Environmental, Health

& Safety
(EH&S)
Manual

February 2007
 Environmental Health and Safety Manual
Policy No. 000 Policy Title: Table of Contents
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

Front Matter
EHS Manual Revision Sheet
EHS Manual Audit Sheet

Section 100 Administrative Policy Date / Revision

Policy Number EHS-101 EHS Policy 03/30/06 Rev 1
Policy Number EHS-102 Medical Records 03/30/06 Rev 1
Policy Number EHS-103 General Site EHS Rules 03/06/06 Rev 1
Policy Number EHS-104 EHS Management of Change 03/30/06 Rev 1

Section 200 OSHA Inspections

Policy Number EHS-201 OSHA Inspection Process 03/30/06 Rev 1
Policy Number EHS-202 OSHA Inspection Procedure 03/30/06 Rev 1

Section 300 Reporting and Recordkeeping

Policy Number EHS-301 OSHA Recordkeeping and Reporting 03/30/06 Rev 1
Policy Number EHS-302 EHS Incident Reporting 03/30/06 Rev 1
Policy Number EHS-304 EHS Monthly Reporting – Field Service 03/30/06 Rev 1

Section 400 EHS Training and Auditing

Policy Number EHS-401 EHS Training Requirements 03/30/06 Rev 1
Policy Number EHS-402 EHS Auditing Process 03/30/06 Rev 1

Section 500 Health and Safety Requirements

Policy Number EHS-501 Major Contractor Safety 03/30/06 Rev 1
Policy Number EHS-502 Control of Hazardous Energy 06/20/06 Rev 2
Lockout/Tagout (LOTO)
Policy Number EHS-503 Personal Protective Equipment 03/30/06 Rev 1
Policy Number EHS-504 Respiratory Protection 03/30/06 Rev 1
Policy Number EHS-505 Hearing Protection and Conservation 03/30/06 Rev 1
Policy Number EHS-506 Hazard Communications 03/30/06 Rev 1

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Policy No:000 Table of Contents

Section 500 Health and Safety Requirement Date / Revision

Policy Number EHS-507 Hazardous Waste Operations and 03/30/06 Rev 1
Emergency Response (HAZWOPER)
Policy Number EHS-508 Emergency Response 03/30/06 Rev 1
Policy Number EHS-509 Fall Protection 03/30/06 Rev 1
Policy Number EHS-510 Powered Industrial Trucks 03/30/06 Rev 1
Policy Number EHS-511 Electrical Safety 03/30/06 Rev 1
Policy Number EHS-512 Fire Protection and Prevention 03/30/06 Rev 1
Policy Number EHS-513 Confined Space Entry 03/30/06 Rev 1
Policy Number EHS-514 Walking and Working Surfaces 03/30/06 Rev 1
Policy Number EHS-515 Ladders and Scaffolding 03/30/06 Rev 1
Policy Number EHS-516 Bloodborne Pathogens 03/30/06 Rev 1
Policy Number EHS-517 Compressed Gas Cylinders 03/30/06 Rev 1
Policy Number EHS-518 Hot Work 03/30/06 Rev 1
Policy Number EHS-519 Radiation 03/30/06 Rev 1
Policy Number EHS-520 Machine Guarding 03/30/06 Rev 1
Policy Number EHS-521 Tools 03/30/06 Rev 1
Policy Number EHS-522 Cranes and Rigging 03/30/06 Rev 1
Policy Number EHS-523 Means of Egress 03/30/06 Rev 1
Policy Number EHS-524 Driver Safety 03/30/06 Rev 1
Policy Number EHS-525 Housekeeping 03/30/06 Rev 1

Section 600 Environmental Requirements

Policy Number EHS-603 Waste Management 03/30/06 Rev 1
Policy Number EHS-604 Toxic Substance Control Act 03/30/06 Rev 1

Appendix Title Policy No.

Appendix A Contractor Safety Forms EHS 501
A.1 Bid Solicitation/Contractor Qualification
Form
A.2 Contractor EHS Training Form
A.3 Contractor EHS Rules Form
A.4 Contractor Work Permit
A.5 Weekly Safety Meeting Form
A.6 Contractor Inspection Checklist

Appendix B Medical Records Access Request Form EHS 102

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Policy No:000 Table of Contents

Appendix Title Policy No.

Appendix C EHS Mgmt. of Change Forms EHS 104
C.1 Examples of Changes
C.2 Change Management Record

Appendix D OSHA Inspection Procedure Forms EHS 202

D.1 Notice to OSHA
D.2 Notice of Protest

Appendix E Recordkeeping and Reporting Forms EHS 301

and Charts
E.1 Recordability Flow Chart
E.2 Recordability Checklist
E.3 Recordability Guidance

Appendix F EHS Incident Reporting EHS 302

F.1 EHS Incident Report Form
F.2 EHS Incident Investigation Form
Appendix H Field Service EHS Monthly Report Form EHS 304
Appendix I EHS Training Forms EHS 401
Appendix J EHS Audit Tracking Form EHS 402
Appendix K Lockout/Tagout Forms EHS 502
K.1 LOTO Index
K.2 Facility Authorized Personnel List
K.3 LOTO Audit Form
K.4 LOTO Control Sheet
Appendix L Personal Protective Equipment Forms EHS 503
L.1 PPE Equipment Inventory
L.2 Hazard Assessment Form
Appendix M Respiratory Protection Forms EHS 504
M.1 Respirator Specification Form
M.2 Cartridge Change Out Schedule
M.3 Respirator Cartridge Selection Chart
M.4 Medical Evaluation Questionnaire
M.5 Fit Test Protocol
M.6 Fit Test Documentation Form
M.7 Respirator Cleaning Procedure
M.8 SCBA Inspection Form

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Policy No:000 Table of Contents

Appendix Title Policy No.

Appendix N Hearing Conservation Forms EHS 505
N.1 Area/Personal Noise Monitoring Survey
Record
N.2 Hearing Conservation Program Audit
Form
Appendix O Fall Protection Forms EHS 509
O.1 Fall Hazard Assessment Form
O.2 Fall Protection Evaluation Form
Appendix P Powered Industrial Truck Forms EHS 510
P.1 Fork Truck Designation
P.2 Sample Daily Fork Truck Maintenance
Checklist
P.3 Sample Fork Truck Training Evaluation
Appendix Q Fire Protection and Prevention Forms EHS 512
Q.1 Classes of fires and Appropriate
Extinguishers
Q.2 Sample Fire Prevention Checklist
Q.3 Sample Fire Extinguisher Inventory Form
Appendix R Confined Space Entry Forms EHS 513
R.1 Example Confined Space Entry Permit
R.2 Pre-Entry Checklist
R.3 Confined Space Inventory Form
Appendix S Waste Management Forms EHS 603
S.1 Exemptions From Hazardous Waste
S.2 Hazardous Waste Listings

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 Environmental Health and Safety
Manual
Date: 9/24/2007 Title: Environmental Health and Safety Manual
Revision Tracking Sheet

This sheet must be completed upon revision of any written S&W Energy
Solutions EHS policy or procedure contained in the EHS manual.

Policy or Rev.
Rev. # Revision Description Revised By
Procedure Date
 Environmental Health and Safety
Manual
Date: 9/24/2007 Title: Environmental Health and Safety Manual Review
Sign-Off Sheet

This sheet must be completed following the annual audit/review of the EHS
manual. The sheet must be signed and dated by the person authorized to
conduct the audit.

Audit Date Audit Conducted By

____________ ___________________________

____________ ___________________________

____________ ___________________________

____________ ___________________________

____________ ___________________________

____________ ___________________________

____________ ___________________________

____________ ___________________________

____________ ___________________________

____________ ___________________________

____________ ___________________________

____________ ___________________________

____________ ___________________________

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____________ ___________________________
 Environmental Health and Safety
Manual
Policy No. EHS-101 Policy Title: Environmental Health and Safety Policy
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 Policy ....................................................................................................................... 2

Page 1
Policy No:EHS-101 S&W EHS Policy

1 Purpose and Scope

The purpose of this Policy is to state S&W Energy Solutions commitment to achieving
environmental, health and safety (EHS) excellence. This commitment is the
responsibility of management and employees in all functions. S&W Energy will strive to
provide a safe and healthy working environment and to avoid adverse impact and injury
to personnel and to the environment and the communities in which we do business.
2 Policy
The well being of our employees while on the job, as well as the preservation of our
environment at our job-sites and surrounding community, has the highest priority at
S&W Energy. While we must provide quality work at a fair price for our customers in
order to survive as a business, we refuse to compromise health and safety or damage
our natural surroundings in the process. We believe that productive, safe, and
environmental-friendly work habits are one in the same.
Many accidents happen when people are in a hurry to get something done, or when
they settle into comfortable habits and become complacent. Mainstream thinking is “an
accident will never happen to me or affect me”. None of us have the ability to predict
when, where, or how an accident will happen. The tragedy is that most accidents would
take but a few seconds to avoid. No matter how busy or experienced you feel you are,
you MUST consistently take the extra time to do any task safely while simultaneously
thinking to avoid negative environmental consequence. You must make safety a core
value in your day to day routine.
This EHS manual and its contents outline the minimum requirements for a safe and
healthy work environment. Certain jobs will require additional protections. It is
extremely important that you understand HOW each task is to be done in a safe
manner. If you do not know, STOP and ASK before you commence your work. Your
safety and well being, as well as the safety of those around you, can be a reality only
through your constant and sincere effort. Simply talking or thinking about safety alone
cannot and will not make safety a fact. You must believe in it, embrace it, and DO it.
The S&W Energy Solutions’ EHS Policy includes very simple elements:
• Fostering a culture promoting compliance and encouragement of employees to raise
their policy questions and concerns, and prohibiting retribution.
• Development and implementation of standards and procedures which will facilitate
compliance by all S&W Energy Facilities, Sites, and personnel to this Policy and all
applicable laws.
• Providing continuous education and training that will enable employees to
understand the basic requirements of this Policy and applicable environmental,
health and safety laws.
• Conducting internal and/or external EHS audits on a periodic basis to ensure
compliance.
• Implementing a method for promptly reporting violations (and possible violations) of
this Policy without the fear of retribution.

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Policy No:EHS-101 S&W EHS Policy

• Establishing strict, but appropriate disciplinary actions to be taken with employees

who violate this Policy.
• Adopting, embracing, supporting, and ensuring employees understand the
philosophy that performance is never more important than compliance.
• Taking prompt remedial action when required.
• Promoting feedback and periodic evaluation to continually improve compliance with
this Policy.
• Evaluating and providing rewards for employees whose actions promote the tenets
of this Policy.
S&W Energy is committed to providing whatever it takes to ensure everyone works in
the safest environment possible. Company management and employees must work as
one to maintain a safe and healthy work atmosphere and to protect the workplace and
surrounding community from negative environmental impact. This goal can only be
achieved through a combined effort of working together.

We at S&W Energy view safety, not as a priority, but as a core VALUE in our business
philosophy. While priorities may change, values stay with us indefinitely.

Richard Wolf
President – S&W Energy Solutions, Inc.

Signature ______________________________________ Date ________________

NOTE: All S&W Energy employees shall review the EHS Policy upon first day of
employment and every year thereafter (annual requirement). The Policy shall be
reviewed and signed by Management on an annual basis.

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 Environmental Health and Safety
Manual
Policy No. EHS-102 Policy Title: Medical Records
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 Definitions ................................................................................................................ 2
2.1 Access – The right and opportunity to examine and copy................................. 2
2.2 Designated Representative............................................................................... 2
2.3 Employee Exposure Record ............................................................................. 2
2.4 Employee Medical Record ................................................................................ 2
2.5 Exposure (or Exposed) ..................................................................................... 3
2.6 Health Professional........................................................................................... 3
2.7 Record .............................................................................................................. 3
2.8 Specific Written Consent................................................................................... 3
2.9 Toxic Substance (Harmful Physical Agent) ....................................................... 3
2.10 Trade Secret ..................................................................................................... 4
3 Preservation of Records........................................................................................... 4
4 Access to Records ................................................................................................... 4
5 Trade Secrets........................................................................................................... 5
6 Training .................................................................................................................... 5
7 Auditing / Inspections ............................................................................................... 5
8 References............................................................................................................... 6
9 See Appendix B ....................................................................................................... 6

Page 1
Policy No:EHS-102 Medical Records

1 Purpose and Scope

This procedure/policy provides information on employees’, and/or their designated
representatives’, rights to gain access to relevant medical records and information. The
procedure also includes the requirements and guidelines of S&W Energy to maintain
files and records relevant to employee medical information. A physician or other health
care professional in charge of medical or exposure records can carry out access to
medical records on behalf of S&W Energy.
Requirements in this procedure are not intended to affect existing legal and ethical
obligations concerning confidentiality of employee medical information regarding
patient/employee disclosure with medical-care relationship.
This procedure/policy applies to any general industry employer who has access to
employee exposure or medical records, or other similar analyses. The medical records
referenced include work-related records in addition to medical records that are not
mandated by specific occupational safety and health standards.

2 Definitions
2.1 Access – The right and opportunity to examine and copy.

2.2 Designated Representative – Any individual or organization to

whom an employee gives written authorization to exercise a right of
access.
2.3 Employee Exposure Record – A record containing any of the
following types of information:
• Environmental (workplace) monitoring or measuring of a toxic substance or
harmful physical agent results; or

• Biological monitoring results which directly assess the absorption of a toxic

substance or harmful physical agent (not including alcohol or drugs); or

• Material Safety Data Sheets (MSDS) indicating the material may pose a
hazard to human health; or

• A chemical inventory or any other record which reveals where and when
used and identity of a toxic substance or harmful physical agent.
2.4 Employee Medical Record – A record concerning the health status
of an employee which is made or maintained by a physician, nurse, or
other health care professional which includes, but not limited to, the
following: medical and employment questionnaires or histories, results of
medical examinations and laboratory tests (pre-employment, baseline,
etc.), medical opinions and diagnoses, first aid records, treatments and
prescription information, and medical complaints.

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Policy No:EHS-102 Medical Records

2.5 Exposure (or Exposed) – Any employee subjected to a toxic

substance or harmful agent in the course of employment through any
route of entry (inhalation, ingestion, skin absorption, etc.) and includes
past exposure and potential exposure. It does not include situations
where the employer can demonstrate that the toxic substance or harmful
agent was not used or handled in the workplace at any given time.
2.6 Health Professional – A physician, occupational health nurse,
industrial hygienist, toxicologist, or epidemiologist, providing medical or
other occupational health services to exposed employees.
2.7 Record – Any item, collection, or grouping of information regardless of
the form or process by which it is maintained (i.e., paper document, x-ray,
microfilm, or automated data processing).
2.8 Specific Written Consent – A written authorization containing the
following information:
• The name and signature of the employee authorizing the release of
medical information;

• The date of the written authorization;

• The name of the individual or organization that is authorized to release the

medical information;

• The name of the designated representative (individual or organization) that

is authorized to receive the released information;

• A general description of the purpose of the release of the medical

information; and

• A date or condition upon which the written authorization will expire (if less
than one year).
2.9 Toxic Substance (Harmful Physical Agent) – Any chemical
substance, biological agent (bacteria, virus), or physical stress (noise,
heat, cold, vibration, repetitive motion) which:
• Is listed in National Institute for Occupational Safety and Health (NIOSH)
Registry of Toxic Effects of Chemical Substances; or

• Has yielded positive evidence of an acute or chronic health hazard in

testing conducted by the employer; or

• Is the subject of a material safety data sheet (MSDS) kept by or known to

the employer indicating that the material may pose a hazard to human
health.

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Policy No:EHS-102 Medical Records

2.10 Trade Secret – Any confidential formula, pattern, process, device, or

information or compilation of information that is used in an employer’s
business and that gives the employer an opportunity to obtain an
advantage over competitors who do not know or use it.
3 Preservation of Records
Unless a specific occupational safety and health standard provides a different period of
time, S&W Energy (and any other employer) shall assure preservation and retention of
records as follows:
The medical record for each employee shall be preserved and maintained for at least
the duration of employment PLUS thirty (30) years. However, the following records
need not be retained for any specific period:
• Health insurance claim records kept separately from S&W Energy’s
medical program and its records; or

• First aid records of one-time treatment and subsequent observations of

minor scratches, cuts, burns, splinters, and the like which do not involve
medical treatment, loss of consciousness, restriction of work or motion, or
transfer to another job; or

• The medical records of employees if they have worked less than one (1)
year for S&W Energy if they are provided to the employee upon termination
of employment.
The exposure record of each employee shall be preserved and maintained for at least
thirty (30) years.
4 Access to Records
Whenever an employee or designated representative requests access to a medical
record, exposure record, or analyses of exposure or medical records, S&W Energy shall
assure that the access is provided in a reasonable time, place, and manner.
If the record cannot be reasonably obtained within fifteen (15) working days, S&W
Energy shall discuss with the employee or designated representative the reason for
the delay and relay to them the earliest date when the record can be made
available.
S&W Energy shall ensure that a copy of the medical record is provided without cost to
the employee and that it is given to the employee for such a period that allows time for a
copy to be made (for their personal records).
A designated representative may gain access to an employee’s medical records,
exposure records, or analyses of exposure or medical records by specific written
consent from the employee ONLY. A sample Medical Records Access Request Form is
included in this procedure.

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Policy No:EHS-102 Medical Records

S&W Energy shall allow access to personnel medical records and information to OSHA
or any other governing regulatory agency upon request, however, the proper written
access must be provided prior to providing the records. Reference OSHA or other
regulatory agency guidelines and requirements before permitting this access.
If employer ever ceases to do business, the employer shall transfer all records
referenced in this procedure to the successor employer. The successor employer shall
receive and maintain these records.
If employer ceases to do business and there is no successor employer, the
employer shall notify the current employees of their rights to access records at
least three (3) months prior to employer ceasing to do business.
5 Trade Secrets
S&W Energy may choose to delete information from an employee medical record upon
request for access by the employee, designated representative, or physician, if the
record contains trade secret information (i.e., manufacturing processes, chemical
mixture data, etc.) as long as the requestor is notified of such action in advance. This is
allowed only if S&W Energy can prove or support the claim that the information deleted
is in fact a trade secret.
Where a treating physician or health care professional determines that the trade secret
information withheld or deleted is necessary to determine proper treatment or
emergency care for the employee, S&W Energy shall immediately disclose the specific
information despite the written confidentiality consents for disclosing trade secret
information. However, upon disclosure of such information, S&W Energy may elect to
have sequestering parties sign written confidentiality consents that information is to be
used for treatment purposes only and not disclosed or used in any other fashion.
6 Training
All S&W Energy employees shall be trained on the requirements and guidelines of this
procedure initially (upon first day of employment) and annually thereafter. The training
shall cover the following:
• The existence, location, and availability of records covered by this
procedure;

• The person responsible for maintaining and providing access to the

records; and

• Each employee’s rights of access of these records.

7 Auditing / Inspections
The Medical Records Access / Recordkeeping procedure shall be reviewed every 3
years. This procedure will be updated as necessary.

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Policy No:EHS-102 Medical Records

8 References
1. 29 CFR 1910.20 Access to Employee Exposure and Medical Records /
OSHA Recordkeeping and Reporting Requirements

2. 29 CFR 1910.1020 Access to Employee Exposure and Medical Records

3. 29 CFR 1926.33 (Same as 29 CFR 1910.1020)

9 See Appendix B
1. Medical Records Access Request Form

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 Environmental Health and Safety
Manual
Policy No. EHS-103 Policy Title: General Site EHS Rules
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

1. Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 Policies..................................................................................................................... 2
2.1 General ............................................................................................................. 2
2.2 Conduct ............................................................................................................ 3
2.3 Asbestos & Other Fibers ................................................................................... 3
2.4 Barricades and Notice of Work Activity ............................................................. 3
2.5 Confined Space Entry ....................................................................................... 4
2.6 Cranes and Motorized Equipment..................................................................... 4
2.7 Defective Equipment......................................................................................... 4
2.8 Demolition ......................................................................................................... 4
2.9 Emergency Response....................................................................................... 4
2.10 Excavations....................................................................................................... 5
2.11 Fire Protection................................................................................................... 5
2.12 Hazard Communication Program (HAZCOM) ................................................... 5
2.13 Hazardous Substance / Waste Management.................................................... 6
2.14 Hot Work ........................................................................................................... 6
2.15 Housekeeping ................................................................................................... 6
2.16 Ladders and Scaffolding ................................................................................... 7
2.17 Lead Paint......................................................................................................... 7
2.18 Lockout / Tagout ............................................................................................... 8
2.19 Personal Protective Equipment (PPE) .............................................................. 8
2.20 Reporting EHS Incidents................................................................................... 8
3 Safety Meetings ....................................................................................................... 9
4 Training .................................................................................................................... 9
5 Auditing / Inspections ............................................................................................... 9

Page 1
Policy No:EHS-103 General Site EHS Rules

1 Purpose and Scope

This policy provides general environmental, health and safety guidelines for all S&W
Energy employees at any S&W Energy Facility or Job-Site. The list highlights the
primary requirements of each site. The specific S&W Energy procedure or policy shall
be reviewed to obtain all requirements for each area covered here. General Site EHS
Rules also provides guidance pertaining to safety meetings (i.e., purpose and
frequency).
In addition to general EHS guidelines and rules, the Facility or Site shall generate any
site-specific requirements that are not referenced here. They shall be attached to this
procedure and indicated as “Facility or Site Specific”. The guidelines included in
Section 2 of this procedure may be amended, upon approval from the S&W Energy
EHS Manager, so that they reflect the requirements of the Site.
2 Policies

S&W Energy is committed to providing a safe and healthy work environment for
all employees, both on-site and Contractor Workers, and is committed to
avoiding adverse impact to the environment in performance of all site activities.

2.1 General

• Employees shall not work at any time when their ability is or may be impaired
as a result of the use of legal prescription drugs.
• All individuals, employees, contractors, visitors, etc. must be seated in moving
vehicles and seat belts worn while the vehicle is in motion.
• Fighting, horseplay, gambling, possession of firearms or other weapons,
possession or use of alcohol or illegal or unauthorized drugs is prohibited.
• Except in “Designated Smoking Areas,” smoking is not permitted on Facility
property.
• Eating and Drinking is only permitted in designated areas.
• All tools and equipment shall be inspected prior to use. Unsafe tools and
equipment shall not be used.
• Employees will perform work in such a manner as to assure at all times
maximum safety to self, fellow workers and the public and in accordance with
all Federal, State, and Local requirements.
• Employees who do not either feel qualified for or physically able to perform will
not attempt to work.
• Employees will perform work according to proper EHS practices and
procedures as posted, instructed, and prescribed.

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Policy No:EHS-103 General Site EHS Rules

• Employees will obtain specific instructions and/or clarifications from their

Supervisor before proceeding with work in situations where an EHS
requirement or procedure is not completely understood.
• Employees will observe and adhere to all warning signs, signals, and notices.
• Employees shall not be permitted to wear loose or flapping clothing or have
rags or other objects extending from pockets or belts when in the immediate
proximity of machinery, motors, engines, or rotating equipment.
• Employees shall never operate any machine or rotating equipment unless all
guards and safety devices are in place and in proper operating condition.

Immediately report every work-related Injury, Illness or Near Miss sustained at

the Facility or Site to your Supervisor.

2.2 Conduct
The following list is not a complete list but includes acts and behavior which are
prohibited and for which an Employee may be removed or dismissed from the Facility:
• Use of obscene or abusive language; racial, gender, or ethnic slurs.
• Failure to follow specific instructions or specifications.
• Deliberately damaging, defacing, or misusing Facility or Site property or the
property of others.
• Removing Facility or Site property from the premises without appropriate
authorization.
• Gambling, bookmaking or selling lotteries on Facility or Site property.
• Immoral or indecent conduct; sexual harassment.
• Illegally possessing, selling, distributing or manufacturing drugs on Facility or
Site property.
2.3 Asbestos & Other Fibers
• All fibrous materials must be accompanied by a MSDS and must be treated with
care.
• Unless a Facility or Site is documented to be asbestos free, the Employee shall
not disturb any fibrous material, but shall notify the Supervisor immediately if
any is found.
• Any Employee or Contractor performing asbestos abatement must comply with
requirements stipulated in Facility or Site procedures and any Federal, State, or
local regulatory requirements.
2.4 Barricades and Notice of Work Activity
• Facility or Site personnel shall erect all necessary barricades and notices to
safeguard all individuals, both Contractor Workers and site employees, during
the conduct of the any work performed at the Facility or Site.

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Policy No:EHS-103 General Site EHS Rules

• Barricades and notices are required around excavations, holes, or openings in

floors, roofs, elevated platforms, around certain types of overhead work, and
whenever necessary to warn people against falling objects or debris.
• Blinking lights must be used on protective barricades, where lighting is
inadequate.
• The use of Caution Tape, yellow and black tape, means access to areas may
be permitted only when it is safe to do so.
• Areas in which entry is not permitted will be taped-off with red and black
barricade tape and have signs similar to: “Danger - Do Not Enter” posted.
Employees shall not enter such areas.
2.5 Confined Space Entry
• Employees must be qualified or trained to perform the work (have appropriate
training per regulatory requirements) and briefed on the hazards of the confined
space(s) prior to beginning work.
• Employees shall use S&W Energy Confined Space Entry procedures, unless
another arrangement has been agreed upon.

No one will enter a PERMIT-REQUIRED CONFINED SPACE until a confined

space entry permit has been issued and posted.

2.6 Cranes and Motorized Equipment

• Employees must be properly trained to operate mobile equipment, complete
and pass applicable examinations and certifications to qualify to operate
equipment. (This may include DOT licensure).
• Only certified operators with valid certifications may operate cranes and other
motorized equipment at the S&W Energy Facility or Site.
2.7 Defective Equipment
• The Employee shall ensure that all tools and equipment shall be inspected prior
to use. Any defective equipment shall be tagged “OUT OF SERVICE” and
removed until it has been repaired or discarded.
2.8 Demolition
• All demolition work shall be conducted in such a manner as established in
accordance with the Engineering requirements.
2.9 Emergency Response
• All Employees and Contract Workers shall review and become familiar with the
Facility’s or Site’s Emergency Response Plan and procedures before beginning
assigned work.

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Policy No:EHS-103 General Site EHS Rules

• All Employees shall be familiar with the Facility’s or Site’s spill notification and
evacuation procedures as described in the Emergency Response Plan and
know where to muster in an emergency. Also, the Employee shall be made
aware of all emergency contacts and procedures for reporting fires.
• Spills must be properly managed to prevent harm or degradation of the
environment, access to storm water or sanitary sewer drains, and to ensure
worker safety.
• Evacuate the area if a spill involves hazardous, explosive, or flammable
materials.
• Supervisors are required to know who is on their job, and be able to account for
them at all times, especially after an evacuation.
• Supervisors must report missing personnel and their presumed location as
quickly as possible.
• Approved First Aid supplies shall be made available to all employees,
contractors, visitors, etc. in ample quantities at all times.
2.10 Excavations
• Prior to commencement of any excavation, the Employee shall notify the Shift
Supervisor, or designee.
• Any Employee shall ensure that excavation areas are properly barricaded and
have posted warning signs to ensure the safety of all individuals in the area.
2.11 Fire Protection
• The reason for discharging a fire extinguisher shall be discussed with all
Employees. After recharging, the extinguisher shall be returned to its original
location.
• Employees shall not obstruct in any way access to fire extinguishers, fire hose
stations or other fire apparatus, emergency eye wash stations and showers,
spill response equipment or other safety related equipment.
• Employees shall know the location and correct operation of the nearest fire
alarm and fire extinguisher.
• Employees shall know the location of designated fire exits and shall not block
access to those exits.
• Employees shall not refuel equipment while it is running or when hot.
• Employees shall keep combustible and flammable materials away from hot
surfaces and ignition sources.
• Employees will store flammable materials in approved cabinets.
• Reference the Site’s Fire Protection and Prevention procedure for detailed
requirements and precautions.
2.12 Hazard Communication Program (HAZCOM)
• Any HAZARDOUS MATERIALS brought on site must be accompanied by the
associated MSDS. They shall be approved by the Facility or Site prior to
bringing them on-site. The MSDS must be provided to the Facility

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Policy No:EHS-103 General Site EHS Rules

Representative, or designee. All hazardous material must be in an approved

container, including all flammable substances.
• All containers shall be properly labeled as to the contents and physical and
health hazards at all times.
• Each Employee must be aware of the Facility or Site HAZCOM program that
includes at a minimum: complete MSDS’s on hand at the work site for each
chemical used, chemical inventory, adequate training for all personnel which
covers: physical and health hazards of all products, proper handling of the
products, and personal protective equipment.

A copy of the Facility or Site’s HAZCOM program and the Facility or Site
MSDS inventory will be made available to any Employee or Contractor
Worker upon request.

2.13 Hazardous Substance / Waste Management

• Employees shall properly handle all hazardous and toxic substances and
materials utilized in its work according to Site procedures and regulatory
standards.
• Propane and compressed gas cylinders must be chained upright and on
approved carriers when moved. Reference Hazardous Material Deliveries and
Compressed Gas Cylinder Procedures for detailed requirements and
guidelines.
• All Employees are responsible for the proper disposal of construction debris
generated by their work at the Facility or Site.
• Enclosed disposal chutes are to be used whenever waste materials are to be
dropped more than 10 feet.
• Employees will comply with requirements of S&W Energy’s Hazardous Material
Handling and Waste Management procedures while on-site.
2.14 Hot Work
• Employees shall not perform hot work (welding, cutting, brazing, and burning
operations) without obtaining a Hot Work Permit.
• All employees shall comply with S&W Energy’s Hot Work procedure and all its
requirements.
2.15 Housekeeping
• Employees shall maintain all walkways and work areas clear of obstructions,
tripping hazards, and debris.
• All oily rags must be disposed of in appropriate containers designed for oily
wastes.

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Policy No:EHS-103 General Site EHS Rules

2.16 Ladders and Scaffolding

• All ladders must be approved for use before being put into service. Each user
must inspect ladders visually before using.
• If it is necessary to place a ladder in or over a doorway, barricade the door
and/or post warning signs.
• Metal ladders must not be used for electrical welding, or near electric lines or
services.
• Ladders must be tied off, with the user wearing a safety harness, if it is
necessary to use a ladder on top of a scaffold or close to the edge of an
elevated platform, roof, or floor opening.
• The top of the ladder must extend at least three (3) feet beyond the supporting
object, when used as access to an elevated work area.
• Sound, rigid and suitable footing is required for all scaffolds and no unsuitable
objects shall be used for support, such as barrels, boxes, bricks or concrete
blocks.
• Guardrails and toe boards shall be installed in conformance with regulatory and
engineering requirements and standards.
• Where persons are required to pass underneath, all scaffolds will be provided
with ½” mesh screening between the tow board and guardrail.
• Scaffold and components shall be capable of supporting four times its intended
load without failure.
• Personnel must wear properly tied-off safety harnesses on scaffold platforms
not equipped with standard handrails or completed decking. Safety harnesses
must be secured before stepping onto the scaffold, and must not be removed
until personnel are clear of the scaffold. Harnesses must be tied off to
independent lifelines or building structures – one lifeline per person.
• No one is allowed to ride a rolling scaffold while it is being moved. All tools and
materials must either be removed or secured on the deck before moving.
Pulling the scaffold along from overhead while on the scaffold is prohibited.
• Brick, tile, block or other similar materials may not be stacked higher than 24
inches on the scaffold deck.
• All scaffolds shall be erected and maintained in accordance with regulatory and
engineering requirements and standards.
• Employees shall comply with S&W Energy’s Ladders and Scaffolding and Fall
Protection Procedures.
2.17 Lead Paint
• For operations comprising of the grinding, welding, or burning of lead painted
surfaces a Supervisor must be notified prior to the start of work. If it is not
known whether the surface has lead paint on it, the Facility Manager or
designee shall be consulted.
• The area shall be posted that work is being conducted on lead painted
surfaces.

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Policy No:EHS-103 General Site EHS Rules

• Work practices such as using HEPA vacuum and exhaust ventilation will be
applied.
2.18 Lockout / Tagout
• Employees must get approval from the Shift Supervisor, or designee, BEFORE
beginning work on Locked Out or Tagged Out equipment.
• All electrical wires and circuits are to be considered energized unless power is
definitely disconnected and the applicable switches locked and tagged out.
• All Employees shall comply with S&W Energy’s Lockout / Tagout procedure.
2.19 Personal Protective Equipment (PPE)
• Employees shall wear flame resistant or 100% cotton long sleeved shirts and
long pants while involved in tasks with exposure to flames or electric arcs.
Shirts with sleeves (long or short) will be worn at all other times.
• ANSI-approved hard hats shall be properly worn by all Employees and
Contractor Workers and visitors throughout the Facility, except in office areas
and in other designated areas. (Metal hard hats are prohibited.)
• ANSI-approved safety glasses with side shields shall be properly worn by all
Employees and Contractor Workers and visitors throughout the Facility, except
in office areas.
• Both chemical goggles and face shields shall be worn when working with or
loading / unloading chemicals such as ammonia, sulfuric acid, caustic etc.
• ANSI approved safety shoes must be worn by all Employees and Contractors
working on site. No sneakers or dress shoes will be allowed.
• Approved full body harnesses and lanyards shall be properly used when
working in areas where a potential fall hazard exists.
• Approved hearing protection shall be properly used in designated areas. When
in doubt of noise levels, hearing protection shall be used. Double hearing
protection must be used when working in or around the turbines/generators
when in operation with enclosures open.
• Respiratory protection will be properly used where administrative or engineering
controls fail to reduce air contaminants to within OSHA prescribed limits.
Employees shall comply with S&W Energy’s Respiratory Protection procedure,
or equivalent procedure of their own.
• Other approved PPE such as face shields, protective clothing, gloves, etc. shall
be used by Employees where the risk of injury or illness may be prevented by
its use.
• All requirements as described in S&W Energy’s Personal Protective Equipment
/ Job Safety Analysis procedure shall be met.
2.20 Reporting EHS Incidents
• Employees are responsible for reporting any work-related injury/illness or near
misses (or environmental incidents) to the Facility Manager or Supervisor as
soon as they become known.

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Policy No:EHS-103 General Site EHS Rules

• The Facility Manager or Supervisor will complete all required paperwork per
S&W Energy’s EHS Incident Reporting and OSHA Recordkeeping Procedures.
3 Safety Meetings
Supervisors at all work locations are responsible for conducting safety meetings with
assigned personnel, including contractors and sub-contractors.
These meetings may be brief 15-20 minute sessions or as long as 30-60 minutes.
Meetings held for training purposes may require additional time.
Meetings shall be held at a frequency established by the Facility or Site but at least
monthly.
ALL safety meetings shall be fully documented on a general form. The record shall
indicate the time, date, and location of meeting, topics covered, duration, name of
instructor (person presenting material), and all personnel attending. Records shall be
kept for one year.
In addition to the regular frequency of safety meetings, a safety meeting shall be
conducted following an injury or near-miss to warn assigned personnel in an effort to
prevent duplicate accidents or injuries.
4 Training
All Employees shall be trained on the guidelines of this procedure initially, prior to work
at the Facility or Site. Refresher training is required any time there is a change to the
Site’s general rules.
5 Auditing / Inspections
This procedure and policy shall be reviewed annually. Safety meeting records may be
reviewed as part of this audit or inspection. The procedure / policy will be updated, as
necessary.

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 Environmental Health and Safety
Manual
Policy No. EHS-104 Policy Title: EHS Management of Change
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 Definitions ................................................................................................................ 3
2.1 Change ............................................................................................................. 3
2.2 Change Management Record (CMR) ............................................................... 3
2.3 Controlled Document ........................................................................................ 3
2.4 Design Review .................................................................................................. 3
2.5 Piping and Instrumentation Diagrams (P&ID) ................................................... 3
2.6 Replacement-in-Kind ........................................................................................ 3
2.7 RFC .................................................................................................................. 3
2.8 Temporary Change ........................................................................................... 4
3 Training .................................................................................................................... 4
4 Auditing / Inspections ............................................................................................... 4
5 References............................................................................................................... 4
6 See Appendix C ....................................................................................................... 4

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Policy No:EHS-104 EHS Management of Change

1 Purpose and Scope

The purpose of this policy is to introduce the need to manage changes (normal,
permanent, and/or temporary changes) to ensure that environmental, health and safety
(EHS) factors has been included as part of the evaluation process. Facility or Site
process, equipment, or operational changes must have appropriate review and
authorization prior to implementation to ensure they do not introduce unacceptable risk
or hazards. The EHS review portion of the Management of Change process is
implemented at Facilities and Sites so as not to compromise the safety and health of
employees (and the community) and to safeguard the surrounding areas from
environmental catastrophes. Management of Change applies to all changes other than
those classified as “replacement-in-kind”.
Although maintenance crews typically conduct changes, all personnel must be aware of
this policy as changes can be proposed by all employees. Everyone must understand
the process and review required to implement a change and understand what
constitutes a change. Many times what may appear to be a minor revision may have
much larger implications. It may lead to injuries, accidents, permitting violations, etc.,
costing companies large sums of money and penalties, not to mention seriously injuring
employees if not handled appropriately. Therefore, proper authorization and analysis is
needed.
A Facility or Site is required to have an overall Management of Change Procedure.
EHS is only one part of the review and analysis of that process. This policy is not
meant to replace any existing Management of Change procedure or process but to re-
emphasize the need for review of all changes and to ensure EHS is included as part of
that review. Definitions and sample Request Forms are included with this policy as a
tool to assist Facilities or Sites with implementing Management of Change procedures.
It is NOT intended as a stand-alone procedure. The EHS Management of Change
Policy should be incorporated into the Facility or Site’s overall Management of Change
procedures.
Prior to implementing ANY change, the proper analyses must be conducted and
approved and the appropriate authorizations, most importantly for this policy EHS
authorization, obtained (and all documented). NO CHANGE SHALL BE MADE OR
IMPLEMENTED WITHOUT THESE REQUIREMENTS BEING MET.

All Facilities or Sites must have a formal system for identifying, assessing,
authorizing, and implementing changes. Management of Change includes
documentation and reviews that manage change by addressing the technical
basis of the change, the impact on the environment, safety, and health,
modification to operating procedures, necessary time periods involved,
authorizations required, training of affected personnel, and updating process
safety information.

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Policy No:EHS-104 EHS Management of Change

2 Definitions
2.1 Change
All modifications to Facilities or Sites (buildings, structures, etc.), equipment,
procedures, processes, operations, raw materials, and processing conditions other
than “replacement in kind” are considered a change. Changes may include
modifications of operation outside previously approved operating limits (EHS
Procedure or Permit), process technology changes (rates, raw material,
experiments, catalysts, etc.), or equipment changes (materials of construction,
equipment specifications, piping arrangements, etc.). A list of typical modifications
classified as changes (and subject to Management of Change) is included as a
reference in the Attachment section of this policy document.
2.2 Change Management Record (CMR)
A form used to document and control the progress of a modification from initiation
through completion of the change. This is also referenced as a Change Request
Form. Reference the Attachment section for an example form.
2.3 Controlled Document
A document whose contents and distribution are “controlled” through the
Management of Change process. Typically these documents include P&ID's,
operational procedures, training manuals, permits, etc.
2.4 Design Review
A review conducted by the appropriate personnel authorized to ensure the change
has been engineered with the appropriate safety, health, and environmental
considerations. This includes one of the authorizations required to implement a
change.
2.5 Piping and Instrumentation Diagrams (P&ID)
Flow charts or system diagrams of operational units that indicate specific
information that can be used in training, troubleshooting, and safe operation
auditing.
2.6 Replacement-in-Kind
Replacement of an instrument, electrical, piping, equipment, apparatus or other
component with an identical part or an equivalent approved and specified by the
applicable Engineering standard. It also includes replacement of procedures or
processes that are the same (i.e., updates). A list of typical modifications classified
as Replacement-in-Kind (and NOT subject to Management of Change) is included
as a reference in the Attachment section of this policy document.
2.7 RFC
Request for Change.

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Policy No:EHS-104 EHS Management of Change

2.8 Temporary Change

A change in piping or procedures for the purpose of accomplishing something not
covered by typical operations will be considered a temporary change. It is
removed as soon as the operation is completed.
3 Training
All S&W Energy employees (at a Facility or Site or Field personnel) shall be trained on
the guidelines of this policy.
Facility (or Site) Managers, technical staff, and supervisors must be trained in the
overall Facility or Site Management of Change Procedure or process and in the detailed
step-by-step procedures through which change is implemented. Training on this policy
is included.
Operators, craftsmen, and other personnel whose job function could involve them in
implementing a change must be trained in the Facility or Site Management of Change
Procedure or process, which includes this policy.
Initial training is required and refresher training required every three years.
4 Auditing / Inspections
The EHS Management of Change Policy shall be reviewed every three years. The
procedure will be updated as necessary.
All documentation (Controlled Documents and Change Request Forms with
supplemental information) shall be retained for the duration of the Policy. These
records and documents may be reviewed during an audit or inspection.
5 References
A. 29 CFR 1910.119, Process Safety Management
B. Plant Guidelines for Technical Management of Chemical Process Safety
6 See Appendix C
C.1 Examples of Changes and Replacement-in-Kind (2 Pages)
C.2 Example Change Request Form (2 Pages)

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 Environmental Health and Safety
Manual
Policy No. EHS-201 Policy Title: OSHA Inspection Process
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Scope....................................................................................................................... 2
2 General Guidelines .................................................................................................. 2

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Policy No:EHS-201 OSHA Inspection Process

1 Scope
Workplace inspections by OSHA compliance officers may occur at any time. Ensuring
full compliance with all applicable standards at all times will minimize any impact that an
inspection may have. This policy outlines the basic OSHA inspection process and
criteria.
2 General Guidelines
Under laws established by the Department of Labor, OSHA inspections proceed as
follows:
1. Inspections can be initiated either by an employee complaint or the Labor
Department's initiative.
2. Advance notice of a safety and health inspection without Labor Department
authorization is prohibited.
3. Compliance officers must present credentials to the owner, operator, or agent in
charge. If the inspection was the result of a complaint, the compliance officer must
present a copy of the complaint prior to the conclusion of the inspection.
4. Compliance officers are entitled to enter without unreasonable delay.
5. A compliance officer may gain entrance by presenting credentials to any employee if
minimum delay fails to produce the manager in charge.
6. Investigations and inspections must be conducted during regular working hours or at
other reasonable times.
7. An authorized employee representative(s), as well as employer representatives, may
accompany the compliance officer during the inspection.
8. In the absence of an authorized employee representative, the compliance officer
may consult with a reasonable number of employees.
9. The compliance officer checks the place of employment, and all pertinent conditions,
structures, machines, apparatus, devices, equipment and materials.
10. The inspection may include possible hazards reported before or during the
inspection.
11. A citation will be issued for any violation.
12. If a condition poses imminent danger, the inspector has the authority to request that
it be corrected immediately. If the situation is not abated, he/she can secure an
injunction through the U.S. District Court, requiring immediate correction or
suspension of the work until it is corrected.
13. The citation will detail the violation and the standard, which has been violated. A
definite length of time for correction (abatement) will be set.
14. A copy of the citation must be posted at or near the place where the violation
occurred. For our purposes, the bulletin board shall be acceptable.
15. An employee or his/her representative may appeal the time given for correction or
the penalty and ask for more severe treatment.

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Policy No:EHS-201 OSHA Inspection Process

16. The employer may appeal the citation and proposed penalty providing it is appealed
within 15 working days of the date of the citation or the right to appeal is lost.
17. When appealed, the “violations” is referred to the Solicitor’s office for review prior to
legal action being taken or appeal to the Review Commission (Federal, not State
programs).
18. The Review Commission is a three-person body independent of the Labor
Department established for the specific purpose of hearing appeals. It should be
noted that if the employee representative feels that the inspector was too easy on
the contractor, he/she could also appeal the proposed penalty or the time of the
abatement, asking for more severe treatment. If the employer does not file the
Appeal within the stipulated fifteen days it loses the right of appeal.
19. When the Review Commission receives the Appeal from the Department of Labor, a
notification of receipt will be sent to the Department of Labor, the employer, and the
employee representatives setting time and place for hearing and appointing a
hearing examiner. At all hearings there will be three parties--The Department of
Labor, the employer, and the employee representatives. The hearing examiner will
act as presiding officer and will issue a ruling. The examiner has the authority to
subpoena records. It is optional at these hearings as to whether or not the parties
are represented by legal counsel, and the President will make this decision.
20. The hearing examiner's ruling will be forwarded to the Review Commission which
can concur in the rulings, modify, or vacate the rulings and can even increase the
proposed penalty, based on the testimony at the hearing.
21. If the company wishes to contest the Review Commission's determination, our legal
counsel will take the matter to the U.S. Court of Appeals.

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 Environmental Health and Safety
Manual
Policy No. EHS-202 Policy Title: OSHA Inspection Procedure
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Scope....................................................................................................................... 2
2 General .................................................................................................................... 2
3 Procedure ................................................................................................................ 2
3.1 Procedures Prior to Arrival of a Compliance Officer.......................................... 2
3.2 Upon Arrival of a Compliance Officer................................................................ 3
3.3 At the Opening Conference............................................................................... 3
3.4 Employee Representation................................................................................. 4
3.5 Company Records ............................................................................................ 4
3.6 During the Inspection ........................................................................................ 5
3.7 Employee Interviews......................................................................................... 5
3.8 Closing Conference .......................................................................................... 6
3.9 After the Inspection ........................................................................................... 6
3.10 Upon Receiving a Citation................................................................................. 6
3.11 Citation Process................................................................................................ 6
4 See Appendix D ....................................................................................................... 7

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Policy No:EHS-202 OSHA Inspection Procedure

1 Scope
This policy is an outline of the procedures required prior to, during, and after an
inspection by OSHA compliance officers.
2 General
The Occupational Safety and Health Act was enacted in 1970, with its purpose being "to
assure so far as possible every man and woman in the nation safe and healthful
working conditions and to preserve our human resources." The management of S&W
Energy is in complete agreement with the purpose of the act and expects each project
to comply with all regulations of the act.
Administration and enforcement of OSHA are vested in the Secretary of Labor and
Occupational Safety & Health Review Commission or with the State Labor Department
in those states with approved programs. The act is enforced by job site inspections by
OSHA Compliance Officers to determine if the regulations provided in the act are being
complied with by employers. Violations of the act as determined by the compliance
officers (COSH) during their inspections will result in financial penalties, up to
$10,000.00 per violation. S&W Energy accepts the enforcement procedures as
provided in the act, but realizes that if certain procedures are followed by the projects
before, during, and after the inspections, the results of the inspections will be much
more favorable to the Company. For this reason, the following procedures to be
followed during an OSHA inspection have been established.
3 Procedure
3.1 Procedures Prior to Arrival of a Compliance Officer
1. The Project Manager (or designee) will designate the General Superintendent,
Resident Engineer, and/or Safety Supervisor, to accompany the Compliance
Officer during the inspection. This employee must be thoroughly familiar with the
work S&W Energy is doing on the project, the work areas in which S&W Energy
is involved, the equipment on the project belonging to or under the control of
S&W Energy, and any subcontractors and their work on the project. He/she
must also be thoroughly familiar with the S&W Energy EHS Manual and the
safety program in effect on the project.
2. All records as required by OSHA (OSHA 300 Form, OSHA 101 Form, Crane
Inspection Reports, etc.) are to be maintained and available.
3. A camera (preferably digital) will be located on the project and available.
4. The OSHA poster will be posted in a location readily observable by all employees
where they normally report for work daily.
5. All safety activities on the project are to be documented; i.e., safety meetings
(when held, who attended, topic covered, etc.), employee disciplinary measures
taken for safety violations, correspondence to other contractors or the owner
about unsafe conditions, etc.

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Policy No:EHS-202 OSHA Inspection Procedure

3.2 Upon Arrival of a Compliance Officer

1. The Project Manager or Safety Supervisor will verify the Compliance Officer's
credentials, making sure the credentials are current. He/she will obtain a
business card from each compliance officer, or record the name, address and
phone number of each one.
2. He/she will determine why the Compliance Officer wants to inspect the project.
The reason for the inspection will help in making the decision as to whether or
not to require a search warrant.
3. DO NOT REQUEST SEARCH WARRANTS UNLESS INSTRUCTED TO DO SO.
Search warrants will be requested only after consultation with S&W Energy
Corporate Safety Department and/or agreement by the corporate legal staff.
4. If the Compliance Officer is at the project as the result of an employee complaint,
the Project Manager or Safety Supervisor will ask for a copy of the complaint.
5. The Project Manager or Safety Supervisor will call the S&W Energy Manager of
Safety immediately after obtaining the information in Nos. 1, 2 and 4 above, and
before allowing the compliance officer to go to the work areas.
6. The Project Manager or Safety Supervisor will notify all project supervisors that
the project is about to be inspected and the reasons for the inspection.
7. The Project Manager or Safety Supervisor will request an opening conference if
the compliance officer does not call for one.
3.3 At the Opening Conference
1. The Project Manager, General Superintendent, Resident Engineer, and the
Safety Supervisor (as applicable) are to be present.
2. Inform the subcontractors of the inspection and offer them the opportunity to be
present. It is not mandatory that they attend; the choice is theirs.
3. Detailed notes must be taken of everything discussed.
4. If the inspection will disrupt an important meeting or critical phase of work,
explain this to the compliance officer and arrange for the inspection to take place
at a later time/date.
5. All publications and documents given by the compliance officer should be kept
and marked with the name of the Compliance Officer and the date of its receipt.
6. The compliance officer's length of time with OSHA, education, prior work
experience, and knowledge of project related work should be noted.
7. If more than one Compliance Officer is involved, it should be determined if they
plan to make the inspection in one group or split into two (2) or more groups. If
they want to divide into two (2) or more groups, it should be determined if it will
present a problem for S&W Energy to provide a qualified employer
representative for each group. If we are not in a position to provide an employer
representative for each group, this should be discussed with the compliance
officers. If they still insist on dividing into groups, the S&W Energy Manager of
Safety should be contacted for direction.

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Policy No:EHS-202 OSHA Inspection Procedure

8. If the project involves many contractors, an agreement should be reached with

the compliance officer that he/she will inspect S&W Energy in a short period of
time, and will not involve us in a prolonged inspection (some project inspections
have taken over a week) while he/she is inspecting us and every other contractor
on the project simultaneously.
9. At all times prior to, during, and after the inspection, all S&W Energy employees
should act in a cooperative, professional, businesslike manner, never entering
into personal arguments with the Compliance Officer or volunteering information.
3.4 Employee Representation
1. One authorized representative of the employees shall be given the opportunity to
accompany the Compliance Officer. If there is a safety committee, one member
of the committee may be designated as the employee representative.
2. There need not be an employee representative for each inspection; however,
where there is no authorized representative the compliance officer will probably
talk to a number of employees about safety and health matters on the site. For
this reason, we always prefer one employee representative to accompany the
inspection team.
3. Employees interviewed during the inspection are not considered as part of the
inspection for "walk around" purposes. Employees should be interviewed in
private, and the Employee Representative should not be with the inspector
during the interview. The name of the employee interviewed, the area he/she is
working in, and any item/area he/she is obviously making comment on or
reference to should be recorded.
3.5 Company Records
1. The Compliance Officer is allowed to look only at the OSHA records required to
be kept by us: OSHA 300/300 A form, OSHA 301 form, Crane Inspection
Records, etc. A copy of any of these records or any other records is not to be
given to the Compliance Officer.
2. The Compliance Officer is not to look at any of our Company safety manuals.
3. The Compliance Officer is not to look at any safety inspection reports made by
our Safety Engineering or Quality Control personnel, insurance carrier, etc., other
than those reports required by OSHA. This includes not giving or letting the
Compliance Officer look at any such reports made on subcontractor's activities.
The officer may look at, but not have a copy of, safety committee minutes, check
lists, or safety program plans.
4. Areas, which include, but are not limited to, our methods and operational
procedures or our erection/form systems, quality control procedures, etc. should
be identified as trade secrets. This will also include all negatives, prints or
photographs, and environmental samples which should be labeled "Confidential -
Trade Secret" and normally not disclosed.

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Policy No:EHS-202 OSHA Inspection Procedure

3.6 During the Inspection

1. The Project Manager, General Superintendent, Resident Engineer, and/or Safety
Supervisor (as applicable) should accompany the Compliance Officer at all times.
They should never allow the Compliance Officer to have free and unlimited
access to the project.
2. The inspection should be controlled. The Compliance Officer should be treated
as would a guest in a house; he/she is there with our permission and will be
expected to follow all instructions given him/her and will be required to conduct
the inspection in such a manner that it does not disrupt the scheduled work.
Remember that it is our project site - not OSHA's. The Compliance Officer is to
be treated as any other visitor under our control while on our project.
3. Detailed notes of everything seen, discussed, and done by the Compliance
Officer should be taken.
4. Photographs of everything the Compliance Officer photographs should be taken.
If the equipment, work area, etc. can be photographed from a more favorable
position (different angle, greater distance, etc.), photograph it from the different
position.
5. No employee is to perform demonstrations for the Compliance Officer. Example
- if a truck is idle and the Compliance Officer asks a person to operate it so
he/she can see if the horn or back-up alarm is working, the request should be
refused. The Compliance Officer should be allowed to see the work only as it is
normally being done.
6. The Compliance Officer's questions should be answered to the best of a person's
knowledge, but further information should not be offered. No evidence against
oneself should be offered.
7. Orders, such as "clean up that trash", during the inspection to have conditions
corrected that have not been noticed by the Compliance Officer should not be
given. The immediate abatement of an alleged violation will not preclude a
citation by the Compliance Officer, and may alert him/her to the condition.
8. If it is not fully understood what a Compliance Officer does or comments on,
questions should be asked and all facts recorded, even if the inspection is
interrupted.
3.7 Employee Interviews
1. Private interviews with S&W Energy employees by the Compliance Officer
should not be allowed if they will be disruptive to the work process. If the
compliance officer insists on having private interviews, it shall be done in
accordance with the section on Employee Representation.
2. Record the names and employer of all personnel interviewed and, if we are
present, the content of such interviews.

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Policy No:EHS-202 OSHA Inspection Procedure

3.8 Closing Conference

1. The Project Manager, General Superintendent, Resident Engineer, and the
Safety Supervisor (as applicable) will be present.
2. There should be notes of everything discussed and records of what documents
were distributed by the Compliance Officer.
3. No questions concerning the inspection should go unanswered. If the
Compliance Officer feels that a violation exists on the project, abatement dates
he/she plans to submit for each condition should be thoroughly discussed. If a
condition cannot be corrected within the abatement date, it should be discussed
with the Compliance Officer.
4. No estimate of abatement time needed to correct any alleged violations should
be given.
5. Give the senior compliance.
3.9 After the Inspection
1. The Manager of Safety should be called to discuss the preliminary results of the
inspection.
2. The Manager of Safety should immediately be sent copies of all notes and
photographs taken.
3. The Manager of Safety shall call the S&W Energy Corporate Safety Department
to discuss the preliminary results of the inspection.
3.10 Upon Receiving a Citation
1. The Manager of Safety should be notified immediately, as there will be only a
limited period of time (15 working days) to make a decision as to how to best
handle the citation. Date stamp the citation as of the date received and fax a
copy to Corporate Safety
2. Make a copy for your record and send the original to corporate safety.
3.11 Citation Process
1. The Compliance Officer has the authority to request any condition that poses
imminent danger be corrected immediately. If the situation is not abated, he can
secure an injunction through the U.S. District Court requiring immediate
correction, or suspension of the work until the condition is corrected.
2. The citation will detail the alleged violation(s) and the standard violated. A
definite length of time for correction (abatement will be set and a monetary
penalty proposed.
3. A copy of the citation must be posted at or near the place where the violation
occurred. DO NOT POST THE PROPOSED PENALTY COLUMN.
4. The employer may appeal the citation and proposed penalty within 15 working
days of the date the citation was received or he/she loses his/her right to appeal.

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Policy No:EHS-202 OSHA Inspection Procedure

5. The decision to appeal the citation and the method used will be made by
Corporate Safety, Corporate Legal and the President. If it is appealed, the
violation is referred to OSHA's Solicitor's office for review and submission to the
Review Commission. The Review Commission is a three person body,
independent of the Labor Department, established for the specific purpose of
hearing Federal and State appeals.
6. When an appeal is submitted to the Review Commission a notification of receipt
appointing a hearing examiner and scheduling a hearing, will be sent to the
Department of Labor, the employer and the employee representatives.
7. The Department of Labor (OSHA), the employer, and the employee
representatives (optional) will participate in the hearing. The hearing examiner,
who has subpoena power, will act as presiding officer and will issue a ruling.
This decision to be represented by Legal Counsel will be made by the President.
8. The hearing examiner's ruling is forwarded to the Review Commission. The
Commission can concur, modify or vacate the ruling.
9. The decision to appeal the Review Commission decision will be made after
review by Corporate Safety, Corporate Legal and the President.
4 See Appendix D
D.1 Notice to OSHA (Federal Only)
If, at the direction of S&W Energy Management, the decision is made to refuse
access to the S&W Energy project area, Exhibit I is to be properly completed and
presented to the Senior Compliance Officer attempting to gain access to the
project. A copy is to be retained and forwarded to S&W Energy with the other
required information.
D.2 Notice of Protest
If S&W Energy is presented with an Inspection Warrant, the S&W Energy Manager
of Safety should be contacted and a fax copy sent immediately. Exhibit II should
be completed and presented to the Senior Compliance Officer serving the warrant
after retaining a copy for our files. Then the inspection can proceed.

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 Environmental Health and Safety
Manual
Policy No. EHS-301 Policy Title: OSHA Recordkeeping and Reporting
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 Definitions ................................................................................................................ 2
3 General Procedure................................................................................................... 6
4 Posting the OSHA 300A Log / Summary ................................................................. 7
5 Procedures for Incidents Involving Worker’s Compensation Claims ........................ 7
6 Training .................................................................................................................... 8
7 Auditing / Inspections ............................................................................................... 8
8 References............................................................................................................... 8
9 Forms....................................................................................................................... 8

Page 1
Policy No:EHS-301 OSHA Recordkeeping and Reporting

1 Purpose and Scope

This procedure describes the notification, investigation, and reporting requirements that
must be followed in the event of an occupational injury, illness or related accident. The
procedure also outlines the reporting and recordkeeping requirements mandated by the
Occupational Safety & Health Act (OSHA) and by insurance companies for worker’s
compensation claims.
The scope of this procedure covers work-related accidents, injuries and illnesses
involving S&W Energy employees. Customers and affiliate labor of S&W Energy are
subject to the same requirements under OSHA but are required to be filed under their
parent company’s name and not under S&W Energy.
NOTE: Procedure updated to reflect Recordkeeping changes taking effect on January
1, 2002.

This Procedure should be used with S&W Energy’s EHS Incident Reporting
(and Follow-Up) Procedure to satisfy all regulatory and Company
requirements pertaining to recordkeeping and reporting of EHS Incidents.

Proper Forms to be completed when an EHS Incident occurs, per the two
procedures include:

EHS Incidents (Environmental and Permit Exceedances, Spills, Leaks,

Explosions, Fires, Near Misses, etc.)
1. EHS Incident Report Form
2. EHS Incident Investigation Report Form

EHS Incidents (Injuries & Illnesses)

1. EHS Incident Report Form
2. EHS Incident Investigation Report Form
3. First Report of Occupational Injury or Illness Form (OSHA 301 Equivalent)
4. OSHA 300 Log updated and maintained (if recordable)

THE S&W ENERGY EHS MANAGER SHALL BE NOTIFIED OF AN

INJURY/ILLNESS OR ACCIDENT AS SOON AS POSSIBLE

2 Definitions
• EHS Incident – An injury / illness, lost time accident, or fatality, including that of a
contractor; a permit exceedance, a hazardous material spill; or other emergency
such as fire, explosion, etc. Recordability of an EHS Incident may not always be

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Policy No:EHS-301 OSHA Recordkeeping and Reporting

determined at the time of occurrence or submittal of a report but may need to be

classified after investigation is completed.

• First Aid – any one-time treatment and any follow-up visit (to doctor or clinic) for
the purpose of observation of minor scratches, cuts, burns splinters and so forth,
which do not ordinarily require medical care. Such one-time treatment, and
follow-up visit for the purpose of observation, is considered first aid even though
provided by a physician or registered professional personnel (registered Nurse or
Physician’s Assistant). Reference the OSHA Recordability Checklist and
Recordability Guidance Notes.

• Incidence Rate (Injury & Illness (I&I) Rate) – A rate (number) calculated using the
number of OSHA Recordable injuries and/or illnesses and total number of
employee hours worked in relation to a common exposure base of 100 full-time
workers. The common exposure base enables one to make an accurate inter-
industry comparison, trend analysis over time, or comparisons among firms
regardless of size. The rate is typically taken over a 12 month rolling total, to
take into account the Standard Factor discussed below. The I&I Rates of all
applicable industries are accumulated and published through the Bureau of
Labor Statistics as a measuring tool for occupational safety. The rate is
calculated as:

N / EH x 200,000 where:

N = Number of injuries and/or illnesses or lost workdays;

EH = Employee hours worked, combined, for all employees during

calendar year or stated period;

200,000 = Standard Factor based on 100 full-time workers (working

40 hours per week, 50 weeks per year). If calculating the I&I rate
over a period of less than 12 months, this factor will vary, totaling a
standard number based on how weeks of the year you are
calculating.

• Log and Summary (OSHA No. 300 Log and 300A Summary) – The 300 Log is an
OSHA recordkeeping form used to list OSHA Recordable (Occupational) injuries
and/or illnesses, kept year to year (on a calendar year basis). The Log is used to
record all Recordable injuries and illnesses and note their extent and severity.
Following an injury report, an OSHA Recordable must be logged on the 300
Form within 7 days of the date of the Incident. Reports can be amended if further
information proves the injury or illness not recordable or work-related. The 300
Log serves as the running list of annual Recordable injuries and illnesses. The
300A Summary is a separate form that totals all the work-related OSHA
recordable injuries and illnesses, transferred from the OSHA 300 Log. 300A
Summaries are required to be posted three months out of every year, required

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Policy No:EHS-301 OSHA Recordkeeping and Reporting

from February 1 to April 30 for the preceding calendar year information. THE
300 AND 300A FORMS REPLACE THE OSHA 200 AND LOG SUMMARY,
RESPECTIVELY.

• Lost Workdays – The number of days, consecutive or not, beyond the day of a
work-place injury or onset of illness, that the employee was away from work or
limited to restricted work activity because of occupational injury or illness. Do not
count the day on which the injury or illness occurred. The count may end if it
exceeds 180 days. They fall into two (2) categories:

Lost Workdays Away From Work – The number of workdays, consecutive or

not, on which the employee would have worked but could not because of
occupational injury or illness.

Lost Workdays (Restricted Work Activity) – The number of workdays,

consecutive or not, which due to work-related injury or illness: (1) The
employee was assigned another job on a temporary basis; or (2) the employee
worked at a permanent job less than full time, differing from pre-injury or
illness status; or (3) the employee worked at a permanently assigned job but
could not perform all duties normally connected with it.

• Medical Treatment – Treatment administered by physicians, by registered

professional personnel or lay persons (i.e., non-medical personnel) in response
to an injury or illness or employee. Medical treatment does not include first aid
treatment (one-time treatment and subsequent observation or minor cuts,
scratches, burns, splinters, and so forth, which do not ordinarily require medical
care) even though provided by a physician or registered professional personnel.
Reference the OSHA Checklist of Medical Treatment included in this procedure.

The following are NOT considered Medical Treatment and, therefore, NOT
Recordable:

• Visits to a doctor or health care professional solely for the observation or

counseling;
• Diagnostic procedures, including administering prescription medications
that are solely for diagnostic purposes; and
• Any procedure that can be labeled First Aid

• Near Miss Incident – An event that COULD have resulted in an EHS Incident.
These are important to record and report for preventative measures or to identify
problem areas or issues.

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Policy No:EHS-301 OSHA Recordkeeping and Reporting

• Occupational Illness – Any abnormal condition or disorder, other than one

resulting from an occupational injury, caused by exposure to environmental
factors associated with employment. It includes acute and chronic illnesses or
diseases that may be caused by inhalation, absorption, ingestion, or direct
contact of contaminants in the workplace.

• Occupational Injury – Any injury such as a cut, fracture, sprain, amputation, etc.,
which results from a work accident or from an exposure involving a single
incident in the work environment. (NOTE: Conditions resulting from animal bites,
such as insect or snake bites, and from one-time exposure to chemicals are
considered to be injuries).

• OSHA 301 Form – A Form required By OSHA to be completed that records

supplemental information for recordable injuries and illnesses. An equivalent
Form may be used as long as it contains the same information as the OSHA 301
Form. In this procedure, the First Report of Occupational Injury / Illness Form
may be used as the OSHA 301 Form. THE OSHA 301 REPLACES THE OSHA
101 FORM.

• Posting – The 300A annual summary of occupational injuries and illnesses that is
posted at each employer’s establishment from February 1st to April 30th, which
includes data (I&I) for the previous calendar year. The posting includes the
summary OSHA 300A Form. If company has “satellite” or field establishments,
the posting can take place at headquarters but information at these remote
locations must be accessible.

• Recordable Cases – All work-related deaths and illnesses, and those work-
related injuries, which result in: Loss of consciousness, restriction of work motion.
Transfer to another job, or require medical treatment beyond first aid. Reference
the Recordability Flowchart and Checklist in this procedure for information on
determining OSHA recordability.

• Restriction of Work or Motion – Condition resulting from an employee’s job

related injury or illness; the employee is physically or mentally unable to perform
all or any part of his/her normal assignment during all or any part of the workday
or shift.

• Work Environment – Consists of the employer’s premises and other locations

where employees are engaged in work related activities or are present as a
condition of their employment. The work environment includes not only physical
locations, but also the equipment or materials used by the employee during the
course of his or her work.

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Policy No:EHS-301 OSHA Recordkeeping and Reporting

• Workers’ Compensation Systems – State-run medical benefits program, set up

by the individual states, to provide medical benefits and/or indemnity
compensation to victims of work-related injuries and illnesses.
3 General Procedure
1. Whenever an injury/illness occurs at a site, the First Report of Occupational
Injury/Illness Form (FROI) provided in this procedure must be completed. This form
satisfies the requirement to record supplementary information of occupational
injuries and illnesses and replaces the OSHA 301 Form.
A. The form must be completed and reported to Headquarters within 48 hours of
occurrence to ensure proper recording of any claim to proper worker’s
compensation authorities. Insurance carriers withhold rights of denying claims
if they are not reported in a prompt manner. If the FROI cannot reasonably be
completed and sent within 24 to 48 hours, a call to Headquarters must be made
for notification of the incident.
B. Recordable Cases must be logged on the OSHA 300 Form within 6 calendar
days of Incident or Case. Recordability must be determined within 7 calendar
days.
C. FROI (or OSHA 301 Logs / Records) shall be maintained on file for at least 5
years.
2. Recordable injuries/illnesses will be reported to the appropriate individuals according
to S&W Energy EHS Incident Reporting (and Follow-Up) Procedures. In addition to
the Form completed for the EHS Incident reporting, a copy of the First Report of
Occupational Injury/Illness Form should be sent to each of these individuals.
3. Company insurance agencies shall be notified of a recordable injury/illness as soon
as possible (this will be done by Headquarters personnel). Company insurance
policies typically require that the insurer be given immediate notice of any accident
or occurrence that may result in a liability under a policy. Failure to do so may result
in loss of coverage and/or right of recovery under a policy. Further, Federal and
State laws require proper and timely filing of workers’ compensation claims and
other accident reports within 24 to 48 hours.
4. Upon receipt of information of injury or illness (of S&W Energy employee), S&W
Energy will determine if the injury/illness is recordable using the OSHA Recordable
Decision Flowchart and the OSHA Recordability Checklist, provided in this
procedure, as a guide. If there is any question, contact the S&W Energy EHS
Manager.

Because recordable injuries and illnesses need to be documented within

certain time frames and because recordability is not always known at time
of incident or receipt of incident report, all cases shall be considered
recordable until determination has been made otherwise.

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Policy No:EHS-301 OSHA Recordkeeping and Reporting

5. In addition, an investigation will be conducted per S&W Energy EHS Incident

Reporting (and Follow-Up) Procedure to identify corrective actions and determine
how to prevent the injury/illness from recurring (for more serious cases).
4 Posting the OSHA 300A Log / Summary
• All recordable injuries/illnesses will be recorded on the Facility or Site (location)
OSHA 300 Log (Log). A copy of this Log is included in this Procedure or can be
obtained from OSHA. Recordables must be logged on the Form no later than 7
calendar days after receiving information that a recordable case has occurred.
• The OSHA 300 Log is to be maintained on a calendar year basis. The Summary
(Form 300A) must be posted in the workplace from February 1st until April 30th for
the preceding calendar year.
• OSHA 300 Logs and 300A Summaries shall be maintained for at least 5 years.
• A SEPARATE OSHA 300A Summary must be posted for each employer at a given
Facility or Site (location) other than S&W Energy. However, they are to be
maintained by that employer and not by S&W Energy.
• An OSHA 300A Summary must be posted at each establishment for S&W Energy,
unless provisions are made with Headquarters as to where the Log is to be posted.
Under some circumstances, the Log can be posted at the employer’s headquarters
site despite the fact that operations or work is carried on at a remote location.
Contact the S&W Energy EHS Manager for specific guidance.
5 Procedures for Incidents Involving Worker’s
Compensation Claims
• The Facility, Site, or Office Manager, Lead or Direct Supervisor (or designee) or
Human Resources Manager is required to complete a Worker Compensation Board
(WCB) Employer’s First Report of Injury/Illness Form for recordable injuries /
illnesses. The First Report of Occupational Injury/Illness Form may be used for this
requirement provided in this procedure and as referenced in Section 3. If this Form
is not acceptable to the WCB, a separate Form supplied by the WCB must be
obtained and completed. Contact the S&W Energy EHS Manager for more
information. ALL REPORTS MUST BE SENT TO HEADQUARTERS (HQ) AND
HQ WILL TRANSFER TO INSURANCE AUTHORITY.
• The Facility, Site, or Office Manager, or Lead or Direct Supervisor (or designee) or
Human Resources Manager will send a copy of the First Report of Injury / Illness
and the State Worker Compensation Board Employer’s First Report of Injury / Illness
(if different) to the S&W Energy EHS Manager, as soon as possible.
• All claims, hospital bills, First Report of Occupational Injury/Illness Form, etc., shall
be sent to:
S&W Energy
1849 Kingwood Drive, Suite 103
Kingwood, Texas 77339
ATTN: Environmental, Health and Safety (EH&S)

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Policy No:EHS-301 OSHA Recordkeeping and Reporting

• A copy of the State Worker Compensation Board Employer’s First Report of

Injury/Illness, or equivalent, will be sent to the State Worker’s Compensation Board.
• All forms must be kept on file for at least 5 years.
6 Training
All S&W Energy employees shall be trained on the requirements and guidelines of this
procedure. EHS Incident Reporting (and Follow-Up) procedures will be given as part of
this training. Training is required every three years or more frequently if program
changes have occurred.
7 Auditing / Inspections
The OSHA Recordkeeping and Reporting Procedure shall be reviewed every three
years. The procedure will be updated as necessary.
8 References
29 CFR 1904 Recording and Reporting Occupational Injuries and Illnesses under OSHA
9 Forms
See Appendix E
E.1 First Report of Occupational Injury/Illness (FROI) Form – OSHA 301
Equivalent
E.2 OSHA Recordable Decision Flow Chart
E.3 OSHA Recordability Checklist
E.4 OSHA Recordability Guidance – Notes

Page 8
 Environmental Health and Safety
Manual
Policy No. EHS-302 Policy Title: EHS Incident Reporting
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 Definitions ................................................................................................................ 2
3 Reporting EHS Incidents.......................................................................................... 3
4 Notification Responsibilities Involving Fatalities ....................................................... 4
5 EHS Incident / Near Miss Investigation & Follow-Up................................................ 4
6 Training .................................................................................................................... 6
7 Auditing / Inspections ............................................................................................... 6
8 References............................................................................................................... 6
9 Forms....................................................................................................................... 6

Page 1
Policy No:EHS-302 EHS Incident Reporting

1 Purpose and Scope

This procedure provides the requirements and structure to report EHS Incidents and
ensures that the appropriate individuals are notified of all EHS incidents that occur at a
S&W Energy Facility, a job-site, or Headquarters / Regional Office as soon as possible.
It also provides a systematic method of investigating the incident, identifying corrective
actions to prevent reoccurrence, and outlines proper follow-up procedures of the
Incident. This procedure outlines the method for and stresses the importance of
communicating the details of incidents or near misses, along with the investigation
results, to all S&W Energy employees to promote environmental, health and safety
awareness and to prevent the incident from reoccurring.

This Procedure should be used with S&W Energy’s OSHA Recordkeeping and
Reporting Procedure to satisfy all regulatory and Company requirements
pertaining to recordkeeping and reporting of EHS Incidents.

Proper Forms to be completed when an EHS Incident occurs, per the two
procedures include:

EHS Incidents (Environmental and Permit Exceedances, Spills, Leaks,

Explosions, Fires, Near Misses, etc.)
1. EHS Incident Report Form
2. EHS Incident Investigation Report Form

EHS Incidents (Injuries & Illnesses)

1. EHS Incident Report Form
2. EHS Incident Investigation Report Form
3. First Report of Occupational Injury or Illness Form (OSHA 301 Equivalent)
4. OSHA 300 Log updated and maintained (if recordable)

THE S&W ENERGY EHS MANAGER SHALL BE NOTIFIED OF AN

INJURY/ILLNESS OR ACCIDENT AS SOON AS POSSIBLE

2 Definitions
• EHS Incident - An injury/illness, lost time accident, or fatality, including that of a
contractor; a permit exceedance; a hazardous material spill; or other emergency
such as fire, explosion, etc. Recordability of an EHS Incident may not always be
determined at time of occurrence or submittal of report but may need to be
classified after investigation is completed.

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Policy No:EHS-302 EHS Incident Reporting

• Near Miss Incident - An event that COULD have resulted in an EHS Incident.
These are important to record and report for preventative measures or to identify
problem areas or issues
• Recordable Case – All work-related deaths and illnesses, and those work-
related injuries that result in: loss of consciousness, restriction of work or motion,
transfer to another job, or require medical treatment beyond first aid. Reference
the Recordability Flowchart and Checklist in the OSHA Recordkeeping and
Reporting Procedure for information on determining OSHA recordability
3 Reporting EHS Incidents
• If an EHS Incident or near miss occurs at a S&W Energy Facility, job-site, or field
service job, the Incident shall be reported to the Facility, Site Manager or Lead
Supervisor as soon as possible. If an EHS Incident or near miss occurs in a
S&W Energy Office (Headquarters or Regional Office), or while traveling on
business, the Incident shall be reported to the Office Manager or employee Direct
Supervisor as soon as possible.

• The Facility or Site Manager, Lead Supervisor, Office Manager, or Direct

Supervisor (or their designees) will complete an EHS Incident Report Form,
provided in this procedure, based on the information of the EHS Incident or near
miss at that time. (NOTE: Reports may need to be revised after first notification
depending on results of any medical testing or further investigation into the
Incident).

• At a S&W Energy Facility, job-site, or during a field service job, the Facility or Site
Manager, Lead Supervisor, or his/her designee, will notify the Customer / Owner
of any EHS Incident or near miss as soon as possible. This can be done verbally
or through written communication (i.e., memo, e-mail, etc.). Method of
communication shall be identified on the EHS Incident Report Form.

• Whether at a S&W Energy Facility, job-site, Headquarters / Regional Office,

during field service job, or business-related travel, the Facility or Site Manager,
Office Manager, Lead or Direct Supervisor (or their designee), shall notify the
S&W Energy EHS Manager of any EHS Incident or near miss as soon as
possible, but no later than 24 to 48 hours after occurrence.

• The Facility or Site Manager, Lead Supervisor, Office Manager, or Direct

Supervisor (or their designees) must also fax or e-mail a copy of the EHS
Incident Report Form to the S&W Energy EHS Manager as soon as possible.

• Outside agencies may also need to be notified in accordance with Federal, State
and Local Regulations. Reference Site Emergency Response information or
regulatory guidelines for contacts and proper procedures. (For O&M Facility, job-
site, or field service jobs, these notifications are typically made by the permit
owner, which in most cases is the Customer).

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Policy No:EHS-302 EHS Incident Reporting

• A copy of the EHS Incident Report Form shall be kept on file for at least 5 years.

All EHS Incidents and near misses shall be reported, including those
involving Contractors (at S&W Energy Facilities or job-sites or if
subcontracted by S&W Energy).

4 Notification Responsibilities Involving Fatalities

• In addition to the requirements for reporting an EHS incident and/or near miss,
the following steps should also be taken if a fatality should occur:

A. A verbal report must be made to OSHA within eight (8) hours after the death of
any employee from a work-related incident or any work-related incident that
results in the hospitalization of three or more employees within 30 days from the
incident date.
B. The following information must be provided to OSHA in that verbal report:

1. The facility name;

2. The location of the Incident;
3. The time of the incident;
4. The number of fatalities or hospitalized employees;
5. The contact person;
6. The phone number; and
7. A brief description of the Incident.
C. A Crisis Management Team or individual(s) may need to be engaged to deal
with individual counseling issues surrounding a fatality or major catastrophe.
OSHA will assist in this effort.
• Upon notification of a fatality, S&W Energy Headquarters will notify Legal, Public
Relations, and Human Resources. S&W Energy Headquarters will also assist in
the fatality investigation, corrective action follow-up, and interfacing with
regulatory agencies, as needed.

