HSE – Cirks Construction Inc.

 
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 HEALTH, SAFETY, & ENVIRONMENTAL MANUAL (HSE) 

Cirks Construction Inc. 

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Revised July 2015

June 2015 
HSE – Cirks Construction Inc. 
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Table of Contents 

Policy tatement on Safety .........................................................................................................1

Duties and Responsibilities for
Safety.........................................................................................2 Employee Safety
Training...........................................................................................................5 Safety
Communication................................................................................................................8
Enforcement of Safety
Policies ...................................................................................................9 Hazard Identification
and Evaluation.........................................................................................11 Hazard
Correction.....................................................................................................................16
Incident
Investigation ................................................................................................................17
Program Records......................................................................................................................20
Emergency Medical Services and First
Aid ...............................................................................21 Hazard ommunication Program –
Materials & Chemicals .......................................................23 Fall
Protection...........................................................................................................................29
Aerial Lift Safety
Procedures.....................................................................................................34 Electrical Safety
& Lock-out / Tag-out Program.........................................................................38 Driving Safety
Policy .................................................................................................................43 Driving
Safety Rules .................................................................................................................50
Confined pace Operations ......................................................................................................54
Company Policy for Permit-Required Confined
Spaces ............................................................57 Respiratory
Protection ..............................................................................................................64 Information
for Employees Using Respirators When Not Required ...........................................74
Ergonomics...............................................................................................................................75
Forklifts .....................................................................................................................................7
6 Fire Prevention and Emergency Action
Plan.............................................................................79 Office
Safety .............................................................................................................................82 Heat
Illness Prevention .............................................................................................................83
Code of Safe Practices – Job Site
Rules...................................................................................86 Code of Safe Practices –
General Safety Rules........................................................................88 Code of Safe Practices
– Electrical Safety ................................................................................90 Code of Safe
Practices – Company Vehicles ............................................................................92 Code of
Safe Practices – Ladder Safety ...................................................................................93 Code
of Safe Practices – Personal Protective Equipment (PPE)...............................................94
Code of Safe Practices – Hand and Power
Tools......................................................................95 Code of Safe Practices – Hazardous
Materials and Chemicals.................................................96 Code of Safe Practices – Fire
Prevention and Housekeeping ...................................................97 Code of Safe Practices –
Traffic Safety.....................................................................................98 Code of Safe Practices
– Welding and Cutting..........................................................................99 Stop Work
Authority ................................................................................................................102 Hazard
ommunication Employee Training ............................................................................104
Excavation Safety
Program.....................................................................................................112 Scaffold Safety
Program - Construction Safety Program.........................................................129 Company
Policy for Occupational Noise Exposure .................................................................134
Mandatory Safety Forms, Permits and
Checklists...................................................................136
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Policy Statement on Safety 

The health and safety of each Cirks Construction Inc. employee is of primary importance to us. 
As a company, we are committed to maintaining a healthy and safe working environment. 
Management will provide necessary safeguards, programs, and equipment required to reduce 
the potential for incidents and injuries. 

To achieve this goal, we have developed and implemented a comprehensive Health, Safety, & 
Environmental Manual (HSE), which incorporates all required components of an Injury and 
Illness Prevention Program (IIPP). This program is designed to prevent workplace incidents, 
injuries, and illnesses. A complete copy of the program is maintained at our corporate office 
and on all job site locations in written or electronic form. You may ask to review it at any time. 
A copy of relevant portions of the program that are applicable to your job will also be provided
to  you. You may also contact the company safety director if you have any questions or
concerns. 

It is the intent of Cirks Construction Inc. to comply with all laws relating to occupational health 
and safety. To accomplish this, we require the active participation and assistance of all 
employees. The policies and procedures contained in this manual are mandatory. You should 
also be constantly aware of conditions in all work areas that can produce injuries or illness. No 
employee is required to work at a job that he or she knows is unsafe. Never hesitate to inform 
your supervisor or foreman of any potentially hazardous situation or condition that is beyond 
your ability or authority to correct immediately. No employee will be discriminated against for 
reporting safety concerns to management. 

It is the responsibility of each employee to support the company safety program and to
perform  in a manner that assures his or her own personal safety and the safety of others,
including  customers, visitors, and other trades. To be successful in our endeavor, all
employees at every  level must adopt proper attitudes towards injury and illness prevention.
We must also cooperate  in all health and safety matters, not only between management and
employees, but also  between each employee and his or her respective co-workers. Only
through such an effort can  any safety program be successful. Our objective is a health and
safety program that will reduce  the total number of injuries and illnesses to an absolute
minimum. Our ultimate goal is zero  incidents. 

