task Planning & Communication, Disruption Avoidance, Accident Analysis,
Forklift Safety and First Aid/CPR training courses.
Review daily pre-task planning outlines.
Provide all safety equipment needed to complete the job.
Ensure that sufficient funds are allotted to the Superintendent to fund necessary
programs.
Ensure that safety is the first topic discussed at all meetings.
Implement a weekly Safety Progress Meeting with all subcontractor and BP Alternative
Energy supervisors. Note: On smaller projects this could be in addition to the
Superintendent’s or Owner’s Meetings.
Participate in the project safety committee.
Issue written subcontractor charge-back forms for cleanup and safety deficiencies.
Issue Non-Contract Compliance forms for safety deficiencies.
Consult with Safety and Legal Departments if subcontractors need to be removed from a
project due to safety issues.
Maintain an understanding of safety by reviewing safety policies, attending meetings and

participating in other company activities designed to promote job safety.
Perform a weekly job walk to determine whether the safety of the projects could be
improved.
Conduct or attend Daily Job-wide safety meetings.
Ensure subcontractors sign waiver and indemnity forms prior to hoisting on borrowed
equipment.

Date 12/5/2007
Establish a Project Safety Committee for the purpose of coordinating project safety
matters. Membership of the project safety committee must include Subcontractors.
Establish and Champion an Incident Review Team. This group will be the initial
response team for all accidents and near misses, and is responsible for the investigation
and reporting on all incidents. Post incident reviews will be conducted and changes
initiated that will eliminate the possibility of reoccurrence. The team leader shall be the
Safety Coordinator.
Maintain log of Subcontractors Worker Injury Safety Statistics.
Perform Pre-Project/Pre-Task planning with Subcontractors for major tasks that require
special safety analysis.
Conduct Pre-construction meetings with Subcontractors to review scope of work and site
safety orientation.
Implement Pre-Employment/Post-Accident Substance Abuse Testing for all BP

Alternative Energy staff.
Insure that Daily Safety Audits, Project Self Assessments and Work Observations are
performed and documented by on site BP Alternative Energy staff. Keep a record of
these audits on site.
** See section 2.A.-10 of the Zero Injury Program Training Manual for further
responsibilities.
2.4 Superintendent
The Superintendent has primary responsibility for implementing the safety program at the
project on a daily basis.

Assist the Project Manager in development of a Site Specific Safety Plan.
Participate in a project safety analysis meeting, planning safety measures before the job
starts.
Identify any special safety hazards in advance by reviewing plans, specifications and
construction methods with technical assistance from the Operating Group Safety
Director.
Assist the Project Manager in establishing an Emergency Response Plan.
Assist Project Manager in defining and providing for general safety conditions.
Assist the Project Manager with Subcontractor pre-construction safety meetings.
Assist the Project Manager in obtaining Subcontractors safety submittals.
Establish first aid and trauma stations.
Obtain first aid training for BP Alternative Energy field supervisors.

Date 12/5/2007
Insure that all required OSHA and Zero Injury information is posted and maintained.
Arrange pre-start-up meeting with each subcontractor.
Sponsor first orientations and conduct second and third orientations for BP Alternative
Energy and subcontractor employees.
Plan, conduct or review the daily pre-task planning outlines.
Implement the nine “High Impact” Zero Injury techniques.
Attend weekly and monthly safety progress meetings.
Implement and champion the daily stretching program at the site. Lead by example.
Hold daily “tool box” safety meetings for all BP Alternative Energy and subcontract
employees.
Ensure subcontractors hold weekly “tool box” meetings. Obtain copies of the minutes.
Implement and enforce compliance to a project housekeeping program. (Refer to section

23.A.-1 of the Zero Injury Program Training Manual).
Enforce BP Alternative Energy employee and subcontractor safety compliance, utilizing

Employee Warning Notices (found in the Project Start-up Packet) when required.
Establish and maintain access routes for vehicle, pedestrian and emergency response
crews.
Make sure that all safety equipment is provided and used correctly.
Immediately report all incidents to BP Alternative Energy management and the Operating
Group Safety Director following the guidelines found in Chapter 4.B of the Zero Injury
Program Training Manual.
Assist in investigating all accidents. If a Safety Coordinator is not on site, the

Superintendent will conduct the investigation.
Investigate and correct all unsafe conditions.
Maintain safety training requirements.
Create a constantly improving safe site environment and culture.
Oversee completion of a daily audit.
Provide for the care of the injured employee. When medical attention is required,
transport injured employee to the medical facility.
Follow Workers’ Compensation Policy.

Date 12/5/2007
Maintain contact with an injured employee.
Attend the mandatory Zero Injury, OSHA 30-Hour, Mobile Crane Safety, Top Driver,
Safety Pre-Task Planning & Communication, Disruption Avoidance, Accident Analysis,
Forklift Safety and First Aid/CPR training courses.
Make provisions for light duty employment.
Evaluate Foremen safety performance.
Obtain MSDS sheets for all hazardous materials brought on site by BP Alternative
Energy, Subcontractors and suppliers, as well as maintain a Haz-Com Program. Make
sure MSDS location is well known by all employees.
Verify that Subcontractors have acquired insurance, as required by contract.
Insure that disposal of all waste generated by BP Alternative Energy is disposed of in

accordance with the BP Alternative Energy Environmental Program.
Complete accident/incident reports.
Assist the Project Manager in a Project Safety Committee. Membership of the Project
Safety Committee must include Subcontractors.
Insure that Subcontractors comply with contractual safety requirements.
Assist the Project Manager in procuring Subcontractor accident reports. Complete the
Weekly Safety Activity Summary and forward copy to Group Safety Director.
Safety Audits, to be performed weekly or more frequently if required by level or type of

activity, shall be kept on site.
Insure Pre-employment/Post Accident Substance Abuse Testing policies are followed.
Ensure execution of the SSE Management Program.
Ensure fair and consistent execution of the Zero Tolerance Policy.
responsibilities.
2.5 Foremen
The foremen have direct control of their crews. This means they also have the most
direct control of the safety program in the field. The importance of the foremen's safety
efforts cannot be overstated.
Conduct work in a safe manner.
Stop work immediately to correct any unsafe condition encountered.

Date 12/5/2007
Take corrective action so that work may proceed in a safe manner.
Be an example to the crew by conducting work in a safe manner.
Attend the mandatory Zero Injury, OSHA 10-Hour, Safety Pre-Task Planning &
Communication, Top Driver, Forklift and First Aid/CPR courses.
Train employees to work effectively by working safely.
Conduct weekly safety meetings to address safety problems with the crews.
Maintain safe work areas that meet company and OSHA Standards.
Report and/or repair unsafe conditions.
Perform a weekly safety audit of the site.
Assist the incident investigation team in conducting accident, injury, and near-miss
investigations and submit reports of findings. Determine cause, not fault.
Assist Superintendent in transporting injured crew members to a medical facility.
Participate in and communicate the Zero Injury Philosophy to crew members.
Complete Pre-Task Planning for each phase of the work. Review with crews and update
as necessary.
Conduct daily pre-task planning sessions each morning with crews to elicit their input and
experience in determining methods and items required.
Act as Mentor in the SSE Management Program.
responsibilities
2.6 Employee’s Safety Responsibilities

BP Alternative Energy is committed to eliminating worker injury at every project
site and every workplace. All employees are empowered as follows:
To conduct all work in a safe manner.
To stop work immediately to correct any unsafe condition encountered.
To take corrective action so that work may proceed in a safe manner.
It is the Company’s goal and expectation that no one will suffer an injury in the
execution of our work.
BP Alternative Energy will make every attempt to insure the continued safety and health
of its employees. In return, employees are required to use good judgment and comply

Date 12/5/2007
with company safety policies. Each person must accept responsibility for their own safety
by working safely and insisting that their co-workers do the same.
Specific duties include:
Arrive at work alert and ready to focus on safely performing their job. The safety of each
worker and those around the worker requires full attention.
Following safety instructions given by Supervisors.
Be on guard for unsafe conditions or activities and take action to correct and report them.
If the problem can not be fixed, report it to the Foreman.
Use good judgment to provide for personal safety and for the safety of co-workers.
Use the required safety equipment.
Comply with all BP Alternative Energy policies and with state and federal OSHA
regulations and good safety practices.
Wear proper clothing for the job. Basic PPE is outlined in detail in Section 4.1.
Attend BP Alternative Energy -required safety training.
Report all injuries / near misses / hazard recognitions to Supervisor immediately after
occurrence.
Understand, support and follow the SSE Management Program.

Date 12/5/2007
3. RESPONSIBILITIES OF SUBCONTRACTORS
3.1 Subcontractor Pre-Mobilization Safety Review
A clear definition of BP Alternative Energy’s expectations from Subcontractors must be
established to effectively coordinate the projects overall safety plan. This section
provides an outline to be discussed with subcontractors prior to site mobilization to
present our commitment to safety as well as review conditions specific to this project.
All subcontractors of every tier are required to adhere to all HSE procedures set forth by
BP Alternative Energy in the Zero Injury Program. In the event subcontractor’s safety
program is judged by BP Alternative Energy to equal or exceed the Zero Injury Program,
subcontractor may be allowed to use their own program.
Present the BP Alternative Energy Zero Injury Safety Policy

Express Management's Safety Commitment
• BP Alternative Energy commitment
• Project Staff’s personal commitment
Project Overview - A brief explanation of the project's:

• Scope
• Construction type
• Schedule
• Maximum number of workers anticipated on site
• Owner
• Final intended use
• Unique or distinguishing features, construction methods, or hazards with your
specific work
• Equipment to be used on site
Project Specific Logistics

• Parking
• Work hours
• Entrances
3.2 Subcontractor Safety Responsibilities

All Subcontractors to BP Alternative Energy must comply with the following activities.

• The following submittals due prior to mobilization:
• Written copy of “Site Specific Safety Plan” with a written “Hazardous
Communication Program” and Emergency Plan - Area Map.
• A copy of all material safety data sheets (MSDS) for each chemical
anticipated to be used on the site and have a copy of it available for
employees.
• Name of the designated project safety coordinator. Certain subcontractors,
identified separate from this plan, will be required to designate a full time
safety coordinator.
• Name of the company safety director.
• Emergency contacts and phone numbers.
• Name of person(s) First Aid/CPR certified

Date 12/5/2007
• A written plan for proper disposal of all chemicals in a manner prescribed by
the Resource Conservation and Recovery Act and/or other applicable laws
and regulations.
• Competent persons in rigging, scaffolding, excavation, confined space, etc.
Designated competent persons must have appropriate documentation.
Attend the pre-construction safety meeting with BP Alternative Energy Project Manager
and Superintendent to review safety hazards specific to this project. Discuss
Subcontractor’s role in Project Safety.

The following submittals are due by 3 p.m. Friday of each week:
• Copies of weekly tool box meetings
• Copies of weekly safety audits performed
• Names of any competent person(s) for any construction act (i.e. scaffold,
trenching, rigging, etc.)
Provide the following submittals as described:

• The Contractor/Subcontractor will submit notice of an Incident or Near Miss
within 2 hours of the occurrence or first becoming aware of the occurrence.
A full report describing the incident or near miss with outcome and corrective
actions will be submitted to BP Alternative Energy within 24 hours of
occurrence or first becoming aware of occurrence.
• Daily Construction Reports describing the number of workers on site and
activities performed. This report shall be submitted at the end of each
workday.
• MSDS sheets at the time of delivery of materials to the site.
• Any and all Crane needs along with the expected associated scope of work.
• Off-Hours or Weekend Work Permit 48 hours prior to date of activities.
Comply with:
• Applicable local, state, and federal safety standards
• Safety requirements specific to project
• Owner’s project safety requirements
Actively participate in project Zero Injury safety program and attend required safety
meetings and training sessions.
Maintain first aid kits or facilities on site as required by local, state, and federal OSHA
regulations.
Maintain and replace safety protection systems damaged or removed by their operations.
Install contractually required general condition safety for Subcontractor’s portion of the
work. (i.e., handrail, fence, fall protection systems, floor opening covers, etc.)
Conduct weekly employee safety toolbox meetings and copy BP Alternative Energy
jobsite office.
Participate in BP Alternative Energy’s safety talks and daily stretch and bend.
Conduct new employee orientations and assure that new employees receive BP
Alternative Energy’s site orientation.