5 EHS Incident / Near Miss Investigation & Follow-Up

• All EHS Incidents and near misses shall be investigated. The investigation will
vary according to the severity or potential severity of the incident. The Facility,
Site, or Office Manager or Lead or Direct Supervisor will designate who is
responsible for conducting and leading the Incident investigation.

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Policy No:EHS-302 EHS Incident Reporting

As indicated by the severity of the Incident, steps to secure the Incident site must
be initiated immediately to ensure the investigating party can conduct the proper
investigation.

• The investigation shall be conducted as soon as practical after the Incident.

• As part of the investigation, individual interviews should be conducted with

individuals who were involved in the Incident or were witness of the Incident.
Interviewing guidelines are as follows:
A. The witnesses should be interviewed promptly, separately and privately.
B. The interviewer should explain the purpose of the investigation to each individual.
C. The interviewer should ask the witness to give their account of the events that
occurred.
D. The interviewer should avoid questions that give a yes or no answer.
E. After the interview, the interviewer should document any concerns identified.

• The investigation shall attempt to identify as many and practical corrective

actions as possible, both immediate recovery actions and long term follow-up
actions, to prevent the incident from reoccurring. All Corrective actions must
have a responsible person assigned and tracked to closure. Management shall
approve closure of all items identified by signing EHS Incident Investigation
Report Form.

• Each concern identified in the investigation must be addressed.

• Upon completion of the investigation, the EHS Incident Investigation Report

Form, provided in this procedure, will be completed by the Facility, Site, or Office
Manager or Lead or Direct Supervisor, or designee, and sent to S&W Energy
EHS Manager and Customer/Owner Headquarters, as applicable.

The EHS Incident Investigation Report Form must be submitted to S&W Energy
EHS Manager within one week from the Incident date.

• A copy of the EHS Incident Investigation Report will be kept on file for at least 5
years.

EHS Incident Report Forms may need to be revised based on investigation

results. Changes shall be made accordingly and as soon as possible.
Amended reports and results shall be documented and filed.

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Policy No:EHS-302 EHS Incident Reporting

6 Training
All S&W Energy employees shall be trained on the requirements and guidelines of this
procedure. Incident Investigation training shall be given as part of this training. Training
is required every three years or more frequently if program changes have occurred.
7 Auditing / Inspections
The EHS Incident Reporting (and Follow-up) Procedure shall be reviewed every three
years. Previous year’s reports may be reviewed during audit or inspection. This
procedure will be updated as necessary.

8 References
29 CFR 1910.119 Process Safety Management
29 CFR 1910.120 Emergency Response Plans
9 Forms
See Appendix F
F.1 EHS Incident Report Form (2 Pages)
F.2 EHS Incident Investigation Report Form

Page 6
 Environmental Health and Safety
Manual
Policy No. EHS-304 Policy Title: EHS Monthly Reporting, Field Service
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 Policy and Guidelines............................................................................................... 2
3 Training .................................................................................................................... 4
4 Auditing / Inspections ............................................................................................... 4
5 Forms....................................................................................................................... 4

Page 1
Policy No:EHS-304 EHS Monthly Reporting, Field Service

1 Purpose and Scope

This procedure provides guidance on S&W Energy’s requirement to report
Environmental, Health and Safety information to Headquarters on a monthly basis. This
requirement is applicable to S&W Energy’s Field Services Division.

Depending on customer requirements, a monthly report of ALL activity is

required at most Field Service jobs and job-sites. This monthly report can be
submitted as part of the general monthly report, as long as the required
information is provided and all the customer requirements are met.

2 Policy and Guidelines

Report Information and Schedule
Each Field Service (FS) job and job-site is required to submit Environmental,
Health and Safety information in the form of a report, provided in this procedure
(Attachment Section). The report shall be completed and submitted on a monthly
basis and must be provided to the S&W Energy EHS Manager, S&W Energy FS
Manager and Supervisor, and the customer representative, at the end of each
month. The monthly report can either be sent via fax, electronically, or mailed to
headquarters as long as it is received by the indicated dates below. The S&W
Energy EHS Manager will distribute to appropriate personnel at headquarters.
Monthly reports are due to Headquarters no later than 7 days following the end of
each month. If the report will be late or delayed for any reason, please contact
S&W Energy Headquarters to notify of the delay in information.
In the case of reporting injuries and illnesses on the monthly report, identify
information in regards to S&W Energy employees ONLY. Although injuries and
illnesses to other contractors and subcontractors are required to be reported as
part of each contractor’s policy, they SHOULD NOT be rolled up on the S&W
Energy’s monthly report. The monthly report is to provide information concerning
S&W Energy employees.
• Other injuries on the same job-site may be noted and passed along to
S&W Energy employees for informational and awareness reasons, but they
are not required to be recorded.
All sections of the monthly report should be completed. If there is a section that
does not apply to your employees or job-site, please indicate with “N/A” for Not
Applicable. If there is no information to report although the category does apply to
your Site, please indicate with “0”.

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Policy No:EHS-304 EHS Monthly Reporting, Field Service

Injuries and Illnesses

If further clarification is required concerning recordable injuries and illnesses, days
away from work, restricted work status, etc., please reference S&W Energy’s
procedure on OSHA Recordkeeping and Reporting.
ALL injuries and illnesses, including all other EHS Incidents, are to be reported as
part of S&W Energy’s EHS Incident Reporting Procedure. The Incident Reporting
process includes reporting injuries and illnesses that are NOT classified as
recordable in addition to those that are. However, the monthly report requires
recordable cases ONLY. Therefore, be advised that the number of injury and
illness cases reported through the EHS Incident Reporting process may differ from
the number recorded here.

Environmental Exceedances
Include air, water (either wastewater or stormwater), chemical spills, etc., in the
appropriate categories on the report, if the incident pertains to, affects, or is the
responsibility of a S&W Energy employee. Please specify as to the type of
exceedance as indicated on the form.
Every permit exceedance is classified as an EHS Incident, according to S&W
Energy’s EHS Incident Reporting Procedure. Therefore, the number of
exceedances reported on the quarterly report can be verified with the EHS Incident
Reports filed.
Only spills and releases that are classified as REPORTABLE should be included
on the monthly report. To be considered reportable will depend on the material
released or spilled, where the material is released or spilled, and the amount.
State and local regulations differ in what they classify as reportable. Please
consult local regulatory agencies to determine the criteria for reportable spills or
releases.
ALL spills or releases of chemicals or hazardous materials, including all other EHS
Incidents, are to be reported as part of S&W Energy’s EHS Incident Reporting
Procedure, if the incident pertains to, affects, or is the responsibility of a S&W
Energy employee. The Incident Reporting process includes reporting spills and
releases that are NOT classified as reportable in addition to those that are.
However, the monthly report requires reportable spills and releases ONLY.
Therefore, be advised that the number of spills and releases reported through the
EHS Incident Reporting process may differ from the number recorded here.

Environmental permitting for Field Service jobs is typically in the name

of the customer. For Environmental Exceedance reporting, consult
with the customer for details on limits, responsibilities, state-specific
rules, etc.

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Policy No:EHS-304 EHS Monthly Reporting, Field Service

Inspections
Include the number of inspections (i.e., regulatory by an agency, conducted by a
customer, conducted by S&W Energy, etc.) the Site has during each month.
Agency inspections are also recorded as part of S&W Energy OSHA Inspection
Procedure. These two numbers should correspond to one another.
Distinguish between the type of inspection conducted, either health and/or safety
related or environmental related.

Violations / Citations / Fines

Record the number of violations, citations, or notices of non-compliance issued to
the Site and any associated fines imposed as result of those citations.

The S&W Energy EHS Manager will review all monthly reports.
They will be assessed to determine any trends or patterns, to
determine any problem areas, to note exceptional EHS
performance, and to determine where EHS can be improved.

3 Training
All S&W Energy Field Service Directors or Supervisors, or their designees shall be
trained on the requirements of this procedure. Refresher training will be given if
the procedure or report changes. It is the responsibility of the Site or Job
Supervisor to track the information required in the monthly report, complete the
report form, and send it to Headquarters by the timeline established in this
procedure.
4 Auditing / Inspections
The S&W Energy EHS Manager shall review the reports every month upon
submittal. Monthly reports shall be maintained for the duration of the job and kept
at Headquarters for the life of the project. This procedure will be updated as
necessary.
5 Forms
See Appendix H
Field Services EHS Monthly Report Form

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 Environmental Health and Safety
Manual
Policy No. EHS-401 Policy Title: EHS Training Requirements
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 Definitions ................................................................................................................ 2
3 Procedure ................................................................................................................ 2
4 Training Process ...................................................................................................... 3
5 Training Plans .......................................................................................................... 3
6 EHS Training Recordkeeping System...................................................................... 4
7 Training .................................................................................................................... 4
8 Auditing / Inspection................................................................................................. 4
9 References............................................................................................................... 5
10 Forms ................................................................................................................... 5

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Policy No:EHS-401 EHS Training Requirements

1 Purpose and Scope

The purpose of this procedure is to establish regulatory required Environmental, Health
& Safety (EHS) training for S&W Energy employees. It establishes EHS training that is
mandatory based upon S&W Energy policy. Best Practice training, training which is not
required either by regulation or by business policy but required under discretion of
Manager or Facility as needed, is also identified. This procedure defines the frequency
of all EHS Training.
This procedure establishes a Recordkeeping System to record and track the training
that has been conducted for each S&W Energy employee at any site.
The scope of this procedure covers all field employees (personnel at O&M Facilities,
field service technicians out on various job sites, etc.), in addition to office employees
working at Headquarters or Regional Offices. Although some courses may be the same
for field and office employees, the required EHS training for field employees is much
more extensive, in purpose, scope, and content. The EHS Training Matrix included in
this procedure identifies field employee EHS training with the office employee EHS
training being a smaller subset of this Matrix. Training Plans are not required to be
submitted by Headquarters and Regional Offices. Training will be set-up by the EHS
Manager.
2 Definitions
Qualified – A person with specific training, knowledge, and experience in the area
for which the person has responsibility and the authority to control.
3 Procedure
All new S&W Energy personnel must make every effort to complete the regulatory
required and S&W Energy required EHS training as identified in the EHS Training
Matrix within the first six months of employment.
Efforts shall be made to attempt to obtain training records/certifications for new
employees of S&W Energy or for employees who have transferred to S&W Energy
from another company. These training records must be reviewed to ensure they
meet EHS requirements, as outlined in this procedure. If no documentation can be
obtained, employees must complete all initial EHS training required for their job
position as identified in the EHS Training Matrix.
EHS refresher training for other employees needs to occur on the frequency
defined in the EHS Training Matrix.
Training records must follow employees who transfer to other Facilities or Sites
within the S&W Energy Business.
S&W Energy has EHS Procedures that also need to be implemented through
training. The regulatory training identified on the Training Matrix satisfies most of
these requirements; however, additional procedural training may be required.
Employees must review all EHS procedures.

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Policy No:EHS-401 EHS Training Requirements

4 Training Process
Each Facility or Site (including Headquarters / Regional Office(s)) needs to implement a
process to ensure regulatory required and S&W Energy required EHS training is being
completed in a timely manner. The process must include the following steps:
• A Training Plan must be created which includes the requirements identified in
the EHS Training Matrix (use of the Matrix and the Annual EHS Training
Tracking Form should be used to generate this Training Plan). The Training
Plan development does not apply to Headquarters or Regional Offices.
Training will be coordinated through EHS Manager.
• Employees must be scheduled for training taking into consideration shift work,
vacations, illness, other training, etc.
• A system must be in place to notify employees in advance of the training.
• Training must be monitored to identify if courses need to be rescheduled for
employees who did not attend, for new employees, or for employees who have
changed positions, etc.
• The Training Plan must be maintained to include employee changes,
rescheduling of courses, etc.
• Training records should attempt to be obtained for new employees transferring
from another business or company; raining records compiled while at S&W
Energy must follow employees who transfer to new positions within the
business.
• Employee training must be recorded in a systematic format, where records can
be readily and easily accessed and training status can easily be determined.
An example Annual EHS Training Tracking Record is included in the
Attachment Section of this procedure.
• A business-wide policy, which includes top-level management commitment,
must be in place requiring that employees attend EHS regulatory required and
S&W Energy required EHS training. The policy must include steps to be taken
if employees arbitrarily miss regulatory required training.
• Any changes to the EHS Training Plan or additional information that needs to
be included in the Training Plan shall be documented and filed with the Training
Plan. Notify the appropriate individuals, as necessary.
Training can be given via several methods including using a live instructor (must be
qualified), using videos from safety qualified vendors, or using computer-based or web-
based training media (CDs, computer programs, etc.). Contact the EHS Manager, or
designee, for more information on EHS training resources.
5 Training Plans
Training plans must be developed for each Facility or Site by the end of the third quarter
of each calendar year (this is to coincide with budget planning). The Training Plan
developed should comprise the training agenda for the following year. Consider the
following when developing the annual Training Plan and developing a list of EHS
training requirements for personnel:

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Policy No:EHS-401 EHS Training Requirements

• Work activities currently in place that have training requirements;

• Anticipated changes in the work force responsibilities that may alter EHS
training requirements;
• New equipment or processes that may trigger additional training requirements;
• Modified work methods or job responsibilities that will require new or modified
training;
• Seasonal or non-routine work assignments subject to EHS regulatory
requirements;
• Training programs that may help to reduce or eliminate workplace injuries or
which the Facility or Site considers a Best Practice; and/or
• Results of EHS assessments or employee discussions.
Training Plans should be consistent with the EHS Training Matrix to ensure consistency
and accuracy in entering this information into the designated EHS Training Tracking
System (i.e., keep course name the same).
Training Plans must be revised during the year to reflect any changes and/or revisions
as well as any personnel changes. For example, if the Facility or Site Manager has left
and a new Facility or Site Manager has been assigned, the Training Plan must be
revised to include the EHS training requirements for the new Facility or Site Manager.
6 EHS Training Recordkeeping System
Each Facility or Site (including Headquarters / Regional Office(s)) must track S&W
Energy employee EHS training continuously.
Any certificates, test results, or other records obtained to validate proof of EHS training
completed shall be kept in an EHS Training records file for the length of employment of
individual.
7 Training
All S&W Energy employees shall be trained on the guidelines and requirements of this
procedure. Initial training is required only.
8 Auditing / Inspection
Training records must be retained for the duration of any employee’s term of
employment with the Company. They may be subject to review at any time to obtain
the training status of an employee.
The Facility or Site Manager, or designee, shall review the EHS Training Program on a
quarterly basis to ensure EHS training is being completed and up-to-date. The EHS
Training Procedure shall be reviewed every 3 years and updated accordingly.

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Policy No:EHS-401 EHS Training Requirements

9 References
29 CFR 1900 – to End OSHA General Industry Standards
29 CFR 1926 OSHA Construction Standards
10 Forms
See Appendix I
EHS Training Matrix (6 Pages)

Page 5
 Environmental Health and Safety
Manual
Policy No. EHS-402 Policy Title: EHS Auditing Process
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 Audit of S&W Energy’s EHS Manual (Policies, Procedures, and Programs) ........... 2
3 EHS Audit or Assessment of the Facility (Walkthrough Audit) ................................. 2
4 Training .................................................................................................................... 4
5 Forms....................................................................................................................... 4

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Policy No:EHS-402 EHS Auditing Process

1 Purpose and Scope

This procedure establishes the requirements for assessing S&W Energy’s
Environmental, Health and Safety (EHS) policies and procedures provided in the EHS
Manual. This includes review of the documentation, developed plans, and associated
practices that accompany each policy and procedure.
This procedure also provides guidance conducting entire Facility EHS assessments and
audits (walk-through), done either internally or by a third party consultant.
2 Audit of S&W Energy’s EHS Manual (Policies, Procedures,
and Programs)
Each EHS policy and procedure provided in the EHS Manual shall be assessed,
audited, updated, and/or revised within the established timeframes provided in each
policy and procedure. (Typically audit timeframes and frequencies are included in the
Auditing Section of each policy or procedure).
• The audit / assessment shall take into account any regulatory or S&W Energy
policy changes that may affect the procedure and require revisions or updates
to the established requirements and guidelines.
• Changes shall be made as soon as possible (as soon as the change is known
or becomes effective) and the revised procedure issued to all those who
possess a copy of the EHS manual.
• The audit / assessment of the policy, procedure, or program shall be conducted
by the S&W Energy EHS Manager, or designee. A schedule will be developed
on an annual basis to identify the policies and procedures, which will be
reviewed through the course of the year.
3 EHS Audit or Assessment of the Facility (Walkthrough
Audit)
Each S&W Energy Facility shall have a complete EHS audit of their Facility completed
on an annual basis.
• More frequent assessments may be conducted, as deemed necessary either by
the customer or a regulatory agency, however, at a minimum, one compete
EHS audit shall be conducted every year.
• The EHS Facility Audit shall consist of an assessment of the Facility practices
and implemented programs covering all topics in S&W Energy EHS Manual.
Use the EHS Manual’s Table of Contents as a guide.
• All findings (i.e., items found to be out of compliance or regulatory-based) shall
be documented by the auditor or auditing team. If the audit is conducted by an
outside third party or by a customer representative, the findings shall be
discussed with the Facility Manager, or designee, prior to documenting as a
finding.
• All findings shall be closed out as soon as possible. The Attachment section of
this procedure contains a form that can be used to document the results of a

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Policy No:EHS-402 EHS Auditing Process

Facility EHS Audit. A copy of this form, or equivalent, shall be submitted to the
S&W Energy EHS Manager following the audit and the findings will be tracked
to closure. The following items shall be included on the tracking form:

• Audit Type – Self assessment or third party audit;

• Finding Type – Regulatory, S&W Energy policy, or best practice;

• EHS Category – Area or classified topics of finding, i.e., waste

management, material handling, electrical safety, etc.;

• Finding – Brief description of the finding;

• Corrective Action – Brief description of corrective action to amend the

finding;

• Contact Name / Responsible Person – Individual to contact in case of a

question / individual responsible for closing out the identified item or person
implementing corrective action (this can be same person or different
individual for each);

• Finding Date – Date of the audit or finding;

• Expected Completion Date – Date that the identified corrective action

shall be implemented and the finding closed. DATE OF CLOSURE
SHOULD NOT BE MORE THAN 30 DAYS FROM DATE OF FINDING
UNLESS DISCUSSED WITH S&W ENERGY EHS MANAGER; and

• Status – Either open or closed. THERE SHALL BE NO REGULATORY

FINDINGS OPEN MORE THAN 30 DAYS, unless special provisions have
been made.

• The annual EHS Audit may be conducted by the Facility itself (employees at the
Facility), by the S&W Energy EHS Manager, or designee, by a Customer or
Owner Representative, or by a third party (consultant or regulatory agency). If
an outside party conducts the audit, S&W Energy shall ensure that the audit
covers all the to criteria outlined in the EHS Manual. THE AUDIT /
ASSESSMENT MUST BE CONDUCTED BY A KNOWLEDGEABLE
INDIVIDUAL OR GROUP OF INDIVIDUALS, QUALIFIED TO ASSESS EHS
FOR S&W Energy.

NOTE: If a Regulatory agency performs an audit, reference the requirements

of S&W Energy Inspections Procedure.

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Policy No:EHS-402 EHS Auditing Process

An EHS Facility assessment or audit must be conducted on an annual basis.

However, the ENTIRE audit dos NOT have to be completed at one time. If ALL of
the EHS topics are audited through the course of the year, this satisfies the
annual EHS audit requirement.

• The EHS Facility audit or assessment results shall be maintained for the life of
the Facility.
4 Training
All Facility Managers or Site Supervisors shall review the Auditing Protocol procedure
and understand the requirements of EHS audits or assessments for their own Facility.
No other training is required.
5 Forms
See Appendix J - Audit Findings Tracking Form

Page 4
 Environmental Health & Safety
Manual
Policy No. EHS-501 Policy Title: Contractor Safety
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

1. Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 Definitions ................................................................................................................ 2
2.1 Competent Person ............................................................................................ 2
2.2 Confined Space ................................................................................................ 2
2.3 Contractor ......................................................................................................... 3
2.4 Contractor Representative ................................................................................ 3
2.5 Contractor Supervisor ....................................................................................... 3
2.6 Contractor Worker............................................................................................. 3
2.7 EHS Incident ..................................................................................................... 3
2.8 Facility or Site ................................................................................................... 3
2.9 Facility (S&W Energy) Representative.............................................................. 3
2.10 Near Miss Incident ............................................................................................ 3
2.11 Sign-In Log (Facility or Site Sign-In Log) .......................................................... 3
2.12 Visitor ................................................................................................................ 4
3 Bid Solicitation.......................................................................................................... 4
3.1 Process ............................................................................................................. 4
4 Contractor Review and Selection ............................................................................. 5
5 Contractor Requirements – Prior to Commencement of Work ................................. 6
6 Inspections and Oversight........................................................................................ 7
7 Disciplinary Action(s)................................................................................................ 8
8 Contractor Injury or Illness / Report of Environmental Accident and Near Misses . 8
9 Visitors and Non-Major Contractors ......................................................................... 8
10 Recordkeeping ..................................................................................................... 9
11 Training ................................................................................................................ 9
12 Auditing / Inspections ......................................................................................... 10
13 References ......................................................................................................... 10
14 Attachments.......................................................... Error! Bookmark not defined.

Page 1
Policy No. EHS-501 Contractor Safety

1 Purpose and Scope

The purpose of this procedure is to establish a method of ensuring only qualified
Contractors are selected to perform work at S&W Energy Facilities or Sites. In addition,
this procedure establishes guidelines and precautions taken for the safety of
Contractors, or any other visitors, while on-site.
The scope of this procedure covers Major Contractors performing high-risk operations
at a S&W Energy Facility or Site or those Major Contractors who have been
subcontracted by S&W Energy. Major Contractors performing high-risk operations
include, but are not limited to:
• Contractors performing maintenance services using: Lock-out / Tag-out, Electrical
Safety, Hot Work, or Respiratory Protection;
• Contractors who will work in Confined Spaces;
• Contractors using hazardous chemicals or materials,
• Contractors using heavy machinery (i.e., cranes, forklifts, etc.);
• Contractors working on scaffolds and ladders requiring fall protection;
• Contractors involved in demolition or excavations (trenching activities); and/or
• Contractors involved in management of hazardous waste or substances;
S&W Energy shall use discretion in their definition of Major Contractor, keeping in mind
the type of work they will be involved in and the possible environmental, health and
safety concerns associated with that work. Purpose here is to ensure that S&W Energy
hires only qualified professionals to perform work activities to ensure a job well done
while keeping safety a top priority.
All other contractors and visitors on site do not need to be pre-qualified or go through
the bid solicitation process. These may include food/cafeteria vendors, lawn care
specialists, mail delivery employees, etc. However, they must use the Sign-In Log. If
these “exempt” Contractors ever need to enter parts of the Facility or Site where work is
being performed or may need to perform such activities as described above, S&W
Energy shall verify their qualifications or have them escorted and assisted by a Facility
Representative.
2 Definitions
2.1 Competent Person
One who is qualified to perform a specified task as proven through training records,
and/or by demonstrating the capability to identify existing and predictable hazards
and the ability to take prompt, corrective measures to eliminate those hazards.
2.2 Confined Space
Any space large enough and so configured that an employee can bodily enter and
perform assigned work, but is not intended for continuous human occupancy, and
has a limited means for entry or exit.

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Policy No. EHS-501 Contractor Safety

2.3 Contractor
Any employee, group of employees, and/or organization working at a S&W Energy
Facility or Site, under contract to perform work by S&W Energy. Contractor can be
regular, temporary, or part-time worker.
2.4 Contractor Representative
An individual designated by Contractor Company to sign paperwork and/or
interface with S&W Energy, representing that Company.
2.5 Contractor Supervisor
Any Contractor Worker in charge of work, regardless of title or classification.
2.6 Contractor Worker
Every regular, temporary, or part-time Contractor employee, including
subcontractors, working at a S&W Energy Facility or Site.
2.7 EHS Incident
An injury/illness, lost time accident, or fatality, including that of a Contractor; a
permit exceedance; hazardous material spill; or other emergency such as fire,
explosion, bomb threat, etc. In case of an injury/illness, further investigation may
be needed to classify as recordable or non-recordable (according to definition of
OSHA).
2.8 Facility or Site
The site or location, and all associated equipment, where S&W Energy is Operator
or working as Contractor.
2.9 Facility (S&W Energy) Representative
The designated Facility employee who is responsible for being a Contractor’s main
point of contact while at the S&W Energy Facility or Site. The Facility
Representative will conduct pre-job health and safety meetings to include review of
work scope, Contractor’s responsibilities, and any Facility or Site specific health
and safety concerns.
2.10 Near Miss Incident
An event which could have resulted in an EHS Incident.
2.11 Sign-In Log (Facility or Site Sign-In Log)
A book maintained for the purpose of recording Contractors and Visitors arriving
and leaving the Facility or Site which includes: name, date, company, purpose of
visit, time of check-in, and time of check-out.

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Policy No. EHS-501 Contractor Safety

2.12 Visitor
Any person who is not a regular, temporary, or part-time Contractor on S&W
Energy Facility or Site property and whose stay is confined to office areas or who is
escorted by a Facility Representative at all times.
3 Bid Solicitation
Each time S&W Energy would like to obtain bids or quotes from a potential Contractor
for work at a S&W Energy Facility or Site (or whether S&W Energy is subcontracting
work at a customer site), a Bid Solicitation / Contractor Qualification Form must be
completed by potential Contractor. The information provided on this Form, and any
subsequent information, must be reviewed and approved by S&W Energy prior to any
Contractor coming on-site to perform work. It is recommended that S&W Energy pre-
qualify Contractors (i.e., go through this process well in advance of work commencing)
so that there is no delay when trying to get qualified Contractors on-site for a specific
job.
The Contractor must submit certification that his/her Contractor Workers are properly
trained to perform the work proposed, per regulatory or other required guidelines
(Federal, State, and/or local). A Contractor Representative may verify this certification of
his/her employees as a group or may verify each one individually. This certification
shall be done on the Contractor EHS Training Tracking Certification Form, provided in
this procedure. This Form shall be sent out with Bid Solicitation / Contractor
Qualification Form. ONLY QUALIFIED CONTRACTORS WHO MEET BID
SPECIFICATIONS AND EHS TRAINING REQUIREMENTS WILL BE CONSIDERED
FOR WORK.
In addition to basic safety and training information required of all Contractors, S&W
Energy shall indicate on the Form any additional information that is required for
submittal by the Contractor in order to be considered for the bid. This will be job- / site-
specific.
3.1 Process
S&W Energy must send Bid Solicitation / Contractor Qualification Form to potential
Contractors. S&W Energy may have to complete portions of the Form, indicating
specific information that the potential Contractor must provide to be considered for
the job. The EHS Training Tracking Certification Form shall also be sent to
Contractor with the bid solicitation.
Potential Contractor must complete the Form and send all information indicated to
the S&W Energy contact, as designated on the Form or in cover letter. Contractor
Representative before submittal must sign the Form.
At a minimum, the Contractor must have a written HAZCOM Program and be able
to provide this document upon request. A written HAZCOM program is a
requirement of all employers, per OSHA regulation in regards to Hazard
Communication.

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Policy No. EHS-501 Contractor Safety

All hazardous chemicals and materials brought on-site by any Contractor must be
accompanied by and MSDS. Chemicals and materials should be identified to the
Facility or Site in advance and noted on the Qualification Form.
The Contractor is required to use S&W Energy EHS procedures while performing
work on-site, unless exceptions are made between customer, S&W Energy, and
Contractor prior to commencement of work. If the potential Contractor wishes to
use their own procedures, they must first ensure that the procedures meet all
regulatory requirements and that they are at least as stringent as S&W Energy’s
policies covering the same topic. Potential Contractor must submit any procedure
they wish to use with the Bid Solicitation Form for review by S&W Energy.
S&W Energy shall indicate the specific health and safety procedures to be used
under the scope of work to be performed. Based on this information, the potential
Contractor shall submit verification that Contractor Workers that will be supplied
are properly trained and qualified to perform the specific work identified. The
Contractor EHS Training Tracking Certification Form shall be completed
accordingly and submitted.
When contract bidding will not be performed, Contractors are still required to
submit the Bid Solicitation / Contractor Qualification Form and any requested
information in order to be allowed to perform work at the Facility.
Any information submitted by a Contractor during bid solicitation must be
maintained on file for at least one year. Annual qualification renewals are required.
4 Contractor Review and Selection
The Bid Solicitation / Contractor Qualification Form and additional submittals will be
reviewed by S&W Energy Representative, or designee as part of the selection process
to evaluate the safety qualifications of the Contractor.
The Safety record submitted by the Contractor shall be evaluated. Contractors with a
poor safety record (check industry averages to compare) or inadequate safety programs
may be disqualified from the bidding process or requested to upgrade their programs to
qualify.
Once the Contractor has been selected, S&W Energy will send to the Contractor the
Contractor EHS Rules Form for the Facility or Site for review. These rules and
guidelines shall comprise Contractor requirements in addition to general EHS rules and
Facility or Site specific rules and guidelines, as provided in attachment in this
procedure. This shall be provided on one Form for the each Facility or Site. Upon
arrival at the Facility or Site, the Contractor must sign this Form, indicating they have
read and fully understand the rules. By sending a copy in advance, it gives the
Contractor or any Contractor Worker time to review site-specific information and ask
any questions they may have prior to starting work and to avoid delays at check-in.
Upon award of the contract, the Contractor will supply the Facility with all of the
requested documentation (that was not previously supplied) as indicated on the Bid
Solicitation / Contractor Qualification Form (i.e. MSDS, Certificate of Insurance, etc.).

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Policy No. EHS-501 Contractor Safety

5 Contractor Requirements – Prior to Commencement of

Work
All Contractors must sign in and sign out on the Facility or Site Sign-In Log upon arrival.
This Log shall contain, at a minimum, the Contractor’s name, date, company, purpose
of visit, time of check-in, and time of checkout. The Log shall be retained in the Facility
or Site files for at least 3 years. Anytime a Contractor Worker or Visitor enters or leaves
the Facility or Site, he/she must sign in and sign out on this Log.
All first time Contractor Workers on-site and/or unescorted visitors must sign the
Contractor EHS Rules Form at time of check-in. It is the responsibility of the Facility or
Site to generate site-specific EHS requirements and add them to the general EHS rules
(applicable to all Facilities and Sites) and Contractor Rules provided in this procedure to
generate one Form, Contractor EHS Rules Form (reference Section 4.0 of this
procedure). These signed Forms shall be retained by the Facility to verify annual
approvals of Contractors.
The signed Contractor EHS rules is valid for one year for each Contractor Worker who
signs it. Each year, at the Contractor Worker’s first visit to the Facility, he/she must
review and sign the Contractor EHS Rules Form. If the Contractor Worker, through his
Company’s bid qualification process, has been approved as Contractor and has been
on-site in the past year and previously signed the Form, he/ she does not need to sign
again until the next year.
OPTIONAL: S&W Energy may choose a number of methods that may assist in
identifying valid and approved Contractor Workers on-site for any given year. One
method is to generate or purchase color-coded stickers or badges to display on hard
hats, signifying that the Contractor Worker has signed the Contractor EHS Rules Form
and has been approved for work during that year. The next year, upon Contractor
Worker’s first visit to the site and upon signing the Contractor EHS Rules Form for that
year, a different color-coded sticker or badge can be issued, designating valid for that
year.
The Contractor Supervisor or Representative may sign one Contractor EHS Rules Form
for all of the Contractor Workers under his supervision. However, each Contractor
Worker MUST have read the rules and fully understand the contents. The Contractor
Supervisor or Representative must indicate (by signing the Rules Form) that he/she is
verifying for all Contractor Workers under his/her supervision.
Each Contractor will be assigned a S&W Energy Facility or Site Representative.
This S&W Energy Facility Representative, or designee, must conduct a pre-job safety
meeting with the Contractor Representative / Supervisor (and his/her Contractor
Workers) prior to the start of work activities. During this meeting, the S&W Energy
Representative shall discuss:
• The scope of work;
• Hazards associated with the job (i.e., any confined spaces and hazards associated
with each);

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Policy No. EHS-501 Contractor Safety

• Expectations of the Contractor Workers;

• Review of the Facility or Site Emergency Procedures (fire alarms, exits, routes of
evacuation, emergency numbers and contacts, etc.); and
• Anything else that may be applicable to the job.
If the Contractor Workers are not present at this pre-job safety meeting, the Contractor
Supervisor must relay this information to the Contractor Workers before beginning work.
All Contractor Workers must receive and understand this information.
NOTE: This safety orientation can be given through the use of a Facility or Site video,
covering all the topics above and all the topics discussed on the Contractor EHS Rules
Form. Contact S&W Energy EHS Manager for more information on videos.
Each day, the Contractor Supervisor or Representative must report to the Control Room
or other designated area assigned by the Facility, and complete a Daily Contractor
Work Permit (for approval to begin work) from the Shift Supervisor. See sample Daily
Work Permit provided in this procedure.
6 Inspections and Oversight
The Contractor shall perform weekly safety meetings with his/her own employees, if on-
site more than one week. The Contractor shall address any safety concern raised at
these meetings immediately. The S&W Energy Representative shall be notified of any
safety concern.
Safety meeting information, agenda and attendants, shall be recorded by the
Contractor (a sample Weekly Safety Meeting Form is provided in this Procedure). A
copy of this form shall be given to the Facility Representative.
If safety becomes a big concern at the site during the course of the work, frequency of
safety meetings may increase, accordingly, to address issues.
The Contractor shall perform safety inspections, at least weekly, of his/her Contractor
Worker’s activities if the Contractor is on-site for longer than one week. The Contractor
shall address safety concerns raised during these audits immediately. The S&W
Energy Representative shall be notified of any safety concern.
Inspections shall be documented (a sample Inspection Checklist is provided in this
procedure). A copy of the checklist shall be shall be given to the S&W Energy
Representative.
In addition to the Contractor inspecting their own workers, the S&W Energy
Representative, or designee, shall also monitor the Contractor Worker’s performance
through inspections. Frequency of inspections will depend on the period of time that
the Contractor is on-site. Inspections should be conducted as practical. They must be
conducted for all Contractors who are on-site for more than one week.
Inspections shall be documented (a sample Inspection Checklist is provided in this
procedure). The Inspection checklist shall be shall be reviewed with Contractor
Representative or Supervisor and kept on file. Contractor may request copy of
Checklist.

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Policy No. EHS-501 Contractor Safety

Any discrepancies and assigned corrective actions must be indicated on the

Checklist(s). The S&W Energy Representative will follow up to ensure that all corrective
actions have been implemented.
Violations of the EHS Rules observed by the S&W Energy Representative or another
employee shall be documented. The notice will be completed by the S&W Energy
Representative and reviewed with the Contractor Supervisor.
Safety infractions will be re-evaluated to verify completion of corrective action(s). If
there is a dispute about an infraction, the matter will be settled at the Facility or Site
Manager’s discretion.
7 Disciplinary Action(s)
Any blatant disregard for health and safety issues or repeated violations will require
disciplinary action. Disciplinary action may include contract dismissal or work stoppage
at the cost to the contract firm.
The Facility or Site Manager, or designee, may bar or remove from the Facility or Site
any Contractor Worker who violates any law or provision of this procedure, or other
S&W Energy procedures, or who otherwise engages in conduct which is likely to cause
personal injury, illness or property damage.
The Contractor shall not re-assign any barred or removed Contractor Worker to perform
work at the Facility or Site without the approval of the Facility or Site Manager, or
designee.
The Contractor shall be solely responsible for discipline of Contractor Workers.
8 Contractor Injury or Illness / Report of Environmental
Accident and Near Misses
The Contractor Supervisor is responsible for reporting all EHS Incidents (including any
work related injury/illness, near miss, environmental accidents) to the S&W Energy
Representative, or Shift Supervisor, as soon as they become known.
After reporting the Incident to the S&W Energy Representative, the Contractor
Supervisor, in conjunction with the Facility or Site Representative, will complete an EHS
Incident Report Form (per S&W Energy procedures) and shall notify the appropriate
individuals per the reporting procedure. The original Form shall remain with the Facility
or Site and a copy given to the Contractor, if so desired upon request.
All EHS Incidents, including near misses, need to be investigated and followed-up. Any
corrective actions proposed as a result of Incident shall be tracked until closed
(reference S&W Energy’s EHS Incident Reporting procedure).
9 Visitors and Non-Major Contractors
All visitors and non-major contractors must sign in and out of the Sign-In Log and
adhere to all Facility or Site Environment, Health and Safety rules.

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Policy No. EHS-501 Contractor Safety

Visitors and non-major contractors are not required to sign the Contractor EHS Rules
Form if they will be escorted at all times by a S&W Energy Facility Representative or
will remain within office areas for the duration of the visit. If not, they must sign the
Form indicating they read and fully understand the rules as posted.
Visitors and non-major contractors must wear proper Personal Protective Equipment
(PPE), i.e., hard hats, safety glasses, ear plugs in required areas, etc., as warranted by
the Facility or Site policies. Safety shoes are also required if exposed to hazards while
on-site.
10 Recordkeeping
The following Contractor Safety recordkeeping shall be maintained in the Facility or Site
EHS Filing System for the period indicated:

• Contractor Environmental, Health & Safety Rules Form 3 years

• Contractor Bid Solicitation / Qualification Form and
Attachments 2 years (updated annually)
• Facility or Site Sign-In Log 1 year (kept up to date)
• Contractor EHS Training Tracking Certification Form 2 years (updated annually)
• Daily Contractor Work Permit 1 year
• Contractor Health and Safety Inspection Checklist 2 years
• Record of Contractor Weekly Safety Meetings 1 year
• EHS Incident Report Form (pertaining to Contractor) 3 years
and supporting documentation
The Contractor Bid Solicitation / Qualification Form and Contractor EHS Training
Tracking Certification Form shall be kept up to date and updated annually as part of
Contractor re-certification.
11 Training
Each Contractor will be required to either provide documentation or certify via the
Contractor EHS Training Tracking Certification Form that their employees have been
trained on the applicable regulatory requirements and standards, along with the hazards
inherent to the nature of their work performed on-site. Contractor Representatives may
certify this training for all of their employees. However, this must be indicated on the
Certification Form. No individual will be allowed to perform work for S&W Energy as a
Contractor unless this training certification is complete and accurate.
Each Facility or Site will have the Contractor Workers review and sign the Contractor
Environment, Health and Safety Rules Form on that Contractor Worker’s first visit to
the site each year.
All S&W Energy Facility or Site employees shall be trained on this procedure. Initial
Training required only.

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Policy No. EHS-501 Contractor Safety

12 Auditing / Inspections
The Contractor Safety Procedure shall be reviewed annually, including review of
records and reports. This procedure will be updated as necessary.
13 References
ANSI Standard for Eye and Face Protection (ANSI Z87.1)
ANSI Standard for Protective Footwear (ANSI Z41)
ANSI Standard for Protective Headgear for Industrial Workers (ANSI Z89.1, ANSI
Z89.2)
26 CFR 1910.451 Scaffolding
29 CFR 1910.28 Scaffolding
29 CFR 1910.120 Hazardous Waste Operations and Emergency
Response
29 CFR 1910.132 - 140 Personal Protective Equipment
29 CFR 1910.146 Permit-Required Confined Space
29 CFR 1910.147 The Control of Hazardous Energy (Lockout / Tagout)
29 CFR 1910.155-164 Fire Protection
29 CFR 1910.179 Overhead and Gantry Cranes
29 CFR 1910.180 Crawler, Locomotive and Truck Cranes
29 CFR 1910.269 Electric Power Generation, Transmission, and
Distribution
29 CFR 1910.333 Electrical Safety
29 CFR 1910.1001 Asbestos
29 CFR 1910.1200 Hazard Communication
29 CFR 1926 OSHA Construction
14 Appendix A (Applicable Forms)
1. Bid Solicitation / Contractor Qualification Form (2 Pages)
2. Contractor EHS Training Tracking Certification Form
3. Contractor Environment, Health and Safety (EHS) Rules Form (6 pages)
4. Daily Contractor Work Permit
5. Sample Weekly Safety Meeting Form
6. Sample Contractor Inspection Checklist (2 Pages)

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 Environmental Health and Safety
Manual
Policy No. EHS-502 Policy Title: Control of Hazardous Energy (Lockout/Tagout)
Date: 6/20/2006 Revision: 2 Approval: Richard Wolf

Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 Definitions ................................................................................................................ 2
3 Major Principles........................................................................................................ 5
4 Procedure ................................................................................................................ 6
4.1 Group Lockout Procedure ................................................................................. 6
4.2 Personal Lockout Procedure........................................................................... 13
4.3 Removal of Authorized Employee Locks and Tags When Off-Site ................. 14
4.4 Lost LOTO Tags ............................................................................................. 14
4.5 Shift Turnover ................................................................................................. 15
4.6 Equipment Specific Lockout / Tagout Procedures .......................................... 15
5 Contractors ............................................................................................................ 15
6 Training .................................................................................................................. 16
7 Auditing / Inspections ............................................................................................. 17
8 References............................................................................................................. 17
9 Forms..................................................................................................................... 17

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Policy No:EHS-502 Control of Hazardous Energy (Lockout/Tagout)

1 Purpose and Scope

This procedure defines the minimum requirements for affixing appropriate lockout and
tagout (LOTO) devices to de-energize, isolate, or otherwise disable machines or
equipment to allow safe maintenance and servicing. Effective hazardous energy control
procedures will protect employees during machine and equipment servicing and
maintenance where the unexpected energization, start up or release of stored energy
could occur and cause injury to employees or possible equipment damage.
This procedure and incorporated practices are in compliance with all applicable Federal
regulations. Strict adherence to this procedure ensures 100% compliance.
The scope of this program applies to all systems, whether mechanical, electrical,
pneumatic, or hydraulic and must be strictly adhered to by personnel employed by S&W
Energy including all contractors and subcontractors. Upon S&W Energy’s approval, the
customer or owner’s LOTO procedure may be substituted for S&W Energy’s policy if it
is at least as stringent as S&W Energy’s policy and complies with all applicable
regulations.
This procedure DOES NOT apply to cord or plug-connected equipment for which
exposures to hazards of energization are controlled by plugging / unplugging equipment
from an energy source and the plug is under exclusive control of personnel performing
the work.
In cases where S&W Energy employees work on equipment locked out by others, S&W
Energy shall be provided the capability to place their own lockout devices in parallel with
those of others.
2 Definitions
1. Affected Employee - An employee whose job requires him/her to operate or
use a machine or equipment on which servicing or maintenance is being
performed under lockout or tagout, or whose job requires him/her to work in an
area in which such servicing or maintenance is being performed.
2. Authorized Employee (AE) - A person who locks and tags out machines,
equipment, or systems in order to perform servicing or maintenance on that
machine or equipment. This person must complete the mandatory training to
be qualified as an Authorized Employee. Only an Authorized Employee installs
and removes his or her own locks and tag out devices as required by this
program. An Authorized Employee is also any employee whose duties include
performing maintenance and or servicing on a LOTO’ed system (including
contractors).
3. Authorized Employee Locks - Personal locks used to enhance the safety of
Authorized Employees performing servicing and/or maintenance of machines,
equipment and/or systems. These locks will not be used for any other purpose.
The locks shall be of one standardized color (colored band), different from
Supervisor (CLA) and System Operation locks and singularly keyed. Each

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Policy No:EHS-502 Control of Hazardous Energy (Lockout/Tagout)

Authorized Employee shall retain the keys to individual personal locks. The use
of an approved tag with the identity of the person applying the lock is required.
4. Authorized Employee Tags - Personal tags applied with the Authorized
Employee’s Lock. The tag reads “Danger - Do Not Operate” and identifies the
LOTO number, the tag number, and the Authorized Employee name. These
tags will not be used for any other purpose.
5. Clearance – The formal state in which a system / equipment has been
shutdown, de-energized, locked out, tagged, and thereby rendered inoperable,
thus permitting maintenance and servicing work to safely proceed. No tagged
isolation point energy control devices shall be operated while a Clearance is in
effect.
6. Clearance and Lockout Authority (CLA) – See definition for Shift
Supervisor/Lead Technician. For purposes of this procedure, CLA and shift
Supervisor are interchangeable.
7. Device Under Test Tag - A Warning tag utilized for temporary testing of
LOTO'ed equipment. The tag reads “Warning – Device Under Test”.
8. Double Block and Bleed - The closure of a line, duct, or pipe by closing and
locking or tagging two in-line valves and by opening and locking or tagging a
drain or vent valve in the line between the two closed valves.
9. Energy Isolating Device - A device that physically prevents the transmission
or release of energy. Examples include circuit breakers, disconnect switches,
valves and blank flanges. NOTE: Push buttons, selector switches, and other
control circuit type devices are NOT considered energy isolating devices.
10. Lockbox - A container provided for the placement of the System Operation
(Clearance) Lock Key(s) for a specific LOTO. The container shall be equipped
to handle Authorized Employee locks and tags placed around the top of the
container.
11. Lockout Device - A device that utilizes a positive means such as a keyed lock
to hold an energy isolating device in a safe position to prevent the energization
of a machine, equipment and/or system. Other lockout devices include blank
flanges and bolted slip blinds. No combination locks may be used.
12. Lockout/Tagout (LOTO) - The placement of a lockout and tagout device on an
energy isolating device, in accordance with this procedure, ensuring that the
energy isolating device and the equipment being controlled cannot be operated
until the lockout/tagout device is removed.
13. LOTO Control Sheet (LOTO Permit) – A form consisting of Tag Information,
Authorized Employee, and Removal of Locks / Tags Information used to identify
the current status of the LOTO.
14. LOTO Index - A form kept on file noting the sequential LOTO number, the
equipment and scope of work, and the origination and closing dates of all
LOTO's. This is a quick reference for open and closed LOTO’s.
15. Maintenance Work Order - An indexed order presented to the Shift
Supervisor/Lead Technician by an Authorized Employee or Requestor prior to

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Policy No:EHS-502 Control of Hazardous Energy (Lockout/Tagout)

the initiation of the formal LOTO process. This order will describe in detail the
scope of work and will be used to determine if a LOTO is required.
16. Requestor – The individual who originally requests a LOTO Permit for the
purpose of performing work on a system or piece of equipment. The Requestor
must be an Authorized Employee.
17. Shift Supervisor or Lead Technician (Clearance and Locking Authority,
CLA) – An employee, designated by Facility Manager, in a supervisory capacity
properly trained in LOTO and qualified to perform LOTO per this procedure and
per regulatory requirements (facilities/sites may use varying titles for this
position.). Depending on staffing and dual roles, this employee may designate
an Authorized Employee to implement portions of this procedure. For purposes
of this procedure, Shift Supervisor/Lead Technician and CLA are
interchangeable.
18. Site Authorized Employee List – Each Facility or site shall generate a list of
individuals authorized to conduct a LOTO. This list typically includes all
permanent operations and maintenance employees (essentially all Authorized
Employees). Shift Supervisors are usually noted as such on this list.
19. Supervisor Locks or CLA Locks - A set of locks that are specifically
designated to be used only as the Lock Box locks. Locks must be a
standardized color (colored band) different from Supervisor and System
Operations locks and keyed individually (one key for one lock). The keys to
Supervisor Locks are to be under the control of the Shift Supervisor / Lead
Engineer. Supervisor Locks are not the Authorized Employee personal locks of
each Supervisor.
20. System Operator (SO) - The employee designated by the Shift
Supervisor/Lead Technician to operate an energy isolating device in order to
apply System Operations locks and tags. The System Operator is trained as an
Authorized Employee. SO also refers to Systems Operations, a part of the
LOTO implemented by the System Operator (interchangeable).
21. System Operations Locks - The locks applied by the System Operator to de-
energize equipment, machines and/or systems. These locks are padlocks of a
standardized color (colored band) different from the Supervisor (CLA) and
Authorized Employee locks. Each LOTO shall utilize padlocks that are either
individually keyed or in sets that are commonly keyed. Duplicate keys to all
sets of padlocks must be under the control of the Facility or Site Manager. SO
locks are also referred to as Clearance Locks.
22. System Operations Tags - The tags applied by the System Operator when
applying System Operations Locks to de-energize equipment, machines and/or
systems. System Operations tags shall be different in color than the Authorized
Employee Tags, read “Danger - Do Not Operate” and shall contain the following
information: the LOTO number, the tag number, the date the tag was applied,
identification of the individual applying the tag, the name of the energy isolating
device, the position of the device and the signature of the Shift Supervisor.

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Policy No:EHS-502 Control of Hazardous Energy (Lockout/Tagout)

23. Tagout - The placement of a System Operations Tag on an energy isolating

device, in accordance with this procedure, ensuring that the energy isolating
device and the equipment being controlled cannot be operated until the tagout
device is removed.

• Tagout will be utilized along with the lockout device.

• Tags shall contain all of the information as identified, respectively. Tag
information shall be written in a language that Authorized Employees
working under the LOTO will understand. Pictorials should be included
where it is uncertain if employees can clearly understand the significance
and purpose of the tag.
• Tag material shall be substantial so as to prevent inadvertent or accidental
removal of the tag. Approved tag materials include rigid vinyl, Seal Tag, or
polyethylene plastic (Red Tag Material).
• Tag shall be attached by a one-piece, all environment tolerant, nylon cable
tie or equivalent that is non-reusable, attachable by hand, self-locking, non-
releasable and has an unlocking strength of no less than 50 lbs.
• Tags shall be affixed such that it is clearly indicated that the operation or
movement of the energy-isolating device from the “safe” or “off” position is
prohibited.
• Only when a lock cannot be physically applied to an energy isolating
device, can a tag, alone be used. The tag shall be fastened at the same
point at which the lock would have been applied.
• Where a tag cannot be affixed directly to the energy-isolating device, the
tag shall be located as close as possible to the device, so that it is
immediately obvious to anyone attempting to operate the device.
3 Major Principles
1. It is mandatory that all persons comply with the restrictions and limitations of this
procedure. Failure to follow and comply with this procedure will result in
disciplinary action up to and including dismissal.
2. No individual shall attempt to start, energize, or use a piece of equipment that
has been locked out and tagged out for servicing and maintenance activities,
except as provided for in this procedure.
3. No individual shall attempt to remove a lockout device and tag, except as
provided for in this procedure.
4. On all piping systems, double block and bleed shall be used whenever possible.
5. Additional personal protective equipment and special work instructions may be
required depending on the hazards present. These requirements shall be
reviewed by all employees involved in the job during a pre-job briefing before the
start of work.
6. A check valve cannot be used as an energy isolation device.
7. A Systems Operations Tag, alone, can ONLY be utilized when a lockout device
cannot be physically applied to an energy-isolating device.

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Policy No:EHS-502 Control of Hazardous Energy (Lockout/Tagout)

8. Whenever an outside firm is contracted to work for S&W Energy, the S&W
Energy LOTO Procedure shall be used. If the Contractor LOTO Program
requires additional or more stringent protection from what this procedure
provides, the Shift Supervisor or CLA and the Facility Manager, or their designee,
shall develop an interface program acceptable to all parties and fully complies
with all OSHA requirements.
9. This procedure does not apply to cord and plug operated equipment when it is
unplugged and the plug is maintained within the exclusive control of the person
performing work.
4 Procedure
This procedure is based on the Group Lockout method, as referenced in and required
by regulatory standards. However, under certain circumstances, Personal Lockout may
be utilized.
4.1 Group Lockout Procedure
Pre-planning of the LOTO shall be conducted by the Shift Supervisor/Lead
Technician or the Requestor. When possible the Shift Supervisor/Lead Technician
will be assisted by Authorized Employee(s) who know the equipment, machine or
system to be LOTO’ed and/or will perform work on the equipment, machine or
system to be LOTO’ed.
As part of the LOTO planning, all sources of energy and other hazards associated
with a machine, equipment or system shall be identified. Potential multiple sources
of energy common to a single unit shall be checked. The machine, equipment or
system shall be reviewed to identify all energy sources that need to be isolated and
locked out. All necessary resources, such as, standard operating procedures,
individual employee system knowledge, up-to-date equipment and system
drawings, equipment manufacturer’s manuals, shall be used in making that
determination.
A. Initiating the LOTO
All work requiring a Lockout/Tagout is to be reviewed with the Shift
Supervisor/Lead Technician by the Authorized Employee. The Authorized
Employee shall perform no work on equipment where a possible hazard exists to
personnel or equipment without the equipment being properly isolated.
A request for Clearance shall be initiated for all work covered by the scope of this
procedure.
1. To request a LOTO, a Maintenance Work Order or a LOTO Request
must be generated or completed. The Maintenance Work Order or
LOTO Request shall indicate the date of the request, the name of the
Authorized Employee (Requestor) requesting the LOTO, the machine,
equipment and/or system for which the LOTO is requested, and the
work to be performed.

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Policy No:EHS-502 Control of Hazardous Energy (Lockout/Tagout)

• In some cases, one individual may function as both the Shift

Supervisor/Lead Technician and a Requestor, depending on title
and function.

B. Shift Supervisor/Lead Technician Review of Requested LOTO –

Preparation of Systems Operations LOTO
1. The Shift Supervisor/Lead Technician shall review the Maintenance
Work Order or Request and decide whether or not to grant the LOTO
request. If the LOTO is to be granted, the Shift Supervisor/Lead
Technician shall begin filling out the LOTO Control Sheet, first
assigning the next number (sequentially) to the LOTO. This shall be
documented on the LOTO Index and LOTO Control Sheet.
2. Upon approval of Request for LOTO, the Shift Supervisor/Lead
Technician shall input information into the LOTO Index, which includes
LOTO number, Date/Time Hung (Date/Time Cleared will be completed
after the close of the LOTO), Description of Work, and signature.
He/She must also complete the top of LOTO Control Sheet with LOTO
number, Date/Time Opened, Equipment Description, Work Scope, and
References.
3. The Shift Supervisor shall verify the scope of work for which the LOTO
has been requested. This verification should include identification of
all potential sources of hazardous energy and the appropriate energy
isolation devices (isolation points required).

NOTE: Pre-printed LOTO Forms should be developed to expedite

Clearances that are frequently used or complicated.

4. The Shift Supervisor/Lead Technician shall designate a System

Operator (SO) for the Systems Operations portion of the Group
Lockout, as applicable.
5. The Shift Supervisor/Lead Technician shall complete required
information for locking out the identified energy isolation points on the
LOTO Control Sheet including the lock/tag number, the name and
number of the energy isolating device, position of device after lock and
tag applied.
6. The Shift Supervisor/Lead Technician, or designee, shall prepare the
LOTO Tags and verify they coincide with listing on LOTO Control
Sheet. The Shift Supervisor will provide the following information on
the tag: the LOTO number, lock and tag number assigned (from LOTO
Form), ID of equipment or device, position of device, and signature of
Shift Supervisor. The remaining information will be provided by SO
upon placement of lockout device.

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Policy No:EHS-502 Control of Hazardous Energy (Lockout/Tagout)

7. Only after the required information on the LOTO Control Sheet, the
LOTO Index and each tag has been completed can lockout/tagout
devices be placed onto the energy isolation device.
8. The Shift Supervisor/Lead Technician will notify all affected employees
of the machines, equipment or systems to be locked and tagged out for
servicing or maintenance.
C. Shutdown, Isolation, De-energizing and Placement of LOTO Devices –
Systems Operations LOTO
1. Shut identified equipment off by normal operating procedures.
2. All sources of stored energy shall be dissipated. For instance, safely
drain any hazardous material from piping or tanks or flush systems.
Verify that all sources of stored energy cannot recharge (bleed off
valve is open, grounded capacitor, etc.) Drains, vents, relief devices
that may allow energy in any form to accumulate must be positioned to
prevent such accumulation and then locked.
3. Designated isolation or blocking points such as valves, switches, and
circuit breakers shall be operated or moved to specified safe position
as indicated on the LOTO Control Sheet.
4. Each system, equipment or machine identified can now undergo
LOTO. Each energy isolation point identified on the LOTO Control
Sheet shall then be locked out and tagged out using the lockout/tagout
device by the designated Systems Operator.
5. The System Operator shall have the original copy of the LOTO Control
Sheet in his/her possession. Immediately after a lock and tag device is
applied, the System Operator will sign and indicate the date and time
on the tag (remaining information on tag completed).
6. The System Operator will also fill in the “Lock / Tag Hung By: Initials &
Date” for that tag on the LOTO Control Sheet.
D. Application of Systems Operations (Clearance) Locks
1. All isolation points identified on the LOTO Control Sheet shall be
secured using Locks and Tags. Every effort shall be made to secure
isolation point with a lock.

• When an energy-isolating device is capable of accepting a Lock,

the Lock shall be used to secure the device. Assisting devices (i.e.,
chains, wedges, blocks, adapter, pins, self-locking fasteners, and
other hardware) may be used as necessary.
• When an energy-isolating device cannot accept a Lock, a tag shall
be used to secure the equipment. Tags alone shall only be used
to secure energy isolating devices that physically cannot
accept a Clearance Lock.

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Policy No:EHS-502 Control of Hazardous Energy (Lockout/Tagout)

•
Locks shall be installed on the blocking point that provides the most
positive isolation of the equipment, regardless of external control
devices and remote operators.
• Tags shall be utilized in conjunction with each Lock for identification
purposes.
E. Application of Tags
1. When a machine or piece of equipment is NOT capable of accepting a
lock, Tags may be used as sole means for securing it. However, the
following conditions must be met:
• The Tag shall be located as close as safely possible to the device
being tagged out, in a position that is immediately obvious to
anyone attempting to operate the device.
Examples of Visible Locations of Tag Attachment:
Remotely controlled equipment – attached to control switch
handles and to device itself.
Manually operated equipment – hung on manual operating
handle.
Equipment within compartments – hung on the compartment
door latch or on a screw eye, if provided, over the
compartment door lock.
Outdoor circuit breakers – hung on the equipment in a
prominent location visible to those working on the
equipment.
Draw-out type circuit breakers – hung on the levering-in
device when practical or on the cubicle door for all other
cases.
• The Tag shall be attached to the device being tagged with an
approved Tag Attachment. Tag attachment criteria are outlined in
Definition section under “Tagout”.
• Tags shall be attached at all isolation points and at remotely
located control elements.

F. Verification
1. The System Operator shall verify the effectiveness of the locking
device, by attempting to reposition the device immediately after it is
applied.
2. The System Operator shall verify that all sources of stored energy
have been dissipated (i.e. bleed-off valve open, etc.).
3. After ensuring that no personnel are exposed, the System Operator
shall verify, as directly as possible, the effectiveness of the LOTO by

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Policy No:EHS-502 Control of Hazardous Energy (Lockout/Tagout)

operating the starting controls for the isolated equipment to make

certain the equipment will not operate. For work that will expose
employees to bare electrical circuits, the circuit must be checked with a
multi-meter, or other appropriate equipment, to ensure the circuit is de-
energized by an Authorized Employee trained and authorized to use
this equipment.
RETURN OPERATING CONTROLS TO THE “OFF” POSITION
AFTER PERFORMING VERIFICATION TEST
NOTE: In cases where the starting controls are operated from the
control room, the System Operator shall request the Shift
Supervisor/Lead Technician or Control Room Operator to attempt to
start the applicable isolated equipment controls while verifying the
equipment is in fact isolated.
4. The System Operator shall retain the lock keys or set of keys in his/her
possession until he/she has locked and tagged all points designated
on the LOTO Control Sheet and verified, as directly as possible, the
correctness of the locks and tags.
5. When completed, the System Operator shall report and return the
Clearance Lock key(s) and LOTO Control Sheet to the Shift
Supervisor/Lead Technician.
6. Once the proper lockout and tagout has been implemented and
verified, the Shift Supervisor/Lead Technician shall place the key(s) to
the Clearance Locks in the Lockbox and secure the Lockbox with the
Supervisor Lock. The key to the Supervisor Lock shall remain under
Shift Supervisor/Lead Technician control.
7. The LOTO Control Sheet shall be retained by the Shift Supervisor.

G. Authorized Employee Lockout/Tagout (Work Performed Under

Clearance)
1. The Shift Supervisor/Lead Technician, or designee, shall brief all
Authorized Employees who will be performing work on the LOTO'ed
equipment, machine and/or system. The briefing shall describe
hazards associated with the job, work procedures involved, special
precautions, energy source controls, and personal protective
equipment required.
2. Each Authorized Employee assigned to perform work on the LOTO
must sign onto the LOTO Control Sheet. Additional pages may be
needed.
3. By signing onto the tagout, the Authorized Employee indicates that
he/she as walked down the system and has initialed all tags on the
tagout.

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Policy No:EHS-502 Control of Hazardous Energy (Lockout/Tagout)

4. The Authorized Employee(s) shall walk down the LOTO to visually

verify each energy isolation device for the correct device position. The
System Operator shall accompany the Authorized Employee on the
walk down if he/she is a contractor or is an on-site employee who is
unfamiliar with the LOTO'ed machine, equipment and/or system.

• To verify that all energy-isolating devices are in the correct position,

each Authorized Employee must initial each LOTO Tag.

NOTE: Each time an Authorized Employee removes his/her lockout

device from the lockbox and signs off the LOTO, he/she MUST be
offered the opportunity to walk down the LOTO upon re-signing onto
the LOTO.
5. Following all AE’s adding their locks and tags and signing onto the
LOTO, the Shift Supervisor/Lead Technician shall review the LOTO
Control Sheet to ensure all information has been completed.
H. Adding Locks and Tags to an Existing LOTO
Locks and tags may need to be added to an existing LOTO. The addition of
locks and tags must be approved by the Shift Supervisor/Lead Technician.
Any locks and tags added to a LOTO become a part of that LOTO. The
following steps shall be taken to add locks and tags to an existing LOTO:
1. The Shift Supervisor/Lead Technician will fill-out the LOTO Control
Sheet identifying each Lock and Tag to be added to the LOTO. The
added locks and tags shall begin with the next sequential number, if
possible.
2. The Shift Supervisor/Lead Technician shall fill-out the additional LOTO
Tags.
3. The Shift Supervisor/Lead Technician, or designee, will notify any
affected persons of the additional devices to be LOTO'ed out of
service.
I. Temporary Removal of LOTO (Test Release)
If it is necessary to temporarily remove LOTO devices for testing equipment,
machines or systems the following steps must be taken:
1. The Authorized Employee requiring a test will make a request to the
Shift Supervisor/Lead Technician and obtain his approval for the test.
2. The Shift Supervisor/Lead Technician will inform all employees who
have signed onto the LOTO and who may be affected by the re-
energization of the equipment, machine, and/or system that a test is
scheduled to take place and to move to a safe location.
3. The Shift Supervisor/Lead Technician will fill out the Test Release
Authorization section of the LOTO Control Sheet including the date

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Policy No:EHS-502 Control of Hazardous Energy (Lockout/Tagout)

and time of the test, Authorized By section, and the Authorized

Employee requesting the test. If more that one test is required during
the duration of the LOTO, annotate the test on the back of the LOTO
Control Sheet.
4. Shift Supervisor will then review LOTO Control Sheet with the
Authorized Employee requesting the test.
5. The Shift Supervisor/Lead Technician will consult with all Authorized
Employees on this LOTO regarding the identified locks and tags. The
Authorized Employees must agree that the LOTO’ed device may be
operated without danger and that their work will stop while the
identified locks and tags are removed.
6. The Authorized Employee shall then remove their lockout device and
tag from the lockbox.
7. The Shift Supervisor/Lead Technician, or designee, will walk down the
system to verify that the area is clear of personnel and equipment.
8. Energize and proceed with the positioning and testing.
9. At the conclusion of the testing, de-energize the equipment, machine,
and/or system and reposition all affected energy isolation devices to
their LOTO’ed position. Replace with the LOTO Locks and Tags.
10. Perform verification for those energy isolation points.
11. The test is now complete. Work can commence once again following
the steps within this procedure. Each Authorized Employee will be
briefed on the status of the LOTO (i.e. test complete, tags rehung)
offered the opportunity to walk down the entire LOTO and sign back
onto the LOTO. Each Authorized Employee may now apply their lock
and tag to the lock box. These Authorized Employees may now restart
their work on that equipment.
J. Closing the LOTO – Release From Clearance
1. When the work is complete and the Authorized Employee no longer
requires a LOTO, they will check the equipment to ensure that all tools
and non-essential materials are clear. The Authorized Employee will
notify the Shift Supervisor/Lead Technician that he/she is ready to be
removed from the LOTO as an Authorized Employee and will apprise
the Shift Supervisor/Lead Technician of the status of his/her work and
the status of the equipment.
2. The Authorized Employee will complete the “Lock/Tag Removed By”
box on the LOTO Control Sheet and indicate that work is complete.
The AE shall then remove their lock and tag from the lockbox.
3. When all Authorized Employees have signed off the LOTO, the Shift
Supervisor/Lead Technician shall then initiate the closing of the LOTO.
4. The Shift Supervisor/Lead Technician, or designee, will walk down the
equipment, machine or system which was under the LOTO, evaluate
the safety of the equipment and the completeness of the work, and will

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Policy No:EHS-502 Control of Hazardous Energy (Lockout/Tagout)

check the work area to ensure all persons are clear of the equipment.
The Shift Supervisor/Lead Technician shall then remove the
Supervisor Lock from the lockbox to obtain LOTO keys.
5. After a lockout device and tag is removed by the System Operator, and
the device is returned to the correct operating position, he/she will
initial and date the “Lock/Tag Removed By” box for that tag on the
LOTO Control Sheet and complete the Cleared Position.
6. The System Operator will return the LOTO Control Sheet and the
removed tags to the Shift Supervisor/Lead Technician. After the tags
and locks have been removed, they should be checked by the Shift
Supervisor/Lead Technician against the LOTO Control Sheet for
location and number to verify all the tags are removed and that the
removed tags are correct.
7. The Shift Supervisor/Lead Technician will then sign the LOTO Control
Sheet “LOTO Clearance Authorized By” section closing the LOTO.
The Shift Supervisor/Lead Technician shall fill in the date the LOTO
was closed on the LOTO Index.
8. The Shift Supervisor/Lead Technician will notify the Control Room that
the LOTO is closed and the equipment is ready for use.
4.2 Personal Lockout Procedure
This Section is intended as an alternative to the Group Lockout Procedure.
However, all conditions listed below must be satisfied prior to using personal
lockout procedure over the group method:
• The work scheduled will be completed within the same work shift of the
employee performing the work. If there is an indication that the work will extend
into another shift, Group Lockout must be used;
• Personal Lockout applies to S&W Energy employees only. Contractors,
temporary employees, vendors, visitors, etc., shall use the Group Lockout
method;
• The equipment has a single energy source which can readily be identified and
isolated at one and only one isolation point;
• A single lockout device will achieve a locked-out condition;
• The machine or equipment has no potential for stored or residual energy or re-
accumulation of stored energy after shut down which could endanger
employees; and
• The work being performed does not create hazards for other employees.
1. Authorized Employee notifies Shift Supervisor/Lead Technician, or
designee, what equipment is to be de-energized and isolated and
requests a LOTO (Clearance) for Personal Lockout. This can be done
verbally.
2. If approved, the Shift Supervisor/ lead Technician, or designee,
documents the Personal Lockout on the LOTO Control Sheet and
assigns a LOTO Number. Follow the steps outlined in the Group

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Policy No:EHS-502 Control of Hazardous Energy (Lockout/Tagout)

Lockout Procedure, as applicable, EXCEPT instead of AE affixing lock

and tag to lockbox, he/she must affix lock and tag to isolation point.
An Operations employee will shutdown, isolate, and have the
Authorized Employee (person requesting the LOTO) place their
personal lock on the equipment isolation point.

NOTE: The single job may be assigned to one or more employees. Each
employee assigned will put their personal lock on the isolation point.

3. The lockout device shall be applied to achieve Clearance. The lock

shall be placed on the blocking point so as to physically secure that
point and render it inoperable by any means short of destroying the
lock.
4. Following placement of lock, a representative from Operations shall
attempt to start the equipment. If equipment does not start, work may
then proceed on the equipment.
Temporary Removal of LOTO (Test Release) and Closing the LOTO shall be the
same as in Group Lockout (AE’s will be removing lock and tag from isolation point
instead of lockbox).
4.3 Removal of Authorized Employee Locks and Tags When Off-Site
There may be times when the LOTO needs to be closed to put the equipment back
into service when an Authorized Employee still on the LOTO is off-site and cannot
be located. In this case, the following steps will be followed to allow closing of the
LOTO.
1. The Shift Supervisor/Lead Technician will attempt to reach the
Authorized Employee to determine if the LOTO may be closed. If the
Authorized Employee indicates that the LOTO may be closed the
Authorized Employee must return to the site to follow the normal
Clearance procedures.
2. If the Authorized Employee cannot be contacted or cannot reasonably
return to the site the Shift Supervisor/Lead Technician may sign the
LOTO Control Sheet to authorize the removal of the Authorized
Employee from the LOTO.
4.4 Lost LOTO Tags
In the event that a tag for a device or piece of equipment which is LOTO’ed is lost,
the following must be done:
1. If a LOTO tag is found not attached to a device or if a device which
should be LOTO’ed does not have a tag, the Shift Supervisor/Lead
Technician must be notified.

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Policy No:EHS-502 Control of Hazardous Energy (Lockout/Tagout)

2. If the tag is found, the Shift Supervisor/Lead Technician will verify the
location and number of the tag with the LOTO Control Sheet and have
it re-hung.
3. If the lost tag cannot be found, a Shift Supervisor/Lead Technician will
issue a new tag for that device using a new tag number. The Shift
Supervisor will note “Tag Lost” in the LOTO Control Sheet and indicate
the number of the replacement tag.
4. If the LOTO was to be closed when the tag was discovered missing,
any remaining tags and locks will be removed and “Tag Lost” will be
written in the LOTO Control Sheet.
4.5 Shift Turnover
1. As part of shift turnover, oncoming and off-going Shift Supervisors
must review the LOTO Index Sheets to determine the status of all
active LOTO’s.
2. Upon turnover, the responsibility for active LOTO’s is automatically
transferred to the oncoming Shift Supervisor, including custody of any
System Operations Lock and Supervisor’s Lock keys.
4.6 Equipment Specific Lockout / Tagout Procedures
1. Each S&W Energy Facility or Site must develop Equipment Specific
LOTO Procedures (ESLPs) for all major equipment, machines, and/or
systems at their facility.
2. Each ESLP will contain the following elements:

• Preparation for Shutdown;

• Machine or Equipment Shutdown;
• Machine or Equipment Isolation;
• Lock-out / Tag-out Device Application;
• Stored Energy Dissipation;
• Verification of Isolation;
• Release from LOTO;
• Additional measures for Outside Contractors, as needed.
5 Contractors
1. Contractors of S&W Energy must adhere to the S&W Energy LOTO
procedure to perform Lockout / Tagout. Prior to performing work, the
contractor will review the S&W Energy LOTO Procedure to ensure they
understand and are able to comply with all of its requirements.
2. All outside contractors must be properly trained (i.e., completed the
proper regulatory compliance training of LOTO) before being allowed
to perform LOTO.

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Policy No:EHS-502 Control of Hazardous Energy (Lockout/Tagout)

3. Contractors shall not be permitted to request Clearances in their own

name. All LOTO requests shall be initiated on the Contractor’s behalf
by a designated employee (Contractor Supervisor) identified as such
prior to commencement of work. These individuals should be added to
the Requestor List for that Contractor.
4. Each Contractor shall have his/her own Personal Safety Lock, clearly
labeled and numbered.
5. The Shift Supervisor shall be provided with a means of determining the
identity of the worker affixing the lock and tag, by the lock label or
number.
6 Training
Training shall be provided to ensure that the LOTO Procedure is understood by all
Authorized Employees at a Facility or Site or Field Service Job and that all
Authorized Employees have the knowledge and skills required for safe application,
usage, and removal of energy controls. Each employee shall receive training that
includes the following:
1. Recognition of applicable hazardous energy sources, the type and
magnitude of energy sources within the work place, and the means
and methods of isolation and control.
2. The purpose, scope, and function of the LOTO Program and
procedure.
3. The limitations of tags, including the following principles:

• Tags are primarily warning devices attached to energy isolating

devices and do not provide the physical restraint that a lock will
provide;

• When a tag is attached to an energy-isolating device, it is to be

removed only by the authorized person responsible for it, unless
provided for under the procedures set forth in Section 4.3.
Otherwise, it is never to be bypassed, ignored, or otherwise
defeated;
• Tags shall be legible and understandable by all authorized
employees, affected employees, and all other employees whose
work operations are or may be in the area in order to be effective;
• Tags shall conform to regulatory specifications, as outlined in this
procedure; and
• Tags shall be securely attached to energy isolating devices so they
cannot be inadvertently or accidentally detached during use.

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Policy No:EHS-502 Control of Hazardous Energy (Lockout/Tagout)

4. Employees shall be retrained whenever they change job assignments;

machines, equipment, or processes change that present a new hazard;
or there is a change in the policy or regulation.
5. Retraining shall be conducted when results of the annual inspection
reveal deviations from the Program.
6. All other employees whose work operations are or may be in an area
where the Program may be used, shall be instructed about the
procedures and about the prohibition relating to attempts to re-start or
re-energize machines or equipment which are locked out or tagged
out.
7. Training records shall be maintained, including the employee names
and dates of training and made readily available upon request.
7 Auditing / Inspections
1. An annual inspection of the LOTO Program shall be conducted to
ensure that the Program and the regulatory requirements are being
followed. The inspection shall be:
• Conducted to correct any deviations from the Program;
• Scheduled by Site or Facility Manager and conducted by Shift
Supervisor/Lead Technician or another qualified independent
source;
• Include a review between Headquarters Operation and each
Authorized Employee of their responsibilities under the Program ;
and
• Be recorded and maintained on file, identifying the machines and
equipment where Program was utilized, date of inspection,
employees involved in inspection, and name of Inspector.
2. A random sample of the LOTO paperwork should be reviewed to note
any discrepancies or deviations from the Program.
3. If during the inspection a discrepancy or procedural inadequacy is
found, steps shall be taken immediately to determine the reason for,
and the corrective action necessary to remedy the discrepancy.
4. A sample Audit Inspection Form is supplied to assist in this annual
requirement.
8 References
29 CFR 1910.147 Control of Hazardous Energy (Lock Out/Tag Out)
29 CFR 1910.269 Electric Power Generation, Transmission, and Distribution
9 Forms
See Appendix K

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Policy No:EHS-502 Control of Hazardous Energy (Lockout/Tagout)

K.1 LOTO Index

K.2 Facility Authorized Personnel List
K.3 Annual LOTO Audit / Inspection Form
K.4 LOTO Control Form

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 Environmental Health and Safety
Manual
Policy No. EHS-503 Policy Title: Personal Protective Equipment (PPE)
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 Definitions ................................................................................................................ 2
3 Procedure ................................................................................................................ 2
4 PPE Requirements................................................................................................... 4
5 Training .................................................................................................................... 8
6 Auditing / Inspections ............................................................................................... 8
7 References............................................................................................................... 8
8 Forms....................................................................................................................... 8

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Policy No:EHS-503 Personal Protective Equipment (PPE)

1 Purpose and Scope

The purpose of this procedure is to minimize and control the exposure to hazards and
the potential for injury through the proper selection and use of personal protective
equipment (PPE). It also provides guidance on performing hazard assessments and
generating job safety analyses (JSAs) for specific types of jobs.
2 Definitions
• Hazard Assessment – A documented analysis performed on each job task or
operation to determine all possible hazards of performing that job. Based on the
hazards determined, precautions must be taken to minimize those hazards and
ensure safety (proper PPE, procedures, etc.)

• Job Safety Analysis (JSA) – A method for studying a job in order to identify
hazards or potential accidents associated with each step or task of a job and for
developing solutions or preventative measures that will eliminate, nullify, or
prevent such hazards or accidents. This documented analysis should include
personal protective equipment, based on the hazards identified, for the
employee’s job function and responsibilities.

• Program Administrator – For purposes of this procedure, an individual suitably

trained, designated by the employer (Facility or Site Manager) to administer the
requirements of Hazard Assessments and JSAs.

3 Procedure
A. PPE Inventory
Each Facility or Site must inventory all PPE that is currently in use or in stock at the
Facility. Record the type, style, make, part number and size of PPE, as available.
The sample PPE Inventory Form in this procedure may be used to record all
available data.
• The Facility or Site Manager, or designee shall delegate a Program
Administrator to distribute and control access to the PPE in the inventory.
• The inventory shall be conducted annually or when stock is low.

B. Hazard Assessment
A Hazard Assessment of all job tasks performed in the workplace shall be
conducted. The Hazard Assessment shall be used to develop Job Safety
Analyses, which include appropriate PPE requirements identified in Hazard
Assessment. Every employee should have a JSA for his/her type of job or job
duties. In the Attachment Section of this procedure there is a list of SOME jobs
that, as a minimum, require hazard assessments. The list is not a complete list but
contains some of the more typical jobs / tasks involved in power plant operations.