______________________________________ 
Ken Cirks; President of Cirks Construction Inc. 

____________________________________________ 
Stuart Nakutin; Safety Director of Cirks Construction Inc.
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Duties and Responsibilities for Safety 

A successful Health, Safety, Environmental and Injury and Illness Prevention Program can only
be  achieved and maintained when there is active interest, participation, and accountability at
all levels  of the organization. At Cirks Construction Inc., it is a condition of employment that all
employees  are responsible for safety. To ensure this, Cirks Construction Inc. delegates the
following safety 
duties by job title. Please keep in mind that this is not an all-inclusive list. In some cases,
employees will need to perform safety duties outside their regular responsibilities to prevent 
incidents. 

Stuart Nakutin, who can be reached at (714) 400-5023, (referenced forward as the
“safety  director”) will plan, organize, and administer the program by establishing
policy, setting  goals and objectives, assigning responsibility, motivating subordinates,
and monitoring  results. All employees of Cirks Construction Inc. will support and
maintain an ongoing  Health, Safety, Environmental and Injury and Illness Prevention
Program through the  following: 

1. Provide clear understanding and direction to all management, employees, and sub
contractors regarding the importance of safety through the development, implementation, 
monitoring, and revision of policies and procedures. 

2. Provide financial support for the Injury and Illness Prevention Program through the  provision
of adequate funds for the purchase of necessary safety materials, safety equipment, proper
personal protective equipment, adequate time for employee safety training, and
maintenance of tools and equipment. 

3. Oversee development, implementation, and maintenance of the IIPP and other required 
safety programs. 

4. Maintain a company commitment to incident prevention by expecting safe conduct on the 

part of all managers, supervisors, and employees. 

5. Hold all levels of management and employees accountable for incident prevention and 
safety. 

6. Review all incident investigations to determine corrective action. 

The safety director for Cirks Construction Inc. acts as a safety resource for the
company  and is responsible for maintaining program records. He is also our primary
person to  deal with outside agencies regarding the safety program and its contents.
Additional  duties include: 

1. Coordinate all loss prevention activities as a representative of management.  

2. Act as a consultant to management in the implementation and administration of the  Safety
Program. 

3. Develop and implement loss prevention policies and procedures designed to insure 
compliance with the applicable rules and regulations of all federal, state, and local 
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agencies. 

4. Review all incident reports to determine root cause and corrective action. 

5. Conduct periodic reviews of the safety program and job sites to evaluate performance, 
discuss problems, and help solve them. 

6. Consult with representatives of our insurance companies in order that their loss control 
services will support the safety program. 

7. Review Workers’ Compensation claims. Help supply the insurance carrier with 
information about injured employees in order to keep loss reserves to a minimum. 

Managers and supervisors play a key role in the prevention of incidents on the job.
They  have direct contact with the employees and know the safety requirements for
various  jobs. Safety responsibilities for these individuals include: 

1. Enforce all safety rules in the Code of Safe Practices, the posted job site rules, and  ensure
safe work procedures. 

2. Verify corrective action has been taken regarding safety hazards and incident 
investigations. 

3. Conduct periodic documented inspections of the work sites to identify and correct unsafe 
actions and conditions that could cause incidents. 

4. Act as a leader in company safety policy and set a good example by following all safety
rules. 

5. Become familiar with federal, state, and local safety regulations. The safety director is 
available for assistance. 

6. Under the guidance of the safety director, train all new and existing employees in proper 
safety procedures and the hazards of the job. 

7. Instruct all employees under his or her supervision in safe work practices and job safety
requirements.  

8. Hold safety meetings with employees. 

9. Ensure employee proficiency when assigning work requiring specific knowledge, special 
operations, or equipment. 

10. Ascertain that all machinery, equipment, and workstations are maintained in safe  working
condition and operate properly. 

11. Correct unsafe acts and conditions that could cause incidents. 

12. Communicate with all employees about safety and incident prevention activities.

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13. Correct the cause of any incident as soon as possible. 

14. Ascertain that proper first aid and firefighting equipment is maintained and used when 
conditions warrant its use. 

15. Maintain good housekeeping conditions at all times. 

16. Investigate all injuries and incidents to determine their cause and potential corrective 
action. 

17. Ascertain that all injuries involving our employees that require medical attention are 
properly treated and promptly reported immediately following the procedures laid out in  our
post incident response protocol. 

Every employee is responsible for working safely, both for self-protection and for 
protection of fellow co-workers. Employees must also support all company safety
efforts.  Specific employee safety responsibilities include: 

1. If you are unsure how to do any task safely, ask your supervisor.  

2. Read and abide by all requirements of the Health, Safety, Environmental Manual and  Injury
and Illness Prevention Program (IIPP). 