Date 12/5/2007
Meet each and every element of the SSE management Program.
Subcontractors and their employees are subject to the Zero Tolerance Policy found in
Section 10 of this Plan.
Provide required personal protective equipment (PPE) to subcontractor’s employees.
3.3 Subcontractors Emergency Plan - Area Map
I have read and fully understand the Subcontractors Safety Responsibilities. I

recognize my responsibility to comply with these rules in addition to all other
safety regulations enforced at the project. Unless otherwise noted, the second
written notice of violation with this agreement will result in a three-day layoff. The
third written notice of violation of this agreement will result in the individual being
permanently removed from the project site. The severity of the violation will result
in discipline increasing in severity.
COMPANY: _______________________________________
TRADE: _______________________________________
BY: _______________________________________
DATE: ________________________________________

Date 12/5/2007
3.4 Subcontractor’s Safety Questionnaire
Name of Subcontractor: ___________________________________________________

Type of Work: ___________________________________ Date: __________________
Current BP Alternative Energy Projects:_______________________________________
1. List key personnel. Please list safety responsible person and his/her experience:
President ___________________________________________________________
Vice President/Operations Manager_______________________________________
Project Manager ______________________________________________________
Safety Coordinator ____________________________________________________
2. Do you have a written Safety Program? Yes___ No___

3. Do you provide site specific safety plans? Yes___ No___
4. Who is responsible for executing the site specific safety plans?_________________
5. Do you have a Drug/Alcohol Screening Program? Yes___ No___
6. Do you conduct pre-employment drug/alcohol screening? Yes___ No___
7. Do you conduct written safety inspections? Yes___ No___
8. Do you have an orientation program for new hires and a
reorientation program? Yes___ No___
9. Do you have a training program for newly hired or
promoted foremen? Yes___ No___
10. Have your foremen had OSHA 10-Hour or OSHA 30-Hour training
in the past 3-5 years? Yes___ No___
11. Do you hold craft “toolbox” safety meetings? Yes___ No___
12. Are craft level employees empowered to stop unsafe acts or work? Yes___ No___
If not, explain why ______________________________________
13. Do you have a Crane Management Program? Yes___ No___
14. Do you have a Hazard Communication Program? Yes___ No___
15. Do you retain the services of an outside safety consultant? Yes___ No___
16. Have you ever been involved on a project that partnered
with OSHA Consultation? Yes___ No___
17. Do you perform incident analyses/accident investigation? Yes___ No___
What level of management reviews it? ___________ __________
18. Will you pre-qualify your subcontractors and provide
documentation to Mortenson? Yes___ No___
19. Do you support and understand a “near miss” reporting system? Yes___ No___
20. Do you have a Short Service Employee (SSE) Program? Yes___ No___

Date 12/5/2007
21. List your firm’s workers’ compensation Interstate Experience Modification Rate
(EMR) for the past three (3) years.
200__ EMR ________ 200__ EMR ________ 200__ EMR ________
List your firm’s Total Recordable Incident Rate (TRIR) for the current and past three
years.
200__ ________ 200__ ________ 200__ ________ 200__ ________
List your firm’s Days Away, Restricted Duty, or Transfer Case Incident Rate (DART)
for current and past three years:
200__ ________ 200__ ________ 200__ ________ 200__ ________
List your firm’s Lost Day Incident Rate (LDI) for the current and past three years (lost
time).
200__ ________ 200__ ________ 200__ ________ 200__ ________
Please use your last year’s OSHA No.300 log to fill in:
A. Number of OSHA recordable accidents ______________
B. Number of lost workday cases ______________
C. Number of restricted workday only cases ______________
Employee hours worked in the field last year ______________

Number of fatalities in your company over the last ten years. ______________
Comments:
_______________________________________________________________________
_______________________________________________________________________
_______________________________________________________________________
List any OSHA citations received in the past three years.

Standard Cited Fines Paid Classification
1) ________________________________________________________________
2) ________________________________________________________________
3) ________________________________________________________________
This information is confidential and only used to determine the value of safety in your
company.
________________________________________
Signature and Date

Date 12/5/2007
3.5 Subcontractor Safety Hazard Notification
Project Name: _______________________________
Address: ___________________________________
Phone # ____________________________________
TO SUBCONTRACTOR:_________________________ Date:_____________________
Supervisor____________________________________ Project____________________
Main Office Address_____________________________ Phone____________________
IN REGARDS TO:
CONTRACTOR________________________________ Phone____________________
Supervisor______________________________________________________________
Main Office Address ______________________________________________________
The following unsafe actions or conditions are noted _____________________________

______________________________________________________________________
______________________________________________________________________
SUBCONTRACTOR BPAE COMPANY

Received by:_________________________ By:_____________________________
Title:________________________________ Title:____________________________
Date:________________________________ Date:____________________________
Corrective action is to be taken immediately. Note below the action taken and return to BP
Alternative Energy.
______________________________________________________________________
______________________________________________________________________
______________________________________________________________________
Signed_______________________________ Date____________________________
The report of the above item is not intended to indicate that other unsafe conditions do not exist nor is it
intended to imply that other violations and/or hazards not observed or reported there on are safe and under
control at the time of this survey. THIS DOES NOT in any way relieve you of your complete responsibility for
safety compliance with safety standards.

Date 12/5/2007
4. ORIENTATION / TRAINING
HSSE Orientation
All personnel will be required to complete the First Day First Hour Orientation before
gaining admittance and conducting work. The First Day First Hour Orientation should
include a review of the facility layout that includes the location of life saving and
emergency equipment and everyone’s responsibilities in an emergency. Additionally it is
intended to increase HSSE awareness by: communicating expectations, providing
information, increasing hazard awareness, elaborating on hazard mitigations,
empowering all personnel to “Stop the Job” and sharing lessons learned. This
requirement will allow for the opportunity to identify and account for all personnel,
including Short Service Employees (SSE) that will be conducting work on the location.
The HSSE Orientation will include at a minimum:
Individual actions to be taken in an emergency

Incident notification
The site emergency response organization
Muster locations and evacuation routes
These HSSE general safety rules
This HSSE drug, alcohol and weapons policy
SSE-Short Service Employees
Control of work process Simultaneous Operations (SIMOPS) Permit to Work (PTW)
Confined Space Entry (CSE) Lock Out Tag Out (LOTO) Job Hazard Analysis (JHA)
Emergency alarms/communications in the event of an emergency
Elements of BP’s Golden Rules of Safety
Applicable BP Safety Immersions
HSSE Training
Specific HSSE training will be required for specific positions within the Project team,
based on the individual’s job description, roles and responsibilities and level of oversight
of Contractors and/or Subcontractors. The training may include any of the following:
Safety Immersions
Advanced Safety Auditing
HSSE Observation Cards
Confined Space Entrant/Attendant
Confined Space Supervisor
Confined Space Competent Person
PTW Overview
PTW Performing Authority
PTW Issuing Authority
PTW Approving Authority
LO/TO Overview
LO/TO Performing Authority
LO/TO Issuing Authority
LO/TO Approving Authority
Environmental Management System
Incident Investigation
Field Industrial Hygiene Monitoring
And various industry or OSHA approved safety courses

Date 12/5/2007
4.1 Orientation #1
1. Zero Injury Safety Program
BP Alternative Energy is committed to constructing this project under safe working

conditions and doing so without any accidents. In order to assure meeting this objective,
ALL employees are required to actively participate in our program. The 9 High Impact
Techniques to our “Zero Injuries” Program are: (a) Pre-plan safety into all work; (b)
Provide orientation and training; (c) Perform thorough accident investigations; (d) Strictly
enforce our substance abuse program; and (e) Recognize and reward safe behavior
through the use of incentives; (f) Near miss reporting; (g) Project Safety leadership Team
– Site Safety Committee; (h) Daily stretching project wide – including subcontractors; (i)
Job Hazard Analysis process in use. Drugs and alcohol are strictly PROHIBITED. If you
are aware of these items on the job-site or of someone under the influence, please
protect yourself and others by reporting them. Prescription drugs should be reported to
your supervisor so that he is aware you are using them.
Weekly safety meetings will be held on site and each employee is encouraged to offer his
or her suggestions on running a safer project, as well as pointing out any
possibility/potential safety problems he or she may have noticed in the past week.
Each employee is expected to immediately take care of any safety problems that he or
she can. If unable to take care of it themselves, employees must contact their supervisor
immediately to get the appropriate help to do so. Non-compliance with safety regulations
is grounds for immediate dismissal!
If we all work together, we can and will work accident free.
2. “Zero Injuries”
Review Zero Injury policy.
3. Safety & Personal Protective Equipment (PPE)
All personnel (including visitors) will adhere to these HSSE requirements while working
on this project. This requires (at a minimum) that all Contractors and Subcontractors
provide the following items of PPE for their own use:
ANSI Z89 Hard hat with company logo front center and name immediately below.
ANSI Z 87.1 Approved Safety glasses with side shields.

Note: The use of contact lenses is discouraged in work situations where personnel are
exposed to dust, chemicals or spray operations where particles may enter eyes. Contact
lenses are prohibited to be worn with respirators. If medical reasons require use of
contact lenses, special attention should be paid to additional eye protection and
supervisor approval must be given.
ANSI Z41 Approved Safety boots; all Safety Boots must have a minimum 4” ‘upper’
that is constructed of either leather or rubber that extends above the ankle—no
synthetic materials such as nylon or rayon are permitted. Boots must have a sole
that is constructed from a slip resistant material with a “defined heel”; wedge soles
are not permitted. Soles must have enough tread to minimize the potential for slips
(under normal conditions) through maintaining sufficient friction (ANSI Z41 terms this,

Date 12/5/2007
“coefficient of friction”) . All safety boots will be “steel toed” and the steel toe or cap,
as it is commonly referred to, must be completely contained beneath the leather or
rubber ‘lower’. Tears or holes in the material or sole are not permitted. If a tear or
hole appears, the boot must be repaired or replaced before the worker reports for
duty on his/her next shift. Half-measure or makeshift repairs such as the wrapping
the hole or tear with tape are not permitted.
Suitable work clothing for the environmental/meteorological conditions. Clothing
must fit closely to the wearer’s body. Shirts must have a 4 inch minimum sleeve .
When long-sleeved clothing is worn it must be buttoned or zippered to minimize the
chances of it becoming caught on objects or inside moving equipment. Whenever
slickers, coveralls or insulated clothing is worn, the legs must be buttoned or zipped
and (if so equipped) the shoulder straps must be over the shoulders with the snap or
button properly secured. Pants must be full length (no shorts).
Hearing protection with a minimum HRR of 21 shall be worn in all areas of high
noise.
Protective gloves; Gloves must be “built for purpose”, e.g. Nitrile for handling
chemicals, leather gloves when working with materials such as metal or steel, etc.
These must be free of holes, tears or other defects that would defeat or minimize the
gloves effectiveness in offering the hand and finger protection for which it was
designed.
ANSI Class 2 Level 2 high visibility vest or shirt when working outside the office.
All personnel are expected to maintain and properly utilize their personnel protective
equipment. Subcontractors will be responsible for the proper issuance, maintenance,
training and utilization of personal protective equipment and other specialty safety
equipment for their employees. Subcontractor shall submit monthly, updated training
logs for all site employees. Site management will assure through daily assessments that
all employees on Cape Vincent have the proper safety equipment available. BP
Alternative Energy Employees will be issued certain items for their protection. These
items will be replaced at no cost if the initial item is turned in.
Replacement of lost items will be paid for by the employee at cost. Abuse and
mishandling of these items could result in termination. These items consist of, but are not
limited to, rubber boots, hard hats, ear plugs, safety glasses, dust masks, face
shields, safety belts, safety vests, etc.
4. Special Safety
Training for any special safety equipment will be provided to BP Alternative Energy
employees by BP Alternative Energy, if required. Training for subcontractor employees
will be provided by subcontractor. Make sure you are physically capable of using such
equipment. If you feel that you are not properly trained it is your duty to notify your
supervisor. Also, explain any special safety concerns you may need to know about (i.e.
gas exposure, special fire procedures, emergency evacuation, etc.)
5. Right to Know Training
Please review the “Right-to-Know” regulations. HAZCOM information is found in Section

5.2 of this Plan. The MSDS sheets are kept at the BP Alternative Energy project office or
Hazard Communication location.

Date 12/5/2007
6. Programs/Statements
Please review the following programs and statements:

• FALL PROTECTION
• EMERGENCY RESPONSE PLAN
• EMPLOYEE SAFETY RESPONSIBILITIES
• HARASSMENT FREE WORKPLACE POLICY
• POLICY STATEMENT (EEO)
• EMPLOYEE ASSISTANCE PROGRAM (Lifeworks)
7. Start and Quit Times and Fatigue Program
Normal work hours are: 7:00 a.m. to 5:30 p.m. At approximately 10 minutes before
quitting time, all tools and materials should be picked up and put in their proper places.
Lunch is from 12:00 to 12:30. Work hours are subject to change at any time.
To identify and manage fatigue and its potential to impact on worker and work place
safety, BP Alternative Energy has implemented the following steps:
th
• Whenever work occurs for 6 continuous full days, the 7 day will be a day of rest
• Workers will be sent home by supervision when their work is complete not when all
others work is complete
• Management, safety professionals, superintendents and foremen will monitor the
status of crews during the course of the day looking for signs of fatigue and when it is
found act appropriately
• Superintendents will monitor hot and cold temperatures and provide relief as is
appropriate for the condition
• Weather forecasting services will be employed to assist in decision making for work
for the following day. Whenever possible the decision to not work will be made at the
end of the work day prior rather than the morning of the day not worked
• Management, safety professionals, superintendents and foremen will observe crews
and rotate task assignments as is appropriate
• Management and safety professionals will ensure and facilitate openness between
craft and supervision to allow for sound decision making when craft practice
empowerment related to fatigue
8. Absent/Tardy
BP Alternative Energy Employees: Absences and tardiness are not permitted. However,
in the case of one or the other a call is required, preferably by the employee personally.
Excessiveness of one or the other will result in the issuance of a Warning Slip and/or
termination. In all cases, the employee should call in. The telephone number is
[XXX.XXX.XXXX]
Excused absences and tardiness should be discussed and cleared with your immediate
supervisor, at least 24 hours in advance whenever possible, for scheduling purposes.
When an employee has missed work for two (2) consecutive days, without contacting his
supervisor, it will be considered a voluntary termination.
9. Telephone Messages