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Policy No:EHS-503 Personal Protective Equipment (PPE)

The Hazard Assessment shall be conducted with a thorough examination of the

actual job tasks that employee is responsible for and performs. It must identify the
possible hazards encountered in performing the task and identify the safety
precautions necessary to eliminate the hazard, along with the PPE required when
performing the task.
Employees who actually perform the job tasks being evaluated shall conduct the
Hazard Assessment. These individuals know the work process and are most
familiar with and sensitive to the actual and potential hazards of the job.
Hazard Assessments shall be conducted on a priority basis. Job tasks that meet
any of the following criteria should be evaluated first:
• Any job task which has resulted in an injury or accident;
• Job tasks with the potential for chemical exposure (loading / unloading,
transferring totes);
• Job tasks with the potential for electrical exposure; and/or
• Job tasks with the potential for physical exposure (high noise, heat,
vibration, etc.).
In conducting the Hazard Assessments, each job task shall be evaluated for the
following types of hazards:
• Chemical (inhalation, ingestion and skin contact with dust, fumes, mists,
gases, vapors or liquids);
• Electrical;
• Physical (heat, noise, vibration);
• Ergonomic stressors (repetitive motion, lifting, awkward postures);
• Falling/moving/flying objects;
• Radiation;
• Lasers, infrared and ultraviolet light;
• Biological;
• Other (potential for falls, fire, explosion, pinching);
• Need for control measures (machine guarding, ventilation, isolation, worker
rotation, lifting devices and tool designs) to do the job safely; or
• Need to follow procedures (LOTO, Confined Space Entry etc.).
Any previous noise monitoring surveys or air monitoring results shall be
incorporated and made part of hazard assessment.
The Hazard Assessment Form provided in this procedure may be utilized to list the
steps required to perform the job task, the potential hazards associated with each
step, the safety precautions to take to eliminate the hazards and the PPE required
to be worn to perform the job task.
The Hazard Assessment Form shall be reviewed initially, upon completion, to verify
the assessment was conducted properly, and reviewed periodically thereafter. It
must be signed by the Facility Manager (certification) upon completion and review.

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Policy No:EHS-503 Personal Protective Equipment (PPE)

Should any safety deficiency be identified while conducting the Hazard

Assessment, the deficiency shall be corrected immediately. At the least, safety
deficiencies shall be treated as an audit finding and shall be tracked to closure as
soon as possible.
A list of jobs requiring hazard assessments is provided in the Attachment Section
of this procedure.
Should a particular job task change, it must be reviewed by the EHS Engineer,
Safety Coordinator, or designee, at the Site (if applicable) for any process changes
that may impact environmental, health or safety issues. If there is no EHS
Engineer at the Site, duty shall be conducted by the Facility or Site Manager, or
designee.
Should an injury/accident occur while performing a job task, the Hazard
Assessment and JSA shall be reviewed as part of the incident investigation. It
should be determined whether or not the JSA was properly adhered to or if it needs
revision.
C. Link of PPE Inventory and the Hazard Assessments
Upon completion of the PPE Inventory and the Hazard Assessments, the Program
Administrator delegated must verify that the PPE on-site covers the PPE required
to perform the job tasks evaluated for the Hazard Assessments. The PPE identified
must be of the appropriate type as identified by the individual Hazard
Assessments. PPE must also be stocked in sufficient quantities and sizes to meet
the needs of the Facility or Site.
The Hazard Assessment Form must then be filed in a location easily and readily
accessible to all employees and anyone else requesting to review it.
4 PPE Requirements
The following section provides the minimum requirements to protect against hazards
identified at any S&W Energy Facility or Site:
A. Eye and Face Protection – Safety Glasses
Only approved safety glasses that meet regulatory (i.e., OSHA) and ANSI
requirements shall be worn by site employees. The frames shall be plastic and the
lenses shall be impact resistant. Side shields are required.
Safety glasses shall be imprinted with Z87.1 to illustrate the glasses meet the
regulatory and ANSI standard.
Employees who wear prescription glasses shall wear safety glasses that
incorporate their prescription into the lens or shall wear protection over their
prescription glasses. Over protection shall be plastic and impact resistant and shall
display the Z87.1 stamp.
For protection from bright sunlight or injurious light radiation, safety glasses with
filter lenses with a shade number appropriate for the work being performed shall be
worn.

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Policy No:EHS-503 Personal Protective Equipment (PPE)

Contact lenses shall not be worn if an employee’s job involves any of the following:
• Working with chemicals including, but not limited to, fumes, vapors, mists,
solvents, and particulate matter (i.e. fiberglass);
• Welding, soldering, brazing, cutting and grinding; and
• Working in dusty environments.
•
B. Head Protection
Site employees shall wear hard hats at all times while at the Facility or Site except
in designated areas (i.e. office areas, control room, locker room) where a hazard is
present.
Hard hats shall conform to ANSI Standard Z89.1 for protection from falling or flying
objects. When protection from possible electrical shock is required, the hard hat
shall conform to ANSI Standard Z89.2.
Objects will not be carried inside the helmet, as proper clearance is needed for the
protective system to be effective.
Hard hat suspension systems should be replaced when needed.
All hard hats shall be replaced every two to five years, or when the hard hat
displays physical damage (cut, dented etc.) that would compromise the integrity of
the hard hat protection.

C. Foot Protection
Hard or Steel toe, leather upper, ANSI approved (meeting ANSI Z41) safety shoes
with rubber soles are required for all site employees other than those personnel
who work solely in administrative areas.
When working with and loading / unloading chemicals (i.e., ammonia), the use of
rubber boots compatible with those chemicals is required.

The following PPE is required WHEN DETERMINED by Hazard Assessments:

D. Splash Hazard Present – Eye Protection
Chemical Goggles - All chemical goggles shall meet regulatory requirements. The
lens shall be impact resistant. Ventilation buttons should be located on top of the
goggles. Chemical goggles shall be labeled as evidence as meeting regulatory or
ANSI requirements.
Face Shields - Only face shields that meet regulatory requirements shall be worn
by employees. Face shields shall be labeled as evidence of meeting regulatory or
ANSI requirements.
Both chemical goggles and face shields shall be worn when working with or loading
/ unloading chemicals such as ammonia, sulfuric acid, caustic etc.

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Policy No:EHS-503 Personal Protective Equipment (PPE)

A standard sign: “CAUTION, EYE HAZARD AREA, DO NOT ENTER WITHOUT

EYE PROTECTION” or its equivalent, must be posted in every area where eye
protection is mandatory. All employees, Contractor Workers, and visitors entering
such an area must wear the required eye protection.

E. Body Protection
For chemical handling (including loading / unloading), employees shall wear a
complete chemical suit including jacket and bib overalls, plastic or rubberized
apron, rubber gloves, chemical resistant boots, chemical goggles and face shield.
For welding, employees shall wear a leather vest, gloves, flame resistant clothing
and a helmet/face shield with appropriate lenses.
For working on energized equipment or open flames, employees shall wear, flame
resistant clothing and insulated gloves.
For material handling, employees shall wear, at the minimum, general-purpose
gloves. Other body protection may be required depending on the type of material
being handled.

F. Hand Protection
Appropriate hand protection shall be worn when an employee’s hands are exposed
to hazards, such as those from skin absorption of harmful substances; severe cuts,
abrasions or lacerations; punctures; chemical burns; or thermal burns.
Employees must take into consideration when selecting hand protection, the tasks
to be performed, duration of use, and the actual or potential hazards to which they
may be exposed.
Work gloves should be worn whenever possible, except when wearing the gloves
would create a hazard such as in the vicinity of moving parts.
Rubber gloves must be worn when acids and caustics are handled.
Rubber gloves are also necessary in certain situations involving electrical work.
Insulated or heat resistant gloves must be worn when handling steam hose or
when performing other duties in which regular work gloves do not afford adequate
protection against burning of the hands.
Leather or leather-palm gloves should always be worn when handling wire rope.
Gloves should be worn when the hands are wet from any substance causing a
slippery grip.

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Policy No:EHS-503 Personal Protective Equipment (PPE)

G. Hearing Protection
Employees shall wear approved hearing protection when exposed to noise levels
greater than 85 dB and/or where mandatory hearing signs are displayed.
Reference Hearing Protection and Conservation procedure for further hearing
protection requirements.

H. Fall Protection
Employees shall wear an approved full body safety harness with shock absorbing
lanyard when work involves climbing or working 4 feet (1.2 m) or more above a
lower level.
All safety harnesses should be 100% synthetic fiber webbing. Leather buckles,
straps, attachment points, etc. are not acceptable. All snap hooks must be of the
locking type. Body belts and non-locking snap hooks are not acceptable as part of
a personal fall arrest system.
The harness shall fit snugly, be properly adjusted, and buckled. The wearer shall
allow no more slack in the lanyard than is necessary.
All safety harnesses should be regularly inspected for excessive wear or damage
that could cause them to fail.
Harnesses with visible wear or damage should be destroyed, not discarded.
Safety harnesses must not be subjected to treatment that could damage or weaken
them.
Full body safety harness with lifeline will be used by each entrant when working in
confined spaces.

I. Respiratory Protection
Employees shall use approved respirators for all designated job tasks requiring
respiratory protection.
Reference the Respiratory Protection procedure for further respiratory protection
requirements.

PPE should not be the sole method of hazard exposure control.

Administrative tools, engineering controls, and equipment safeguards
should be considered.

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Policy No:EHS-503 Personal Protective Equipment (PPE)

5 Training
All S&W Energy Facility or Site employees (including Field personnel) shall be trained
on the requirements and guidelines of this procedure initially, upon hire. The training
shall include:
• Content and importance of JSA and Hazard Assessment requirements;
• When PPE is necessary;
• What PPE is necessary:
• The proper donning, adjustment and wear of PPE;
• The limitations of PPE; and
• The proper care, maintenance, and useful life and disposal of PPE.
The Facility or Site shall ensure that each affected employee demonstrates that he/she
understands the requirements of this procedure before being allowed to work in areas
where PPE is required.
If there is any change in the hazard or PPE identified for certain tasks or jobs, the JSA
shall be reviewed, amended, and employee retrained to ensure he/she understands the
new hazard and PPE required.
Refresher training is required every 3 years, if not given more frequently due to
changes.
6 Auditing / Inspections
The PPE & JSA Procedure shall be reviewed every 2 years. Documented training
records, Hazard Assessments, and updated JSAs may be reviewed as part of this
inspection or audit. This procedure will be updated as necessary.
7 References
• 29 CFR 1910.132 to 1910.140 PPE Requirements
• ANSI Standard for Eye and Face Protection (ANSI Z87.1)
• ANSI Standard for Protective Footwear (ANSI Z41)
• ANSI Standard for Protective Headgear for Industrial Workers (ANSI Z89.1, or
Z89.2)
8 Forms
See Appendix L
• L.1 - Personal Protective Equipment Inventory
• L.2 - Hazard Assessment Form

Page 8
 Environmental Health and Safety
Manual
Policy No. EHS-504 Policy Title: Respiratory Protection
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 Definitions ................................................................................................................ 2
3 General .................................................................................................................... 3
4 Job & Area Hazard Assessment / Selection of Respirator ....................................... 4
5 Medical Evaluations ................................................................................................. 7
6 Fit Testing ................................................................................................................ 8
7 Maintenance and Care............................................................................................. 9
8 Contractors ............................................................................................................ 11
9 Recordkeeping ....................................................................................................... 11
10 Training .............................................................................................................. 11
11 Auditing / Inspections ......................................................................................... 12
12 References ......................................................................................................... 12
13 Forms ................................................................................................................. 12

Page 1
Policy No:EHS-504 Respiratory Protection

1 Purpose and Scope

The purpose of this procedure is to define the proper selection and use of respiratory
protection equipment, to provide guidance for medical evaluations for those employees
who must wear respirators, to outline the requirements that ensure proper maintenance
and care of respiratory equipment, and to define required training of employees in
regards to respiratory standards. A respiratory program shall be implemented in order
to prevent excessive exposure of employees to occupational dusts, fumes, mists, gases
and vapors.
This procedure and its requirements meet all regulatory obligations for Respiratory
Protection.
2 Definitions
• Air Purifying Respirator - A respirator with an air purifying filter, cartridge, or
canister that removes specific air contaminants by passing ambient air through
the air-purifying element.
• Canister (or Cartridge) – A container with a filter, sorbent, or catalyst, or
combination of these items, which removes specific contaminants from the air
passed through the container.
• Emergency Situation - Any occurrence such as, but not limited to, equipment
failure, rupture of containers, or failure of control equipment that may or does
result in an uncontrolled significant release of an airborne contaminant.
• Employee Exposure – Exposure to a concentration of an airborne contaminant
that would occur if the employee were not using respiratory protection.
• End-of-Service-Life indicator (ESLI) - A system that warns the respirator user
of the approach of the end of adequate respiratory protection, for example, that
the cartridge is approaching saturation or is no longer effective.
• Fit Factor – A quantitative estimate of the fit of a particular respirator to a
specific individual.
• Fit Test – The use of a protocol to qualitatively or quantitatively evaluate the fit
of a respirator on an individual.
• Immediately Dangerous to Life or Health (IDLH) - An atmosphere that poses
an immediate threat to life, would cause irreversible adverse health effects, or
would impair an individual’s ability to escape from a dangerous atmosphere.
• Negative Pressure Respirator – A respirator in which the air pressure inside
the face piece is negative during inhalation with respect to the ambient air
pressure outside the respirator.
• NIOSH – National Institute for Occupational Safety and Health.
• Oxygen Deficient Atmosphere - An atmosphere with oxygen content below
19.5% by volume.
• PLHCP – Physician or other Licensed Health Care Professional; individual
whose legally permitted scope of practice allows him/her to independently
provide or be delegated the responsibility to provide some, or all, of the health
care services required under this Program (i.e.; respiratory protection).

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Policy No:EHS-504 Respiratory Protection

• Positive Pressure Respirator - A respirator in which the pressure inside the

respiratory inlet covering exceeds the ambient air pressure outside the
respirator.
• Pressure Demand Respirator - A positive pressure atmosphere-supplying
respirator that admits breathing air to the face piece when the positive pressure
is reduced inside the face piece by inhalation.
• Program Administrator – An individual suitably trained, designated by the
employer to administer the requirements of this procedure and its elements.
• Qualitative Fit Test - A pass/fail fit test to assess the adequacy of respirator fit
that relies on the individual's response to the test agent.
• Quantitative Fit Test - An assessment of the adequacy of respirator fit by
numerically measuring the amount of leakage into the respirator.
• Self-Contained Breathing Apparatus (SCBA) - An atmosphere-supplying
respirator for which the breathing air source is designed to be carried by the
user.
• Service Life – The period of time that a respirator, filter or sorbent, or other
respiratory equipment provides adequate protection to the wearer.
• Supplied-Air Respirator (SAR) - An atmosphere-supplying respirator for which
the source of breathing air is not designed to be carried by the user.
• Tight-Fitting Face piece – A respiratory inlet covering that forms a complete
seal with the face.
• User Seal Check – An action conducted by the respirator user to determine if
the respirator is properly sealed to the face.
3 General
The Facility or Site must develop and implement a written respiratory protection
program per regulatory standards which includes required work-specific procedures for
required use of respiratory protection. This procedure meets the requirements of these
standards.
The Facility Manager or Lead Supervisor must appoint an individual (referenced as
Program Administrator), or team, to administer or oversee the respiratory
protection program and conduct the required evaluations of program effectiveness.
The Program Administrator shall be selected based on his/her knowledge of the
respiratory hazards at the workplace and the requirements of the respiratory
protection standard.
The respiratory protection program must include the following provisions:
• Procedures for selecting respirators;
• Medical evaluations of employees required to use respirators;
• Fit testing procedures;
• Procedures for proper use of respirators in routine and reasonably
foreseeable emergency situations;
• Procedures and schedules for cleaning, disinfecting, storing, inspecting,
repairing, discarding, and otherwise maintaining respirators;

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Policy No:EHS-504 Respiratory Protection

• Procedures to ensure adequate air quality, quantity, and flow of breathing air
for atmosphere-supplying respirators;
• Training of employees in the respiratory hazards to which they are potentially
exposed during routine and emergency situations;
• Training of employees in the proper use of respirators, including putting on
and removing them, any limitations on their use, and their maintenance; and
• Procedures for regularly evaluating the effectiveness of the program.

Respiratory Protection will be properly used where administrative or

engineering controls fail to reduce air contaminants to within regulatory
prescribed limits. It shall NOT be used as a substitute for accepted
engineering control measures against air contaminants.

4 Job & Area Hazard Assessment / Selection of Respirator

A. Respiratory Protection Hazard Assessment
The Facility or Site shall select and provide an appropriate respirator based on the
respiratory hazards to which the worker is exposed and workplace and user factors
that affect respirator performance and reliability. Respiratory hazards must be
evaluated throughout the workplace environment to identify relevant conditions and
user factors and base selection on these factors.
All respiratory hazard(s) in the workplace shall be identified and evaluated as
part of a Hazard Assessment process. This Hazard Assessment process is
the same process and can be substituted for the process identified in
generating Job Safety Analyses (JSA) for employees (an additional EHS
procedure).
NOTE: JSAs are required by regulation. As hazards are identified per
job, the proper personal protective equipment, which may include
respiratory protection, is identified.
For each job task for which a Hazard Assessment is conducted, a reasonable
estimate of employee exposures to respiratory hazard(s) and an identification
of the contaminant’s chemical state and physical form shall be determined.
Where the employee’s exposure during performance of the job task cannot be
identified or reasonably estimated, an IDLH atmosphere will be assumed. Air
monitoring is the recommended method to establish employee exposure.
The Facility or Site shall determine the routine tasks that could result in
personnel exposure to an atmosphere that is, or could rapidly become,
hazardous. For example, tasks could include spray painting and the handling
of ammonia, acids and caustics, etc.

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Policy No:EHS-504 Respiratory Protection

The Facility or Site shall determine those areas where an oxygen deficient
atmosphere exists or could develop. These areas shall be considered IDLH
atmospheres.
The Facility or Site shall evaluate the nature of emergency response at their
locale. The Facility or Site shall indicate whether respiratory protection shall
be utilized for emergency response efforts or for escape only.
B. Selecting a Respirator
The Facility or Site shall provide a variety of respirator choices to ensure that
each employee required to wear a respirator can obtain an acceptable fit.
Only respirators approved by NIOSH shall be purchased and worn.
Information to be considered in selecting the type of respirator to be used
includes:
•Estimated or actual contaminant concentration where the respirator will be
used;
• Characteristics and limitations of available respirators;
• Regulatory-published Permissible Exposure Limits, Threshold Limit Values, or
NIOSH Recommended Exposure Limit;
• Nature of contaminant: gas, vapor, or particulate;
• Could the contaminant concentration become immediately dangerous to life
or health;
• If the contaminant is flammable, does the estimated or actual concentration
approach the lower explosive limit;
• Does the contaminant have adequate warning properties (i.e. odor);
• Is the contaminant an eye irritant;
• If the contaminant is a gas or vapor, is there an available cartridge that traps it
efficiently and safely;
• Can the contaminant be absorbed through the skin;
• The Respirator Specification Form in the Attachment Section shall be utilized
to document the type of respiratory protection required for the specific hazard
present.
C. Respirator Requirements for Routine Tasks
For protection against gases and vapors, a full or half-face atmosphere
supplying or air-purifying respirator (cartridge or canister type) must be
utilized.
A separate respirator must be purchased and maintained for each site
employee that uses a respirator on a routine basis.
Air-purifying respirators (cartridge or canister type) have limitations to the
concentration for which a particular cartridge/canister can be used. Therefore,
the respirator shall be equipped with an end-of-service-life indicator (ESLI)
certified by NIOSH for the contaminant.

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Policy No:EHS-504 Respiratory Protection

If there is no ESLI appropriate for conditions at the Facility or Site, a change-

out schedule for canisters and cartridges shall be implemented that is based
on objective information or data that will ensure that canisters and cartridges
are changed before the end of their service life. The Facility shall describe the
information and data relied upon, the basis for the canister and cartridge
change-out schedule and the basis for reliance on the data. For more
information on establishing a facility cartridge change-out schedule, see the
Guidance on the Development of a Cartridge Change-Out Schedule and the
Respirator Cartridge Selection Chart in the Attachment Section of this
procedure.
For protection against particulates, an atmosphere supplying respirator or an
air purifying respirator equipped with a filter certified by NIOSH, as a high
efficiency particulate air (HEPA) filter, or an air-purifying respirator equipped
with a filter certified for particulates by NIOSH under, shall be utilized. See
Guidance on the Development of a Cartridge Change-Out Schedule for
reference to a list of respirators approved by NIOSH.
D. Respirator Requirements for IDLH Atmospheres
Facility or Site employees are prohibited to enter IDLH atmospheres EXCEPT
when necessary for response to emergency situations. If entry to an IDLH
atmosphere is necessary, the following requirements must be met:
• Employees in an IDLH atmosphere shall use a full-face pressure demand
SCBA certified by NIOSH for a minimum service life of thirty (30) minutes
or a combination full face pressure demand supplied-air respirator (SAR)
with auxiliary self-contained air supply.
• One employee at a minimum or, when needed, more than one employee
will be located outside the IDLH atmosphere when entry into that IDLH
atmosphere is necessary.
• Visual, voice, or signal line communication will be maintained between the
employees inside the IDLH atmosphere and the employee located outside
the IDLH atmosphere at all times.
• Employees outside the IDLH atmosphere shall be equipped with pressure
demand or other positive pressure SCBA's or SAR with auxiliary SCBA
and appropriate retrieval equipment for removing the employee(s) who
enter the IDLH atmosphere.
E. Respirator Requirements for Emergency Situations
When responding to emergency situations, air supplying-type respirators [i.e.
Self-Contained Breathing Apparatus (SCBA)] must be used. For those
Facilities that have the potential requirement for use of respirators during an
“Emergency Response”, a minimum of two SCBA’s must be purchased and
maintained on-site for emergency response situations.
Respirators provided for escape only shall be NIOSH-certified for escape from
the atmosphere in which they will be used.

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Policy No:EHS-504 Respiratory Protection

If the Facility provides supplied-air and/or SCBA type respirators, the Facility
must confirm with the manufacturer of the compressed air, compressed
oxygen, liquid air, and/or liquid oxygen that the breathing gas meets all
requirements under applicable regulatory standards.
5 Medical Evaluations
This Section specifies the minimum requirements for medical evaluation that must be
implemented to determine an employee’s ability to use a respirator.
The Facility or Site shall identify a physician of licensed health care professional
(PLHCP) to perform medical evaluations using a medical questionnaire or
equivalent medical examination.
The PLHCP shall use a Medical Evaluation Questionnaire (example provided in
Attachment Section) or a similar form that includes all of the information provided in
the example in performing the medical exam. The medical exam and the
questionnaire shall be kept confidential and filed in the employee’s personnel file.
Annually, a PLHCP will perform a medical evaluation to determine that all
employees required to wear respirators are medically fit to wear the respirator.
Pulmonary function tests will be included in the employee’s medical evaluation.
The Facility or Site must provide the PLHCP with a copy of this procedure, a copy
of the regulatory standard and the following information prior to the employee’s
medical exam:

• Type and weight of the respirator to be used;

• Duration and frequency of respirator use;
• Expected physical work effort;
• Additional personal clothing and equipment to be worn; and
• Temperature and humidity extremes that may be encountered.
This information, and any other supplied prior to the medical evaluation, need not
be provided for subsequent evaluations if the information has not changed.
If an employee refuses a medical evaluation/exam, they cannot work in an
atmosphere that requires the use of a respirator.
Employees shall not be assigned to tasks requiring the use of respirators unless
they have been medically evaluated, fit tested (discussed in next section), and
trained on the use and care of their respirator.
Following the exam, the PLHCP will provide the Facility with a recommendation
regarding the employee’s ability to use a respirator. The Respirator Clearance
Evaluation, Examiner’s Written Opinion Form in the Attachment Section can be
utilized but at a minimum the recommendation shall include:
• Any limitations on respirator use related to the medical condition of the
employee including if the employee is not medically able to use the
respirator;

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Policy No:EHS-504 Respiratory Protection

• The need for follow-up exams: A follow-up exam is required when an

employee provides a positive response to any question among questions
1-8 in Section 2 of the sample Medical Evaluation Questionnaire provided
in this procedure; and
• A statement that the employee was provided with a copy of the physician’s
or licensed health care professional’s recommendations.
The PLHCP’s recommendation shall be maintained in the employee’s personnel
file.
Other than annual evaluations, more frequent medical examinations regarding
respirator use shall be administered under the following scenarios:
• An employee reports medical signs or symptoms that are related to the
ability to use a respirator;
• The health care professional administering the program informs the
employer that the employee needs to be reevaluated; or
• A change occurs in the conditions that may result in a substantial increase
in the physiological burden placed on the employee.
6 Fit Testing
Each employee required to wear a respirator shall be either qualitatively or
quantitatively fit tested with the same make, model, style and size of respirator that
the employee will use. The Fit Test Protocol in the Attachment Section of this
procedure shall be utilized.
Whenever possible, the respirator manufacturer’s representative shall provide
employee initial and annual fit testing. Employees trained by the manufacturer’s
representative are also qualified to perform fit testing of Facility personnel.
Fit testing for all employees required to wear a respirator shall be performed in a
test environment at the time of initial fitting, whenever a different respirator face
piece (size, style, model, or make) is used, and at least annually thereafter.
The isoamyl acetate procedure shall be used as the preferred qualitative fit test
method. Irritant smoke shall be used as an alternate method.
Fit test results shall be documented, including the date, name of the tester, type of
test, test results, employee name, and name and model number of the respirator
which was found to fit properly. See Attachment Section for the documentation
form.
Employees shall perform field qualitative fit checks and field inspection prior to
entering a contaminated atmosphere. Field Qualitative fit checks shall consist of
the following checks:
• Positive pressure check: Close exhalation valve with palm. Breathe into
mask. Fit is satisfactory if some pressure can be built up inside mask
without any leakage.

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Policy No:EHS-504 Respiratory Protection

• Negative pressure check: Close off the inlet openings of the cartridge with
palms. Inhale gently so that a vacuum occurs within the face piece, and
hold breath for 10 seconds. If no inward leakage is detected, then the
respirator seal is good.
The Facility or Site shall prohibit employees to wear a respirator when conditions
prevent a good seal of the respirator face piece to the face. This may include:
Facial hair that comes between the sealing surface of the face piece and the face
or that interferes with valve function;
Temple pieces on glasses, goggles or other personal protective equipment.
Absence of one or more dentures.
Site employees shall notify the Facility Manager or Supervisor if there is any
reason why the fit of their respirator may be compromised. An additional fit test
shall be conducted whenever the employee reports or the Facility Manager, a
Supervisor or any employee makes a visual observation of changes in an
employee’s physical condition that could affect respirator fit. Such conditions
include, facial scarring, dental changes, cosmetic surgery or an obvious change in
body weight.
7 Maintenance and Care
A. Cleaning and Disinfection
Individual employees shall clean and disinfect their own respirators as often as
necessary to be maintained in a sanitary condition. Employees shall follow the
Respirator Cleaning and Disinfection Procedure provided in Appendix M.
Disposable respirators can be reused if they will continue to provide the same
protection to employees.
Disinfection before use is required if respirators are used by more than one
person.
Emergency use respirators shall be cleaned and disinfected after each use.
B. Storage
After cleaning, respirators shall be stored to protect them from damage,
contamination, dust, sunlight, extreme temperatures, excessive moisture, and
damaging chemicals. They shall also be packed or stored to prevent
deformation of the face piece and exhalation valve.
Emergency and rescue respirators shall be quickly accessible and stored in a
clearly marked container.
Respirators shall be placed in plastic bags and sealed. Respirators shall be
stored in this manner whenever they are not in use.
7.8 Respirators shall be stored so that the face piece and exhalation valve are
not bent or distorted.

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Policy No:EHS-504 Respiratory Protection

C. Inspection
Respirator inspection shall include (where applicable) checking the tightness
of connection and condition of the face piece; the head straps; the gaskets
and diaphragms; valves, the connecting tube, cartridges, and canister or
filters; and rubber parts for pliability and deterioration.
Employees shall inspect routine use respirators before each use and during
cleaning.
Respirators maintained for use in an emergency shall be inspected monthly
and shall be checked for proper function before and after each use.
Emergency escape-only respirators shall be inspected before being carried
into the workplace for use.
SCBA's shall be inspected monthly. Air and oxygen cylinders shall be
maintained in a fully charged state and shall be recharged when the pressure
falls to 90% of the manufacturer’s recommended pressure level. Any
deficiencies identified during the monthly inspection shall be corrected
immediately, or the SCBA shall be removed from service.
Monthly inspection information of SCBA’s and respirators maintained for
emergency use shall include the date of the inspection, the name of the
inspector, the findings / deficiencies, required corrective actions and a serial
number or other means of identifying the inspected respirator. This
information may be documented on a tag attached to the respirator, the
storage compartment for the respirator or as an inspection report stored as
paper or electronic files. The SCBA Inspection Form in the Attachment
Section of this procedure is recommended for documenting these inspections.
D. Repair
Respirators that fail inspection or are otherwise found to be defective must be
removed from service, and must be discarded or repaired or adjusted in
accordance with the following procedures (always reference manufacturer’s
recommendations):
• Repair shall be done only by persons trained in proper respirator assembly.
• Replacement and repairs shall not deviate from manufacturer's
recommendations.
• Replacement parts shall be only those designed for the specific respirator
being worn.
• A supply of replacement parts shall be maintained.
Disposable respirators shall be discarded when they require repair.

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Policy No:EHS-504 Respiratory Protection

8 Contractors
Contractors shall provide respiratory protection for their own employees under their
own respiratory protection program.
Contractors are responsible for ensuring their Contractor Workers have the proper
respiratory fit testing and training.
Contractors shall not engage in practices that violate the requirements of this
procedure or S&W Energy’s Contractor Safety Policy.
Contractors must comply with the requirements outlined in the regulatory
standards.
9 Recordkeeping
Records of medical evaluations regarding respiratory protection shall be retained at
least as long as the employee’s duration of employment PLUS 30 years.
Fit Test records, either quantitative or qualitative, shall be retained until the next fit
test is conducted (annually).
A written copy of the most current Respiratory Protection Program shall be
maintained on file for life of Facility or service. It shall be updated as necessary
and made readily accessible.
10 Training
Respiratory Protection Fit Testing training will be conducted for all employees who
will be responsible for wearing a respirator both initially when hired, annually
thereafter, and after any change which might affect the fit of a respirator.
All S&W Energy employees (at a Facility or Site or Field personnel) who will
be wearing a respirator or be involved in emergency situations where
respirators may be used, shall be trained on the requirements and guidelines
of this procedure at least on an annual basis. Training shall include:
• Why the respirator is necessary and how improper use, fit, or maintenance
can compromise the protective effect of equipment;
• What the limitations and capabilities of the respirator are;
• How to use the respirator effectively, especially during emergency
situations or instances where respirator malfunctions;
• Instructions on the proper donning and wearing of the respirator and
checking its fit and operation (including demonstrations);
• Instructions in maintenance, storage, and inspection of the respirator;
• The rationale of the respirator selection used based on the nature of the
hazard;
• A discussion on the importance and timing of changing filters and/or
cartridges; and
• How to recognize medical signs and symptoms that may limit or prevent
the effective use of respirators.

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Policy No:EHS-504 Respiratory Protection

•
Retraining may be more frequent under the following circumstances:
• Changes in the workplace that may affect respirator use; or
• Inadequacies of the employee’s knowledge and understanding of the
program or any of its parts.
11 Auditing / Inspections
The Respiratory Protection Procedure shall be reviewed every two years. This
procedure will be updated as necessary. During this review, the Inspector or
Auditor shall:
• Ensure employees are using the respirators correctly;
• Ensure the Program, and all its elements, are being met and satisfied;
• Ensure proper hazard assessments were conducted and the appropriate
respirator is being used accordingly; and
• Ask employees for their views on the Program effectiveness. Employees
shall be asked to comment on their respirator fit, appropriate respirator
selection for the hazards they may encounter, proper respirator use under
the conditions at the Facility and proper respirator maintenance. Any
problems identified by an employee shall be corrected.
Any records may be reviewed during this audit or inspection.
12 References
29 CFR 1910.134 Respiratory Protection
42 CFR Part 84 Respirator Cartridge Selections
ANSI Z88.6-1984 ANSI Standard for Respirator Use - Physical
Qualifications for Personnel
ANSI Z88.2 – 1992 ANSI Standard for Respiratory Protection
ANSI K13.1-1973 Identification of Air Purifying Respirator Canisters and
Cartridges
13 Forms
See Appendix M
• M.1 - Respirator Specification Form
• M.2 - Guidance on Development of a Cartridge Change-Out Schedule
• M.3 - Respirator Cartridge Selection Chart
• M.4 - OSHA Medical Evaluation Questionnaire
• M.5 - Fit Test Protocol
• M.6 - Respirator Fit Test Documentation Form
• M.7 - Respirator Cleaning and Disinfection Procedure
• M.8 - SCBA Inspection Form

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 Environmental Health and Safety
Manual
Policy No. EHS-505 Policy Title: Hearing Protection and Conservation
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 Definitions ................................................................................................................ 2
3 Monitoring Procedure – General Requirements and Information ............................. 3
4 Monitoring Procedure – Area Monitoring.................................................................. 4
5 Monitoring Procedure – Personal Monitoring ........................................................... 4
6 Monitoring Procedure – Other Requirements........................................................... 5
7 Audiometric Testing ................................................................................................. 5
8 Hearing Protection - Equipment ............................................................................... 7
9 Training .................................................................................................................... 7
10 Auditing / Inspections ........................................................................................... 8
11 References ........................................................................................................... 8
12 Forms ................................................................................................................... 8

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Policy No:EHS-505 Hearing Protection and Conservation

1 Purpose and Scope

This procedure provides all regulatory required elements and guidance for implementing
a hearing conservation program. The procedure outlines monitoring, testing,
appropriate protective equipment (both area and personal), training, and recordkeeping
requirements for protection against occupational noise exposure.
Regulations require that Facilities or Sites must be monitored to determine area noise
levels and that a hearing conservation program must be implemented where
employees’ are exposed to occupational noise levels that exceed 85 dBA on an 8-hour,
time weighted average (TWA) basis.
2 Definitions

• Action Level – An 8-hour time-weighted average of 85 decibels measured on

the A-scale, slow response, or equivalently, a dose of 50 percent.
• Area Noise Monitoring Survey – A survey conducted using a sound level
meter to determine the levels of noise (in decibels) for a given or specified area.
• Attenuation – The method to reduce the amplitude or magnitude of noise
levels by use of hearing protection; to reduce in force. Different hearing
protection offers different levels and amounts of attenuation.
• Audiogram – A chart, graph, or table resulting from an audiometric test
showing an individual’s hearing threshold levels as a function of frequency.
• Audiologist – A professional specializing in the study and rehabilitation of
hearing, who is certified by the Speech-Language-Hearing Association (or
equivalent) or licensed by a Board of Examiners.
• Baseline Audiogram – The audiogram against which future audiograms are
compared.
• Decibels (dBAs) – A unit to measure noise level, measuring relative difference
in power, usually between acoustic signals; a unit of measure of sound.
• Hertz (Hz) – Unit of measurement of frequency, numerically equal to cycles per
second.
• Noise Dosimeter – An instrument that integrates a function of sound pressure
over a period of time in such a manner that it directly indicates a noise dose. A
dosimeter stores sound level measurements and integrates these
measurements over time, providing an average noise exposure reading for a
given period of time, such as an 8-hour workday.
• Otoloryngologist – A physician specializing in the diagnosis and treatment of
disorders of the ear, nose, and throat.
• Personal Noise Monitoring Survey – A survey conducted using personal
noise dosimeters over a period of time, determining the noise exposure of the
individual over that time period (typically 8-hour time weighted average).
• Sound Level – Ten times the common logarithm of the ratio of the square of
the measured A-weighted sound pressure to the square of the standard
pressure.

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Policy No:EHS-505 Hearing Protection and Conservation

• Sound Level Meter – An instrument for the measurement of sound level,

measuring intensity at a given moment.
• Standard Threshold Shift - A change in hearing threshold relative to the
baseline audiogram of an average of 10 dBA or more at 2000, 3000, and 4000
Hz in either ear.
• Time-Weighted Average (TWA) – Sound level which if constant over the
specified exposure time period (i.e. 8-hour), would result in the same noise
dose as is measured.
3 Monitoring Procedure – General Requirements and
Information
The noise levels of each Facility or Site must be monitored initially and every time there
is a change to the plant's configuration or operation that could change the noise profile.
All personnel shall have the opportunity to observe noise level surveys being
conducted, and to review the results of these surveys. Surveys are to be conducted
according to the following procedures:
Based on the results of noise monitoring, if employees will be subjected to noise
levels exceeding those listed in the table below, employee exposure to these noise
levels must be controlled in one of more of the following methods:

Hours Per dBA Hours Per dBA

Day Day
8 85 1.5 102
6 92 1 105
4 95 .5 110
3 97 .25 115
2 100 None 140

Implementing practical and feasible engineering solutions and adaptations to

reduce noise levels. These may include, but are not limited to, mechanical
isolation, screening, enclosing, vibration damping, etc.
Limiting the time during which an employee may be exposed to the hazardous
noise levels. An employee may not be exposed to noise levels for time
periods exceeding those listed in the table above unless personal hearing
protection is provided and used (administrative control).
If controls are not practical or feasible to implement to reduce noise levels
below the listed values in the table, personal protective equipment shall be
provided and used to reduce the levels.
A hearing conservation program must be implemented if 8-hour time-weighted
average exceeds 85 dBA. The hearing conservation program will consist of all

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Policy No:EHS-505 Hearing Protection and Conservation

elements outlined in this procedure. Implementation of this procedure satisfies

requirements of this program.
4 Monitoring Procedure – Area Monitoring
Using sound level meters, area monitoring shall be performed (can be part of general
monitoring). Area monitoring is conducted to determine the noise level present in
various areas of the Facility or Site.
The Facility or Site shall determine a monitoring route. This route should include
all locations personnel would be expected to go during a shift or workday.
Area noise monitoring shall be conducted along this route using the calibrated
sound level meter set on the A-scale at slow response (refer to manufacturer
guidelines and instructions on proper care and use of equipment).
Noise level readings shall be recorded along with the date, time, general
equipment status, location of reading, and any other factors that might affect
the plant's noise levels. A suitable form for recording this data is provided in
this procedure. A marked-up site map should be attached to the form
indicating Facility or Site areas with noise levels exceeding 85 dBA.
Based on the results of area noise monitoring, the following actions shall be taken:
Hearing protection must be worn when working in all areas determined in the
area survey to have noise levels exceeding 85 dBA.
Double hearing protection must be worn in any area having noise levels over
100 dBA. Personnel should limit their exposure to noise levels over 100 dBA.
S&W Energy will provide the appropriate hearing protection to all employees
and Facility or Site visitors based on the results (this responsibility will be
determined in advance). Employees must be given the opportunity to select
their hearing protection based on review of area monitoring results.
All areas requiring hearing protection or are high noise areas shall be clearly
marked. All areas requiring double hearing protection shall be marked
"Double Hearing Protection Required".
5 Monitoring Procedure – Personal Monitoring
Using dosimeters, personal noise monitoring shall be performed (can be part of general
monitoring). Personal noise monitoring is conducted to determine the average noise
level to which employees are exposed. The average is referred to as a time-weighted
average.
Personnel must be broken down into groups of employees normally exposed to
similar noise levels. A typical group breakdown could include lead operators, junior
operators, and mechanics.
The dosimeter should be reset and calibrated (refer to manufacturer’s guidelines
on proper care and use of equipment). Employees shall wear dosimeters during

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Policy No:EHS-505 Hearing Protection and Conservation

their normal workday. A TWA should be determined for a representative of each

job group.
Take two separate surveys for each job group. After each survey, the following
information shall be recorded:

• Date and time period of monitoring;

• Name and job group of the person monitored;
• Operational status (what are conditions at time of monitoring); and
• Any other variables which might affect the noise level.

A suitable form for recording this data is provided in this procedure (in Appendix N)
Based on results of Personal noise monitoring, the following actions shall betaken;
If personal noise monitoring results indicate that any job group is exposed to a
TWA exceeding 85 dBA, all members of that job group must be notified, in
writing, of their exposure level.
If a job group TWA exceeds 90 dBA, management must be notified to review
the feasibility of administrative and engineering controls to reduce this
exposure level.
All areas of high noise levels shall be clearly marked
6 Monitoring Procedure – Other Requirements
Copies of all area and personal noise monitoring results are to be available for any
audit or for personnel to review. Records of these surveys shall be retained
indefinitely.
Monitoring shall be repeated whenever a change in production, process, or
equipment, or controls, increases noise exposure to the extent that:

• Additional employees may be exposed at or above the action level; or

• The attenuation provided by hearing protectors may be rendered in
adequate.
Any employee shall be given the opportunity to observe any noise measurements
conducted.

7 Audiometric Testing
If the implementation of a hearing conservation is mandated by the noise monitoring
process, S&W Energy Facility or Site personnel shall undergo baseline and annual
audiograms. Audiograms must be performed and evaluated in accordance with
regulatory standards. Audiometric tests shall be administered by a licensed or certified
audiologist, otolaryngologist, a physician, or technician who is certified by the Council of

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Policy No:EHS-505 Hearing Protection and Conservation

Accreditation in Occupational Hearing Conservation (or equivalent) or who has

satisfactorily demonstrated competence in administering audiometric examinations.
Within 6 months of an employee’s first exposure at or above the noise action level,
a valid baseline audiogram shall be conducted for that employee. If for any reason
the baseline is not given within that first 6-month period, employee shall wear
hearing protection for any period exceeding that 6 months until the baseline is
obtained.
Baseline audiogram tests shall be preceded by at least 14 hours without
exposure to workplace noise. Hearing protection may be substituted for this
requirement.
Employees must be notified of the need to avoid high levels of occupational
noise for the 14-hour period preceding the baseline audiogram.
The audiogram from the pre-employment physical may serve as the baseline
audiogram.
At least annually after receiving the baseline audiogram, a new audiogram shall be
conducted for those subject employees.
The annual audiogram shall be compared to the baseline to determine if a standard
threshold shift has occurred or other problems exist.
If annual audiogram shows a standard threshold shift has occurred, employee
may obtain retest (to verify) within 30 days and consider the retest as their
annual audiogram.
If annual audiogram shows a standard threshold shift has occurred, the
employee shall be notified of this fact in writing within 21 days of
determination.
If it is suspected by physician or audiologist that a problem exists, the
employee shall be notified and all tests and test results shall be reviewed with
him/her.
Unless the physician or audiologist determines that the standard threshold
shift or other problems identified are not work or occupational-related, S&W
Energy shall:

• Fit employees with the proper hearing protection (if employees not wearing
any) and train them in the proper use and care of such protection;
• Refit employees with hearing protection of greater attenuation (if
employees currently wearing protection) and retrain them on the proper
use and care of such equipment; or
• Refer employee to clinical physician for additional testing if it is suspected
that the shift or problem is caused or aggravated by wearing hearing
protection.

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Policy No:EHS-505 Hearing Protection and Conservation

Audiometric test results should be evaluated to determine if hearing degradation is

occurring.
Audiometric test results shall be maintained by S&W Energy and shall contain the
following information:

• Name and job classification of employee;

• Date of the audiogram;
• The examiner’s name;
• Date of last calibration of audiometer; and
• Employee’s most recent noise exposure assessment.
Audiometric test results shall be maintained for the duration of the employee’s
employment. The employee or former employer or designated representatives
shall provide access to records upon request.
8 Hearing Protection - Equipment
Hearing protection shall be provided or made available to ALL employees exposed
to an 8-hour TWA of 85 dBA or greater. Hearing protection shall be replaced as
necessary. Employees may request hearing protection even if the noise levels are
below the published action levels.
Hearing protection shall be enforced in areas posted as such, based on noise
surveys or other requirements.
Employees shall be able to select the most suitable hearing protection for them, as
provided by S&W Energy. S&W Energy (the Facility or Site Manager) shall ensure
that appropriate hearing protection is made available to employees.
Employees shall be provided training on hearing protection as well as training on
proper use and care of protection. Fit testing shall be provided for those required
to wear hearing protection.
For areas where hearing protection is required, hearing protector attenuation shall
be evaluated to ensure the protectors are providing the proper level of protection or
id additional protection is required.
9 Training
All Facility or Site employees (including Field personnel) shall be trained on the
requirements and guidelines of this procedure annually. The following topics must
be covered:
• The effects of noise on hearing;
• The purpose of hearing protection, its advantages and disadvantages;
• Attenuation of various types;
• Instructions on selecting, fitting, use and care of hearing protection; and
• The purpose of noise surveys and audiometric testing (brief description of
procedures).

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Policy No:EHS-505 Hearing Protection and Conservation

10 Auditing / Inspections
The Hearing Protection and Conservation Procedure shall be reviewed every two
years. This procedure will be updated as necessary.
Audiometric results shall be inspected annually to determine if standard threshold
shift has occurred.
11 References
29 CFR 1910.95 (& Appendices) Occupational Noise Exposure
12 Forms
See Appendix N
• N.1 - Area / Personal Noise Monitoring Survey Record
• N.2 - Hearing Protection and Conservation Program Auditing Checklist

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 Environmental Health and Safety
Manual
Policy No. EHS-506 Policy Title: Hazard Communications
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 Definitions ................................................................................................................ 2
3 Chemical Management Requirements ..................................................................... 4
4 Written Hazard Communications (HAZCOM) Program ............................................ 6
5 Labels and Other Forms of Warning ........................................................................ 7
6 Material Safety Data Sheet (MSDS)......................................................................... 8
7 Training .................................................................................................................... 9
8 Auditing / Inspections ............................................................................................. 10
9 References............................................................................................................. 10

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Policy No:EHS-506 Hazard Communications

1 Purpose and Scope

This procedure provides the requirements and guidelines to ensure either the
employees at the workplace or the supplier evaluates hazardous substances and
materials manufactured or received in the workplace and that information concerning
their hazards is communicated to all employees. The HAZCOM procedure includes the
requirements for developing and maintaining a written hazard communication program
for the workplace, including lists of hazardous chemicals on site, labeling and storage
requirements for hazardous materials as well as information regarding Material Safety
Data Sheets, MSDS, (their definition and function).
This procedure requires each Facility or Site to develop a written Hazard
Communication Program and outlines the elements that shall be included in the written
document. This procedure also includes guidance on the Facility or Site’s chemical
management requirements (inventory, storage, handling, hazardous material approval
process, etc.).
The HAZCOM program and procedure does NOT include guidelines regarding
hazardous wastes (procedures and guidelines included in a separate procedure) or
hazardous chemicals / substances contained within articles (see definition of article).
2 Definitions
• Article – A manufactured item other than a fluid or particle which is formed to a
specific shape or design during manufacture process, which has end use
functions dependent in whole or in part upon its shape or design during end
use, which under normal conditions of use does not release more than very
small quantities of a hazardous chemical and does not pose a physical or
health hazard.
• Chemical – Any element, chemical compound or mixture of elements or
compounds.
• Combustible Liquid – Any liquid having a flashpoint at or above 100 degrees
F but below 200 degrees F, except any mixture having components with
flashpoints of 200 degrees F or higher, the total volume of which makes up 99%
or more of the total volume of the mixture
• Container – Any bag, barrel, bottle, box, can, cylinder, drum, reaction vessel,
storage tank, secured tank truck or the like that contains a hazardous chemical.
For purposes of this procedure, pipes or piping systems as not to be considered
containers.
• Exposure or Exposed – Describes that an employee is subjected in the course
of employment to a chemical that is a physical or health hazard, and includes
potential (accidental or possible) exposure.
• Flammable – A chemical that falls into one of the following categories:
• Flammable Gas – A gas that at ambient temperature and pressure forms a
flammable mixture with air at a concentration of 13% by volume or less;
• Flammable Liquid – Any liquid of having a flashpoint below 100 degrees F,
except any mixture having components with flashpoints of 100 degrees F or

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Policy No:EHS-506 Hazard Communications

higher, the total of which make up 99% or more of the total volume of the
mixture;
• Flammable Solid – A solid agent other than an explosive or blasting agent, that
is liable to cause fire through friction, absorption or moisture, spontaneous
chemical change, or retained heat from manufacturing or processing, or which
can be ignited readily. When ignited readily, a flammable solid burns vigorously
and persistently as to create a serious hazard.
• Flashpoint – Lowest temperature at which a liquid or solid gives off a vapor in
such a concentration that when the vapor combines with air near the surface of
the liquid or solid, a flammable mixture is formed and ignites. The lower the
flashpoint, the more flammable the product.
• Hazardous Chemical – Any chemical, which is a physical hazard or a health
hazard.
• Hazardous Material – Material possessing a high potential for harmful effects
upon persons.
• Hazard Warning – Any words, pictures, symbols, or combination thereof
appearing on a label or other appropriate form of warning which convey the
specific physical and health hazard(s), including target organ effect(s) of the
chemical(s) in the container(s).
• Health Hazard – A chemical for which there is statistically significant evidence
based on at least one study conducted in accordance with established scientific
principles that acute or chronic health effects may occur in exposed employees.
• Immediate Use – In reference to this procedure, immediate use means the
hazardous chemical will be under the control of and used only by the person
who transfers it from a labeled container and only within the work shift in which
it is transferred.
• Label – Any written, printed, or graphic material displayed on or affixed to
containers of hazardous chemicals.
• Material Safety Data Sheet (MSDS) – Written or printed material concerning a
hazardous chemical which is prepared by the manufacturer of a chemical that
contains, among other information, the name, physical properties and chemical
characteristics, hazards associated with the chemical, appropriate personal
protective equipment to be worn when using the chemical, storage
requirements, and what to do in case of an emergency with the chemical. All
information provided on an MSDS shall be in accordance with regulatory
standards.
• Physical Hazard – A chemical for which there is scientifically valid evidence
that it is a combustible liquid, a compressed gas, explosive, flammable, an
organic peroxide, an oxidizer or unstable or reactive material.
• Trade Secret – Any confidential formula, pattern, process, device, information
or compilation of information that is used in an employer’s business, and that
gives the employer an opportunity to obtain an advantage over competitors who
do not know or use it.

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Policy No:EHS-506 Hazard Communications

The Facility or Site’s HAZCOM Program and procedure also serves as a

guide to the Facility or Site’s Chemical Management requirements.

3 Chemical Management Requirements

A. Approval and Inventory
The Facility shall develop a list of all hazardous chemicals on-site, or in more
general terms, keep a current chemical inventory. The list or inventory shall be
developed by the Facility Manager or designee and kept up-to-date as new
chemicals are added and others are deleted from the list.
The written inventory should be classified into categories of hazardous
chemicals or materials, according to specific regulatory classifications and
definitions. Designations include hazardous materials, extremely hazardous
substances, hazardous waste, acutely hazardous substances, etc.
Most of the designations have a separate EHS procedure dedicated to that
topic. Reference regulatory standards and S&W Energy’s EHS Manual for the
requirements of different classifications of hazardous materials.
The Facility shall develop an approval process, where the chemicals on-site must
be approved before being accepted. The chemical approval process shall include
criteria based on several factors such as the physical or health hazards associated
with the chemical, its ability to perform its function, its byproducts (after use), etc.
The approval process shall include a systematic check, where it must be approved
by every department before being accepted.
Once on the Approved Site Chemical Inventory, each hazardous chemical or
material accepted and brought on-site must be accompanied by an MSDS. No
chemical shall be accepted or received unless the appropriate MSDS is provided.
Containers of hazardous materials entering the Facility or Site must be
checked to ensure that the materials are properly labeled with the chemical
name and contents, the appropriate hazard warning, and the name and
address of the supplier or manufacturer.
It is recommended that the labeling follow a standard and recognizable
labeling system such as NFPA standards.
Reference the HAZCOM labeling portion of this procedure for details on
labeling requirements for hazardous materials.
Each MSDS must be maintained by the Site and made readily accessible to all
employees. MSDS’s shall be current and reflect the inventory of hazardous
chemicals on-site at that time. MSDS’s for those chemicals that are no longer on-
site shall be maintained for the life of the facility.

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Policy No:EHS-506 Hazard Communications

B. General Drum Handling and Storage of Hazardous Materials

Hazardous materials shall be stored in drums that are in good condition. The
material must be compatible with the drum.
The drum storage area shall be designed and operated to contain any leaks or
spills (the proper containment shall be installed). The area should be covered
unless a drainage system is installed to properly handle rainwater accumulation.
The hazardous material storage area shall be inspected regularly. The inspector
shall check for leakage and deterioration of the drums or the containment system.
Ignitable and reactive materials must be stored at least 50 feet (17 meters) inside
the Facility property line.
Incompatible materials must be kept separated by barriers such as walls, berms,
etc.
Drums must be clearly marked with the amount and contents of the container and
the hazards of the material. Refer to the Hazard Communication portion of this
procedure for information on labeling.
C. Handling and Storage of Flammable and Combustible Materials
Small quantities of flammable liquids should be stored in approved safety
containers. These approved safety containers have self-closing caps, flame
arrestors, and pressure relief vents. The container shall be labeled accordingly.
Dispensing drums shall be equipped with a special self-closing faucet and a
pressure-vacuum relief vent. A ground wire shall also be attached.
Storage cabinets, rooms, or specified area should be designated to store
flammable liquids. Large quantities of flammable liquids should be stored well
away from the immediate work area. Reference the regulatory standards for
specifications on cabinets and storage rooms.
Never handle a flammable substance near a heat source or bring a heat source
near a flammable substance.
Safe transfers of flammable liquids are made in an open, well-ventilated area
where the vapors will be dissipated by large volumes of fresh air. Employees shall
ensure there is a bond between containers to eliminate static electricity.
Using funnels and spouted cans are recommended for quick transfers and
prevention of spills.
Rags saturated with flammable or combustible liquids are highly susceptible to
spontaneous combustion and must be disposed of in containers provided for that
purpose. They shall never be piled on the ground.

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Policy No:EHS-506 Hazard Communications

4 Written Hazard Communications (HAZCOM) Program

Each Facility shall develop, implement and maintain at each workplace, a written
hazard communication program.
The HAZCOM program shall describe how the following are met at the
specified workplace:
• Labeling and other forms of warning for hazardous chemicals;
• Acceptance, use, and maintenance of Material Safety Data Sheets
(MSDS’s); and
• Distribution of information to employees and employee training.
The written HAZCOM program shall include a list of the hazardous chemicals
known to be present at the Facility, using identities or names located on the
chemical’s MSDS. The list may be compiled for the Facility or Site as a whole
or for individual work areas. Reference the Chemical Inventory, as described
in Section 3.
The written HAZCOM program shall include the methods the Facility or Site
will use to inform employees of the hazards associated with chemicals
contained in their work areas (whether they are associated with non-routine
tasks or in unlabeled pipes).
If the Facility or Site uses or stores hazardous chemicals on site, they must make
provisions to inform employees of other employers working on-site (i.e.,
construction, contractors, etc.) of the elements of the Site’s HAZCOM program, if
there is a potential of exposure. The Facility shall ensure the following:

• The other employer’s employees have access to MSDS’s for each

hazardous chemical they may be exposed to;
• The methods the employer will use to inform the other employer’s
employees of any precautionary measures that need to be taken to protect
them during an emergency involving these chemicals; and
• The methods used to inform the employer’s employees of the Facility’s
labeling system used in the workplace.

The written HAZCOM Program shall be made readily available, upon request, to
employees, their designated representatives, or any regulatory agency. It is
recommended that a copy of the program be positioned in a central location, i.e., a
control room or office, so that it can be accessed at any time. This should be the
centralized location where the MSDS’s are located as well. Contact the S&W
Energy EHS Manager for a written HAZCOM program template.

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Policy No:EHS-506 Hazard Communications

5 Labels and Other Forms of Warning

Each Facility shall ensure that each container of hazardous chemicals leaving the
workplace are properly labeled, tagged, or marked. These containers shall be
labeled with the following information, at the minimum:

• Identity of the hazardous chemical;

• Appropriate hazard warnings; and
• Name and address of chemical manufacturer, importer, or other
responsible party.
The labeling of hazardous material containers leaving the Facility shall be in
accordance with the regulatory standards outlined in this procedure as well as
in accordance with the standards of the Department of Transportation (DOT)
and their labeling guidelines for hazardous chemicals. The two labeling
systems shall not be in conflict with one another.
Each Facility shall ensure that each container of hazardous chemicals in the
workplace is labeled, tagged or marked with the following information, at a
minimum:
• Identity of the hazardous chemical therein; and
• Appropriate hazard warnings, or alternatively, words, pictures, symbols, or
combination thereof, which provide at least general information regarding
the hazards of the chemicals, and which in conjunction with the other
information immediately available to employees under the HAZCOM
program, will provide employees with specific information regarding the
physical and health hazards of the hazardous chemical.
Employer shall ensure that the labeling system is consistent using recognized
labels or tags. It is recommended that the labeling be consistent with NFPA or
other equivalent standards.
Portable containers of hazardous chemicals are not required to be labeled if the
hazardous chemicals are transferred from labeled containers and which are
intended for immediate use by the employee who performs the transfer.
Process vessels containing hazardous material shall be labeled. Examples include
ammonia tanks, acid and caustic tanks, waste oil containers, and chemical mixing
tanks.
Piping containing hazardous materials shall be labeled indicating the substance in
the pipe. This includes ignitable materials such as natural gas and fuel oil. The
distance between labels should not exceed 25 feet. Pipe labels shall contain the
contents and the direction of flow within the pipe.
No one shall remove or deface existing labels on containers of hazardous
chemicals unless the container is immediately marked with the required information
following removal of original label.

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Policy No:EHS-506 Hazard Communications

The labels or other forms of warning shall be legible, in the appropriate language(s)
so all employees understand, and prominently displayed on each container or
readily available in the work area throughout each work shift.
If the Facility becomes newly aware of any significant information regarding the
hazards of a chemical, the labels designated to that chemical shall be revised
within three months of becoming aware of the new information.

6 Material Safety Data Sheet (MSDS)

Each Facility shall obtain and maintain a material safety data sheet for each
hazardous chemical that is used in the workplace.
Each MSDS shall be in a language that can be read and understood by all
employees and shall contain at least the following information:
• The identity used on the label. If the hazardous chemical is a single
substance, the chemical and common name should be provided. If the
hazardous chemical is a mixture, the chemical and common names of the
ingredients which contribute to the known hazards and the common name
of the mixture itself shall be provided;
• Physical and chemical characteristics of the hazardous chemical (such as
flashpoints, vapor pressures, etc.);
• Physical hazards of the hazardous chemical including potential for fire,
explosion, or reactivity;
• Health hazards of the hazardous chemical including signs and symptoms
of exposure and any medical conditions which are generally recognized as
being aggravated by exposure to the chemical;
• The primary routes of entry;
• The permissible exposure limits used or recommended by the chemical
manufacturer or responsible party who prepared the MSDS, where
available;
• Information concerning whether or not the hazardous chemical is a
carcinogen or is a possible carcinogen;
• Any generally applicable precautions for safe handling and use which are
known to the chemical manufacturer or responsible party preparing the
MSDS, including appropriate hygienic practices, protective measures, and
procedures for clean-up or spills and leaks;
• Emergency and first aid procedures;
• The date of preparation of the MSDS or the last revision or change to it;
and
• The name, address and telephone number of the chemical manufacturer or
other responsible party preparing or distributing the MSDS who can
provide additional information on the hazardous chemical and appropriate
emergency procedures, if necessary.

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Policy No:EHS-506 Hazard Communications

If no relevant information is found for any given category on the MSDS, the
chemical manufacturer or responsible party who prepared the MSDS shall mark it
to indicate that no applicable information was found. If a Facility receives an
MSDS which doesn’t contain information in the specified category AND there is no
information regarding “not applicable”, the chemical manufacturer or responsible
party should be contacted to discuss the discrepancy.
Each delivery of a hazardous chemical must be accompanied by the corresponding
MSDS. If there is no MSDS, the chemical shall not be received.
If for any reason the Facility or Site loses or cannot locate the MSDS for a certain
chemical, the chemical manufacturer or other responsible party shall be contacted
immediately to obtain an MSDS for that chemical.
The Facility or Site shall maintain copies of the required MSDS’s for each
hazardous chemical and shall ensure that they are readily accessible during each
work shift to all employees.
Electronic access, microfiche, and other alternatives to maintaining paper copies of
the MSDS’s are permitted as long as there are no barriers to immediate employee
access.
If employees must travel between workplaces during their course of work, the
MSDS’s for any hazardous chemical may be kept at the primary workplace
location. However, the employer must ensure that the information on an MSDS
can be obtained by the employee immediately in case of an emergency.
MSDS’s can be kept in any form, including operating procedures, and may be
designed to cover groups of hazardous chemicals where it may be more
appropriate to address the hazards of a process rather than individual chemicals.
However, employers shall ensure that the required information is supplied in all
cases and is readily accessible to all employees when required or requested.
7 Training
All S&W Energy Facility or Site employees (including Field personnel) shall be
trained on the requirements and guidelines of this procedure and the Site’s
HAZCOM program at the time of their initial assignment (upon initial hire). In
addition, employees shall be trained whenever a new physical or health hazard the
employees have not previously been trained about is introduced into their work
area. Refresher training is required every 2 years.
Information and training may be designed to cover categories of hazards or
specific chemicals.
The training shall include at least:
• Methods and observations that may be used to detect the presence or
release of a hazardous chemical in the work area (such as monitoring
conducted, monitoring devices, visual appearance or odor of certain
chemicals, etc.);

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Policy No:EHS-506 Hazard Communications

• The physical and health hazards of the chemicals in the work area;
• The measure employees can take to protect themselves from these
hazards, including specific procedures implemented that include
appropriate work practices, emergency procedures, and personal
protective equipment; and
• Details of the hazard communication program, including an explanation of
the labeling system and material safety data sheets and how employees
can obtain and use the appropriate hazard information.
8 Auditing / Inspections
The Hazard Communication Procedure shall be reviewed every 2 years. Documented
chemical management information or the written HAZCOM program may be reviewed
as part of this audit or inspection. This procedure will be updated as necessary.

9 References
29 CFR 1910.1200 Hazard Communications
29 CFR 1910.106 Flammable and Combustible Liquids

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 Environmental Health and Safety
Manual
Policy No. EHS-507 Policy Title: Hazardous Waste Operations and Emergency
Response (HAZWOPER)
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 Definitions ................................................................................................................ 2
3 Determining Applicability.......................................................................................... 3
4 Emergency Response Plan...................................................................................... 3
5 Procedure ................................................................................................................ 4
6 Training .................................................................................................................... 7
7 Auditing / Inspections ............................................................................................... 9
8 References............................................................................................................... 9

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Policy No:EHS-507 Hazardous Waste Operations and Emergency Response (HAZWOPER)

1 Purpose and Scope

This procedure establishes guidelines to enable compliance with HAZWOPER
regulations for those Facilities or Sites that are subject to the regulatory standard based
on their operations and inventory of chemicals and materials. The guidelines and
requirements are intended to limit the exposure of employees dealing with uncontrolled
releases of hazardous material and to protect the environment from uncontrolled
releases by the best means possible.
This program applies to all Facilities or Sites that have the potential for an uncontrolled
release of hazardous substances that may require emergency response operations to
eliminate or control the hazard. The level of response will depend on Facility or Site
preparation, equipment, and employee level of training in combination with the hazards
associated with each Facility. Community response is also factored into HAZWOPER
applicability and level of response for each Facility.
This procedure shall be used with S&W Energy’s Emergency Response Procedure and
S&W Energy’s Waste Management Procedure.
2 Definitions
• Clean-Up Operation – An operation where hazardous substances are removed,
contained, incinerated, neutralized, stabilized, cleared-up, or in any other manner
processed or handled with the goal of making the site safer for people or the
environment.
• Controlled Release – Releases that are contained by in-place facilities or
safeguards, does not go off property, can be stopped by closing valves, or
absorbed/neutralized promptly at the time of release.
• Emergency Response – A response effort by employees from outside the
immediate release area or by other designated responders (i.e., local fire
departments, mutual aid groups, designated HAZMAT teams, etc.) to an incident
that results in or potentially results in an uncontrolled release of a hazardous
substance or other incident that can be classified as an emergency.
• Hazardous Materials (HAZMAT) Response Team – An organized group of
employees, designated by the employer who are expected to perform work to
handle and control actual or potential leaks or spills of hazardous substances
requiring possible close approach to the substances; the response is for the
purpose of control or stabilization of the incident.
• Hazardous Substance – Any substance designated in any of the categories
listed below and exposure to which results or may result in adverse affects on the
health or safety of employees:
1. Any substance defined under designated sections of CERCLA
(Comprehensive Environmental Response, Compensation, and Liability
Act, commonly known as Superfund);
2. Any biological agent and other disease causing agent which after release
into the environment and upon exposure, ingestion, inhalation, or
assimilation into any person, either directly from the environment or

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Policy No:EHS-507 Hazardous Waste Operations and Emergency Response (HAZWOPER)

indirectly, will or may reasonably be anticipated to cause death, disease,

behavioral abnormalities, etc.
3. Any substance listed by the U.S. Department of Transportation (DOT) as
hazardous material (under 49 CFR 172 and appendices); or
4. Any hazardous waste as defined in 40 CFR 261.3 or 49 CFR 171.8.
• Incident Command System (ICS) – System implemented as part of the
Emergency response indicating the channels of communication and
identification of individuals responsible for certain tasks and activities. One
individual (and back-up) at each Facility is designated to lead the Incident
Command System.
• Uncontrolled Release (Uncontrolled Incident) – A release of a hazardous
substance which cannot be controlled by shutting off valves, cannot be
controlled by in-place facilities such as dikes, catch basins, sump tanks, etc., or
cannot be absorbed or neutralized promptly. An uncontrolled incident can also
be a fire that has progressed beyond the incipient stage, cannot be suppressed
by the use of fire extinguishers, requires the use of chemical protective clothing
and/or requires the use of positive pressure respirators.

The Facility or Site shall be evaluated for hazardous substances to

determine the level of Emergency Response. All employees assigned to
work activities as the normal work assignment or to provide assistance on
an emergency basis must be informed of the hazardous substances
identified or known to be present.

3 Determining Applicability
The requirements of this procedure cover emergency response operations for
releases of, or substantial threats of releases of, hazardous substances without
regard to the location of the hazard.
In addition, each Facility or Site shall be evaluated to determine if they are subject
to Hazardous Waste regulations as they are outlined by RCRA (Resource
Conservation and Recovery Act). Depending on applicability to RCRA standard
levels, there may be additional requirements other than the general HAZWOPER
requirements included in this procedure. Consult with the S&W Energy EHS
Manager for applicability status and additional requirements.
4 Emergency Response Plan
An emergency response plan shall be developed and implemented to handle
anticipated emergencies prior to commencement of emergency response
operations. The plan shall be in writing and available for inspection and duplication
by employees, their representatives, or regulatory agencies.

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Policy No:EHS-507 Hazardous Waste Operations and Emergency Response (HAZWOPER)

• All elements that must be included in an Emergency Response Plan and the
developmental steps to create such a written Plan are outlined in S&W
Energy’s Emergency Response procedure in S&W Energy’s EHS Manual.
Reference this procedure for a template Plan and other requirements.
Prior to initiating emergency response activities, the Facility or Site shall be
surveyed to determine the presence of hazardous conditions, such as explosive
gases, toxic gases, oxygen deficiency, or other life threatening conditions.
Following the identification of hazards and a determination of the proper personal
protective equipment (PPE) is available and sufficient to safeguard personnel, a
continuing monitoring program should be implemented and continue for the
duration of the emergency response activities.
A site control program should be developed during the planning stages of any
emergency response activity and modified as necessary as information becomes
available.
• The Site Control Program should include a site map, the designated work
zones, site communication procedures, safe work practices and the
identification of the nearest medical services. This information may be
included in the Facility’s Emergency Response Plan.
A detailed description of the response activities that may be required in the event of
a release as applicable to a given Facility or Site and/or hazardous substance
should also be developed, including notification/alerting procedures and
emergency response contact telephone numbers.
5 Procedure
A. Handling Emergency Response - ICS
Each Facility or Site shall develop a site-specific Incident Command System
(ICS) and shall designate an individual in charge of the ICS. All emergency
response activities and their communications shall be directed, coordinated
and controlled through the designated individual.
The designated individual in charge of the ICS shall identify, to the extent
possible, all hazardous substances or conditions and identify appropriate
analysis, exposure limitations, engineering controls, handling procedures and
use of new technologies.
The designated individual in charge of ICS shall implement appropriate
emergency operations and assure personal protective equipment available
and worn is appropriate for the hazards to be encountered.
The individual in charge of the ICS shall limit the number of emergency
response personnel at the emergency site, in those areas of potential or actual
exposure, to those who are actively performing necessary emergency
operations.

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Policy No:EHS-507 Hazardous Waste Operations and Emergency Response (HAZWOPER)

The individual in charge of the ICS shall designate a safety official, who is
knowledgeable in the operations being implemented at the emergency
response site, with specific responsibility to identify and evaluate hazards and
to provide direction with respect to the safety operations for the emergency at
hand.
When activities are determined to be dangerous to life and health or to involve
an imminent danger condition, the safety official shall have the authority to
terminate activities and immediately inform the individual in charge of the ICS
of the situation.
After emergency operations have terminated, the individual in charge of ICS
shall implement appropriate decontamination procedures.
B. Personal Protective Equipment Selection
Chemical protective clothing and equipment to be used by organized and
designated HAZMAT team members shall meet the following requirements:
Personal Protective Equipment (PPE) shall be selected and used which will
protect employees from the hazards and potential hazards they are likely to
encounter as identified during a site characterization or a job safety analysis.
• PPE shall be selected based on an evaluation of the performance
criteria of the PPE relative to the requirements and limitations of the
site, the task-specific conditions and duration, and the nature of the
hazards or potential hazards involved.
• The level of protection provided by PPE selection shall be
increased when additional information on site conditions indicates
that increased protection is necessary.
• A written personal protective equipment plan shall be established.
S&W Energy’s PPE / JSA procedure in the EHS Manual satisfies
this requirement.
Respiratory protection shall be provided according to S&W Energy’s
Respiratory Protection Procedure and policy. Specific hazards or potential
hazards will require varying levels of respiratory protection. This shall be
determined during site hazard characterization or analysis.
• Positive pressure self-contained breathing apparatus, or positive
pressure air-line respirators equipped with air escape air supply,
shall be available and used when chemical exposure levels present
may create a substantial possibility of immediate death, serious
illness or injury, or impair the ability to escape.

Totally-encapsulating chemical protective suits (Level A protection) shall be

used in conditions where skin absorption of a hazardous substance may result
in a substantial possibility of death, serious illness or injury, or impair the ability
to escape.

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Policy No:EHS-507 Hazardous Waste Operations and Emergency Response (HAZWOPER)

•
Totally-encapsulating suits shall be capable of maintaining positive
air pressure and shall be capable of preventing inward gas leakage
of more than 0.5%. Consult with vendor or manufacturer
recommendations and test methods for verification of these
requirements.
C. Medical Surveillance
A medical surveillance program shall be initiated for all employees that:
• Have been exposed to hazardous substances at or above
permissible limits, regardless of respirator use, for 30 days or more
per year; or
• Wear a respirator for 30 days or more per year; or
• Are injured or acquired illnesses through over exposure to
hazardous substances; or
• Are members of HAZMAT teams.
Medical examinations under the established medical surveillance program
shall be given according to the following frequency guidelines:
1. For employees who have been exposed to hazardous substances
at or above permissible limits, regardless of respirator use, for 30
days or more per year, employees who wear a respirator for 30
days or more per year, or for members of HAZMAT teams, medical
examinations shall be given:
• Prior to assignment;
• At least once every twelve months for each employee covered
unless the physician believes more frequent examinations are
necessary;
• At termination of employment or reassignment to a new area;
and
• As soon as possible after an employee believes or there is
notification that the employee has developed signs or symptoms
indicating possible overexposure to a hazardous substance.
2. For employees injured or who have acquired illnesses through over
exposure to hazardous substances, medical examinations shall be
given:
• As soon as possible following the emergency incident or
indication of symptoms.
Follow S&W Energy’s Medical Records Access / Recordkeeping procedure for
detailed information on content of medical examinations and who shall
conduct or perform the evaluations.
D. Decontamination
Decontamination procedures shall be developed and tailored to each site,
appropriate to the hazardous substances present.

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Policy No:EHS-507 Hazardous Waste Operations and Emergency Response (HAZWOPER)

6 Training
Training shall be based on the duties and functions to be performed by each responder
of an emergency response organization. All employees must be trained prior to hire or
prior to taking part in any of the tasks or responsibilities of emergency response they
are assigned.
A. There are several levels of emergency response training. Each Facility or Site
must determine the employees to be trained and the level they are to be trained
based on the Site’s capability to respond and the surrounding area’s emergency
response assistance. The training shall be given in accordance with the
following:
First Responder Awareness Level – Individuals who are likely to witness or
discover a hazardous substance release and have been instructed to initiate
emergency response activities by notifying the appropriate individuals. These
employees must not take any further action other than notifying the proper
authorities. This level of training shall include the following:

• An understanding of what hazardous substances are, especially

those specific to the site, and the risks associated with each;
• An understanding of the potential outcomes associated with an
emergency created when hazardous substances are present;
• The ability to recognize the presence of hazardous substances
in an emergency;
• The ability to identify the hazardous substance, if possible;
• An understanding of the role of the first responder awareness
individual in the scheme of the Site’s emergency response
system; and
• The need to recognize the need for additional resources and to
make appropriate notifications to the community.

First Responder Operations Level – Individuals who respond to releases or

potential releases of hazardous substances as part of the initial response to
the site for the purpose of protecting nearby persons, property, or the
environment from the effects of the release. They are instructed to respond in
a defensive fashion without actually trying to stop the release. Their function
is to contain the release, keep it from spreading, and prevent exposure. First
Responders at the Operations Level require at least 8 hours of training and
include the following training:
• Knowledge of the basic hazard and risk assessment techniques;
• Know how to select and use proper personal protective
equipment provided;
• An understanding of basic hazardous materials terms;

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Policy No:EHS-507 Hazardous Waste Operations and Emergency Response (HAZWOPER)

• Know how to perform basic control, containment and/or

confinement operations within the capabilities of the resources
and personal protective equipment available.
• Know how to implement basic decontamination procedures; and
• An understanding of the relevant standard operating procedures
and termination procedures.

Hazardous Materials Technician Level – Individuals who respond to

releases or potential releases for the purpose of stopping the release. They
assume a more aggressive role than First Responder level in that approach
the release in order to plug, patch or otherwise stop the release of a
hazardous substance. Hazardous Materials Technician shall have received at
least 24 hours of training equal to First Responder Level but meet the
following additional topics:
• Know how to implement the employer’s emergency response
plan;
• Know the classification, identification, and verification of known
and unknown materials by using field survey instruments and
equipment;
• Be able to function in an assigned role in the Incident Command
System (ICS);
• Know how to select and use proper specialized chemical PPE
provided to the hazardous materials technician;
• Understand hazard and risk assessment techniques;
• Be able to perform advance control, containment, and/or
confinement operations within the capabilities of the resources
and PPE available;
• Understand and implement decontamination procedures;
• Understand termination procedures; and
• Understand basic chemical and toxicological terminology and
behavior.

On-Scene Incident Commander – Incident Commanders who will assume

control of the Incident scene beyond the first responder awareness level, shall
receive at least 24 hours of training equal to the first responder operations
level and in addition have competency in the following areas and shall so
certify:
• Know and be able to implement the employer’s incident
command system;
• Know how to implement the employer’s emergency response
plan;
• Know and understand the hazards and risks associated with
employees working in chemical protective clothing;

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Policy No:EHS-507 Hazardous Waste Operations and Emergency Response (HAZWOPER)

• Know how to implement the local emergency response plan;

• Know of the state emergency response plan and of the Federal
Regional Response Team; and
• Know and understand the importance of decontamination
procedures

Each Facility or Site shall be evaluated to determine the level of training

required. Trainers who teach any of the above levels shall have training
credentials and instructional experience to demonstrate competent
instructional skills and a good command of the subject.

B. All S&W Energy Facility or Site employees (including Field personnel) shall be
trained on the requirements and guidelines of this procedure and at the First
Responder Awareness Level. Other levels of training should be given, as
necessary. Refresher training is required annually, no matter what level is
required.
C. All employees assigned to an Emergency Response Team working at a site
exposed to a hazardous substance, their supervisors and management of the
site shall receive training before they are permitted to work.
7 Auditing / Inspections
The HAZWOPER Procedure shall be reviewed every 2 years. This procedure will
be updated as necessary.
8 References
29 CFR 1910.120 Hazardous Waste Operations and Emergency Response

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 Environmental Health and Safety
Manual
Policy No. EHS-508 Policy Title: Emergency Response
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 Definitions ................................................................................................................ 2
3 Emergency Action Plans & Emergency Response Plans – General Requirements. 2
4 General Guidance for Emergencies ......................................................................... 4
5 Evacuation Routes and Assembly Areas ................................................................. 9
6 Plot Plans ................................................................................................................. 9
7 Alarms, Whistles, Signals, Alerts.............................................................................. 9
8 General Procedures ............................................................................................... 10
9 Training .................................................................................................................. 11
10 Auditing / Inspections ......................................................................................... 11
11 References ......................................................................................................... 11

Page 1
Policy No:EHS-508 Emergency Response

1 Purpose and Scope

The purpose of this procedure is to provide policy and guidance for creating Emergency
Action Plans and Emergency Response Plans for a Facility or Site. The types of
incidents and scenarios covered under these Plans include, but are not limited to, fire,
explosions, bomb threats, medical emergencies, high winds, sever lightning or
hurricanes, heavy rainfall and floods, earthquakes, heavy snowfall or ice, and/or any
hazardous material spill or leak.
Emergency Response requirements cover all types of S&W Energy Facility or Site
classifications including Office Building (Headquarters or Regional Office), Power Plant
Facility, and/or Field Locations. Each Plan will include all minimum requirements as this
procedure indicates but each must be tailored specifically to each type of Facility
classification.
2 Definitions
• Emergency Action Plan – A plan for a workplace, or parts thereof, describing
what procedures the employer and employees must take to ensure employee
safety from fire or other emergencies.
• Emergency Response Plan – A plan developed and implemented to handle
anticipated emergencies prior to the commencement of emergency response
operations. It is also intended to minimize hazards to employees, the public or
the environment from fires, explosions, or any unplanned sudden or non-
sudden release of hazardous materials, hazardous waste or hazardous
constituents to air, soil, surface water or ground water. The plan is designed to
set procedures for reporting all releases or threatened releases of hazardous
materials.
• Field Location – Short-term job-sites with work currently in progress.
• LEPC – Local Emergency Planning Committee / Commission.
• Office Building – Stand-alone facilities which are primarily dedicated to
administration, sales, technical and management support.
• Power Plant Facility – Fixed industrial locations operated and maintained on
an ongoing basis by S&W Energy (O&M Facilities)
3 Emergency Action Plans & Emergency Response Plans –
General Requirements
A. Emergency Action Plan
Each Facility or Site shall develop an Emergency Action Plan in writing to
inform employees of the actions to be taken in case of an emergency. The
Facility or Site shall establish the types of evacuation to be used in emergency
circumstances.
The following elements, at a minimum, shall be included in the Emergency
Action Plan:

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Policy No:EHS-508 Emergency Response

•
Emergency escape procedures and emergency escape route
assignments;
• Procedures to be followed by employees who remain to operate
critical plant operations before they evacuate;
• Procedures to account for all employees and visitors after
emergency evacuation has been completed;
• Rescue and medical duties for those employees who are to perform
them;
• The preferred means of reporting fires and other emergencies; and
• Names or regular job titles of persons or departments who can be
contacted for further information or explanation of duties under the
plan.
B. Emergency Response Plan
Each Facility or Site shall develop an Emergency Response Plan in writing to
handle anticipated emergencies involving hazardous materials or substances.
The following elements, at a minimum, shall be included in the Emergency
Response Plan, to the extent they are not addressed elsewhere:
• Pre-emergency planning and coordination with outside parties;
• Personnel roles, lines of authority, and communication;
• Emergency recognition and prevention;
• Safe distances and places of refuge;
• Site security and control;
• Evacuation routes and procedures;
• Decontamination procedures;
• Emergency medical treatment and first aid;
• Emergency alerting and response procedures;
• Critique of response and follow-up;
• PPE and emergency equipment;
• Site topography, layout, and prevailing weather conditions;
• Procedures for reporting incidents to local, state, and federal
governmental agencies;
The Emergency Response Plan shall be rehearsed regularly as part of the
overall training program for site operations.