3. Know and follow the Code of Safe Practices and all company safety policies and 
procedures. 

4. Wear all required personal protective equipment (PPE). 

5. Report all incidents and injuries, no matter how minor, to your supervisor immediately.

6. Do not operate any equipment you have not been trained on or authorized to use. 7.

Report any safety hazards or defective equipment immediately to your supervisor. 8. Do

 not remove, tamper with, or defeat any guard, safety device, or interlock. 9. Never use

any equipment with inoperative or missing guards, safety devices, or interlocks. 

10. Never possess or be under the influence of alcohol or controlled substances while on the 
premises. 

11. Never engage in horseplay or fighting. 

12. Participate in and actively support the safety program.

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Employee Safety Training 

California law requires that employees be trained in the safe methods of performing their job. 
Cirks Construction Inc. is committed to instructing all employees in healthy and safe work 
practices. Awareness of potential hazards, as well as knowledge of how to control them, is
critical in maintaining a healthy and safe work environment in preventing injuries. To achieve 
this goal, we will provide training to each employee on general safety issues and safety
procedures specific to that employee's work assignment. 

Every new field employee will be given instruction by his or her supervisor in the general safety
requirements of their job. A copy of our Code of Safe Practices shall also be provided to each 
employee.  

Field managers, supervisors, and employees will be trained at least twice per year on various 
incident prevention topics. 

Training provides the following benefits: 

• Makes employees aware of job hazards 

• Teaches employees to perform jobs safely 
• Promotes two-way communication 
• Encourages safety suggestions 
• Creates interest in the safety program 
• Fulfills CAL-OSHA requirements 

Employee training will be provided at the following times: 

1. New field employees will receive a safety orientation. 

2. New field employees will be given a copy of the Code of Safe Practices and required to  read
and sign for it. 
3. Employees given a new job assignment, for which training has not been previously 
provided, will be trained before beginning the new assignment. 

4. Whenever new substances, processes, procedures, or equipment that represent a new 

hazard are introduced into the workplace. 

5. Whenever Cirks Construction Inc. is made aware of a new or previously unrecognized 

hazard. 

6. Whenever management believes that additional training is

necessary. 7. After all serious incidents. 

8. When employees are not following safe work policies and procedures.

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Training topics will include, but are not be limited to: 

• Code of Safe Practices 

• Employee’s safety responsibility 
• General safety rules 
• Safe job procedures 
• Ergonomics 
• Safe lifting and material handling practices 
• Use of hazardous materials 
• Use of equipment 
• Emergency procedures 
• Contents of the safety program 

Documentation of Training: 

All training will be documented on the following form: 

“New Employee Safety Orientation Form” 

The following training method should be used. Actual demonstrations of the proper
way  to perform a task are very helpful in most cases.  

• Instruct them how to do the job safely. 

• Train them how to do the job safely. 
• Have them tell you how to do the job safely. 
• Have them show you how to do the job safely. 
 • Follow up to ensure they are still performing the job safely.

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Field Employee Safety Training 

The supervisor will verbally cover the following items with each new field employee on the first 
day of their employment. 

Employee Name: ______________________________ Start Date: ___________________ 

Safety Manager/Supervisor:

___________________________________________________ Employee Position:

__________________________________________________________ Instruction has been

received in the following areas: 

1. Code of Safe Practices, Jobsite Rules, Construction 101 and Safety Forms.* 2.
Hazard Communication (Right to Know Policy) 
3. Driving Safety Rules.* 
 4. Safety rule enforcement procedures. 
5. Necessity of reporting ALL injuries, no matter how minor, IMMEDIATELY. 6.
Proper method of reporting safety hazards. 
7. Emergency procedures and First Aid. 
8. Proper work clothing and required personal protective equipment. 
9. List all special equipment, such as lifts, employee is trained and authorized to operate. 
10. Emergency Exits and Fire Extinguishers. 

* Give a copy of these items to the employee. 

Note any special requirements: 

_________________________________________________________________________

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_________________________________________________________________________

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I agree to abide by all company safety polices and the Code of Safe Practices. I also 
understand that failure to do so may result in disciplinary action or possible termination. 

Signature: ______________________________________________
 (Employee) 

Signature: ______________________________________________
 (Safety Manager / Supervisor)

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Safety Communication 
This section establishes procedures designed to develop and maintain employee involvement
and  interest in the HSE Manual and IIPP. These activities will also ensure effective
communication  between management and employees on safety related issues that is of prime
importance to Cirks  Construction Inc. The following are some of the safety communication
methods that may be  used: 

1. New employee safety orientation and provision of the Code of Safe Practices. 

2. Periodic safety meetings with employees that encourage participation and open two-way 
communication. 
3. Provision and maintenance of employee notices discussing safety issues, incidents, and 
general safety suggestions. 