Date 12/5/2007
No personal telephone calls except for emergencies. Emergency calls will be handled
appropriately.
10. Your Personal Tools
Your foreman or supervisor will provide you with a list of tools required to perform the
work expected of you. You should have a means of carrying these tools with you at all
times.
11. Fighting
Fighting is strictly prohibited and an immediate termination will result from it. Also, any
employee acting in a manner that seriously jeopardizes the safety of themselves or
another employee, will be subject to immediate dismissal.
12. Insubordination
All personnel shall respect the rank of Subcontractor, Foreman, and Supervisors as well
as his co-workers and other supervisors within the company.
13. Written Ticket Violations
As part of our program to insure a safe working area for each employee, we have
instituted a written “Violation/Warning Notice” system. All management personnel,
including foreman, are authorized to issue these warning notices. Please note that any
infraction is cause for immediate dismissal. Reference the Zero Tolerance Policy in
Section 10 of this Plan.
Disciplinary action for violation of safety or other project rules not found in the Zero
Tolerance Policy:
• 1st Offense: Written warning
• 2nd Offense: Written warning and 3 day lay-off
• 3rd Offense: Permanent dismissal
• Zero tolerance for environmental or archeological violations. This may result in

immediate termination.
** Life threatening violations may result in immediate termination.
14. Machinery and Equipment
Repairs should be made by authorized personnel only. No temporary repairs will be

tolerated. This includes small and large equipment. Starting and operating procedures
are different for all equipment. Check with your supervisor for instructions. Do not operate
any machinery, equipment or power tools unless you have had instructions/training and
are qualified.
15. Accidents
ALL injuries, no matter how small, must be reported to your supervisor for
documentation purposes. They must also be noted on your time card. All near misses

Date 12/5/2007
are likewise to be reported and fixed immediately. BP Alternative Energy employees must
also report near misses and injuries on your time card.
All accidents will be immediately investigated by a team of management personnel. This

will be done to ascertain the “root” cause of the accident so that similar incidents can be
prevented from happening in the future.
16. First Aid
First Aid Kits are available at the BP Alternative Energy construction trailer and in all BP
Alternative Energy site trucks. Other first aid kits are available at various locations on the
project. Check with your supervisor for the locations nearest you. The site safety
professional will prepare and publish a listing of all persons on the project that hold
current certification(s) for CPR / First Aid / Blood Born Pathogen Safety / AED use as well
as primary and secondary response assignments and contact means.
17. Payday
For your protection, employees must pick up their own paychecks. If unable to do so,
employees may designate someone else to pick it up for them provided the employee
has signed a note requesting that another named party be given their paycheck.
18. Check List
BP Alternative Energy employees must double check to make sure that you have
completed the following forms:
o New Employee Form (BP Alternative Energy)
o W-4 Form (IRS Withholding)
o I -9 Form (Eligibility Verification)
o Zero Injury Booklet Form
o Insurance Enrollment
19. Zero Tolerance Policy
BP Alternative Energy and subcontractor employees of every tier are subject to the Zero
Tolerance Policy. This policy is reviewed in the First Day First Hour orientation. Each
employee must indicate their understanding and acceptance of this policy by signing the
Zero Tolerance Policy form. Employees may keep a photo copy of the form.
20. Short Service (SSE) Policy
BP Alternative Energy and subcontractor employees of every tier are subject to the SSE
Policy (see section 1.3). This policy is reviewed in this orientation.
21. Special Driving Standard
In addition to driver training under the BP Alternative Energy “Top Driver” program and
the provisions of the Zero Tolerance Program, the following standards are established:
• Use of cell phones while any vehicle is in operation is prohibited. Vehicles must be
placed in park before cell phone use is permitted.
• Use of radios while any vehicle with the exception of cranes is in operation is
prohibited. Vehicles must be placed in park before radio use is permitted.

Date 12/5/2007
4.2 Orientation #2
General
1. Hold 14 days after employee starts work.

2. Maximum 10 employees in a meeting. Schedule multiple sessions if necessary.
3. Chaired by key management personnel. Doesn’t need to be employee’s direct
supervisor.
4. Have signature sheet signed by all attending session. Keep on file to make sure
everyone gets orientation/training.
5. Three-week rotating schedule of attendees and trainer to be posted in conference
room at all times. If no employee is due for training on a specific day, session will be
cancelled and so noted on the schedule.
Topics:
A. Responsibility
Ask employee “who is responsible for safety?” Emphasize that everyone is
responsible for safety.
B. BP Alternative Energy Concern

Elaborate on Zero Injury Safety Program, emphasizing that BP Alternative
Energy is very concerned about the personal well being of each and every
employee.
C. Employee Empowerment
Explain again that every employee is empowered to stop working if someone or
something around him or her is unsafe. Each employee is required to
immediately fix any unsafe condition they can and to notify a supervisor to fix
things they can’t. If an employee sees another employee doing something in an
unsafe manner, he must express his/her concern to the other employee (keep
comments positive and constructive - avoid criticizing in a negative or demeaning
manner.)
D. Safety Culture
Explain that safe people develop a mind set that when combined with other
people of the same mindset produces a safety culture THAT WORKS!
Employees not willing to adopt the necessary safety mind set will be terminated.

Date 12/5/2007
E. Accidents
Explain that accidents are simply not acceptable. Employees don’t want to get
hurt and BP Alternative Energy doesn’t want employees to get hurt. No one
wants to go home with an injury. The pain can be magnified by repercussions on
the family. No one from BP Alternative Energy wants to tell family members of
any employee that he/she has been hurt. Explain again that all accidents or near
miss incidents must be reported immediately. (A near miss incident is defined as
any incident where a person could have been injured.) All such accidents or
incidents will immediately be investigated by a team of top management
personnel (Project Manager, Superintendent, etc.) The team will try to ascertain
the root cause(s) of the incident/accident to prevent reoccurrence. (The root
causes will likely surprise many people - accidents don’t just happen.) The
results of the investigation will be reported to the project at the job-wide safety
meeting, if not before. This meeting will be documented and kept on record with
the project’s safety files.
2. Pre-Task Planning
Explain the importance of pre-task planning from both a safety and a productivity
stand point. Emphasize the importance of the five-minute meetings each
morning with their foreman to discuss the work planned for the day. Planning
safety into every activity is crucial (if hiring a foreman, emphasize that he/she
must take the lead in this area and that this is his/her duty).
3. Safety Training
Train/explain the safe way to handle many of the following common concerns:
A. 100% Fall Protection

B. Eye Protection
C. Be alert around cranes and earth moving equipment
D. Specialized tools (Hytorc, impact wrenches, etc.)
E. Ladders
F. Torches
G. Air Hoses (whip checks)
H. Extension cords/GFCI’s
I. Power Tools (proper use of cords, guards)
J. Rebar Protection
K. Housekeeping
L. Special Safety Equipment (care and use)
M. HazCom/Right to Know/MSDS
N. Trench Excavations
O. Proper Lifting Techniques
4. Review
Briefly review each of the topics in the New Hire/Subcontractor
Orientation/Training #1 session and ask the employee if he/she has any
questions. Close on a positive note, saying “we don’t want anyone hurt on this
project and we want employees to enjoy their work with us as much as possible.”

Date 12/5/2007
4.3 Orientation #3
General
1. Hold 14 days after orientation session #2

2. Maximum 6 employees in a meeting. Schedule multiple sessions if necessary.
3. Chaired by project management / supervisory personnel, does not need to be
employees direct supervisor.
4. Use sign-in sheet and keep on file.
5. Three-week rotating schedule of attendees and trainer to be posted in conference
room at all times. If no employee is due for training on a specific day, session will be
cancelled and so noted on the schedule.
Topics
A. Motivation
Explaining that the biggest motivator for the Zero Injury program is the
humanitarian concern we should all have for each other. NO ONE WANTS TO
GET HURT OR TO SEE OTHERS GET HURT. If we look out for each other we
CAN work with no injuries.
B. Responsibility
Explain again that each employee is responsible for assuring that he/she works
in a safe manner. Each is also responsible to notify someone else of their
concerns when they feel someone else is working unsafe. Remind them again
that they are empowered to stop work if any conditions are unsafe and that they
are RESPONSIBLE to fix any unsafe conditions they can, and to notify a
supervisor to fix any unsafe conditions they can’t.
C. Incentives
Go through incentive program thoroughly with employees.
4. Review
Briefly review New Hire Orientation/Training Session #2 and ask if there are any
questions. Make sure everyone understands completely.
5. Employee Feedback
A. Leadership
Ask employees how well they feel their crew is following our ZERO INJURY
PROGRAM. Is pre-planning being done by the crew each morning? Are
employees comfortable with this program?
B. Open Discussion
Is there anything anyone wants to add? Suggestions? Thoughts? Ideas? Or
just questions about ANYTHING?

Date 12/5/2007
4.4 Landowner Orientation
BP Alternative Energy’s commitment to Zero Injuries starts the first day, first hour any
employee, vendor, customer, owner, landowner, et al, joins the project. One of the keys
to obtaining a Zero Injury jobsite is the orientation process. This is a requirement of
anyone wishing to be on site at any time during the duration of the project. All owner’s
personnel / landowners will be asked to attend an orientation session that will lay out the
jobsite safety requirements, rules of safe activity, list of hazards, and Hazard
Communication requirements (MSDS) prior to entering areas of construction.
BP Alternative Energy will supply all landowners with a hard hat, safety glasses, and high
visibility vest to be worn while outside their vehicles while on the project upon completion
of the required orientation. It is the customer / owner’s responsibility to enforce the site
safety requirements on landowners.
Prior to anyone wishing to drive out to, visit, deliver any materials, etc. it is a requirement
that the individual(s) stop in at the BP Alternative Energy trailer and check in. If any
owner / landowner wish to bring a visitor on site, it is also a requirement that they check
in at the BP Alternative Energy trailer and that visitor receive their orientation as well.
4.5 New Employee/Subcontractor Orientation Log

1 2 3 Other (Circle One)
PRINT NAME SIGNATURE COMPANY DATE

Date 12/5/2007
5. SAFE WORK PROGRAMS
5. 1 Substance Abuse Policy (Non-DOT)

BP Wind Energy North America Inc. (Company) has a strong commitment to provide a
safe work place for its employees and other persons working or visiting on its premises.
In order to assist in maintaining a safe working environment and to protect Company
property, this policy concerning substance abuse (“Substance Abuse Policy”) is
established.
Contractors, subcontractors, and vendors who perform labor or services on Company

premises and projects , hereinafter referred to as “Contractors”, shall have and
administer a formal substance abuse interdiction policy.
The failure of a Contractor to comply with the provisions of this policy may constitute
cause for cancellation of its contract.
ARTICLE I – POLICY STATEMENT
a) The use, possession, concealment, transportation, promotion, manufacture,

distribution, or sale of the following Prohibited Substances is strictly prohibited on
Company premises and projects, including all property owned, operated, leased
by, or under the control of Company.
b) No Contractors shall report to work, be on the job, or be on Company premises
under the influence of Prohibited Substances.
c) No Contractors shall test positive for the presence of Prohibited Substances in
amounts exceeding the cut-off levels adapted by the Company, as identified in
this Substance Abuse Policy or a Service Order.
d) No Contractors shall refuse to undergo a Prohibited Substance test required by
this policy.
e) “Prohibited Substances” are defined as: (a) any alcoholic beverage, the use of
which is not authorized by the Company, (b) any substance that an individual
may not manufacture, dispense, sell, possess, use, or distribute under the laws
of the state in which the individual is employed or is working, and (c) any other
Intoxicating Substance. “Intoxicating Substance” means a drug(s) or alcohol or
any substance in which its use impairs work behavior or performance in a
manner determined by the Company to be unsafe. Drug paraphernalia and
similar items used for substance abuse are likewise prohibited from Company
premises and projects.
f) The Company reserves the right to report known illegal activity to law enforcement
authorities.
Contractors will submit a copy of their policy and program to the Company employee
designated to administer contracts or to a party as otherwise designated by Company.
Such policy must provide for substance testing of employees and must meet the
minimum standards as set forth in Article II below. Company reserves the right to deny
entry to Company premises and projects of any Contractor who fails to present a written
policy that meets the standards of this Substance Abuse Policy, or who fails to administer
an acceptable policy.
A violation of this Substance Abuse Policy will subject a Contractor's employee to denial
of entry to Company premises and projects. Reinstatement of the access privilege may

Date 12/5/2007
be made after one year upon request of the employing contractor. Such requests will be
evaluated on the merits of each case. A request will be granted only upon receipt of
evidence that the employee has successfully passed a substance screen within thirty (30)
days of the request and has successfully completed an assessment by a Substance
Abuse Professional ("SAP") and has complied with all recommended treatment or
rehabilitation prescribed by the SAP.
ARTICLE II – TESTING
A. DEFINITIONS
For the purpose of this policy:
1. "Substance testing" means the analysis of urine, saliva, or breath;
however, at times circumstances may warrant additional testing methods.
2. "Chain of custody" means the combination of procedures and

documentation which provides a faithful and accurate written record of the
custody of a biological specimen from time of initial collection of a
specimen to final laboratory analysis.
3. "Negative test result" means a laboratory conclusion that the presence of a

substance was not detected in a specimen at or above the screening and
confirmation levels utilized.
4. "Screened positive result" means that an EMIT analysis has revealed one
or more substances present at or above screening cut-off level.
5. "Positive result" means a laboratory conclusion that a specimen was found

to contain the presence of a substance based on one or more analytical
procedures which did include gas chromatography/mass spectrometry
(GC/MS), as reviewed and confirmed when necessary by qualified
laboratory or medical personnel.
B. LABORATORY AND SAMPLING STANDARDS

1. Testing for the following substances, at the indicated screening and
confirmation cutoffs, are recommended:
GC/MS
Drug EMIT Screen Confirmation Levels
Amphetamines 1000 ng 500 ng
Cannabinoids 50 ng 15 ng
Cocaine 300 ng 150 ng
Metabolites
Opiates 2000 ng 2000 ng
Phencyclidine 25 ng 25 ng
Alcohol .02 BAC .02 BAC
Contractors subject to DOT testing shall abide by appropriate levels.