Emergency Action Plans and Emergency Response Plans are very similar with
many of the same requirements. They may be combined into one
comprehensive Plan as long as the minimum requirements, as outlined in this
Section for both Plans, are satisfied.

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Policy No:EHS-508 Emergency Response

The Emergency Action Plans and Emergency Response Plans shall be

reviewed periodically and, as necessary, be amended to keep it current with
new or changing conditions or information.

An employee alarm system shall be installed in accordance with regulatory

standards to notify employees of an emergency situation; to stop work
activities if necessary; to lower background noise in order to speed
communication; and to begin emergency procedures. Elements of the alarm
system include:
• Loud or distinct enough to be perceived above ambient noise or
light levels by all employees in the affected areas;
• A clearly recognizable signal to evacuate the work area, if
necessary, or to perform actions under Emergency Response; and
• Preferred means of reporting emergencies and communication
(manual pull box alarms, radio, public address system, telephones,
etc.).
Each alarm device or component shall be constructed and installed to
comply with local standards and approved.
Employer must ensure that each alarm system is restored to normal
operating condition following any use or test.
Employer shall ensure that all alarm systems are maintained in
operating condition except when undergoing repair or maintenance. In
such a case, alternative alarm systems must be used; Back-up power
supplies shall be maintained.
4 General Guidance for Emergencies
Emergency procedures are necessarily general, as much depends on the severity
of the emergency, often aggravated by circumstances such as heavy seas, bad
communications, disrupted logistics, and rescue difficulties.
Concern in order of importance is:
1. The safety of the personnel working in the emergency area
2. Protection of equipment
3. Minimum loss in production
An Emergency Action Plan and Emergency Response Plan, if separate, are to be
maintained at each work site at all times while work is in progress.
All assigned personnel are to be thoroughly briefed on its content and availability.
It is the responsibility of each Manager and Supervisor to ensure this briefing is
conducted and documented.
The personal safety and property of residents around the emergency area must be
preserved as much as possible.

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Policy No:EHS-508 Emergency Response

The extent of the emergency area should be defined and restricted.

All necessary equipment and specialists should be brought in for assistance, as
required.
Damage to property should be rectified as soon as the situation allows the
equipment and personnel to enter the area.
Legal aspects such as claims should be promptly reported to senior management
for handling.
Consider the facility and determine the effect each type of emergency can have on
the normal operations and on the standard emergency procedures established.
Changes and revisions to such operations or procedures may result.
Review all normal operations carefully, to ensure that no critical operation is started
which can not be completed before it may become necessary to commence
evacuation procedures.
Make certain that the appropriate pre-planned evacuation procedure is suited to
each circumstance.
Ensure that in the event of an emergency alert the following instructions are
adhered to:
• Retain transportation assets in ready status for as long as possible.
• Any construction or non-essential operations are to be stopped and work
begun to secure all facilities.
• Personnel are not to be assigned duties which will necessitate their being at
remote parts of field or isolated parts of an installation for a prolonged period
unless they have radio communications readily available.
• A weather forecasting service is to be monitored to provide timely warning of
impending bad weather.
In the event it becomes necessary to respond to any one of the following types of
emergencies, the Plan should provide instructions and information applicable to the
specific emergency conditions.
A. Fire or Explosion
All personnel will immediately prepare to evacuate upon hearing a fire alarm
signal. Time and situation permitting, all equipment and materials currently in
use should be properly disconnected, shut off, or otherwise secured to
preclude additional hazardous conditions. Do Not go to the scene of the fire
unless specifically told to do so.
In the event of a fire, Company personnel should immediately:
• Trip the nearest fire alarm (if provided) or report the fire by telephone to the
Local Fire Department and/or the Client Fire/Security Office. The appropriate
emergency telephone numbers are to be prominently posted at each work
location.

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Policy No:EHS-508 Emergency Response

• If assigned personnel are trained in the use of fire extinguishers AND, using
prudent judgment, the fire can be extinguished quickly, minimizing the hazard
by quick action, Company personnel should respond accordingly.
DO NOT FIGHT A FIRE ALONE! If the fire gets large or out of control, then
evacuate. Once the fire brigade or fire department has arrived on the scene,
Company personnel should clear the area of the fire scene and go to the
designated assembly point via the evacuation route immediately.
Do not discuss the incident or your actions with anyone not connected with the
Company, the Fire Department, Client Operations or Security. All
communication of information to other parties will be by the Company
Management or the client representative as appropriate.
All personnel are to remain at the designated assembly area until the All Clear
Signal is sounded or specific instructions are provided for other action.
B. Bomb Threats
In those circumstances in which determined individuals plan to inflict damage
or disrupt operations, regardless of motive, it is extremely difficult to prevent
them. Security plans should be drawn up to act as a deterrent, introducing
obstacles and making access more difficult. These plans should be drawn up
in consideration of the available civil authorities and treated as confidential.
Personnel should not place themselves in jeopardy to apprehend intruders but
should concentrate their efforts on containing the effects of an incident.
In the event a phone call warns of a bomb threat the following may prove
helpful:
• The individual receiving a telephone call in which the caller states a bomb has
been planted and is set to detonate should remain calm and quietly summon
assistance while keeping the caller on the phone.
• Interrupt the caller as often as possible by asking questions and asking the
caller to repeat. This may prevent the caller from completing the message
and hanging up. Be polite and act very concerned.
• Inform the caller that the detonation of the bomb could result in death or
serious injury to innocent people.
Using the following as a guide, attempt to record details of the call:
• Date and time call received
• Exact words of caller.
• Questions to ask:
1. When is bomb going to explode?
2. Where is bomb right now?
3. What kind of bomb is it?
4. What does it look like?
5. Why did you place the bomb?

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Policy No:EHS-508 Emergency Response

•Description of caller's voice: Male / Female, Young / Middle Age / Old,

Accent, Tone of Voice
• Background Noise
• Is voice familiar? If so, who did it sound like?
C. Medical Emergencies
Facilities selected to provide these Emergency Medical services are to be
posted for ready reference at each facility or job location. Managers should
direct activities to identify selected facilities in near proximity to each work
location and should arrange for posting of the necessary Emergency
Information. Managers of departments that work at various job sites should
ensure the nearest medical facility is identified during the initial site job walk
and include the information for posting in a Job Safety Packet prepared for
short term work locations.
All on-the-job injuries/illnesses other than minor first aid cases, i.e. cleansing
of abrasions and scratches and application of band aids must be transported
as soon as possible for medical care and/or treatment.
Transport non-emergency injuries/illnesses to the doctor's office (if identified)
on an Emergency Information Posting.

NOTE: Call prior to transport to ensure doctor's availability and for

alternate instructions in the event a hospital is recommended for
treatment.
NOTE: An Ambulance service is to be utilized only when required due
to nature of the injury/illness which rules out the use of other
transportation.
All on-the-job injuries/illnesses must be reported and investigated in
accordance with the instructions provided in the Accident Investigation and
Reporting section of this Manual.
D. High Winds, Severe Lightning or Hurricanes
A comprehensive set of step by step instructions should be prepared in
advance and all personnel should familiarize themselves with their instruc-
tions.
At any time when a storm is forecast steps should be taken immediately to
safeguard personnel and facilities in the more exposed areas.
E. Heavy Rainfall or Floods
An analysis of road and field conditions should be made of the surrounding
area in the event of flooding.
Check whether emergency procedures can be carried out in the event of
flooded roads, bridges, etc.

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Policy No:EHS-508 Emergency Response

Tanks, pipelines and other equipment should be firmly secured against

floating. Tanks should be kept full if practical.
If time permits, wells in the more exposed areas should be closed in either by
safety valves in the well or with the master valve at the surface.
For evacuation purposes helicopters equipped with floatation gear and winch
may be required in flooded areas.
F. Earthquakes
Earthquakes are unpredictable with today's technology and as a result it is
extremely difficult to implement protective or preventative measures other than
making those architectural modifications that minimize structural damages in
critical areas. The following actions are recommended to be taken during and
immediately after an earthquake:
• Shut-off sources of release of process fluids.
•
• Investigate what gases can be expected in the exposed areas.
•
• Check for toxic vapor or liquids.
•
• Check possibility of damaged equipment collapse.
•
• Restrict personnel access to area.
•
• Keep fire-extinguishing equipment ready for use.
•
• Any further actions needed to put the installations in a safe condition.
•
• Consider effect of possible subsequent tidal wave.
G. Heavy Snowfall or Ice
In areas where the possibility of excessive snowfall or icing exists, pre-planned
instructions and necessary equipment should be available for safeguarding
personnel and facilities.
Vital equipment should be protected against collision damage due to poor
visibility, snowing-in or icing by using signs, crash barriers or other aids.
H. Hazardous Material Leak or Spill
Accidental spills of hazardous materials must be reported at once to the
Manager/Job Supervisor and (if applicable) designated client representative,
per Reporting Procedures. If safe to do so, get information on the spilled
material, control entry to the spill site and watch over the area until help
arrives.

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Policy No:EHS-508 Emergency Response

Do not attempt to clean-up spills without direction and/or training. If trained at

the First Responder Operations Level, dike around liquid spills to prevent
drainage into water supply and contact with other materials.

Check the Material Safety Data Sheets (MSDS) for personal protection
equipment requirements and for disposal instructions and precautions.
See the Hazardous Waste Operations and Emergency Response Program
(HAZWOPER) for additional guidance for events of this nature.
5 Evacuation Routes and Assembly Areas
Floor plans of each Office Facility with clear routes of egress established and
prominently marked shall be developed. Once the floor plans have been prepared,
the floor plan for each floor showing the evacuation route will be prominently
posted for ready reference by building occupants.
Specifically designated assembly areas will be established for each facility and
such areas will be noted on the posted floor plan which contains the marked
evacuation routes.
Evacuation routes for Power Plant Facilities will be established by the Facility
Manager and will be posted prominently for quick reference by assigned
employees.
Evacuation routes for Field Locations will be as specified by client or property
owner.
NOTE: It is the job supervisor's responsibility to obtain this information from
the client representative immediately upon arrival at the job site and instruct
his assigned crew accordingly.
6 Plot Plans
Plans should be developed for each owned, leased or operated property which
show the orientation of the structure on the property, the location of hazardous
material storage, points of entry and egress, and the location of fire hydrants and
fire extinguishers.
The Plot Plans will be kept readily available, removed from the facility in the event
of fire or explosion and provided to local Emergency Response Units.
Responsibility for the development, custody and control of Plot Plans will be
assigned to the Manager at Office Facilities and the Facility Manager at Power
Plant Facilities.
7 Alarms, Whistles, Signals, Alerts
Each facility will establish and maintain a method of communicating the occurrence
of an emergency which requires action by (or the evacuation of) assigned
personnel.

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Policy No:EHS-508 Emergency Response

The alarm system must be tested monthly to ensure proper operation and a written
record of the test is to be maintained on site.
These communications may be any audible signal or alarm that is sufficient to
provide adequate warning to all locations within each facility. In some cases,
communication by voice may be sufficient, depending on the size of the facility and
its ambient noise level.
The job supervisor immediately upon arrival at the site must determine alarms
established by clients for the Field Locations and all assigned personnel must then
be instructed in the characteristics of and the correct response to all emergency
alarm signals.
The following information (if applicable) shall be obtained and posted at each Field
Location work site:

• Fire Alarm (describe)

• Evacuation Alarm Signal (describe)
• All Clear Signal (describe)
• Alarm Boxes (note locations)
• Fire Extinguishers (note locations)
• Windsock (note location)
• Evacuation Route
• Assembly Area

NOTE: It is the responsibility of each Job Supervisor to ensure the

above information is obtained, recorded herein, posted
prominently, and that each member of the assigned crew is
familiarized with this information during a pre-job safety
orientation meeting and walk through.
8 General Procedures
Immediately upon the sounding of an emergency alarm, all unnecessary work will
cease and, time permitting; all unnecessary equipment will be shutdown or secured
to prevent additional hazard sources.
NOTE: Personnel assigned specific emergency shutdown duties will
perform their assigned tasks.
All personnel not assigned specific duties requiring their presence during the
emergency will immediately proceed to evacuate the facility, utilizing routes
specified and posted for their work site.
All personnel will proceed directly to designated assembly points as soon as they
have cleared the danger area.
Managers and Supervisors shall gather all assigned personnel to obtain a head
count to ensure all personnel present at the work site prior to the emergency are
accounted for.

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Policy No:EHS-508 Emergency Response

Supervisors shall provide a report of missing personnel to the senior company (or
client) representative present at the assembly area, or to the Emergency Response
Unit Officials present at the site.
All personnel will remain in the assembly area until permission is specifically given
to leave the assembly area or the emergency is declared secure by
announcements made by the Emergency Response Officials, through the sounding
of an "All Clear" signal, or through the senior company (or client) representative
present.
9 Training
All personnel must be trained on the alarm system established at his/her place of
assignment.
Annual Fire/Evacuation Drills will be conducted to ensure assigned personnel are
familiar with Alarm Signals, Emergency Procedures, Evacuation Routes, and
Assembly Areas.
All assigned personnel will also receive training on the Fire Prevention Plan.
New employees will be provided instruction on the Alarm Signals, Emergency
Procedures, Evacuation Routes, and Assembly Areas during the first day of work
at a facility.
The Office Manager or Facility Manager / Supervisor, or designee, shall review the
plan with each employee covered by the plan at the following times:
• Initially when the plan is developed,
• Whenever the employee's responsibilities or designated actions under the
plan change, and
• Whenever the plan is changed.
All S&W Energy employees shall be trained on the requirements and guidelines of
this procedure and on their Emergency Response / Action Plan specifically.
Training is required annually.
10 Auditing / Inspections
The Emergency Response Procedure shall be reviewed every two years. The
procedure will be updated as necessary.
The Emergency Action and Emergency Response Plans developed as a result of
this procedure shall be reviewed every two years. The Plans will be updated as
necessary and retraining conducted accordingly.
11 References
29 CFR 1910.38 Emergency Action & Fire Prevention Plans
29 CFR 1910.120 Hazardous Waste Operations and Emergency Response
29 CFR 1910.165 Employee Alarm Systems

Page 11
 Environmental Health and Safety
Manual
Policy No. EHS-509 Policy Title: Fall Protection
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 Definitions ................................................................................................................ 2
3 Assessment and Control Options............................................................................. 4
4 Fall Protection System Categories ........................................................................... 5
5 Selection of Proper Fall Protection........................................................................... 5
6 Inspection, Maintenance, and Care.......................................................................... 9
7 Training .................................................................................................................. 10
8 Auditing / Inspections ............................................................................................. 10
9 References............................................................................................................. 10
10 Forms ................................................................................................................. 10

Page 1
Policy No:EHS-509 Fall Protection

1 Purpose and Scope

This procedure provides the requirements and guidelines in regards to fall protection.
The procedure provides requirements that ensure all S&W Energy Facilities or Sites
identify and evaluate fall hazards around the workplace, to ensure there is proper
selection and use of fall hazard controls, to ensure fall protection equipment is used,
inspected and maintained, and to ensure all employees are given the appropriate level
of training to perform work that involves fall protection. This procedure shall be used in
combination with S&W Energy’s Personal Protective Equipment / Job Safety Analysis,
Ladders and Scaffolding, and Walking and Working Surfaces procedures.
2 Definitions
• Anchor Point (“Tie-Off” Point) – Secure point of attachment for the connection
device and fall protection system. Anchor points are typically beams or other
similar sturdy support structures located above or at an even level with the user.
• Body Belt – A strap with means both for securing it about the waist and
attaching it to a lanyard, lifeline or deceleration device.
• Body Harness – Straps that secure about the person in a manner that
distributes the fall-arrest forces over at least the thighs, pelvis, waist, chest and
shoulders with a means for attaching the harness to other components of a
personal fall arrest system.
• Body Wear – Part of fall protection systems, the support equipment worn by the
user performing the fall hazard work.
• Connecting Device (Connector) – Device used to connect the parts of a
personal fall arrest system or positioning device system together.
• Deceleration Device – Any mechanism, such as a rope grab, shock-absorbing
lanyard or self-retracting lifeline, which serves to dissipate a substantial amount
of energy during the fall arrest, or otherwise limits the energy imposed on the
employee during fall arrest.
• Deceleration Distance – The additional vertical distance a falling person travels,
excluding lifeline elongation and free fall distance, before stopping. From the
point at which a deceleration device begins to operate.
• Fall Arrest System – A system including, but not limited to an anchor point,
connection device, and a body belt or harness used to arrest an employee in a
fall from a working level.
• Fall Hazard – Any situation in which a fall from an elevated height could result in
an injury. A fall hazard is present when:

• Work is conducted at unprotected heights at or exceeding four (4) feet

above the lower level, such as unprotected sides or edges of a walking
or working platform, floor or wall openings, ramps and other similar
locations; or
• Work is conducted above dangerous equipment or processes at
unprotected work heights below four (4) feet.

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Policy No:EHS-509 Fall Protection

• Horizontal Lifeline – A connection device used in conjunction with an attached

fall arrest device between the body wear and the anchor point. Typically
flexible lifeline is suspended horizontally (keeping taut) between two fixed
anchor points at a level even or above the user.
• Lanyard – A flexible line of rope, wire rope, or strap that generally has a
connector at each end for connecting the body belt or body harness to a
deceleration device, lifeline or anchor point.
• Positioning Device System – A body belt or body harness system rigged to
allow an employee to be supported on an elevated vertical surface, such as a
wall, and work with both hands free while leaning backwards.
• Retractable Lifeline – A self-contained device linking the body wear to the
anchor point. The device acts as a continuously taut lanyard, allowing the user
to travel varying distances and directions while still attached to a fall protection
device.
• Rope Grab – A deceleration device that travels on a lifeline and automatically,
by friction, engages the lifeline and locks to arrest a fall.
• Safety Lanyard – The connection device linking the body wear to the anchor
point or as a connection device to a lifeline system. Typically safety lanyards
are short lines made up of rope strap, webbing, cable, or similar materials with
connectors on both ends.
• Snap-Hook – A connector consisting of a hook-shaped member with a normally
closed keeper, or similar arrangement, which may be opened to permit the hook
to receive an object and when released automatically closes to retain the
object.
• Unprotected – For the purposes of this procedure, without standard guardrails
or similar protection.
• Vertical Lifeline (Rope Grab) – A connection device used in conjunction with
an attached fall arrest device, such as a rope grab, between the body wear and
the anchor point. Typically, the flexible lifeline is suspended vertically from an
anchor point overhead.

Fall hazards are present at any height. However, according to regulatory

standards, fall hazards are present, as defined at 4 feet in general industry and 6
feet in construction. Because S&W Energy operates most of its Facilities as part
of general industry, the minimum distance where fall protection is required is 4
feet and meets the criteria in the definition of a fall hazard.

EACH SITUATION SHALL BE EVALUATED SEPARATELY TO DETERMINE

PRESENCE OF A FALL HAZARD AND TO DETERMINE WHETHER OR NOT FALL
PROTECTION SHALL BE REQUIRED.

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Policy No:EHS-509 Fall Protection

3 Assessment and Control Options

A. Fall Hazard Assessment
A fall hazard assessment shall be conducted to identify the location and relative fall
hazard associated for an activity. Management and employees shall work together
to identify fall hazards within the work place. Fall hazards can include, but are not
limited to the following:
• Work at unprotected heights exceeding 4 feet or above dangerous equipment or
processes;
• Wall and/or floor openings;
• Employee elevating equipment;
• Railcars; and
• Ladders
Tasks identified as fall hazards shall be documented by the Facility or Site on the
Fall Hazard Assessment / Inventory form, provided in the Attachment section of
this procedure.
All locations requiring the use of fall protection will be labeled as such. An example
sign or label reads as the following: “NOTICE – Fall Protection Controls
Required”.
B. Fall Hazard Control
Fall hazards identified shall be in controlled in one of two ways: eliminating the
hazard or, if that is not possible or feasible, then utilize fall protection controls.
When choosing fall hazard control options, elimination versus implementation and
use of fall protection equipment, the following factors should be considered;
• Probability of a fall, based on the conditions of the work location and the type of
work to be conducted;
• Potential injury resulting from a fall;
• Frequency employees are exposed to a fall hazard;
• Number of employees exposed to the fall hazard;
• Feasibility and practicality of controlling the hazard; or
• Cost associated with controlling the hazard.
If elimination is chosen, some methods to consider are providing guardrails for
work platforms, providing guardrails or covers for floor or wall openings, or
relocating equipment or controls to eliminate the need to access locations with
fall hazards.
If fall protection is chosen, ensure that all fall protection system consists of
these three components: body wear, connecting device, and anchor point.
When fall protection controls are selected, they shall be selected to provide proper
protection for the employee, they shall be selected according to manufacturer’s
recommendations, and they shall be selected by someone who is qualified and
knowledgeable on fall protection equipment and use.

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Policy No:EHS-509 Fall Protection

The Fall Protection Evaluation form should be completed for the fall hazard
identified with the fall protection method (control of hazard). A sample form is
provided in the Attachment section of this procedure. A photo is sometimes a good
tool to use and provide with this evaluation. Please attach any photos to the
evaluation form.
4 Fall Protection System Categories
When fall protection is selected as the means to control the fall hazard, there are four
(4) different categories of fall protection systems available to use, depending on the
application. The 4 systems are Fall Arrest, Positioning and Restraint, Suspension, and
Retrieval.
Choose the fall protection system that provides the best protection against a fall and/or
an injury due to a fall hazard for the task or job specified. The Attachment section of
this procedure provides detailed information on these four systems as a reference.
5 Selection of Proper Fall Protection
A functioning fall protection system must be designed not only to provide protection to
the user but also to allow them the ability to perform the job task required without, or
with minimal, limitations.
A trained and qualified person must select fall protection. Good resources can either be
a professional engineer (someone who can certify the proper design and rating) or the
manufacturer’s representative. The trained and qualified individual must be able to
provide information on the specific limitations, use, inspection and maintenance or each
component and the system.
It is important to ensure the proper fall protection is selected for each individual
situation, which involves evaluating many different factors. Some factors to consider
when selecting the fall protection system for the job are as follows:

• Severity and magnitude of the fall hazard;

• Number and frequency of employees exposed to the fall hazard;
• Permanent or temporary fall hazard;
• Need for user mobility (vertical vs. horizontal) to perform the task;
• Location of fixed anchor points or availability of temporary anchor points;
• Safe falling distances available above the lower level or equipment accounting
for free fall and deceleration distance;
• Potential for user to swing into other hazards in the event of a fall;
• Manufacturer’s use limitations for the fall protection equipment and components;
• Work being performed increasing the potential for a fall (i.e., on a narrow ledge,
unstable work platform, etc.);
• Environmental conditions increasing the potential for a fall (i.e., rain, snow, high
wind, slippery surfaces, etc.); and
• Rescue required in the event of a fall.

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Policy No:EHS-509 Fall Protection

The various fall protection systems have selected limitations and are suited for defined
use applications. Use the table below as a guideline when selecting the proper fall
protection system:

Fall
Protection Recommended: Typical Applications:
System
Fall Arrest • Any potential for falls from an • Working on elevated platforms or
elevated height work surfaces
• Working on top of rail cars
• Climbing on fixed ladders
• In conjunction with positioning,
restraint and suspension systems
Positioning • Work in a fixed position with • Cleaning windows from a window
accessible anchor points ledge
• Minimal potential for free fall • Working on rebar structure
(less than 2 feet)
Restraint • No exposure to the fall hazard • Work performed on a roof or
(within 6 feet) ledge structures
Suspension • No potential for free fall • Window washers and painters
• Access only from above • Suspension into a tank or other
structure
Retrieval • User removal from above the • Confined space entry
working area

The following guidelines, precautions, and facts about the three (3) fall protection
components should be reviewed prior to selecting and/or using fall protection
equipment:

• Body wear typically consists of a full body harness but it can also be a safety belt
or chest harness where conditions warrant. It is most commonly made of nylon,
polyester or similar webbing material. The recommended body wear is the full
body harness.

The full body harness suspends the victim (who has fallen) in an upright
position while waiting for assistance. For these reasons, it is
recommended to use safety belts ONLY in conditions with little or no
potential for free falls. The physical shocks to the midsection or
suspension from a body belt are not desirable in the event of a fall and
can cause serious injury.

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 Policy No:EHS-509 Fall Protection

• The following table describes the recommended applications for two types of
body wear:

Fall Recommended: Not Recommended:

Protection:
Full Body • Any potential for free fall • Use outside manufacturer’s
Harness • Use within manufacturer’s limitations
limitations

Fall Recommended: Not Recommended:

Protection:
Safety Belt • No potential for free fall • Any potential for free fall
• Positioning or restraining • Use outside manufacturer’s
protection only limitations
• Use within manufacturer’s
limitations

• All connection devices must have a minimum strength of 5,000 pounds per user.
• Most lanyards have shock-absorbing features to provide additional force
reduction (up to 80%) in the event of a fall.
• Shock-absorbing lanyards may not be applicable in all situations, particularly
where fall distances are minimized.
• Safety lanyards should not be attached to a retractable lifeline since they may
add additional free fall distance to the overall system.
• Retractable lifelines give the user the ability to move in various directions within
safe working distances of the lifeline.
• Vertical lifelines give the user the ability to move limited horizontal distances and
different vertical heights when the system is adjusted.
• Only one user is allowed per vertical lifeline, since a fall by on user would shock
the lifeline and potentially cause other users on the same system to fall.
• Horizontal lifelines give the user the ability to move horizontally the length of the
lifeline.
• Lifelines should not be wrapped directly around the support structure.
• The recommended applications for connecting devices are outlined in the table
below:

Fall Recommended: Not Recommended:

Protection:
Shock • Adequate height above the • Inadequate height above the
Absorbing lower level to accommodate the lower level to accommodate the
Lanyard deceleration distance deceleration distance
(expansion) of the lanyard (expansion) of the lanyard
• Use within manufacturer’s • Use with retractable lifeline
limitations • Use outside manufacturer’s

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Policy No:EHS-509 Fall Protection

limitations

Fall Recommended: Not Recommended:

Protection:
Safety • Potential for only minimal free • Potential for moderate to
Lanyard fall maximum free fall
(non-shock • Inadequate height to the lower • Use outside manufacturer’s
absorbing) level to accommodate the limitations
deceleration distance
(expansion) of the lanyard
• Use within manufacturer’s
limitations
Retractable • Anchor point available • No anchor point available
Lifeline overhead overhead
• Swing from the fall will not • Swing from the fall will direct the
direct the user into other user into other structures or
structures or hazards hazards
• Adequate height to the lower • Inadequate height to the lower
level to accommodate the level to accommodate the
deceleration distance of the deceleration distance of the
retractable lifeline retractable lifeline
• Use requires horizontal and/or • Use outside manufacturer’s
vertical travel limitations
• Use within manufacturer’s
limitations
Vertical • Anchor point available • No anchor point available
Lifeline overhead overhead
(Rope Grab) • Swing from the fall will not • Swing from the fall will direct the
direct the user into other user into other structures or
structures or hazards hazards
• User requires no or limited • User requires frequent horizontal
horizontal or vertical travel and vertical travel
• Single user on the system • Multiple users on the same
• Use within manufacturer’s system
limitations • Use outside manufacturer’s
limitations

Horizontal • Anchor point available at each • No anchor point available at

Lifeline end of the work area each end of the work area
• User requires frequent • User requires frequent vertical
horizontal travel travel
• Multiple users on the system • Use outside manufacturer’s
(provided the proper rating) limitations
• Use within manufacturer’s

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Policy No:EHS-509 Fall Protection

limitations

• Anchor points positioned above the user reduce the distance of free fall.
• Area of anchor point shall be free of rough or sharp edges that can cause
damage to the connector or lifeline.
• The connection to the anchor point should be a direct connection with a locking
device (snap-hooks with spring loaded keeper, cross arm strap, eyebolt) to
properly secure the connection device.
• Knots are not permitted as a means to tie off, since they reduce the support
strength.
When selecting or designing fall protection systems, it is important to remain clear of
electrical hazards. Under certain circumstances, fall protection equipment may be
electrically conductive and possible cause electric shock or electrocution.
6 Inspection, Maintenance, and Care
All fall protection equipment shall be inspected to ensure the equipment is properly
functioning. Inspection frequency will depend upon type of use, frequency of use, and
date/age of the equipment. Equipment should not go more than 3 months without being
inspected.

Although thorough inspections are required at least every quarter (3 months), a

pre-use inspection shall be conducted on all equipment prior to each use. Use
manufacturer’s recommendations on frequency of inspection

Use the following as basic fall protection equipment inspection criteria:

• Inspect body wear webbing, harnesses and safety lanyards for cuts, burns,
chemical damage, abrasions, stretching, frayed fibers or edges, pulled stitches or
other signs of wear.
• Inspect body wear buckles, D-rings, and safety lanyard hardware for proper
function, elongation, distortion, loose components, rust, cracks, free movements
or other signs of wear or malfunctioning.
• Inspect the spring-loaded keeper on the locking snap-hooks for proper
functioning, seating and spring closure.
• Inspect the shock absorber of shock lanyard for any signs of wear affecting the
functioning of the absorber, for signs of elongation, deployment or the warning
flag.
• Inspect ropes and cables for cuts, burns, chemical damage, abrasions,
stretching, frayed fibers or edges, pulled stitches or other signs of wear.
• Inspect for proper functioning of mechanical fall protection components
(retractable lifelines, winches, etc.)

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Policy No:EHS-509 Fall Protection

• Inspect anchor points for cracks, rusting or other signs of support deterioration
and inspect for secure attachment.
Any fall protection equipment found to be defective shall be removed from service
immediately until replaced or repaired.
All fall protection equipment will be cleaned and maintained in a good working order
following each use.
Follow manufacturer’s recommendations for maintenance and storage of fall protection
equipment.
7 Training
All S&W Energy Facility or Site employees (including Field personnel) who will be
involved with assessment of fall hazards in the workplace, using fall protection, and/or
inspecting fall protection equipment, shall be trained on the requirements and guidelines
of this procedure (initially). Refresher training is required every 2 years.
The training must be site-specific and include the following elements:
• Types of general fall hazards;
• Identification of site specific fall hazards;
• Means to eliminate or minimize fall hazards;
• Types of fall protection used on site;
• Limitations of fall protection;
• Use and care of fall protection; and
• Inspection of fall protection
Fall protection should be a combination of classroom and hands-on training. Since
misuse of equipment can result in serious injury or even death, it is extremely important
that employees are able to physically demonstrate their ability to properly use the
equipment as well as understanding the basic fundamentals.
8 Auditing / Inspections
Fall protection equipment shall be inspected daily or prior to each use to ensure they
are free of defects and not damaged. If not used as often, equipment shall be inspected
at least every 3 months.
The Fall Protection Procedure shall be reviewed every 2 years. This procedure will be
updated as necessary.
9 References
29 CFR 1910.21 to 29 CFR 1910.30 Subpart D, Walking-Working Surfaces
29 CFR 1910.269 Electrical Power Generating Facilities
10 Forms
See Appendix O

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Policy No:EHS-509 Fall Protection

O.1 - Fall Hazard Assessment / Inventory

O.2 - Fall Protection Evaluation Form

Page 11
 Environmental Health and Safety
Manual
Policy No. EHS-510 Policy Title: Powered Industrial Trucks
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 Definitions ................................................................................................................ 2
3 Fork Truck Requirements and Guidelines................................................................ 3
4 Training .................................................................................................................... 6
5 Auditing / Inspections ............................................................................................... 8
6 References............................................................................................................... 8
7 Forms....................................................................................................................... 8

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Policy No:EHS-510 Powered Industrial Trucks

1 Purpose and Scope

The purpose of this procedure is to provide the requirements for the operation and
maintenance of industrial powered trucks (i.e., fork trucks, forklifts, etc.). It also
establishes the required training for personnel assigned to operate the trucks and
includes general design criteria for a majority of the industrial powered trucks commonly
found and operated at S&W Energy Facilities or Work Sites.
The requirements and design specifications of this procedure apply to fork trucks,
tractors, platform lift trucks, motorized hand trucks, or other specialized industrial trucks
powered by electric motors or internal combustion engines. This procedure does NOT
apply to compressed air or non-flammable compressed gas-operated industrial trucks
nor does it apply to vehicles intended primarily for earth moving or over-the-road
hauling.
2 Definitions
• Approved Industrial Truck – A truck that is listed or approved for fire safety
purposes for the intended use by a nationally recognized testing laboratory, using
nationally recognized testing standards.
• Class I (Atmosphere) – Locations in which flammable gases or vapors are, or may
be present in the air in quantities sufficient to produce explosive or ignitable
mixtures.
• Class II (Atmosphere) – Locations that are hazardous because of the presence of
combustible dust.
• Class III (Atmosphere) – Locations where easily ignitable fibers or filings are
present but not likely to be in suspension in quantities sufficient to produce ignitable
mixtures
• Competent (Qualified) Trainer - For purposes of this procedure, a person with the
knowledge, training, and experience to train powered industrial truck operators and
evaluate their competence. An example of a Competent (Qualified) Trainer is a
person who, by possession of a degree, certificate, or professional standing, or who
by extensive knowledge, training, and experience has demonstrated the ability to
train and evaluate powered industrial truck operators.
• Designations – Describes the different classifications of powered industrial trucks
based on type of fuel used to power and specific areas or “atmospheres” most
suitable for operation. Refer to the Attachment section in this procedure which
includes the eleven different designations and brief descriptions of each.
• Mast – The upright section of a forklift that contains a set of tracks that house ball
bearings, rollers and chains. It tilts forward or backward and may shift from side to
side.
• Overhead Guard(s) – Keeps falling objects from hitting the operator but is not
strong enough to withstand the force of a heavy load.
• Operators – Any employee properly trained, according tom this procedure, to use a
powered industrial truck and whose job responsibilities include truck operation.

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Policy No:EHS-510 Powered Industrial Trucks

• Powered Industrial Truck – Any mobile powered-propelled truck used to carry,

push, pull, lift, stack or tier materials. They can be ridden or controlled by a walking
operator. In this procedure, Powered Industrial Trucks may be referred to as fork
trucks, fork lift, or just truck.
• Unattended – When the operator is 25 feet or more away from the vehicle which
remains in view or whenever the operator leaves the vehicle and it is not in view.

All users of Powered Industrial Trucks (fork trucks) shall ensure that it is
approved and bears some label or other identifying mark indicating
approval by the testing laboratory.

3 Fork Truck Requirements and Guidelines

A. General
The user of an industrial truck shall ensure that all nameplates and markings are in
place and are maintained in legible condition.
No user or customer shall modify or make additions to the industrial truck which
affects capacity and safe operation WITHOUT the manufacturer’s prior written
approval. All markings shall be changed accordingly, if so modified.
The atmosphere or location where the industrial powered truck is to be used shall
be classified as hazardous or non-hazardous prior to the consideration of the type
of truck to be used.
For those industrial powered vehicles that require battery changing and charging
the following guidelines and requirements apply:
• There shall be a designated area for battery charging.
• Facilities or Sites shall be equipped for flushing and neutralizing spilled
electrolyte, for fire protection, and for adequate ventilation for fumes generated
during gassing of batteries.
• When charging batteries, acid shall be poured into water; water shall NOT be
poured into acid.
• Trucks shall be securely positioned and brake applied before attempting to
charge or change battery.
• Care shall be taken to assure that vent caps are functioning.
• Smoking shall be prohibited in the charging area.
• Precautions shall be taken to prevent open flames, sparks, or electric arcs in
the battery charging areas.
• Metallic objects shall be kept away from the top of uncovered batteries.
B. Truck Operations
No person shall be allowed to stand or pass under the elevated portion of any fork
truck, whether loaded or empty.

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Policy No:EHS-510 Powered Industrial Trucks

Unauthorized personnel shall not be permitted to ride on powered industrial trucks.

If powered industrial vehicle is equipped with seat belts, employer and operator
shall ensure they are properly functioning and operator must wear them during use.
Arms and legs are prohibited from being placed between the uprights of the mast
or outside the running lines of the truck.
When a truck is left unattended, load engaging shall be fully lowered, controls shall
be neutralized, power shall be shut off, and brakes set. Wheels shall be blocked if
parked on an incline.
A safe distance shall be maintained from the edge of ramps or platforms while on
an elevated dock or platform.
Trucks shall not be used for opening or closing of doors.
Brakes shall be set and wheel blocks in place to prevent movement of trucks while
loading or unloading.
In areas where fork trucks are used, there shall be sufficient headroom under
overhead installations (i.e., lights, pipes, sprinkler systems, etc.) to prevent damage
or accidents.
An overhead guard shall be used as protection against falling objects.
Only approved industrial trucks shall be used in hazardous locations (Reference
the Truck Designation / Location Classifications in the Attachment section of this
procedure)
If a truck is equipped with vertical and/or horizontal controls elevatable with the
lifting carriage or forks for lifting personnel, the following additional precautions
shall be taken for the protection or personnel being elevated:
• Use of a safety platform firmly secured to the lifting carriage and/or forks;
• Means provided whereby personnel on the platform can shut off power to the
truck;
• Protection from falling objects, as necessary
Fire aisles, access to stairways, and fire equipment shall be kept clear.
If the truck for any reason is in need of repair, defective, or in any way unsafe, the
truck shall be taken out of service until it has been restored to safe operating
condition. Authorized personnel shall make all repairs.
Fuel tanks shall not be filled while the truck is running. Spillage shall be avoided
and spilled fuel shall be washed away or properly cleaned-up and the tank cap
replaced before restarting the engine.
No truck shall be operated with a leak in the fuel system until the leak has been
corrected.

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Policy No:EHS-510 Powered Industrial Trucks

C. Traveling
All traffic regulations shall be observed including Facility or Site speed limits.
Under all travel conditions, the truck shall be operated at a speed that will permit it
to be brought to a stop in a safe manner.
Other trucks traveling in the same direction shall not be passed at intersections,
blind spots, or other dangerous locations.
The driver is required to slow down and sound the horn at cross aisles and other
locations where vision is obstructed
The driver is required to look in the direction of and keep a clear view of the path of
travel.
Grades shall be ascended and descended slowly.
• When ascending and descending grades in excess of 10%, loaded trucks shall
be driven with the load upgrade.
• On all grades, the load and load engaging means shall be tilted back if
applicable and raised only as far as necessary to clear the road surface.
Stunt driving and horseplay shall not be permitted.
Dockboards and bridgeplates shall be properly secured before they are driven over
and their maximum rated capacity never exceeded.
Elevators shall be entered squarely. Once on the elevator, the controls shall be
neutralized, power shut off, and brakes set. Motorized hand trucks must enter the
elevator with load end forward.
D. Loading
Only stable and safely arranged loads shall be handled. Caution shall be
exercised when handling off-center loads which cannot be centered.
Only loads within the rated capacity of the truck shall be handled.
Trucks equipped with attachments shall be operated as partially loaded trucks
when not handling a load.
A load engaging means shall be placed under the load as far as possible; the mast
shall be carefully tilted backward to stabilize the load.
An elevated load shall not be tilted forward except when the load is in the deposit
position over a rack or stack. Tilting forward with load engaging means tilted is
prohibited except to pick up a load.
E. Maintenance
Authorized personnel shall make all repairs.
No repairs shall be made in Class I, Class II, or Class III locations.
Trucks in need of repair to the electrical system shall have the battery
disconnected prior to repair.

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Policy No:EHS-510 Powered Industrial Trucks

All parts replaced shall be equivalent as to the design and safety with those of the
original parts.
Trucks shall not be altered either in regards to relative positions of various parts
from the original design or relative to the addition of extra parts not provided by the
manufacturer UNLESS it is approved by the manufacturer and altered by
authorized personnel. Additional counterweighing of fork trucks shall not be done
unless approved by the manufacturer.
Fork trucks shall be examined before being placed into service. Such examination
shall be made daily or prior to each use. An example checklist is provided in the
Attachment section of this procedure. Checklists shall be maintained on file along
with records of alterations or repairs, testing results, or other manufacturer’s
information pertinent to the safe operation and maintenance of the fork truck.

Fork Trucks and other powered industrial vehicles shall be inspected DAILY
or prior to each use. Checklists shall be maintained on file.

Any vehicle that emits hazardous sparks or flames from the exhaust system shall
immediately be removed from service and not returned to service until the cause
for emission of sparks or flames has been eliminated.
When the temperature of any part of any truck is found to be in excess of its normal
operating temperature, creating a hazardous atmosphere, the vehicle shall be
removed form service until the cause of such overheating is eliminated.
Trucks shall be kept in a clean condition. Non-combustible agents shall be used
for cleaning trucks.
4 Training
Employers must develop and implement a training program. The employer shall ensure
that each powered industrial truck operator is competent to operate such a vehicle
safely as demonstrated by the successful completed training and evaluation specified in
this section.
Training shall consist of a combination of formal instruction (i.e., lecture, discussion,
video tape, etc.), practical evaluation (demonstrations performed by the trainer and
exercises performed by the trainee) and evaluation of the operator’s performance in the
workplace.
All operator training and instruction shall be conducted by persons who have the
knowledge, training, and experience to train powered industrial truck operators and
evaluate their competence (a Competent Qualified Trainer).
As a standard part of training, all operators shall be trained in the following topics
(unless demonstrated that they do not apply in the workplace). These are the
minimum requirements for the formal instruction portion of fork truck training:

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Policy No:EHS-510 Powered Industrial Trucks

• Operating instructions, warning, and precautions for the types of truck the
operator will be authorized to operate;
• Truck controls and instrumentation: where they are located, what they do and
how the work;
• Engine or motor operation;
• Steering and maneuvering;
• Visibility including restrictions due to loading;
• Fork and attachment adaptation, operation, and use limitation;
• Vehicle capacity;
• Vehicle stability;
• Vehicle inspection and maintenance that the operator will be required to
perform;
• Refueling and/or recharging of batteries;
• Operating limitations;
• Typical and possible surface conditions where the vehicle will be operated;
• Composition of loads to be carried and load stability;
• Load manipulation, stacking and unstacking;
• Pedestrian traffic in areas where the vehicle will be operated;
• Various types of truck designations and classifications;
• Hazardous (classified) areas where the vehicle will be operated;
• Ramps and other sloped surfaces that could affect the vehicle’s stability;
• Closed environments where the build-up of noxious gases (i.e., carbon
monoxide) could become an issue.
As a standard part of training, all operators shall be evaluated on performance of
operating the powered industrial truck taking into consideration the topics
discussed in the formal instruction. This is the minimum requirement for the
practical evaluation portion of the fork truck training. Practical evaluation can be
determined in any one of the following ways (Reference Sample Evaluation in
Attachment Section).
• A discussion with the employee;
• An observation of the employee operating the powered industrial truck;
• A performance test
No tests (i.e., quizzes) are required. However, the employer or trainer MUST verify
competency through some method of evaluation. Records verifying operator
training may be requested during an audit. Sample quizzes are provided in this
procedure which may be used.
To verify completed training, the employer shall certify that each operator has been
trained and evaluated as required. The certification shall include the name of the
operator, the date of the training, the date of the evaluation, and the identity of the
person performing the training or evaluation.
Training certifications shall be maintained on file until the next certification is given.

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Policy No:EHS-510 Powered Industrial Trucks

An evaluation of each truck operator’s performance shall be conducted at least

once every three years.
Refresher training shall be conducted as often as required below or at least every
three years (and include the same material as initial training):
• Whenever the operator has been observed to operate the vehicle in an
unsafe manner;
• Whenever the operator has been involved in an accident or near-miss
incident;
• When the operator has received an evaluation that reveals that he/she is
not operating the truck safely;
• When the operator is assigned to operate a different type of truck; or
• When a condition in the workplace changes in a manner that could affect
safe operation of the truck.
Trainees, who are not fully trained per the regulatory requirements and certified,
may operate a powered industrial vehicle ONLY:
• Under the direct supervision of persons who have the knowledge, training
and experience to train operators and evaluate their competence.
• Where such operation does not endanger the trainee or other employees.

5 Auditing / Inspections
The Powered Industrial Trucks (Fork Truck Safety) Procedure shall be reviewed every 2
years. Safety checklists and training records will be reviewed as part of this procedure
audit. The procedure will be updated as necessary.
6 References
29 CFR 1910.178 Powered Industrial Trucks
ANSI B56.1-1969 National Standard for Powered Industrial Trucks
7 Forms
See Appendix P
P.1 - Fork Truck Designations
P.2 - Sample Daily Fork Truck Maintenance Checklist
P.3 - Sample Fork Truck Evaluation Test

Page 8
 Environmental Health and Safety
Manual
Policy No. EHS-511 Policy Title: Electrical Safety
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 Definitions ................................................................................................................ 2
3 General Procedure / Requirements.......................................................................... 4
4 Grounding ................................................................................................................ 9
5 Electrical Equipment Locations .............................................................................. 10
6 Training .................................................................................................................. 11
7 Auditing / Inspections ............................................................................................. 11
8 References............................................................................................................. 11

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Policy No:EHS-511 Electrical Safety

1 Purpose and Scope

The purpose of this procedure is to provide policy and guidance to ensure that safe
electrical work practices are followed in S&W Energy facilities or on job sites where
S&W Energy employees are working. When it is necessary to perform work in an area
where there is likely to be exposure to energized circuits or electrical hazards, the
special precautions included in this procedure must be followed.
This procedure pertains to all those employees working on electrical equipment or in
and around areas where electrical hazards may be present. They shall be trained to
recognize and/or avoid hazards to which they will or may be exposed.
This procedure shall be used in conjunction with the S&W Energy Lock-Out / Tag-Out
(LOTO) Procedure.
2 Definitions
• Affected Employee – An employee whose job requires him or her to operate or use
a machine or piece of equipment on which servicing or maintenance is being
performed under LOTO, or whose job requires him or her to work in an area in which
such servicing or maintenance is being performed.
• Alternating Current (A-C) – Current which reverses its direction of flow at regular
intervals.
• Ampacity – The current carrying capacity for electrical conductors measured in
amperes.
• Bond – The electrical interconnection of conductive parts designed to maintain a
common electrical potential.
• Bus – A conductor or group of conductors that serve as a common connection for
two or more circuits.
• Circuit – A conductor or system of conductors through which an electrical current is
intended to flow.
• Conductor – A material, usually in the form of a wire, cable or bus bar, used for
carrying an electric current.
• Deenergized – Free of from any electrical connection to a source of potential
difference and from electric charge; not having a potential different from that of the
earth. (This term is used only in reference to current carrying parts, which are
sometimes energized or live).
• Designated Employee – An employee who is designated to perform specific duties
under the terms of this procedure and who is knowledgeable in the construction and
operation of the equipment and the hazards involved.
• Direct Current (D-C) – Current which flows in one direction.
• Enclosed – Surrounded by a case, housing, fence, or walls which will prevent
persons from accidentally contacting energized parts.
• Energized (Alive or Live) – Electrically connected to a source of potential
difference, or electrically charged so as to have a potential significantly different from
that of the earth in the vicinity.

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Policy No:EHS-511 Electrical Safety

• Energy Source – Any electrical, mechanical, hydraulic, pneumatic, chemical,

nuclear, thermal, or other energy source that could cause injury to personnel.
• Exposed Parts – For live (energized) parts, capable of being accidentally touched
or approached closer than a safe distance by a person; for wiring methods, on or
attached to the surface or behind panels which allow access; and for communication
systems, circuits in such a position that failure of the supports or insulation will cause
contact with another circuit.
• Ground – A conducting connection, whether intentional or accidental, between an
electric circuit or equipment and the earth, or to some conducting body that serves in
place of the earth.
• Ground Fault – A condition in which the fault current to ground is greater than the
predetermined value for the circuit.
• Ground Fault Circuit Interrupter (GFCI) – A device whose function is to interrupt
the electric circuit to the load when a fault current to ground exceeds some
predetermined value that is less than that required to operate the overcurrent
protection device of the supply circuit.
• Grounded – Connected to earth or to some other conducting body that serves in
place of the earth.
• Guarded – Covered, fenced, enclosed, or otherwise protected, by means of suitable
covers or casings, barrier rails or screens, mats, or platforms, designed to minimize
the possibility, under normal conditions, of dangerous approach or accidental
contact by persons or objects.
• High Voltage – Nominal voltages equal to 600 Volts or above.
• Impedance – The reactance and resistance which opposes the flow of current in an
AC circuit.
• Inductance – the property of electrical circuit which produces an electromotive force
by the variation of the current in the circuit itself or a neighboring circuit.
• Insulated – Separated from other conducting surfaces by a dielectric (including air
space) offering a high resistance to the passage of current.
• Low Voltage – Nominal voltages of below 600 Volts.
• Nominal Voltage – Voltage value assigned to a circuit or system to designate the
voltage class (service), such as 120/240 and 600.
• Portable Electric Tools – Equipment includes portable appliances, tools, hand
lamps, appliances, and other portable apparatus that are connected by cord and
plug. Majority of Portable Electric Tools, used in this procedure, have 120 Volt / 60
Hertz motors.
• Overcurrent – A condition in which the current is greater than the rate current of the
equipment or the ampacity of the conductors. Overcurrent can result from overload,
short circuit, or ground fault.
• Overload – A condition in which the equipment is operated in excess of its normal
full load, or conductor is operated in excess of its rated ampacity.
• Qualified Employee – A person knowledgeable in the equipment involved and
hazards associated with the work task, as applicable to the construction or operation
of electric power generation, transmission or distribution activities and or equipment.
There are specific requirements to become a Qualified Employee:

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Policy No:EHS-511 Electrical Safety

• Have the skills and techniques necessary to distinguish live parts from
other parts of electrical equipment;
• Have the skills and techniques to determine nominal voltage of exposed
live parts; and
• Know the clearance distances required (in the regulations) and the
corresponding voltages
In addition, a Qualified Employee is:
• A person who must have the appropriate training per regulatory standards;
and
An employee who is undergoing on-the-job training and who, in the course of such
training, has demonstrated the ability to perform duties safely at his or her level of
training and who is under the direct supervision of a qualified person is considered
to be qualified for the performance of those duties.
Retraining is required before performing tasks that are completed at intervals
greater than once per year.
• Short Circuit – A path of a circuit, which drops from its normal resistance to very
low resistance.
• Voltage – The effective potential difference between any two conductors or between
a conductor and ground. Voltages are expressed in nominal voltages unless
otherwise indicated. The operating voltage of the system may vary from this value.
• Working Clearances – Authorizations to perform specified work or permission to
enter a restricted area.

All repair and maintenance work on electrical equipment shall be performed by

trained and authorized personnel only (QUALIFIED EMPLOYEE).

3 General Procedure / Requirements

Where work requires employees to work on or near exposed circuit parts or equipment,
and there is danger of injury due to electrical shock, unexpected movement of
equipment, or other electrical hazards, the circuit parts and equipment that endanger
the employees shall be deenergized and locked- and tagged-out in accordance with
S&W Energy’s Lock-Out / Tag-Out procedure.

Only Qualified Persons may work on equipment or circuits that have NOT been
deenergized.

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Policy No:EHS-511 Electrical Safety

When it is not feasible to deenergize and lock or tag out electrical circuits and
equipment, employees are permitted to work on or near exposed energized electrical
equipment (conductors and circuit parts), provided the appropriate safety related work
practices are implemented for the voltage level of the exposed electrical equipment.
Permission for this work must be granted by the Facility or Site Manager, or designee.
In no situation or at any time shall a S&W Energy employee be authorized to work on or
near energized circuit parts or equipment when the voltage level exceeds 600 volts,
nominal due to extreme dangers associated with and the lack of frequent experience
working on high voltage systems. In these situations, a licensed electrical contractor
must be used.
A. Notify all personnel concerned or affected before starting any electrical equipment.
B. Always assume a circuit is “hot” until you have checked it. Watch for any loose
wires.
C. Employees shall be thoroughly familiar with emergency trip switches.
D. Interlocks and safety devices shall be maintained in a safe and operable condition.
No interlock or other safety device shall be modified tom defeat its function except
for repair or adjustment.
E. Always remove the load from a circuit before pulling the switch. In addition, always
close panel doors on switches before they are turned on.
F. Ventilate the working area well and keep fires and sparks away from charging
batteries since the acid fumes could ignite and explode. Always remember that
hydrogen gas is generated while charging a battery.
G. All employees shall know the proper type of fire extinguisher to use when a fire
occurs of electrical nature. Know where these fire extinguishers are located.
NEVER USE WATER ON AN ELECTRICAL FIRE.
H. Employees shall not be permitted to work in areas where they are likely to encounter
electrical hazards UNLESS they have been trained on and are fully aware of the
general safe work practices specified below:

• Alertness of Employees - Employees should not knowingly be permitted to work

on or near energized circuits when their alertness is recognizably impaired due to
illness, fatigue or other reasons.
• Proper Lighting - Employees must not enter spaces containing exposed electrical
parts unless adequate illumination is provided. Employees shall not reach blindly
into areas which may contain energized equipment.
• Space Considerations - When work near exposed electrical equipment is in an
area such that the space confinements is a safety concern, special consideration
must be given to the number of employees working in the area and the amount of
equipment at the scene so as not to interfere with safe passage near exposed
circuits.
• Working Clearances - Safe distances (and working clearances) shall not be less
than indicated in the Tables, included in the Attachment Section of this
procedure, while working on or near live circuit parts. Distances shall be

Page 5
Policy No:EHS-511 Electrical Safety

measured from the live parts if such parts are exposed or from the enclosure
front opening if such are enclosed.
• Housekeeping and Janitorial Duties - Housekeeping and janitorial duties must
not be performed adjacent to exposed energized electrical parts where such
parts present an electrical safety hazard, unless adequate precautions are taken.
(Water, steam, conductive cleaning fluid, steel wool, or metalized cloth are
examples of materials not suitable for use in the vicinity of energized components
unless procedures are followed to prevent electrical contact).
• Overhead Lines – When work is performed in areas where energized overhead
lines are not guarded, isolated, or insulated, precautions must be taken to
prevent employees from contacting such lines directly (through the body) or
indirectly (through conductive tools or equipment). Again, reference the Tables
in the Attachment Section of this procedure for required and recommended
Approach Distances and Working Clearances.
I. Employees shall be safeguarded from injury by utilizing appropriate personal
protective gear and equipment / tools while working in situations in which there are
potential electrical hazards. These include, but are not limited, to the following:

• Flame-Resistant Clothing – Flame-resistant clothing should be worn by all

electrical workers because of the electrical hazards they face. A full body
NOMEX suit is recommended wear. Employees exposed to electrical hazards
SHALL NEVER wear fabrics which contain the following fabrics, either alone or in
blends:

• Acetate;
• Nylon;
• Polyester; or
• Rayon

Some fabrics specifically designed for use in protective clothing include

flame-retardant materials, synthetic materials, synthetic-cotton blends,
and 100% cotton. Avoid WOOL clothing, as wool produces cyanide
gas when it burns.

All protective equipment shall be inspected prior to each use, shall

be tested annually, and shall be maintained and stored in a safe,
reliable condition.

• Conductive Apparel - Conductive articles of jewelry and clothing such as watch

bands, bracelets, rings, necklaces, key-chains, metalized aprons, belt buckles,
or metal headgear shall not be worn where such items present an electrical
contact hazard with exposed energized parts. They can be worn ONLY IF they
can be rendered nonconductive by covering, wrapping, or using some other
effective means of insulation.

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Policy No:EHS-511 Electrical Safety

• Eye and Face Protection – Suitable eye and face protection shall be worn for
voltage in excess of 300 volts, nominal and when performing work on exposed
energized parts of equipment where there is a danger of injury to the eyes and
face from electric arc or flashes.
• Headgear – Electrical workers must wear nonconductive head protection
whenever they could be exposed to the danger of contacting energized parts or
equipment. Check hardhats to ensure proper rating (conforming to ANSI Z89.2,
Class E Hard Hat.)
• Footwear – Workers must wear some type of footwear that protects them
against accidental electric current when working near energized parts. Over
shoe styles include boots, rubbers, and galoshes. Shoes with shock resistant
soles are the most common. Shoes shall be inspected to ensure integrity prior
to working near energized parts.
• Electrical Safety Gloves – When working on or near low-voltage, energized
electrical parts, rubber gloves are required. (See Table below for glove classes
according to voltage rating). Whenever rubber gloves are used, they shall be
protected by outer leather or canvas gloves. In addition, rubber gloves shall be
air tested prior to each use (i.e., check inside and out for breakdowns,
punctures, cracks, and/or cuts).

Class of Insulating Item Voltage Rating Typical Color

00 500 Beige
0 1,000 Red
1 7,500 White
2 17,000 Yellow
3 26,500 Green
4 36,000 Orange

NOTE: Never use Rubber Gloves for Voltages greater than the rated Voltage.
Leather gloves DO NOT provide protection from electrical currents. Leather
gloves should be worn OVER rubber gloves to protect the rubber from cuts,
abrasions, etc. and shall NEVER be used IN PLACE of rubber gloves
regarding electrical work.

Bare Hand Work is PROHIBITED on ANY circuit over 50 volts.

• Ladders – Metal ladders and scaffolds are electric conductors; they should
never be used around electric circuits or in place where they can come in
contact with electrical circuits. Portable ladders and scaffolds shall be of non-
conductive type only.

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Policy No:EHS-511 Electrical Safety

• Insulated Tools - Employees must use suitable insulated tools or handling

equipment where it is possible for these items to make contact with energized
equipment or parts. This type of protective equipment helps insulate electrical
workers from flashover, shock, and burn hazards.
• Insulated tools are designated as “secondary” protective devices and must be
used in conjunction with appropriate personal protective gear, NOT IN PLACE
OF IT.
• Electrical Safety Matting, Blankets, and Protective Barriers – Protective shields,
barriers or insulating materials (suitable for the voltage rating of the equipment)
shall be used to prevent electrically induced injuries for voltages in excess of
300 volts, nominal and when employees are working in the vicinity of exposed
energized parts when the possibility of heating or arcing is likely.
• Insulating blankets are a “secondary” source of worker protection. Blankets
must be tested before they are initially used and annually thereafter. If they are
damaged in any way, blankets must be taken out of service immediately.
• Permanent Rubber Matting – Permanently installed rubber insulated floor
matting (suitable for the voltage rating of the equipment) shall be installed in
switchgear rooms, motor control centers, and all other applicable locations to
provide continuous protection from any electrical safety hazards that exist. In
outdoor motor control centers where permanent installation is not possible, the
rubber matting shall be readily accessible.
• Hot Sticks (Shotguns) – Used on Live Lines, these insulated sticks of reinforced
fiberglass, epoxiglass, or wood are considered “live-line tools” and are used to
energize or deenergize the elements of conductors or parts associated with
electrical equipment. They are typically used to help maneuver and shift pieces
of equipment of provide the proper working clearances and distances with its
extended reach. Workers must still use gloves when using Hot Sticks.

J. To alert other employees that there are exposed energized parts or components in
the area, the following alerting methods shall be used, as required and feasible:

• Safety signs and tags shall always be used to warn employees that there are
potential hazards in the area.
• Barricades shall be used in conjunction with safety signs when it is necessary to
prevent or limit personnel access to work areas where the possibility of
exposure to exposed energized conductors is highly likely. Metal barricades
must not be used in these situations.
• Manual signaling shall be used when work areas prevent signs and barricades
from being effective alert measures.

K. Only employees who have a thorough knowledge of working safely with test
instruments and equipment on energized circuits shall be permitted to perform
testing work on electronic circuits or equipment where there is danger of injury due
to accidental contact with energized parts or improper use of test equipment.

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Policy No:EHS-511 Electrical Safety

Test instruments and equipment and all associated test leads, cables, power cords,
probes, and connectors shall be visually inspected for external defects or damage
before each use. If damaged in any way, the equipment shall not be sued until
replaced or repaired.
Test instruments and their accessories shall be rated for the circuits and equipment
to which they will be connected and must be suitable for the environment in which
they will be used.
L. After work on energized systems, the employee performing the work is responsible
for removing any personal protective equipment and barricades, and reinstalling all
permanent barriers and/or covers.
M. Portable electric tools shall be treated in such a manner as not to damage or impair
the safety of the device. Some examples of POOR work practices that shall be
avoided when using or handling these types of tools include:

• Raising and lowering the tool using the power cord;

• Using the cord to pull the plug from the socket;
• Using the tool in a manner for which it was not designed (i.e., as a hammer);
• Using the tool in a manner such that it is exposed to water, steam, or excessive
dust.
Prior to each use, portable electric tools should be inspected for damage to the
plug, cord, or external case. Inspect for loose parts, cracks or tears, and wear that
might prevent the insulation from functioning properly and thus creating a safety
hazard. If tools or electrical equipment is not used daily or frequently, then a
quarterly inspection is required.
Any defective or broken tool or piece of equipment must IMMEDIATELY be taken
or tagged “OUT OF SERVICE” to prevent from using.
4 Grounding

EFFECTIVE GROUNDING states the path to ground:

1. Is permanent and continuous;
2. Has the capacity to conduct any fault current that may be imposed upon it;
and
3. Has low enough impedance to limit the voltage to ground and facilitate the
operation of circuit overcurrent devices.

Page 9
Policy No:EHS-511 Electrical Safety

Only flexible cords and cables which contain an equipment grounding conductor shall
be used for cord and plug connected electric equipment. Existing equipment grounding
connections shall never be by-passed.
Adapters which interrupt the continuity of the equipment grounding connection (i.e.,
convert a three prong plug to a two-prong plug) shall not be used.
NOTE: In the case of a power tool that is double insulated, a flexible cord without a
grounding conductor may be used, but not recommended.
Whenever portable electric tools are used, the equipment must be protected via a
ground fault circuit interrupter (GFCI).
Each Site should have an Assured Equipment Grounding Program. It is an inspection
program covering the following:
• All cord sets (extension cords;
• Receptacles that are not a part of the permanent wiring of the structure;
• Equipment connected by cord and plug that is available for use or is used by
employees.
Under this program, regulatory standards mandate that the following two tests be
performed BEFORE the first use of new equipment, AFTER suspected damage to
the equipment, and at THREE MONTH INTERVALS (QUARTERLY):
• A continuity test to ensure that the equipment grounding conductor is
electrically continuous;
•
• A test must be performed on receptacles that are not part of the permanent
wiring of the building or structure, on all cord sets, and on cord- and plug-
connected equipment that is required to be grounded;
•
• A test to ensure that the equipment grounding conductor is connected to its
proper terminal.
5 Electrical Equipment Locations
The entrances to enclosures containing exposed high voltage energized parts, such as
transformers or switchyards, shall be kept locked, if capable. Access doors or gates to
rooms, vaults, or fenced enclosures containing electrical equipment shall be readily
opened from the inside without the use of a key.
Post entrances to rooms and other guarded locations containing exposed live parts with
conspicuous signs forbidding unqualified persons to enter.
Permanent and easy-to-read warning signs shall be posted on all doors and gates that
provide access to enclosures containing exposed energized parts and conductors
forbidding unqualified persons to enter. Signs shall be legible at 12 feet, of sufficient
durability to withstand the environment, and shall read something similar to the
following: “WARNING: HIGH VOLTAGE – KEEP OUT”.

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Policy No:EHS-511 Electrical Safety

Put up appropriate caution signs on metal-enclosed switchgear, unit substations,

transformers, pull boxes, connection boxes, and similar equipment

6 Training
Any S&W Energy Facility or Site employees (including Field personnel) who will be
involved with electrical work on or near exposed energized parts (a qualified employee)
or working in areas where electrical work may be performed, shall be trained on the
requirements and guidelines of this procedure initially, upon hire.
Qualified employees shall be trained and competent in the following:
• The skills and techniques necessary to distinguish exposed live parts from other
parts or electrical equipment;
• The skills and techniques necessary to determine the nominal voltage of
exposed live parts;
• The minimum approach distances specified and the corresponding voltages to
which the qualified person will be exposed; and
• The proper use of precautionary techniques, personal protective equipment,
insulating and shielding materials, and insulated tools for working on or near
exposed energized parts of electric equipment.
Refresher training is required annually.
7 Auditing / Inspections
A quarterly inspection of electrical equipment should be made and findings recorded.
All electrical hand tools, extension cords and other protective equipment should be
inspected periodically and results documented. A visual inspection should be
conducted prior to any use of this equipment (check for electrical integrity and
insulation).
The Electrical Safety Procedure shall be reviewed annually. This procedure will be
updated as necessary.
8 References
29 CFR 1910.137 Electrical Protective Equipment
29 CFR 1910.269 Electric Power Generation, Transmission, and Distribution
29 CFR 1910.331-335 Safety-Related Work Practices - Electrical

Page 11
 Environmental Health and Safety
Manual
Policy No. EHS-512 Policy Title: Fire Protection and Prevention
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 Definitions ................................................................................................................ 2
3 Procedure ................................................................................................................ 3
4 General Fire Prevention and Fire Safety Requirements........................................... 4
5 Fire Prevention and Fire Safety Equipment Requirements ...................................... 5
6 Testing, Inspection, and Maintenance of Fire Prevention Safety Equipment ........... 5
7 Alarm Systems ......................................................................................................... 6
8 Training .................................................................................................................... 6
9 Auditing / Inspections ............................................................................................... 7
10 References ........................................................................................................... 8
11 Forms ................................................................................................................... 8

Page 1
Policy No:EHS-512 Fire Protection and Prevention

1 Purpose and Scope

The purpose of this procedure is to provide general guidance to prevent the onset of fire
in the workplace. This procedure also defines the minimum requirements for Facility- or
Site-specific fire protection and prevention procedures and plans.
This procedure does NOT provide direction for cutting, burning, welding, brazing, or any
other hot work operations. Specific procedures for these activities are provided
separately in S&W Energy’s EHS Manual.
This procedure does NOT provide direction for emergency response. Specific
procedures for these activities are provided separately in S&W Energy’s EHS Manual.
2 Definitions
• Automatic Fire Detection Device – A device designed to automatically detect
the presence of fire by heat, flame, light, smoke or other products of
combustion.
• Carbon Dioxide – A colorless, odorless, electrically non-conductive inert gas
which acts as an extinguishing agent by reducing the concentration of oxygen
or fuel vapor in the air, such that combustion is not possible and cannot
continue.
• Combustible Liquid – A liquid having a flashpoint at a specified temperature at
or above 100 degrees F and below 200 degrees F.
• Dry Chemical – An extinguishing agent composed of very small particles of
chemicals such as sodium bicarbonate, potassium bicarbonate, or potassium
chloride, supplemented by special treatment to provide resistance to packing
and moisture absorption, as well as to provide proper flow capabilities.
• Dry Powder – A compound used to extinguish or control Class D fires.
• Flammable Liquid – A liquid having a flashpoint at a specified temperature
below 100 degrees F, with a vapor pressure of less than 40 pounds per square
inch at 100 degrees F.
• Flash Point – Lowest temperature at which a liquid or solid gives off a vapor in
such a concentration that when the vapor combines with air near the surface of
the liquid or solid, a flammable mixture is formed. The lower the flashpoint, the
more flammable the product.
• Grounding – The procedure used to carry an electrical charge to ground
through a conductive path.
• Halogenated Agent – A colorless, electrically nonconductive gas that
extinguishes fires by inhibiting the chemical chain reaction of fuel and oxygen.
• Incipient Stage Fire – A fire that is at the initial or beginning stage and that can
be controlled or extinguished by a portable fire extinguisher, Class II standpipe,
or small hose system, without the need for protective clothing or breathing
apparatus.
• Multipurpose Dry Chemical – A dry chemical which is approved for use on
Class A, Class B, and Class C fires.

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Policy No:EHS-512 Fire Protection and Prevention

• Safety Can – An approved container, no more than 5 gallons capacity, having a

spring closing lid and spout cover and designed to safely relieve internal
pressure under fire exposure.
• Standpipe Systems:
• Class I Standpipe System – A 2.5-inch hose connection for use by fire
departments and those trained in handling heavy fire streams.
• Class II Standpipe System – A 1.5-inch hose system that provides a
means to control and extinguish incipient stage fires.
• Class III Standpipe System – A combined system of hose, for the use of
employees trained in hose operations, that is capable of controlling the
more advanced stages of fire (beyond the incipient stage) in the
workplace’s interior.
• Small Hose System – A system of hose, with a minimum diameter of 5/8 of
an inch which can be used by employees to control and extinguish incipient
fires.
3 Procedure
A Fire Protection/Prevention Plan must be prepared specifically for each Facility or Site.
The plan should be either included or referenced in the Facility or Site Emergency
Response Plan and/or Emergency Action Plan.
• The Fire Protection and Prevention Plan and the Emergency Response Plan
have many differences but contain a lot of the same information. If the
information is not included in one Plan because it is already included in another
Plan, the information must at least be referenced. This ensures that both plans
are in compliance with regulatory requirements.
• The plan is to be maintained on-site, kept up-to-date, and made readily
available for employee review.
The following is a list of key elements that shall be included in a Fire Protection and
Prevention Plan:
• Potential fire hazards and their proper handling and storage requirements;
• Potential ignition sources and their control measures (refer to the Attachment
Section of this procedure for table of Common Industrial Ignition Sources and
Preventive Measures);
• Types of fire protection equipment or systems that control a fire;
• Job titles of personnel responsible for maintenance of equipment and systems
installed to prevent or control fires;
• Job titles of those personnel responsible for control of fuel source hazards (i.e.,
flammable and combustible material);
• Housekeeping procedures that help control accumulations of flammable and
combustible waste material and residues;
• Maintenance requirements for equipment and systems installed on heat
producing equipment to prevent accidental ignition of combustible materials;
• Emergency telephone numbers and contact information;

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Policy No:EHS-512 Fire Protection and Prevention

• Emergency shut down procedures; and

• Emergency notification system.
Every Facility or Site shall evaluate the possible fire hazards around the workplace and
determine the measures to prevent and/or contain a fire.
4 General Fire Prevention and Fire Safety Requirements
All fires shall be reported tom the local fire authorities, to Company management, and
where applicable, to the Client Company.
Good housekeeping and equipment maintenance must be practiced to keep fire
hazards to a minimum.
Matches and cigarette lighters should not be carried into any area where an explosive
atmosphere may exist.
Smoking must be confined to specifically designated areas. Smoking is not permitted
within 35 feet (10.7 meters) of combustible or flammable materials. Areas where
flammable gases or liquids are used or stored should be designated as a “No Smoking”
area. Appropriate signs should be displayed.
Oily waste or oil soaked clothing must be properly disposed. Covered metal containers
for disposal of oily rags, waste, and other flammable rubbish must be provided.
Containers must be emptied and disposed of on a daily basis or emptied enough to
keep the premises in a safe and sanitary condition.
Before an open flame (i.e., a welding torch) is carried into an enclosed are such as a
small confined building, a tank, or vessel, a test shall be conducted to detect the
presence of gas. Use of a combustible gas indicator is recommended.
When volatile hydrocarbon liquids, such as condensates, gasoline, and some oils, are
decanted into open metal containers, the open container must be grounded. Threaded
connections or a bonding wire to the vessel or piping should be used to prevent
generation of static electricity near an ignition source.
Only approved safety cans should be used to store gasoline. The can shall be properly
labeled identifying the contents.
Oil or gasoline from leaks should not be burned. Any leakage should be cleaned up
and disposed of in the proper manner.
All leaks should be repaired and reported as soon as possible. If immediate repair is
not possible, adequate warnings must be provided to affected personnel and extra
precautions against fires implemented.
• In the event of a gas leak, all fires, open flames, and engines should be shut
down immediately.
• When testing for leaks around fittings, use soapsuds or the appropriate leak-
test fluid. NEVER USE AN OPEN FLAME.

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Policy No:EHS-512 Fire Protection and Prevention

Flammable Liquids
Flammable liquids and sprays must not be used near open flames or be used for
cleaning purposes.
Flammable liquids shall not be stored in open containers or in glass containers.
5 Fire Prevention and Fire Safety Equipment Requirements
Fire fighting equipment is for fire use only and shall be kept in its designated place at all
times when not in use.
All fire protection equipment must be located in designated areas that are clearly
identified with appropriate markings.
• The equipment should be located in the vicinity of likely fire hazards but easily
accessible to operating personnel.
• All employees should familiarize themselves with the location and proper use of
fire extinguishing equipment.
Fire protection equipment and apparatus shall be colored red for easy identification.
Fire extinguishers partially used shall be discharged of pressure, recharged or replaced
immediately.
Extinguishers should not be filled with any material other than that which is designated
on the extinguisher.
All fire extinguisher hose nozzles (and all fire fighting equipment) should be kept free of
obstruction at all times.
An empty or defective fire extinguisher should never be hung until it has been serviced
or repaired. Fire extinguishers should be kept filled. Manufacturer’s instructions for
refilling and maintaining must be followed.

Reference the Attachment Section of this Procedure for information on the

different classes of fires and the appropriate rated fire extinguishers to be
used in each case.

6 Testing, Inspection, and Maintenance of Fire Prevention

Safety Equipment
All portable fire extinguishers must be inspected monthly by designated personnel.
Designated on-site personnel can conduct the inspection. Each monthly inspection
must be recorded on a tag affixed to each unit. Each unit must be serviced annually by
a certified contractor. The contractor must affix a service tag.
Automatic sprinkler systems must be serviced semi-annually by a licensed contractor.
A service tag must be affixed, documenting the service.

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Policy No:EHS-512 Fire Protection and Prevention

A licensed contractor must do a non-discharging actuating test on fixed extinguishing

systems at least annually. These systems typically are classified as automatic fire
protection systems that use foam, carbon dioxide, halon, Freon, or other chemicals.
Employees should be instructed to leave the building when testing these systems to
avoid inhalation of these chemicals.
All fire hoses and hose reels should be tested at least every year at maximum available
working pressure or more frequent if circumstances indicate. (Unlined fire hoses inside
buildings shall be excluded from pressure testing).
Smoke detectors shall be tested quarterly to ensure they are in proper operating
condition.
7 Maintenance records for fire equipment must be
maintained for five years. Alarm Systems
Each workplace should have established procedures for reporting fires and other
emergencies and for sounding emergency alarms. Emergency alarm systems may
include manual pull box alarms, public address systems, radio and telephones, and
direct verbal communications.
All employees in the affected work area should be able to hear and recognize any alarm
above ambient noise or light levels. Emergency notification can consist of a steam
whistle, air horns, strobe lights, or similar lighting devices.
Emergency telephone numbers shall be posted near telephones, employee notice
boards, and other conspicuous places. Manually operated actuation devices for use in
conjunction with employee alarms must be unobstructed, conspicuous, and readily
accessible.
Employee alarm systems should be properly maintained in operating condition. Trained
personnel should perform all servicing, testing and maintenance. An alarm backup
system should be provided when the system is out of service or under repair.

If a fire is observed, employees should first activate the alarm system, notify
the control room (or equivalent primary contact area), and follow the site
emergency Action Plan and/or Emergency Response Plan accordingly.

8 Training
All S&W Energy Facility or Site employees (including Field personnel) shall be trained in
understanding the purpose and function of this procedure and shall be trained on the
requirements and guidelines in their Facility- or Site-specific Fire Protection and
Prevention Plan initially, upon hire. Refresher training is required annually.

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Policy No:EHS-512 Fire Protection and Prevention

• Maintenance, or other designated personnel, may additionally be trained in

procedures for proper inspection, operation, maintenance, and repair of fire
detection and extinguishing systems.
If assigned specific duties for fire suppression, designated employees must be
instructed on the proper use of available fire fighting equipment at the facility or Site.
Training must occur annually.
Training on this procedure and its requirements should be given in conjunction with the
Facility or Site’s Emergency Response Procedures.
Employees shall receive basic instruction in the procedures to be followed in the event
of a fire in their work area. Fire drills shall be conducted annually and may be included
as part of the emergency response drill.
Personnel required to use fire extinguishers to control incipient fires must receive
annual training.
9 Auditing / Inspections
Fire extinguishers in the facility shall be inspected monthly by the designated site
personnel or fire safety vendor. Other fire safety equipment shall be inspected per the
guidelines and requirements of Section 6 of this procedure.
A review of the written Fire Protection and Prevention Program should be done
annually. The written Fire Protection and Prevention Program must be signed and
dated following any review or revision. In addition, a periodic review and evaluation of
the program should be done after any incident or evacuation.
The Fire Protection and Prevention Procedure shall be reviewed every 2 years. This
procedure will be updated a necessary.