4. Written communications from management or the safety director, including memos, 

postings, payroll stuffers, and newsletters. 

5. Anonymous safety suggestion program. 

Employees will be kept advised of highlights and changes relating to the safety program. 
Management shall relay changes and improvements regarding the safety program to
employees,  as appropriate. Employees will be involved in future developments and safety
activities by  requesting their opinions and comments be reviewed, as necessary. 

All employee initiated safety related suggestions shall be properly answered, either
verbally  or in writing, by the appropriate level of management. All employees are
encouraged to  bring any safety concerns they may have to the attention of
management. Cirks  Construction Inc. will not discriminate against any employee for
raising safety issues or  concerns. 

Cirks Construction Inc. welcomes anonymous notification whereby employees who wish to
inform  the company of workplace hazards without identifying themselves may do so by
phoning or  sending written notification to the safety director or company manager.

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Enforcement of Safety Policies 

The compliance of all employees with the Cirks Construction Inc. HSE Manual and IIPP is 
mandatory and shall be considered a condition of employment. 

The following programs will be utilized to ensure employee compliance with the safety
program  and all safety rules. 

• Training programs 
 • Retraining 
• Optional safety incentive programs 
• Disciplinary action 

Training Programs 

The importance of safe work practices and the consequences of failing to abide by safety rules 
will be covered in the New Employee Safety Orientation and safety meetings. This will help 
ensure that all employees understand and abide by Cirks Construction Inc. safety policies. 

Safety Correction Notices 

Employees or subcontractors that are observed performing unsafe acts or not following proper 
policies or procedures will be corrected by their supervisor. A Safety Correction Notice may be 
completed by the supervisor to document the infraction. If multiple employees are involved, 
additional safety training will be held. 

Safety Incentive Programs 

Although strict adherence to safety policies and procedures is required of all employees, the 
company may choose to periodically provide recognition of safety-conscious employees and
job  sites without incidents through a safety incentive program.  

Disciplinary Action 

The failure of an employee to adhere to safety policies and procedures established by Cirks 
Construction Inc. can have a serious impact on everyone concerned. An unsafe act can not 
only threaten the health and well-being of the employee committing the unsafe act, but it can 
also affect the safety of his or her co-workers and customers. Accordingly, any employee who 
violates any of the Company's safety policies and procedures will be subject to disciplinary 
action or dismissal. 

Note: Failure to promptly report any on-the-job incident or injury, on the same day as the 
occurrence, is considered a serious violation of the Company's Code of Safe Practices. Any 
employee who fails to immediately report a work-related incident or injury, no matter how
minor, shall be subject to disciplinary action or dismissal. 

Employees will be disciplined for infractions of safety policies and procedures where unsafe 
work practices are observed, not just those that result in an injury. Often, when an injury 
occurs, the incident investigation will reveal that the injury was caused because the employee 
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violated an established safety policy or safe work practice. In any disciplinary action, the 
supervisor should be cautious that discipline is given to the employee for safety violations, and 
not simply because the employee was injured on the job or filed a Workers’ Compensation 
claim.  
Violations of safety rules and the Code of Safe Practices are to be considered equal to 
violations of other company policies. 

As in all disciplinary actions, each situation is to be carefully evaluated and investigated. The 
particular step taken in the disciplinary process will depend on the severity of the violation, 
employee history, and regard to safety. Managers and supervisors should consult with the 
Human Resources Manager if there is any question about whether or not disciplinary action is 
justified. Employees may be terminated immediately for willful or extremely serious violations.

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 Hazard Identification and Evaluation 
To assist in the identification and correction of hazards, Cirks Construction Inc. has developed 
the following procedures. These procedures are representative only and are not exhaustive of 
all the measures and methods that will be implemented to guard against injury from
recognized  and potential hazards in the workplace. As new hazards are identified or improved
work  procedures developed, they will be promptly incorporated into our Safety Manual. The
following  methods will be utilized to identify hazards in the workplace: 

• Loss Prevention Self-Assessment 

• Loss analysis of incident trends 
• Incident investigations 
• Employee observation 
• Employee suggestions 
• Regulatory requirements for our industry 
• Periodic safety inspections at minimum monthly 
• Documentation of inspections 

Loss Analysis 

Periodic loss analyses will be conducted by the safety director and all superintendents. These 
will help identify areas of concern and potential job hazards. The results of these analyses will 
be communicated to management, supervisors, and employees through safety meetings and 
other appropriate means. 