Date 12/5/2007
2. Specimens will be tested using an enzyme immunoassay (such as EMIT)
and/or a radioimmunoassay (approved on-site testing is permissible). In
this testing scheme, a positive finding is called a screened positive. All
screened positives will be further tested using GC/MS.
3. Alcohol screening testing may include utilization of either breath or saliva

testing.
C. CONFIDENTIALITY
When Contractors conduct drug testing of Contractor’s employees for the
purpose of establishing eligibility to enter Company premises or projects, such
substance testing results which are positive will not be individually disclosed to
Company. Contractor shall certify that each employee assigned to work on
Company premises has passed a substance test that meets the standards of
this Substance Abuse Policy.
D. TESTING
1. Contractor shall conduct substance testing in these situations:
a. upon hire of each new employee.
b. upon reasonable suspicion by the Contractor or Company that a

Contractor’s employee on Company premises is under the influence of or
has consumed any substance or item prohibited by this Substance Abuse
Policy or a Service Order.
c. when designated by Company management, immediately following any

incident which results in a recordable bodily injury as defined by OSHA, or
damage to Company or Contractor-owned property. Additionally, any
substance testing, following an incident requiring DOT substance testing
as regulated and described by DOT (FHA, RSPA, and USCG), shall be
strictly adhered to. (Note: Substance testing may also be required of the
Contractor by Company following a near-miss incident. A near-miss
incident is any incident which, if it had proceeded to a reasonably possible
and more serious level of development, would have had the potential for
personnel injuries, property damage, or serious liability claims).
d. either random or annual testing.
2. Contractor shall assume all costs associated with testing.
3. The refusal of Contractor's employee to sign a consent form or submit to

any testing will result in revocation of the person's access privileges.
4. Contractor shall, whenever possible, provide Company with reports

summarizing substance test results for a project. Contractor shall not
include any information in such reports that would enable the identification
or association of specific test results to individual persons, and shall not
provide such reports when the number or timing of the test results would
enable the identification or association of specific test results to individual
persons.

Date 12/5/2007
E. EXCEPTIONS (The following is verbatim from the MSA)
The following exceptions may be granted at the discretion of Company
management:
1. Contractors hired on short notice may be permitted to begin Work on-site

pending receipt of the results of pre-access substance testing. This
permission shall not extend beyond seven (7) calendar days from the first
date after Work starts by Contractor.
Any person working under this provision shall be removed from the work
site immediately upon receipt of a positive test result, or at the end of
seven (7) calendar days if test results have not been reported.
This provision is to allow Work to begin on emergency or short notice

situations only. Testing shall be done as soon as reasonably feasible, and
results shall be available within the seven (7) calendar days allotted. This
provision covers only Contractor’s employees needed for initial staffing and
does not extend to those hired with sufficient time for pre-access testing (2-
3 days after job begins).
2. Contractors or vendors whose need for site access poses a minimal safety
risk may be exempted from the requirements of this Substance Abuse
Policy by agreement of Contractor and authorized Company management
or pursuant to the terms of a Service Order.
3. A person who is regulated by DOT and satisfies DOT substance testing

requirements shall be deemed to be in compliance with this Substance
Abuse Policy.
F. VALIDITY PERIOD
Company will recognize a substance test conducted of a Contractor’s employee
while that employee worked for a different employer provided that (1) the test is
conducted within the 90-day period required by this policy, and (2) the
laboratory and sampling procedures meet the standards set forth in this policy.
Company requires that the testing requirements be verified by an independent
agency, such as the Contractor's Safety Council.
ARTICLE III – SEARCHES AND INSPECTIONS

Company reserves the right at all times on its premises and projects to conduct
unannounced substance screens, searches, and inspections of Contractor’s employees,
vendors, and other persons, including their effects, lockers, baggage, desks, tool boxes,
clothing, and vehicles. The purpose of such screens, searches, and inspections is to
ensure compliance with this policy. This unannounced search and inspection policy shall
be posted on the premises or projects.
Any controlled substances or items prohibited by this policy, or any materials that are
illegal to possess, discovered by Company on its premises or projects will be retained by
Company and turned over to the appropriate law enforcement agency.
The refusal of Contractor's employee to submit to a search or inspection will result in the
revocation of the person's access privileges.

Date 12/5/2007
ARTICLE IV – COMPLIANCE AUDITS
Company reserves the right to periodically audit Contractor's records to verify compliance
with this policy. Such verification shall include, but not be limited to:
1. examination of the Contractor's substance abuse policy and its implementing

directives and procedures;
2. a determination that substance testing is being conducted in those situations

which require it and that the testing meets the standards of this policy;
3. examination of chain of custody procedures which ensure integrity of collected

specimens; or
4. evaluation of laboratory services.
Such audit shall not include access to or review of individual test results. Any inadvertent
disclosure of individual test results will be treated as confidential so as to protect the
privacy of tested persons.
ARTICLE V – SUBCONTRACTS
In all cases where Contractor is permitted to employ a subcontractor, the Contractor shall
ensure that the subcontractor and subcontractor's employees are in compliance with this
Substance Abuse Policy. Contractor’s subcontracts shall stipulate that Company
reserves the right to audit subcontractor's substance programs.
ARTICLE VI – NOTICE
Contractor shall ensure that each of Contractor’s employees and subcontractor
employees is informed of the provisions of this policy and of the Contractor's substance
abuse policy. Notice shall include the consequences of failure to comply, and notice shall
be made prior to entering Company premises.
ARTICLE VII – CONCLUSION

Consideration for Work on Company premises will be conditioned upon Contractor's
implementation of a policy that conforms to the minimum standards expressed in this
Substance Abuse Policy. Contractor shall develop and implement such a program.
The central goal of this policy is to provide a safe and efficient working environment for all
persons on Company premises. Cooperation is vitally important to the achievement of
this important goal.

Date 12/5/2007
5.2 Hazard Communication/Right to Know
It is the policy of BP Alternative Energy to comply with the standards set forth by the
Occupational Safety and Health Administration, the United States Department of Labor,
as well as those set forth by any other state or local governing authority.
State and Federal OSHA Regulations require all employers to notify their employees of
any hazards to which they might be exposed and to provide protection from them. Types
of hazards covered by BP Alternative Energy’s policy are chemicals, noise, radiation,
vibration, and extremes in temperature and biological hazards. This Right-to-Know
Manual, that contains Material Safety Data Sheets (MSDS) pertinent to the hazardous
materials on the Cape Vincent project, will be located in the BP Alternative Energy Office
Trailer.
Each employee on the Cape Vincent project will be briefed on their rights regarding the
Right-to-Know Laws including but not limited to:
1. Hazard Communication Program content
2. Labels and other forms of warning
3. Material Safety Data Sheets
4. Employee information and training
Employee rights:
1. Each employee has the unconditional right to know about any hazards to which
they might be exposed.
2. The right to refuse work if an imminent hazard is perceived to exist or if proper
training and equipment have not been provided.
3. The right to access any information on hazards on the site.
Employees who are expected to be exposed to specific substances on the Cape Vincent
project shall additionally:
1. Be trained in safe work practice specific to the hazard.
2. Review the MSDS Sheet specific to the substance.
3. Be made aware of specific health consequences associated with hazard.
4. Be issued all required safety equipment & demonstrate proficiency in use.
All BP Alternative Energy employees at the project will receive Right-to-Know training, to
be documented by signing the exhibit 5.4 Hazard Communication Training Log.
Additional training will be conducted at weekly “toolbox talks” and when work operations
or material deliveries warrant it.
The Superintendent is in charge of maintaining the Right-to-Know Manual. All

subcontractors must provide training to their employees and maintain a current MSDS file
on the job site for their employees, as well as submit copies to BP Alternative Energy for
coordination.
Hazardous non-routine tasks will be addressed prior to work being started. Specific
hazards, protective measures, and any special equipment needed for the job will be
covered. Examples of non-routine tasks could be Confined Space Entry and possible
toxic gas exposure.
No container of hazardous substances will be released for use unless properly labeled
and proper personal protective equipment has been provided.

Date 12/5/2007
5.3 Hazardous Materials
The purpose of this section is to establish uniform guidelines for the safe storage,
handling, and disposal of hazardous materials.
The OSHA Hazard Communication Standard regulates all chemical substances that
present a physical or health hazard. Employees covered by this standard are to be
informed of the following;
• The hazardous properties of chemicals at the facility,
• The location of these chemicals,
• How to determine necessary precautions for protection from hazardous
chemicals and
• Necessary actions and information required when bringing a new chemical into
the facility.
The following items are to be considered Hazardous Materials on the Cape Vincent
project and should be treated appropriately. Each can be found in Section 25 of the Zero
Injury Program Training Manual.
• Waste Oils - form or vehicles (25.B.-1)

• Concrete Hardeners and Sealers (25.B.-3)
• Acids and Bases (25.B.-3)
• Disinfectants
• Paints and Coatings (25.B.-2)
• Heavy Metals - residuals of stripping operations (25.J.-1)
• Fuels (25.B.-1)
• Solvents and Cleaners (25.B.-2 to 25.B.-3)
• Pesticides and Herbicides
• Asbestos ** (25.H.-1)
• Lead **(25.I.-1)
Storage of Hazardous Materials

This information can be found in the Hazardous Materials Section 22 of the Zero Injury
• Must comply with all applicable OSHA, NFPA, and local code requirements.
• Provide at least one 20 lbs. A-B-C fire extinguisher within 10 feet.
• Follow good housekeeping practices
• Provide proper signage:
1. ID types of materials
2. If different materials are stored together, ID the materials and their
designated storage spot
3. Provide proper labeling on all containers, including temporary ones
• Notify the proper emergency authorities including local fire department
• A competent person will be responsible for determining the proper segregation of
materials and the distance requirements.
• The following materials will be separated:
1. Flammables
2. Toxins
3. Oxidants
4. Reducers

Date 12/5/2007
5. Concentrated Acids
6. Water reactives
7. Peroxides
8. Pyrophorics
9. Cylinder gases (whether empty or full)
10. Combustibles
• Do Not Accept hazardous materials if:
1. The container is damaged
2. The supplier has used a temporary container
3. The labeling has been damaged
General Safety
Please reference Section 22 of the Zero Injury Program Training Manual.
• Before using hazardous materials, all personnel must be able to ID the materials
and be familiar with their hazardous characteristics
• Follow all PPE measures noted on the MSDS Sheets
• All personnel handling hazardous materials shall be properly trained per section
2.C of the Zero Injury Program Training Manual as well as 29 CFR 1926.21 (b)
• Use the materials only for their approved purpose
• Avoid storage of excess materials in temporary containers
ANY AND ALL QUESTIONS SHOULD BE ADDRESSED TO THE ENVIRONMENTAL

SAFETY & HEALTH SERVICES GROUP.
Hazardous Waste Disposal

This information can be found in the Hazardous Materials Section 22 of the Zero Injury
Contaminated Soils
Soils believed to be contaminated with a hazardous concentration of a chemical must be
tested to determine whether they are hazardous wastes or exhibit hazardous
characteristics. If the soil is determined to be non-hazardous, work may commence in
the area and the soil may be disposed of following the Environmental Program
requirements. Soils found to be contaminated with hazardous materials must be
disposed of as hazardous wastes. A review of the MSDS sheet to ascertain the proper
protection required shall be done as well as a review of the proper disposal procedure
found in the Environmental Program. Soils contaminated with gasoline may be aerated
to remove the volatile fraction and then may be disposed of regularly.
Chemicals, stored or used on this project will meet the requirements defined in this
program. This program does not apply to chemicals regulated by the Consumer Product
Safety Act, tobacco, or foods. The Consumer Products Safety Act includes chemicals
that can be purchased publicly, will be used in the same manner and quantity as a
normal consumer, and which results in a duration and frequency of exposure that is not
greater than a normal consumer would experience. Examples of chemicals excluded
from this program would include bathroom deodorizers, white out, WD-40, and dish soap.

Date 12/5/2007
5.4 Hazard Communication Training Log
PRINT NAME SIGNATURE COMPANY DATE

Date 12/5/2007
5.5 Fire Protection and Hot Work Permits
Fire Protection
1. The Superintendent must notify local fire departments near the project and:
a) Ask for their support during the planning
b) Request periodic review of the site
c) Develop and agree upon an Emergency Response Plan
2. Storage
a) See section 21.A.-1 to 21.A.-2 of the Zero Injury Program Training Manual
3. Fire Extinguishers
a) A minimum of at least one (1) extinguisher (at least a 10 pound ABC dry
chemical type) for every 3000 square feet of building area
b) At least one (1) extinguisher per floor and an additional 10 pound ABC
extinguisher must be placed adjacent to all stairways
c) Extinguishers must be:
1) Inspected at least weekly by the safety professional or their designee
2) Refilled immediately after being discharged
3) Conspicuously stored, well marked, and easily accessible
d) Records must be kept of inspection dates
4. Portable Heaters
a) See section 21.A.- 2 to 21.A.- 3 of the Zero Injury Program Training Manual
5. Training
a) All employees should be trained in the proper use of extinguishers and in the
hazards involved with the initial stages of fire fighting.
Hot Work Permits
1. See section 19.A.-1 to 19.A.- 6 of the Zero Injury Program Training Manual
2. Follow the instructions on the Hot Work Permit and fill out all applicable sections.
3. Attain the appropriate signatures prior to beginning work.
4. Permits should be filled out daily (or before each shift in a multi-shift work day).
5. See Hot Work Permit Guidelines referenced in Section 10 of the Zero Injury Program
Training Manual.
Blasting Permits
1. See section 7.b of the Zero Injury Program Training Manual
2. Follow the instructions on the Blasting Permit and fill out all applicable sections.
4. Permits should be filled out for each blast operation.