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Policy No:EHS-512 Fire Protection and Prevention

10 References
29 CFR 1910.38 Employee Emergency Response Plans and Fire Prevention
Plans
29 CFR 1910.106 Flammable and Combustible Liquids
29 CFR 1910.144 Safety Color Code for Marking Physical Hazards
29 CFR 1910.157 Portable Fire Extinguishers
29 CFR 1910.158 Standpipe and Hose Systems
29 CFR 1910.159 Automatic Sprinkler Systems
29 CFR 1910.164 Fire Detection Systems
29 CFR 1910.165 Employee Alarm Systems
29 CFR 1910.252 Welding, Cutting, Brazing / Fire Protection and Prevention
NFPA Standard 51B
NFPA Publication Fire Protection Systems Inspection, Test, and Maintenance
Manual
11 Forms
See Appendix Q
Q.1 - Classes of Fires and Appropriate Fire Extinguishers
Q.2 - Sample Fire Prevention Checklist
Q.3 - Sample Fire Extinguisher Inventory Form

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 Environmental Health and Safety
Manual
Policy No. EHS-513 Policy Title: Confined Space Entry
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 Definitions ................................................................................................................ 2
3 General Requirements ............................................................................................. 4
4 Procedure(s) ............................................................................................................ 6
5 Contractor Requirements For Confined Space Entry ............................................. 11
6 Rescue Services .................................................................................................... 12
7 Training .................................................................................................................. 13
8 Auditing / Inspections ............................................................................................. 13
9 References............................................................................................................. 13
10 Forms ................................................................................................................. 13

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Policy No:EHS-513 Confined Space Entry

1 Purpose and Scope

This procedure outlines the guidelines to safeguard employees and contractors against
health and safety hazards associated with work to be performed within Confined
Spaces. More specifically, it defines the minimum requirements for identifying and
evaluating confined space hazards around a Facility or Site and establishes
requirements for safe entry into Permit-Required and Non-Permit Required Confined
Spaces.
This procedure serves as the Permit-Required Confined Space Program and provides
written procedures reflecting regulatory requirements for preparing permits for entry and
for returning the permit space to service following termination of entry.
2 Definitions
• Attendant - An individual stationed outside a Permit-Required Confined Space
who monitors the Authorized Entrants and who performs all Attendants’ duties
assigned in this procedure. Attendant’s duties include:

• Knowing the hazards that may be faced during entry into any one confined
space; and
• Maintaining an accurate account of Entrants in the permit space by
monitoring sign-in / sign-out log; and
• Remaining outside the permit space during entry operations until relieved by
another Attendant; and
• Communicating with Entrants as necessary to monitor safety status and work
progress; and
• Monitoring activities to determine if it is safe to remain in the space or need to
evacuate; and
• Summoning rescue activities as soon as it is determined that assistance is
needed; and
• Performing non-entry rescue, as required.

• Authorized Entrant - An employee who is authorized by the Facility or Site

Manager, or their designee, to enter a Permit-Required Confined Space. This
can also be a Contractor employee, designated by Contractor representative.
• Confined space - A space that meets the following requirements:

• Is large enough and so configured that an employee can bodily enter and
perform assigned work; and
• Has limited or restricted means for entry or exit (for example: tanks,
vessels, vaults, and pits are spaces that may have limited means of entry);
and
• Is not designed for continuous employee occupancy.

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Policy No:EHS-513 Confined Space Entry

• Confined Space Entry Permit - A written or printed document that is required

to be completed and posted at the entrance to a Permit-Required Confined
Space prior to entry into that space. The permit shall be completed by the Entry
or Shift Supervisor. A Contractor Supervisor may complete the Permit for
Contractor employees but the Permit must still be reviewed and signed by Site
Supervisor.
• Engulfment - The surrounding and effective capture of a person by a liquid or
finely divided (flowable) solid substance that can be aspirated to cause death by
filling or plugging the respiratory system or that can exert enough force on the
body to cause death by strangulation, constriction, or crushing.
• Entry - The action by which a person passes through an opening into a permit-
required confined space. Entry includes ensuing work activities in that space
and is considered to have occurred as soon as any part of the entrant’s body
breaks the plane of an opening into the space.
• Entry Supervisor - An employee (i.e., Shift Supervisor, or designee, foreman,
or crew chief) responsible for determining if acceptable entry conditions are
present at a permit-required confined space where entry is planned, for
authorizing entry and overseeing entry operations, and for terminating entry as
required by this procedure. For entries involving Contractors, the Entry
Supervisor shall be a qualified Contractor employee. An Entry Supervisor may
also serve as an Attendant or as an Authorized Entrant, if properly qualified and
trained. Duties of Entry Supervisor may be passed from one individual to
another during course of an entry.
• Hazardous Atmosphere - An atmosphere that may expose employees to the
risk of death, incapacitation, impairment of ability to self -rescue (that is, escape
unaided from a permit space), injury, or acute illness from or more of the
following causes:

• Flammable gas, vapor, or mist in excess of 10% of its Lower Flammable

Limit (LFL);
• Airborne combustible dust at a concentration that meets or exceeds it’s
LFL;
• Atmospheric oxygen concentration below 19.5% or above 23.5%;
• Atmospheric concentration of any substance for which a dose or
permissible exposure limit is published in Subpart G, Occupational Health
and Environmental Control, or in Subpart Z, Toxic and Hazardous
Substances, of 29 CFR 1910.1000 and which could result in employee
exposure in excess of its dose or Permissible Exposure Limit.
• Any other atmospheric conditions that is immediately dangerous to life and
health.

• Hot Work Permit – Written authorization by the Facility or Site, allowing

operations such as riveting, welding, cutting, burning, and heating (or others)
capable of providing a source of ignition.

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Policy No:EHS-513 Confined Space Entry

• Immediately Dangerous to Life and Health (IDLH) – Any condition that poses
an immediate or delayed threat to life or that would cause irreversible adverse
health effects or that would interfere with an individual’s ability to escape
unaided from a permit-required confined space.
• Inerting – The displacement of the atmosphere in a confined space by a
noncombustible gas (such as nitrogen) to such an extent that the resulting
atmosphere is noncombustible.
• Lower Explosive Level (LEL) - Lowest concentration of a gas, vapor, dust or
mist that will ignite in air.
• Non-Permit Required Confined Space - A confined space that does not
contain, or with respect to hazardous atmospheres, have the potential to
contain any hazard capable of causing death or serious physical harm.
• Permissible Exposure Limit (PEL) - Atmospheric concentration of any
substance for which a dose is published in regulatory standards (i.e., Subpart Z,
Toxic and Hazardous Substances, of 29 CFR 1910.1000).
• Permit-Required Confined Space - A confined space that has one or more of
the following characteristics:

• 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; or
• Contains any other recognized serious safety or health hazard.

• Qualified – Refers to a person with specific training, knowledge, and

experience in the area for which the person has responsibility and the authority
to control.
• Retrieval System - The equipment (including a retrieval line, chest or full-body
harness, wristlets, if appropriate, and a lifting device or anchor) used for non-
entry rescue of persons from permit spaces.
3 General Requirements
A. Evaluation of the Workplace / Site
The Facility or Site Manager, or designee shall evaluate the workplace or worksite and
identify each confined space. Each confined space identified must be classified as
either Permit-Required Confined Space or Non-Permit Required Confined Space.
The Facility or Site shall use the Confined Space Inventory Form to record all applicable
information regarding hazardous atmospheres, associated hazards, personal protective
equipment required to enter the space and rescue equipment required to be on-hand for
each space identified. Determinations and dates the space was tested will be made
available to entrants/contractors upon request.

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Policy No:EHS-513 Confined Space Entry

B. Permit-Required Confined Space

For Facilities with Permit-Required Confined Spaces, the Facility shall:
1. Develop and implement a written Confined Space Permit Program and
subsequent procedures to coordinate entry operations into Permit-Required
Confined Spaces
2. Coordinate entry operations when employees of more than one employer are
working simultaneously as Authorized Entrants in a Permit-Required Confined
Space.
3. Develop and implement testing guidelines and procedures for classifying the type
and magnitude of the hazards and conditions within the space.
4. Implement permitting system to identify proper approval for entry.
5. Develop communication procedures to be used by Authorized Entrants and
Attendants to maintain contact during the entry.
6. Identify the rescue and emergency services, either on-site or off-site, that can be
summoned and the means for summoning those services.
7. Inform employees exposed to permit-required confined spaces by posting danger
signs (labeling):

• The sign must be posted by the entry point of the Permit-Required Confined
Space. A recommended Confined Space Entry sign is given in the
Attachment section of this procedure.
• The sign must be clearly and permanently labeled.
• The sign shall not be placed on a hatch cover or in any area where the sign
can be covered from view. When entrance covers are removed, the opening
shall be promptly guarded by a railing, temporary cover, or other temporary
barrier that will prevent an accidental fall through the opening and protect
each employee in the space from foreign objects entering the space.
• An example sign may read: “DANGER – PERMIT REQUIRED CONFINED
SPACE, DO NOT ENTER”.

C. Non-Permit Required Confined Space

An Attendant is not required for entry into a Non-Permit Required Confined Space.
However, it is recommended that no employee work alone in any spaces around the
Facility or Site. The “buddy system” should be adhered to when possible.
Air monitoring is required initially in order to classify the space as a Non-Permit
Required Confined Space. This air monitoring information will be recorded the
Confined Space Entry Permit (Page 2) for documentation purposes. Page 2 of the
Confined Space Entry Permit on which monitoring data was recorded will then be
filed with the Confined Space Inventory Form. As long as conditions do not
change, no additional air monitoring is required. However, if there is ever a
question about the condition of the atmosphere in the space, consult the Shift
Supervisor and/or Facility or Site Manager and retest the atmosphere.

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Policy No:EHS-513 Confined Space Entry

When there are changes in the use or configuration of a Non-Permit Required

Confined Space that might increase hazards to Entrants, the space shall be
reevaluated and, if necessary, reclassified as a Permit-Required Confined Space.
D. Reclassification of a Permit-Required Confined Space
A space classified by the Facility or Site as a Permit-Required Confined Space may be
reclassified as a Non-Permit-Required Confined Space under the following procedures:
1. If the permit space poses no actual or potential atmospheric hazards and if all
hazards within the space are eliminated without entry into the space, the permit
space may be reclassified as a Non-Permit-Required Confined Space for as long
as the non-atmospheric hazards remain eliminated.
2. If it is necessary to enter the space to eliminate hazards, entry shall be
performed under normal Permit-Required Confined Space procedures. If testing
within that entry demonstrates that the hazards have been eliminated, the permit
space may be classified as a Non-Permit-Required Confined Space for as long
as the hazards remain eliminated.
3. The testing that reclassified the Permit-Required Confined Space as a Non-
Permit-Required Confined Space must be documented, including the date,
location of space, and person making the determination (this can be done on the
air monitoring section of the Confined Space Entry Permit (Page 2 of the
Permit)). The space shall be reclassified on the Confined Space Inventory Form.

Control of atmospheric conditions through forced air ventilation DOES NOT

constitute ELIMINATION OF THE HAZARDS for purpose of reclassification. It
cannot be reclassified if the hazardous atmosphere is being CONTROLLED and
NOT ELIMINATED.

4 Procedure(s)
A. Pre-Entry Requirement

No person shall enter a Permit-Required Confined Space without at least one

Attendant outside the permit space into which entry is authorized for the
duration of entry operations. Attendant and Entrant should have either visual
contact of one another or be able to communicate verbally in case of
emergency.

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Policy No:EHS-513 Confined Space Entry

Prior to entry:
1. Provide pedestrian, vehicle, or barriers, as necessary, to protect entrants from
external hazards.
2. Ensure the space has met specified acceptable entry conditions (identified on
Confined Space Inventory).

• Test the internal atmosphere to ensure no hazards exist. Conditions shall be

monitored for oxygen content, flammable gases (vapors), and potential toxic
contaminants, in that order. Refer to Section on Testing of a Confined Space.
• Clean, purge, inert, flush, and/or ventilate the space, as necessary, to
eliminate or control any hazardous atmosphere present.

3. Isolate the space by use of a physical disconnect or by blanking all piping or feed
lines (exceptions are process vessels where blanking off would not be
acceptable). Systems, which could carry hazardous substances into the space,
must be isolated and locked out or tagged out in accordance with applicable
Facility and/or Site procedures.
4. Provide temporary lighting, as necessary. Temporary lighting used in the space
shall be of vapor proof design, with heavy cords and insulation in good condition.
Explosion-proof, intrinsically safe, or twelve (12) volt (or less) lighting systems
shall be used in Permit-Required Confined Spaces.
5. Identify equipment, such as personal protective equipment, testing equipment,
communications equipment, alarm systems, and rescue equipment, to be used
during the entry. Utilize the Pre-Entry Checklist in the Attachment Section of this
procedure in preparation for entry.

NOTE: This is not an exhaustive list and may not be the only necessary pre-
entry steps

6. Provide at least one Attendant at each Permit-Required Confined Space.

7. Prepare and complete required information on Confined Space Entry Permit and
obtain correct signatures and approvals for entry. All paperwork shall be kept on
file.
B. Entry Requirements / Entry Process

The Attachment Section of this Procedure includes a Confined Space Entry

Permit Form, for reference. It contains all the information required and may be
used at the Facility or Site. Any other Form used must contain at least the same
information as the Form attached.

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Policy No:EHS-513 Confined Space Entry

Entry Permit
1. Before entry, a Confined Space Entry Permit shall be completed, approved, and
posted at the entry to the Permit-Required Confined Space and is in effect for the
duration of work in the space. Provisions shall be made if the work carries over
to the next shift (i.e., issue a new permit for the next shift). The Permit shall be
posted so that all Authorized Entrants can review and confirm that all pre-entry
preparations have been completed.
2. The Entry Supervisor, or designee, shall complete the permit for entry into
Permit-Required Confined Spaces by on-site employees. A Contractor
Supervisor shall fill out the Permit for any entry involving a Contractor.
HOWEVER, in this case, the Permit MUST be reviewed and approved by the
Entry Supervisor from the Facility or Site.

A Confined Space Entry Permit must include the following:

• Identification of the confined space to be entered;

• Purpose of the entry;
• Date and duration of the permit;
• Personnel (by name) currently serving as Attendant(s);
• Name(s) of the current Authorized Entrant(s);
• NOTE: This requirement may be met by using a separate Sign-In / Sign-Out
Log that is posted outside of space next to permit.
• Name of Entry Supervisor
• A list of hazards in the Permit-Required Confined Space;
• A list of measures used to isolate the Permit-Required Confined Space and
eliminate or control the hazards (LOTO, purging, inerting, ventilating, and
flushing);
• The acceptable entry conditions;
• Monitoring and testing results of the conditions within the Permit-Required
Confined Space (includes names of testers and times). Refer to Section on
Testing of a Confined Space.
• The rescue and emergency services available and the means to summon
them;
• Communication procedures for Attendants and Entrants;
• Any required equipment (such as respirators, communication, alarms, etc.);
and
• Any additional permits (such as hot work) for the Permit-Required Confined
Space.

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Policy No:EHS-513 Confined Space Entry

3. The Entry Supervisor identified on the Permit shall sign the permit to authorize
entry upon his/her approval of all requirements being satisfied.
4. The Entry Supervisor shall terminate entry and cancel the entry permit when:

• The entry operations covered by the entry permit have been completed; or
• A condition that is not allowed under the entry permit arises in or near the
permit space.
The Facility or Site shall retain copy of the canceled Permit for at least 1 year to
facilitate review of Program.
C. Other Entry Requirements
1. A Confined Space Sign In/Sign Out Log will be kept at the entry portal of the
space and all employees/Contractors will sign this log each time they enter or exit
the Permit-Required Confined Space.
2. The current Attendant may not enter or leave the Permit-Required Confined
Space entrance until properly relieved by someone who is properly trained in
confined space entry and briefed on the hazards of that particular confined space.
D. Testing of a Confined Space
1. The Entry Supervisor, or a trained Facility or Site employee, shall test the
atmosphere of the confined space immediately prior to employee entry with a
calibrated direct-reading instrument. A written record of test results from air
monitoring must be made on the Confined Space Entry Permit. The Entrant must
have the opportunity to observe this testing if so desired and has the right to
request reevaluation.
2. Facilities or Sites must provide and maintain on-site test equipment that can
properly perform the air monitoring tests.
3. Test equipment shall be calibrated in accordance with manufacturer's
requirements. Instrument calibrations shall be recorded on an Instrument
Calibration Log, an example of which is provided in the Attachment Section of this
procedure.
4. All available means must be utilized to evaluate the confined space atmosphere
without entering the space (i.e., extension probes, remote sensors, or insertion of
the test equipment).
5. Multiple points of testing shall be taken along the path of entry. Entry into the
space is permitted to perform this requirement when other means have been
exhausted. Readings shall be taken to adequately define the conditions of path of
entry.
If the confined space area is sufficiently large, the space shall be adequately tested
(i.e., in a multi-point grid fashion) to provide the most accurate conditions present.

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Policy No:EHS-513 Confined Space Entry

If Entry is required to perform testing, appropriate and sufficient personal

protective equipment (PPE) must be used to provide the top level of safety
(i.e., self-contained breathing apparatus or airline respirators). In addition, an
Attendant must be present.

6. There may be no hazardous atmosphere within the space whenever any

employee is inside the space. Therefore, if a hazardous atmosphere is known or
expected to exist (i.e., toxic contaminants thought to exceed the PEL), entry is not
permitted.
7. When testing for atmospheric hazards, test first for oxygen, then for combustible
gases and vapors, then for toxic gases and vapors.
8. Entry into a Permit-Required Confined Space is allowed under the following
conditions:
• Oxygen count is within the 19.5% to 23.5% level (between oxygen deficient
and oxygen rich environments; and
• LEL is less than 10%; and
• Level of any substance found in Subpart Z of 29 CFR 1910.1000, Table Z-1,
Limits for Air Contaminants, is less than the PEL (under OSHA) or other limits
established by any regulation.
Entry MAY be permitted if the conditions above are exceeded ONLY IN AN
EMERGENCY SITUATION AND BY ENTRANTS OR ATTENDANTS WHO ARE
PROPERLY TRAINED. Proper personal protective equipment (i.e., respirators,
self-contained breathing apparatus, etc.) must be used to ensure safety.

9. If the LEL is above 10%, ventilate the space until the LEL is less than 10%. If
this condition is not possible, no one may enter the space unless it is an
emergency situation and there are no ignition sources.
10. If, as a result of testing, it is determined that oxygen deficient or oxygen rich
environments and/or dangerous air contamination does not exist, entry into the
space may proceed. Re-testing must be done if the space has been vacant for
more than four (4) hours or at the change of a shift to ensure that oxygen
deficiency and/or dangerous air contamination has not developed.
11. Oxygen-consuming equipment such as cutting torches must not be used
unless provisions are made to ensure adequate combustion air and exhaust gas
venting. Also, any activity which can result in a change in atmospheric conditions
should be monitored AT LEAST hourly. Continuous monitoring is the preferred
method of monitoring.
12. Welding is permitted in Confined Spaces, however, the compressed gas tanks
or gas cylinders are NOT allowed inside the Space (they must be located outside

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Policy No:EHS-513 Confined Space Entry

the Confined Space). Local exhaust ventilation shall be used to remove welding
fumes.
13. Continuous forced air ventilation shall be used as follows:
• The forced air ventilation shall be so directed as to ventilate the immediate
areas where a hazardous atmosphere is confirmed or suspected and an
employee is or will be present within the confined space and shall continue
until all employees have left the space;
• The air supply for the forced air ventilation must be from a clean source; and
• An employee may enter the space after air monitoring has confirmed that
forced air ventilation has eliminated any hazardous atmosphere;

14. The atmosphere within the Space shall be periodically tested as necessary to
ensure that the continuous forced air ventilation is preventing the accumulation of a
hazardous atmosphere.
15. If a hazardous atmosphere is detected during entry:

• Each employee shall immediately leave the confined space;

• The confined space shall be evaluated to determine how the hazardous
atmosphere developed; and
• Measures will be taken to correct the cause of the recurrence of the
hazardous environment before re-entry takes place.
5 Contractor Requirements For Confined Space Entry
Contractors of S&W Energy must adhere to the S&W Energy Confined Space Entry
procedure to perform work in confined spaces. Prior to commencement of any work
involving confined space entry, the Contractor shall review the S&W Energy Confined
Space Entry Procedure to ensure they understand and are able to comply with all of its
requirements.
Contractors shall be made aware of all the Confined Spaces on-site (Inventory Form)
and why they are classified as such (i.e., hazards associated with each).
Contractors shall be made aware of any special procedures or precautions associated
with confined spaces or areas around confined spaces where the Contractor may be
working.
Contractors must use the Facility or Site Confined Space Entry Permit, as provided in
this procedure. The contractor may have designated Entry Supervisor to sign the
Permit for entry approval, HOWEVER, this must be reviewed, signed, and approved by
Facility or Site Entry Supervisor before entry of Contractors are allowed. If a Contractor
wishes to use their own company permit, they must first discuss the matter with the
Facility or Site Manager. If the Permit is deemed equal, then an exception may be
made.

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Policy No:EHS-513 Confined Space Entry

If the Contractor cannot provide his/her own rescue services, the Contractor must notify
the Facility or Site prior to arriving on-site so that the Facility can assist in coordinating
or locating rescue services.
The Contractor Supervisor shall designate a qualified and trained Entry Supervisor and
Attendant(s) to oversee entry activities into the confined space.
The Contractor must perform air monitoring of the confined space to ensure a safe
environment is established prior to entry into the space (Some Facilities or Sites may
not allow Contractors to test but instead have Facility or Site employee perform this
task, observed by and communicated to Contractor). It is recommended that Facility
personnel re-test the atmosphere in the space to confirm the air monitoring results
obtained by the Contractor.
The Entry or Shift Supervisor or designee shall accompany the Contractor Supervisor to
the space entrance to post the completed Confined Space Entry Permit.
The Entry or Shift Supervisor must authorize entry into the confined space in order for
the Contractor’s work to begin.
6 Rescue Services
Rescue services must be coordinated ahead of time and may be provided by on-site
employees or an off-site service for any site that has Permit-Required Confined Spaces.
The emergency number must be clearly identified on the permit and posted throughout
the Facility.
Each member of the rescue service shall be trained to perform the assigned rescue
duties.
Outside rescue services must be made aware of the hazards of the confined spaces,
must have access to comparable permit spaces or afforded the opportunity to practice
at the Facility where they will be doing the rescue in order to develop rescue plans and
practice rescues. At this time the Facility can evaluate a prospective rescuer’s ability to
perform the rescues at that Facility.
If local outside rescue services are not available, on-site teams must be properly
equipped and receive the same training as Authorized Entrants, plus training in the use
of personal protective and rescue equipment and first aid, including CPR. They must
practice simulated rescues at least annually.
To facilitate non-entry rescue, retrieval systems or methods shall be sued whenever an
authorized entrant enters a permit space unless the retrieval equipment would increase
the overall risk of entry or would not contribute to the rescue of the entrant. Retrieval
systems shall meet the following requirements:

• A full chest or body harness and life-line attached with a D-ring in the center of
the back or above the head, or other retrieval means including manual or
mechanical retrieval-assisted equipment must always be used unless it creates a
greater hazard or would not be feasible for retrieval.

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Policy No:EHS-513 Confined Space Entry

• The other end of retrieval line shall be attached to a mechanical device or fixed
point outside the permit space in such a manner that rescue can begin as soon
as the rescuer becomes aware that rescue is necessary.
Hospital or treatment facilities must be provided with any MSDS or other information in
a Permit-Required Confined Space hazard exposure situation that may aid in the
treatment of rescued employees.
7 Training
Training shall be provided so that all employees whose work is regulated by this
Procedure acquire the understanding, knowledge, and skills necessary for the safe
performance of their duties assigned.
A. All employees who are involved in confined space entry operations will be trained in
all aspects of this procedure, as well as for specific Facility procedures and
programs, such as Lockout/Tagout, Respiratory Protection, Personal Protective
Equipment (PPE), and the proper use and calibration of required monitoring devices
for Permit-Required Confined Spaces as they pertain to Confined Space Entry.
B. Authorized Entrants and Attendants shall be trained on:
C. The hazards that may be faced during entry, including information on the mode,
signs or symptoms and consequences of exposure; and
D. Proper use of monitoring equipment for testing atmospheric conditions, including
calibration procedures; and
E. Communication with Attendant, to recognize signals or commands to avoid
dangerous situations and evacuate when necessary; and
F. Rescue services and techniques.
G. Training shall occur initially upon hire and refresher training will be conducted every
two years or more frequently if program changes have occurred.
H. If the Facility has an on-site rescue team, they will be trained initially and then
annually thereafter, as well as perform annual drills.
I. Training records shall be maintained, including the employee names and dates of
training. They should be made readily available, upon request.
8 Auditing / Inspections
The Confined Space Entry Procedure shall be reviewed annually, including review of
active and closed permits, canceled permits, equipment calibration logs, etc. The
procedure will be updated as necessary.
9 References
29 CFR 1910.146 Confined Space Entry
29 CFR 1910.1000, Subpart Z Limits For Air Contaminants
10 Forms
See Appendix R

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Policy No:EHS-513 Confined Space Entry

R.1 - Example Confined Space Entry Permit (2 Pages)

R.2 - Pre-Entry Checklist
R.3 - Confined Space Inventory Form

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 Environmental Health and Safety
Manual
Policy No. EHS-514 Policy Title: Walking and Working Surfaces
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 Definitions ................................................................................................................ 2
3 General Requirements ............................................................................................. 3
4 Protection for Floor Openings .................................................................................. 3
5 Protection for Wall Openings and Holes .................................................................. 4
6 Protection for Open-Sided Floors, Platforms, and Runways .................................... 4
7 Fixed Industrial Stairs............................................................................................... 5
8 Other Working Surfaces........................................................................................... 5
9 Training .................................................................................................................... 5
10 Auditing / Inspections ........................................................................................... 6
11 References ........................................................................................................... 6

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Policy No:EHS-514 Walking and Working Surfaces

1 Purpose and Scope

This procedure provides the requirements and guidelines to ensure compliance with
work performed on various platforms (i.e., stairs, elevated platforms other than ladders
and scaffolding, etc.) and more general standards and requirements for walking and
working surfaces located throughout the workplace or job site. Safety requirements for
wall and floor openings, open holes (such as manholes or confined space entryways),
and work areas around stairs, windows, open-sided floors, etc., are included in this
procedure. The Walking and Working Surfaces procedure is provided to protect
employees from injury during work and to achieve 100% compliance regulations. This
procedure should be used in conjunction with S&W Energy’s Ladders and Scaffolding
and Fall Protection procedures.
This procedure provides the basic requirements of protection in or on the specified
walking and working surfaces. It does not include design and construction criteria of
those safety devices mentioned. Refer to regulatory standards for these specifications.
In addition, requirements for other working platforms such as aerial lifts and manlifts are
not included as part of the scope of this procedure. The general requirements will apply
to these working platforms (also reference the S&W Energy’s Ladders and Scaffolding
and Fall Protection Procedures for more general requirements). However, these
working platforms are not as common at the Facilities or Sites as the other walking and
working surfaces outlined in this procedure. Therefore, they will be addressed on as as-
needed basis, per regulatory standards.
2 Definitions
• Floor Opening – An opening in any floor, platform, pavement, or yard measuring 12
inches or more in its least dimension through which persons may fall. Some
examples may include a hatchway, stair or ladder opening, pit or large manhole.
• Handrail – A single bar or pipe supported on brackets from a wall or partition to
furnish persons with a handhold in case of tripping.
• Mid-Rail – A rail approximately midway between the guardrail and platform used
when required, and secured to the uprights erected along the exposed sides and
ends of the platforms.
• Nosing – The portion of a tread projecting beyond the face of the riser immediately
below.
• Platform – A working space for persons that is elevated above the surrounding floor
or ground.
• Riser – The upright member of a step situated at the back of a lower tread and near
the leading edge of the next higher tread.
• Runway – A passageway for persons elevated above the surrounding floor or
ground level, such as a footwalk along shafting or a walkway between buildings.
• Standard Railing – A vertical barrier erected along exposed edges of a floor
opening, wall opening, ramp, platform or runway to prevent falls of persons.
• Toeboard – A vertical barrier at floor level erected along the exposed edges of a
floor opening, wall opening, platform, runway or ramp to prevent falls of materials.

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Policy No:EHS-514 Walking and Working Surfaces

• Tread – The horizontal member of a step.

• Wall Opening – An opening, at least 30 inches high and 18 inches wide in any wall
or partition, through which persons may fall.
3 General Requirements
A. All work areas, passageways, storerooms and service rooms must be kept in a
clean, orderly and sanitary condition.
B. All floors must be maintained in a clean and dry condition to the best possible extent.
Where wet processes are used, utilize drainage, platforms, mats and other means to
provide a safe working surface.
C. Every floor, working place and passageway must be kept free from protruding nails,
splinters, and holes, loose boards or obstructions that could create a hazard.
D. Where mechanical handling equipment is used, sufficient safe clearances must be
provided for aisles, loading docks, doorways and turns. Permanent aisles and
passageways must be identified.
E. Open pits, tanks, ditches, etc., must be provided with covers and/or guardrails to
protect employees from the hazard(s) presented.
F. Approved floor openings must be conspicuously posted, and the load placed in that
area may not exceed the rated capacity.
4 Protection for Floor Openings
A standard railing shall guard every stairway floor opening. The railing shall be
provided on all exposed sides, except at the entrance to the stairway.
Every ladderway floor opening or platform shall be guarded by a standard railing with
standard toeboard on all exposed sides, except the entrance to the opening. The
passage through railing shall be provided with a swinging gate or so offset that a person
cannot walk directly into the opening.
Every hatchway and chute floor opening shall be guarded by either:
• A hinged floor opening cover of standard strength and construction equipped with
standard railings or permanently attached thereto so as to leave only one
exposed side; or
• A removable railing with toeboard on not more than two sides of the opening and
fixed standard railings with toeboards on all other exposed sides.
A floor opening cover of standard strength and construction shall guard every pit and
trapdoor floor opening.
Every manhole floor opening shall be guarded by a standard manhole cover, which
need not be hinged in place.
Every temporary floor opening shall have standard railings, or shall be constantly
attended by someone.
Every floor hole into which persons can accidentally walk shall be guarded by either:

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Policy No:EHS-514 Walking and Working Surfaces

• A standard railing with standard toeboard on all exposed sides; or

• A floor hole cover of standard strength and construction.

Every floor hole into which persons cannot accidentally walk (on account of fixed
machinery, equipment or walls) shall be protected by a cover that leaves no openings
more than 1 inch wide.
Where doors or gates open directly on a stairway, a platform shall be provided and the
swing of the door shall not reduce the effective width to less than 20 inches.
5 Protection for Wall Openings and Holes
Every wall opening from which there is a drop of more than 4 feet shall be guarded by
either:

• Rail, roller, picket fence, half-door, or equivalent barrier. Where there is

exposure below to falling materials, a removable toeboard or the equivalent
shall also be provided; or
• An extension platform onto which materials can be hoisted for handling, and
which shall have side rails or equivalent guards and standard specifications.

Every chute wall opening from which there is a drop of more than 4 feet shall be
guarded by a rail, roller, picket fence, half-door, or equivalent barrier, or any
combination thereof.
Every window wall opening at a stairway landing, floor, platform, or balcony from which
there is a drop of more than 4 feet, and where the bottom of the opening is less than 3
feet above the platform or landing shall be guarded by standard slats, standard grill
work, or a standard railing.
Every temporary wall opening shall have adequate guards, but need not be of standard
construction.
6 Protection for Open-Sided Floors, Platforms, and
Runways
Every open-sided floor or platform 4 feet or more above adjacent floor or ground level
shall be guarded by a standard railing, or equivalent, on all open sides except where
there is an entrance to a ramp, stairway, or fixed ladder. The railing shall be provided
with a toeboard wherever persons can pass, wherever there is moving machinery, or
wherever there is equipment with which falling materials could create a hazard.
Every runway shall be guarded by a standard railing, or equivalent, on all open sides 4
feet or more above adjacent floor or ground level. If tools or materials are to be used on
the runway, a toeboard is required on each exposed side to prevent them falling to a
lower level.

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Policy No:EHS-514 Walking and Working Surfaces

Regardless of height, open-sided floors, walkways, platforms, or runways above or

adjacent to dangerous equipment shall be guarded with a standard railing and toeboard.
7 Fixed Industrial Stairs
Fixed stairs must be provided where:

• Operations necessitate regular intervals between levels;

• Access to elevations is daily or at each shift for purposes of inspection or
regular maintenance;
• Work at various levels may result in exposure to acids, caustics, or other
harmful substances;
• Work at different levels involves the carrying of tools or equipment by hand
Stair treads must be slip resistant and the nosings must be of non-slip finish.
8 Other Working Surfaces
Portable and powered dockboards shall be strong enough to carry the load imposed on
them.
Portable dockboards shall be secured in position, with devices that will prevent their
slipping.
Powered dockboards shall be designed in accordance with Commercial Standards.
Handholds, or other effective means, shall be provided on portable dockboards to
permit safe handling.

If the proper protection cannot be provided for the walking and working
surfaces and areas outlined in this procedure (i.e., guardrails and toeboards
around open holes, etc.), then fall protection is required when working in these
areas. Reference S&W Energy’s Fall Protection procedure to ensure that the
situation meets all criteria of a fall hazard and the proper fall protection is used
in each situation.

9 Training
All S&W Energy Facility or Site employees (including Field personnel) who will be
working in areas or on platforms as outlined in this procedure shall be trained on the
requirements and guidelines of this procedure initially, upon hire. Refresher training is
required every 2 years.

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Policy No:EHS-514 Walking and Working Surfaces

10 Auditing / Inspections
The Walking and Working Surfaces procedure shall be reviewed every 2 years. This
procedure will be updated as necessary.

11 References
29 CFR 1910.22 Walking & Working Surfaces, General Requirements
29 CFR 1910.23 Guarding Floor and Wall Openings and Holes
29 CFR 1910.24 Fixed Industrial Stairs
29 CFR 1910.30 Other Working Surfaces

Page 6
 Environmental Health and Safety
Manual
Policy No. EHS-515 Policy Title: Ladders and Scaffolding
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 Definitions ................................................................................................................ 2
3 General Requirements for Ladders .......................................................................... 3
4 Proper Selection, Safe Set-Up, and Safe Use of Ladders........................................ 4
5 Proper Care and Storage ......................................................................................... 5
6 Specific Ladder Types – Additional Requirements................................................... 6
7 Scaffolding ............................................................................................................... 7
8 Training .................................................................................................................. 10
9 Auditing / Inspections ............................................................................................. 10
10 References ......................................................................................................... 10

Page 1
Policy No:EHS-515 Ladders and Scaffolding

1 Purpose and Scope

This procedure defines the guidelines and requirements for the general use and storage
of ladders used on-site and the general use and safety standards of scaffolding used
on-site. In addition, the procedure outlines general precautions and requirements, what
to look for during inspections, and requirements specific to various types of ladders and
scaffolds.
This procedure DOES NOT include the requirements for constructing or manufacturing
ladders and scaffolds. It provides some information on the design criteria and
guidelines for erection of scaffolding but primarily focuses on safe use and precautions.
Reference ladder and scaffold manufacturer guidelines for detailed information on
design and construction. All ladders and scaffolds must be verified that they have been
constructed to the appropriate standards and are in compliance w/ safety standards
before they are used.
2 Definitions
• Cage – A guard, which is an enclosure that is fastened to the side rails of the
fixed ladder or to the structure to encircle the climbing space of the ladder for the
safety of the person who must climb the ladder.
• Cleats - Ladder crosspieces of rectangular cross-section placed on the edge on
which a person may step in ascend or descend.
• Coupler – A device for locking together the components of a tubular metal
scaffold.
• Extension Ladder – A non-self-supporting portable ladder, adjustable in length.
It consists of two or more sections traveling in guides or brackets so arranged as
to permit length adjustment.
• Manually Propelled Mobile Scaffold – A portable-rolling scaffold supported by
casters.
• Platform – A working space for persons elevated above the surrounding floor or
ground.
• Rungs – Ladder crosspieces of circular or oval cross-section on which a person
may step in ascending or descending a ladder.
• Runner – The lengthwise horizontal bracing or bearing members or both.
• Runway – A passageway for persons elevated above the surrounding floor or
ground level, such as a footwalk along shafting or a walkway between buildings.
• Scaffold – Any temporary elevated platform and its supporting structure used for
supporting workmen or materials or both.

• Light Duty Scaffold – A scaffold designed and constructed to carry a working

load not to exceed 25 pounds per square foot.
• Medium Duty Scaffold – A scaffold designed and constructed to carry a
working load not to exceed 50 pounds per square foot.
• Heavy Duty Scaffold – A scaffold designed and constructed to carry a working
load not to exceed 75 pounds per square foot.

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Policy No:EHS-515 Ladders and Scaffolding

• Sectional Ladder – A non-self-supporting portable ladder, non-adjustable in

length, consisting of two or more sections so constructed that the sections may
function as a single ladder.
• Standard Railing – A vertical barrier erected along exposed edges of a floor
opening, ramp, platform, or runway to prevent falls of persons.
• Toeboard – A vertical barrier at floor level erected along exposed edges of a
floor opening, wall opening, platform edge runway, or ramp to prevent falls of
materials.
• Tube and Coupler Scaffold – An assembly consisting of tubing which serves
as posts, bearers, braces, ties, and runners, a base supporting the posts, and
special couplers which serve to connect the uprights and to join the various
members.
• Tubular Welded Frame Scaffold – A sectional, panel or frame metal scaffold
substantially built up of prefabricated welded sections which consist of posts
and horizontal bearer with intermediate members. Panels or frames shall be
braced with diagonal or cross braces.
3 General Requirements for Ladders
Before a ladder is used it shall be inspected to ensure safety. Check for the following:

• Steps and side rails are free of oil, grease, paint, water, or other foreign material
that may make ascending or descending the ladder dangerous (slippery);
• Steps are firmly anchored to the side rails;
• Rungs, rails, braces, uprights, or side rails loose or damaged;
• Loose or missing hinges, screws, nails, nuts, or bolts;
• Defects in any of the hardware connections;
• Sharp corners or rough edges that could cut or scratch; or
• Decayed or split steps, braces, or rails (on a wooden ladder);
• If a ladder was dropped, recheck it thoroughly before using it. If a ladder is
damaged or defective, remove it from service.
Never use a defective ladder. Tag or label it so that it may be repaired, replaced, or
destroyed.
Do not leave ladders unattended unless properly secured.
Wood ladders should never be painted. Never use a wood ladder that has been
painted. The paint can conceal defects in the ladder.
The bottom section of section ladders shall be equipped with safety shoes. The feet
and rungs shall be slip-resistant.
Employees shall not work on ladders (outside) during storms or high winds.

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Policy No:EHS-515 Ladders and Scaffolding

If a ladder is damaged or defective, remove it from service immediately. Either

replace the ladder or repair it, according to manufacturer’s recommendations,
before returning the ladder back into service.

4 Proper Selection, Safe Set-Up, and Safe Use of Ladders

A. Selection
Different jobs require different ladders: stepladders, straight ladders, extension
ladders, sectional ladders, etc. To select the proper ladder, consider the following:
• Is the ladder strong enough to support the employee as well as any
equipment that is required?
• Is the ladder long enough so the employee can work safely, without standing
on the top rung or stretching beyond a safe distance?
• Can the ladder be properly positioned so that the employee will not have to
reach outward more than arms length?
• Can the ladder be secured in place and properly tied off?
• Will the ladder pose a safety hazard for the work that needs to be done?
Metal or aluminum ladders, or ladders with metal side rails, shall not be used near
electrical equipment or lines. Only wood, fiberglass, or other non-conducting
ladders shall be used in these situations.
B. Set-Up
Ladders shall not be placed in a horizontal position and used as a runway or a
scaffold unless designed for this purpose.
Place portable ladders so that both side rails have secure footing. Provide solid
footing on soft ground to prevent the ladder from sinking.
Never lean a ladder against unsafe backing or set up behind a door that opens
toward the ladder without locking or otherwise securing the door from opening.
Always tie ladders to solid structures, if tie-off is possible. The top section should
always be securely tied off to something substantial.
Employee shall not set up ladders near overhead obstructions and/or energized
lines.
If a ladder needs to be set up in area where there is high traffic, a barrier shall be
erected or set-up to keep people from walking or working too close and possibly
bumping or moving the ladder while someone is on it.
Keep the area around the base of the ladder free from clutter.
Ladders shall not be placed on boxes, barrels, or other unstable bases to achieve
more height.

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Policy No:EHS-515 Ladders and Scaffolding

The base or foot of the ladder should be placed one-fourth the ladder length from
the vertical plane of the top support.
When ladders are used to climb from one level to another, the top of the ladder
must extend 3 feet above the higher level.
C. Use (Carrying and Climbing)
A ladder shall be carried horizontally, rather than vertically.
Employees should never carry a ladder by themselves (unless it can be carried
easily). If it is too long or too heavy, seek assistance.
Only one employee shall work from a ladder at one time. If work requires two
employees, a second ladder shall be used.
Employees shall face the ladder when ascending and descending and shall use
both hands.
If tools or other objects must be transported up or down elevated work platforms,
use a rope tool belt, or pouch.
Never slide down a ladder.
Be sure that employees are wearing footwear that is not slippery (i.e., free from oil
or grease) before climbing.
A full body harness with lanyard is required when working more than 4 feet above
ground level without standard railings or other fall protection. (Reference Fall
Protection Procedure for detailed requirements on fall protection).
Employees shall not tie their safety harness off to a ladder unless the ladder is
permanently secured.
Do not reach further than arms length from the ladder. Move the ladder as work
progresses. RULE OF THUMB: Keep belt buckle inside rails.
An employee should not be climbing a ladder if ill or on prescription drugs.
If an employee gets dizzy or panics while on a ladder, the following steps are
recommended:

• Drape your arms over a rung:

• Rest your head against another rung or a side rail; and/or
• Do not continue climbing, wait until the feeling passes

5 Proper Care and Storage

Do not leave a ladder in position for an extended period of time. If the job is done,
return the ladder to storage so it is out of the way.

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Policy No:EHS-515 Ladders and Scaffolding

Designate ladder storage areas at the Facility or Site. Make sure all employees are
aware of these locations so that a ladder can be obtained for use at anytime or in case
of an emergency.
Do not leave ladders next to stairways, creating possible tripping hazards.
Ladders should be stored in a dry place.
In storage, rest the ladder on support racks so it hangs straight and level. If unable to
store in an upright position, place the ladder on the edge and lean against a wall, and
not on plant equipment.
6 Specific Ladder Types – Additional Requirements
In addition to the requirements in previous sections, outlining general precaution and
requirements of ladders, proper selection, use and storage, the following safety
guidelines and requirements must be adhered to for the specific type of ladder
identified. Remember all other requirements for ladders still apply.
A. Fixed Ladders
Check to ensure there are no loose or missing cleats before climbing a fixed
ladder.
If the ladder is 20 feet or longer, it must be equipped with a cage. Ladder cages
must extend 42 inches above the top of the next landing. Verify, before use, that
there are no parts of the cage that are damaged or corroded.
Cages begin 7 to 8 feet from the base of the ladder.
Anchoring shall be checked to make sure it is solid (not loose or broken).
Verify that the fixed rungs on the walls have not been damaged or the surface
around the rungs missing any material that could compromise the anchoring.
B. Straight Ladders and Extension Ladders
Employees shall not climb higher than the third rung from the top on straight or
extension ladders.
Straight ladders shall be equipped with safety shoes.
Straight and extension ladders shall be equipped with non-slip or slip resistant feet.
The minimum width between side rails of a straight ladder and any section of an
extension ladder shall be 12 inches.
The length of single ladders or individual sections of ladders shall not exceed 30
feet. Two section ladders shall not exceed 48 feet in length and over two section
ladders shall not exceed 60 feet in length.
Visually inspect extension ladders to ensure that the ropes or lines are not worn,
loose, or broken. Also check to see locks are operable and in good condition.

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Policy No:EHS-515 Ladders and Scaffolding

C. Step Ladders
Be sure the stepladder is fully open and locked before starting to climb. The
locking device shall be of sufficient size and strength so as to securely hold the
front and back sections in open positions.
Employees shall not work from the top step of a stepladder. This does NOT apply
to safety platform ladders.
Step ladders longer than 20 feet shall not be used on-site.
If an employee is working on a step ladder 10 feet or more above the ground or the
floor, the ladder shall be held by at least one other person.
Stepladders shall not be used as straight ladders.
Never climb on the back supports of a stepladder.
Never stand on the tray of stepladder.
Don’t climb higher than the second rung from the top on a stepladder.

SUMMARY FOR LADDERS:

1. Select the right ladder for the job to be done.
2. Only ladders that are in good condition, company approved and meet
regulatory specifications shall be used.
3. Inspect the ladder from top to bottom prior to use to make sure it is safe
and secure.
4. Place the ladder on a firm, solid surface and level it.
5. Position the ladder at the proper angle.
6. Stay inside the side rails as you work.
7. Return the ladders to proper storage upon completion of job tasks.

7 Scaffolding
A. General Requirements
All scaffolds must be built or erected according to regulatory (i.e., OSHA)
standards.
Employees shall not work on scaffolds during storms or high winds.
Any scaffold damaged or weakened from any cause shall immediately be repaired
and shall not be used until repairs have been completed.
All scaffold platforms and walkways shall be designed, constructed, and
maintained to support 4 times the maximum weight they are expected to support
during use.

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Policy No:EHS-515 Ladders and Scaffolding

• All hardware used to construct scaffolds (nuts, bolts, nails, etc.) shall be of
adequate size and sufficient numbers to develop the strength needed.
• The poles, legs, uprights of scaffolds shall be plumb and securely and rigidly
braced to prevent swaying and displacement.

All scaffold platforms and walkways shall have top railings, mid railings, and
toeboards in conformance with regulatory standards.
The footing or anchorage for scaffolds shall be sound, rigid, and capable of
carrying the maximum intended load without settling or displacement. Unstable
objects such as barrels, boxes, loose brick or concrete blocks may not be used to
support scaffolds or planks.
All work platforms and walkways shall be fully planked at all times work is in
progress. All planking or platforms shall be overlapped (a minimum of 12 inches)
or secured from movement.
Scaffolds shall not be altered or moved horizontally while they are in use or
occupied. When mobile scaffolding is being relocated, the source of power shall be
disconnected.
Overhead protection shall be provided and must be worn for employees working on
scaffolds whenever work is being carried on above them.
A scaffold over a walkway, aisle, or work area shall have the sides screened (one
half inch mesh or equivalent) from toeboard to the top of the rail, extending along
the entire opening, where an employee is required to work or pass under the
scaffold.
An access ladder or equivalent safe access shall be provided. The first rung of the
scaffold access ladder shall be no greater than 12 inches above the floor / ground
level and shall extend at least three rungs above the scaffold platform when
overhead space permits.
Use a swing gate when possible to access the scaffold platform.
Scaffold assemblies and platform work surfaces shall be visually inspected daily
before use by the user for obvious structural deficiencies. Scaffolds shall be free of
ice, snow, oil, grease, or other slippery materials before being used.
Scaffolds shall not be erected or placed within close proximity (20 feet) of power
lines without approval from the Facility or Site Manager.
When erecting a scaffold greater than 6 feet in height, employees shall wear a
safety harness with a safety line or lanyard attached to the scaffolding or nearest
structure capable of supporting their body weight and impact load.
Scaffolds, which are more than one section high, MUST be tied off.
Scaffold shall be secured to permanent structures through use of anchor bolts,
reveal bolts, or equivalent means.

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Policy No:EHS-515 Ladders and Scaffolding

Avoid overcrowding scaffolds. Overloading can weaken the structure or cause

scaffolds to become top-heavy.
When hoisting material onto a scaffold, use a tag-line.
Never lay hand tools or excess material on the edge of scaffolds or beams where
they may fall.
Hard hats must be worn when workers on or below scaffolds are exposed to
overhead hazards.
B. Tubular and Coupler-Type Scaffolding
Tubular metal scaffolds and coupler type scaffolds shall be erected and used
according to manufacturer’s recommendations.

• Proper seating and locking of all connections shall be rigidly observed, and
diagonal bracing or equivalent must be securely bolted or wired to upright
members.
• The support posts shall be spaced no more than 6 feet apart by 10 feet along
the length of the scaffold for light duty tube and coupler scaffolds, 6 feet by 8
feet for medium duty tube and coupler scaffolds, and 6 feet by 6 and a half
feet for heavy duty tube and coupler scaffolds.

Adequate base support shall be provided for uprights.

Cross bracing shall be installed across the width of the scaffold at least every third
set of posts horizontally, and every fourth runner vertically.
Tube and coupler scaffolds shall be constructed to support four times the maximum
intended loads.
Fixed scaffolds shall be secured to the building structure at 26 feet vertically and 30
feet horizontally.
Competent and experienced personnel who have had the appropriate training shall
erect all tube and coupler scaffolds.
All general requirements for scaffolds apply.
Manually-Propelled Scaffolds
Rolling-type metal scaffolds shall be used only on hard, smooth, level surfaces. Do
not ride a scaffold that is being moved.
Rolling scaffolds exceeding 5 feet in height shall have their wheels locked or
chocked when in use.
When freestanding rolling towers are used, their height shall not exceed four times
the minimum base dimension.
Two horizontal, diagonal braces shall be used on manually propelled scaffolds.

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Policy No:EHS-515 Ladders and Scaffolding

All general requirements for scaffolds apply.

8 Training
Each S&W Energy Facility or Site employees (including Field personnel) who will
be involved with conducting work using a ladder or scaffold, or may be responsible
for inspecting good safety practices involving ladder or scaffold use, shall be
trained on the requirements and guidelines of this procedure (initially). Refresher
training is required every 2 years.
As referenced in the Purpose and Scope, the guidelines and requirements included
in this procedure outline safety precautions and simple safety standards for the use
and inspection of scaffolds and ladders. In the case of scaffolds, additional, more
in-depth training is required, per regulations, if employees are responsible for
erecting scaffolding. It must be approved and a tag affixed indicating it was built to
standard to each approved scaffold once erected. Reference Federal, State, or
local regulations if this is the case at your Facility or Job Site.
9 Auditing / Inspections
Ladders and Scaffolds shall be inspected daily or prior to each use to ensure they
are free of defects and contain all the safety precautions necessary.
The Ladders and Scaffolding Procedure shall be reviewed every 2 years. This
procedure will be updated as necessary.
10 References
29 CFR 1910.25 Portable Wood Ladders
29 CFR 1910.26 Portable Metal Ladders
29 CFR 1910.27 Fixed Ladders
29 CFR 1910.28 Safety Requirements for Scaffolding
29 CFR 1910.29 Manually-Propelled Mobile Ladder Stands and Scaffolds

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 Environmental Health and Safety
Manual
Policy No. EHS-516 Policy Title: Bloodborne Pathogens
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 Definitions ................................................................................................................ 2
3 General Policy.......................................................................................................... 3
4 Post Exposure Precautions ...................................................................................... 5
5 Post Incident Actions................................................................................................ 6
6 Medical Evaluations and Medical Records............................................................... 6
7 Training .................................................................................................................... 8
8 Auditing / Inspections ............................................................................................... 9
9 References............................................................................................................... 9

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Policy No:EHS-516 Bloodborne Pathogens

1 Purpose and Scope

This procedure provides the policy requirements and guidelines to comply with the
Bloodborne Pathogens standard and the requirement to develop a written Exposure
Plan. The guidance and plan provides information that will help employers eliminate
and minimize employee exposure to bloodborne pathogens, including but not limited to
hepatitis B (HBV) and human immunodeficiency virus (HIV). It also includes procedures
that are to be followed in case there is an exposure incident.
This procedure and policy applies to all employees, at a minimum, for awareness
purposes.
2 Definitions
• Blood – Human blood or human blood components and products made from human
blood.
• Bloodborne Pathogens – Pathogenic microorganisms that are present in human
blood and can cause disease in humans.
• Contaminated – The presence or reasonable anticipated presence of blood or other
potentially infectious materials on an item or surface.
• Contaminated Laundry – Laundry which ahs been soiled with blood or other
potentially infectious materials or may contain sharps.
• Contaminated Sharps – Any contaminated object that can penetrate the skin
including, but not limited to, needles, scalpels, broken glass, etc.
• Decontamination – The use of physical or chemical means to remove, inactivate or
destroy bloodborne pathogens on the surface or item to the point where they are no
longer capable of transmitting infectious particles and the surface of the item is
rendered safe for handling, use or disposal.
• Engineering Controls – Controls such as sharp disposable containers, self-
sheathing needles, etc., which isolate or remove the bloodborne pathogen hazard
from the workplace.
• Exposure Incident – A specific eye, mouth, other mucous membrane, non-intact
skin, or parenteral contact with blood or other potentially infectious materials that
result from performance of employee’s duties.
• HBV – Hepatitis B virus.
• HIV – Human immunodeficiency virus.
• Licensed Health Care Professional – A person whose legally permitted scope of
practice allows him or her to independently perform the activities such as
vaccinations and post-exposure evaluations and follow-up.
• Occupational Exposure – Reasonable anticipated skin, eye, mucous membrane,
or parenteral contact with blood or other potentially infectious materials that may
result from the performance of an employee’s duties.
• Parenteral – Piercing mucous membranes or the skin barrier through such events
as punctures, bites, cuts or abrasions.
• Regulated Waste (Biohazardous Waste) – Liquid or semi-liquid blood or other
potentially infectious materials; contaminated items that would release blood or other

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Policy No:EHS-516 Bloodborne Pathogens

potentially infectious materials in a liquid or semi-liquid state if compressed; items

that are caked with dry blood or other potentially infectious materials and are
capable of releasing these materials during handling.
• Source Individual – Any individual, living or dead, whose blood or other potentially
infectious materials may be a source of occupational exposure to employees.
• Sterilize – The use of physical or chemical procedure to destroy all microbial life
including highly resistant bacteria.
• Universal Precautions – An approach to infection control, where all human blood
and certain human body fluids are treated as if known to be infectious for HIV, HBV,
and other bloodborne pathogens.
• Work Practice Controls – Controls that reduce the likelihood of exposure by
altering the manner in which a task is performed.

Each employer having employees with occupational exposure shall establish a

written Exposure Control Plan. This procedure and policy outlines the
requirements of an Exposure Plan. Implementation of this procedure meets all
of the elements of the Written Exposure Plan.

Because this industry does not typically encounter exposure of bloodborne

pathogens, the Exposure Control (Bloodborne Pathogens Plan) is primarily for
awareness. Exposure will most likely occur when assisting someone whom is
injured (clean up) or involved in an accident where infectious materials may be
used for first aid, etc. However, all employees shall be made aware of the
dangers or exposure and procedures to prevent exposure.

3 General Policy
A. Personal Protective Equipment
Each Facility or Site shall supply personal Protective Equipment (PPE). The PPE
required for bloodborne pathogen exposure controls include disposable latex
gloves, protective eyewear and/or facemask, protective CPR shield, and biohazard
clean up and disposal kit.

• Gloves shall be worn when it can be reasonably anticipated that the

employee may have hand contact with blood, other potentially infectious
materials, mucous membranes, and non-intact skin. Disposable gloves shall
not be washed or decontaminated for re-use

PPE will only be considered appropriate if it does not permit blood or other
infectious material to pass through it or to reach the employee’s work clothes,

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Policy No:EHS-516 Bloodborne Pathogens

street clothes, undergarments, skin, eyes, or mouth under normal conditions of use
and for the duration of time which the PPE will be used.
PPE must be stored in a separate unlocked cabinet or box, in an accessible area,
and made available to all employees.
The employees shall use the appropriate PPE whenever there is potential for
occupational exposure.
B. Engineering and Work Practice Controls
Engineering and work practice controls shall be used to eliminate or minimize
employee exposure. The controls should be used in combination with effective and
appropriate PPE.
Engineering and safe work practices should be examined and maintained or
replaced on a regular schedule (such as annually), as necessary, to ensure their
effectiveness.
Employees shall wash their hands with soap and water immediately, or as soon as
feasible, after the removal of gloves or other PPE. Employees shall wash their
hands following the contact of body areas that may be contaminated with blood or
other potentially infectious material.
Eating, drinking, smoking, applying cosmetics (i.e., lip balm) and handling contact
lenses is prohibited in the work area when there is potential for occupational
exposure.
Immediately, or soon as feasible after use, contaminated sharps (reusable) shall be
placed in appropriate containers. The containers shall be puncture resistant,
labeled and color-coded properly, and leak-proof.
C. Facility or Site Maintenance or Housekeeping
Facilities or Sites shall be maintained in a clean and sanitary condition.
All equipment and working surfaces shall be cleaned and decontaminated after
contact with blood or other potentially infectious materials.
Broken glass which may be contaminated with blood or other infectious material
shall not be picked up directly with the hands. It shall be cleaned up using
mechanical means only or with appropriate hand protection.
D. Vaccinations
Hepatitis B vaccine shall be made available, at no cost, to all employees. The
vaccination shall be offered within 10 working days of initial assignment to all
employees who have or potential to have occupational exposure.
Employees who decline the vaccination shall be required to sign a release. The
release shall be kept on file with the employee’s record. No employee shall work in
an area where there is occupational exposure or a major potential for exposure
unless he has had the Hepatitis vaccination.

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Policy No:EHS-516 Bloodborne Pathogens

Employees who initially decline the Hepatitis B vaccine may, at a later date, receive
the vaccine at no charge, provided they are still S&W Energy employees with the
potential for occupational exposure.
4 Post Exposure Precautions
All surfaces exposed to blood or other potentially infectious materials shall be
wiped clean and disinfected using water and bleach solution (recommended 10:1
ratio).
Biohazard clean up and disposal kits shall be used to clean items or equipment
and surfaces that were exposed to blood or other potentially infectious materials.
PPE or laundry that does not meet the Regulated Waste definition shall be
disposed of in the normal trash or laundry.

• Band-Aids, gauze pads, janitorial cleaning supplies, and toiletries shall not be
considered Regulated Waste if they do not meet the definition of Regulated
Waste and may be disposed of in the normal trash.

Regulated Waste shall be placed in containers which are:

• Closable;
• Constructed to contain all contents to prevent leakage of fluids during
handling, storage, or transport;
• Labeled or color coded in accordance with guidelines included in this
section; and
• Closed prior to removal to prevent spillage or protrusion of contents during
handling, storage, transport, or shipping.

If outside contamination of the regulated waste container occurs, it shall be placed

in a second container that meets all the criteria of the first container.
Contaminated laundry and PPE shall be handled as little as possible and shall be
bagged or containerized where they were used and without being sorted or rinsed.

• The employer shall ensure that employees who have contact with
contaminated laundry wear protective gloves and other appropriate PPE to
prevent exposure.

Warning labels shall be affixed to containers of regulated waste or other potentially

infectious materials. Labels shall be fluorescent orange or orange-red, with
lettering and symbols in a contrasting color. Each label shall have the
BIOHAZARD name and symbol (reference regulatory standard for symbol). Red
bags or red containers may be substituted for labels.

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Policy No:EHS-516 Bloodborne Pathogens

• Labels shall be affixed as close as feasible to the container by string, wire,

adhesive or other method that prevents their loss or unintentional removal.

• Regulated waste that has been decontaminated need not be labeled or color-
coded.
Biohazardous waste can be stored on site for no longer than 90 days and must be
removed by a Department of Health Services authorized medical waste hauler.

• Records of any medical waste transported off-site for treatment and disposal
shall include quantity of waste transported, the date transported and the
name of the registered waste hauler or individual hauling the waste. Records
shall be kept on-site for at least 2 years.
5 Post Incident Actions
The Facility Manager, or designee shall do a post-incident evaluation and follow-up
each time an employee experiences an exposure incident.
Then post incident evaluation is to identify and correct problems in order to prevent
reoccurrence of similar events and shall include the following:

• Engineering control in place at the time of the Incident;

•
• Safe work practices in place at the time of the Incident;
•
• PPE and clothing utilized at the time of the Incident; and
•
• Policy control failures.

The post incident evaluations shall be maintained on file at the Facility or Site for at
least 2 years.

6 Medical Evaluations and Medical Records

A. Evaluations
Following any report of an exposure incident, a confidential medical evaluation and
follow-up shall be conducted, including:

• Circumstances and routes of exposure;

• If the source individual is unknown or their consent for testing is denied, it
shall be documented and determined if and when possible collection and
testing of their blood may be accomplished to determine HBV and HIV
antibodies.

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Policy No:EHS-516 Bloodborne Pathogens

Collection and testing of an exposed employee’s blood for HBV and HIV status
shall be done as soon as possible after consent is obtained. If the employee
consents to baseline blood testing, but no HIV testing, the sample shall be
preserved for a minimum of 90 days during which time testing will be done at the
employee’s election.
The exposure evaluating physician (or licensed healthcare professional) shall have
access to the following information:

• A copy of the applicable OSHA regulations;

• A description of the exposed employee’s duties as related top, occupational
exposure;
• Routes of exposure; and
• Employee’s treatment record, including vaccination status.

The exposed employee shall receive a copy of the evaluating physician’s written
report within 15 working days of completion of the evaluation. The report shall
contain the following:

• Recommendations regarding the indications and receipt of Hepatitis B

vaccine;
• A statement that the employee has been informed of the results of the
evaluation as well as information regarding other medical conditions resulting
from the incident which may, in the future, require further evaluation and
treatment; and
• Any other findings or diagnoses shall remain confidential (Reference Medical
Records Access / Recordkeeping Procedure in S&W Energy’s EHS Manual).
B. Records
Accurate medical records shall be established and maintained for each employee
with occupational exposure(s).
Medical records shall contain the following information:

• Employee name and social security number;

• A copy of the employee Hepatitis B vaccine record, or a signed statement
declining the vaccination;
• A copy of the result of the examinations, testing and any follow-up
procedures;
• A copy of the health care professional’s written report; and
• A copy of the information provided to the evaluation health care professional.

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Policy No:EHS-516 Bloodborne Pathogens

Employee records shall be kept confidential. Information contained in employee

medical records shall not be disclosed to any person without the employee’s
written consent, except as provided by law. (Refer to Medical Records Access /
Recordkeeping Procedure in S&W Energy’s EHS Manual).
Employee medical records shall be maintained for the duration of employment plus
thirty years.
7 Training
All S&W Energy Facility or Site employees (including Field personnel) shall be
trained on the requirements and guidelines of the Bloodborne Pathogens policy,
program, and procedure initially, upon hire.
The training program shall contain at least the following elements:

• An accessible copy of the regulatory text of this standard and an explanation

of its contents (this procedure);
• A general overview of the symptoms of bloodborne pathogens;
• An explanation of the modes of transmission of bloodborne pathogens;
• An explanation of the appropriate methods for recognizing tasks and other
activities that may involve exposure to blood or other potentially infectious
materials;
• An explanation of the use and limitations and methods that will prevent or
reduce exposure including appropriate engineering controls, work practices,
and PPE;
• Information on the types, proper use, location, removal, handling,
decontamination and disposal of PPE;
• Information on the Hepatitis B vaccination;
• Information on the appropriate actions to take and persons to contact in an
emergency involving blood or other potentially infectious materials;
• An explanation of the procedure to follow if an exposure incident occurs;
• Information on the post-exposure evaluation and follow-up; and
• An explanation of the signs, labeling, and color-coding of regulated waste and
biohazardous waste.

Refresher training is given annually or additional training may be required when

changes or modifications to tasks include added potential for exposure.

Bloodborne Pathogens training can also be given as part of CPR / First Aid
training and is typically a topic covered as part of that training. If CPR and/or
First Aid training is given and bloodborne pathogens is part of this training, it
will satisfy the requirements of the procedure.

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Policy No:EHS-516 Bloodborne Pathogens

8 Auditing / Inspections
The Bloodborne Pathogens Policy and Procedure shall be reviewed every year
(annually). This procedure will be updated as necessary.
9 References
29 CFR 1910.1030 Bloodborne Pathogens

Page 9
 Environmental Health and Safety
Manual
Policy No. EHS-517 Policy Title: Compressed Gas Cylinders
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 Definitions ................................................................................................................ 2
3 General Precautions and Requirements .................................................................. 2
4 Handling of Compressed Gas Cylinders .................................................................. 3
5 Compressed Gas Cylinder Storage.......................................................................... 3
6 Compressed Gas Cylinder Connection and Use...................................................... 4
7 Specific Compressed Gas Requirements ................................................................ 4
8 Training .................................................................................................................... 5
9 Auditing / Inspections ............................................................................................... 6
10 References ........................................................................................................... 6

Page 1
Policy No:EHS-517 Compressed Gas Cylinders

1 Purpose and Scope

This procedure establishes the guidelines and requirements for handling, use and
storage of compressed gases (cylinders). This includes flammable, oxidizing, corrosive
and toxic gas cylinders, typically used at S&W Energy Facilities or Sites. The
requirements of this procedure meet the compliance requirements established by the
regulatory standards.
2 Definitions
• Corrosion (or Pitting) – The loss of wall thickness of a compressed gas cylinder by
corrosive media.
• Flammable Gases – Gases which when mixed with air in concentrations of 13% or
less (by volume) form a flammable mixture.
• Oxidizing Gases – Non-flammable gases, which in the presence of an ignition
source and a fuel can support and vigorously accelerate combustion. Common
oxidizing gases include oxygen and chlorine.
3 General Precautions and Requirements
Do not use compressed gas cylinders as rollers, supports or for any other purpose other
than to contain and use the content as received.
Do not place compressed gas cylinders where they can become part of an electrical
circuit. When used for welding, the cylinders shall not be grounded or used for
grounding.
Do not expose compressed gas cylinders to extreme temperatures.
Do not ship leaking or defective compressed gas cylinders. Contact the manufacturer
for instructions.
If the cylinders or valves on the cylinder are noticeably corroded, notify the gas
manufacturer and follow their instructions.
Keep valve protection and valve outlet caps on the cylinders at all times except when
containers are secured and connected to dispensing equipment.
No employee shall modify, tamper with, obstruct, remove or repair any part of the
compressed gas cylinder, including pressure relief devices, or valve protection devices.
Do not direct compressed gas streams toward any person.
Dispose of non-refillable cylinders according to manufacturer’s recommendations.
Compressed gas cylinders shall not be taken into tanks, unventilated rooms, or other
confined spaces (this does not apply to gas cylinders associated with self-contained
breathing apparatus, SCBAs).
The contents of the compressed gas cylinder shall be properly labeled on the cylinder
and the labels shall be kept in legible condition. If the label cannot be read and the
employee is unsure of the contents, the compressed gas shall not be used until the
contents have been verified.

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Policy No:EHS-517 Compressed Gas Cylinders

Prior to each use, a visual inspection of the compressed gas cylinders shall be
performed to determine that they are in good condition. Visual inspection includes
checks for dents, bulges, cuts, gouges, digs, corrosion, pitting, signs of exposure to fire,
or weld defects.

• Cylinders that are questionable should be returned to the manufacturer of the

same type (or equivalent re-qualification agency) for re-inspection.
4 Handling of Compressed Gas Cylinders
Cylinders must not be rolled in the horizontal position or dragged in any manner.
Always handle or consider the compressed gas cylinders as being full.
Use an appropriate hand truck or similar handling device to move the cylinders. Make
sure the cylinders are properly secured prior to moving them.
Use caution to guard against cylinders violently striking against each other or other
surfaces.
Never lift a compressed gas cylinder by its cylinder cap.
Only properly trained persons shall handle compressed gases.
5 Compressed Gas Cylinder Storage
A sign must be posted showing the hazard class or the name of the gases to be stored
in each container storage area.
“NO SMOKING” signs must be posted in the vicinity of the compressed gas storage
area where appropriate.
Cylinders should be grouped together according to hazard class, and separate storage
should be provided for full and empty cylinders.
Cylinders shall not be stored near readily ignitable substances.
Cylinders should not be exposed to corrosive chemicals or fumes.
Cylinders shall not be stored near unprotected platform edges or in locations where
heavy moving objects may strike or fall on them. They should be stored in such a
manner as to not obstruct exit routes or means of egress.
Cylinders shall be stored in locations that are free from long exposures to damp
environments (to prevent corrosion on the bottom of the cylinder). If stored on paved
surfaces, the surface should be graded to prevent accumulation of water.
Do not store cylinders in the sun as this may cause extreme temperature elevations and
temperature swings.
Cylinders shall be stored upright and secured to prevent falling (both full and empty
cylinders). They shall be stored valve-end up.

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Policy No:EHS-517 Compressed Gas Cylinders

6 Compressed Gas Cylinder Connection and Use

The container valve shall be kept closed at all times except when the container is in
use. Valve outlets shall be pointed away from all personnel when the valve is being
opened.
On valves without hand wheels, the wrench provided or recommended by the gas
manufacturer must be used when opening or closing the valve. Hammers or other tools
shall not be sued in attempting to open or close the valve.
Open the cylinder valve slowly when using the compressed gas.
Where compressed gas cylinders are connected to a manifold, the manifold and its
related equipment, such as regulators, must be of proper design (appropriate
temperatures, pressures, and flows) for the product they are to contain.
When compressed gas cylinders are connected to a process where there is potential for
back flow of process materials that may contaminate the cylinder, a check valve or other
suitable device shall be used to prevent back flow into the regulator.
Piping, regulators and other equipment shall be kept gas tight to prevent leakage (use
an approved leak test solution or instrument). NEVER tighten connections or leaking
fittings or attempt repairs while the system is under pressure.
Prior to removing a regulator from a cylinder, the cylinder valve shall be closed and the
regulator relieved of gas pressure.
Equipment including regulators, hoses, gauges, etc., provided for use with a particular
compressed gas shall not be used on gas cylinders containing a gas of different
chemical properties unless information is obtained from the manufacturer that it can be
done safely.
7 Specific Compressed Gas Requirements
In addition to the specific requirements for compressed gases described in this section,
all general requirements also apply.
A. Flammable Gases

Do not sue flammable gases near open flames, sources of heat, adjacent to
oxidizers and non-explosion proof electric systems, or near ungrounded electrical
equipment.
Post NO SMOKING signs around flammable gas storage areas and ensure
portable fire extinguishers are available for fire emergencies.
A flame shall not be used for detection of flammable gas leaks. Use either a
flammable gas leak detector or a compatible gas leak detection solution.
Spark proof tools shall be used when working with or on flammable compressed
gas cylinders or systems.

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Policy No:EHS-517 Compressed Gas Cylinders

Flammable gas cylinder storage areas shall be well ventilated. The storage area
must be kept free of combustible materials. Heating of these areas shall be by
steam, hot water or other indirect means. Direct heating by flame is PROHIBITED.
Flammable gas cylinders must be kept at least 20 feet from flammable liquids,
highly combustible materials and oxidizers.
Do not store flammable gas cylinders near arcing equipment, open flame or other
sources of ignition.
Flammable compressed gas systems, piping, tubing, fittings, gaskets, etc. must be
suitable for the applicable compressed flammable gas service and for the
pressures and temperatures involved.
All lines and equipment associated with flammable gas systems should be
grounded.

B. Oxidizers
Any material used in contact with oxidizing agents must be suitable for this type of
service.
Valves, piping, fittings, regulators, and other equipment used in oxygen service
shall be of a material and pressure rating compatible with oxygen.
Equipment used for oxygen must be cleaned with oxygen compatible materials free
from oils, greases, and other contaminants.
Oxidizers shall be stored separately from flammable gas containers and
combustible materials. A minimum distance of 20 feet or a non-combustible barrier
having a fire resistance rating of at least 30 minutes is considered a minimum
requirement.

C. Corrosive and Toxic Gases

Areas where corrosive gases are utilized must be equipped with emergency
showers and eyewash fountains.
Toxic and corrosive gases must be stored outdoors in a separate non-combustible
building without other occupancy or in a separate room without other occupancy.
The room shall be constructed of non-combustible materials with a fire resistance
rating of at least 1 hour.
Storage areas must be adequately ventilated to prevent hazardous concentrations.
8 Training
Each S&W Energy Facility or Site employee (including Field personnel) who will be
involved with handling, using, or storing compressed gases and compressed gas
cylinders, shall be trained on the requirements and guidelines of this procedure.
Refresher training is required every 3 years.

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Policy No:EHS-517 Compressed Gas Cylinders

9 Auditing / Inspections
The Compressed Gas Cylinder Procedure shall be reviewed every 3 years. This
procedure will be updated as necessary.
10 References
29 CFR 1910.101 Compressed Gases – General Requirements
29 CFR 1910.252 Welding, Cutting, Brazing
29 CFR 1910.253 Oxygen-Fuel Gas Welding and Cutting

Page 6
 Environmental Health and Safety
Manual
Policy No. EHS-518 Policy Title: Hot Work
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 Definitions ................................................................................................................ 2
3 Procedure ................................................................................................................ 2
4 Special Precautions ................................................................................................. 4
5 Completion of Hot Work ........................................................................................... 5
6 Training .................................................................................................................... 5
7 Auditing / Inspections ............................................................................................... 5
8 References............................................................................................................... 5

Page 1
Policy No:EHS-518 Hot Work

1 Purpose and Scope

This procedure provides the requirements and guidelines to ensure appropriate fire
prevention precautions are taken before Hot Work is performed. It also provides a
method to issue and authorize Hot Work Permits.
2 Definitions
• Combustible Material – A material capable of igniting and burning; a material with a
flash point at or above 100 degrees F (38 degrees C).
• Fire Watch – A designated individual, trained in the use of fire extinguishers and
familiar with Facility or Site fire alarm sounds, signals, and fire procedures, required
during welding, cutting, burning (or other Hot Work) operations. A Fire Watch shall
be maintained for at least one half hour (30 minutes) after completion of Hot Work to
detect and extinguish possible smoldering fires.
• Flammable Material – A material easily ignited and capable of burning with high
rapidity; a material with a flash point below 100 degrees F (38 degrees C).
• Flash Point – Lowest temperature at which a liquid or solid gives off a vapor in such
a concentration that when the vapor combines with air near the surface of the liquid
or solid, a flammable mixture is formed. The lower the flash point, the more
flammable the product.
• Hot Work – Any work that can cause sufficient heat to ignite nearby combustible or
flammable material. This pertains primarily to the use of welding and burning
equipment, but can include heat-treating, riveting, cutting, open fires, portable
grinders, non-explosion-proof equipment or any other flames or spark-producing
equipment.
• Hot Work Permit – A Permit required and issued prior to any Hot Work being
performed, verifying that all fire hazards have been eliminated or controlled providing
a safe area for the Hot Work operation. Permit indicates location of fire safety
alarms and contacts in case of emergency (fire), location of Hot Work operation,
valid length of Permit and the Fire Watch present. The Permit requires authorizing
employee signature (i.e., Supervisor issuing Permit or designee) and Fire Watch.

If all identified fire hazards cannot be removed from the area where Hot Work
will be performed or moved to a safe vicinity and guards cannot be
constructed to confine the heat, sparks, slag, etc., generated during these
operations, no Hot Work shall be performed.

3 Procedure
A Hot Work Permit is required prior to conducting any Hot Work operations. The permit
shall document all fire protection and prevention requirements. The Permit shall
include, at a minimum: the date(s) authorized for Hot Work, the object on which Hot

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Policy No:EHS-518 Hot Work

Work is to be performed, operator performing work, name of the Fire Watch, information
on emergency (fire) contacts and equipment, and signature of authorization. A sample
Hot Work Permit is included as part of this Procedure in the Attachment Section.
If a Contractor is to perform Hot Work, the Facility or Site must advise and instruct the
Contractor of all combustible, flammable, or hazardous conditions that may be present.
A Contractor may complete the Hot Work Permit; however, authorization is required
from the Facility or Site (i.e., S&W Energy) Supervisor, or designee.
• Prior to Hot Work, the area where Hot Work is to be performed shall be
inspected by a Shift Supervisor (responsible individual), or designee. All
precautions shall be taken to ensure safety during operation (refer to the
Special Precautions in next Section).
• A combustible gas test may be performed by the Shift Supervisor before issuing
a Hot Work Permit where flammable gases may be present.
• The Supervisor, or designee, in charge of the work shall check to see that no
other work in the area, such as line breaking or normal production procedures,
can cause an unexpected release of flammable materials. Where equipment
has contained flammable liquids, blinding, cleaning, venting, and disconnection,
as necessary, is required to ensure that no flammable liquids enter the heated
work area.
• The Supervisor shall designate a Fire Watch for the operation. During
operation, the Fire Watch shall watch for fires in all exposed areas and try to
extinguish them only when obviously within capacity of equipment available or
sound the alarm.
• The Supervisor shall ensure proper fire extinguishing equipment or other means
of emergency / fire fighting is readily available.
• The Supervisor, or designee, shall complete the Hot Work Permit. Upon
completion and verification of all safety hazards and information on the Permit,
the Supervisor, or designee, shall have the designated Fire Watch sign the
Permit upon their approval). The Supervisor shall then sign the Permit,
authorizing the work to commence.
• The Permit shall be posted in area of Hot Work or made readily available for
anyone to review at any time during period of work.
• If the permitted activity carries over onto another shift, another permit shall be
issued with the same degree of inspection and control as the preceding shift.
The permit shall remain on the job until it is completed.