Incident Investigations 

All near loss incidents (NLI) must be reported. Incidents and injuries will be investigated in 
accordance with the guidelines contained in this program. Incident investigations will focus on 
causal factors and corrective action, including the identification and correction of hazards that 
may have contributed to the incident. 

Employee Observation 

Superintendents and foremen shall be continually observing employees for unsafe actions or 
conditions and taking corrective action as necessary. 

Employee Suggestions 

Employees are encouraged to report any hazard they observe to their supervisors. No 
employee of Cirks Construction Inc. is to ever be disciplined or discharged for reporting any 
workplace hazard or unsafe condition. However, employees who do NOT report potential 
hazards or unsafe conditions that they are aware of will be subject to disciplinary action. 

Regulatory Requirements 

All industries are subject to government regulations relating to safety. Many of these 
regulations are specific to our type of business. Copies of pertinent regulations can be
obtained  from the safety director.
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Periodic Safety Inspections 

Periodic safety inspections ensure that physical and mechanical hazards are under control
and  identify situations that may become potentially hazardous. Inspections shall include a
review of  the work habits of employees in all work areas. These inspections will be conducted
by the  supervisor, manager, safety director, or other designated individual. 

Periodic safety inspections will be conducted: 

• When new substances, processes, procedures, or equipment are used.

• When new or previously unrecognized hazards are identified. 
• Periodically by the supervisor.  
• Periodically by the safety director.  

These inspections will focus on both unsafe employee actions as well as unsafe conditions. 
The following is a partial list of items to be checked: 

• Compliance with the Code of Safe Practices. 

• The proper use, condition, maintenance, and grounding of all electrically  operated
equipment. 
• The proper use, condition, and maintenance of safeguards for all power-driven 
equipment. 
• Housekeeping and personal protective equipment (PPE). 
• Hazardous materials. 
• Proper material storage. 
• Provision of first aid equipment and emergency medical services. 

Any and all hazards identified will be corrected as soon as practical in accordance with the
Cirks  Construction Inc. hazard correction policy. 

If imminent or life threatening hazards are identified which cannot be immediately corrected,
all  employees must be removed from the area, except those with special training required to 
correct the hazard. Employees with special training required to correct the hazard will be 
provided necessary safeguards. 

Documentation of Inspections 

Safety inspections will be documented to include the following: 

• Date on which the inspection was performed. 

• The name and title of person who performed the inspection. 
• Any hazardous conditions noted or discovered, and the steps or procedures  taken to
correct them. 
• Signature of the person who performed the inspection. 
One copy of the completed form should be sent to the office. All reports shall be kept on file for 
a minimum of two (2) years.

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SAFETY AUDIT CHECKLIST

JOB NAME

SUPERINTENDENT NAME

INSPECTION DATE

COMPLETION OF PROJECT

INSPECTOR NAME

GENERAL  YES  NO  N/A

KDC Signage

Job Site Rules Posted

Sign In Sheet

Pedestrian Protection

Perimeter Protection

Duty To Warn – Duty To Protect – Duty to Control

Accident Reporting Instructions

Safety & Health Program (IIPP)

Safety Data Sheets

First Aid Kit

Eye Wash Station

Tailgate Meeting Documentation

 Plans/Specs/ Drawings of job

Fire Extinguishers - Fire extinguishers inspected &

tagged

Emergency Evacuation Plan (EEP)

Medical Clinic and Map

JOB HAZARD ANALYSIS FOR CRITICAL YES  NO  N/A

WORK 

Crane Activity

Excavation 5 ft or greater

Scaffold Work

Confined Space Work

Hot Work

Working at heights in excess of 10ft

PERSONAL PROTECTIVE EQUIPMENT (PPE)  YES  NO  N/A

Face shield being used when chipping, grinding, chop saw etc….

Hard hat

Safety Glasses

Cut Resistant Gloves

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Class II Vest

Respiratory Protection

FALL PROTECTION  YES  NO  N/A

 Site Specific Fall Protection Plan (SFPP) available for
review

Rescue Plan Completed

Retrieval Method Available

Equipment Inspection Conducted

Fall Protection ABC’s followed

Site Specific Fall Protection Plan (SFPP) available for

review

SCAFFOLDING WORK  YES  NO  N/A

Daily Signed Green tag by Comp

Person

Plumb

Base Plates & Mudsills

Plank Size, spacing and construction

Guardrails

Access Ladder

CRANE ACTIVITY  YES  NO  N/A

KDC Crane Plan

Followed

JHA

Pic Plan Completed

Rigging Plan

CONFINED SPACES  YES  NO  N/A

JHA completed
 Confined Space Plan (CSP)

Use of sniffer

Attendant

Entrant

CP Permit

JHA completed

DIGGING  YES  NO  N/A

Utility companies contacted and/or utilities located.