Date 12/5/2007
Dig Permits
1. See section 9.A of the Zero Injury Program Training Manual
2. Follow the instructions on the Dig Permit and fill out all applicable sections.
4. Permits should be filled out daily for each separate excavation (or before each shift in
a multi-shift work day).
Underground Permit System
The permit can be found in Section VIII, Appendix E Excavation & Shoring of the
Disruption Avoidance Training Manual referenced in Section 10.
5.6 Lock Out/ Tag Out/ Check Out Program (LO/TO/CO)

I. Summary OSHA 1926.417 and 1910.147
NOTE - This section will be coordinated with Cape Vincent site safety procedures if
necessary
BP Alternative Energy has established a written safety program (Section 13.A.-1 of the
Zero Injury Program Training Manual) applying to work on any machine or equipment
where there is the potential for unexpected energizing, start-up, or release of stored
energy from gravitational, electrical, mechanical, thermal or material flow equipment. The
program consists of an energy control program, periodic inspections, and employee
training. All inquiries into the specifics of this program should be referenced in the Zero
Injury Program Training Manual, Section 13.A.-1 and/or a site specific program
established and maintained by others.
Potentially hazardous energy sources must be isolated to protect workers who are
engaged in activities involving equipment. This is done through the application of
isolation devices. In all work situations or conditions the Control of Hazardous Energy
must be done in accordance with 29 CFR 1910.147 and with these HSSE Policies,
Standards and Procedures. As a general rule, no work will be conducted on systems,
subsystems or equipment that are, or have the potential to contain, hazardous energy in
any form. Key provisions of this Lock-Out/Tag-Out System include:
• The method of isolation and discharge of stored energy are agreed and executed
by a competent person(s)
• Any/all stored energy is discharged
• A system of locks and tags is utilized at the correct isolation points
• A test or tests are conducted to ensure the isolation(s) is (are) effective
• Isolation effectiveness is periodically monitored
II. Scope
BP Alternative Energy and its Subcontractors

Date 12/5/2007
III. Definitions
Lockout device: A lock, chain and lock, or other device with an identification tag , which
can only be opened or removed by means of a key to hold an energy isolating device in
the safe position and prevent the energization of a machine or equipment. Included are
blank flanges and bolted slip blinds. A lock out bar is designed to accept additional locks
where multiple use is required.
Tagout device: A distinctive sign, or tag, that identifies it is a lock out device and identifies
the individual who has placed the lock, along with the time and date it was placed. The
tag should be standard shape and size throughout the work site.
Checkout: Means that the energy source that needs to be locked out / tagged out has
been checked to insure that all energy sources have indeed been locked out.
General
Each company shall provide their own lock out, tag out, and check out devices for
securing, blocking, or isolating of machines or equipment from their energy source.
These aforementioned devices may only be used for lock out / tag out situations and be
strong enough to prevent their removal without the use of excessive force. Each
contractor or entity having personnel working on a project site shall have a unique color
assigned for LOTO devices. The master list identifying color and contractor will be
published for reference. Keys for LOTO devices shall be controlled by a single
designated person for each entity having devices. Control shall be accomplished by
storage under lock and key.
Although the electrical subcontractor will usually handle the lock out, tag out, and check
out for all electrical devices in the building, BP Alternative Energy personnel need to be
aware that the LO/TO/CO/ program also applies to many other areas of our work. These
areas include all of the following, but are not limited to:
• Any hydraulic equipment (mechanical concrete buggies, etc.)

• Any lines that have pressure built up in them (standby fire lines, etc.)
• Live electricity during the demolition phase of a project
• Concrete buckets which are spring loaded
• Come-alongs that are used to tweak a forming system
• Pneumatic powered tools (Jackhammers, etc.)
• Any powder-activated power tools (Hilti’s, etc.)
• Any equipment that is under tension and could release all of its energy if it were
to break
• Any equipment that could cause a pinch to occur (Forks on a forklift being
lowered, an engine that is being turned over that catches, etc.)
• Any further questions should be referenced to Environmental Safety &

Health Services Group and the Zero Injury Program Training Manual.

Date 12/5/2007
5.7 Fall Protection
Working at heights of six feet (6’)* or higher cannot proceed unless:
• A fixed platform is used with a guard rail system is in place, verified as meeting
OSHA requirements or…
• Fall arrest equipment is used that is capable of supporting at least 2275 kg
(5,000 lbs) static load per person and has:
o A proper anchor mounted, preferably overhead
o Full body harness using double latch self locking snap hooks at each
connection
o Synthetic fiber lanyards
o Shock absorber
• Fall arrest equipment will limit free fall distances to six feet or less
• A visual inspection of the fall arrest equipment and system is completed and any
equipment that is damaged or has been activated is taken out of service
• Person(s) are competent to perform the work
** Refer to Section 10 of the Zero Injury Program Training Manual for further
reference.
1926.501 Duty to Have Fall Protection
• Employers must determine whether walking/working surfaces are structurally capable

of supporting workers safety.
• Workers on walking/working surfaces with unprotected sides or edges six feet or

higher above a lower level must be protected from falling by the use of guardrails, toe
boards, nets or fall arrest systems.
• Workers constructing or working near leading edges at six feet or higher above a
lower level must be protected from falls by guardrails, toe boards, nets or fall arrest
systems.
• Workers in hoist areas must be protected from falling more than six feet by
guardrails’ toe boards or personal fall arrest systems.
• Workers must be protected from falling more than six feet through holes (including
skylights) by hole covers that are secured over the hole to prevent accidental
movement, guardrails, toe boards or personal fall arrest systems.
• Workers on the face of formwork or reinforcing steel must be protected from falling
six feet or more by personal fall arrest systems, nets or positioning devices.
• Workers on the edge of excavations deeper than six feet must be protected from
falling by guardrails, fences or barricades or fall arrest systems.
• Workers less than six feet above dangerous equipment must be protected from
falling into or onto the equipment by guardrails, toe boards or equipment guards.

Date 12/5/2007
• Workers six feet or higher above dangerous equipment must be protected from fall
hazards by guardrails, toe boards, personal fall arrest systems or nets.
• Bricklayers performing overhand bricklaying and related work six feet or higher above
lower levels must be protected from falling by guardrails, toe boards, nets, personal
fall arrest systems or must work in a controlled access zone.
• Bricklayers reaching more than ten inches below the level walking/working surface on
which they are working must be protected from falling by guardrails, toe boards, nets,
or personal fall arrest systems.
• Roofers working on low-slope roofs with unprotected sides and edges six feet or
more above lower levels must be protected from falls by guardrails, nets, personal fall
arrest systems or any of the following combinations:
o warning lines and guardrails,
o warning lines and safety nets,
o warning lines and personal fall arrest systems, or
o warning lines and safety monitoring.
• Roofers on steep roofs with unprotected sides and edges six feet or higher above
lower levels must be protected from falling by guardrails systems with toeboards,
nets or personal fall arrest systems.
• Workers near wall openings six feet or higher above lower levels and less than 39
inches above the walking/working surface must be protected from falling by
guardrails, toe boards, nets or personal fall arrest systems
• Workers on walking/working surfaces six feet or higher above lower levels which are
not otherwise addressed must be protected from falling by guardrails, toe boards,
nets or personal fall arrest systems.
• Where workers are exposed to falling objects, the employer must have each worker
wear a hard hat and must:
o erect toeboards, screens or guardrails to prevent objects from falling,
o erect a canopy structure and keep objects away from the edge of the higher
level, or
o barricade the area to which objects could fall and keep objects away from the
edge of the higher level.
o All hand tools 5 lbs or less shall be attached to the worker by a lanyard.
1926.502 Fall Protection Systems Criteria and Practices
• The top edge of guardrails must be between 39 inches and 45 inches high.
• Midrails, screen, mesh or intermediate vertical members must be installed between

the top edge of the guardrails and the walking/working surface when there is no wall
or parapet wall at least 21 inches high.
• Guardrails must be capable of withstanding a force of at least 200 pounds applied

within two inches of the top edge in any outward or downward direction.

Date 12/5/2007
• With 200 pounds of downward force the top edge of the guardrail must not deflect to
less than 39 inches.
• Midrails, screens, mesh and intermediate vertical members must be capable of

withstanding a force of at least 150 pounds applied in any downward or outward
direction at any point along the midrails or other member.
• Guardrail must be surfaced in a way that will prevent punctures, lacerations and
snags.
• The ends of top rails and midrails must not overhand terminal posts unless an
overhang would not create a projection hazard.
• Steel and plastic banding must not be used on top and midrails.
• Top and midrails must be at least one-quarter inch nominal diameter or thickness.
• When guardrail is used in hoisting areas, a chain, gate or removable guardrail section
must be placed across access opening when hoisting operations are not taking
place.
• When guardrails are used at holes they must be erected on all unprotected sides or
edges.
• When guardrails are used to protect holes that are used for passage of materials not
more than two sides can be protected by removable guardrail.
• Safety nets must be installed as close as possible, but not more than 30 feet below
the walking/working surface.
• Safety nets must extend outward from the outermost projection of the work surface
(see regulations for distances).
• Drop tests must be performed on safety nets by dropping a 400 pound 30-32 inch
diameter bag of sand into the net from the highest walking/working surface (but not
less than 42 inches).
• When it is unreasonable to perform a drop test on a net, the employer or a

designated competent person must certify that the net and net installations are in
compliance with this standard.
• Nets must be inspected at least once a week and defective nets and parts must be
removed from service.
• Body belts are not acceptable as part of a fall arrest system.
• Lanyards and vertical lifelines must have a minimum breaking strength of 5,000
pounds.
• Personal fall arrest systems when stopping a fall must limit the maximum arresting
force on the worker to 900 pounds.

Date 12/5/2007
• Personal fall arrest systems must be rigged so that the worker can fall no more than
six feet and contact any lower level.
• Positioning devices must be rigged to prevent free falls more than two feet.
• Warning lines must be erected around all sides of a roof work area.
• Controlled access zones must be defined by a control line or other means that
restricts access.
• An anchor connector shall be used if an anchorage does not have a connection point
compatible with a carabineer or snap hook.
• Documentation of date of first use will be kept or in the absence of that data, the date
of manufacturer will be considered the start of service life. A competent or qualified
person will conduct and document 2 formal inspections on fall arrest equipment.
• A project specific rescue plan will be developed.
1926.503 Fall Protection Training Requirements
• The employer will provide a training program for each employee who might be
exposed to fall hazards.
• A competent person will train on the nature of fall hazards; correct procedures for
erecting, maintaining, disassembling and inspecting fall protection systems to be
used; use and operation of protective systems; role of employees in safety monitoring
systems; limitations of mechanical equipment; correct procedures for handling and
storage of equipment and materials; and role of employees in fall protection plans.
• Training will be a combination of classroom and practical training. Trainees will

demonstrate proper function and use of fall protection equipment.
• The employer must keep a written certification record to verify compliance with
training requirements.
• Retraining will occur when changes in the workplace render previous training
obsolete; changes in types of fall protection systems or equipment render previous
training obsolete; or inadequacies in employee’s knowledge or use of fall protection
systems indicate employee has not retained understanding or skill.

Date 12/5/2007
5.8 RESPIRATORY PROTECTION PROGRAM
(OSHA 1910.134, OSHA 1926.103)
** Refer to Section 25.E in the Zero Injury Program Training Manual for further reference
and respirator forms, questionnaires, etc.
A respiratory protection program has been established to coordinate the use and
maintenance of respiratory protective equipment. The use of respiratory protective
equipment, other than disposable dust masks, by a BP Alternative Energy employee is a
non-routine task. Respirators will only be used when it is not possible to clear the air
through other methods. Respirators will be used in accordance with this program and
applicable law.
Whenever the project management team believes air quality will be poor, the
Environmental Safety & Health Services Group should be consulted for assistance
in identifying the potential hazards and selecting the proper protective measures.
This will be done when planning the project. After the project is under construction, the
responsibility for monitoring air quality and involving the Safety Department will be
assigned to the Superintendent.
Applicable contaminant and exposure levels combined with relevant Material Safety
Data Sheets will be used when evaluating the implementation of a job specific respiratory
protective program. After deciding that respirators are required and the proper
respirators for the job are determined by the Environmental Safety & Health
Services Group, the following items will be addressed by the Superintendent.
1. The Superintendent will make sure that each employee who must wear a respirator
has been certified physically capable of doing so by a Health Care Professional.
2. The Superintendent will make sure that each employee who will use a respirator has
been properly trained in the fitting, proper use, limitation, and care of the device by a
competent person.
3. The Superintendent will see that respirators are issued only to individuals for their
exclusive personal use.
4. The Superintendent will provide for the daily cleaning, inspection, and maintenance
of respirators in use.
5. The Superintendent will make provision for proper sanitary storage of the respirators.
6. The Superintendent will provide for appropriate surveillance of the work area
conditions and degree of employee exposure to assure compliance with the intent of
the program.
7. The Environmental Safety & Health Services Group and Superintendent will monitor
the effectiveness of the program.
8. The Superintendent will assure that only approved devices are used; that they are
not altered; that they are properly maintained and fitted; and that they are used only
in accordance with law, this program, and manufacturer's instructions.