NOTE: Hot Work shall not be permitted in the following situations:

• In areas not authorized by Management; or
• In buildings with sprinkling systems while such protection is impaired; or
• In the presence of explosive atmospheres (mixtures of flammable gases,
vapors, etc.) or explosive atmospheres that may develop in cleaned areas
where these atmospheres existed in the past; or

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Policy No:EHS-518 Hot Work

• In areas near the storage of large quantities of exposed, ignitable

materials.

4 Special Precautions
The following special precautions shall be adhered to whenever and wherever
applicable. They shall be checked and verified as part of the Hot Work Permit approval
process, prior to commencement of Hot Work.
Wherever there are floor openings (cracks in the flooring), cracks or holes in the
walls, open doorways, or broken windows, precautions shall be taken so that no
readily combustible material will be exposed to sparks that may go through those
openings.
Precautions should be taken to ensure that molten metal and slag do not fall to
floors below, where welding or cutting is performed overhead and hot material may
fall to the ground. The area below should be barricaded or roped off to prevent
people from walking underneath.
Suitable fire extinguishing equipment shall be maintained (and ready) for
immediate use in case of emergency. Fire extinguishing equipment may
consist of pails of water, buckets of sand, hose, or portable extinguisher.
Fire Watchers are required whenever Hot Work is performed in locations
where fires might develop or any of the following conditions exist:

• If there exists combustible material, in building construction or contents, closer

than 35 feet (10.7 meters) to the point of operation;
• If there exists combustible material more than 35 feet (10.7 meters) away but
are easily ignited by sparks;
• Wall of floor openings within 35 foot (10.7 meter) radius expose combustible
material in adjacent areas; or
• Combustible materials are adjacent to the opposite side of partition, wall,
ceiling, etc., and are likely to be ignited by conduction or radiation.

Floors containing combustible material shall be swept clean within a radius of 35

feet (10.7 meters). If the floor itself is made of a combustible material, it shall be
kept wet, covered with sand, or protected by fire-resistant shields. (If floors have
been wet, personnel arc welding, a type of Hot Work, shall be protected from
possible shock.
Where practical, all combustibles shall be relocated at least 35 feet (10.7 meters)
from the Hot Work operation. If not practical to move, combustibles shall be
protected with flameproof covers or otherwise shielded to prevent fire.
Where Hot Work is performed near walls, partitions, ceiling, or roof of combustible
construction, fire-resistant shields shall be provided to prevent ignition. If
performed near non-combustible walls, precautions shall be taken to prevent

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Policy No:EHS-518 Hot Work

ignition of combustibles on the other side, due to conduction or radiation,

preferable by relocating the combustibles.

5 Completion of Hot Work

Work area and all adjacent areas where sparks might have spread shall be inspected
by the Fire Watch for at least 30 minutes after the work is completed and no more fire
conditions are noted.
Hot Work Permits shall be kept on file for one year.
6 Training
All S&W Energy Facility or Site employees (including Field personnel) who will be
involved with Hot Work operations or working in areas where Hot Work may be
performed shall be trained on the requirements and guidelines of this procedure initially,
upon hire. Refresher training is required every 2 years. (Typically training is given as
part of Welding, Cutting, and Brazing training course).
7 Auditing / Inspections
The Hot Work Procedure shall be reviewed every 2 years. Documented Hot Work
Permits may be reviewed as part of this inspection or audit. This procedure will be
updated as necessary.
8 References
29 CFR 1910.119 Process Safety Management / Hot Work
29 CFR 1910.252 (Subpart Q) Welding, Cutting, Brazing / Fire Protection and
Prevention
NFPA Standard 51B

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 Environmental Health and Safety
Manual
Policy No. EHS-519 Policy Title: Radiation
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Scope....................................................................................................................... 2
2 IONIZED (X-RAY) RADIATION................................................................................ 2
3 NON-IONIZED (LASERS) RADIATION ................................................................... 2

Page 1
Policy No:EHS-519 Radiation

1 Scope
This section provides a broad guidance pertaining to working with or around radiation.
Safety is paramount when working with any form of radiation. This section in no way
overrides or supercedes any regulatory standards and compliance with those standards
will be maintained at all times.
2 IONIZED (X-RAY) RADIATION

• Any activity that involves the use of radioactive materials, whether or not under
license from the Nuclear Regulator Commission (NRC), shall be performed by
competent persons specially trained in the proper and safe operation of such
equipment.
• When materials are used under NRC license, only persons actually licensed, or
competent persons under the direct supervision of the licensee, shall perform
such work.
• Technicians shall sufficiently barricade and post standard radiation signs around
areas to be tested so that employees cannot be exposed.
• Technicians shall not leave a radioactive source unattended even though it may
be locked in its housing and the area barricaded.
• Any deviation from this policy must be proposed in writing and receive joint
approval of both the Safety Supervisor and the Construction Manager, or the
Manager of Safety, whichever is applicable.
• Any paperwork necessitated by loss, contamination, etc., as required by the
NRC, shall be the sole responsibility of the Safety Supervisor or the using
Subcontractor with copies to the Construction Manager and the Manager, Safety.

3 NON-IONIZED (LASERS) RADIATION

• Only qualified and trained employees shall be assigned to install, adjust, and
operate laser equipment.
• Proof of qualification of the laser equipment operator shall be available and in
possession of the operator at all times.
• Employees, when working in areas in which a potential exposure to direct or
reflected laser light greater than 0.005 watts (5 milliwatts) exists, shall be
provided with anti-laser eye protection devices.
• Areas in which lasers are used shall be posted with standard laser warning
placards.
• Beam shutters or caps shall be utilized, or the laser turned off, when laser
transmission is not actually required. When the laser is left unattended for a
substantial period of time, such as during lunch hour, overnight, or at change of
shifts, the laser shall be turned off.
• Only mechanical or electronic means shall be used as a detector for guiding the
internal alignment of the laser.

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Policy No:EHS-519 Radiation

• The laser beam shall not be directed at employees.

• When it is raining or snowing, or when there is dust or fog in the air, the operation
of laser systems shall be prohibited where practical. Employees shall be kept out
of range of the area of source during such weather conditions.
• Laser equipment shall bear a label to indicate maximum output.
• Employees shall not be exposed to light intensities above:

A. Direct Staring: 1 microwatt per square centimeter

B. Incidental Observing: 1 milliwatt per square centimeter
C. Diffused Reflected Light: 2-1/2 watts per square centimeter
• Laser units in operation should be set up above the heads of employees when
possible.
• Employees shall not be exposed to microwave power densities in excess of 10
milliwatts per square centimeter.

Page 3
 Environmental Health and Safety
Manual
Policy No. EHS-520 Policy Title: Machine Guarding
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 Types of Guarding.................................................................................................... 2
3 General Requirements for Machine Guards............................................................. 2
4 References............................................................................................................... 3

Page 1
Policy No:EHS-520 Machine Guarding

1 Purpose and Scope

Employee exposure to unguarded or inadequately guarded machines is prevalent in
many workplaces. Consequently, workers who operate and maintain machinery suffer
approximately 18,000 amputations, lacerations, crushing injuries, abrasions, and over
800 deaths per year. Amputation is one of the most severe and crippling types of
injuries in the occupational workplace, and often results in permanent disability. This
section focuses on recognizing and controlling common amputation hazards associated
with the operation and use of certain types of machines.
Moving machine parts have the potential for causing severe workplace injuries, such as
crushed fingers or hands, amputations, burns, blindness, just to name a few.
Safeguards are essential for protecting workers from these needless and preventable
injuries. Any machine part, function, or process which may cause injury must be
safeguarded. When the operation of a machine or accidental contact with it can injure
the operator or others in the vicinity, the hazards must be either eliminated or controlled.

2 Types of Guarding
One or more methods of machine guarding shall be provided to protect the operator and
other employees in the machine area from hazards such as those created by point of
operation, ingoing nip points, rotating parts, flying chips and sparks.
Examples of guarding methods are:
• Barrier guards
• Two-hand tripping devices
• Electronic safety devices
3 General Requirements for Machine Guards
Guards shall be affixed to the machine where possible and secured elsewhere if for any
reason attachment to the machine is not possible. The guard shall be such that it does
not offer an accident hazard in itself.
Point of operation is the area on a machine where work is actually performed upon the
material being processed.
The point of operation of machines whose operation exposes an employee to injury
shall be guarded. The guarding device shall be in conformity with any appropriate
standards or, in the absence of applicable specific standards, shall be so designed and
constructed as to prevent the operator from having any part of his body in the danger
zone during the operating cycle.
Special hand tools for placing and removing material shall be such as to permit easy
handling of material without the operator placing a hand in the danger zone. Such tools
shall not be in lieu of other guarding required by this section, but can only be used to
supplement protection provided.

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Policy No:EHS-520 Machine Guarding

The following are some of the machines which usually require point of operation
guarding:
• Guillotine cutters.
• Shears.
• Alligator shears.
• Power presses.
• Milling machines.
• Power saws.
• Jointers.
• Portable power tools.
• Forming rolls
• Calendars

A. Barrels, containers, and drums

Revolving drums, barrels, and containers shall be guarded by an enclosure which is
interlocked with the drive mechanism, so that the barrel, drum, or container cannot
revolve unless the guard enclosure is in place.

B. Exposure of blades
When the periphery of the blades of a fan is less than seven (7) feet above the floor or
working level, the blades shall be guarded. The guard shall have openings no larger
than one-half (1/2) inch.

C. Anchoring fixed machinery

Machines designed for a fixed location shall be securely anchored to prevent walking or
moving.
4 References
29 CFR 1910.212 Machine Guarding

Page 3
 Environmental Health and Safety
Manual
Policy No. EHS-521 Policy Title: Tools
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 General Requirements ............................................................................................. 2

Page 1
Policy No:EHS-521 Tools

1 Purpose and Scope

The proper use of all tools is vitally important in the personal safety of all employees.
The following section provides general guidelines for the use of a variety of tools. This
should not be considered an all-inclusive policy and prudent judgment must be used at
all times while operating any tool or equipment.
2 General Requirements

• Tools shall be used only for the purpose for which they are designed.
• All tools, regardless of ownership, shall be of an approved type, maintained in
first class condition, and be subject to inspection at any time. Tools with sharp
edges shall be stored and handled so that they will not cause damage or injury.
• Tools such as chisels, punches, drills, and hammers that become cracked or
mushroomed shall be dressed, repaired, or replaced before further use.
• Tools, except those normally carried on belts, that must be raised or lowered
from one elevation to another shall be placed in an approved container or firmly
attached to hand lines.
• Tools shall not be thrown from place to place or from person to person under any
circumstances.
• Tools shall not be left lying around where they could cause tripping or stumbling.
• Tools shall never be placed unsecured on elevated places. When working on or
above open grating or boards, care should be taken not to place tools on this
walkway lest they be knocked off, causing injury to people below.
• All hand-held power tools must be equipped with a constant pressure switch that
will shut off the power when the pressure is released.
• Switches or valves on any type of power tools, especially air tools, shall not be
wired or tied in the open position. Any tool which is damaged or defective shall
not be used. This includes wrenches with sprung or damaged jaws and chisels,
drills, or punches with flared or damaged heads. Pipes shall not be used to
extend a wrench handle for added leverage unless the wrench was designed for
such use.

A. HAND TOOLS
• Files, rasps, and other hand tools that have a sharp tang shall not be used
without approved handles.
• Wood handles that are loose, cracked, or splintered shall be replaced. Taping or
lashing them with wire will not be permitted.
• Only tools designed with striking faces shall be hit with a hammer. Files and
screwdrivers should never be hit.
• The use of adjustable jawed wrenches should be avoided. Use of the proper
sized wrench is recommended.
• Pipe wrenches shall never be used on bolts or nuts.
• Striking two hammers together shall be avoided.

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Policy No:EHS-521 Tools

B. POWDER ACTUATED TOOLS (Stud Guns)

• Only low velocity powder actuated guns or captive stud drives will be permitted
for use.
• Only employees who possess valid operator cards issued for the make and
model of tool to be used are permitted to use powder actuated tools. The
manufacturer's representative will conduct training classes at the job site upon
request.
• Powder charges and fasteners shall be stocked in sufficient quantities to
prevent the use of improper fasteners or charges.
• Powder actuated tools shall not be overloaded.
• The tool shall be tested each day before loading to see that safety devices are
in proper working condition. The method of testing shall be in accordance with
the manufacturer's recommended procedure.
• Any tool found not in proper working order, or that develops a defect during use,
shall be immediately removed from service, tagged, and not used until properly
repaired.
• Personal protective equipment shall be used in accordance with Policy 125.
• Tools shall not be loaded until just prior to the intended firing time. Neither
loaded nor empty tools are to be pointed at any employee. Hands shall be kept
clear of the open barrel end.
• Loaded tools shall not be left unattended.
• Fasteners shall not be driven into very hard or brittle materials, including, but
not limited to, cast iron, glazed tile, surface-hardened steel, glass block, live
rock, face brick, or hollow tile.
• Driving into materials easily penetrated shall be avoided unless such materials
are backed by a substance that will prevent the pin or fastener from passing
completely through and creating a flying missile hazard on the other side.
• No fastener shall be driven into a spalled area caused by unsatisfactory
fastening.
• Tools shall not be used in an explosive or flammable atmosphere.
• All tools shall be used with the correct shield, guard, or attachment
recommended by the manufacturer.

C. ELECTRIC TOOLS

• Portable electric tools (except those with self-contained power), such as electric
drills, saws, etc, shall have their frames grounded at all times when connected
to a source of power unless of the double insulated, UL-approved type.
• All electric cords and cables must be covered or elevated to protect them from
damage and from becoming tripping hazards.
• All electric tools used will be protected with a GFCI located as near the power
supply as possible.

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Policy No:EHS-521 Tools

• All circular saws shall have working guards in place at all times.
• All plugs shall be butt end type only. Plugs with metal bodies are prohibited.
• All electric tools and cord sets shall be inspected in accordance with OSHA
Rules and Regulations 29 CFR 1926.400 9(h) (3) and Policy 121.

D. PNEUMATIC TOOLS

• Employees shall not engage in horseplay with compressed air hoses. Practical
jokes can cause serious injury and are strictly forbidden.
• Line pressure shall be maintained as low as possible to effectively accomplish
the job at hand.
• An approved safety check valve or anti-surge valve must be installed at the
manifold outlet of each supply line 1/2 inch in diameter or greater for hand-held
pneumatic tools.

Page 4
 Environmental Health and Safety
Manual
Policy No. EHS-522 Policy Title: Cranes and Rigging
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 Definitions ................................................................................................................ 2
3 General Requirements - Cranes .............................................................................. 3
4 Requirements for Moving the Load (Crane) ............................................................. 5
5 Crane Inspections .................................................................................................... 6
6 Crane Testing........................................................................................................... 7
7 Crane Maintenance.................................................................................................. 7
8 General Requirements - Slings ................................................................................ 7
9 Training .................................................................................................................. 11
10 Auditing / Inspections ......................................................................................... 11
11 References ......................................................................................................... 11

Page 1
Policy No:EHS-522 Cranes and Rigging

1 Purpose and Scope

This procedure provides guidance to maintain compliance with the regulatory standards
for the safe design, operation, and maintenance of cranes and other lifting devices
typically found at S&W Energy work sites.
2 Definitions
• ANSI – American National Standards Institute
• Appointed – Assigned specific responsibilities by the employer or the employer’s
representative.
• Bridge – Part of the crane consisting of girders, trucks, and ties, footwalks and drive
mechanism which carries the trolley or trolley(s).
• Boom – A member hinged to the front of the rotating superstructure with the outer
end supported by ropes leading to a gantry or A-frame and used for supporting the
hoisting tackle.
• Cab – The operator’s compartment of the crane.
• Cab-Operated Crane – A crane controlled by an operator in a cab located on the
bridge or trolley.
• Counterweight – A weight used to supplement the weight of the machine in
providing stability for lifting working loads.
• Designated – Selected or assigned by the employer or the employer’s
representative as being qualified to perform specific tasks or duties.
• Footwalk – The walkway with handrail, attached to the bridge or trolley for access
purposes.
• Frequent Inspection – Inspections of daily to monthly intervals.
• Gantry Crane – A crane similar to an overhead crane except that the bridge for
carrying the trolley or trolleys is rigidly supported on two or more legs running on
fixed rails or other runway.
• Hoist – An apparatus that may be part of the crane, exerting a force for lifting and
lowering.
• Load – The total superimposed weight on the load block or hook.
• Load Block – The assembly of hook or shackle, swivel, bearing, sheaves, pins, and
frame suspended by the hoisting rope.
• Outriggers – Extendable or fixed metal arms attached to the mounting base which
rests on the supports at the outer ends.
• Overhead Crane – A crane with a moveable bridge carrying a moveable or fixed
hoisting mechanism and traveling on an overhead fixed runway structure.
• Periodic Inspection – Inspections of 1 to 12 month intervals.
• Proof Load – The load applied in performance of a proof test.
• Proof Test – A nondestructive tension test performed by the sling or crane
manufacturer or an equivalent entity to verify construction and workmanship of the
sling and or crane.
• Qualified Person – A person with specific training, knowledge, and experience in
the area for which the person has responsibility and the authorization to control.

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Policy No:EHS-522 Cranes and Rigging

• Rated Load – The maximum load for which a crane or individual hoist is designed
and built by the manufacturer and shown on the equipment nameplate(s).
• Running Sheave – A sheave that rotates as the load block is raised or lowered.
• Sheave – A wheel or disk with a grooved rim, used as a pulley.
3 General Requirements - Cranes
A. Overhead and Gantry Cranes
All new overhead and gantry cranes constructed and installed must meet design
specifications of the American National Standard Safety Code for overhead and
gantry cranes, ANSI B30.2
The crane shall never be loaded beyond its rated load (except for test purposes).
Cranes may be modified and re-rated only if the changes and supporting structure
are reviewed and approved by qualified engineer(s) or the manufacturer. All other
testing and labeling requirements still apply.
Outdoor storage bridges shall be equipped with rail clamps and wind indicator.
The wind indicator shall be provided to give a visible or audible alarm to the bridge
operator at a predetermined wind velocity.
The rated load of the crane shall be plainly marked on each side of the crane; each
hoist shall have its rated load marked on it or on its load block and be clearly
legible from the ground floor. In addition, recommended operating speeds and
special hazard warnings shall be conspicuously posted on all equipment and
visible to the operator while he/she is at the control station.
Pendant control stations shall be kept clean and function labels kept legible.
A minimum clearance of 3 inches overhead and 2 inches laterally shall be provided
and maintained between crane and any obstructions.
The hoist chain or hoist rope associated with the crane shall be free of kinks or
twists and shall not be wrapped around the load.
The load shall be attached to the load block hook by means of slings or other
approved lifting devices.
An accessible fire extinguisher (rating of 5BC or higher) shall be available at all
operator stations or crane cabs.
Hand signals to crane operators shall be those prescribed by the applicable ANSI
standard for the type of crane in use. An illustration of the standard signals shall
be posted at the job-site or near the crane. See Attachment section of this
procedure for copy of posted hand signals
Only designated personnel shall be permitted to operate a crane. Crane
operator(s) shall have proper training and able to demonstrate qualifications of
such training to employer, or designee, prior to operation.

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Policy No:EHS-522 Cranes and Rigging

The Facility or Site Manager / Supervisor shall designate a competent or qualified

person, who shall inspect all machinery and equipment prior to each use, and
during use, to make sure it is in safe operating condition.
B. Crane Cabs
The cab and location of control and protective equipment shall be such that all
operating handles are within convenient reach of the operator when facing the
direction of travel of the cab.
The cab shall be located to afford a minimum of 3 inches clearance from all fixed
structures.
All windows in cabs shall be of safety glass, or equivalent, that introduces no
visible distortion that will interfere with the safe operation of the crane.
Access to the cab and/or bridge walkway shall be by a conveniently placed fixed
ladder, stairs, or platform requiring no step over any gap exceeding 12 inches.
Where necessary, a ladder shall be provided to give access to the cab roof.
C. Crane Footwalks and Ladders
If sufficient headroom is available on cab-operated cranes, a footwalk shall be
provided on the drive side along the entire length of the bridge of all cranes.
Where footwalks are located, there shall not be less than 48 inches of headroom
provided.
Gantry cranes shall be provided with ladders or stairways extending from the
ground to the footwalk or cab platform.
Walking surfaces shall be of anti-slip type.
Stairways must be equipped with rigid and substantial handrails.
Ladders shall be securely and permanently fastened in place.
D. Crane Hoisting Equipment
Sheaves:
• Sheave grooves shall be smooth and free from surface defects that may cause
rope damage.
• Sheaves carrying ropes that can be momentarily unloaded shall be equipped
with close-fitting guards to guide ropes back into groove when the load is
reapplied.
• Sheaves in the bottom block shall be equipped with close-fitting guards that will
prevent rope from becoming fouled when the block is lying on the ground with
ropes loose.
• All running sheaves shall be equipped with means of lubrication.

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Policy No:EHS-522 Cranes and Rigging

Ropes:
• The rated load divided by the number of parts of rope shall not exceed 20% of
the nominal breaking strength of the rope. Use manufacturer’s
recommendations when using hoisting ropes.
• Wherever rope is exposed to temperatures at which fiber cores would be
damaged, rope having an independent wire rope or wire-strand core or other
temperature-resistant core shall be used.
• Replacement rope shall be the same size, grade, and construction as original
rope furnished by crane manufacturer, unless otherwise recommended by
manufacturer based on use.
4 Requirements for Moving the Load (Crane)
The load shall be secured and properly balanced in the sling or lifting device before it is
lifted more than a few inches.
Before hoisting the load, the operator shall ensure that the hoist rope is not kinked and
that multiple part lines are not twisted around each other.
The hook shall be brought over the load so as to prevent swinging.
The operator shall take every precaution to make no sudden acceleration or
deceleration of the load and ensure the load does not contact any obstructions.
A person shall be designated to observe clearance of the equipment and give timely
warning for all operations where it is difficult for the operator to maintain desired
clearance by visual means.
Cranes shall NOT be used for side pulls EXCEPT when it has been determined by
qualified and responsible individual that the stability of the crane will not be affected and
that various parts of the crane will not become overstressed causing damage.
There shall be no hoisting, lowering, or traveling of the load with an employee ON the
load.
All employees shall be kept clear of loads about to be lifted and of suspended loads.
The operator shall avoid carrying loads over people.
The operator shall test the brakes each time a load approaching the rated load is
handled.
The load shall not be lowered below the point where less than two full wraps of rope
remain on the hoisting drum.
The operator shall not leave his/her position at the controls while the load is suspended.

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Policy No:EHS-522 Cranes and Rigging

5 Crane Inspections

INITIAL INSPECTION: Prior to initial use of all new or altered cranes, an initial
inspection shall be conducted which complies with provisions of this
procedure.

A. Daily (or prior to each use):

• Check all functional operating mechanisms of cranes and associated hoists for
maladjustment or excessive wear of components interfering with proper
operation (visual).
• Check for deterioration or leakage in lines, tanks, valves, drain pumps, and
other parts of air or hydraulic systems (visual).
• Check hooks for deformation or cracks (visual); Check hooks for any cracks
having more than 15% in excess of normal throat opening or more than 10
degrees twist from the plane of the unbent hook.
• Check hoist chains, including end connections, for excessive wear, twist,
distorted links interfering with proper function or stretch beyond manufacturer’s
recommendations (visual).
• Check for deformed, cracked, or corroded members.
• Check for loose bolts and/or rivets.
• Check for cracked and worn sheaves.
• Check for worn, cracked, or distorted parts such as pins, bearings, shafts,
gears, rollers, locking and clamping devices.
• Check for excessive wear on brake system parts, linings, pawls, and ratchets.
• Check load, wind, and other indicators over their full range for any significant
discrepancies.
• Check for excessive wear of chain drive sprockets and excessive chain stretch.
• Any noted deficiencies must be carefully examined, should be documented, and
determination made as to whether they constitute a safety hazard.

B. Monthly (documented / certification):

• Check all items listed under daily visual checks. Documented information
should include certification record which includes date of inspection, the person
performing the inspection, identifier indicating what piece of equipment was
inspected, and list of any deficiencies (if no deficiencies, indicate with “OK”).
• Check all ropes for deterioration (loss of strength), reduction of rope diameter,
signs of internal or external corrosion, signs of wear, any broken wires,
corroded or broken wires at end connections, severe kinking or unstranding.
• All deficiencies listed must be carefully examined and determination made as to
whether they constitute a safety hazard.

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Policy No:EHS-522 Cranes and Rigging

• Monthly inspection documents shall be kept on file for at least one year. A tag
should be affixed to the crane (or inspected equipment) noting last inspection
results and dated.
C. Annual:

• A thorough annual inspection of the hoisting machinery shall be made by a

competent or qualified person or by a government or private agency approved
to perform inspections. The employer shall maintain a record of the results and
dates of each inspection for the life of the equipment.

Any unsafe conditions disclosed by the inspections shall be corrected before

operation of the crane, hooks, hoists, ropes, etc. Adjustments and repairs
shall be done only by designated and qualified personnel.

6 Crane Testing
Prior to initial use, all new and altered cranes shall be tested to ensure compliance,
including test of the following functions: hoisting and lowering, trolley travel, bridge
travel, limit switches, and locking and safety devices. Test results shall be documented
and left on file for life of the crane and associated devices.
Rated Load Test: Test loads shall be more than 125% or the rated load unless
otherwise recommended by the manufacturer. All tests shall be documented and kept
on file for life of the crane.
7 Crane Maintenance
A preventative maintenance program based on manufacturer’s guidelines and
recommendations shall be established and followed.
Anytime maintenance is done on a crane that may affect the load carrying capabilities, a
re-certification and proof load test must be conducted.
8 General Requirements - Slings
This Section applies to slings used in conjunction with other material handling
equipment for the movement of material by hoisting. Various types of slings include
alloy steel chain, wire rope, metal mesh, natural or synthetic fiber rope, and synthetic
web (nylon, polyester, and polypropylene).

A. All Slings
• Slings that are damaged or defective shall not be used.
• Slings shall not be shortened with knots or bolts or other makeshift devices.
• Sling legs shall not be kinked.

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Policy No:EHS-522 Cranes and Rigging

• Slings shall not be loaded in excess of their rated capacities.

• Slings used in a basket hitch shall have loads balanced to prevent slippage.
• Slings shall be securely attached to their loads.
• Slings shall be padded or protected from sharp edges of their loads.
• Suspended loads shall be kept clear of all obstructions.
• All employees shall be kept clear of loads about to be lifted and suspended
loads.
• Hands or fingers shall not be placed between the sling and its load while the sling
is being tightened around the load.
• A sling shall not be pulled from under a load when the load is resting on the sling.
• A visual inspection of slings and all fastenings and attachments shall be
conducted daily (or before use) by a competent, qualified person designated by
the employer. Every month, a documented inspection should be conducted
which includes all the daily checks in addition to the sling-specific requirements
(as outlined in the following sections). Monthly inspection reports should be
signed, dated, and kept on file for life of equipment.
• All employees should familiarize themselves with the types of slings available for
easiest and safest lifting.
B. (Alloy Steel) Chain Slings
• Alloy steel chain slings shall have permanently affixed to it durable identification
stating size, grade, rated capacity, and reach.
• Before each use, each new, repaired, or reconditioned alloy steel chain sling
shall be proof tested by sling manufacturer or equivalent entity. Employer shall
retain certificate of the proof test.
• Alloy steel chain slings shall be inspected monthly. The monthly inspection
should include inspection on wear, check for defective welds, check for
deformation and increase in length. These inspections should be documented
and kept on record. Frequency of inspections may increase based on
determination from frequency of sling use, severity of service conditions, nature
of lifts being made, or based on experience on service life of slings.
• If defects or deterioration is present, the sling shall be immediately removed form
service.
• If alloy steel chain sling heated in excess of 1000 degrees F, it shall be
permanently removed from service.
• Slings shall be removed from service if hooks are cracked, have been opened
more than 15% of the normal throat opening measured at the narrowest point or
twisted more than 10 degrees from the plane of the unbent hook.
• All general requirements for slings apply.

C. Wire Rope Slings

• Fiber core wire rope slings shall be permanently removed from service if they are
exposed to temperatures in excess of 200 degrees F.
• Welding of end attachments shall be performed prior to assembly of the sling. All
welded attachments shall not be used unless proof tested at twice their rated

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Policy No:EHS-522 Cranes and Rigging

capacity by the manufacturer or equivalent entity. Employer shall retain certificate

of the proof test.
• Wire rope slings shall be immediately removed from service if any of the
following conditions are present:

• In running ropes, six (6) randomly distributed broken wires in one rope lay, or
three (3) broken wires in one strand in one rope lay; in standing ropes, more
than two (2) broken wires in one lay in sections beyond end connections or
more than one broken wire at an end connection;
• Wear or scraping of one-third the original diameter of outside individual wires;
• Kinking, crushing, bird caging or any other damage resulting in distortion of
the wire rope structure;
• Evidence of heat damage;
• End attachments that are cracked, deformed, or worn;
• Hooks that have been opened more than 15% of the normal throat opening
measured at the narrowest point or twisted more than 10 degrees from the
plane of the unbent hook; or
• Corrosion of the rope or end attachments.

• All general requirements for slings apply.

D. Metal Mesh Slings

• Each metal mesh sling shall have permanently affixed to it a durable
identification stating rated capacity for vertical basket hitch and choker hitch
loading.
• Handles shall have rated capacity at least equal to the metal fabric and exhibit no
deformation after proof testing.
• Coatings that diminish the rated capacity of the sling shall not be applied.
• All new and repaired metal mesh slings shall not be used unless proof tested by
the manufacturer or equivalent entity at a minimum of 1.5 times their rated
capacity.
• Metal mesh slings shall be immediately removed form service if any of the
following conditions are met:

• A broken weld or broken brazed joint along the sling edge;

• Reduction in wire diameter of 20% due to abrasion or 15% due to
corrosion;
• Lack of flexibility due to distortion of the fabric;
• Distortion of the female handle so that the depth of the slot is increased
more than 10%;
• Distortion of either handle so that the width of the eye is decreased more
than 10%;
• A 15% reduction of the original cross sectional area of metal at any point
around the handle eye; or

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Policy No:EHS-522 Cranes and Rigging

• Distortion of any handle out of its plane.

•
• All general requirements for slings apply.

E. Natural and Synthetic Fiber Rope Slings

• Fiber rope slings shall have a minimum clear length of rope between eye splices
equal to 10 times the rope diameter.
• Knots shall not be used in lieu of splices.
• Clamps not designed specifically for fiber ropes shall not be used for splicing.
• Fiber rope slings shall not be used if end attachments in contact with the rope
have sharp edges or projections.
• Only fiber rope slings made from new rope shall be used; use of repaired or
reconditioned fiber rope is prohibited.
• Natural and synthetic fiber rope slings shall be immediately removed from service
if any of the following conditions are present:

• Abnormal wear;
• Powdered fiber between strands;
• Broken or cut fibers;
• Variations in the size or roundness of strands;
• Discoloration or rotting; or
• Distortion of hardware in the sling.

• All general requirements for slings apply.

F. Synthetic Web Slings

• Each sling shall be marked or coded to show the rated capacities for each type of
hitch and type of synthetic web material.
• Synthetic webbing shall be of uniform thickness and width.
• Nylon web slings shall not be used where fumes, vapors, sprays, mists, or liquids
of acids or phenolics are used.
• Polyester and polypropylene web slings shall not be used where fumes, vapors,
sprays, mists or liquids of caustics are present.
• Synthetic web slings of nylon or polyester shall not be used at temperatures in
excess of 180 degrees F.
• Synthetic web slings, which have been repaired, shall not be used unless
repaired by sling manufacturer or an equivalent entity. Each repaired sling shall
be proof tested by the manufacturer or equivalent entity to twice the rated
capacity prior to return to service. The employer shall retain certificate of the
proof test.
• Synthetic web slings shall be immediately removed from service if any of the
following conditions are present:

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Policy No:EHS-522 Cranes and Rigging

• Acid or caustic burns;

• Melting or charring of any part of the sling service;
• Snags, punctures, tears, or cuts;
• Broken or worn stitches; or
• Distortion of fittings.

• All general requirements for slings apply.

9 Training
Employees assigned to operate and inspect cranes and rigging equipment shall be
trained on this procedure and its requirements initially, upon hire. Refresher training is
required every 2 years.
10 Auditing / Inspections
The Cranes and Rigging Procedure shall be reviewed every two years. The procedure
will be updated as necessary.
All test and inspection records shall be maintained for the life of the equipment (crane,
lifting equipment, etc.). They shall be made available upon request and readily
accessible. Test and inspection records may be reviewed during auditing and
inspections.

11 References
29 CFR 1910.179 Overhead and Gantry Cranes
29 CFR 1910.180 Crawler Locomotive and Truck Cranes
29 CFR 1910.184 Slings
29 CFR 1926.550 Cranes, Derricks, Hoists, Elevators, and Conveyors

Page 11
 Environmental Health and Safety
Manual
Policy No. EHS-523 Policy Title: Means of Egress
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 Definitions ................................................................................................................ 2
3 General Requirements ............................................................................................. 2
4 Housekeeping .......................................................................................................... 4
5 Training .................................................................................................................... 4
6 Auditing / Inspections ............................................................................................... 5
7 References............................................................................................................... 5

Page 1
Policy No:EHS-523 Means of Egress

1 Purpose and Scope

This procedure provides the fundamental requirements essential to providing a safe
means of egress from fire and like emergencies. The requirements of this procedure
establish then minimum requirements per regulatory standards.
Exits from vehicles, vessels, or other mobile structures are NOT covered by this
procedure.
The Means of Egress Procedure shall be closely tied to S&W Energy’s Emergency
Response Procedure (and documented Plan) and S&W Energy’s Fire Protection and
Prevention Procedure (and Plan).
2 Definitions
• Approved – For purposes of this procedure, equipment listed or approved by a
nationally recognized testing laboratory.
• Emergency Action Plan – A documented plan for any workplace describing the
procedures the employer and employees must take to ensure employee safety from
fire or any other emergency. Reference S&W Energy’s Emergency Response
Procedure for detailed information and a sample template of an Emergency Action
Plan.
• Emergency Escape Route – The route the employees are directed to follow in the
event they are required to evacuate the workplace or seek a designated refuge area.
• Exit Access – That portion of a means of egress, which leads to an entrance to an
exit.
• Exit Discharge – That portion of a means of egress between the termination of an
exit and a public way.
• High Hazard (Contents or Areas) – Classified as those contents or areas where
there are materials which are likely to burn with extreme rapidity or from which
poisonous or toxic fumes or explosions are to feared in case of a fire.
• Means of Egress – A continuous and unobstructed way of exit travel from any point
in a building or structure to a public way and consists of three separate and distinct
parts: the way of exit access, the exit, and the way of exit discharge.
3 General Requirements
Every building or structure (new or old) designed for human occupancy shall be
provided with exits sufficient to permit the prompt escape of occupants in case of a fire
or another emergency.
• The design of the exits and other safeguards shall be such that reliance for
safety to life in case of fire or other emergency will not solely depend on any
single safeguard.
• Exit access shall be so arranged that it will not be necessary to travel toward any
area of high hazard occupancy in order to reach the nearest exit, unless the path
of travel is effectively shielded from the high hazard location.

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Policy No:EHS-523 Means of Egress

• Free and unobstructed egress must be provided from all parts of the building at
all times when it is occupied.
• No lock or any fastening shall be installed to prevent free escape from any exit.
In no case shall access to an exit be through a bathroom or other room subject to
locking except where the exit is required to serve only the room subject to
locking.

Every exit shall be clearly visible or the route to reach it shall be conspicuously indicated
in such a manner that every occupant of every building or structure will readily know the
direction of escape from any point. Each path of escape in its entirety shall be so
arranged or marked that the way to a place of safety outside is unmistakable.
• Any door, passage, or stairway that is not an exit or does not lead to an exit, but
could be mistaken for an exit, must be identified with a sign reading “Not an
Exit” or by a sign indicating the actual use for the space.
• Exits and access to exits shall be marked by readily visible signs in all cases
where the exit or way to reach the exit is not immediately visible to the
building’s occupants. As sign reading “EXIT” with an arrow indicating the
direction of the nearest exit shall be placed in every location where this direction
is not immediately apparent.
• The minimum width of any way of exit access shall in no case be less than 28
inches.

When more than one exit is required from a story, at lest two of the exits shall be remote
from each other and so arranged as to minimize any possibility that both may be
blocked by any one fire or other emergency condition.
Means of egress shall be so designed and maintained as to provide adequate
headroom, but in no case shall the ceiling height be less than 7 feet and 6 inches not
any projection from the ceiling be less than 6 feet and 8 inches from the floor.
Where a means of egress is not substantially level, such differences in elevation shall
be negotiated by stairs or ramps.
No furnishings, decorations, or other objects shall be placed as to obstruct exits, access
thereto, egress there from or visibility thereof.
Adequate and reliable illumination must be provided for all exit facilities.
No building under construction shall be occupied until all exit facilities are completed
and ready for use.
No existing building under repair shall be occupied unless all existing exits and fire
protection are maintained continuously.
Every exit, way of approach to the exit and way of travel from the exit must be
maintained free of obstructions.
Every automatic sprinkler system, fire detection and alarm system, exit light, fire door
and other items of emergency equipment must be continuously maintained in proper

Page 3
Policy No:EHS-523 Means of Egress

operating condition. Periodic inspections and tests shall be made a necessary to

ensure proper maintenance. Refer to S&W Energy’s Fire Protection and
Prevention procedure for details on inspection of fire detection and protection
equipment.
Mirrors shall not be placed on exit doors or adjacent to any exit in such a manner as to
confuse the direction of the exit.
Where accumulations of snow or ice are likely, exterior exits shall be covered with a roof
or area continuously cleared to ensure free of any obstructions.
An Emergency Action Plan must be developed and maintained at the Facility or on-site
and available for employee review. Refer to S&W Energy’s Emergency Response
procedure for details on the elements of this Plan and the information provided.
A Fire Prevention Plan must be developed and maintained at the Facility or on-site and
available for employee review. Refer to S&W Energy’s Fire Protection and Prevention
procedure for details on the elements of this Plan and the information provided.
4 Housekeeping
General cleanliness and common sense around the workplace can prevent most
accidents as well as keep all areas clear for the appropriate means of egress. Some
general housekeeping guidelines are listed below:
• Keep air hoses, welding leads, and extension cords out of doorways and off the
floor to prevent tripping. Each employee (and visitor and contractor) is
responsible for keeping his/her immediate work area free of trash and tools not
in use.
• Clean up all spilled liquids immediately to prevent the possibility of someone
slipping and falling.
• Stack materials and supplies in a safe manner and keep them out of walkways.
• Never pile trash or other materials, especially storage rooms, in areas where
they would block exits or fire doors.
5 Training
All S&W Energy Facility or Site employees (including Field personnel) shall be trained
on the requirements and guidelines of this procedure. Training can be incorporated into
Facility or Site Emergency Action Plan and/or Fire Prevention Plan training, including
the drills associated with each of those training requirements.
Refresher training ON THIS PROCEDURE ONLY is required every 3 years or more
frequently if changes to the Facility or Site occur that alters means of egress.
Refer to S&W Energy’s Emergency Response and Fire Protection and Prevention
procedures for the requirements on content and frequency of training, which should
include Means of Egress.

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Policy No:EHS-523 Means of Egress

6 Auditing / Inspections
The Means of Egress Procedure shall be reviewed at least every 3 years or more
frequently if Facility or Site changes dictate. This procedure will be updated as
necessary.
7 References
29 CFR 1910.22 Walking & Working Surfaces – General Requirements
29 CFR 1910.35 – 1910.37 Means of Egress (Subpart E)
29 CFR 1910.38 Emergency and Fire Prevention Plans

Page 5
 Environmental Health and Safety
Manual
Policy No. EHS-524 Policy Title: Driver Safety
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 Definitions ................................................................................................................ 2
3 General Procedure................................................................................................... 2
4 Disciplinary Action Procedures................................................................................. 4
5 Accident Procedures ................................................................................................ 4
6 Vehicle Inspection .................................................................................................... 4
7 Training .................................................................................................................... 5
8 Auditing / Inspections ............................................................................................... 5
9 References............................................................................................................... 5

Page 1
Policy No:EHS-524 Driver Safety

1 Purpose and Scope

This procedure provides the requirements and guidelines for motor vehicle safety. The
requirements and guidelines are provided and enforced to ensure that Facility or Site
vehicles will be operated and maintained in a safe manner and that all vehicles and
drivers comply with all government regulations (Federal, State, and Local). It also
provides steps to be taken in the event of an accident.
This procedure applies to all S&W Energy employees who operate a vehicle (either
leased or owned) for the purpose of their job or work tasks. This includes office
personnel or sales people renting an automobile for business.
2 Definitions
• Accident – For the purpose of this procedure, any event involving a Facility or Site
vehicle which results in any amount of damage, injury, or liability for or against the
employee responsible or the Facility (Company).
• Class A Vehicle – The designation or classification for a lightweight Facility vehicle.
This designation may include passenger cars, panel trucks, and pick up trucks with a
load capacity rating of ¾ tons (3,300 kilograms) or less.
• Class C Vehicle – The designation or classification for a heavyweight Facility
vehicle. This designation may include stake-body, dump, and multi-axle trucks.
• Facility Vehicle – All vehicles owned or leased by the Facility or Site and provided
to employees to perform their work responsibilities.

Violation of State licensing, Department of Transportation (DOT), or any

other requirements for the safe and legal operation of Company vehicles will
result in the immediate suspension of employees driving privileges. It is
S&W Energy policy to check an employee’s motor vehicle record prior to
first authorization of use and periodically thereafter.

3 General Procedure
ANY EMPLOYEE WHO DRIVES A FACILITY VEHICLE MUST HAVE A VALID
DRIVER’S LICENSE.

All facility vehicles shall be properly licensed and insured per government
regulations (i.e., registration, tag, and title).
A proof of insurance must be with the vehicle at all times (i.e., keep insurance card
in the glove compartment).

Page 2
Policy No:EHS-524 Driver Safety

No vehicle shall be driven when the load on the vehicle interferes with proper
vision, free movement of the driver, accessibility to emergency equipment, or exit
from the vehicle cab.
The operator of a facility vehicle and all other occupants within the passenger
compartment must wear seatbelts.
Transporting of persons in an unauthorized manner in facility vehicles is prohibited.
Transporting in an unauthorized manner shall be deemed to include the following
actions:
• Transporting more than 3 persons, including the driver, in the front seat.
• Transporting persons on the fenders, running boards, or tops of vehicles.
• Transporting persons with appendages extending from the vehicle.
• Transporting persons in other than a seated position.

All loads shall be properly secured and checked prior to transport.

Motor vehicles shall not be fueled while the engine is running, unless such action is
needed to fuel the vehicle. Smoking and using cellular telephones while the
vehicle is being fueled is prohibited.
Hazardous materials transportation is limited to small quantities (i.e., below
quantities requiring placards or special licenses).
Class C vehicles should be equipped with an audible warning device when
traveling in reverse (back-up alarm).
Vehicles shall be left on facility property when not in use.
Vehicles shall be securely locked with keys removed during non-working hours. All
vehicles should be parked off the street, where possible, during non-working hours.
Traffic laws are to be obeyed at all times. The driver operating the vehicle is
responsible for any traffic citations received related to driver control.
All traffic citations received while driving a facility vehicle must be reported to the
Facility Manager, or designee.
Employees shall report any change in their driving status to the Facility Manager,
or designee, as soon as the change is known. Records of such driver’s status shall
be maintained and kept on file at the Facility.
Facility vehicle status and use shall be known at all times. The Attachment Section
of this procedure contains a Facility vehicle Sign In / Sign Out Sheet, which is a
recommended tool to monitor the status of all facility vehicles.

Drivers should carry their valid driver’s license with them at all times.

Page 3
Policy No:EHS-524 Driver Safety

4 Disciplinary Action Procedures

If an accident has been determined to be preventable, the Facility Manager, or
designee, will initiate disciplinary actions commensurate with the severity of the
accident, taking into consideration the driver’s previous accident record and driving
experience.
The involved driver will be subject to immediate discipline and may be held
responsible for all damages and resulting liabilities if it is determined that an
accident was preventable and was caused by any one of the following reasons:

• Driving under the influence of drugs and/or alcohol;

•
• Driving by an unauthorized driver of a Facility vehicle;
•
• Driving a Facility vehicle for unauthorized purposes; or
•
• Driving in blatant violation of the law (i.e., driving without a valid driver’s license,
excessive speed, driving recklessly, unauthorized parking, etc.).

Failure to report an accident or leaving the scene of an accident will result in

disciplinary action.
5 Accident Procedures
In case of a vehicle accident, the driver must stop and set out emergency reflectors
or flares to protect the driver, any passengers, and the vehicle.
Specifics of the accident should be discussed with the police and representative of
the Facility (or Company), only. The driver should not assume any blame or
responsibility, express opinions, or become involved in any arguments as a result
of the accident. In addition to reporting the accident to the Facility or Site, local-
reporting requirements should be followed.
Each driver is required to report every accident, property damage, or loss incident
involving a Facility vehicle to the Facility Manager, or designee, as soon as
possible. Vehicle accidents shall be reported per the Facility EHS Incident
Reporting (and Follow-up) procedures.
6 Vehicle Inspection
No vehicle shall be placed in service until it has been properly inspected and found
to be in good operating condition. All applicable Federal, State, and local
government inspection requirements shall be met.
All vehicles should be on a scheduled safety and maintenance program.

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Policy No:EHS-524 Driver Safety

• Vehicles should be visually inspected on a daily basis, or prior to each use,

checking mirrors, windows, lights, horn, tires, and brakes.
• Other than daily visual inspections, vehicles in use should be checked in more
detail on a regular basis, at least quarterly, to assure that it is in safe operating
condition and free from apparent damage that could cause failure when in use.
A mechanic or a Facility employee who is capable and qualified to inspect the
motor vehicle should conduct this more detailed inspection. The Attachment
Section of this procedure contains a checklist to be used by the driver to ensure
safety of Class A vehicles.
• The Facility or Site should develop a similar checklist for Class C vehicles, if
applicable.

Completed checklists and records of tests and safety inspections shall be

maintained at the Facility or Site and be made available upon request by the
designated authority.
A vehicle not meeting safe operating conditions shall be immediately removed from
service. Its use shall be prohibited until unsafe conditions have been corrected.
The vehicle shall be re-inspected before being returned to service.
7 Training
All S&W Energy Facility or Site employees (including Field personnel) who are or may
be required to drive a Facility vehicle shall be trained on the requirements and
guidelines of this procedure prior to the use of the vehicle. A valid driver’s license is
ALWAYS required. Refresher training is required every 3 years.
Defensive driver training courses may be required for any employee at the discretion of
the Facility Manager, or designee.
Drivers may be required to attend periodic training classes, as required by local
jurisdiction.
8 Auditing / Inspections
Vehicle should be inspected according to the Vehicle Inspection Section of this
procedure.
The Driver Safety Procedure shall be reviewed every 3 years. Documented vehicle
inspection reports, vehicle repair records, and employee driving records may be
reviewed as part of this inspection or audit. This procedure will be updated as
necessary.
9 References
U.S. Federal Motor Carrier Safety Regulations

Page 5
 Environmental Health and Safety
Manual
Policy No. EHS-525 Policy Title: Housekeeping
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 General Requirements ............................................................................................. 2

Page 1
Policy No:EHS-525 Housekeeping

1 Purpose and Scope

This policy provides guidelines for all S&W Energy facilities and site regarding
housekeeping and general worksite cleanliness. Housekeeping is maintaining the job
site in a neat and orderly manner with the proper removal of trash. A dirty, cluttered job
site is hazardous.
2 General Requirements
The following will be adhered to:
• Scrap materials shall be disposed of as each job is completed by each
craftsperson. The job is not complete until the trash and scrap have been
removed.
• The project will be kept in an orderly manner at all times.
• Trash receptacles shall be provided at practical and strategic locations.
• Trash receptacles shall be dumped at regular intervals and shall not be allowed
to overflow.
• Oily rags, etc. shall be kept separate and disposed of separately in metal fire-
resistant containers with tops.
• Periodically, a general cleanup will be affected with all Contractors and Sub-
contractors required to share in the operation.
• All scrap lumber, forms, and crates shall have protruding nails removed upon
dismantling.
• Glass drinking bottles shall not be permitted on S&W Energy projects.
• Lunch and food waste shall be disposed of immediately in trash barrels as
generated. Barrels shall have tightly closing lids.
• All office trailers shall be kept in good, clean order.
• Scaffolds shall be cleaned on a regular basis, and debris removed as soon as
possible. Materials shall not be thrown down from scaffolding except in
controlled situations and only at the direction of the Safety Supervisor when
appropriate precautionary methods have been implemented.

A. MATERIAL STORAGE
• All material must be properly stacked and secured to prevent sliding, falling, or
collapse. Aisles, stairs, and passageways must be kept clear to provide for the
safe movement of employees and equipment and to provide access in
emergencies.
• The storage of materials must not block any exit from a building or free access
on the form system.
• Material stored inside buildings or structures under construction must not be
placed within 6 feet of any hoist-way or other inside floor opening, or within 10
feet of any exterior wall which does not extend above the top of the material
stored.
• Pipe, conduit, and bar stock should be stored in racks or stacked and blocked to
prevent movement.

Page 2
Policy No:EHS-525 Housekeeping

• The quantity of materials stored on scaffolds, platforms, or walkways must not

exceed that required for one days operation, nor exceed the capacity of the
scaffold.
• Non-compatible materials shall be segregated in storage.
Lumber:
• Protruding nails must be pulled when stripping forms or uncrating materials.
• Lumber shall be stacked on level and solidly supported sills.
• Lumber shall be so stacked as to be stable and self-supporting.
• Fire protection shall be provided in accordance with S&W Energy’s Fire
Protection and prevention policy.

B. OUTSIDE STORAGE AREAS

• Outside storage areas shall be kept clean, free of debris, and graded so that
water will run off.
• Grass and weeds shall be controlled by cutting or approved weed killers.
• Access roads and lanes shall be adequate to allow free movement of material
handling equipment and shall be kept level and free of potholes.
• Dust control should be utilized to minimize personnel to excessive exposures.

C. MATERIAL DISPOSAL
• S&W Energy and subcontractors are responsible for collecting and disposing of
their own trash on the project unless covered under conditions of the contract.
• All waste and surplus materials shall be collected and disposed of as soon as
each individual task or job is complete.
• Disposing of waste materials or debris by burning is prohibited, except when
specifically authorized by the Project Safety Department; then, only in
compliance with federal, state, and local fire regulations.
Usable Materials:
• All extra parts, bolts, etc., shall be returned to their appropriate storage facilities.
• All employees shall return usable scrap to an organized area out of the general
confines of the work site. This area shall be kept in good order.

D. SPILLS
• Liquid spills shall be cleaned up as soon as they occur by S&W Energy or
subcontractors.
• If cleanup cannot be affected immediately, the spill area shall be barricaded
with an acceptable physical barrier or tape until cleanup is effected.
• Any time a non-biodegradable material is spilled or discharged into sewer or
run-off ditch systems, S&W Energy or the subcontractor responsible shall
immediately notify the Construction Manager and Safety Supervisor. It is the
responsibility of site management to make timely reports to appropriate
agencies requiring notification.

Page 3
Policy No:EHS-525 Housekeeping

• S&W Energy or the subcontractor responsible for the non-biodegradable spill

shall assist project personnel to affect a cleanup that conforms to the spill
prevention, control, and countermeasure plan for the project.

E. WASTE RECEPTACLES
• Waste containers should not have been previously used for toxic or dangerous
materials.
• Metal drums or cans shall be stationed throughout the project in close proximity
for all contractors and crafts to dispose of project-generated trash. Drums or
cans must be:
• Dumped on a regularly scheduled basis so drums will not become overfilled.
• Shall be marked with a stenciled sign "TRASH."
• Paper or cardboard drums and boxes will not be used for trash collection.
• Large waste receptacles, such as dumpsters, are required to have a platform
with steps and handrails in place at all times for employee access.
• All solvent waste, oily rags, and flammable liquids shall be kept in fire-resistant
covered containers until removed from the project.

Page 4
 Environmental Health and Safety
Manual
Policy No. EHS-603 Policy Title: Waste Management
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 Definitions ................................................................................................................ 2
3 Identify and Classify Wastes .................................................................................... 4
4 Determination of Generator Status........................................................................... 6
5 Management of Hazardous Waste........................................................................... 8
6 Land Disposal Restrictions (LDR) .......................................................................... 12
7 Transportation Requirements (Disposal, Labeling, and Manifesting) ..................... 15
8 Other Reporting and Recordkeeping Requirements .............................................. 18
9 Waste Minimization ................................................................................................ 20
10 Training .............................................................................................................. 21
11 Auditing / Inspections ......................................................................................... 22
12 References ......................................................................................................... 22
13 Forms ................................................................................................................. 22

Page 1
Policy No:EHS-603 Waste Management

1 Purpose and Scope

This procedure provides the requirements and guidelines for managing waste, in
particular hazardous waste, at a S&W Energy Facility or job-site. The Waste
Management procedure includes guidance on identifying and classifying wastes
generated on-site, determining generator status, managing the wastes (i.e., labeling,
storage, accumulation, ID certification), transportation requirements, land disposal
requirements, if applicable, and all recordkeeping and reporting.
Waste Management applies to all employees at each Facility or job-site in some
capacity. Managers and Supervisors must be aware of manifesting and managing
requirements while other employees need to be aware of accumulation, labeling,
storage, and handling requirements. Reference the Training section of this procedure
for information on employee training requirements.
2 Definitions
• Acutely Hazardous Waste – All wastes designated with an “H” Hazard Code,
which includes all “P” listed wastes (Reference the Attachment Section for further
descriptions).
• CERCLA – Comprehensive Emergency Response, Compensation, and Liability
Act.
• CESQG – Conditionally-Exempt Small Quantity Generator.
• Characteristic – For purposes of Hazardous Waste definition and this
procedure, exhibiting ignitability, corrosivity, reactivity, or toxicity properties.
• Container – Any portable device, in which a material is stored, transported in,
treated, disposed of, or otherwise handled.
• Containment Building – A hazardous waste management unit that is used to
store or treat hazardous waste.
• EPCRA (or SARA Title III) – Emergency Planning and Community Right-to-
Know Act (or Superfund Amendments and Reauthorization Act).
• Episodic Generation – Hazardous Waste generators who periodically exceed or
fall below normal generation limits from month to month.
• Generator – According to RCRA, any person (or Site, business entity) who
produces hazardous waste or who causes a hazardous waste to become subject
to a regulation.
• Hazardous Waste – A solid waste, or combination of solid wastes, which
because of its quantity, concentration, or physical, chemical, or infectious
characteristics, may cause or significantly contribute to an increase in mortality
rate or irreversible illnesses or pose a substantial hazard (present or potential) to
human health or the environment when improperly treated, stored, transported,
disposed of or otherwise managed. A waste is hazardous if it is not listed as an
exemption, according to RCRA, and is a listed waste and characteristic. A
hazardous waste must be a solid waste, as defined.

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• Hazardous Waste Management – The systematic control of the collection,

source separation, storage, transportation, processing, treatment, recovery, and /
or disposal of hazardous waste.
• Land Disposal – Placement of a waste in landfills, underground injection wells,
waste piles, land treatment units, surface impoundments, salt domes,
underground mines and caves, concrete vaults, bunkers, or any other placement
on or in the land.
• Land Disposal Restrictions (LDR) – A program implemented by EPA and
RCRA as part of the Hazardous and Solid Waste Amendments (HSWA) that is
focused on minimizing concerns regarding the short term and long term effects of
hazardous waste disposal and to substantially diminish the toxicity of hazardous
wastes prior to disposal.
• LQG – Large Quantity Generator
• Non-Acutely Hazardous Waste – Hazardous waste not designated as Acutely
hazardous.
• Point of Generation (POG) – At or before the location where a solid waste
produced by a system, process or waste management unit is determined to be a
hazardous waste, but before the waste is either combined with other hazardous
wastes or materials.
• Prohibited Wastes – Restricted hazardous wastes that are currently subject to
LDR treatment standards and the prohibitions on dilution and storage. Since
treatment standards have been established for virtually all hazardous wastes,
most hazardous wastes are also prohibited wastes.
• Resource Conservation and Recovery Act (RCRA) – An act developed,
established, and passed into law, in 1976, by the Environmental Protection
Agency (EPA, the Federal government) that basically promotes the protection of
health and the environment and to conserve valuable raw materials and energy
resources. One of the main focuses of this complex regulation is the
management of hazardous wastes, creating the “cradle-to-grave” management
system and establishing programs to protect the environment.
• Restricted Waste – Hazardous wastes for which LDR treatment standards have
been set and are the broadest category of wastes subject to the LDR
requirements.
• Satellite Accumulation Area – Hazardous waste storage at or near the point of
generation prior to removal to a centralized storage area.
• Solid Waste – For purposes of this procedure, a solid waste is any garbage,
refuse, sludge, or any other discarded material including solid, semi-solid, liquid,
or contained gaseous materials. Hazardous wastes are a subset of solid wastes.
Neither is necessarily physically “solid”.
• SQG – Small Quantity Generator.
• Tank – According to RCRA, a stationary device designed to hold hazardous
waste that is constructed primarily of non-earthen materials which provide
structural support.
• Treatment – Any method, technique or process, including neutralization,
designed to change the physical, chemical, or biological character or composition

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of any hazardous waste so as to recover energy or material resources from the

waste, or so as to render such waste as non-hazardous, or less hazardous; safer
to transport, store, or dispose of; or amenable for recovery, amenable for
storage, or reduced in volume. Examples of treatment include: Incineration,
distillation, evaporation, crushing lamps, open detonation, compacting wastes,
chemical precipitation, dilution, filtration, neutralization, combustion, or blending
fuel.
• Waste Minimization – A program implemented with the intended result of
reducing the amount of waste generated and disposed of, by using techniques
such as source reduction and environmentally sound recycling. This may include
equipment or technology modifications, process modifications, reformulation of
products, substitution of raw materials, or improvements of housekeeping,
maintenance, or inventory control. Treatment of wastes for destruction or
disposal is NOT waste minimization.

The steps involved in management of wastes include the following:

1. Identify and classify waste generation (determine if hazardous)

2. Determine generator status
3. Management of the wastes (storage, handling, accumulation, permitting)
4. Identification of Land Disposal Restrictions (LDRs), if applicable
5. Identify transportation requirements (labeling, manifesting and disposal)
6. Establish recordkeeping and reporting requirements
7. Establish appropriate training for all levels of employees, including
management

3 Identify and Classify Wastes

Each Facility or Site shall identify all waste streams and their points of generation
(POG) at their Facility or Site.
Each waste stream shall be analyzed at the POG, prior to being treated or commingled
with any other waste, to determine if the waste generated is hazardous.
Determining if a site generates hazardous waste is a three-step process (keep in mind
that the waste must be a solid waste as defined in Section 2):
• Check to see if the waste meets any of the exclusions in Section 261.4
(Reference the Attachment Section of this Procedure);
• If the waste is not excluded, check to see if it meets any of the hazardous waste
listings (Reference the Hazardous Waste Listings in the Attachment Section of
this Procedure):

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• If not listed, determine whether the waste exhibits a characteristic of hazardous

waste (one of four: ignitability, corrosivity, reactivity, or toxicity). Reference the
description of these characteristics in the Attachment Section of this Procedure.

NOTE: Exclusions from the definition of solid waste include Domestic Sewage,
Clean Water Act Permitted Discharges (industrial wastewater discharges), and
Nuclear Materials (Radioactive Wastes).
The waste must be classified at the POG. A substance may not be hazardous at
the origin of a process but may become hazardous as a product or waste of a
process, at the point it is generated. The reverse is also true.
Use either process knowledge or analytical methods to assist in determining if the solid
waste is a hazardous waste.
Process knowledge involves evaluating the materials used in the process that
generates the waste to determine if the waste stream contains hazardous
constituents that would render the waste hazardous or if the process is one that
presumes to generate a hazardous waste.
Process knowledge can also be used to determine a waste or waste stream to be
non-hazardous.
Analytical knowledge and methods involves sampling and testing the material
using any number of analytical methods including, but not limited to, total
constituent analysis, TCLP, EP, pH testing, paint filter methods, etc. Reference the
regulatory standards for acceptable and published analytical methods.
Correctly apply mixture, derived-from and contained-in rules when determining if the
solid waste is hazardous waste.
Mixture Rule – Any mixture of a listed hazardous waste and a solid waste, no
matter what percentage of the waste mixture is composed of the listed hazardous
waste; the entire mixture must be managed as the listed hazardous waste and
carry the applicable listing waste code(s).
Derived-From Rule – Any solid waste derived from the treatment, storage, or
disposal of a listed hazardous waste is a hazardous waste.
Contained-In Policy – Materials that are not solid waste but contain listed
hazardous waste, must be managed as a hazardous waste until the State or EPA
determines that the materials no longer contain a hazardous waste.
For all hazardous wastes, determine the applicable hazardous waste codes. This is
important for manifesting of waste, labeling and storage requirements. The Attachment
Section contains information on hazardous waste codes.
If the waste is determined to be hazardous, each Facility or Site is classified as a
hazardous waste generator, according to RCRA standards, and subject to the
standards and requirements for managing hazardous waste in this procedure.

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Facilities or Sites that generate hazardous waste must obtain an EPA (or State)
identification number.
If the waste is determined to be non-hazardous, RCRA disposal requirements do not
apply. Wastes shall be disposed of and managed according to the specific Facility or
Site rules for the types of wastes generated.

The importance of accurate, complete, and rapid waste categorization cannot

be overemphasized. Most RCRA violations can be traced back to improper
waste identification.

4 Determination of Generator Status

Once a Facility or Site has determined that they do in fact generate hazardous waste,
they must determine their generator status. There are three (3) key factors in
determining the classification or status level of a hazardous waste generator. These
factors include:

• The quantity of waste generated on a monthly basis (the amount generated in a

month and NOT the amount disposed of or transported off-site in a month);
• The type of waste generated; and
• The amount of waste stored on site at any one time.

There are three (3) generator categories that may apply to a Facility or Site. They
are Conditionally Exempt Small Quantity Generators (CESQG), Small Quantity
Generators (SQG), and Large Quantity Generators (LQG).
Each Facility or Site must determine the amount of hazardous waste they generate on a
monthly basis and the amount of hazardous waste stored on-site at any one time
(“counting your waste”).

• When “counting your waste” to determine generator status, do not count any
waste that is excluded or exempted from regulation. Reference the exemptions
in the Attachment Section of this procedure.
• Count each waste only once per calendar month (i.e., spent solvent reclaimed
and reused).

Each Facility or Site must determine the type of waste generated on-site (non-acute or
acute hazardous waste; reference the Definition Section for definitions of these waste
types).

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A. Conditionally Exempt Small Quantity Generators (CESQG)

Facilities or Sites that generate or produce less than 100 kg of non-acute
hazardous waste (normal hazardous waste) and less than 1 kg of acute hazardous
waste per calendar month shall classify themselves as a CESQG.
Facilities or Sites that do not accumulate more than 1,000 kg of non-acute
hazardous waste at any time shall classify themselves as a CESQG.
CESQ Generators are exempt form most hazardous waste management
regulations, including LDR treatment standards. They have no limits on how long
they can store their wastes on-site.
B. Small Quantity Generators (SQG)
Facilities or Sites that generate or produce more than 100 kg but less than 1,000
kg of non-acute hazardous waste (normal hazardous waste) and less than 1 kg of
acute hazardous waste per calendar month shall classify themselves as an SQG.
Facilities or Sites that do not accumulate more than 6,000 kg of non-acute
hazardous waste at any time shall classify themselves as an SQG.
SQ Generators may store their waste on-site for 180 days, or for 270 days if the
waste is shipped more than 200 miles, without a permit.
C. Large Quantity Generators (LQG)
Facilities or Sites that generate or produce more than 1,000 kg of non-acute
hazardous waste (normal hazardous waste) or more than 1 kg of acute hazardous
waste per calendar month shall classify themselves as an LQG.
Facilities or Sites do not have a limit as to the amount of waste they may
accumulate on-site.
LQ Generators may store their wastes on-site for 90 days or less without a permit.

Generators who store waste longer than the time allowed are subject to
extensive permitting requirements under RCRA.

If the amount of waste generated in a given calendar month places the generator in
a different generator status category, the Facility or Site is responsible for
complying with all applicable requirements for that category for all waste generated
during that calendar month (Episodic Generation).
• Notification must be made to the State or EPA (RCRA Department) if the Facility
or Site changes generator status, especially for SQG and LQG where EPA ID
numbers are required and for inspector’s verification during an audit.
• Try to maintain generator status and avoid episodic generation. Some states
may limit the number of status changes you can make annually.

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5 Management of Hazardous Waste

A. General Facility Standards
The following requirements apply to SQGs and LQGs that manage waste without a
permit (additional requirements may apply to generators who have permits):

• Generators must obtain a site-specific EPA identification number (see the

following section);
• Generators who treat hazardous waste on-site to meet LDR standards must have
a Waste Analysis Plan (WAP) that specifies the frequency of testing and those
restricted wastes meet appropriate treatment standards under LDRs. (Reference
sections that include treatment of hazardous wastes and LDRs)
• Generators must maintain and operate their facilities in a manner that will prevent
fires, explosions, or unplanned releases of hazardous waste; and
• When there is an imminent or actual emergency situation, the generator must
provide and implement emergency procedures, as outlined in the Facility or
Site’s Emergency Response or Action Plan.

B. Identification Numbers
Except for conditionally exempt small quantity generators of hazardous waste, all
sites that generate, treat, store, or dispose of hazardous waste must obtain a
hazardous waste activity identification (ID) number. This number is used on all
required documentation pertaining to hazardous wastes generated at the site.
• Identification numbers can be obtained by contacting the EPA Regional Office
or through the appropriate State agency in charge of implementing RCRA
requirements. A form is required to be completed and submitted, providing the
necessary information.
• Numbers are available for emergency situations or one-time shipments of
hazardous waste.
• A hazardous waste ID number is NOT a permit. It does NOT provide
authorization for a Facility or Site to receive hazardous wastes from another
Facility (unless a specific RCRA permit is obtained).

Generators may not offer hazardous waste for transportation, disposal, or

treatment to entities that do NOT have a hazardous waste ID number.

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EPA ID numbers for hazardous waste are to be issued in the name of the
Customer or Owner of the Facility or Job-Site (similar to all other permitting
such as air, water, etc.). Whether operating a Facility as part of an O&M or
performing work on a job-site as part of a Field Service job, S&W Energy only
manages the hazardous waste. S&W Energy shall NEVER obtain an EPA ID
number in their name or sign hazardous waste disposal manifests unless they
own the site or contractual arrangements have been made with the Customer
or Owner.

C. Accumulation Standards
Generators may store their waste on-site WITHOUT having to obtain a permit as
long as the short-term accumulation requirements are met.

• For CESQG, hazardous waste may be accumulated on-site without a time limit
as long as the amount of waste never equals or exceeds 1,000 kg of non-acute
hazardous waste or 1 kg of acutely hazardous waste at any one time.
• For SQG, hazardous waste may be accumulated no more than 180 days (270
days if the waste must be transported father than 200 miles from the site), as
long as the amount accumulated never exceeds 6,000 kg at any one-time.
• If these periods are exceeded, the Facility will be considered the operator of a
hazardous waste storage facility, requiring a permit.
• For LQG, hazardous waste may be accumulated no more than 90 days. If the
LQG exceeds the accumulation requirements without a permit, it is classified as
an interim status storage facility and it must, among other requirements,
prepare a closure plan with financial assurance and assume potential liability
from the release of hazardous constituents and associated costs.

Except where satellite accumulation areas are used, the accumulation periods
described above begin at the time of generation and NOT at the time of hazardous
waste identification.
• The clock begins for a particular container of hazardous waste when the first
drop of hazardous waste enters the container. The container shall be labeled
with this date.

D. Satellite Accumulation Areas

Satellite accumulation areas must have the following requirements:

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• Must use containers (not tanks) that are in good condition and compatible with
the wastes they contain (recommended UN-approved or DOT-approved
containers);
• Must be marked with the words “Hazardous Waste” or similar words that
convey the contents of the container;
• Must be closed except when it is necessary to add or remove wastes;
• Must not exceed more than 55 gallons of non-acute hazardous waste or one
quart of acute hazardous waste. More than one container may be used in a
satellite accumulation area, so long as the total does not exceed 55-gallons;
• Once the storage limit of 55 gallons is met, the container should be moved to
the 90/180-day storage area in that same day, but no more than 3 days, to
prevent excess accumulation and potential fines from Inspectors.
• The container shall be marked with the date the container is full or the date the
55-gallon storage limit is met. This is the time that the 90/180-day storage limit
begins. While a container with capacity greater than 55 gallons may be used,
the 55-gallon limit still remains;
• The 90/180-day storage time limit does not apply to satellite accumulation areas
UNTIL 55 gallons of non-acute hazardous waste or one quart of acute
hazardous wastes are accumulated;
• Nothing precludes the placement of several satellite accumulation areas in
close proximity to one another, however, each must be clearly marked to make
the designation between them;
• There are no recordkeeping requirements for satellite accumulation areas other
than proper labeling of the container and the date excess accumulation begins
(or date of 55 gallon limit); and
• There are no air emission requirements for satellite accumulation areas;

E. Hazardous Waste Storage – Containers (i.e., 55-gallon drums)

• Containers storing hazardous waste must be in good condition.

• Incompatible wastes must NOT be stored in the same container and the
constituents of the waste must be compatible with the material of which the
container is made.
• Containers must be securely covered except when wastes are added or
removed.
• Containers shall be handled in a manner as to prevent ruptures or leaks.
• Weekly inspections must be conducted and documented to assure that
containers remain in good condition and to assure storage limits (time and
amount) are not exceeded.
• Containers meeting the definition of “empty”, according to RCRA can be
managed as non-hazardous waste.

F. Hazardous Waste Storage – Tanks

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• Tanks storing hazardous waste must be evaluated to assess structural integrity

and compatibility with the wastes they will hold.
• Tank systems (and ancillary equipment such as valves and piping) must have
secondary containment and leak detection systems.

G. Hazardous Waste Storage – Containment Buildings

• Only LQ Generators are authorized, by regulation, to store hazardous waste in

containment buildings. They can not be used for SQ Generators.
• Containment buildings must be completely enclosed and have self-supporting
walls.
• Containment buildings must contain a primary barrier designed to withstand the
movement of people, waste, and handling equipment.
• Containment buildings shall be operated in a manner that prevents waste from
being tracked in and out of the unit.
• If wastes with a liquid component are stored in the unit, the containment building
must be provided with secondary containment.
• If wastes are totally comprised of liquid (100% liquid), they cannot be managed in
a containment building.
• Hazardous wastes may be stored in containment buildings for less than 90 days
without a permit. Generators must have on file a documented procedure or
written description that ensures the waste volume remains in the unit no longer
than 90 days.
• Facilities or Sites must obtain, before operating the containment building (unit), a
certification by a qualified registered professional engineer that the containment
building meets the design standards as described in regulation. This certification
must be kept on file.

H. Air Emission Standards – FOR LQ GENERATORS ONLY

• Large quantity generators who accumulate hazardous waste on-site are subject
to RCRA organic air emission standards (under 40 CFR 265, Subparts AA for
process vents, Subpart BB for equipment leaks, and Subpart CC for tanks and
containers).
• Compliance with the air emission standards is part of the LQG conditional
exemption from the requirement to obtain a permit or interim status for the on-site
accumulation of hazardous wastes.
• Units such as wastewater treatment units, neutralization units, closed-loop
recycling units, satellite accumulation units, and totally enclosed treatment units
are exempt from RCRA air emission standards.

I. Treatment of Hazardous Waste

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Generally, hazardous waste cannot be treated unless the Facility or Site has a
RCRA permit. However, certain activities are available to generators without a
permit.
Exemptions from permitting requirements for hazardous waste treatment units
include the following:
• Wastewater treatment units;
• Totally enclosed treatment facilities;
• Elementary neutralization (treatment of corrosive-only) units;
• Emergency response action treatment units; and/or
• Addition of absorbent material to waste in containers.

Hazardous wastewater may be treated without a RCRA permit so long as the

treatment occurs in a tank (see definition of tank) and the discharge runs directly to
a publicly owned treatment works (POTW) or is subject to National Pollution
Discharge and Elimination Standard (NPDES) requirement.
Corrosive-only wastes may be neutralized in tanks without a permit. This
exemption can not be used to treat a corrosive waste that is a listed waste or
meets other hazardous waste characteristics.
Treatment may occur in totally enclosed treatment systems as long as the system
is hard-piped to a production process and assured that no hazardous waste
constituents will escape into the ambient environment.
Sorbent material may be added to waste in a container provided the addition
occurs at the time the waste is first placed in the container. Adding sorbent to
liquid hazardous waste is considered treatment and must comply with additional
requirements under RCRA. If the sorbent is to be discarded, ultimately, in a
landfill, the sorbent material must be non-biodegradable.
The Facility or Site may treat waste in containers and tanks, or containment
buildings during the 90-day accumulation period.

J. CESQG Special Hazardous Waste Management Requirements

Because conditionally exempt small quantity generators manage hazardous
wastes under reduced regulation (i.e., are exempt from many RCRA obligations
that apply to small or large quantity generators), they must manage their wastes
according to specific requirements.
CESQ Generators that send their waste to municipal solid waste landfills or non-
municipal solid waste landfills must ensure that such landfills are subject to design
and operating standards set forth in the RCRA standards.
6 Land Disposal Restrictions (LDR)
Certain Facilities or Sites may be subject to LDR standards, depending on several
factors, primarily focusing on generators who dispose of their wastes off-site.

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Hazardous wastes subject to the LDR cannot be land disposed unless first treated to
specific levels or by specified technologies. The LDR program has three major
components that may affect operations:
• Treatment standards, that typically mandate pretreatment prior to disposal;
• Prohibitions that ensure wastes are not merely diluted or stored to avoid applicable
standards; and
• Paperwork requirements to ensure the program is enforceable, all handlers of the
waste are aware of their obligations, and that handlers can demonstrate to the
Facility or Site compliance in writing.
Each Facility or Site must determine their applicability to the LDR Program.
Hazardous waste must be disposed of off-site (destined for land disposal at any
point in its life cycle). However, land-based units such as tanks, containers, drip
pads, containment buildings, and “pump and treat” operations that manage
hazardous waste do NOT constitute land disposal.
If the waste is subject to an exemption or exclusion, the LDR program is not
applicable. These exemptions and exclusions include:

• Wastes exempt in 40 CFR Part 261 (see Attachment Section outlining the waste
exemptions);
• Wastes generated by CESQ Generators. Facility or Site must be SQG or LQG to
be subject to LDR;
• “Newly Listed” or identified wastes for which there is no standard in effect; or
• Wastes that are granted a variance.

All exemptions must be documented to prove the LDR program is not applicable.
The waste generated must be hazardous at the POG (reference Section on
identifying and classifying wastes). All hazardous waste codes of applicable
hazardous waste must be identified. The hazardous waste must be either
restricted or prohibited wastes to be applicable to LDR standards (see Definition
Section for definitions of restricted and prohibited wastes).
If the waste (or any treatment residue from the waste) is placed in a landfill, surface
impoundment, waste pile, salt dome, or other land-based unit (other than those
exempt listed above), the LDR program applies.
Temporary storage of hazardous waste on land triggers LDR compliance.

If the Facility or Site meets the criteria listed in Section 6.1, the LDR program is
applicable to that Facility. Generators should NOT rely on their waste vendors
to comply with these obligations.

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After making the determination as to whether or not the Facility or Site is subject to
the LDR program, and if the answer is YES, the following obligations must be met:

• Determine whether the hazardous waste is a restricted or prohibited waste;

• Determine the concentration of regulated hazard constituents present in the
hazardous waste;
• Determine whether the waste is wastewater or non-wastewater category of
waste;
• Determine which treatment standards are applicable;
• Assess whether treatment standards have been met; and
• Ensure the dilution and storage prohibition are not violated.

Hazardous wastes subject to LDRs cannot be land disposed unless first treated to
applicable levels and are subject to dilution and storage prohibitions as well.
Generators disposing of hazardous wastes off-site must either certify their wastes
meet the LDR standards or notify the treatment, storage, and disposal (TSD)
facility that the wastes do not meet the treatment standards.
In addition to restricted and prohibited wastes, the EPA has established treatment
standards for listed and characteristic hazardous wastes.
Use 40 CFR Part 268 and the associated tables to identify the LDR treatment
standards for the categorized waste for LDR requirements. Use all of the
classifications and waste types identified to find the appropriate standard. Use
established treatment methods to reach the treatment standards for disposal.

If you do not know all the applicable waste codes, the concentrations of
hazardous constituents in the waste, and whether the waste is a wastewater or
non-wastewater, compliance with LDRs is difficult to attain. The importance of
accurate and complete waste identification to compliance cannot be
overemphasized.

The final step in compliance with LDR requirements is to ensure all the proper
paperwork is completed and reports filed and sent accordingly. The paperwork
required for the LDR program consists of all documentation of hazardous waste
categorization, notification, certification and recordkeeping.
The initial shipment of waste off-site for storage, recycling, treatment, or disposal
must be accompanied by a one-time LDR notification that waste is or is not subject
to treatment standards.

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If the initial shipment DOES NOT meet the applicable treatment standards, a one-
time notification must be prepared and sent with shipment that includes:

• EPA Hazardous Waste and Manifest Numbers;

• Treatability group and subcategory, if any;
• A statement that the waste is subject to LDRs
• Waste analysis data, if available;
• If the waste is exempt from LDR, a statement that the waste does not have to
meet the treatment standards before land disposal is required. This should also
be noted in the Facility or Site’s operating record at the POG or after it.