Exact location of utilities marked when near excavation.

Underground installations protected

Precautions taken to protect employees from accumulation of

water.

Surface water controlled or diverted.

Atmosphere tested

Oxygen content is between 19.5% and 21%.

Flammable gas build-up to 20% of lower explosive limit (LEL).

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Toxic Levels of gases are below limits set on gas monitor.

Ventilation blowing into space and air intake placed away from vehicle 
exhaust

EXCAVATION/TRENDING/SHARING  YES  NO  N/A

Pre-Excavation Report

JHA
 Soil Test – Type (circle one)ABC

Protective device

Atmospheric Testing

Current Conditions N/A Description or Measure Comments /

Observations

Terrain, Weather, Water accumulation

Traffic conditions

Heavy equipment location

Spoils location

Trench width

Trench depth

Access / egress conditions

ELECTRICAL  YES  NO  N/A

Lock Out Tag

Out

JHA

Tailgate Meeting

FLAMMABLE & COMBUSTIBLE LIQUIDS  YES  NO  N/A

Stored and handled in appropriately

container

Labeled Correctly

Right To Know Poster

MOBILE EQUIPMENT  YES  NO  N/A

Daily inspection conducted on all mobile equipment - documented

 Owner’s manual secured in all mobile equipment

Seat belts functional and worn on mobile equipment (as required)

Proper attachments used on all mobile equipment

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Hazard Correction 
The following procedures will be used to evaluate, prioritize, and correct identified safety
hazards. Hazards will be corrected in order of priority; the most serious hazards will be 
corrected first.  

Hazard Evaluation 

Factors that will be considered when evaluating hazards include: 

• Potential severity - The potential for serious injury, illness, or fatality. •

Likelihood of exposure - The probability of the employee coming into contact  with
the hazard. 
• Frequency of exposure - How often employees come into contact with the  hazard. 
• Number of employees exposed 
• Possible corrective actions - What can be done to minimize or eliminate the 
hazard? 
• Time necessary to correct - The time necessary to minimize or eliminate the 
hazard. 

Techniques for Correcting Hazards 

1. Engineering Controls: Could include machine guarding, ventilation, noise reduction at  the
source, and provision of material handling equipment. These are the first and  preferred
methods of control. 

2. Administrative Controls: The next most desirable method would include rotation of 
employees or limiting exposure time. 

3. Personal Protective Equipment: Includes hard hats, hearing protection, respirators, and
safety glasses. These are often the least effective controls for hazards and should  be
relied upon only when other controls are impractical. 

Documentation of Corrective Action 

All corrective action taken to mitigate hazards should be documented. Depending on the 
circumstances, one of the following forms should be used: 
 • Safety contact report 
• Safety meeting report 
• Memo or letter 
• Safety inspection form 

All hazards noted on safety inspections will be re-checked on each subsequent inspection and 
notations made as to their status. 

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Incident Investigation 
The supervisor, manager, or other designated individual will investigate all work-related 
incidents in a timely manner. This includes minor incidents and "near loss incidents," as well
as  serious injuries. An incident is defined as any unexpected occurrence that results in injury
to  personnel, damage to equipment, facilities, material, or interruption of normal operations. 

Responsibility for Incident Investigation 

Immediately upon being notified of an incident, the supervisor, manager, or other designated 
individual shall conduct an investigation. The purpose of the investigation is to determine the 
cause of the incident and corrective action to prevent future reoccurrence; not to fix blame or 
find fault. An unbiased approach is necessary in order to obtain objective findings. 

The Purpose of Incident Investigations 

• To prevent or decrease the likelihood of similar incidents. 

• To identify and correct unsafe work practices and physical hazards. Incidents  are
often caused by a combination of these two factors. 
• To identify training needs. This makes training more effective by focusing on  factors
that are most likely to cause incidents. 

What Types of Incidents Do We Investigate 

• Fatalities 
• Serious injuries 
• Minor injuries 
• Property damage 
• Near losses 

Procedures for Investigation of Incidents 

Immediately upon being notified of an incident the supervisor, manager, or other designated 
individual will: 
1. Visit the incident scene, as soon as possible, while facts and evidence are still fresh and 
before witnesses forget important details and to make sure hazardous conditions to  which
other employees or customers could be exposed are corrected or have been removed. 

2. Provide for needed first aid or medical services for the injured employee(s). 

3. If possible, interview the injured worker at the scene of the incident and verbally "walk"  him
or her through a re-enactment. All interviews should be conducted as privately as  possible.
Interview all witnesses individually and talk with anyone who has knowledge of  the
incident, even if they did not actually witness it. 