Date 12/5/2007
5.9 Voluntary Respirator Use Form
Appendix D to Section 1910.134 (Mandatory) Information for Employees Using

Respirators When Not Required Under the Standard
Respirators are an effective method of protection against designated hazards when

properly selected and worn. Respirator use is encouraged, even when exposures are
below the exposure limit, to provide an additional level of comfort and protection for
workers. However, if a respirator is used improperly or not kept clean, the respirator itself
can become a hazard to the worker. Sometimes, workers may wear respirators to avoid
exposures to hazards, even if the amount of hazardous substance does not exceed the
limits set by OSHA standards. If your employer provides respirators for your voluntary
use, or if you provide your own respirator, you need to take certain precautions to be sure
that the respirator itself does not present a hazard.
You should do the following:
1. Read and heed all instructions provided by the manufacturer on use, maintenance,
cleaning and care, and warnings regarding the respirators limitations.
2. Choose respirators certified for use to protect against the contaminant of concern.
NIOSH, the National Institute for Occupational Safety and Health of the U.S.
Department of Health and Human Services, certifies respirators. A label or statement
of certification should appear on the respirator or respirator packaging. It will tell you
what the respirator is designed for and how much it will protect you.
3. Do not wear your respirator into atmospheres containing contaminants for which your
respirator is not designed to protect against. For example, a respirator designed to
filter dust particles will not protect you against gases, vapors, or very small solid
particles of fumes or smoke.
4. Keep track of your respirator so that you do not mistakenly use someone else’s
respirator.
I have read the following and understand all the variables associated with respirator use
mentioned on this page. I acknowledge that I am wearing this respirator VOLUNTARILY
and choose to by my own free will.
________________________________________________
PRINT NAME
_______________________________________________________________________
SIGNATURE DATE

Date 12/5/2007
5.10 Confined Space Program OSHA 1926.21
Our work will periodically require entering areas that qualify as "confined spaces." The
Occupational Safety and Health Administration (OSHA) defines a confined space as an
area having limited means of exit, which is subject to the accumulation of toxic or
flammable contaminants, or has an oxygen deficient atmosphere. Some examples
of confined spaces are storage tanks, process vessels, bins, boilers, ventilation or
exhaust ducts, sewers, underground utility vaults, tunnels, and pipelines. Open-top
spaces more than four feet in depth such as pits, tubs, vaults, and vessels are also
classified as confined space. Because of the unique dangers associated with working in
confined spaces, the Project Manager and Superintendent should review work of this
type with the Environmental Safety & health Services Group before starting a project.
Using the pre-entry checklist can identify dangers associated with various types of
spaces. An example of this form is located at the end of this section.
All entities performing work on this project will insure that prior to entering any enclosed
spaces, tanks, trenches, etc. that an appropriate evaluation is made of the space prior to
making an entry. These spaces may be Confined Spaces and must be treated as such if
they meet either of the following Code of Federal Regulations statutes: 1) 29 CFR
1926.21(b)(6)(ii) or 29 CFR 1910.146(b). Key elements of BP’s Confined Space Entry
process include:
• All other options have been ruled out and the Confined Space Entry must be
conducted
• A permit is issued with authorization by a responsible person(s)
• Permit information is communicated to all affected personnel and posted
• All persons involved are competent to conduct the work
• All sources of energy affecting the space have been properly isolated
• Atmospheric testing is conducted, verified and repeated before and throughout
the entry period
• A standby person(s) or attendant(s) are properly positioned and stationed
throughout the entry
• Unauthorized entry is prohibited
• All personnel are empowered to ‘Stop the Job’ and evacuate the space if
conditions change
Work should not be started in any permit-required spaces without advice from the
Group Director, Safety & Quality.
The Environmental Safety & health Services Group will outline the procedures and
equipment required for work performed in confined spaces.
Confined spaces fall into two categories. Permit required confined spaces and non
permit confined spaces.
PERMIT REQUIRED CONFINED SPACES are confined spaces that have one or more of
the following characteristics:
• Space contains or has a potential to contain a hazardous atmosphere;

• Contains a material that has the potential for engulfing an entrant;
• Has an internal configuration such that an entrant could be trapped or
asphyxiated by inwardly converging walls or by a floor which slopes downward
and tapers to a smaller cross-section;

Date 12/5/2007
• Contains any other recognized serious safety or health hazard.
NON-PERMIT CONFINED SPACES are not confined spaces where dangerous air
contamination, oxygen deficiency or oxygen enrichment cannot develop nor have the
potential to contain any hazard capable of causing death or serious physical harm.
The following paragraphs explain each item on the form:
A. Permit: Entry into permit required and non-permit required confined spaces are
permitted only when all the provisions noted on the work permit are met per confined
space classification. The permit should be posted at the entrance to the space for
the duration of the work or per shift (maximum of 12 hours). When work in the
confined space is completed, a copy of the permit should be kept on file at the
jobsite.
B. Atmospheric Testing: The atmosphere of all confined spaces must be tested by a

qualified person or BP Alternative Energy’s Safety Department before entry. Records
will be kept each day or shift and filed at the jobsite upon completion of the work.
C. Monitoring: During work in permit required confined spaces, air quality must be
monitored continuously.
D. Medical Surveillance: Employees who will be working in confined spaces must have
a doctor's signed clearance when specific PPE is needed. The doctor should be sure
that the employee can do the following:
1. Wear respirators as described by 29 CFR 1910.134 and ANSI standards.
2. Hear, see and respond to warnings such as lights, buzzers, or verbal and
visual signals by personnel.
3. Show that they have no physical problems that would prevent them from
getting out of the space under their own power in an emergency, or which
would be aggravated by the nature of the space or the work.
The physician’s signed clearance must be sent to the Group Safety Director before
beginning work.
Confined Space work when building wind power facilities is defined below:
Work areas that are considered “Permit Required” confined space:
• Wind turbine rotor hub, nacelle and tower spaces after the complete assembly
has been erected, is mechanically complete, and has been energized.
• Electrical system components and enclosures that have been energized.
Work areas that are considered “Non-Permit Required” confined space:

• Wind turbine foundation excavations
• Wind turbine components including tower sections, during unloading, washing,
preparation, rigging, erection, torquing, wiring and cleaning.
All other work is not considered confined space.
Consult the Environmental Safety & Health Services Group for medical
requirements.

Date 12/5/2007
E. Training of Personnel: The Superintendent/ Environmental Safety & Health Services
Group will train employees who will be working in a confined space. This training
should cover:
1. Emergency entry and exit procedures
2. Respirator usage (selection by Safety Department only)
3. First Aid
4. Lockout procedures
5. Safety equipment use
6. Rescue and training drill
7. Work procedures specific to the job
Training is not finished until the entry permit is signed and the Superintendent feels the
employees are competent.
F. Labeling and Posting: The entry to the confined space must be labeled with a sign
reading: "Danger - Confined Space - Entry by Permit Only."
G. Preparation: The following must be done before starting work:
1. The area must be isolated from any systems or processes that might present
a hazard.
2. All electrical and mechanical systems associated with the space must be
locked out and tagged. Reference the Zero Injury Training Program Manual
for “Tag & Lockout” procedures.
3. The area must be purged and ventilated to reduce the amount of toxic
materials or increase oxygen content as required. It must never be assumed
that airflow eliminates the need for atmospheric testing or other measures
required by the permit.
4. The cleaning processes that will be used must be reviewed before starting
work to be sure that they are the least hazardous methods available.
5. Before the project starts, the special tools and equipment needed should be
identified so that the Superintendent can insure they are available to
employees.
H. Procedures: The Superintendent should make a plan for any work that will be done
in confined spaces. The plan should cover each of the items on the permit.
Plans should also cover methods for maintaining communication with the workers
from outside the confined space.
The Superintendent's pre-planning should also cover methods for rescue and
contacting emergency assistance agencies in an emergency.
Finally, the plan should include detailed procedures for completing the work.
I. Safety Equipment and Clothing: BP Alternative Energy will provide all of the personal
protective gear required by its employees including but not limited to, special head
protection, hearing protection, hand protection, foot protection, eye protection and
clothing.

Date 12/5/2007
RESPIRATORY EQUIPMENT FOR WORK IN CONFINED SPACES MUST BE
SELECTED BY THE ENVIRONMENTAL SAFETY & HEALTH SERVICES GROUP
J. Rescue Equipment: Winches, hoists, stretchers, lifelines, and other equipment will be
provided so that workers in trouble can be rescued without anyone else going into
the confined space.
K. Record Keeping/Exposure: Records of all employee exposures to hazardous

concentrations of chemicals while working in confined spaces will be sent to the
Group Director, Safety & Quality.
L. Observer Required at Entrance: An observer will be posted at the entrance to any

occupied permit required confined space covered under this section for the purpose
of securing help in case of an emergency. This observer is not a rescue person.
Under no circumstance should the observer enter the confinement!

Date 12/5/2007
(a) WORK PERMIT AND CHECKLIST OF CONSIDERATIONS FOR ENTRY
WORKING IN AND EXITING CONFINED SPACES CHART
JOB # SUPERINTENDENT
CITY FOREMAN
WORK AREA DATE

Permit valid for one shift PERSON PERFORMING
or maximum of 12 hours ATMOSPHERIC TEST
X = Requirement
O = Determination by the Qualified Person
Confined Space Permit Required Non-Permit Required
1. Permit X( ) X( )
2. Atmospheric Testing X( ) X( )
Type of testing instrument:___________________ Reading Reading Reading Reading

Time _______ _______ _______ _______
Oxygen _______ _______ _______ _______
Flammable _______ _______ _______ _______
Toxic H2S and CO _______ _______ _______ _______
Other _______ _______ _______ _______

Project Number:
Date 12/5/2007
Revision 0 61 0092352\A4363\App L - Site Specific HSSE.doc
Continue for Permit Required Spaces Only
3. Monitoring X( ) 9. Safety Equipment and Clothing

If not continuously monitored, periodic tests Head Protection X( )
are needed. Document readings in the table. Hearing Protection X( )
Hand Protection X( )
4. Medical Surveillance X( ) Foot Protection X( )
Body Protection X( )
5. Training of Personnel X( ) Respiratory Protection X( )
Ground Fault Protection X( )
6. Labeling and Posting X( ) Low Voltage X( )
7. Preparation 10. Rescue Equipment X( )

Isolate/Lockout/Tagout X( ) SCBA’s X( )
Purge and Ventilate X( ) Tri-pod/Hoisting device X( )
Requirements for special
Equipment & Tools X( ) 11. Recordkeeping/Exposure X( )
8. Procedures: 12. Attendant Required at Entry X( )

Initial Work Plan X( )
Communications X( )
Rescue X( )
Superintendent: ________________________________________________________
I have received instruction on this work, fully understand and have complied with all provisions noted on this form.
Employees
__________________________ __________________________ __________________________
__________________________ __________________________ __________________________
__________________________ __________________________ __________________________

Project Number:
Date 12/5/2007
(b) CONFINED SPACE CLASSIFICATION TABLE CS-3
Parameters Permit Required Confined Space Non-Permit Confined Space

Characteristics Atmosphere that has one or more of the Atmosphere where dangerous
following characteristics: air contamination, oxygen
1. Confined space contains or has a deficiency or oxygen enrichment
potential to contain a hazardous cannot develop or have the
atmosphere; potential to contain any hazard
2. Contains a material that has the capable of causing death or
potential for engulfing an entrant; serious physical harm.
3. Has an internal configuration such that
an entrant could be trapped or
asphyxiated by inwardly covering walls
or by a floor which slopes downward
and tapers to a smaller cross-section;
Or
Contains any other recognized serious
safety or health hazard.
Oxygen 19.4% or less or 23.6% or more 19.5% to 23.5%
Flammability Greater than 10% LEL 10% LEL or Less

Characteristics
Toxicity Hydrogen Sulfide 1 ppm to 10 ppm Hydrogen Sulfide 0 ppm

Carbon Monoxide 1 ppm to 35 ppm Carbon Monoxide 0 ppm
Hydrogen Sulfide greater than 15 ppm is
IDLH
Hydrogen Sulfide greater than 200 ppm is
IDLH
Procedures 1. Contact BP Alternative Energy Safety 1. Space tested for oxygen and
Department air contaminates
2. Permit required 2. Recommend to monitor
3. Personal protective equipment and/or ventilate continuously
4. Attendant require 3. No attendant required
*Maintain communication 4. Standard rescue procedures
*Alert rescue team
5. Rescue equipment
*Hoisting device
*SCBA’s available
Rescue team trained in CPR/First Aid
*LEL (Lower Exposure Limit)

*PPM (Parts Per Million)
**IDLH (Immediately dangerous to life or health)
NOTE: BP Alternative Energy Company Environmental Safety & Health Services Group should
be notified for confined spaces with possible toxic atmospheres other than Hydrogen Sulfide,
Carbon Monoxide or Chlorine.

Project Number:
Date 12/5/2007
b) CONFINED SPACE CLASSIFICATION TABLE CHART CS-1
PARAMETERS CLASS A CLASS B CLASS C

Characteristics • Atmosphere free of dangerous • Atmosphere free of dangerous • Atmosphere where dangerous
air contamination, oxygen air contamination, oxygen air contamination, oxygen
deficiency, or oxygen deficiency or oxygen enrichment cannot develop.
enrichment cannot be verified enrichment has been verified • Potential hazard
• Immediately dangerous to life dangerous, but not immediately • Requires no modification of
or health. life threatening. work procedures
• Entry and rescue procedures • Rescue procedures require • Standby rescue procedures
require individuals to be fully fully equipped life support
equipped with life support equipment SCBA.
equipment.
Oxygen 16% or less 16.1% to 19.4% 19.5% to 21.4%
Flammability Characteristics 20% or greater of LEL 10% to 19% LEL 10% LEL or less
Procedures 1. Contact BPAE Safety 1. Contact BPAE Safety 1. Contact BPAE Safety
Department Department Department
2. Permit required 2. Permit required 2. Permit required
3. Approved respirator 3. Space tested for oxygen 3. Space tested for oxygen
4. Safety belt or harness contaminates contaminates
5. Hoisting devices 4. Monitored continuously 4. Monitored or ventilated
6. Standby required 5. Standby required continuously
*Maintain communication 6. Maintain communications 5. Standard rescue procedures
*SCBA available 7. Standby trained in rescue 6. No standby required
*Alert rescue team before
entering
7. Trained employee in CPR/First
Aid
Toxicity **IDLH Hydrogen Sulfide 11ppm to 15 ppm Hydrogen Sulfide 1 ppm to 10 ppm Hydrogen Sulfide 0 ppm
Greater then 15 ppm is IDLH Carbon monoxide 0 ppm
Carbon Monixide 36 ppm to 200
ppm greater than 200 ppm is IDLH ppm

*PPM (Parts Per Million)
**(Immediately dangerous to life or health)
Class A only.
Note: Environmental Safety & Health Services Group shall be notified for all confined spaces with possible toxic atmospheres.