If the waste DOES meet the treatment standards, both notification AND
certification are required. The notification portion includes all the information as
indicated above. The certification portion includes the following:

• Statement certifying that treatment standards have been met; and

• A statement certifying that waste has been improperly diluted to meet the
standards.

Notification and certification are required for initial shipments only. A new
notification and certification is required when the waste destination or treatment
status changes.
Notification and certification records need to be maintained for at least 3 years.
Generators treating prohibited wastes on-site to meet treatment standards must
prepare a Waste Analysis Plan (WAP). The WAP must be:

• Based on detailed physical and chemical analysis of a representative sample;

• Describe how the generator will meet the standards; and
• Contain all information to comply with 40 CFR Part 268 when treating wastes
including description of Facility processes, identification of types and quantities of
waste and description of sampling procedures.

IMPORTANT NOTE: An LDR determination must be made for all hazardous

waste generated at the Facility or Site.

7 Transportation Requirements (Disposal, Labeling, and

Manifesting)
A. Labeling, Packaging, Marking, and Placarding

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Any person or employee who prepares hazardous waste for transportation must be
trained in accordance with Department of Transportation (DOT) requirements.
DOT training is different from training required by RCRA. RCRA training does not
satisfy the DOT training requirements. The training Section of this procedure
provides mot information.
All hazardous waste must be properly packaged, labeled, marked and placarded
before they leave the site.
• Packaging must comply with the DOT packaging requirements of 49 CFR Parts
173, 178, and 179.
• Each package must be labeled as required by DOT, 49 CFR Part 172.
• In addition to marking the package in compliance with Part 172, the generator
must place the following inscription on any package of 110 gallons or less:

HAZARDOUS WASTE – Federal Law prohibits Improper Disposal. If found,

contact the nearest police or public safety authority or the United States
Environmental Protection Agency (US EPA).
Generator’s Name & Address:
Manifest Document Number:
• The generator must offer the proper placards to the transporter, according to 49
CFR Part 172, Subpart F.
Each Facility or Site that offers hazardous materials for transportation, or which
transports hazardous materials must have the following emergency response
information immediately available:

• The description of the hazardous material;

• The immediate hazards to health and the risks of fire and explosion;
• The immediate precautions to be taken in the event of an incident, such as
methods for handling fires or spills; and
• Preliminary first aid measures.

NOTE: A Material Safety Data Sheet (MSDS) can satisfy the information request
as long as it provides all of the information required.
Any Facility or Site offering hazardous materials for transportation must provide a
24-hour emergency response telephone number for use during an emergency.
B. Manifests
A manifest must accompany each shipment of hazardous waste by a Facility or
Site that generates over 100 kg / month of hazardous waste.

• The Facility accepting the hazardous waste must be designated on the manifest.
An alternate Facility may also be designated. If the waste cannot be delivered to

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the principal Facility listed on the manifest, the generator must designate another
Facility, or the waste must be returned to the generator.
• Each manifest must be filled out accurately and completely. Information required
on manifest include:

• Manifest number;
• DOT proper shipping description of the waste;
• Generator’s name, address, and EPA identification number;
• Name, address, and EPA identification number of the designated facility;
• Name and EPA Identification number of the transporter; and
• Appropriate signatures (generator, transporter, and designated facility).

• Disputes with transporters or disposal / treatment Facilities regarding the

contents of the manifest should be carefully documented and kept on file.
• While it is permissible for the generators to allow a vendor to fill out the manifest,
the generator must sign the manifest and is responsible for the accuracy.
Therefore, it is not recommended to rely on the vendors to complete the
manifest.
• The proper manifests shall be chosen.

• The first choice is the State manifest, in which the designated Facility is
located.
• If no manifest is required in the State of the designated Facility, the second
choice is the manifest of the State in which the State is generated.
• If neither of the first two states’ manifests is required, then EPA’s hazardous
waste manifest (Federal form) may be used.

• The generator must retain a copy of each manifest, signed by the transporter at
the time the waste is removed form the Facility or Site. All transporters must be
provided a copy for their records.
C. Exception Reporting
The Facility designated to receive the wastes must receive two copies of the
manifest: one for its own records and one to return to the generator. The generator
is responsible for ascertaining that the waste has been received by the proper
Facility and report cases in which a return manifest is not received.

• If a LQG does not receive a signed copy of a manifest from the designated end-
point Facility within 35 days of transport, the generator must determine the status
of the hazardous waste.
• If the manifest copy is not returned within 45 days of initial waste shipment, an
LQG must forward a report to the appropriate environmental agency. The report
must include a legible copy of the manifest and statement of the efforts
undertaken to locate the waste and the results of those efforts.

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Policy No:EHS-603 Waste Management

• SQ generators must submit a legible copy of the manifest (along with some
indication that the required copy of the manifest has been received), if the
generator has not received a signed copy of the manifest within 60 days of the
initial shipment. No formal report is required.

The manifest must also be accompanied by a waste minimization certification,

certifying that the generator has a waste minimization program in place. This
certification is printed directly on most manifests (Reference section on Waste
Minimization).
Any necessary LDR paperwork must accompany the manifest.
CESQ Generators are NOT required to use a manifest.

Hazardous Waste must be transported by vendors with approved EPA or

State hazardous waste identification numbers and only to permitted
treatment, storage, or disposal Facilities Each Facility or Site shall assure
that the transporter they use is qualified and has the appropriate ID and that
the disposal Facility to which the waste is going is approved and properly
permitted to maintain compliance.

8 Other Reporting and Recordkeeping Requirements

A. Biennial Report
A Biennial report must be filed with either the authorized State agency (or EPA) by
March 1 of each even-numbered year for LQGs.
For generators who treat, store, or dispose of hazardous waste off-site, the biennial
report must identify:
• General Facility information, including EPA ID number and generator’s name
and address;
• Transporter information, including name and address of all transporters used;
• Designated treatment, storage, and disposal facility information;
• Waste description and quantity information; and
• Waste minimization efforts information.

For generators who treat, store, or dispose of hazardous waste on-site, the biennial
report must identify:

• Descriptions of the types and quantities of hazardous waste the Facility

handled during the year; and

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Policy No:EHS-603 Waste Management

• Descriptions of all methods used to treat store, and dispose of wastes.

SQGs and CESQGs do not have to file a biennial report.

B. Release Reporting (Contingency Plans and Incident Reporting)

All RCRA hazardous wastes are CERCLA hazardous substances and, therefore,
subject to CERCLA or EPCRA immediate notification requirements. All CERCLA
hazardous substances are assigned reportable quantities that must be reported if
exceeded. Reference CERCLA or EPCRA standards for details on the quantities
and reporting.
Whenever a reportable quantity or more of hazardous substance (or hazardous
waste) is released into the environment, immediate notice to the National
Response Center (NRC) must be provided within 24 hours of the release.
Facilities that store wastes on-site pursuant to the RCRA 90-day exemption (LQGs)
from a permit requirement, must have a contingency plan in place and comply with
associated reporting requirements in the event of a release (incident reporting).
Contingency Plans describe the response actions to be taken, including reporting
requirements, whenever an imminent or actual emergency occurs. They must
include the following:
• A description of planned response and emergencies;
• A description of arrangements for response support;
• A description of emergency coordinators, including names, contact
information and emergency equipment available; and evacuation
procedures.
NOTE: Existing Spill Prevention Control and Countermeasure (SPCC) Plans and/or
Emergency Response Plans may be amended to meet contingency plan
requirements.
In the event of a fire, explosion or a release concerning a hazardous waste that
could threaten human health or the environment, immediately notify the applicable
regional agency identified in the contingency plan or the National Response
Center.
Written notification to the EPA Regional office is required within 15 days of any
incident that requires implementation of the contingency plan. This notification
shall include:
• General facility information;
• Incident description;
• Injury and hazard assessment; and
• Name and estimated quantity of materials involved.

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Policy No:EHS-603 Waste Management

Contingency Plans shall be amended whenever regulations change that affect the
content, the Plan fails, Facilities change, emergency coordinators or information
changes, or emergency equipment changes.
SQGs have similar requirements when it comes to release reporting and
contingency plans. Reference the regulations as these requirements vary State to
State. CESQG are not required to comply with contingency plan requirements.
The incident reporting requirements, under contingency plan implementation, do
not have quantitative thresholds and thus apply where neither CERCLA nor
EPCRA release reporting requirements apply.
C. Recordkeeping
All records under RCRA must be retained for a certain period of time:

CATEGORY MINIMUM TIME RETENTION

REQUIRED
Signed manifests and receipt copies 3 years
Waste analyses 3 years
LDR records 3 years
Biennial reports 3 years
Manifests 3 years
Exception reports Active life
All land disposal documentation 3 years
Training records for current employees Until site closure or 3 years
following employment at Site
Contingency plan Active life
EPA ID number Active life
Records of tank design, installation, releases, etc. Active life

9 Waste Minimization
Waste Minimization requirements apply to hazardous waste management generators,
specifically LQGs that generate hazardous waste on-site. SQGs must make a “good
faith effort” to minimize waste and select best affordable waste management options.
Reference the Definition Section for a definition of Waste Minimization.
Each LQG must establish a waste minimization program. Each manifest signed
must certify that a program exists and is in place at applicable Sites or Facilities.
The program shall address issues to reduce the volume or quantity of waste
generated and reduce the toxicity of the waste to the extent economically
practicable.
Biennial reports must also contain information regarding waste minimization efforts,
providing comparisons from previous years as indication or proof of reduction.
Waste minimization program elements include:

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Policy No:EHS-603 Waste Management

• Management support statement (signed by top-level management);

• Characterization of waste generation and management costs;
• Periodic minimization assessments;
• Cost allocation system;
• Technology transfer; and
• Program implementation and review
The program shall be written and documented, made available for inspection, and
include the signature of corporate responsible officer for RCRA compliance.
EPA has published guidance on waste minimization. Reference their literature for
assistance.
10 Training
All S&W Energy Facility or Site employees (including Field personnel) who will be
involved with Hazardous Waste operations or working in areas where Hazardous
Waste operations may be performed shall be trained on the requirements and
guidelines of this procedure.
The training program that teaches Facility or Site personnel their obligations and
teaches awareness of hazardous waste operations according to RCRA must:
• Train employees who are responsible for managing hazardous waste in the
mechanics of their job function;
• Train employees as to why they must perform certain tasks in a prescribed
manner;
• Be directed by a person trained in hazardous waste management procedures;
• Be designed to ensure that the Facility personnel are able to respond to
emergency situations; and
• Be given to Facility personnel and successfully completed within 6 months of hire
or assignment to the Facility or Job-Site;
Hazardous Waste awareness training is required annually.
For SQGs, all employees must be trained so that they thoroughly understand and
are familiar with proper waste handling and emergency procedures relevant to their
responsibilities.
For those Facilities or Sites who manage hazardous waste, training shall include
the following:
• Chemical characteristics of the waste that they are assigned to manage
• What to do in case of a spill;
• Types of personal protective equipment (PPE) or clothing to be worn;
• Proper operation of trucks, forklifts, or any other machinery to be used in waste
management; and
• Who to inform in case of emergency.
Hazardous Waste Management training is required annually.

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Policy No:EHS-603 Waste Management

Any person or employee (Facility or Site) who prepares waste for transportation
must be trained in accordance with DOT training requirements (49 CFR part
172.704). DOT training must include the following:
• General awareness / familiarization training designed to enable employees to
recognize and identify hazardous materials;
• Function-specific training that is applicable to the transportation related functions
the employee performs;
• Safety training that focuses on required emergency response information,
measures to reduce employee exposure, and procedures for avoiding accidents.
DOT training must be given within 90 days after employment.
DOT certification is also required IF any S&W Energy employee is authorized to
sign hazardous waste manifests. No employee may sign a hazardous waste
manifest unless he has the proper certification and training.
11 Auditing / Inspections
The Waste Management Procedure shall be reviewed annually. Documented records
and plans may be reviewed as part of this annual audit. This procedure will be updated
as necessary.
12 References
40 CFR 260 RCRA Basic Definitions
40 CFR 261 Hazardous Waste Listings and Characteristics, Recycling
Exemptions, & Solid and Hazardous Waste Exemptions
40 CFR 262 RCRA Generator Standards
40 CFR 263 RCRA Transporter Standards
40 CFR 264 Standards for Permitted Treatment, Storage, and Disposal Facilities
40 CFR 266 Management Standards for Specific Types of Recycled Hazardous
Waste
40 CFR 268 Land Disposal Restrictions (LDR)
40 CFR 273 Universal Waste Standards
49 CFR 171 DOT: General Information, Regulations, and Definitions
49 CFR 172 DOT: Hazardous Materials Emergency Response Information,
Communication, and Training
49 CFR 173 DOT: General Requirements for Shipments and Packaging
49 CFR 178 DOT: Specifications for Packaging
13 Forms
See Appendix S

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Policy No:EHS-603 Waste Management

S.1 - Exemptions from Hazardous Waste – Categories

S.2 - Hazardous Waste Listings (and Some Hazard Codes)

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 Environmental Health and Safety
Manual
Policy No. EHS-604 Policy Title: Toxic Substance Control Act
Date: 3/30/2006 Revision: 1 Approval: Richard Wolf

Table of Contents

1 Purpose and Scope.................................................................................................. 2

2 Definitions ................................................................................................................ 2
3 Procedure / Requirements ....................................................................................... 2
4 Training .................................................................................................................... 4
5 Auditing / Inspections ............................................................................................... 4
6 References............................................................................................................... 4

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Policy No:EHS-604 Toxic Substance Control Act

1 Purpose and Scope

This procedure provides the requirements applicable to S&W Energy under the Toxic
Substance Control Act (TSCA). Specifically, this procedure provides the requirements
and responsibilities of all employees (and employers) to identify, assess, manage, and
reduce potential risks posed by exposure to existing chemical substances in the
workplace through the process of identifying adverse health affects (when they occur or
become known), submitting allegations of such information, and notifying employees
and keeping records of these allegations.
TSCA has many parts and many requirements but only the section pertaining to records
and reports of allegations of chemical substances causing significant adverse reactions
to health and/or the environment (section 8(c)) applies to S&W Energy under the current
scope of business.
2 Definitions
• Allegation – A statement made without formal proof or regard for evidence, that a
chemical substance or mixture has caused a significant adverse reaction to health or
the environment.
• Known Human Effects – A commonly recognized human health effect of a
particular substance or mixture as described either in:

• Scientific articles or publications; or

• The Company’s product labeling or Material Safety Data Sheet (MSDS);
• An effect is not a “Known Human Effect” if:
• It was a manifestation of a toxic effect after a significantly shorter exposure
period or lower exposure level than described; or
• It was a manifestation of a toxic effect by an exposure route different from that
described.

• Significant Adverse Reactions – Reactions that may indicate a substantial

impairment of normal activities, or long-lasting or irreversible damage to health or
the environment.
• Substance – For purposes of this procedure / policy, a chemical substance or
mixture, unless otherwise indicated.
3 Procedure / Requirements
If any person, such as employee of company, individual consumer, a neighbor of the
company’s Facility, another company on behalf of its employees, or an organization on
behalf of its members, feel that they have been subject to a significant adverse reaction
due to a chemical substance or material, or some by-product thereof, shall have the
right to notify the company of such a case in the form of an allegation.
Significant adverse reactions to human health that must be recorded through the
allegation reporting process are, but not limited to:

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Policy No:EHS-604 Toxic Substance Control Act

• Long-lasting or irreversible damage, such as cancer or birth defects;

• Partial or complete impairment of bodily functions, such as reproductive
disorders, neurological disorders or blood disorders;
• An impairment of normal activities experienced by all or most of the persons
exposed at one time;
• An impairment of normal activities which is experienced each time an individual
is exposed.

Significant adverse reactions to the environment (includes environs of the plant or

disposal site) that must be recorded through the allegation reporting process are, but
not limited to:

• Gradual or sudden changes in the composition of animal or plant life in an area;

• Abnormal number of deaths of organisms;
• Reduction of the reproductive success or vigor of a species;
• Reduction in agricultural activity, whether crops or livestock;
• Alterations in the behavior or distribution of a species; or
• Long-lasting or irreversible contamination of components of the physical
environment, including groundwater, surface water, soil surfaces, etc.

Allegations must be submitted either in writing and signed by the alleger or are
submitted orally. In the case of an oral allegation, the company must transcribe the
allegation into written form or inform the alleger to submit in writing for recordkeeping
purposes and compliance.
The allegation must include or implicate the substance said to have caused the
significant adverse reaction by one of the following ways:

• Naming the specific substance;

• Naming the mixture that contains the substance;
• Naming an article that contains the specific substance;
• Naming a company process or operation in which substances are involved; or
• Identifying an effluent, emission, or other discharge from a site of
manufacturing, processing, or distribution of a substance.

Companies are not required to record significant adverse reactions to human health that
do not meet the definition of known human effects as defined previously.
Companies are not required to record a significant adverse reaction to the environment
if the alleged cause of the reaction can be directly attributable to an accidental spill or
other accidental discharge, emission exceeding permitted limits, or other incident of
environmental contamination that has been reported to the regulatory agency under
applicable authority.

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Policy No:EHS-604 Toxic Substance Control Act

Records of all allegations of significant adverse reactions made as part of this

procedure / policy shall be maintained at the company’s headquarters or at any other
appropriate location central to the company’s operations.
The allegation record shall consist of:

• The original allegation, as received;

• An abstract of the allegation and other pertinent information such as name and
address of site which received the allegation, the date the allegation was
received, the implicated substance, description of the alleger (company
employee, individual consumer, company neighbor, etc.), and a description of
the alleged health or environmental effect(s);
• The results of any self-initiated investigation with respect to the allegation; and
• Copies of any further required records or reports relating to the allegation.

Records of significant adverse reaction allegations shall be retained for 30 years from
the date of such actions were first reported. If a company ceases to do business, the
successor must receive all of these records. If the company ceases to do business and
there is no successor, records shall be submitted to the Federal Regulatory agency.
Companies must make records of allegations available for inspection by any designated
representative of the regulatory agency.
Upon request, the regulating agency may request that the allegations be submitted.
Upon this request, the company shall submit the designated records to the proper
agency indicated. This shall be done no later than 45 days following the request. Any
person or company submitting copies of allegations may assert a business
confidentiality claim as part of the submitted information.
4 Training
All S&W Energy employees shall be trained on the requirements and guidelines of this
procedure annually.
5 Auditing / Inspections
The TSCA Procedure shall be reviewed every 3 years. This procedure will be updated
as necessary.
6 References
40 CFR 717 Records and Reports of Allegations that Chemical Substances
Cause Significant Adverse Reactions to Health or the Environment

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 Policy No. EHS-501 Contractor Safety – Appendix A.1

BID SOLICITATION / CONTRACTOR QUALIFICATION FORM – Page 1

Contractor to Complete Sections I - V
I Contractor Name: SIC#:
Address: Contact Name:
Phone: Fax:
II. Insurance / Workers Compensation

Insurance Agent/Carrier: Contact Name:

Address: Phone:
Insurance Coverage
($ amt.):
Workers Compensation Contact Name:
Carrier:
Address: Phone:
III. Safety Information (Accident Rates) Year Rate (I&I or EMR)
Injury & Illness Rate (I&I) or Experience Modification Rate (EMR) for the 1.
past 3 years:
(I&I Rate = injury + illness cases x (200,000 hrs.) / (total hrs. worked) 2.
(Contact Insurance Carrier or Workers Comp Carrier for EMR) 3.

Lost Workday Case Rate for the past 3 years: 1.

(lost workday cases) x (200,000 hrs.) / (total hrs. worked) 2.
3.
Has there been a work-related death within the past five (5) years? Yes No
Has the company received a citation from a regulatory agency within the past Yes No
five (5) years?
If yes to either question, explain (attach additional sheets if necessary):
NOTE: If Contractor employs less than 10 employees FOR ENTIRE COMPANY, OSHA does not require I&I rates
recorded. However, Contractor shall provide safety information relating to injury and illness.
IV. Additional Required Information
Wastes to be Generated: Oil Oily Debris Solvents Paint Other(s) _____________________________

Estimated Quantities of Wastes

Contractor Work to Generate: Noise >85 dB Chemical Exposure, specify ____________________ Excessive Dust
Fugitive Emissions, specify _________________________ Other _____________________
Subcontractors to be Used? Yes If yes, list names:
V. On behalf of the Contractor, I acknowledge that all information provided on this form is true and that I agree to provide any support
information that may be requested from PES as proof of information here provided.
The Contractor agrees that:
• The Contractor shall ensure, to the extent possible, that all Subcontractors, Suppliers, and Agents of the Contractor, in connection
with the Contractor’s work at the PES Facility or Site, shall act in full compliance with local, state and federal laws.
• The Contractor has attached all documentation requested for submittal with this quote and agrees to provide all requested
documentation upon award of the Contract for the job quoted (reference next page for other possible required information).
Contractor Representative Title:
(Print):
Contractor Representative Date:
(Signature):

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 Policy No. EHS-501 Contractor Safety – Appendix A.1

BID SOLICITATION / CONTRACTOR QUALIFICATION FORM – Page 2

Facility to Complete Sections VI - X

VI.
Scope of
Work:
VII. Submittals
With Upon With Upon
quote Award quote Award
Document Document
Health & Safety Program Other:
HAZCOM Program
Certificate of Insurance for Worker
MSDS (of Chemicals Brought On-Site)
EHS Training Certification
VIII. Training Documentation
Training Regulation (OSHA) Training Regulation (OSHA)
Confined Space Entry 29 CFR 1910.146 Respiratory Protection 29 CFR 1910.134
Lock Out / Tag Out 29 CFR 1910.147 Scaffolds (erection & use) 29 CFR 1910.28
29 CFR 1910.269 26 CFR 1910.451
Electrical Safety 29 CFR 1910.333 Other (use additional
sheets):
IX. Safety Meetings, Inspections, and Equipment
Frequency of Safety Meetings: Frequency of Safety Inspections:
Safety Equipment to be Supplied by Contractor:
Chemical Protection, specify Hearing Protection, specify
Confined Space Rescue Equipment Respiratory Protection, specify
Confined Space Air Monitor (4 gas) Safety Glasses (w/ side shields)
Fall Protection, specify Safety Shoes (steel toe)
Hard Hats Other(s):
X. Contractor Qualification Review
Date Bid Specification ______/______/______ Date Quote ______/______/______
Contractor Qualification: Approved Not Approved
Reason Why Not
Contractor Reviewer(s): Title: First Name: Last Name:
Title: First Name: Last Name:

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Policy No. EHS-501 Contractor Safety – Appendix A.2

Contractor EHS Training Tracking Certification Form

YEAR COMPANY OR CONTRACTOR NAME CONTRACTOR REPRESENTATIVE NAME

Last First

CONTRACTOR WORKERS FOR COMPANY LISTED ABOVE

Last First Work to be Performed Last First Work to be Performed
(LOTO, Confined (LOTO, Confined
Space, etc.) Space, etc.)

CONTRACTOR TRAINING CERTIFICATION:

EHS Training Certification is valid for one year. Training shall be verified and certified on an annual basis, adding or deleting names, updating status,
as part of annual re-certification of vendor.

I verify that all employees listed above as Contractor Workers have been properly trained per regulatory standards for the work that is listed for them to perform.
The regulatory training is current and up to date. No Contractor Worker will perform duties for which he/she is not properly trained.

CONTRACTOR REPRESENTATIVE (Signature): ____________________________________________ Date: ________________________

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Policy No. EHS-501 Contractor Safety – Appendix A.3

Contractor Environment, Health & Safety (EHS) Rules Form

Each Contractor Worker must read, understand and comply with the following rules.

Contractor Safety Policy

S&W is committed to providing a safe and healthy work environment for all
employees, both on-site and Contractor Workers, and is committed to avoiding
adverse impact to the environment in performance of all site activities.

General
1. The Contractors must sign a Daily Contractor Work Permit at the beginning of the day.
2. Contractor Workers shall not work at any time when their ability is or may be impaired as a result of
the use of legal prescription drugs.
3. Contractor Workers must be seated in moving vehicles and seat belts worn while the vehicle is in
motion.
4. Fighting, horseplay, gambling, possession of firearms or other weapons, possession or use of alcohol
or illegal or unauthorized drugs is prohibited.
5. Except in “Designated Smoking Areas,” smoking is not permitted on Facility property.
6. Eating and Drinking is only permitted in designated areas.
7. All tools and equipment shall be inspected prior to use. Unsafe tools and equipment shall not be
used.
8. Contractor Workers will perform work in such a manner as to assure at all times maximum safety to
self, fellow workers and the public and in accordance with all Federal, State, and Local requirements.
9. Contractor Workers who do not either feel qualified for or physically able to perform will not attempt to
work.
10. Contractor Workers will perform work according to proper EHS practices and procedures as posted,
instructed, and prescribed.
11. Contractor Workers will obtain specific instructions and/or clarifications from their Supervisor before
proceeding with work in situations where an EHS requirement or procedure is not completely
understood.
12. Contractor Workers will observe and adhere to all warning signs, signals, and notices.
13. Contractor Workers shall not be permitted to wear loose or flapping clothing or have rags or other
objects extending from pockets or belts when in the immediate proximity of machinery, motors,
engines, or rotating equipment.
14. Contractors may not use Facility tools, moving equipment, or stock room supplies without prior
approval from the Facility or Site (S&W) Representative.
15. Contractors shall never operate any machine or rotating equipment unless all guards and safety
devices are in place and in proper operating condition.
16. Contractors shall remain in the general area of their assigned work. Do not enter other areas unless
authorized by the Facility or Site (S&W) Representative.

Immediately report every work-related Injury, Illness or Near Miss sustained at

the Facility or Site to your Supervisor.

Conduct
The following list is not a complete list but includes acts and behavior which are prohibited and for which
a Contractor Worker may be removed from the Facility:
1. Use of obscene or abusive language; racial, gender, or ethnic slurs.
2. Failure to follow specific instructions or specifications.

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Policy No. EHS-501 Contractor Safety – Appendix A.3

3. Deliberately damaging, defacing, or misusing Facility or Site property or the property of others.
4. Removing Facility or Site property from the premises without appropriate authorization.
5. Gambling, bookmaking or selling lotteries on Facility or Site property.
6. Immoral or indecent conduct; sexual harassment.
7. Illegally possessing, selling, distributing or manufacturing drugs on Facility or Site property.

Asbestos & Other Fibers

1. All fibrous materials must be accompanied by a MSDS and must be treated with care.
2. Unless a Facility or Site is documented to be asbestos free, the Contractor Worker shall not disturb
any fibrous material, but shall notify the Supervisor immediately if any is found.
3. Any Contractor performing asbestos abatement must comply with requirements stipulated in Facility
or Site procedures and any Federal, State, or local regulatory requirements.

Barricades and Notice of Work Activity

1. The Contractor Supervisor, or designee, is responsible for notifying the Facility (S&W) Representative
if barricades, signs or other notices of work activity are required. The Contractor Supervisor will work
with Facility or Site personnel, as designated, to erect all necessary barricades and notices to
safeguard all individuals, both Contractor Workers and site employees, during the conduct of the
Contractor’s work.
2. Barricades and notices are required around excavations, holes, or openings in floors, roofs, elevated
platforms, around certain types of overhead work, and whenever necessary to warn people against
falling objects or debris.
3. Blinking lights must be used on protective barricades, where lighting is inadequate.
4. The use of Caution Tape, yellow and black tape, means access to areas may be permitted only when
it is safe to do so.
5. Areas in which entry is not permitted will be taped-off with red and black barricade tape and have
signs similar to
“Danger - Do Not Enter” posted. Contractor Workers shall not enter such areas.

Confined Space Entry

1. Contractors must be pre-qualified by the Facility to perform the work (have appropriate training per
regulatory requirements) and briefed on the hazards of the confined space(s) prior to beginning work.
2. Contractors shall use S&W Confined Space Entry procedures, unless another arrangement has been
agreed upon by the Contractor and S&W.

No one will enter a PERMIT-REQUIRED CONFINED SPACE until a confined

space entry permit has been issued and posted.

Cranes and Motorized Equipment

1. The Contractor is responsible for mobile equipment operator training, applicable examinations and
certifications to qualify to operate equipment, and DOT licensure.
2. Only certified operators with valid certifications may operate cranes and other motorized equipment at
the S&W Facility or Site.

Defective Equipment
1. The Contractor Worker shall ensure that all tools and equipment shall be inspected prior to use. Any
defective equipment shall be tagged “OUT OF SERVICE” and removed until it has been repaired or
discarded.

Demolition
1. All demolition work shall be conducted in such a manner as established in accordance with the
Engineering requirements.

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Policy No. EHS-501 Contractor Safety – Appendix A.3

Emergency Response
1. Contract Workers shall review and become familiar with the Facility’s or Site’s Emergency Response
Plan and procedures before beginning assigned work. This is typically done at initial safety meeting.
2. The Contractor shall ensure that all Contractor Workers are familiar with the Facility’s or Site’s spill
notification and evacuation procedures as described in the Emergency Response Plan and know
where to muster in an emergency. Also, the Contractor shall be made aware of all emergency
contacts and procedures for reporting fires.
3. The Contractor must arrange to have spill containment (secondary containment), decontamination of
affected clothing, equipment and spill clean-up, if applicable to activities performed on-site.
Contractor may provide their own or get assistance from Facility to provide.
4. Spills must be properly managed to prevent harm or degradation of the environment, access to storm
water or sanitary sewer drains, and to ensure worker safety.
5. Evacuate the area if a spill involves hazardous, explosive, or flammable materials.
6. Contractor Supervisors are required to know who is on their job, and be able to account for them at all
times, especially after an evacuation.
7. Contractor Supervisors must report missing personnel and their presumed location to the Facility
(S&W) Representative as quickly as possible.
8. Approved First Aid supplies shall be made available by the Contractor for its Contractor Workers in
ample quantities at all times. If this cannot be supplied, the Contractor shall ask for the assistance of
the Facility or Site to provide.

Excavations
1. Prior to commencement of any excavation, the Contractor shall notify the Facility (S&W)
Representative, Shift Supervisor, or designee.
2. Contractor, in conjunction with Facility or Site personnel, shall ensure that excavation areas are
properly barricaded and have posted warning signs to ensure the safety of all individuals on-site.

Fire Protection
1. The reason for discharging a fire extinguisher shall be discussed with all Contractors. After
recharging, the extinguisher shall be returned to its original location by the Facility Representative, or
designee.
2. Contractor Workers shall not obstruct in any way access to fire extinguishers, fire hose stations or
other fire apparatus, emergency eye wash stations and showers, spill response equipment or other
safety related equipment.
3. Contractor Workers shall know the location and correct operation of the nearest fire alarm and fire
extinguisher.
4. Contractor Workers shall know the location of designated fire exits and shall not block access to
those exits.
5. Contractor Workers shall not refuel equipment while it is running or when hot.
6. Contractor Workers shall keep combustible and flammable materials away from hot surfaces and
ignition sources.
7. Contractor Workers will store flammable materials in approved cabinets (supplied by the Contractor
or Facility).

Hazard Communication Program (HAZCOM)

1. Any HAZARDOUS MATERIALS brought on site must be accompanied by the associated MSDS.
They shall be approved by the Facility or Site prior to the Contractor bringing them on-site. The
MSDS must be provided to the Facility Representative, or designee. All hazardous material must be
in an approved container, including all flammable substances. Hazardous materials are not to be left
on site.
2. All containers used by the Contractor shall be properly labeled as to the contents and physical and
health hazards at all times.
3. Each Contractor will have a HAZCOM program that includes at a minimum: complete MSDS’s on
hand at the work site for each chemical used, chemical inventory, adequate training for all personnel

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Policy No. EHS-501 Contractor Safety – Appendix A.3

that covers: physical and health hazards of all products, proper handling of the products, and
personal protective equipment.

A copy of the Facility or Site’s HAZCOM program and the Facility or Site
MSDS inventory will be made available to any Contractor Worker upon
request.

Hazardous Substance / Waste Management

1. Contractor Workers shall properly handle all hazardous and toxic substances and materials utilized in
its work at the Facility or Site.
2. Propane and compressed gas cylinders must be chained upright and on approved carriers when
moved.
3. All Contractors are responsible for the proper disposal of construction debris generated at this Facility
or Site.
4. Contractors must make advance arrangements with the Facility Representative for the placement of
the proper waste collection containers at the work-site and is not to be placed in any existing waste
container located at the Facility or Site without approval by the Facility.
5. Enclosed disposal chutes are to be used whenever waste materials are to be dropped more than 10
feet.
6. Contractor Workers will comply with requirements of S&W’s Hazardous Material Handling and Waste
Management procedures while on-site.

Hot Work
1. Contractor Workers shall not perform hot work (welding, cutting, brazing, and burning operations)
without obtaining a Hot Work Permit.
2. Contractor Workers shall comply with S&W’s Hot Work procedure and all its requirements.

Housekeeping
1. The Contractor Worker shall maintain all walkways and work areas clear of obstructions, tripping
hazards, and debris.
2. All oily rags must be disposed of in appropriate containers designed for oily wastes.

Ladders and Scaffolding

1. All ladders must be approved for use before being put into service. Each user must inspect ladders
visually before using.
2. If it is necessary to place a ladder in or over a doorway, barricade the door and/or post warning signs.
3. Metal ladders must not be used for electrical welding, or near electric lines or services.
4. Ladders must be tied off, with the user wearing a safety harness, if it is necessary to use a ladder on
top of a scaffold or close to the edge of an elevated platform, roof, or floor opening.
5. The top of the ladder must extend at least three (3) feet beyond the supporting object, when used as
access to an elevated work area.
6. Sound, rigid and suitable footing is required for all scaffolds and no unsuitable objects shall be used
for support, such as barrels, boxes, bricks or concrete blocks.
7. Guardrails and toe boards shall be installed in conformance with regulatory and engineering
requirements and standards.
8. Where persons are required to pass underneath, all scaffolds will be provided with ½” mesh
screening between the tow board and guardrail.
9. Scaffold and components shall be capable of supporting four times its intended load without failure.
10. Personnel must wear properly tied-off safety harnesses on scaffold platforms not equipped with
standard handrails or completed decking. Safety harnesses must be secured before stepping onto
the scaffold, and must not be removed until personnel are clear of the scaffold. Harnesses must be
tied off to independent lifelines or building structures – one lifeline per person.

Page 4
Policy No. EHS-501 Contractor Safety – Appendix A.3

11. No one is allowed to ride a rolling scaffold while it is being moved. All tools and materials must either
be removed or secured on the deck before moving. Pulling the scaffold along from overhead while on
the scaffold is prohibited.
12. Brick, tile, block or other similar materials may not be stacked higher than 24 inches on the scaffold
deck.
13. All scaffolds shall be erected and maintained in accordance with regulatory and engineering
requirements and standards.
14. Contractors shall comply with S&W’s Ladders, Scaffolding and Fall Protection procedures.

Lead Paint
1. For operations comprising of the grinding, welding, or burning of lead painted surfaces the Facility
(S&W) Representative must be notified prior to the start of work. If it is not known whether the
surface has lead paint on it, the Facility (S&W) Representative will be consulted.
2. The area shall be posted that work is being conducted on lead painted surfaces.
3. Work practices such as using HEPA vacuum and exhaust ventilation will be applied.

Lockout / Tagout
1. Contractor Workers must get approval from the Facility or Site Shift Supervisor, BEFORE beginning
work on LOTO'ed equipment.
2. All electrical wires and circuits are to be considered energized unless power is definitely disconnected
and the applicable switches locked and tagged out.
3. Contractors shall comply with S&W’s Lockout / Tagout procedure.

Personal Protective Equipment (PPE)

1. Contractor Workers shall wear flame resistant or 100% cotton long sleeved shirts and long pants
while involved in tasks with exposure to flames or electric arcs. Shirts with sleeves (long or short) will
be worn at all other times.
2. ANSI-approved hard hats shall be properly worn by all Contractor Workers and visitors throughout the
Facility, except in office areas and in other designated areas. (Metal hard hats are prohibited.)
3. ANSI-approved safety glasses with side shields shall be properly worn by all Contractor Workers and
visitors throughout the Facility, except in office areas.
4. Both chemical goggles and face shields shall be worn when working with or loading / unloading
chemicals such as ammonia, sulfuric acid, caustic etc.
5. ANSI approved safety shoes must be worn by all Contractors working on site. No sneakers or dress
shoes will be allowed.
6. Approved full body harnesses and lanyards shall be properly used when working in areas where a
potential fall hazard exists.
7. Approved hearing protection shall be properly used in designated areas. When in doubt of noise
levels, hearing protection shall be used. Double hearing protection must be used when working in or
around the turbines/generators when in operation with enclosures open.
8. Respiratory protection will be properly used where administrative or engineering controls fail to
reduce air contaminants to within OSHA prescribed limits. Contractors shall comply with S&W
Respiratory Protection procedure, or equivalent procedure of their own.
9. Contractors are responsible for ensuring their Contractor Workers have the proper respiratory fit
testing and training.
10. Other approved PPE such as face shields, protective clothing, gloves, etc. shall be used by
Contractor Workers where the risk of injury or illness may be prevented by its use.
11. All requirements as described in S&W’s Personal Protective Equipment procedure shall be met.

Reporting EHS Incidents

1. The Contractor Supervisor is responsible for reporting any work related injury/illness or near misses
(or environmental incidents) to the Facility (S&W) Representative as soon as they become known.
2. The Contractor Worker, Contractor Supervisor and Facility (S&W) Representative will complete all
required paperwork per S&W’s EHS Incident Reporting procedure.

Facility or Site-Specific Contractor EHS Rules

Page 5
Policy No. EHS-501 Contractor Safety – Appendix A.3

Any S&W Facility or Site shall add any site-specific EHS rules not previously covered in these Rules. Use
additional sheets, if necessary. Any attachments or additions shall be kept with the original set of rules.
The first time each Contractor arrives on-site each year, they must read and sign this Form (which shall
include any site-specific rules added). Records shall be maintained for 3 years.
Contractor EHS Rules Compliance Statement

I HAVE READ AND FULLY UNDERSTAND THE ABOVE RULES. I HAVE BEEN
INFORMED OF THE PROPER ACTIONS TO TAKE IN THE EVENT OF A FACILITY
EMERGENCY AND HAVE BEEN BRIEFED ON ALARM LOCATIONS, EVACUATION
ROUTES AND MUSTER AREAS.

Printed Company:
Name:
Signature: Date:

Page 6
Policy No. EHS-501 Contractor Safety– Appendix A.4

Daily Contractor Work Permit

This form must be completed in full by the Contractor Supervisor prior to any
work being conducted.

Contractor Today’s Date:

Work to be
Done:

Work Will Confined Space Hot Work Respiratory Protection

Involve: Entry
Hearing Protection LOTO
Others:
Contractor Supervisor Certification

Contractor Workers under my supervision at this Facility or Site will work within the requirements
established in all S&W Energy Solutions (SWES) procedures that are applicable to their work.

Within the last year, Contractor Workers under my supervision have received and have
acknowledged that they will comply with the site Contractor Environment, Health and Safety
Rules.

I have been advised by the Facility (PES) Representative of the hazards associated with this job,
the location of emergency equipment, procedures for reporting an emergency, evacuation routes
and any additional personal protective equipment that is required to perform the job.

I have communicated all of this information to EACH Contractor Worker under my supervision.

I understand it is my Company’s and my own responsibility to ensure that all Contractor Workers
under my supervision are identified on the Contractor EHS Training Tracking Certification Form
and ensure that each have been trained to the appropriate standards for which they are to
perform work.

ADDITIONAL INFORMATION:

Contractor Supervisor: Date: ____/____/____

Witnessed by Shift
Supervisor, Control Room
Operator, or Designee: Date: ____/____/____

Page 1
Policy No. EHS-501 Contractor Safety – Appendix A.5

Sample Weekly Safety Meeting Form

Contractor Name:
Date: Time: AM PM
Safety Topic:
Mtg. Conducted Signature

Meeting Attendees

Print Name Signature

1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19
20.
21.
22.
23.
24.
25.
Description of Meeting:

A copy of this form must be given to the Facility (S&W)

Representative.

Page 1
Policy No.EHS-501 Contractor Safety – Appendix A.6

Sample Contractor Inspection Checklist – Page 1

Contract Job:
Yes No
Chemical Storage/Usage Corrective Action
• MSDSs for chemicals brought on site?
• Correct chemical dispensing (grounding
and containment)?
• Chemicals in proper containers?
• All containers labeled?
Compressed Gases
• Cylinders secured?
• Protective cap fastened?
• Incompatible cylinders separated?
Confined Space
• Entry permit displayed?
• Air monitoring results recorded?
• Safety equipment utilized?
• Attendant/standby person present?
• Rescue equipment ready?
• Rescue services identified?
Electrical Safety / LOTO
Have all Contractors:
• Signed onto the LOTO Form?
• Been afforded the opportunity to walk
down the LOTO
• Each Contractor Worker on the LOTO
has their own personal lock
• Electrical equipment/extension cords in
good condition?
• Are tools and/or plugs grounded
(GFCI)?
Elevated Work Areas
• Openings in floors and walls guarded?
• Appropriate fall protection used?
Excavations
• All underground utilities identified?
• Proper agency contacted (i.e.
DIGSAFE)?
• Appropriate sloping and/or shoring?
• Hazardous conditions controlled?
• Means of entry and egress established?
• Work area access controlled?
Comments:

Page 1
Policy No.EHS-501 Contractor Safety – Appendix A.6

Sample Contractor Inspection Checklist – Page 2

General Safety Yes No Corrective Action

• Is work area free of debris and clutter?
• Is access to work areas, walkways,
exits, safety
showers, fire extinguishers
unobstructed?
• Are floors dry?
• Work area access controlled?
• Date of last fire extinguisher inspection?
Hand Tools
• Tools in good condition?
• Guards in place?
Hot Work (Welding, Cutting, Sparking)
• Hot work permit displayed?
• No flammable or combustible materials
in the area?
• Fire watch posted?
• Welding screen in place?
• Fire extinguishers nearby & charged?
• Means to report fires easily accessible?
• Appropriate PPE in use?
• Leads and gas hoses in good
condition?
Ladders and Scaffolds
• Ladders secured and tied off?
• Scaffold railings and toe boards secure?
Motorized Equipment
• All equipment inspected?
• All fork trucks, cranes, manlifts in good
working condition?
• All operators trained?
• Seat belts worn?
• Safe operating procedures followed?
Personal Protective Equipment (PPE)
Is all required PPE being worn?
• Safety Shoes
• Hard Hats
• Safety Glasses
• Hand/Arm protection
• Respiratory protection
• Hearing protection
Other:

Inspection Conducted By:

Contractor Date:
S
Facility i Date:
R i

Page 2
Policy No. EHS-102 Medical Records Appendix B

Medical Records Access Request Form

I, ____________________________________ (full name of worker / patient), hereby authorize

______________________________ (Individual or organization holding the medical records) to
release to ___________________________________ (Individual or Organization authorized to
receive the medical information), the following medical information from my personal medical
records:

(Describe generally the information desired to be released)

I give my permission for this medical information to be used for the following purpose:

But I do not give permission for any other use or re-disclosure of this information.

Other information or special requests:

(Describe any additional information that may be important to this request and
authorization such as (1) a particular expiration date of consent or authorization of this
letter, (2) medical information to be recorded in the future that this consent may cover, or
(3) describe portions of the medical records which you intend not to be released as a
result of this letter).
Full Name of Employee or Legal Representative:

Signature of Employee or Legal Representative:

Date of Signature:

Page 1
Policy No. EHS-104 EHS Management of Change Appendix C.1

EXAMPLES OF CHANGES AND REPLACEMENT-IN-KIND – Page 1

Examples of “Changes” (requiring the Management of Change Process):

• Introduction of a new chemical, or reintroduction of a chemical after an absence of 2 years or

more;

• Installation of new equipment, piping, electrical or control systems, or modifications to

existing equipment, piping, electrical, or control systems;

• Installation of a new building or structure, or modification of an existing building or structure;

• Shutdown of an operating facility for 6 months or more, or restart of a facility following a 6-

month idle period;

• Revision of a procedure or process parameter to allow operation outside of the well-

understood and documented “safe operating scenario”;

• Any procedural modification (new or existing) or change to a controlled document;

• Revision of a hardware or software control system, control scheme, or critical alarm limit;

• Any change in safety alarm settings, interlocks, and process trips;

• Any change in safety relief valve setting or capacity;

• Any repair or replacement NOT IN KIND, where either materials, material surfaces or
properties, testing, fabrication techniques, or applicable codes are changed;

• Any changes in safety or protective equipment as to location and type (fire protection,
alarms, vapor detection systems, etc.)

Page 1
Policy No. EHS-104 EHS Management of Change Appendix C.1

EXAMPLES OF CHANGES AND REPLACEMENT-IN-KIND – Page 2

Specific Examples of Activities Which Do NOT Constitute A Facility or Operational

Change (no Management of Change Process required):

• Replacement-In-Kind of equipment, Facility structures, piping, instrumentation, electrical

components, or any other piece of equipment or apparatus (replacement of equipment with
equipment having the same technical specifications);

• Change in set point of an operating guide alarm;

• Routine service changes of multiservice operating systems where the operating procedures
provide appropriate guidelines for such service changes, and where the procedures have
been subjected to a Facility or operational Review prior to becoming effective;

• Building modifications (interior redesign within an existing structure);

• Changes to computer control applications, unless the changes would appear on P&ID's;

• Operating procedures (or permits) that are in agreement with past operating practices.

These two lists are not intended to be all encompassing. These are only a few listed examples
and types. Each proposed change shall be reviewed to see if it meets the applicability criteria of
the Management of Change procedure and policy.

Page 2
Policy No. EHS-104 EHSManagement of Change Appendix C.2

CHANGE MANAGEMENT RECORD (CHANGE REQUEST FORM) – Page 1

Person Proposing Change: Date: System to be Modified:

Basis For Change (check all that apply):

Safety Operational Necessity Environmental Procedural

Economic New Material or Design Other:

_____________________________

Scope / Justification of Change:

Description:

Attach Pictures, Drawings, P&IDs, or Other Documents, as necessary.

Initial Review:

Signature: Date:

Final Review (Change Request Approval):

Signature: Date:

Page 1
Policy No. EHS-104 EHSManagement of Change Appendix C.2

CHANGE MANAGEMENT RECORD (CHANGE REQUEST FORM) – Page 2

CHECK ALL THAT APPLY REQ’D RESPONSIBILITY COMPLETION DATE INITIALS

Detailed Parts List / Cost

Process Hazard Review
Hazardous (New or
Revised) Material Review
Revised Operating
Procedures
Revised Maintenance
Procedures
Training (Operator or
Maintenance)
P&ID Update
Electrical Drawing Update
Spare Parts Review
Regulatory Agency
Permit
Safety Review - X
REQUIRED
Other:

Facility Change Request Completed:

Signature: Date:

THIS FORM MUST REMAIN ON SITE FOR THE DURATION OF THE POLICY OR
PROCEDURE

Page 2
Policy No. EHS-202 OSHA Inspection Procedure Appendix D.1

NOTICE TO OSHA

It is the policy of S&W Energy to cooperate with any governmental agency seeking to lawfully enforce
federal, state, or local laws and regulations pursuant to the safeguards guaranteed to us by the
Constitution of the United States.

S&W Energy is familiar with federal court decision and the ruling of the Supreme Court of the United
States in the Marshal v. Barlow’s, Inc. that all warrantless searches or inspections of company property,
or any portion thereof, conducted pursuant to Section 8(a) of the Occupational Safety and Health Act of
1970 are unconstitutional. Therefore, S&W Energy chooses to exercise its constitutional rights and will
not permit or is any employee of the Company authorized to permit, any search or inspection by any
representative of the Occupational Safety and Health Administration unless conducted pursuant to a
valid warrant.

S&W Energy does not believe that probable cause exists for an OSHA inspection of its property. In the
event that the Secretary of Labor believes otherwise and decides to make application for an inspection
warrant, S&W Energy hereby requests that it be given advance notice of such application so it can have
an opportunity to oppose the same.

This statement of policy has been reduced to writing and is being delivered in hand to each OSHA
representative seeking to make a warrantless search of our property so that OSHA will be officially
advised of everything stated herein.

This notice to OSHA was delivered in hand on the premises of the S&W Energy project to

, a representative of OSHA, by

, a representative of S&W Energy, on

, 20 at o’clock

Page 1
Policy No. EHS-202 OSHA Inspection Procedure Appendix D.2

NOTICE OF PROTEST

ProEnergy Services acknowledges the existence of an inspection warrant which appears on its face to
authorize an OSHA inspection to be conducted on these premises. The company does not believe that
the said warrant was issued pursuant to the law and does not believe that probable cause exists for the
warrant.

However, since the warrant is facially in proper form, the Company believes it could be cited for contempt
of court if it declined to allow the inspection to begin as stated in the warrant. The Company, therefore
will allow the inspection UNDER PROTEST. By so doing, we do not waive our right to challenge the
validity of the inspection or the authorization of its conduct and specifically preserve the right to do so
should any OSHA enforcement proceeding be commenced against this company, based on this
inspection or should there be any other reason to litigate this matter.

This Notice of Protest was delivered in hand on the premises of this company to

, a representative of

OSHA, by , a representative of

ProEnergy Services, on , 20 , at o’clock

Page 1
Policy No. EHS-301 OSHA Recordkeeping and Reporting Appendix E.1

OSHA RECORDABLE INCIDENT FLOWCHART

GUIDE TO RECORDABILITY CASES UNDER THE OCCUPATIONAL SAFETY AND HEALTH

ACT (OSHA)

If a CASE

NOTE: A CASE must involve a

Results from a work
death, an injury, or an illness to Does not result from
accident or from an an Employee a work accident or
exposure in the work from an exposure in
environment and is: the work environment

A An An Injury
Death Illness which
Involves:

Restriction of
Medical Loss of Transfer to None of These
Work or
Treatment other Consciousness Another Job
Motion
than First Aid

THEN CASE NOT TO

BE RECORDED
THEN CASE MUST BE RECORDED

Page 1
Policy No. EHS-301 OSHA Recordkeeping and Reporting Appendix E.2

OSHA RECORDABLE INCIDENT CHECKLIST

A. An occupational injury (caused by an instantaneous event in the work environment) is OSHA recordable
if at least one of the following items is checked:

Medical Treatment:

Treatment of INFECTION (application of nonprescription medication is considered first aid and not
recordable).
Application of ANTISEPTICS during second or subsequent visit
Treatment of SECOND or THIRD DEGREE BURN(S)
Application of SUTURES (stitches)
Application of BUTTERFLY ADHESIVE DRESSING(S) OR STERI STRIP(S) in lieu of stitches
Removal of FOREIGN BODIES EMBEDDED IN EYE if more than irrigation is required
Removal of FOREIGN BODIES FORM WOUND if procedure is more complicated than using
tweezers or other simple techniques
Use of PRESCRIPTION MEDICATIONS (except a single dose administered on the first visit for
minor injury or discomfort)
Use of HOT OR COLD SOAKING THERAPY during second or subsequent visit to medical
personnel
Application of HOT OR COLD COMPRESS(ES) during second or subsequent visit to medical
personnel
CUTTING AWAY DEAD SKIN (surgical debridement)
Application of HEAT THERAPY during second or subsequent visit to medical personnel
Use of WHIRLPOOL BATH THERAPY during second or subsequent visit to medical personnel
PHYSICAL THERAPY SESSIONS during second or subsequent visit to medical personnel
POSITIVE X-RAY DIAGNOSIS (fractures, broken bones, etc.)
ADMISSION TO A HOSPITAL or equivalent medical facility for medical treatment involving more
than one observation
Series of treatments given by a CHIROPRACTOR

2. Loss of Consciousness

3. Restriction of Work or Motion

Light duty / restricted work activity

Days away from work

4. Transfer to Another Job (as a result of an injury)

**IF ONE ITEM ABOVE IS CHECKED, THE WORK-RELATED INJURY IS ALMOST ALWAYS RECORDABLE**

B. An occupational illness (a case resulting from anything other than an instantaneous event in the
work environment) is always recordable. Work-related illnesses usually occur over time, and
result in both acute and chronic illnesses caused by inhalation, direct contact, etc. The difference
between a recordable injury and recordable illness is well-represented using a hearing loss
example. If a loss of hearing from an explosion (an instantaneous event) AND it fits into one of
the injury recordability criteria above, it is a recordable injury. If a loss of hearing resulted from
exposure to industrial noise over a period of time, it is a recordable illness. Another example of
a recordable illness is work-related carpal tunnel syndrome, because it is almost always results
from repetitious movement.

Page 1
Policy No. EHS-301 OSHA Recordkeeping and Reporting Appendix E.3

OSHA RECORDABILITY GUIDANCE – NOTES

When is an injury or illness considered work-related?

If an event or exposure in the work environment caused or contributed to the condition or significantly aggravated a
preexisting condition. Work-relatedness is presumed for injuries and illnesses resulting from events or exposures
occurring in the workplace, unless specifically noted otherwise. The work environment includes the establishments
and other locations where one or more employees are working or are present as a condition of their employment.
Which work-related injuries and illnesses do you record?
See Previous Recordability Flowchart
What are additional “Criteria” for recordability?
Record the following conditions if they are work-related:
• Any needle stick injury or cut from a sharp object that is contaminated with another person’s blood or other
potentially infectious material;
• Any case involving an employee to be medically removed under the requirements of an OSHA health standard;
• Any Standard Threshold Shift (STS) in hearing (i.e., cases involving an average hearing loss of 10dB or more
in one ear); and
• Tuberculosis infection as evidenced by a positive skin test or diagnosis by a physician or other licensed health
care professional.
What is First Aid?
If incident requires only the following types of treatment, consider it First Aid and NOT Recordable:

• Using non-prescription medications at non-prescription strength;

• Administering tetanus immunizations;
• Cleaning, flushing, or soaking wounds on the skin surface;
• Using wound coverings, such as bandages, Band-Aids, gauze pads, etc.
• Using hot or cold therapy;
• Using any totally non-rigid means of support, such as elastic bandages, wraps, no-rigid back belts, etc.;
• Using temporary immobilization devices while transporting an accident victim (splints, slings, neck collars, or
back boards);
• Drilling a toenail or fingernail to relieve pressure, or draining fluids from blisters;
• Using eye patches;
• Using simple irrigation or a cotton swab to remove foreign bodies not embedded in or adhered to the eye;
• Using irrigation, tweezers, cotton swab or other simple means to remove splinters or foreign material from
areas other than the eye;
• Using finger guards;
• Using massages;
• Drinking fluids to relieve heat stress.
Under what circumstances should you NOT enter employee’s name on the OSHA 300
Form:

• Any injury or illness to an intimate body part or to the reproductive system;

• An injury or illness resulting from a sexual assault;
• A mental illness;
• A case of HIV, hepatitis, or tuberculosis,
• A needle stick injury or cut from sharp object contaminated with blood or other infectious material;
• Other illnesses that an employee may request that his or her name not be entered on the Log.
Under these circumstances, “Privacy Case” should be entered in the space provided for “Employee Name”

Page 1
 Policy No. EHS-302 EHS Incident Reporting Appendix F.1

EHS INCIDENT REPORT FORM – PAGE 1

Incident Report #:

Facility / Site / Job Name: Location: Phone #:

GENERAL INFORMATION:
EMPLOYEE INVOLVED (if Injury/Illness/Fatality/Near Miss): TYPE OF INCIDENT:

S&W Energy Employee Injury/Illness/Fatality

Contractor ___________________________________________ Near Miss
(Company Name) Fire
Visitor Spill/Release
Customer Permit Violation
Other: ______________________________________________ Explosion
Not Applicable (if environmental/permit/spill related) Other:
__________________________________________

Date of Incident: Day of Week: Approximate Time (AM/PM): Shift:

IF PERMIT VIOLATION, EXCEEDANCE, or RELEASE:

TYPE OF PERMIT VIOLATION (ENVIRONMENTAL)

Air Description (NOx, SO2, CO, NH3, etc.):

____________________________________________

Permit Limit (include units): _________________________ Actual Reading (include units):

_______________________

Water Description (pH, heavy metals, oil&grease, etc.)

____________________________________

Permit Limit (include units): _________________________ Actual Reading (include units):

_________________________

Chemical Spill / Release Description (include name of chemical, off-site migration, and estimated quantity):
________________________________________________________________________________________________________

Other:
____________________________________________________________________________________________________

NOTIFICATIONS: DATE: TIME: CONTACT NAME / METHOD:

Facility/Site/Office Manager (Supervisor)
Customer Representative (if applicable)
S&W Energy EHS Manager

Page 1
 Policy No. EHS-302 EHS Incident Reporting Appendix F.1

EHS INCIDENT REPORT FORM – PAGE 2

INJURY / ILLNESS / NEAR MISS - PERSONNEL INFORMATION

Last Name: First Name Middle Initial: Age:

IF CONTRACTOR, Company Name: Phone: Company Contact Name:

Job Title: Type of Injury (Body Parts Injured):

Medical Treatment Provided (EMT or Hospital Name, Info):

DESCRIPTION OF INCIDENT – DETAILED SEQUENCE OF EVENTS:

(Attach additional pages as necessary)

WITNESSES OF INCIDENT (IF APPLICABLE):

Last Name: First Name: Middle Initial:

Last Name: First Name: Middle Initial:

Last Name: First Name: Middle Initial:

Page 2
 Policy No. EHS-302 EHS Incident Reporting Appendix F.2

EHS INCIDENT INVESTIGATION REPORT FORM

(Attach Additional Pages, If Necessary)
Reference Same Incident Report Number that Relates to this Investigation:
Incident Report #:

Facility / Site / Job Name: Location: Phone #:

INDIVIDUALS INTERVIEWED:
LAST NAME FIRST NAME MI JOB TITLE

DESCRIPTION OF CAUSES AS A RESULT OF INVESTIGATION: Who, When, Where and Why

FOLLOW-UP CORRECTIVE ACTIONS (Attach Additional Pages if Necessary):

Corrective Action(s) Responsible Estimated Actual
Person Completion Date Completion Date

INVESTIGATION TEAM:
Investigator: ________________________ ________________________ Job Title: ______________________ Date:
__________
Investigator: ________________________ ________________________ Job Title: ______________________ Date:
__________

CLOSURE APPROVAL:
Facility/Site/Office Manager, _____________________ ____________________ ________
Supervisor Print Signature Date

ALL CORRECTIVE ACTIONS MUST BE TRACKED TO CLOSURE AND CLOSURE APPROVED

Page 1
 Policy No. EHS-304 EHS Monthly Reporting, Field Service Appendix H

Field Service Monthly EHS Report Form

Facility / Site Name: Month: Year:

S&W Energy Injuries and Illnesses Month Year to

Date
Number of Recordable Injuries and Illnesses
Number of Recordable Injuries or Illnesses Involving Number: Number:
Days Away From Work (Include Number of Days Days: Days:
Missed)
Number of Recordable Injuries or Illnesses Involving Number: Number:
Days of Restricted Work Duty (Include Number of Days Days: Days:
w/ Restricted Work Duty)
Total Number of All S&W Energy Employee Hours Worked
– Combined

Facility Environmental Exceedances

Number of Air Permit Exceedances
Nitrogen Oxides (NOx):
Sulfur Dioxide (SO2):
Carbon Monoxide (CO):
Ammonia (NH3):
Other:
Number of Water Permit Exceedances
Wastewater:
Storm water:
Other:
Number of Reportable Spills and Releases

Agency Inspections
Number of Regulatory Agency EHS Inspections / Audits
Health & Safety:
Environmental:

Violations / Citations / Fines

Number of Violations / Citations / Notices of Non-
Compliance
Number of Fines Proposed (Include $ Amount)

Page 1
 S&W Energy Solutions (SWES) EHS Training Matrix - Appendix I

Regulatory S&W Best

Required Required Practice Regulatory Refresher Frequency Refresher
Course # EHS Course Title Topics Applicability (R) (S&W) (BP) Comments Reference (Y/N) (Yrs) Requirement
To inform employees on the
Accident Prevention, Signs meaning of various Danger and
1 & Tags Caution Signs and Tags All employees R 29CFR1910.145 (C) Y Every 3 years S&W

All employees (at least

To inform employees of the awareness). More
Ammonia Loading & proper handling, loading, & extensive course for those
2 Unloading unloading procedures handling Ammonia. S&W N/A Y Every 2 Years S&W

Methods of recognizing asbestos,

ACMs, & related health effects
associated w/ asbestos exposure,
operations that could result in
asbestos exposure, protective
controls, work practices, medical All employees - if proven
surveillance requirements, that site or work does not
communication reqs. INCLUDE conatin any asbestose or
Section on Fiber Management never will, this training is
(identification and hazards of optional. Required if
Asbestos Mgt. Awareness ceramic fibers other than handling (along with other
3 (Class IV) asbestos) required training). R 29CFR1910.1001(j) Y Annually 29CFR1910.1001(j)

To inform employees of safe lifting

practices, and ways to protect and
care for the back (can be inlcuded
4 Back Safety as part of Ergonomics training) All employees BP N/A Y Every 2 Years BP

To inform employees of methods

of minimizing occupational All employees who receive
exposure to HBV, HIV, etc. by first aid and/or CPR
5 Bloodborne Pathogens using universal precautions. training. R 29CFR1910.1030 Y Annually 29CFR1910.1030
For entry into confined spaces--
training, permitting, hazard All employees except
6 Confined Space Entry recognition Admin. R 29CFR1910.146(d) & (g) Y Every 2 Years S&W
Designated individuals,
depending on Site
requirements. These
indiviuals must also be
To train personnel on how to trained in First Aid, CPR,
Confined Space Rescue rescue someone from a confined and Bloodborne
7 Team - Classroom space Pathogens. R 29CFR1910.146(k) Y Annually 29CFR1910.146(k)

Page 1 of 7 2/19/2007
 S&W Energy Solutions (SWES) EHS Training Matrix Appendix I

Regulatory S&W Best

Required Required Practice Regulatory Refresher Frequency Refresher
Course # EHS Course Title Topics Applicability (R) (S&W) (BP) Comments Reference (Y/N) (Yrs) Requirement
To train personnel through
practical experience how to All confined space rescue
Confined Space Rescue rescue someone form a confined team members (may
8 Team Drill - Hands-On space include outside agencies) R 29CFR1910.146(k) Y Annually 29CFR1910.146(k)

Any person who is on a

confined space rescue
team, or designated
individuals (based on site
or contractor requirement)
must be trained in CPR.
All employees trained in
To inform and teach employees CPR must also be trained 29CFR1910.269 29CFR1910.269
9 CPR proper CPR techniques. in Bloodborne Pathogens. R 29CFR1910.146(k) Y Annually 29CFR1910.146(k)

Any employee assigned to

Crane-specific operations and operate/inspect cranes.
inspection. Inspection and use of Employees assigned to
slings and attachments. (Couple use/inspect slings and 29CFR1910.179
10 Crane & Rigging Safety training with Slings and Derricks) attachments. R 29CFR1910.184 Y Every 2 Years S&W
Defensive Driving (Use of Discussion of proper driving All employees who
Cars on Company techniques, attitudes, and safety operate vehicles for
11 Business) measures. company use. S&W N/A Y Every 3 years S&W

All employees who are

involved in maintenance
Recognition of energy sources and service of equipment
Energy Control & Power and the need to apply locks/tags under LOTO or who work
Lockout (EPCL) - to such sources to assure proper in areas where LOTO is 29CFR1910.147,
12 Lockout/Tagout (LOTO) deenergization for maintenance. being performed. R 29 CFR1910.269 Y Every 2 Years S&W
EHS Vision and Commitments.
Overview of envrionmental, health
13 EHS Awareness , & safety regulations. All employees BP Initial Only N/A N

Review S&W Energy Services

EHS Policy (include business
14 EHS Policy Drug & Alcohol Policy) All employees S&W N/A N Annually S&W

Page 2 of 7 2/19/2007
 S&W Energy Solutions (SWES) EHS Training Matrix Appendix I

Regulatory S&W Best

Required Required Practice Regulatory Refresher Frequency Refresher
Course # EHS Course Title Topics Applicability (R) (S&W) (BP) Comments Reference (Y/N) (Yrs) Requirement

Explain fundamentals of electrical

accidents. Define proper
procedures for identifying
energized equipment & working
on electrical equipment safely. All employees allowed to
Electrical Safety-- Define appropriate safe distances work on or near energized 29CFR1910.269(a)
15 QUALIFIED INDIVIDUAL to energized equipment. parts. R 29CFR1910.332(a) Y Annually S&W

Electrical Safety-- Explain fundamentals of electricity All employees other than

UNQUALIFIED and electrical safety (may be those identified as
16 INDIVIDUAL portion of Quailified training). Qualified Individuals S&W Initial Only N/A N

Emergency Action Plan - Explains actions to be taken by

17 Classroom employees during an emergency. All employees R 29CFR1910.38(a)(5) Y Annually S&W

Demonstrates preparedness of
Emergency Response / employees to respond to an
18 Action Plan - Drill emergency (INCLUDE Fire Drill) All employees S&W N/A Y Annually S&W
To inform employees on how to
report emergencies (can be
combined with Emergency Action
19 Employee Alarm Systems Plan Training) All employees R 29CFR1910.165(b) Y Annually S&W

Discussion of ergonomics, and

how to minimize potentially
20 Ergonomics harmful workplace situations. All employees R (Proposed) 29CFR1910.900 Y Every 3 years 29CFR1910.900
Proper inspection & use of fall
protection systems, stairways, All employees (except
21 Fall Protection ladders, etc. Admin) R 29CFR1926.503 Y Every 2 Years S&W
Familiarize employees with the
Fire Extinguisher (Portable) proper inspection and use of
22 Awareness portable fire extinguishers All Employees R 29CFR1910.157(g) Y Annually 29CFR1910.157(g)
Informs employees on the site fire
hazards of the materials and
Fire Prevention Plan - processes to which they are
23 Classroom exposed. All employees R 29CFR1910.38(b) Y Annually S&W
Demonstrates preparedness of
employees to respond to a fire
(INCLUDE as part of Emergency
24 Fire Prevention Plan-Drill Action Drill) All employees S&W N/A Y Annually S&W
Employees designated by
site or contractor
requirements. Designated
individuals must also be
To train employees on proper trained in Bloodborne
25 First Aid First Aid techniques. Pathogens. R 29CFR1910.151 Y Every 3 years 29CFR1910.151

Page 3 of 7 2/19/2007
 S&W Energy Solutions (SWES) EHS Training Matrix Appendix I

Regulatory S&W Best

Required Required Practice Regulatory Refresher Frequency Refresher
Course # EHS Course Title Topics Applicability (R) (S&W) (BP) Comments Reference (Y/N) (Yrs) Requirement
Any employee who
Awareness training on the packages, handles, labels,
DOT: Hazardous Material labeling, packaging, & shipping or is involved with
Transport Training- requirements for the transport of transport hazardous
26 Awareness hazardous materials materials R 49CFR172.704(a) Y Every 3 years 49CFR172.704(a)

Same as above HOWEVER

DOT: Hazardous Material includes additional information Employee designated to
Transport Training which allows employee to beocme sign hazardous material
27 CERTIFICATION certified to sign manifests manifests R 49CFR172.704(a) Y Every 3 years 49CFR172.704(a)

Awareness training on hazardous

waste classification, identification, All employees who are 40CFR262.16 40CFR262.16
Hazardous Waste storage, manifesting, labelling, associated with managing 40CFR265.16 40CFR265.16
28 Management land ban requirements (RCRA) hazardous waste R 40CFR262.34 Y Annually 40CFR262.34
All employees - training
must be given to those
employees working in
Discusses Material Safety Data areas where a new
Sheets (MSDSs), chemical chemical or material has
Hazard Communication labeling systems, facility specific been introduced, informing
29 (HAZCOM) chemicals and chemical hazards. of hazards. R 29CFR1200(h) Y Every 2 Years S&W

To inform employees who are

likely to discover a hazardous
Hazardous Waste substance release to initiate
Operations and Emergency appropriate emergency response
Response (HAZWOPER) actions by notifying the proper
30 Awareness Level people about the release. All employees R 29CFR1910.120(q) Y Annually 29CFR1910.120(q)

HAZWOPER - First To train employees to take

Responder Operations defensive actions in responding to All employees except Initial - 8 hours Annually - 8
31 Level a release of a haz. substance. Admin. R mandatory 29CFR1910.120(q) Y hours 29CFR1910.120(q)

To train employees to respond to

releases for the purpose of
HAZWOPER-Hazardous stopping the release, including All employees except Intial - 24 hours Annually - 8
32 Materials Technician Level taking offensive actions. Admin. R mandotory 29CFR1910.120(q) Y hours 29CFR1910.120(q)

Page 4 of 7 2/19/2007
 S&W Energy Solutions (SWES) EHS Training Matrix Appendix I

Regulatory S&W Best

Required Required Practice Regulatory Refresher Frequency Refresher
Course # EHS Course Title Topics Applicability (R) (S&W) (BP) Comments Reference (Y/N) (Yrs) Requirement

To inform employees how to

respond to hazardous materials
spills including taking offensive Any one who has Incident
actions to stop the release and to Commander
inform employees of skills & responsibilities as
HAZWOPER - On Scene knowledge needed to assume identified in Emergency Initial - 24 to 40 Annually - 8
33 Incident Commander Level control of the incident scene. Response Plan R hours mandatory 29CFR1910.120(q) Y hours 29CFR1910.120(q)

Effects of noise on hearing, All employees working in

purpose of hearing protection, areas which may be
audiometric testing, and subject to hearing
34 Hearing Protection explanation of testing procedures protection requirements. R 29CFR1910.95(k) Y Annually 29CFR1910.95(k)

Reporting, recordkeeping, and

investigations of EHS Incidents
Incident Reporting and (include OSHA Recordkeeping
35 Investigation and Reporting) All employees S&W N/A Y Every 3 years S&W

Recognition of potential exposures

to airborne concentrations of lead.
Information to idenitfy and plan for
related situations which may
necessitate special safety
precautions and which may impact All employees who may be
36 Lead Safety Awareness cost. affected R Initial Only 29CFR1910.1025(l) N

Employers will inform employees

of the location and availability of 29CFR1910.1020
37 Medical Records Access their medical records. All employees R 29CFR1926.33 Y Annually CFR1910.1020
To train employees about the
presence of PCBs onsite and
rules and regulations concerning All employees who may be
38 PCB Awareness PCBs. affected R 29CFR1910.1200 Y Every 2 Years S&W

To inform employees of their site-

specific air permit limits and All employees engaged in Every 3 years
monitoring requirements. Include air permit recordkeeping (or when
39 Permits, Air CEMs information, if applicable and reporting S&W N/A Y permits change) S&W

To inform employees of their site-

specific wastewater permit limits All employees engaged in
and monitoring requirements. wastewater permit Every 3 years
Include stormwater permitting, recordkeeping and (or when
40 Permits, Wastewater where applicable. reporting S&W N/A Y permits change) S&W

Personal Protective Identification and proper use of

41 Equipment (PPE) personal protective equipment. All employees R 29CFR132(f) Y Every 3 years S&W

Page 5 of 7 2/19/2007
 S&W Energy Solutions (SWES) EHS Training Matrix Appendix I

Regulatory S&W Best

Required Required Practice Regulatory Refresher Frequency Refresher
Course # EHS Course Title Topics Applicability (R) (S&W) (BP) Comments Reference (Y/N) (Yrs) Requirement
Every 3 years
(or when
Employees designated to evaluation
Powered Industrial Trucks Inspection requirements and safe operate and/or inspect proves more
42 (Forklifts) operation of fork trucks. forktrucks R 29CFR1910.178 Y frequent) 29CFR1910.178

Explain the purpose, proper use

and care of the respirator.
Discuss the characteristics of the
hazardous environment, and the
limitations of the respirator. All employees who may
Discuss different types and when need to don respirator
43 Respiratory Protection to use. during work activities. R 29CFR1910.134(a) Y Annually 29CFR1910.134(k)

All employees who may

Respiratory Protection FIT Quantitative or qualitative test to need to don respirator
44 TESTING ensure proper respirator fit. during work activities. R 29CFR1910.134(e) Y Annually 29CFR1910.134(e)

All employees who work

on a scaffold or who erect,
Explain requirements on scaffold dismantle, move, operate,
types, how to erect and dismantle, repair, maintain, or inspect 29CFR1910.28
45 Scaffolds operate and inspect scaffolds scaffolds. R 29CFR1926.454 Y Every 2 Years S&W

Any employee assigned to

Recognition of damage and operate/inspect derricks
defects in slings and all fastenings (cranes). Employees
and attachments. (Couple training assigned to use/inspect 29CFR1910.181(b)
46 Slings & Derricks with Cranes and Rigging) slings and attachments. R 29CFR1910.184(d) Y Every 2 Years S&W

To train employees on the

Spill Prevention Control operation and maintenance to Every 3 years or
and Countermeasures prevent the discharges of oil (may All employees except when plan
47 (SPCC) only apply to some Sites) Admin. R 40CFR110 and 112 Y changes 40CFR110 and 112

Employees who work with

chemicals must be able to
recognize the health and safety
effects regarding these chemicals
and understand the process of
Toxic Substances Control reporting an incident such as an
48 Act (TSCA) Section 8 adverse health effect. All employees R 40 CFR717 Y Annually 40 CFR717
Recognize the hazards relating to
ladders and stairs and minimize
49 Walking/Working Surfaces the dangers. All employees R 29CFR1910.106 Y Every 2 years S&W

Page 6 of 7 2/19/2007
 S&W Energy Solutions (SWES) EHS Training Matrix Appendix I

Regulatory S&W Best

Required Required Practice Regulatory Refresher Frequency Refresher
Course # EHS Course Title Topics Applicability (R) (S&W) (BP) Comments Reference (Y/N) (Yrs) Requirement
To inform employees of safe
welding, cutting, and brazing All employees engaged in 29CFR1910.252
50 Welding, Cutting, & Brazing practices (include Hot Work) welding/brazing operations R 29CFR1910.254 Y Every 2 years S&W

Page 7 of 7 2/19/2007
 Policy No. EHS-402 EHS Auditing Process Appendix J

S&W Energy EHS Audit Findings Tracking Form

AUDIT CONTACT NAME / EXPECTED

TYPE FINDING TYPE / FINDING RESPONSIBLE COMPLETION
EHS CATEGORY DESCRIPTION CORRECTIVE PERSON FINDING DATE DATE STATUS
ACTION
 Policy No. EHS-502 Rev. 2 Control of Hazardous Energy (Lockout/Tagout)
Appendix K.1

Index for Lockout / Tagout Control Sheets

Control Sheet Date / Time Shift Supervisor Date / Time Shift Supervisor
Number Hung: Authorizing Description of Work Cleared: Authorizing
Hanging Clearing
Policy No. EHS-502 Rev.2 Control of Hazardous Energy (Lockout/Tagout)
Appendix K.2

S&W Energy Authorized Personnel List

________________ (Facility / Site Name)
Designated Shift
Supervisor or Lead
Tech?
NAME TITLE Y/N
Policy No. EHS-502 Rev.2 Control of Hazardous Energy (Lockout/Tagout)
Appendix K.3

ANNUAL LOCK-OUT/TAG-OUT (LOTO) AUDIT FORM

Name of Auditor / Inspector: ________________________ Date of Audit: ________________

This Form is meant to be used as a Guide to assist in the Annual Audit of the Facility / Site LOTO Program. The
audit should be a review of the topics addressed in each of the questions posed below. Interviews will need to be
conducted and records and documentation will need to be reviewed to get proper results. The Audit is required to
ensure the proper measures are being implemented to provide a safe and effective LOTO program and to remain in
compliance with regulatory standards.
Please expand on the questions listed below and attach additional sheets, if necessary (or use back of Form). This
Form, and any associated paperwork, shall be signed, dated, and kept on file at the Facility / Site. Any deficiencies
or action items resulting from this inspection should be documented and followed-up to implement the proper
corrections.

1. Does the Facility / Site have a written Lock-Out / Tag-Out (LOTO) Procedure? Y or N

• Has the Facility / Site implemented and trained Employees on the LOTO Procedure? Y or N
• Date of Last LOTO Training Given: ______________________________________

2. Has the Facility / Site defined all areas and equipment where LOTO is required (inventory)? Y or N

• Has the Facility / Site generated Equipment Specific LOTO Procedures (ESLPs) for
“Major Equipment”? Y or N
• Are these ESLPs written and documented? Y or N
• Do they meet the requirements as outlined in the Procedure? Y or N

3. Are Employees provided with locks and tags? Y or N

4. Are all employees trained to recognize equipment or systems which has been locked out and/or tagged out and
shall not be operated until the LOTO lifted (random sample of employee interviews)? Y or N

5. Are only trained and authorized employees permitted to Lock and Tag out equipment? Y or N

6. Is ALL Facility / Site equipment capable of being locked out with the unit completely isolated and completely
de-energized? Y or N

Please indicate those pieces of equipment or systems which are not capable of being
locked out and provide reasons why they are not.
_____________________________________________________________________
_____________________________________________________________________
_____________________________________________________________________
_____________________________________________________________________

7. Does the LOTO procedure address verification of de-energized equipment? Y or N

8. Does the LOTO procedure address shift change? Y or N

9. Does the LOTO procedure address Contractors? Y or N

10. Randomly review open and closed LOTO’s to determine if correct paperwork is being filed and that the LOTO’s
are being performed and closed according to the Procedure. Specifically identify any deficiencies. Use additional
sheets or back of this form, as necessary.
 ATTACHMENT EHS-502 Rev 2 K.4 - LOCKOUT / TAGOUT CONTROL SHEET
DATE AND TIME SHEET OPENED DATE AND TIME CLOSED NUMBER PAGE OF _
_

EQUIPMENT DESCRIPTION: __________________________ _____________________________________________________________________________

WORK SCOPE FOR LOCKOUT/DANGER TAGOUT AND WORK TO BE COMPLETED PRIOR TO RELEASE:
_____________________________________________________________________________________________________________________________________________

REFERENCES, DRAWINGS USED FOR LOCKOUT/TAGOUT PREPARATION.