4. Report the incident to the safety director and supervisors immediately. All serious  incidents
will be reported to the insurance carrier as soon as possible.

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5. Consider taking signed statements in cases where facts are unclear or there is an  element
of controversy. 

6. Thoroughly investigate the incident to identify all incident causes and contributing  factors.
Document details graphically. Use sketches, diagrams and photos as needed.  Take
measurements when appropriate. 

7. All incidents involving death, disfigurement, amputation, loss of consciousness, or 

hospitalization for more than 24 hours must be reported to CAL-OSHA immediately. 

8. Focus on causes and hazards. Develop an analysis of what happened, how it  happened,
and how it could have been prevented. Determine what caused the incident itself, not just
the injury. 

9. Every investigation must also include an action plan. How can such incidents be  prevented
in the future? 

10. In the event a third party or defective product contributed to the incident, save any 
evidence as it could be critical to the recovery of claim costs. 

Accurate and Prompt Investigations 

• Ensures information is available 

• Causes can be quickly corrected 
• Helps identify all contributing factors 
• Reflects management concerns 
• Reduces chance of recurrence 

Investigation Tips 

• Avoid placing blame 

 • Document with photos and diagrams, if needed 
• Be objective, get the facts 
• Reconstruct the event 
• Use open-ended questions 

Questions to Ask 

When investigating incidents, open-ended questions such as; who, what, when, where, why,
and how, will provide more information than closed-ended questions such as "Were you
wearing  gloves?" 

Examples include: 

• How did it happen? 

• Why did it happen? 
• How could it have been prevented? 
• Who was involved?

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• Who witnessed the incident? 

• Where were the witnesses at the time of the incident? 
• What was the injured worker doing? 
• What was the employee working on? 
• When did it happen? 
• When was the incident reported? 
• Where did it happen? 
• Why was the employee assigned to do the job? 

The single, most important question that must be answered as the result of any 
investigation is: 

"What do you recommend to be done (or have you done) to prevent this type of
incident  from recurring?" 

Once the Incident Investigation is completed 

• Take or recommend corrective action 

• Document corrective action 
• Management and the safety director will review the results of all investigations
• Consider safety program modifications 
• Information obtained through incident investigations can be used to update to
improve our current program
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Program Records 
The safety director will ensure the maintenance of all HSE Manual and IIPP records, for the 
listed periods, including: 

1. New Employee Safety Orientation Forms Length of Employment 2. Code

of Safe Practices Receipt Length of Employment 3. Disciplinary Actions for

Safety Length of Employment 4. Safety Inspections 2 years 

5. Safety Meeting Reports 2 years 

6. Safety Correction Notices 2 years 

7. Incident Investigations 5 years 

8. CAL-OSHA Log of Injuries 5 years 

9. Inventory of Hazardous Materials (if any) Indefinitely  

10. Employee Exposure or Medical Records Indefinitely 

Note: Records are available for review upon request.

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Emergency Medical Services and First Aid 

Cirks Construction Inc. will ensure the availability of emergency medical services for its 
employees at all times. We will also ensure the availability of a suitable number of appropriately 
trained persons to render first aid. The safety director will maintain a list of trained individuals  
and take steps to provide training for those that desire it. 

First-Aid Kits  

Every work site shall have access to at least one first-aid kit in a weatherproof container. The 
first-aid kit will be inspected regularly to ensure that it is well stocked, in sanitary condition, and 
any used items are promptly replaced. The contents of the first-aid kit shall be arranged to be 
quickly found and remain sanitary. First-aid dressings shall be sterile and in individually sealed 
packages. The following minimum first-aid supplies shall be kept. 

Type of Supply Required by Number of Employees 

Dressings in adequate quantities consisting of: 1-5 6-15 16-200 200+ Adhesive dressings X
X X X Adhesive tape rolls, 1-inch wide X X X X Eye dressing packet X X X X 1-inch gauze
bandage roll or compress X X X 2-inch gauze bandage roll or compress X X X X 4-inch
gauze bandage roll or compress X X X Sterile gauze pads, 2-inch square X X X X Sterile
gauze pads, 4-inch square X X X X Sterile surgical pads suitable for pressure dressings X X
Triangular bandages X X X X Safety pins X X X X Tweezers and scissors X X X X Cotton-
tipped applicators* X X Forceps* X X Emesis basin* X X Flashlight* X X Magnifying glass* X
X Portable oxygen and its breathing equipment* X Tongue depressors* X Appropriate record
forms* X X X X First-aid textbook, manual or equivalent* X X X X *To be readily available but not
necessarily within the first-aid kit.  