Project Number:
Date 12/5/2007
5.11 Scaffold Standards
Only approved, competent and authorized personnel are allowed to build, modify, move,
or inspect scaffolding. A minimum of one certified scaffold builder is required during the
construction or modification of any scaffold. He/she is responsible for the oversight and
inspection of scaffolds that have been built or modified before they can be tagged as safe
for use.
There is no such thing as a temporary scaffold. All scaffolding must be erected and
maintained to conform to established scaffolding standards. Guardrail systems must
comply with 29 CFR 1926.502(b)(1) which requires top rails to be 42” (+ 3”), Mid rails
should be midway between the top rail and walking surface and must be equipped with
toeboards that are a minimum of 3.5” in vertical height and must not permit more than ¼”
clearance between the bottom of the toeboard and top of the walking/working surface.
Guardrail systems must be installed on all open sides of scaffolding more than 6 feet
above the ground. Scaffolding guardrails (top and mid-rails and toe boards) should be
constructed from components furnished by the manufacturer. Where the manufacturer
does not supply toeboards, sound 2” X 4” inch lumber and must not permit gaps of
greater then ¼’ between the bottom of the toeboard and walking/working surface and no
more than a 1” gap or opening anywhere in the toeboard, in any direction.
Listed herein are excerpts from the revised OSHA Standards 29 CFR Part 1926 Safety
Standards for scaffolds used in the construction industry that became effective November
26, 1996. These general guidelines address issues most commonly experienced in the
erection and use of scaffolds. For “specific regulations” relative to the erection or use of
scaffolds, refer to OSHA Standards for the Construction Industry 29 FCR Part 1926.451.
Refer to Section 20 of the Zero Injury Program Training Manual for further policy.
Scaffold Capacity Requirements
• Capable of supporting 4 times maximum intended load, plus its own weight
• Suspension ropes shall support 6 times the maximum load
• Scaffolds shall be designed by a qualified person and shall be constructed and
loaded according to the design
• No scaffold shall be erected, moved, dismantled or altered except under the
supervision of competent persons
• Scaffolds shall be inspected and documented prior to each shift by a competent
person as defined by OSHA 1926.405(b).
• All scaffolds will be tagged indicating current actual status based on inspection, with
a RED tag which denotes “DANGER - DO NOT USE” or a “GREEN - OK TO USE”
tag allowing access to an inspected, properly constructed scaffold
Platform Construction
• Scaffolds must be fully planked on all working levels.

• Spacing between planks shall not exceed 1”
• Each platform and walkway shall be at least 18” wide
• The decked edge shall be no more than 14” from the work face, 18” for plastering
• Only approved scaffold grade planking may be used
• Planks must be overlapped at least 12” or secured and the overlap must occur at the
support
• Wood platforms shall not be covered with opaque finished, i.e. paint

Project Number:
Date 12/5/2007
• Scaffold components from different manufactures shall not be intermixed unless
approved by a competent person
• Toe boards shall be 4” in height and installed on the outside edges where employees
could come in contact with falling objects.
Supported Scaffolds
• Scaffolds with height to base ratio greater than 4 to 1 shall be restrained from tipping
• Guys shall be installed where they support both inner and outer legs
• Guys shall be located a MINIMUM of every 30’ horizontally and 26’ vertically
• The top guy shall be no further than the 4 to 1 height ratio from the top
• Legs shall be supported by base plates, mud sills or other firm foundations
• Footings shall be level, sound, rigid and capable of support without settling
• Scaffolds shall be plumb and braced
• Forklifts and loaders shall not be used to support scaffolds
Scaffold Access
• Access shall be provided for all platforms 2’ or more above/below an access point
• Ladders shall be positioned so as to not tip the scaffold
• Ladders shall have rest platforms at intervals not to exceed 35’
• 12’ for scaffold stairways
• The first step/rung shall be within 24” of the supporting level
• Frame access ladders:
o Designed for use as a ladder
o Rung length of at least 8”
o Maximum rung spacing, 16.75”
o Uniform rung spacing, except at joints
• Cross braces shall not be used as a means of access.
• Access for scaffold erectors shall be provided
Scaffold Use
• No scaffold shall be erected, moved, dismantled or altered except under the

supervision of competent persons
• Scaffolds shall be inspected by a competent person before each shift and after any
occurrence that could affect the integrity
• Immediately upon discovery of a damaged or out of specification scaffold component,
the scaffold system will be “Red Tagged” and taken out of service. Use will be
prevented until necessary repairs are made.
• Working on scaffold covered with snow, ice or other slippery material is prohibited
• Debris shall not accumulate on platforms
• When swinging loads near any scaffold, a tag line must be used to control the load
• Ladders or other devices shall not be used to increase working level height
• Scaffold erection shall be completed under supervision of a competent person
Fall Protection
• Fall protection shall be provided on all platforms 6’ or more above the next level
o Guardrails on all open sides
o Personal fall arrest system
• Fall protection will be required for erectors

Project Number:
Date 12/5/2007
Falling Object Protection
• Employees working on and around scaffold must be protected from falling objects
• Toeboards are required on all platforms
• If material extends above the toeboard:
o A screen must be installed, or
o the area below must be barricaded off, or
o a canopy must be installed
Electrical Hazards
• Inspect the area for all electrical hazards prior to erecting scaffolds
• If an electrical hazard is present notify the power company to de-energize or relocate
the line
• Minimum clearance from a power line is 10’, unless additional distance is required by
applicable code or standard.
Mobile Scaffolds
• Cannot exceed a height to base ratio of 4 to 1

• Riding mobile scaffolds is prohibited
• Secure or remove all materials and equipment from platform before moving
• Casters must be pinned to the scaffold and locked at all times, except when moving
• Mobile scaffolds must be used on a firm and level surface
• Never use side arm brackets
• Diagonal bracing is required on the first level, and at 20’ intervals thereafter
• Provide a safe access
• All joints shall be restrained from separation
• Cleat or secure all plank
Training Requirements
• Scaffold training is required:

o For all new employees who will be working on scaffolds
o When worksite changes present a new hazard
o When equipment is changed
o When trained employees demonstrate a lack of understanding
• All scaffold erectors must be trained on:
o Scaffold hazards
o Correct scaffold erection procedures
o Load carrying capacity
o Design and use criteria for the various types of scaffolds
• All employees working on scaffolds must be trained on:
o Electrical hazards
o Fall hazards
o Falling object hazards
o Use of the scaffold
o Material handling
o Load carrying capacities
Summary

Project Number:
Date 12/5/2007
• Fall protection is required at 6’ on all scaffold
• Scaffold must be within 14” of the structure
• Scaffold must be fully planked
• Scaffold must be designed and erected under the supervision of a qualified person
• Scaffold must be inspected prior to use by a competent person
The Cape Vincent project does not anticipate the use of scaffolding for the scope of the
project. If scaffolding is required however, the above requirements must be followed.
5.12 Blood Borne Pathogens

** Refer to Section 25. K of the Zero Injury Program Training Manual for further reference
Definition
As defined by OSHA 29 CFR 1910.1030(b), “Blood borne Pathogens” means pathogenic

microorganisms that are present in human blood and can cause disease in humans.
These pathogens include, but are not limited to, hepatitis B virus (HBV) and human
immunodeficiency virus (HIV)
Universal Precautions
“Universal Precautions” is the name used to describe a prevention strategy in which all
blood and potentially infectious materials are treated as if they are, in fact,
infectious, regardless of the perceived status of the source individual. In other words,
whether or not you think the blood/body fluid is infected with blood borne pathogens, you
treat it as if it is. This approach is used in all situations where exposure to blood or
potentially infectious materials is possible. This also means that certain engineering and
work practice controls shall always be utilized in situations where exposure may occur.
Rules to Follow
• Always wear personal protective equipment in exposure situations.

• Remove PPE that is torn or punctured, or that loses its ability to function as a
barrier to blood borne pathogens.
• Replace PPE that is torn or punctured.
• Remove PPE before leaving the work area.
Personal Protective Equipment
The first thing to do in any situation where you may be exposed to blood borne
pathogens is to ensure you are wearing the appropriate personal protective equipment
(PPE). For example, wearing latex gloves is a simple precaution that should always be
used in order to prevent blood or potentially infectious body fluids from coming in contact
with your skin. To protect yourself, it is essential to have an impervious barrier
between you and the potentially infectious material. Other PPE examples are:
goggles, face shields, aprons, mouth-to-mouth resuscitation masks, etc.
Emergency Procedures
In an emergency situation involving blood or potentially infectious materials, you should

always use Universal Precautions and try to minimize your exposure by wearing gloves,
splash goggles, pocket mouth-to-mouth resuscitation masks, and other barrier devices.

Project Number:
Date 12/5/2007
Clean up and disposal must be performed by a trained/competent person. Contact
the Director, Quality & Safety for assistance.
If you are exposed, however, you should:

1. Wash the exposed area thoroughly with soap and running water. Use non-
abrasive, antibacterial soap if possible.
o If blood is splashed in the eye or mucous membrane, flush the affected area
with running water for at least 15 minutes.
2. Report the exposure to your supervisor.
3. Contact the Environmental Safety & Health Services Group immediately!
5.13 Electrical
NOTE: Double insulated tools are not required to be grounded or tested.
All BP Alternative Energy and Subcontractor employees will comply with OSHA 1926.400
- .449
Refer to Section 8 of the Zero Injury Program Training Manual for further reference.
** ALWAYS treat all electrical circuits as being “HOT” or “LIVE” until known otherwise.
No “Hot work” is allowed on line electrical parts by any BP Alternative Energy personnel.
Electrical Subcontractors shall submit a pre-task plan outlining the reasons requiring work
on an energized part prior to beginning.
Only electrical equipment where the following is identified will be allowed to be used:
• Manufacturer’s name
• Voltage, current, wattage
• Other ratings as necessary
The BP Alternative Energy Lockout / Tagout Program must be followed when performing
repair / work on electrical equipment.
Temporary Power
The use of Ground Fault Circuit Interrupter systems (GFCI or GFI) will be used on all 120
volt, single-phase, 15 and 20-amp receptacles.
* More on Temporary Power can be found on page 8.A.-2 of the Zero Injury Program
Training Manual. Illumination
BP Alternative Energy Standards for required lighting in Foot Candles can be found on
Page 8.A.-4 of the Zero Injury Program Training Manual. If there are any questions or
concerns, please notify the Environmental Safety & Health Services Group immediately.

Project Number:
Date 12/5/2007
Mobile Cranes and Overhead Power Lines
During construction, mobile cranes may be required to pass either below or near existing
overhead power lines. This section will be amended, as BPAE determine if such a
situation exists. Section 10.8.4 of the Mobile Crane Safety Training Manual provides
limiting distances from power lines when the crane is both in operation and when
transiting with no load and boom lowered. In particular, during transit with no load and
boom lowered, the following distances apply:
Less than 0.75 kV 4 ft
0.75 – 50 kV 6 ft
50 – 345 kV 10 ft
345 – 750 kV 16 ft
750 – 1000 kV 20 ft
The following will be updated, once the site layout and intentions regarding crane
movement are finalized:
The lines are [xxx] kV and have [XX] feet of clearance from the ground. This clearance
dimension was verified by [Power Company] on [Date]. When the crane is boomed
down completely, the total height above ground of the boom, carriage, gantry, carbody,
housing, etc., is [Feet & Inches]. When the total height of the crane in this condition is
subtracted from the clearance of the wires, the remaining distance is [Feet & Inches].
The minimum clearance for these power lines according to the OSHA Crane Safety
Handbook is [Feet & Inches]. Thus the crane [Will / Will Not] be able to safely pass
under or near the power lines.
In all instances where a crane will pass under or near overhead power lines, a spotter will
be used to communicate with the crane operator. The spotter will be a competent person
skilled in the proper use of hand signals to direct crane operations. The spotter will
remain at a safe distance.
ELECTRICAL ASSURED GROUNDING

All electrical cord sets, portable electric hand tools, and any equipment connected by
cord and plug (except those that are permanently attached and not exposed) shall be
visually inspected before each day's use for external defects by the user. Supervisors
are responsible for implementing and enforcing the requirements of this program.
Ground-fault protection for personnel shall be provided on this equipment by using either
ground-fault circuit interrupters or an assured equipment grounding conductor inspection
program.
5.14 Environmental
Environmental reporting requirements will be addressed in the Hazardous Materials

Emergency Plan and the BP Alternative Energy Environmental Program.
5.15 Snake / Insect Bites and Dangerous Animals
When there is a chance of coming into contact with either snakes or insects of any
species whose bite may contain venom, the following shall guide operations and
response:

Project Number:
Date 12/5/2007
During orientation, snakes and / or insects that a BP Alternative Energy or Subcontractor
employee could come into contact with will be discussed. Training and education
pertaining to prevention of bites will be stressed. Awareness training will be provided by
TBD, site safety coordinator.
Prevention Tips:
1. Avoidance
2. Wear long pants per BP Alternative Energy dress code
3. Wear leather boots
4. Do not thrust hands or feet into any areas that you can not directly observe as
clear
5. Make noise when walking, drag your feet, kick up dust
If a bite does occur, typical symptoms may include:

• Bloody wound discharge
• Blurred vision
• Burning
• Convulsions
• Diarrhea
• Dizziness
• Excessive sweating
• Fainting
• Fang marks on skin
• Fever Increased thirst
• Numbness and / or tingling
• Loss of muscle coordination
• Rapid pulse
• Severe localized pain
• Skin discoloration
• Swelling at the site of the bite
• Weakness
If a bite does occur, engage the following response protocol:

1. Contact the BP Alternative Energy office and activate the Emergency Response
Team
2. Keep the patient quiet and still
3. Do not cut or wash the wound
4. Immediately bandage the bite site firmly but not too tight. The bandage should
extend above the bite site approximately 6 and 1/2 inches.
5. Immobilize the limb with a splint
6. Immediately transport the victim to the nearest hospital
Ticks are parasitic arthropods that feed on the blood of warm-blooded mammals and can
be carriers of diseases such as Lyme disease and Rocky Mountain Spotted Fever. Ticks
prefer to live in woods, tall grass, weeds and brush.
To avoid acquiring ticks:

1. Keep work areas clear of overgrown vegetation
2. Wear light-colored clothing with long sleeves and pants
3. Tuck clothing in particularly pants into socks and boots
4. Use an insect repellent containing DEET according to manufacturer’s instructions
5. Check body frequently for the presence of ticks

Project Number:
Date 12/5/2007
If a tick is found on the body:
1. Remove it using a pair of fine-tipped tweezers, grasping the tick as close to the
skin as possible and pulling slowly, steadily, and firmly
2. Once removed, clean area of skin with an antiseptic
3. Avoid crushing the body of the tick
4. Do not apply heat to the tick
Watch for the following early symptoms of Lyme disease:

• Fever and chills
• Muscle and joint aches
• Weakness or fatigue
• Headache
• Swollen lymph nodes
• Skin rash (typically a bull’s-eye appearance)
Seek medical attention of any of these symptoms appear or when bitten by a tick.
Treatment of tick bites will be recorded as first aid on site (FAOS).
Black bears inhabit certain areas of North America. They roam in forests, swamps, bogs,
farms and areas where they can obtain food easily. To avoid attracting black bears:
• Do not feed wildlife including squirrels and birds
• Keep garbage cans and dumpsters closed and locked if possible
If a bear is encountered:
1. Keep your distance
2. Slowly back away
3. Make noise
4. Avoid direct eye contact
5. Avoid getting near any cubs (or between the bear and the cubs)
6. Give the bear an escape route
7. Do not run (bears can out run humans and rapid movements can be perceived
as danger)
8. Do not climb trees (bears are excellent tree climbers)
If attacked by a black bear, fight back. Black bears have been driven away when
humans fight with rocks, sticks, or even bare hands.
5.16 Project Signs

The project shall provide signs to notify and warn the public and the construction team
where construction activities will occur. Three areas will have signs developed for use
during the construction period.
1. Jobsite office:
BP Alternative Energy project sign will be located at the construction office. This
sign will
indicate:
Project Name:
Owner:
Major Contractors:
BP Alternative Energy Contact Information

Project Number:
Date 12/5/2007
2. Wind Turbine Access Roads
The turbine access road signs shall indicate:
Construction Area - Authorized Personnel Only
Proper Personnel Protective Equipment Required
WTG’s accessed by road
Speed limit
3. Traffic control/alert signage

Signs will be positioned along public roads where construction work is occurring.
The signs will be positioned at each end of the construction work zone. If there is
an obstructed view due to hill or other feature, additional signs will be placed on
each side of the obstruction. It is the intention to relocate these signs as the
construction progresses.
6. ACCIDENT/INCIDENT REPORTING PROCEDURES

The Incident Reporting Matrix is to be used for classifying and reporting incidents on any
work site or facility. This matrix is a guidance tool that should be used in determining the
actions and notifications required, based on the type and severity of the incident. The
time lines and actions required post-incident are contained within the matrix. These must
be strictly adhered to.
Each project should develop a site-specific incident notification flowchart to insure that
the appropriate internal and external notifications are made after an incident has
occurred. Included in this flowchart should be any regulatory notifications that need to be
made, the types of incidents requiring such notifications and the responsible person who
is charged with making these notifications.
All incidents will be investigated and, depending on the level of severity, may be
investigated by BP Alternative Energy personnel who are not part of the site team or BP
HSSER group and local, state or federal regulatory officials in the case of a serious
incident where a fatality or serious fire, explosion or environmental event has happened.
.
Near Miss
Fill out the First Incident Report and immediately forward it to the persons noted on the
report. Report to be completed for Subcontractor as well as BP Alternative Energy near
misses.
Accident Resulting in Damage to Property and/or Equipment
• Fill out the First Incident Report and immediately forward it to the persons noted on
the report. Report to be completed for Subcontractor as well as BP Alternative
Energy property and/or equipment damage.
• If the damages to property or equipment is likely to exceed $500.00, immediate
notification to Operations Management and Chandler Thomas as noted on First
Incident Report Form is required.
Injury to a BP Alternative Energy Employee
• Insure that adequate medical attention is provided. Fill out the First Incident Report
and immediately forward it to the persons noted on the report.

Project Number:
Date 12/5/2007
• If employee must receive any medical attention beyond on-site first aid (i.e. visit to
the doctor, dentist, chiropractor, etc.)
o Employee must be accompanied to medical provider by a BP Alternative Energy
supervisor.
o Immediately contact the “Call in Claims Center” at 1-800-362-0000.
o Complete a Summary of Injury Report and forward as described on form.
o Record “OSHA recordable” cases on the job site posted OSHA 300 Form the day
of the injury
• If injury may result in a lost time injury immediate notification to Operations
Management and Safety Staff as noted on First Incident Report form is required.
Injury to Employee of a Subcontractor
• Fill out the First Incident Report and immediately forward it to the persons noted on
the report.
• Within 24 hours, obtain a copy of accident report from Subcontractor and forward it to
the same individuals as were sent the First Incident Report.
• Complete a Summary of Injury Report, and distribute it as described on form, along
with a copy of Subcontractor Accident Report.
** A Root Cause Analysis will be performed on all lost time cases and any other incidents
the Safety Department deems necessary.
Note: Refer to Crisis Management Plan in the event of a serious injury, incident,
and property damage, or fatality.
**Refer to Section 1.3, Item IV of this Plan for reporting procedures.

**Refer to Section 4 of the Zero Injury Program Training Manual for further policy and
procedures.
6.1 Site Security

Provisions of the site security plan are enumerated in detail in the Cape Vincent project
Scope of Work document Exhibit A.

Project Number:
Date 12/5/2007
7. DISRUPTION AVOIDANCE
Please reference BP Alternative Energy Disruption Avoidance manual and all applicable
forms will be utilized to assure that all unplanned shutdowns are avoided and that all
work is performed in the safest manner possible.
8. STRETCHING PROGRAM
BP Alternative Energy’s Stretch and Bend will take place on a daily basis prior to the
beginning of each shift. In addition to stretching, a safety discussion will take place at
this meeting to discuss site conditions, recent incidents, tool box talk topics of interest,
and to address any on site concerns. All BP Alternative Energy and subcontractor
employees are required to attend daily stretch and bend as a project team, unless prior
arrangements have been made and approved by Cape Vincent project management.
9. SEVERE WEATHER
Severe Weather / Electrical Storm Procedures
When severe weather or electrical storms move in to the area, weather service reports
must be monitored closely and we must be prepared to react should severe weather
become threatening. It is important to remember that the safety of project employees is
our number one priority. The turbines are designed to withstand high wind speeds and
are equipped with a lightning rod / grounding system, however evacuation of the turbines
may still be necessary in severe weather conditions. If severe weather is discovered in
the field, immediate notification should be given to the BP Alternative Energy office. If
radio transmission of the report is not confirmed, repeat radio transmissions until
notification is given by telephone or in person to the BP Alternative Energy office.
• Immediately after receiving a severe weather report, Project Management must

gather and assess the situation on site.
• Any uncertainties or questions should be directed to the local weather service for
information regarding our area specifically.
• A final decision regarding evacuation will be made by the Project Manager or

General Superintendent.
• If a decision to evacuate the towers is made, the broadcast announcement must

be made on all three radio channels - confirm that Cape Vincent has received the
announcement as well.
• Employees must evacuate not only the towers, but the areas immediately
surrounding the towers as quickly as possible - do not stop for finishing touches
or equipment other than turning any gas heating devices off.
• BP Alternative Energy must be informed of our decision to evacuate immediately

after the decision is made.
• Foremen are required to account for the personnel on their crews and report to
the office that everyone on their crew is accounted for (Including Subcontractors).
o Each foreman must choose a meeting point for their crew

Project Number:
Date 12/5/2007
o No crew member shall leave until entire crew is accounted for
• Crews must stay together until word is given to the foreman regarding either
returning to the towers or ending the work day - crews must not return to the
towers until an all clear is given.
• The decision to return to the turbines MUST be made by the Project Manager or
General Superintendent after closely reviewing weather reports and discussing
the issue with the weather services. A second opinion from a weather service
should be sought out. In all cases, if there is uncertainty, err on the side of safety.
As stated in BP Alternative Energy’s orientation, everyone on site has the right and
responsibility to stop unsafe work. If unsafe conditions are identified, including unsafe
weather conditions, supervision should be notified immediately so that proper and timely
decisions may be made.
10.0 ADDITIONAL POLICIES AND PROCEDURES

The following policies / procedures are completed and implemented by the project team
and are included in this Safety Plan by reference:
• Crisis Management Plan
• Emergency Response Plan
• Traffic Control Plan - see section 32 of Zero Injury Training manual
• Disruption Avoidance Training Manual
• Crane Management Program
• Forklift Management Program
• Guidelines for Issuance of Hot Work Permits
• Zero Tolerance Policy
• Violence Free Workplace Policy
• Harassment Free Workplace Policy
• EEO Policy
• BP Alternative Energy Bans Firearms in all offices, trailers, vehicles and project
sites
• BP Alternative Energy Mobile Crane Safety Program
• Environmental Program
Management of Change:
(Taken from BP Golden Rules of Safety) Work arising from temporary or permanent
changes to organization, personnel, systems, process, procedures, equipment, products,
materials or substances, and laws and regulations can not proceed unless a
Management of Change process is completed where applicable to include:
• A risk assessment completed by all impacted by the change
• Development of a work plan that clearly specifies the time scale for the change
and any control measures to be implemented regarding:
o Equipment, facilities and process
o Operations, maintenance and inspection procedures
o Training, personnel and communication
o Documentation
• Authorization of the work plan by the responsible person(s) through completion.

Project Number:
Date 12/5/2007

BP SDEIS App L Site Specific HSSE Cape Vincent

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Site Specific Health, Safety, Security, and Environmental Plan

Environmental Resources Management Southwest, Inc.

Cape Vincent Wind Energy Project

2. Responsibilities of BP Alternative Energy

5. Safe Work Programs

Cape Vincent Wind Energy Project

6. Accident / Incident Reporting Procedures

10. Additional Policies and Procedures

Cape Vincent Wind Energy Project

1.1 Safety Performance Measurements

BP Alternative Energy (BPAE) have established the following goals to

1. Total Recordable Incidence Rate (TRIR) 2.0

TRIR is a standard OSHA measurement based on 200,000 man hours of

In support of these goals the following leading indicators will be utilized:

1. Measure the effectiveness of Pre-Task Planning by scoring

Cape Vincent Wind Energy Project

BP Alternative Energy is committed to eliminating worker

1. To conduct their work in a safe manner.

2. To stop work immediately to correct any unsafe

3. To take corrective action so that work may proceed

It is the Company’s goal and expectation that no one will

Cape Vincent Wind Energy Project

Attach copies of meeting minutes, forms, logs, reports, etc.

1.4 Initial Implementation of Zero Injury Techniques

Cape Vincent Wind Energy Project

I. Pre-project/Pre-task Safety Planning:

The project schedule will be developed in contemplation of creating safe working

Cape Vincent Wind Energy Project

Subcontractors pre-qualification must include an assessment of safety performance and

II. Safety Orientation and Training: BP Alternative Energy

III. Drug and Alcohol Abuse Program:

IV. Incident Investigation:

Accident / Incident reporting procedures are outlined in detail in Section 6.

Cape Vincent Wind Energy Project

Plan Provisions: A program of safety recognition, with appropriate incentives, will be

VI. Short Service Employee Management:

• Viewing of the BP Immersion Series (Inclusion to SSE program is under review)

• ensure that a formal on-site safety orientation is developed and implemented

Cape Vincent Wind Energy Project

• accept responsibility for the safety of an assigned SSE through example

Cape Vincent Wind Energy Project

• Site or area specific Emergency Response Plans, including location of

• demonstrate a working knowledge of the applicable site safety policies and

Cape Vincent Wind Energy Project

The committee will be co-chaired by an hourly worker representative and a management

II. Committee Duties

Boundaries Have the authority to make recommendations of proposed HSSE solutions

Cape Vincent Wind Energy Project

IV. Work Observations

VI. Committee Postings

Cape Vincent Wind Energy Project

Specific safety responsibilities of the project manager, superintendent, foremen, workers,

The BP Alternative Energy Zero Injury Program Training Manual is incorporated by

2.2 Project Safety Coordinator

Assist Project Manager in:

Cape Vincent Wind Energy Project

Assist Superintendent with:

Obtain and review subcontractors’:

Cape Vincent Wind Energy Project

2.3 Project Manager

Pre-construction phase responsibilities:

Conduct a project safety analysis meeting, checking plans, specifications, and

Demand that subcontractors’ insurance meets contract requirements and contains