______________________________________________________________________________________________________________________________________________

LOTO Requested By: LOTO Authorized By:

Lock / Tag Lock / Tag

LOCK # / TAG NAME AND NUMBER OF Energy Isolating Hung By: LOTO Removed By: Cleared
LETTER Device (DESCRIPTION) Initials / Date Position Initials / Date Position
/
/
/
/
/
/
/
/
/
/
/
/
/
/

Test Release Authorization: Date/Time ____________ Authorized By _______________________ Authorized Employee _______________

OVER PLEASE...
Title Sign On Date & Time Sign Off Date & Time

Shift Supervisor

Authorized Employee /Contractor

Authorized Employee/Contractor

Authorized/ Employee /Contractor

Authorized Employee /Contractor

Authorized Employee /Contractor

Authorized Employee /Contractor

Authorized Employee /Contractor

Authorized Employee /Contractor

Authorized Employee /Contractor

Authorized Employee /Contractor

Authorized Employee /Contractor

LOTO Clearance Authorized By _________________________________________ Date/Time _____________________________

Each Authorized Employee must sign on & sign off to work under this control sheet. By signing on the tagout, the Authorized Employee indicates he has walked down the
system and has initialed all the tags on the tagout. Locks & Tags cannot be removed until all Authorized Employee(s) and the Shift Supervisor have signed off. Maintenance
requiring more than one Authorized Employee will require each employee to sign on and off at the beginning and the end of the job. The Authorized Employee in charge of the job
must be indicated next to the sign-on.
TRANSFER OF AUTHORIZED EMPLOYEE IN CHARGE

When one Authorized Employee in charge starts a job and another Authorized Employee in charge will finish the job, the responsibility as the Authorized Employee in-charge must
be transferred by signing below. During extended maintenance shutdowns where the job may take several days, the authorized employees in charge for each shift may sign on and
write their shift time by their signature, then once the job is completed they sign off.

Sign-On Sign-Off Sign-On Sign-Off

_____________________________ _____________________________ __________________________ ___________________________

_____________________________ ____________________________ __________________________ ____________________________

____________________________ ____________________________ ___________________________ ____________________________

 Policy No. EHS-503 Personal Protective Equipment Appendix L.1

S&W Energy
Personal Protective Equipment Inventory

Facility: Date: Page Of

INSTRUCTIONS: Complete the Personal Protective Equipment (PPE) Inventory for each article of PPE currently used
at the Facility. Under the PPE type, enter the manufacturer, model and style of PPE available. Enter the PPE in order
by the affected body part, such as eye and face, hand, head, foot, body, respiratory, and hearing. Provide a hazard
description for each article of PPE and assign a Part # for reference.

PPE Type Body Part Hazard Description Part # Quantity Available

Example: Lab Safety, Neoprene Hand Chemical Burns XX-YY 4 pair
Gloves, black
 Policy No. EHS-503 Personal Protective Equipment Appendix L.2

S&W Energy
Job Hazard Assessment Form

Job Title: Page Of

Analysis By: Title: Date:
Review By: Title: Date:
New Approved By: Date Approved:
Revised Facility Manager:
Required and/or Recommended PPE:

Sequence of Basic Job Steps Potential Hazards Recommended Action / Procedure

Annual Review:
Reviewer / Date: _______________ Reviewer / Date: _______________ Reviewer / Date: _______________
Reviewer / Date: _______________ Reviewer / Date: _______________ Reviewer / Date: _______________

Page 1
 Policy No. EHS-504 Respiratory Protection Appendix M.1

S&W Energy
Respirator Specification Form
Facility: Employee’s Name: Date:

Job Description:

Contaminant
3
Estimated or Actual Contaminant(s): Concentration Level: (ppm or mg/m )

Nature of Contaminant: Gas, Vapor, or Particulate (circle one) Warning Properties: (i.e. odor)

If a gas or vapor, is there any absorbent that traps it? Yes No Explain:

Could Contaminant(s) become IDLH? Yes No Explain:

If flammable, does concentration approach LEL? Yes No Explain:

Is contaminant(s) an eye irritant? Yes No Explain:

Can contaminant(s) be absorbed through the skin? Yes No Explain:

OSHA Permissible Exposure Level, ACGIH TLV or NIOSH REL:

Respirator

Recommended Respiratory Protection

First Choice:
Make: Model #: Type:
Second Choice:
Make: Model #: Type:
Characteristics of respirator:

Limitations of respirator:

NIOSH Approval Numbers: Respirator Identification:

Page 1
Policy No. EHS-504 Respiratory Protection Appendix M.2

GUIDANCE ON DEVELOPMENT OF CARTRIDGE CHANGE-OUT SCHEDULES – Page 1

OSHA regulation 29 CFR 1910.134 no longer allows a contaminant’s warning properties (smell, taste, or irritation)
to be used to determine cartridge breakthrough. The user must have a respirator equipped with a NIOSH approved
end-of-service-life indicator (ESLI) for the specific contaminant or must use a cartridge change-out schedule for the
specific cartridge and contaminant. Currently, there are limited cartridges equipped with an ESLI. Therefore, at
this time a cartridge change-out schedule is the only viable option for those cartridges that will be used.

This document is intended to provide guidance in establishing their specific change-out schedules. This guidance
is only a starting point for developing such a program. Each site’s program will be different due to individual site
characteristics that must be included in any change-out schedule determinations.

Manufacturer Consultation
The best course of action in establishing a cartridge change-out schedule is to consult the manufacturer of the
cartridge. The following information has been obtained for commonly used safety product providers.

Company Web Site Phone Number

North Safety Products http://www.safetyonline.net/north/ 1-800-430-4110
3M –Occupational Health and http://www.mmm.com/market/safety/ohes2/index. 1-800-896-4223
Environmental Safety Products html
MSA Safety Products http://www.msanet.com/safetyproducts/index.html 1-800-MSA-2222

The following information is provided to assist you in understanding the various issues surrounding the
establishment of a cartridge change-out schedule, to provide recommendations for establishing a change-out
program and to provide resources for obtaining further detailed information.

Precautions When Using Data to Establish Your Change Schedule

The following is a partial list of factors which may affect the usable cartridge service life and/or the degree of
respiratory protection attainable under actual workplace conditions. These factors should be considered when
developing a cartridge change-out schedule.

• Type of contaminant(s)
• Contaminant concentration
• Relative humidity
• Breathing rate
• Temperature
• Changes in contaminant concentration, humidity, breathing rate and temperature
• Mixtures of contaminants: (1) multiple contaminants present simultaneously versus (2) alternate usage of the
same cartridges against different contaminants on different occasions
• Accuracy in the determination of the conditions
• The contaminant concentration in the workplace can vary greatly. Consideration must be given to the quality
of the estimate of the workplace concentration.
• Cartridge storage conditions (exposure to trace levels of contaminants and humidity and elevated
temperatures)
• Storage conditions between multiple uses of the same respirator cartridges. It is recommended that the
chemical cartridges be replaced after each work shift. Contaminants adsorbed on a cartridge can migrate
through the carbon bed without airflow. Desorption of the contaminant (including those with poor warning
properties) after partial use of the chemical cartridge can occur after a short period (hours) without use (e.g.,
overnight) and result in a non-use exposure to someone nearby.
• Age of the cartridge
• Condition of the cartridge and respirator
• Respirator and cartridge selection
• Respirator fit
• Respirator assembly, operation, and maintenance
• User training, experience and medical fitness

Page 1
Policy No. EHS-504 Respiratory Protection Appendix M.2

GUIDANCE ON DEVELOPMENT OF CARTRIDGE CHANGE-OUT SCHEDULES – Page 2

• Warning properties of the contaminant

• The quality of the warning properties should be considered when establishing the chemical cartridge change
schedule.
• Good warning properties may provide a secondary or back-up indication for cartridge change-out. Change
schedules for contaminants with poor warning properties may require a greater safety factor than a
contaminant with good warning properties.
• Other conditions specific to the particular user and/or workplace

Information excerpted from MSA’s Cartridge Change Test Program available on the Internet at
http://www.msanet.com/safetyproducts/resptest/index.html

Non-Organic Vapor Contaminants

Both MSA and North Safety Products have performed end of service life estimations for non-organic vapor
contaminants. Test data indicating recommended change out schedules for these cartridges can be found at
http://www.msanet.com/safetyproducts/resptest/dataindex.stm – the MSA Respirator Test Data Index and at
http://SafetyOnline.net/north/feature1.htm – on the North Safety Products esLife EZ Service Life Estimation Table.

Organic Vapor Contaminants

For organic vapor contaminants that have a boiling point of less than 149°F (65°C), the user must change
cartridges no less frequently than at the end of each work shift, even if a service life estimate would permit less
frequent cartridge changes. Organic vapors with this characteristic may desorb from the charcoal in the cartridge
when not in use overnight. This leaves high concentrations of contaminant in the cartridge housing free to move
into the respirator mask when use is resumed, exposing the user to the contaminant and the risk of serious injury or
illness.

Poor Warning Properties

If a change-out schedule is developed for use against a organic vapor contaminant with poor warning properties
(i.e. smell, taste, or irritation or above the permissible exposure limit), the user loses the ability to determine if the
change-out schedule is adequate and the respirator is functioning properly because the user will not be able to
detect breakthrough. For this reason, it is not recommended to use air-purifying respirators for such contaminants
even though OSHA does not prohibit the use of air purifying respirators for protection against contaminants having
poor warning properties. For protection against contaminants having poor warning properties, a supplied air
respirator should be used.

Information excerpted from the North Safety Products esLife Service Life Estimation CD-ROM website located on
the Internet at http://SafetyOnline.net/north/feature1.htm

Existing Warning Properties

For organic vapor contaminants that have warning properties (smell, taste, irritation etc.), OSHA recommends
following these rules of thumb for establishing a change-out schedule for organic vapor cartridges:

• If a chemical’s boiling point is greater than 70°C and the concentration is less than 200 ppm you can expect a
service life of 8 hours at a normal work rate.
• Service life is inversely proportional to work rate.
• Reducing concentration by a factor of ten will increase service life by a factor of five.
• Humidity above 85% will reduce service life by 50%.
Note: These generalizations should only be used with another method of predicting service life for specific contaminants.

Information excerpted from Appendix A of OSHA Directive CPL 2-0.120 - Inspection procedures for the Respiratory
Protection Standard. This document can be found on the Internet at http://www.osha-
slc.gov/OshDoc/Directive_toc/toc_for_CPL.html.

Page 2
Policy No. EHS-504 Respiratory Protection Appendix M.2

GUIDANCE ON DEVELOPMENT OF CARTRIDGE CHANGE-OUT SCHEDULES – Page 3

Particulate Contaminants
The new 42 CFR Part 84 regulation provides for nine classes of filters (three levels of filter efficiency, each with
three categories of resistance to filter efficiency degradation). The three levels of filter efficiency are 95%, 99%, and
99.97%. The three categories of resistance to filter efficiency degradation are labeled N, R, and P. The class of
filter will be clearly marked on the filter, filter package, or respirator box. For example, a filter marked N95 would
mean an N-series filter that is at least 95% efficient. Chemical cartridges that include particulate filter elements will
carry a similar marking that pertains only to the particulate filter element.

The new classes of non-powered particulate respirators require new decision logic for selection of the proper
respirator. The selection process for using the new particulate classification is summarized as follows:

1. The selection of N-, R-, and P-series filters depends on the presence or absence of oil particles, as follows:

• If no oil particles are present in the work environment, use a filter of any series (i.e., N-, R-, or P-series).

• If oil particles (e.g., lubricants, cutting fluids, glycerin, etc.) are present, use an R- or P-series filter. Note: N-
series filters cannot be used if oil particles are present.

• If oil particles are present and the filter is to be used for more than one work shift, use only a P-series filter.

2. Selection of filter efficiency (i.e., 95%, 99%, or 99.97%) depends on how much filter leakage can be accepted.
Higher filter efficiency means lower filter leakage.

3. The choice of face piece depends on the level of protection needed--that is, the assigned protection factor
(APF) needed.

Note: To help you remember the filter series, use the following guide:
N for Not resistant to oil, R for Resistant to oil, P for oil Proof

Use Limitations of Particulate Respirators

The service life of all three categories of filters efficiency degradation (i.e., N-, R-, and P-series) is limited by
considerations of hygiene, damage, and breathing resistance. All filters should be replaced whenever they are
damaged, soiled, or causing noticeably increased breathing resistance (e.g., causing discomfort to the wearer).
R- or P-series filters can be used for protection against oil or non-oil aerosols. N-series filters should be used only
for non-oil aerosols. Use and reuse of the P-series filters would be subject only to considerations of hygiene,
damage, and increased breathing resistance. Generally, the use and reuse of N-series filters would also be subject
only to considerations of hygiene, damage, and increased breathing resistance. However, for dirty workplaces that
could result in high filter loading (i.e. 200 mg), service time for N-series filters should be extended beyond 8 hours
of use (continuous or intermittent) by performing an evaluation in specific workplace settings that: (a) demonstrates
extended use will not degrade the filter efficiency below the efficiency level specified in Part 84, or (b) demonstrates
the total mass loading of the filter(s) is less than 200mg. The R-series filters should be used only for a single shift
(or for 8 hours of continuous or intermittent use) when oil is present. However, service time for the R-series filters
can be extended using the same two methods described above for N-series filters. These determinations would
need to be repeated whenever conditions change or modifications are made to processes that could change the
type of particulate generated in the user's facility.

A list of Particulate Respirators Certified Under 42 CFR Part 84 is available on the Internet at
http://www.cdc.gov/niosh/p84intro.html

Information was excerpted from the NIOSH Guide to the Selection and Use of Particulate Respirators Certified
Under 42 CFR 84, DHHS (NIOSH) Publication No. 96-101, January 1996 that can be found on the Internet at
http://www.cdc.gov/niosh/userguid.html.

Page 3
Policy No. EHS-504 Respiratory Protection Appendix M.3

RESPIRATOR CARTRIDGE SELECTION CHART

Color-coding identifies cartridges manufactured for each type of contaminant. The following chart is provided to aid
in selecting the proper cartridge.

A T M O S P H E R IC C O N T A M IN A N T C O L O R A S S IG N E D
A cid G as W h ite
A cid G as & O rg an ic V apo r Y ello w
A m m on ia G as G reen
D ust, F um es & M ists (O th er th a n ra d io ac tiv e m a teria ls) O ra n ge
O rg an ic V ap o rs (E x ce p t tritiu m & N o b le g a ses ) B la ck
O th er V ap o rs & G ases n o t listed ab o v e O liv e

References: Information for this chart is taken from ANSI K13.1-1973, Identification of Air Purifying Respirator
Canisters and Cartridges.

Note: 1. A purple stripe shall be used to identify radioactive materials in combination with any
vapor or gas.

2. An orange stripe shall be used to identify dust, fumes, and mists in combination with
any vapor or gas.

3. Where labels only are colored to conform to this table, the canister or cartridge body
shall be grey or a metal canister body may be left in its natural metallic color.

The user shall refer to the wording of the label to determine the type and degree of protection the canister or
cartridge will afford.

Page 1
Policy No. EHS-504 Respiratory Protection Appendix M.4

OSHA Respirator Medical Evaluation Questionnaire

CFR 1910.134- Appendix C

The Occupational Safety and Health Administration requires the use of the following questionnaire initially
as part of our respiratory protection program. Please complete the form and return it to the physician and /
or health care provider utilized by your Facility. Lung tests and physical exams are only required currently
if deemed necessary by the physician or licensed health care provider after reviewing your answers. You
will have the opportunity to discuss your responses with the health care provider if you chose or have a
physical examination if deemed necessary, and then be given a copy of a written opinion. You may also
request a copy of the questionnaire and exam. If you have any questions about this form or related to
your ability to wear a respirator, please ask your physician or health care provider.

To the employer: Answers to questions in Section 1, and to question 9 in Section 2 of Part A, do not require a
medical examination.

To the employee: Can you read (circle one): Yes / No

Your employer must allow you to answer this questionnaire during normal working hours, or at a time and place
that is convenient to you. To maintain your confidentiality, your employer or supervisor must not look at or review
your answers, and your employer must tell you how to deliver or send this questionnaire to the health care
professional who will review it.

Part A. Section 1. (Mandatory) The following information must be provided by every employee who has been
selected to use any type of respirator (please print).

NAME:____________________________________DATE:_______________________________

AGE:_______ SEX:_______ HEIGHT: __________ft. _________in. WEIGHT_________lb.

JOB HELD/APPLIED FOR:________________________________SS#____________________

1. A phone number where you can be reached by the health care professional who reviews this
questionnaire: ( ) _____ - ____
2. The best time to call you at this number:__________________________

3. Has your employer told you how to contact the health care professional who will review this questionnaire:
YES / NO (see top of page instructions)

4. Check the type of respirator you will use (you can check more than one category):
a._______ N,R, or P disposable respirator (filter-mask, non-cartridge type only).
b._______ Other type (half or full-face piece type, powered-air purifying, supplied-air, self-contained breathing apparatus).

5. Have you worn a respirator: Yes/No If “yes” what type(s):

If you have answered this questionnaire in the past, please answer the questions in this box. If you check
yes on any of these questions, then answer all the questions on the next 2 pages. If you answer no to the
questions in this box STOP, skip to the 3rd page and sign your name at the bottom. No further exam is
needed.
1) Do you have any medical concerns or problems wearing a respirator? Yes____ No ____
2) Were you sent to be evaluated because someone else thought you were having problems or you failed
your “fit” test because of a possible health problem? Yes____ No____
3) Have there been any significant changes in what you do, such as: a) increased physical effort, b)
increased temperature in your work area, or c) increased use of personal protective clothing? Have
these changes caused you any problems when wearing your respirator? Yes____ No____

Page 1
Policy No. EHS-504 Respiratory Protection Appendix M.4

OSHA Respirator Medical Evaluation Questionnaire

Part A. Section 2. (Mandatory) Questions 1 through 9 below must be answered by every employee who has
been selected to use any type of respirator.
1. Do you currently smoke tobacco, or have you smoked tobacco in the last month: YES/NO

2. Please place a check before any conditions you have ever had :
a._____ Seizures (fits)
b._____ Diabetes (sugar disease)
c._____ Allergic reactions that interfere with your breathing
d._____ Claustrophobia (fear of closed-in places)
e._____ Trouble smelling odors

3. Have you ever had any of the following pulmonary or lung problems?
a._____ Asbestosis g.______ Silicosis
b._____ Asthma h.______ Pheumothorax (collapsed lung)
c._____ Chronic bronchitis i.______ Lung cancer
d._____ Emphysema j.______ Broken ribs
e._____ Pneumonia k.______ Any chest injuries or surgeries
f.______ Tuberculosis l.______ Any other lung problem that you’ve been told about

4. Do you currently have any of the following symptoms of pulmonary or lung illness?
a._____ Shortness of breath
b._____ Shortness of breath when walking fast on level ground or walking up a slight hill or incline
c._____ Shortness of breath when walking with other people at an ordinary pace on level ground
d._____ Have to stop for breath when walking at your own pace on level ground
e._____ Shortness of breath when washing or dressing yourself
f._____ Shortness of breath that interferes with your job
g._____ Coughing that produces phlegm (thick sputum)
h._____ Coughing that wakes you early in the morning
i._____ Coughing that occurs mostly when you are lying down
j._____ Coughing up blood in the last month
k._____ Wheezing
l._____ Wheezing that interferes with your job
m._____ Chest pain when you breathe deeply
n._____ Any other symptoms that you think may be related to lung problems

5. Have you ever had any of the following cardiovascular or heart problems?
a._____ Heart attack e._____ Swelling in your legs or feet (not caused by walking)
b._____ Stroke f._____ Heart arrhythmia (irregular heart beat)
c._____ Angina g._____ High blood pressure
d._____ Heart failure h._____ Any other heart problems that you’ve been told about

6. Have you ever had any of the following cardiovascular or heart symptoms?
a._____ Frequent pain or tightness in your chest
b._____ Pain or tightness in your chest during physical activity
c._____ Pain or tightness in your chest that interferes with your job
d._____ In the past two years, have you noticed your heart skipping/missing a beat
e._____ Heartburn or indigestion that is not related to eating
f._____ Any other symptom that you think may be related to heart or circulation problems

7. Do you currently take medication for any of the following problems?

a._____ Breathing or lung problems
b._____ Heart trouble
c._____ Blood pressure
d._____ Seizures

Page 2
Policy No. EHS-504 Respiratory Protection Appendix M.4

OSHA Respirator Medical Evaluation Questionnaire

8. If you’ve used a respirator, have you ever had any of the following problems?
a._____ Eye irritation
b._____ Skin allergies or rashes
c._____ Anxiety
d._____ General weakness or fatigue
e._____ Any other problem that interferes with your use of a respirator

9. Would you like to talk to the health care professional who will review this questionnaire about your answers to this
questionnaire? YES/NO

A “Yes” answer to any question, 1-8, in Section 2 will require a follow-up examination.
______________________________________________________________________________________________________
_____

Questions 10 to 15 below must be answered by every employee who has been selected to use either a full-face
piece respirator or a self-contained breathing apparatus (SCBA). For employees who have been selected to use
other types of respirators, answering these questions is voluntary. Everyone is requested to sign the form
at the bottom.
10. Have you ever lost vision in either eye (temporarily or permanently): YES / NO

11. Do you currently have any of the following vision problems?

a._____ Wear contact lenses c._____ Color blind
b._____ Wear glasses d._____ Any other eye or vision problem

12. Have you ever had an injury to your ears, including a broken eardrum? YES / NO

13. Do you currently have any of the following hearing problems?

a._____ Difficulty hearing
b._____ Wear a hearing aid
c._____ Any other hearing or ear problems

14. Have you ever had a back injury? YES/NO

15. Do you currently have any of the following musculoskeletal problems?

a._____ Weakness in any of your arms, hands, legs, or feet
b._____ Back pain
c._____ Difficulty fully moving you arms and legs
d._____ Pain or stiffness when you lean forward or backward at the waist
e._____ Difficulty fully moving your head up or down
f._____ Difficulty fully moving head side to side
g._____ Difficulty bending at your knees
h._____ Difficulty squatting to the ground
i._____ Climbing a flight of stairs or a ladder carrying more than 25 lbs.
j._____ Any other muscle or skeletal problem that interferes with using a respirator

Employee Signature:__________________________ Date:_____________

Examiners Signature:_________________________ Date:_____________

Examiner or designated representative- For subsequent years, after initial qualification to wear a respirator
using this questionnaire; the employee does not need a medical evaluation if the ‘boxed’ questions on page 1 are
all answered (no).
If this is the case, please indicate below with an X:

_______ This employee does not need further medical evaluation at this time. Fit testing is authorized, if indicated.

Page 3
 Policy No. EHS-504 Respiratory Protection Appendix M.5

Fit Test Protocol

General Fit-Testing Requirements

1. The following criteria shall be used to help determine the adequacy of the respirator fit:
Chin properly placed;
Adequate strap tension, not overly tightened;
Fit across nose bridge;
Respirator of proper size to span distance from nose to chin;
Tendency of respirator to slip;
Self-observation in mirror to evaluate fit and respirator position.

2. The employee shall conduct a user seal check, either the negative and positive pressure seal checks. Before conducting
the negative and positive pressure checks, the subject shall be told to seat the mask on the face by moving the head from
side-to-side and up and down slowly while taking in a few slow deep breaths. Another face piece shall be selected and
retested if the employee fails the user seal check tests.

3. The test shall not be conducted if there is any hair growth between the skin and the face piece-sealing surface, such as
stubble beard growth, beard, mustache or sideburns which cross the respirator-sealing surface. Any type of apparel which
interferes with a satisfactory fit shall be altered or removed.

4. If a employee exhibits difficulty in breathing during the tests, she or he shall be referred to a physician or other licensed
health care professional, as appropriate, to determine whether the employee can wear a respirator while performing her or
his duties.

5. If the employee finds the fit of the respirator unacceptable, the employee shall be given the opportunity to select a different
respirator and to be retested.

6. Exercise regimen. Prior to the commencement of the fit test, the employee shall be given a description of the fit test and
the employee's responsibilities during the test procedure. The description of the process shall include a description of the
test exercises that the subject will be performing. The respirator to be tested shall be worn for at least 5 minutes before the
start of the fit test.

7. The fit test shall be performed while the employee is wearing any applicable safety equipment that may be worn during
actual respirator use which could interfere with respirator fit.

8. The following test exercises are to be performed for all fit testing. The employee shall perform exercises, in the test
environment, in the following manner:
Normal breathing. In a normal standing position, without talking, the subject shall breathe normally.
Deep breathing. In a normal standing position, the subject shall breathe slowly and deeply, taking caution so as not to
hyperventilate.

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 Policy No. EHS-504 Respiratory Protection Appendix M.5

Fit Test Protocol

Turning head side to side. Standing in place, the subject shall slowly turn his/her head from side to side between the
extreme
positions on each side. The head shall be held at each extreme momentarily so the subject can inhale at each side.
Moving head up and down. Standing in place, the subject shall slowly move his/her head up and down. The subject shall be
instructed to inhale in the up position (i.e., when looking toward the ceiling).
Talking. The subject shall talk out loud slowly and loud enough so as to be heard clearly by the test conductor. The subject can
read
from a prepared text such as the Rainbow Passage (see below), count backward from 100, or recite a memorized poem or song
Bending over. The employee shall bend at the waist as if he/she were to touch his/her toes.
Normal breathing. Same as exercise (1).

9. Each test exercise shall be performed for one minute except for the grimace exercise which shall be performed for 15
seconds. The employee shall be questioned by the test conductor regarding the comfort of the respirator upon completion
of the protocol. If it has become unacceptable, another model of respirator shall be tried. The respirator shall not be
adjusted once the fit test exercises begin. Any adjustment voids the test, and the fit test must be repeated.

Isoamyl Acetate (IAA) Qualitative Fit Test (QLFT) Protocol

NOTE: This protocol is not appropriate to use for the fit testing of particulate respirators. If used to fit test particulate
respirators, the respirator must be equipped with an organic vapor filter.

1. The fit test chamber shall be a clear 55-gallon drum liner suspended inverted over a 2-foot diameter frame so that the top
of the chamber is about 6 inches above the employee's head. If no drum liner is available, a similar chamber shall be
constructed using plastic sheeting. The inside top center of the chamber shall have a small hook attached.

2. Each respirator used for the fitting and fit testing shall be equipped with organic vapor cartridges or offer protection against
organic vapors.

3. After selecting, donning, and properly adjusting a respirator, the employee shall wear it to the fit testing room. This room
shall be separate from the room used for odor threshold screening and respirator selection, and shall be well ventilated, as
by an exhaust fan or lab hood, to prevent general room contamination.

4. A copy of the test exercises and any prepared text from which the subject is to read shall be taped to the inside of the test
chamber.

5. Upon entering the test chamber, the employee shall be given a 6-inch by 5-inch piece of paper towel, or other porous,
absorbent, single-ply material, folded in half and wetted with 0.75 ml of pure IAA. The employee shall hang the wet towel
on the hook at the top of the chamber. An IAA test swab or ampule may be substituted for the IAA wetted paper towel
provided it has been demonstrated that the alternative IAA source will generate an IAA test atmosphere with a
concentration equivalent to that generated by the paper towel method.

Page 2
 Policy No. EHS-504 Respiratory Protection Appendix M.5

Fit Test Protocol

6. Allow two minutes for the IAA test concentration to stabilize before starting the fit test exercises. This would be an
appropriate time to talk with the employee; to explain the fit test, the importance of his/her cooperation, and the purpose for
the test exercises; or to demonstrate some of the exercises.

7. If at any time during the test, the subject detects the banana-like odor of IAA, the test is failed. The subject shall quickly
exit from the test chamber and leave the test area to avoid olfactory fatigue.

8. If the test is failed, the subject shall return to the selection room and remove the respirator. The employee shall repeat the
odor sensitivity test, select and put on another respirator, return to the test area and again begin the fit test procedure
described in steps 1 through 7 above. The process continues until a respirator that fits well has been found. Should the
odor sensitivity test be failed, the subject shall wait at least 5 minutes before re-testing. Odor sensitivity will usually have
returned by this time.

9. If the subject passes the test, the efficiency of the test procedure shall be demonstrated by having the subject break the
respirator face seal and take a breath before exiting the chamber.

10. When the employee leaves the chamber, the subject shall remove the saturated towel and return it to the person
conducting the test, so that there is no significant IAA concentration buildup in the chamber during subsequent tests. The
used towels shall be kept in a self-sealing plastic bag to keep the test area from being contaminated.

Page 3
Policy No. EHS-504 Respiratory Protection Appendix M.6

Respirator Fit Test Documentation Form

Name of Employee Tested:_______________________________

Date:____________________________

Expiration Date: _____________________________________

Type of Fit Test: (check one)

Qualitative Quantitative

Isoamyl Acetate Test used? Yes No

Fit Factor and Strip Chart Recording Attached? Yes No

Smoke Irritant Test used? Yes No

Other recordings of the test? Yes No

Respirator Information:

Make: _______________________________

Model: _____________________________________________

Style: _______________________________

Size: _______________________________________________

Results: Pass Fail

Retain this record until the next fit test is administered (annually if not sooner).

cc: Employees training record

Page 1
 Policy No. EHS-504 Respiratory Protection Appendix M.7

Respirator Cleaning and Disinfection Procedure

1. Remove filters, cartridges, or canisters.

2. Disassemble face pieces by removing speaking diaphragms, demand and pressure-demand valve
assemblies, hoses, or any components recommended by the manufacturer. Discard or repair any
defective parts.

3. Wash components in warm (110 deg. F [43 deg. C] maximum) water with a mild detergent or with a
cleaner recommended by the manufacturer. A stiff bristle (not wire) brush may be used to facilitate the
removal of dirt.

4. Rinse components thoroughly in clean, warm (110 deg. F [43 deg. C] maximum), preferably running
water. Drain.

5. When the cleaner used does not contain a disinfecting agent, respirator components should be
immersed for two minutes in one of the following:

a. Hypochlorite solution (50 ppm of chlorine) made by adding approximately one milliliter of laundry bleach to one
liter of water at 110 deg. F [43 deg. C] or,

b. Aqueous solution of iodine (50 ppm iodine) made by adding approximately 0.8 milliliters of tincture of iodine (6-
8 grams ammonium and/or potassium iodide/100 cc of 45% alcohol) to one liter of water at 110 deg. F [43 deg.
C] or,

c. Other commercially available cleansers of equivalent disinfectant quality when used as directed, if their use is
recommended or approved by the respirator manufacturer.

6. Rinse components thoroughly in clean, warm (110 deg. F [43 deg. C] maximum), preferably running
water. Drain. The importance of thorough rinsing cannot be overemphasized. Detergents or disinfectants
that dry on face pieces may result in dermatitis. In addition, some disinfectants may cause deterioration
of rubber or corrosion of metal parts if not completely removed.

7. Components should be hand-dried with a clean lint-free cloth or air-dried.

8. Reassemble face piece, replacing filters, cartridges, and canisters where necessary.

9. Test the respirator to ensure that all components work properly.

Page 1
 Policy No. EHS-504 Respiratory Protection Appendix M.8

SCBA Inspection
Inspect Monthly & After Each Use

SCBA Location: Unit / ID #

Date: Inspected
by:

Functional check of SCBA Sat / Corrective Action Inspector

Unsat Initials
Alarm Works Properly
Regulator Functions Properly
Facepiece: Clean, not distorted, no tears, no cracks
Elastic Parts: Pliable no deterioration
Head Harness: Clean, no tears, no cracks no missing
pieces. No loss of elasticity. No wear from buckle.
Lens: Clean & Clear, no cracks, sealed to mask
Exhalation Valve: Clean, good seal, no tears, tight
Inhalation Valve: Clean, good seal, no tears, tight
Cylinder: No dents or gouges, fits tightly in band
Cylinder Hydro Test Date _______________
Gage: Cylinder >90% full, check gage face, indicator
Harness: Clean, no wear, fully extended
Demand Valve O-ring: clean, no tears, seated properly
SCBA Cleaned and reassembled after inspection &
drying

If any defects are found DO NOT USE RESPIRATOR.

Turn in the respirator to your supervisor immediately for repair or
replacement.

Page 1
 Policy No. EHS-505 Hearing Protection and Conservation Appendix N.1

AREA / PERSONAL NOISE MONITORING RESULTS

DATE / TIME OF TEST:

COMMENTS / ADDITIONAL FACTORS:

AREAS WITH NOISE LEVELS EXCEEDING 85 dBA:

AREA NOISE LEVEL

RETAIN RECORDS INDEFINITELY

(This form can be used for area and/or personal noise monitoring survey results. In all
cases, please provide additional information, i.e., area or personal, TWA’s, etc., as
applicable.)

Page 1
 Policy No. EHS-504 Hearing Protection and Conservation Appendix N.2

S&W Energy
Hearing Protection and Conservation Program Auditing Checklist

REQUIREMENT YES NO ACTION REQUIRED /

COMMENTS
Are feasible engineering and/or administrative controls
considered for implementation or utilized to keep noise
exposures within allowable limits?
Where sound levels exceed an 8-hour exposure of 85
dBAs, is a continuing effective hearing conservation
program administered? (This procedure includes all
elements of required hearing conservation program)
Does S&W Energy make hearing protection available
to all employees exposed to an 8-hour TWA of 85
decibels or greater?
Are noise levels measured using a sound level meter
(for area surveys) or a noise dosimeter (for personal
surveys) and are records of these levels being
recorded and maintained on file?
Where engineering controls are not feasible, are
administrative controls (i.e., worker rotation) being
considered for implementation or used to minimize
individual employee exposure to noise?
Is there an on-going program to educate and train
employees in safe levels of noise and exposure,
effects of noise on their health, and use of personal
protection?
Is approved hearing protective equipment (noise
attenuating devices) available to every employee
working in noisy areas? Are the attenuating devices
appropriate for the areas (properly rated equipment
used)?
If you use ear protectors, are employees properly
fitted and instructed in their use?
Are employees in high noise areas given periodic
(annual) audiometric testing to ensure that S&W
Energy has an effective hearing protection system?

Page 1
 Policy No. EHS-509 Fall Protection Appendix O.1

S&W Energy
Fall Hazard Assessment / Inventory

Location Reason(s) for Access Fall Hazard

Work at Unprotected Heights at or Exceeding 4 Feet
Ladders
Lifts
Wall or Floor Openings
Railcars and Vehicles
Other: ____________________________________

Work at Unprotected Heights at or Exceeding 4 Feet

Ladders
Lifts
Wall or Floor Openings
Railcars and Vehicles
Other: ____________________________________

Work at Unprotected Heights at or Exceeding 4 Feet

Ladders
Lifts
Wall or Floor Openings
Railcars and Vehicles
Other: ____________________________________

Work at Unprotected Heights at or Exceeding 4 Feet

Ladders
Lifts
Wall or Floor Openings
Railcars and Vehicles
Other: ____________________________________

Work at Unprotected Heights at or Exceeding 4 Feet

Ladders
Lifts
Wall or Floor Openings
Railcars and Vehicles
Other: ____________________________________

Work at Unprotected Heights at or Exceeding 4 Feet

Ladders
Lifts
Wall or Floor Openings
Railcars and Vehicles
Other: ____________________________________

Facility: Location:

Contact: Date of Evaluation:

Page 1
 Policy No. EHS-509 Fall Protection Appendix O.2

Fall Protection Evaluation Form

Location of Fall Hazard:

Reason For Work / Task:

Description of Fall Hazard:

Work at Unprotected Heights Exceeding 4 Feet Ladders

Wall or Floor Openings Lifts

Railcars / Vehicles
Other:
______________________________________________________________________
Fall Protection Equipment Category:

Fall Arrest Positioning

Suspension Retrieval
Other:
______________________________________________________________________
Equipment Required:

Type Equipment Location Inspection Frequency

Location of Anchor Point:

Description of Use Procedures:

Maintenance and Storage of Equipment:

Limitations and Precautions:

Facility: Location:

Contact: Date of Evaluation:

Page 1
 Policy No. EHS-510 Powered Industrial Trucks Appendix P.1

INDUSTRIAL TRUCK DESIGNATIONS

Designation / Classification
Description
Similar to G classification but are Diesel engine powered instead of Gasoline
D engine powered.
DS Diesel powered and provided with additional safeguards to the exhaust, fuel, and
electrical systems. (May be used in some locations where a D-unit may not be
suitable).
DY Diesel powered that have all the safeguards of the DS classification and in
addition do not have any electrical equipment (including ignition) and equipped
with temperature limitation features.

E Electrically powered having minimum acceptable safeguards against inherent

fire hazards.
ES Electrically powered, including all safeguards as the E classification with
additional safeguards to the electrical system to prevent emission of hazardous
sparks and to limit surface temperatures. (May be used in some locations where
an E-unit may not be suitable).
EE Electrically powered, including all safeguards as an E and ES classification,
where the electric motor and all other electrical equipment is completely
enclosed. (May be used in some locations where an E- or ES-unit may not be
suitable).
EX Electrically powered, different from the E, ES, and EE classifications in that the
electrical fittings and equipment are so designed that the units may be used in
certain atmospheres containing flammable vapors or dust.

G Gasoline powered having minimum acceptable safeguards against inherent fire

hazards.
GS Gasoline powered, including all safeguards as the G classification with additional
safeguards to the exhaust, fuel, and electrical systems. (May be used in some
locations where a G-unit may not be suitable).

LP Similar to the G unit, only Liquefied Petroleum Gas (LPG) is used as fuel instead
of Gasoline
LPS Liquefied Petroleum Gas (LPG) powered including additional safeguards to the
exhaust, fuel, and electrical systems. (May be used in some locations where an
LP-unit may not be suitable).

Page 1
Policy No. EHS-510 Powered Industrial Trucks Appendix P.2

Daily Forklift Checklist

[ X ] Needs Attention [ √ ] OK [ N/A ] Not Applicable to This Unit
Items Requiring Attention Must Be Reported To The Shift Supervisor Immediately

Date: From _____________ To _______________

Item to be checked Sun Mon Tue Wed Thu Fri Sat

Engine Oil
Engine Oil Leaks
Trans. Oil
Trans. Oil Leaks
Hyd. Oil
Hyd. Oil Leaks
Hyd. Hoses
Engine Coolant
Radiator Hoses
Fuel
Tires
Seat Belt
All Control Functions
Gauges
Brakes
Parking Brake
Safety Devices
Back-Up Alarm
Horn
Lights
Overhead Guards
Fire Extinguisher

Comments:

Operators Signature

Page 1
Policy No. EHS-510 Powered Industrial Trucks Appendix P.3

PERFORMANCE TEST
FOR FORK TRUCK OPERATORS

Employee Name Date Time

1. Shows familiarity with truck controls.

2. Gave proper signals when turning.

3. Slowed down at intersections.

4. Sounded horn at intersections.

5. Obeyed signs.

6. Kept a clear view of direction of travel.

7. Turned corners correctly - was aware of rear end swing.

8. Yielded to pedestrians.

9. Drove under control and within proper traffic aisles.

10. Approached load properly.

11. Lifted load properly.

12. Maneuvered properly.

13. Traveled with load at proper height.

14. Lowered load smoothly/slowly.

15. Stops smoothly/completely.

Page 1
Policy No. EHS-510 Powered Industrial Trucks Appendix P.3

PERFORMANCE TEST
FOR FORK TRUCK OPERATORS

16. Load balanced properly.

17. Forks under load all the way.

18. Carried parts/stock in approved containers.

19. Checked bridgeplates/ramps.

20. Did place loads within marked area.

21. Did stack loads evenly and neatly.

22. Did drive backward when required.

23. Did check load weights.

24. Did place forks on the floor when parked, controls neutralized, brake on set, power off.

25. Followed proper instructions for maintenance - checked both at beginning and end.

TOTAL SCORE: ____________

RATING EVALUATOR: ___________________________

ADDITIONAL COMMENTS:

Page 2
Policy No. EHS-512 Fire Protection and Prevention Appendix Q.1

CLASSES OF FIRES & APPROPRIATE FIRE EXTINGUISHERS

Every fire extinguisher is rated for the class or classes of fire it is designed to extinguish. An
extinguisher may be rated A, BC, or ABC. An extinguisher solely rated for a Class A fire will not
adequately extinguish a Class B, C, or D fire. In some cases, the improper type of extinguisher
may spread the fire.

Class A and B extinguishers also carry a numerical rating to indicate the extinguishing potential
of the unit. The numerical rating indicates how large a fire an experienced person can safely put
out with that unit.

Class A Fire

Fires that occur in ordinary materials such as wood, paper, rags, and rubbish. The quenching
and cooling effects of water or of solutions of containing large percentages of water are of first
importance in extinguishing these fires.

Class A Extinguishers
Class A extinguishers work by cooling the lit material to a temperature below its ignition
temperature and soaking the material to prevent re-ignition. Class A extinguishers typically use
pressurized water, foam, or multi-purpose dry chemicals to extinguish a fire of ordinary
combustible materials.

Class B Fire

Fires that occur in the vapor-air mixture over the surface of flammable liquids such as gasoline,
oil, grease, paints, and thinners. The limiting of air is of primary importance. Generally, regular,
dry chemical, multipurpose dry chemical, carbon dioxide and foam may be sued depending on
the circumstances of the fire. Solid streams of water are likely to spread the fire but on large
fires of this class, water fog nozzles prove effective.

Class B Extinguishers
Foam, carbon dioxide, and dry chemicals are typical agents used in a Class B fire extinguisher.
Class B extinguishers extinguish flammable liquids or gases by removing the oxygen and
preventing the vapors from reaching their ignition temperature.

Class C Fire

Fires that occur in or near electrical equipment where non-conducting extinguishing agents shall
be used. Dry chemical, carbon dioxide, compressed gas or vaporizing liquid may be used.
Foam or solid stream of water should NOT be used because both are good conductors and can
expose the operator to severe shock.

Class C Extinguishers
Energized electrical equipment is extinguished by using Class C extinguishers. Class C
extinguishers contain an agent that is not capable of conducting an electric charge, such as

Page 1
Policy No. EHS-512 Fire Protection and Prevention Appendix Q.1

carbon dioxide or dry chemicals. Water extinguishers or extinguishers with agents capable of
conducting an electric current are never to be used on Class C fires.

Class D Fires

Fires that occur in combustible metals such as magnesium, titanium, zirconium, lithium, and
sodium. Specialized techniques, extinguishing agents and equipment are needed to control and
extinguish fires of this type. Normal extinguishing agents generally should not be used, as there
is danger in most cases of increasing intensity of the fire because of a chemical reaction
between some extinguishing agents and the burning metal.

Class D Extinguishing Agents

Class D extinguishing agents are specifically designed for the material involved and should only
be used on Class D fires. Class D extinguishing agents work by absorbing the heat from the
ignited material and cooling it below its ignition temperature. Class D extinguishers are used to
respond to fire involving flammable metals.

All S&W Energy employees who are responsible for responding to incipient stage fires should
be properly trained on the use of portable fire extinguishers.

The PASS method is a common method for using a portable fire extinguisher:

• Pull the pin to unlock the handle.

• Aim low at the base of the fire.
• Squeeze the handle while holding the extinguisher upright.
• Sweep the extinguisher from side to side, covering the fire with the extinguishing agent.

Page 2
 Policy No. EHS-512 Fire Protection and Prevention Appendix Q.2

Fire Prevention Checklist

Electrical Equipment
† No makeshift wiring † Fuse and control boxes clean and closed
† Extension cords serviceable † Circuits properly fused or otherwise protected
† Motors and tools free of dirt and grease † Equipment approved for use in hazardous areas (if
† Lights clear of combustible materials required)
† Safest cleaning solvents used † Ground connections clean and tight and have electrical
continuity
Friction
† Machinery properly lubricated † Machinery properly adjusted and/or aligned
Special Fire-Hazard Materials
† Storage of special flammables isolated † Nonmetal stock free of tramp metal
Welding And Cutting
† Area surveyed for fire safety † Combustibles removed or covered
† Permit issued
Open Flames
† Keep away from spray rooms and booths † Portable torches clear of flammable surfaces
† No gas leaks
Portable Heaters
† Set up with ample horizontal and overhead † Safely mounted on noncombustible surface
clearances † Not used as rubbish burners
† Secured against tipping or upset † Use of steel drums prohibited
† Combustibles removed or covered
Hot Surfaces
† Hot pipes clear of combustible materials † Soldering irons kept off combustible surfaces
† Ample clearance around boilers and furnaces † Ashes in metal containers
Smoking And Matches
† “No smoking” and “smoking” areas clearly marked † No discarded smoking materials in prohibited areas
† Butt containers available and serviceable
Spontaneous Ignition
† Flammable waste materials in closed, metal † Piled material, cool, dry, and well ventilated
containers † Trash receptacles emptied daily
† Flammable waste material containers emptied
frequently
Static Electricity
† Flammable liquid dispensing vessels grounded or † Proper humidity maintained
bonded
† Moving machinery grounded
Housekeeping
† No accumulations of rubbish † Premises free of unnecessary combustible materials
† Safe storage of flammables † No leaks or dripping of flammables and floor free of spills
† Passageways clear of obstacles † Fire doors unblocked and operating freely with fusible links
† Automatic sprinklers unobstructed intact
Extinguishing Equipment
† Proper type † In working order
† In proper location † Service date current
† Access unobstructed † Personnel trained in use of equipment
† Clearly marked

Page 1
 Policy No. EHS-512 Fire Protection and Prevention Appendix Q.3

Fire Extinguisher Inventory Form

Serial or ID Number Location in the Facility Status of Equipment

Page 1
 Policy No. EHS-513 Confined Space Entry Appendix R.1

CONFINED SPACE ENTRY PERMIT – PAGE 1 of 2

ALL PAGES OF THIS PERMIT WILL REMAIN POSTED AT THE ENTRANCE TO THE CONFINED SPACE FOR THE
DURATION OF THE PERMIT VALID DATES

Description of Confined Space: _________________________________________________ Date: ______________________

PERMIT VALID: FROM __________________ TO __________________________

Purpose of Entry: ______________________________________________

Proof of Isolation: LOTO# ____________

Permits Associated with Entry: Hot Work, identify _______________________ Other: _____________
Entry Supervisor(s) (includes Contractor Entry Supervisor)

Authorized Entrant(s) (includes Contractors)

Current Attendant(s)

List of Possible Hazards Present Yes No Measures to Isolate, Eliminate, or Control Hazard
Limited Means of Entrance / Egress Lifeline / Safety Harness
Hazardous Atmosphere Forced Ventilation or Continuous Monitoring
Potential For Engulfment / Drowning Purge and Block or Isolate Inlet Valve
Electrical Hazard Proof of Isolation (LOTO Permit)
Welding or Cutting Hot Work Permit
Oxygen Deficiency Forced Ventilation, Continuous Monitoring
Toxics Forced Ventilation, Continuous Monitoring
Flammables Forced Ventilation, Continuous Monitoring, Non-Sparking
Tools, Fire Extinguisher and Low Voltage Lighting
Slipping / Tripping / Falling Lifeline / Safety Harness
Chemicals (Known or Likely) Purge & Flush
Others: Others:

Special Requirements Yes No Special Requirements Yes No

Fire Extinguisher on standby? Protective Clothing?
Lifeline / Escape Harness? Respirator(s)?
Low Voltage Lighting (12V or less)? SCBA(s) on standby?

Identify Communication: _______________________ Secure Area (Caution Tape, etc.)?

Identify Rescue Procedures: ____________________ Tripod Emergency / Escape Unit?

IN EMERGENCY CALL (Facility Emergency Number)

Page 1
 Policy No. EHS-513 Confined Space Entry Appendix R.1

CONFINED SPACE ENTRY PERMIT – PAGE 2 of 2

ALL PAGES OF THIS PERMIT WILL REMAIN POSTED AT THE ENTRANCE TO THE CONFINED SPACE FOR THE
DURATION OF THE PERMIT VALID DATES

Test Results
Tests to be Permissible Test 1 Test 2 Test 3 Test 4
Taken Exposure
(Valid for one Limit Time: Time: Time: Time:
shift only)
Percent of Oxygen 19.5 - 23.5%
Percent L.E.L. <10%
Carbon Monoxide 35 PPM
Ammonia 25 PPM
Hydrogen Sulfide 10 PPM
Other

Continuous / Periodic tests shall be established before entry. For any questions pertaining to test results contact the person(s) shown below:

Tester(s) Date Time

Test Instrument(s) Used Model # Serial # / Calibration Date

ENTRY CANNOT BE MADE IF ANY REQUIREMENT IS LEFT BLANK OR PERMISSIBLE EXPOSURE LEVELS
(PELs) ARE EXCEEDED.

SPACE RE-CLASSIFIED AS NON-PERMIT REQUIRED CONFINED SPACE:

Temporarily (valid only for time span of Permit) Permanently

For Permanent re-classification, file this page with the Confined Space Inventory Form.

I have reviewed the work authorized by this permit and the information
contained herein. Written instructions and safety procedures have been
received and understood.
Contractor Supervisor authorizing all entry conditions satisfied:______________________________________________
Signature / Date / Time

Shift or Entry Supervisor authorizing all entry conditions satisfied: _______________________________________

Signature / Date / Time
After Work Completion: All personnel are out of the Confined Space and the Space is OK to return to normal
conditions

__________________________/___________/________(Signature of Entry or Shift Supervisor / Date / Time)

Page 2
 Policy No. EHS-513 Confined Space Entry Appendix R.2

Confined Space Pre-Entry Checklist

Prior to entry, all safety equipment and services required to support the entry personnel while in the confined
space and to provide a means of rescue, should be collected, inspected and tested to ensure functional
integrity. The following steps are recommended actions to take prior to entry.

Pre-Entry Checklist Yes No N/A / Comments

1. Set up and test
a. the communication systems
b. tripod/hoist
c. cables
d. hooks
e. ratchets
f. winches
2. Inspect
a. full body harness webbing
b. “D” rings
c. buckles
d SCBA masks
e. hoses
f. regulators
g. oxygen
3. If using an air-purifying respirator, verify the correct cartridges are available in
sufficient quantity to permit replacement when needed and at least every
eight (8) hours;
4. Check all alarms which will be relied upon to notify entrants and the attendant
of an emergency;
5. Set up the air mover/blower
a. attach hoses
b. test run the blower
c. set up and test the oxygen/gas meter
6. Obtain a copy of any applicable MSDS in the event it is necessary to
provide it to the emergency response units or medical facilities; check to
determine
a. short term exposure limits (STEL)
b. threshold limit value (TLV)
c. permissible exposure limit (PEL),
d. determine the immediately dangerous to life (IDLH) level
e. check to ensure appropriate PPE has been selected and is on hand
7. Check
a. lights
b. extension cords
c. welding cables for broken or frayed insulation
d. fittings on oxygen/acetylene cutting torches
e. hoses for leaks
8. Verify emergency phone numbers, emergency response unit, and current first
aid/CPR training of all proposed entrants.

Entry Supervisor Signature:____________________________________ Date: ___________________________

Any additional equipment that will actually be taken into the confined space must be inspected to insure it
is in safe working condition and that it will not create a hazard to the entrants.

Page 1
 Annual EHS Training Tracking Record

CALENDAR RR PR
YEAR: 2000
1 - Accident Prevention,
Site / Location: XYZ Signs & 2 - Ammonia Loading and
Tags (3) Unloading (2)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
I&C Technician John Doe 123-45-6789 9/6/2000 No 9/6/2003

RR = Regulatory Required
PR = PES Required
BP = Best Practice
Ref. Completed = Refresher Completed, NO or DATE
Next Ref. Req. By = Next Refrsher Required, DATE or NA
(0) = Initial Only Required
(1) = Annual Refresher
(2) = Refresher Every 2 Years

Employee Training
EHS Page 1 of 50 2/19/2007
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CALENDAR RR PR
YEAR: 2000
1 - Accident Prevention,
Site / Location: XYZ Signs & 2 - Ammonia Loading and
Tags (3) Unloading (2)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
(3) = Refresher Every 3 Years

Employee Training
EHS Page 2 of 50 2/19/2007
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CALENDAR RR BP
YEAR: 2000
3 - Asbestos Mgt.
Site / Location: XYZ Awareness 4 - Back
(Class IV) (1) Safety (2)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
I&C Technician John Doe 123-45-6789

RR = Regulatory Required
PR = PES Required
BP = Best Practice
Ref. Completed = Refresher Completed, NO or DATE
Next Ref. Req. By = Next Refrsher Required, DATE or NA
(0) = Initial Only Required
(1) = Annual Refresher
(2) = Refresher Every 2 Years

Employee Training
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CALENDAR RR BP
YEAR: 2000
3 - Asbestos Mgt.
Site / Location: XYZ Awareness 4 - Back
(Class IV) (1) Safety (2)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
&C (3) = Refresher Every 3 Years 123 6 89

Employee Training
EHS Page 4 of 50 2/19/2007
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CALENDAR RR RR
YEAR: 2000

Site / Location: XYZ 5 - Bloodborne 6 - Confined Space Entry

Pathogens (1) -2
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial (2) Ref. Completed Next Ref. Req. By:
I&C Technician John Doe 123-45-6789

RR = Regulatory Required
PR = PES Required
BP = Best Practice
Ref. Completed = Refresher Completed, NO or DATE
Next Ref. Req. By = Next Refrsher Required, DATE or NA
(0) = Initial Only Required
(1) = Annual Refresher
(2) = Refresher Every 2 Years

Employee Training
EHS Page 5 of 50 2/19/2007
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CALENDAR RR RR
YEAR: 2000

Site / Location: XYZ 5 - Bloodborne 6 - Confined Space Entry

Pathogens (1) -2
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial (2) Ref. Completed Next Ref. Req. By:
&C (3) = Refresher Every 3 Years 123 6 89

Employee Training
EHS Page 6 of 50 2/19/2007
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CALENDAR RR RR
YEAR: 2000
7 - Confined Space 8 - Confined Space
Site / Location: XYZ Rescue Team Rescue Team
Classroom (1) Drill (1)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
I&C Technician John Doe 123-45-6789

RR = Regulatory Required
PR = PES Required
BP = Best Practice
Ref. Completed = Refresher Completed, NO or DATE
Next Ref. Req. By = Next Refrsher Required, DATE or NA
(0) = Initial Only Required
(1) = Annual Refresher
(2) = Refresher Every 2 Years

Employee Training
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CALENDAR RR RR
YEAR: 2000
7 - Confined Space 8 - Confined Space
Site / Location: XYZ Rescue Team Rescue Team
Classroom (1) Drill (1)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
&C (3) = Refresher Every 3 Years 123 6 89

Employee Training
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CALENDAR RR RR
YEAR: 2000

Site / Location: XYZ 10 - Crane &

9 - CPR (1) Rigging Safety (2)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
I&C Technician John Doe 123-45-6789

RR = Regulatory Required
PR = PES Required
BP = Best Practice
Ref. Completed = Refresher Completed, NO or DATE
Next Ref. Req. By = Next Refrsher Required, DATE or NA
(0) = Initial Only Required
(1) = Annual Refresher
(2) = Refresher Every 2 Years

Employee Training
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CALENDAR RR RR
YEAR: 2000

Site / Location: XYZ 10 - Crane &

9 - CPR (1) Rigging Safety (2)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
&C (3) = Refresher Every 3 Years 123 6 89

Employee Training
EHS Page 10 of 50 2/19/2007
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CALENDAR PR RR
YEAR: 2000
12 - Energy Control &
Site / Location: XYZ 11 - Defensive Power Lockout (EPCL)
Driving (3) Lockout / Tagout (LOTO) (2)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
I&C Technician John Doe 123-45-6789

RR = Regulatory Required
PR = PES Required
BP = Best Practice
Ref. Completed = Refresher Completed, NO or DATE
Next Ref. Req. By = Next Refrsher Required, DATE or NA
(0) = Initial Only Required
(1) = Annual Refresher
(2) = Refresher Every 2 Years

Employee Training
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 Annual EHS Training Tracking Record

CALENDAR PR RR
YEAR: 2000
12 - Energy Control &
Site / Location: XYZ 11 - Defensive Power Lockout (EPCL)
Driving (3) Lockout / Tagout (LOTO) (2)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
&C (3) = Refresher Every 3 Years 123 6 89

Employee Training
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CALENDAR BP PR
YEAR: 2000

Site / Location: XYZ 13 - EHS 14 - EHS

Awareness (0) Policy (1)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
I&C Technician John Doe 123-45-6789 NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
RR = Regulatory Required
PR = PES Required
BP = Best Practice
Ref. Completed = Refresher Completed, NO or DATE
Next Ref. Req. By = Next Refrsher Required, DATE or NA
(0) = Initial Only Required
(1) = Annual Refresher
(2) = Refresher Every 2 Years

Employee Training
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CALENDAR BP PR
YEAR: 2000

Site / Location: XYZ 13 - EHS 14 - EHS

Awareness (0) Policy (1)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
&C (3) = Refresher Every 3 Years 123 6 89

Employee Training
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CALENDAR RR PR
YEAR: 2000

Site / Location: XYZ 15 - Electrical Safety 16 - Electrical Safety

Qualified (1) UnQualified (0)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
I&C Technician John Doe 123-45-6789 NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
RR = Regulatory Required
PR = PES Required
BP = Best Practice
Ref. Completed = Refresher Completed, NO or DATE
Next Ref. Req. By = Next Refrsher Required, DATE or NA
(0) = Initial Only Required
(1) = Annual Refresher
(2) = Refresher Every 2 Years

Employee Training
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CALENDAR RR PR
YEAR: 2000

Site / Location: XYZ 15 - Electrical Safety 16 - Electrical Safety

Qualified (1) UnQualified (0)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
&C (3) = Refresher Every 3 Years 123 6 89

Employee Training
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CALENDAR RR PR
YEAR: 2000
17 - Emergency 18 - Emergency
Site / Location: XYZ Action Plan Response/Action Plan
Classroom (1) Drill (1)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
I&C Technician John Doe 123-45-6789

RR = Regulatory Required
PR = PES Required
BP = Best Practice
Ref. Completed = Refresher Completed, NO or DATE
Next Ref. Req. By = Next Refrsher Required, DATE or NA
(0) = Initial Only Required
(1) = Annual Refresher
(2) = Refresher Every 2 Years

Employee Training
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CALENDAR RR PR
YEAR: 2000
17 - Emergency 18 - Emergency
Site / Location: XYZ Action Plan Response/Action Plan
Classroom (1) Drill (1)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
&C (3) = Refresher Every 3 Years 123 6 89

Employee Training
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CALENDAR RR RR
YEAR: 2000

Site / Location: XYZ 19 - Employee Alarm

Systems (1) 20 - Ergonomics (3)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
I&C Technician John Doe 123-45-6789

RR = Regulatory Required
PR = PES Required
BP = Best Practice
Ref. Completed = Refresher Completed, NO or DATE
Next Ref. Req. By = Next Refrsher Required, DATE or NA
(0) = Initial Only Required
(1) = Annual Refresher
(2) = Refresher Every 2 Years

Employee Training
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CALENDAR RR RR
YEAR: 2000

Site / Location: XYZ 19 - Employee Alarm

Systems (1) 20 - Ergonomics (3)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
&C (3) = Refresher Every 3 Years 123 6 89

Employee Training
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CALENDAR RR RR
YEAR: 2000
22 - Fire Extinguisher
Site / Location: XYZ Awareness
21 - Fall Protection (2) (Portbale) (1)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
I&C Technician John Doe 123-45-6789

RR = Regulatory Required
PR = PES Required
BP = Best Practice
Ref. Completed = Refresher Completed, NO or DATE
Next Ref. Req. By = Next Refrsher Required, DATE or NA
(0) = Initial Only Required
(1) = Annual Refresher
(2) = Refresher Every 2 Years

Employee Training
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CALENDAR RR RR
YEAR: 2000
22 - Fire Extinguisher
Site / Location: XYZ Awareness
21 - Fall Protection (2) (Portbale) (1)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
&C (3) = Refresher Every 3 Years 123 6 89

Employee Training
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CALENDAR RR PR
YEAR: 2000
23 - Fire Prevention 24 - Fire Prevention
Site / Location: XYZ Plan Plan
Classroom (1) Drill (1)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
I&C Technician John Doe 123-45-6789

RR = Regulatory Required
PR = PES Required
BP = Best Practice
Ref. Completed = Refresher Completed, NO or DATE
Next Ref. Req. By = Next Refrsher Required, DATE or NA
(0) = Initial Only Required
(1) = Annual Refresher
(2) = Refresher Every 2 Years

Employee Training
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CALENDAR RR PR
YEAR: 2000
23 - Fire Prevention 24 - Fire Prevention
Site / Location: XYZ Plan Plan
Classroom (1) Drill (1)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
&C (3) = Refresher Every 3 Years 123 6 89

Employee Training
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CALENDAR RR RR
YEAR: 2000
26 - DOT: Hazardous Material
Site / Location: XYZ Transport Training
25 - First Aid (3) Awareness (3)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
I&C Technician John Doe 123-45-6789

RR = Regulatory Required
PR = PES Required
BP = Best Practice
Ref. Completed = Refresher Completed, NO or DATE
Next Ref. Req. By = Next Refrsher Required, DATE or NA
(0) = Initial Only Required
(1) = Annual Refresher
(2) = Refresher Every 2 Years

Employee Training
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CALENDAR RR RR
YEAR: 2000
26 - DOT: Hazardous Material
Site / Location: XYZ Transport Training
25 - First Aid (3) Awareness (3)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
&C (3) = Refresher Every 3 Years 123 6 89

Employee Training
EHS Page 26 of 50 2/19/2007
 Annual EHS Training Tracking Record

CALENDAR RR RR
YEAR: 2000
27 - DOT: Hazardous Material
Site / Location: XYZ Transport Training 28 - Hazardous Waste
CERTIFICATION (3) Management (1)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
I&C Technician John Doe 123-45-6789

RR = Regulatory Required
PR = PES Required
BP = Best Practice
Ref. Completed = Refresher Completed, NO or DATE
Next Ref. Req. By = Next Refrsher Required, DATE or NA
(0) = Initial Only Required
(1) = Annual Refresher
(2) = Refresher Every 2 Years

Employee Training
EHS Page 27 of 50 2/19/2007
 Annual EHS Training Tracking Record

CALENDAR RR RR
YEAR: 2000
27 - DOT: Hazardous Material
Site / Location: XYZ Transport Training 28 - Hazardous Waste
CERTIFICATION (3) Management (1)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
&C (3) = Refresher Every 3 Years 123 6 89

Employee Training
EHS Page 28 of 50 2/19/2007
 Annual EHS Training Tracking Record

CALENDAR RR RR
YEAR: 2000 30 - Hazardous Waste
29 - Hazard Ops. & Emergency
Site / Location: XYZ Communication Resp. (HAZWOPER)
(HAZCOM) (2) Awareness (1)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
I&C Technician John Doe 123-45-6789

RR = Regulatory Required
PR = PES Required
BP = Best Practice
Ref. Completed = Refresher Completed, NO or DATE
Next Ref. Req. By = Next Refrsher Required, DATE or NA
(0) = Initial Only Required
(1) = Annual Refresher
(2) = Refresher Every 2 Years

Employee Training
EHS Page 29 of 50 2/19/2007
 Annual EHS Training Tracking Record

CALENDAR RR RR
YEAR: 2000 30 - Hazardous Waste
29 - Hazard Ops. & Emergency
Site / Location: XYZ Communication Resp. (HAZWOPER)
(HAZCOM) (2) Awareness (1)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
&C (3) = Refresher Every 3 Years 123 6 89

Employee Training
EHS Page 30 of 50 2/19/2007
 Annual EHS Training Tracking Record

CALENDAR RR RR
YEAR: 2000
31 - HAZWOPER 32 - HAZWOPER
Site / Location: XYZ First Responder Hazardous Mat'ls.
Operations (1) Technician Level (1)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
I&C Technician John Doe 123-45-6789

RR = Regulatory Required
PR = PES Required
BP = Best Practice
Ref. Completed = Refresher Completed, NO or DATE
Next Ref. Req. By = Next Refrsher Required, DATE or NA
(0) = Initial Only Required
(1) = Annual Refresher
(2) = Refresher Every 2 Years

Employee Training
EHS Page 31 of 50 2/19/2007
 Annual EHS Training Tracking Record

CALENDAR RR RR
YEAR: 2000
31 - HAZWOPER 32 - HAZWOPER
Site / Location: XYZ First Responder Hazardous Mat'ls.
Operations (1) Technician Level (1)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
&C (3) = Refresher Every 3 Years 123 6 89

Employee Training
EHS Page 32 of 50 2/19/2007
 Annual EHS Training Tracking Record

CALENDAR RR RR
YEAR: 2000
33 - HAZWOPER
Site / Location: XYZ On-Scene-Incident-
Command Level (1) 34 - Hearing Protection (1)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
I&C Technician John Doe 123-45-6789

RR = Regulatory Required
PR = PES Required
BP = Best Practice
Ref. Completed = Refresher Completed, NO or DATE
Next Ref. Req. By = Next Refrsher Required, DATE or NA
(0) = Initial Only Required
(1) = Annual Refresher
(2) = Refresher Every 2 Years

Employee Training
EHS Page 33 of 50 2/19/2007
 Annual EHS Training Tracking Record

CALENDAR RR RR
YEAR: 2000
33 - HAZWOPER
Site / Location: XYZ On-Scene-Incident-
Command Level (1) 34 - Hearing Protection (1)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
&C (3) = Refresher Every 3 Years 123 6 89

Employee Training
EHS Page 34 of 50 2/19/2007
 Annual EHS Training Tracking Record

CALENDAR PR RR
YEAR: 2000

Site / Location: XYZ 35 - Incident Reporting 36 - Lead Safety

& Investigation (3) Awareness (0)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
I&C Technician John Doe 123-45-6789 NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
RR = Regulatory Required
PR = PES Required
BP = Best Practice
Ref. Completed = Refresher Completed, NO or DATE
Next Ref. Req. By = Next Refrsher Required, DATE or NA
(0) = Initial Only Required
(1) = Annual Refresher
(2) = Refresher Every 2 Years

Employee Training
EHS Page 35 of 50 2/19/2007
 Annual EHS Training Tracking Record

CALENDAR PR RR
YEAR: 2000

Site / Location: XYZ 35 - Incident Reporting 36 - Lead Safety

& Investigation (3) Awareness (0)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
&C (3) = Refresher Every 3 Years 123 6 89

Employee Training
EHS Page 36 of 50 2/19/2007
 Annual EHS Training Tracking Record

CALENDAR RR RR
YEAR: 2000

Site / Location: XYZ 37 - Medical Records 38 - PCB

Access (1) Awareness (2)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
I&C Technician John Doe 123-45-6789

RR = Regulatory Required
PR = PES Required
BP = Best Practice
Ref. Completed = Refresher Completed, NO or DATE
Next Ref. Req. By = Next Refrsher Required, DATE or NA
(0) = Initial Only Required
(1) = Annual Refresher
(2) = Refresher Every 2 Years

Employee Training
EHS Page 37 of 50 2/19/2007
 Annual EHS Training Tracking Record

CALENDAR RR RR
YEAR: 2000

Site / Location: XYZ 37 - Medical Records 38 - PCB

Access (1) Awareness (2)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
&C (3) = Refresher Every 3 Years 123 6 89

Employee Training
EHS Page 38 of 50 2/19/2007
 Annual EHS Training Tracking Record

CALENDAR PR PR
YEAR: 2000

Site / Location: XYZ

39 - Air Permits (3) 40 - Wastewater Permits (3)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
I&C Technician John Doe 123-45-6789

RR = Regulatory Required
PR = PES Required
BP = Best Practice
Ref. Completed = Refresher Completed, NO or DATE
Next Ref. Req. By = Next Refrsher Required, DATE or NA
(0) = Initial Only Required
(1) = Annual Refresher
(2) = Refresher Every 2 Years

Employee Training
EHS Page 39 of 50 2/19/2007
 Annual EHS Training Tracking Record

CALENDAR PR PR
YEAR: 2000

Site / Location: XYZ

39 - Air Permits (3) 40 - Wastewater Permits (3)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
&C (3) = Refresher Every 3 Years 123 6 89

Employee Training
EHS Page 40 of 50 2/19/2007
 Annual EHS Training Tracking Record

CALENDAR RR RR
YEAR: 2000
42 - Powered Industrial
Site / Location: XYZ 41 - Personal Protective Trucks
Equipment (PPE) (3) (i.e. Forklifts) (3)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
I&C Technician John Doe 123-45-6789

RR = Regulatory Required
PR = PES Required
BP = Best Practice
Ref. Completed = Refresher Completed, NO or DATE
Next Ref. Req. By = Next Refrsher Required, DATE or NA
(0) = Initial Only Required
(1) = Annual Refresher
(2) = Refresher Every 2 Years

Employee Training
EHS Page 41 of 50 2/19/2007
 Annual EHS Training Tracking Record

CALENDAR RR RR
YEAR: 2000
42 - Powered Industrial
Site / Location: XYZ 41 - Personal Protective Trucks
Equipment (PPE) (3) (i.e. Forklifts) (3)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
&C (3) = Refresher Every 3 Years 123 6 89

Employee Training
EHS Page 42 of 50 2/19/2007
 Annual EHS Training Tracking Record

CALENDAR RR RR
YEAR: 2000
44 - Respiratory
Site / Location: XYZ 43 - Respiratory Protection
Protection (1) FIT TESTING (1)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
I&C Technician John Doe 123-45-6789

RR = Regulatory Required
PR = PES Required
BP = Best Practice
Ref. Completed = Refresher Completed, NO or DATE
Next Ref. Req. By = Next Refrsher Required, DATE or NA
(0) = Initial Only Required
(1) = Annual Refresher
(2) = Refresher Every 2 Years

Employee Training
EHS Page 43 of 50 2/19/2007
 Annual EHS Training Tracking Record

CALENDAR RR RR
YEAR: 2000
44 - Respiratory
Site / Location: XYZ 43 - Respiratory Protection
Protection (1) FIT TESTING (1)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
&C (3) = Refresher Every 3 Years 123 6 89

Employee Training
EHS Page 44 of 50 2/19/2007
 Annual EHS Training Tracking Record

CALENDAR RR RR
YEAR: 2000

Site / Location: XYZ

45 - Scaffolds (2) 46 - Slings & Derricks (2)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
I&C Technician John Doe 123-45-6789

RR = Regulatory Required
PR = PES Required
BP = Best Practice
Ref. Completed = Refresher Completed, NO or DATE
Next Ref. Req. By = Next Refrsher Required, DATE or NA
(0) = Initial Only Required
(1) = Annual Refresher
(2) = Refresher Every 2 Years

Employee Training
EHS Page 45 of 50 2/19/2007
 Annual EHS Training Tracking Record

CALENDAR RR RR
YEAR: 2000

Site / Location: XYZ

45 - Scaffolds (2) 46 - Slings & Derricks (2)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
&C (3) = Refresher Every 3 Years 123 6 89

Employee Training
EHS Page 46 of 50 2/19/2007
 Annual EHS Training Tracking Record

CALENDAR RR RR
YEAR: 2000 47 - Spill Prevention
Control & 48 - Toxic Substance
Site / Location: XYZ Countermeasure Control Act
(SPCC) (3) (TSCA) (1)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
I&C Technician John Doe 123-45-6789

RR = Regulatory Required
PR = PES Required
BP = Best Practice
Ref. Completed = Refresher Completed, NO or DATE
Next Ref. Req. By = Next Refrsher Required, DATE or NA
(0) = Initial Only Required
(1) = Annual Refresher
(2) = Refresher Every 2 Years

Employee Training
EHS Page 47 of 50 2/19/2007
 Annual EHS Training Tracking Record

CALENDAR RR RR
YEAR: 2000 47 - Spill Prevention
Control & 48 - Toxic Substance
Site / Location: XYZ Countermeasure Control Act
(SPCC) (3) (TSCA) (1)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
&C (3) = Refresher Every 3 Years 123 6 89

Employee Training
EHS Page 48 of 50 2/19/2007
 Annual EHS Training Tracking Record

CALENDAR RR RR
YEAR: 2000

Site / Location: XYZ 49 - Walking / Working 50 - Welding, Cutting, &

Surfaces (2) Brazing (2)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
I&C Technician John Doe 123-45-6789

RR = Regulatory Required
PR = PES Required
BP = Best Practice
Ref. Completed = Refresher Completed, NO or DATE
Next Ref. Req. By = Next Refrsher Required, DATE or NA
(0) = Initial Only Required
(1) = Annual Refresher
(2) = Refresher Every 2 Years

Employee Training
EHS Page 49 of 50 2/19/2007
 Annual EHS Training Tracking Record

CALENDAR RR RR
YEAR: 2000

Site / Location: XYZ 49 - Walking / Working 50 - Welding, Cutting, &

Surfaces (2) Brazing (2)
JOB / TITLE NAME SS# or ID# Initial Ref. Completed Next Ref. Req. By: Initial Ref. Completed Next Ref. Req. By:
&C (3) = Refresher Every 3 Years 123 6 89

Employee Training
EHS Page 50 of 50 2/19/2007
Policy No. EHS-603 Waste Management Appendix S.1

Exemptions from Hazardous Waste – Categories

(According to 40 CFR 261.4):

• Household Hazardous Wastes (garbage, trash, sanitary wastes, etc.)

• Agricultural Wastes

• Mining Overburden

• Fossil Fuel Combustion Wastes

• Oil, Gas, and Geothermal Wastes

• Mining and Mineral Processing Wastes

• Cement Kiln Dust

• Certain Trivalent Chromium Wastes

• Arsenic Treated Wood

• Petroleum Contaminated Media from Underground Storage Tanks (USTs)

• Spent ChloroFluoroCarbon (CFC) Refrigerants

• Used Oil Filters

• Samples (includes Treatability study samples and waste characterization samples)

• Hydrocarbon Recovery Operation Wastes

Reference the regulatory standard cited for detailed information

on each of the categories.

Page 1
Policy No. EHS-603 Waste Management Appendix S.2

Hazard Waste Listings (and Some Hazard Codes)

According to EPA, a hazardous waste listing is a narrative description of a specific type of waste
the EPA considers dangerous enough to warrant regulation. Hazardous waste listings describe
wastes from very specific industrial processes, wastes form very specific sectors of industry, or
wastes in the form of very specific chemical formulations.

There are four (4) different criteria upon which EPA may base its determination to list a waste as
hazardous:

• The waste typically contains harmful chemicals that could pose a threat to human health
and/or the environment in the absence of regulation (toxic listed wastes);

• The waste contains dangerous chemicals that could pose a threat to human health and/or
the environment even when properly managed (acutely hazardous wastes);

• The waste typically exhibits one of the four characteristics of hazardous waste; or

• EPA has reason to believe that the waste typically fits within statutory definition of hazardous
waste.

TYPES OF LISTED WASTE:

Hazardous Wastes from Non-Specific Sources “F” LIST

Hazardous Wastes from Specific Sources “K” LIST

Unused Discarded Commercial Chemical Products “P” LIST

(Acutely Hazardous Wastes)

Or

“U” LIST
(Non-Acutely Hazardous Wastes)

F-LIST = Manufacturing Process Wastes, typically from spent solvents and electroplating
wastes

Spent Solvent Wastes (F001-F005)

Wastes from Electroplating and Other Metal Finishing Operations (F006-F012, F019)
Dioxin-bearing Wastes (F020-F023 and F026-F028)
Wastes from the Production of Certain Chlorinated Aliphatic Hydrocarbons (F024-F025)
Wastes from Wood Preserving (F032, F034, and F035)
Petroleum Refinery Wastewater Treatment Sludges (F037-F038)
Multisource Leachate (F039)

Page 1
Policy No. EHS-603 Waste Management Appendix S.2

Hazard Waste Listings (and Some Hazard Codes)

K-LIST = Primarily residues from manufacturing and wastewater treatment processes and
covers wastes from 13 specific industries (more specific than F-List)

13 industries
Wood Preservation Inorganic Pigment Manufacturing
Organic Chemicals Manufacturing Pesticides Manufacturing
Inorganic Chemicals Manufacturing Explosives Manufacturing
Petroleum Refining Iron and Steel Production
Primary Aluminum Production Secondary Lead Processing
Veterinary Pharmaceuticals Mfg. Ink Formulation
Coking

P- and U-LIST = Commercial Chemical Products (CCP) and spill residues that are unused or
off-specification AND intended for discard AND sole active ingredient in formulation (once a
chemical has been used, it cannot be classified as a CCP)

Examples:
Technical and pure grade unused CCPs (i.e., unused can of acetone)
Off-Specification CCPs (i.e., too much waster in an unused chemical product)
Container Liners
Spill Residues for Discard

NOTES: Even if the chemical is off-specification, it is not a waste until you decide to
discard it. And once a chemical is used for its intended purpose, the P or U listing is not
applicable.

To indicate its reason for listing a waste, EPA assigns a hazard code to each waste listed on the
F, K, P and U Lists.

FOR LISTED WASTES ONLY:

(T) = Toxic Waste
(H) = Acute Hazardous Waste

FOR LISTED AND CHARACTERISTIC WASTES:

(I) = Ignitable Waste
(C) = Corrosive Waste
(R)= Reactive Waste
(E) = Toxicity Characteristic Waste

Reference the regulatory standards 40 CFR 261.31, 261.32, and 261.33 for detailed information
and listings for each of the categories (Listed Wastes).

Page 2