Drugs, antiseptics, eye irrigation solutions, inhalants, medicines, or proprietary preparations

shall  not be included in Cirks Construction Inc. first-aid kits unless specifically approved, in
writing, by  an employer-authorized licensed physician. Other supplies and equipment, if
provided, shall be  in accordance with the documented recommendations of an employer-
authorized licensed  physician upon consideration of the extent and type of emergency care to
be given based upon  the anticipated incident and nature of injuries and illnesses and
availability of transportation to  medical care. 

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First Aid 

The designated first aid person on each site will be available to render appropriate first aid for 
injuries and illnesses. Proper equipment for the prompt transportation of the injured or ill person 
to a physician or hospital where emergency care is provided, or an effective communication 
system for contacting hospitals or other emergency medical facilities, physicians, ambulance, 
and fire services, shall also be provided. The telephone numbers of the following emergency 
services in the area shall be posted near the job telephone, or otherwise made available to the 
employees where no job site telephone exists:  

1. A company authorized physician or medical clinic, and at least one alternate if

available.  2. Hospitals.  
3. 911.  
4. Fire-protection services. 
5. Police services.  

Prior to the commencement of work at any site, the supervisor or manager shall locate the 
nearest preferred medical facility and establish that transportation or communication methods 
are available in the event of an employee injury. 

Each employee shall be informed of the procedures to follow in case of injury or illness through 
our new employee orientation program, Code of Safe Practices, and safety meetings.  

Incident Procedures 

These procedures are to be followed in the event of an employee injury in the course of 
employment: 

1. For severe incidents call 911 and request the Paramedics. 

2. Employees must report all work related injuries to their supervisor immediately even if they 
do not feel that it requires medical attention. Failure to do so may result in a delay of  
Workers’ Compensation benefits and disciplinary action could be taken. 

3. The supervisor and employee should determine whether or not outside medical attention is 
needed. 

4. If medical attention is not desired or the employee refuses treatment, you must still fill out a 
Cirks Construction Inc. “Incident Report" in case complications arise later. 

5. In all cases, if the employee cannot transport himself or herself for any reason, 
transportation should be provided. 

6. In the event of a serious incident involving hospitalization for more than 24 hours, 
amputation, permanent disfigurement, loss of consciousness, or death, phone contact 
should be made with the office immediately. Contact must also be made by the safety 
director with the nearest CAL-OSHA office within 8 hours.

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Hazard Communication Program – Materials &

Chemicals Introduction 
It is the policy of Cirks Construction Inc. that the first consideration of work shall be the 
protection of the health and safety of all employees. We have developed this Hazard 
Communication Program to ensure that all employees receive adequate information about the 
possible hazards that may result from the various materials used in our operations. This
Hazard  Communication Program will be monitored by our safety director, who will be
responsible for  ensuring that all facets of the program are carried out, and that the program is
effective.  

Our program consists of the following elements: 

1. Hazardous material inventory 

2. Collection and maintenance of Safety Data Sheets (SDS) 
3. Container labeling 
4. Employee training 

The following items are not required to be included in the program and are therefore omitted: 

• Foods, drugs, cosmetics, and tobacco 

• Untreated wood products 
• Hazardous waste 
• Consumer products packaged for sale to and use by the general public provided 
that our exposure is not significantly greater than typical consumer exposure 

Hazardous Material Inventory 

The job site superintendent maintains a list of all hazardous materials used in our operations. 
This list contains the name of the product, the type of product (solvent, adhesive, etc.), and the 
name and address of the manufacturer.  

Safety Data Sheets (SDS) 

Copies of SDS for all hazardous substances, to which our employees may be exposed, will be 
kept in a binder at the job site and stored electronically at the office. SDS will be made
available  to all employees, at all times, upon request. Copies of the most commonly used
products will  also be kept by the supervisor at the work site.  

The safety director and on-site superintendent will be responsible for reviewing incoming SDS
for new and significant health and safety information. They will ensure that any new
information  is passed on to the affected employees. 

They will also review all incoming SDS for completeness. If an SDS is missing or obviously 
incomplete, a new SDS will be requested from the manufacturer. CAL-OSHA will be notified if
a  complete SDS is not received and the manufacturer will not supply one.  

New materials will not be introduced into the shop or field until a SDS has been received. The 
employees purchasing materials will make it an ongoing part of their function to obtain SDS for 
all new materials when they are first ordered.
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Container Labeling 

No container of hazardous substances will be used unless the container is correctly labeled
and  the label is legible. 

All chemicals in cans, bags, drums, pails, etc., will be checked by the receiving department to 
ensure the manufacturer's label is intact, is legible, and has not been damaged in any manner 
during shipment. Any containers found to have damaged labels will be held until a new label 
has been installed. New labels will be obtained from the manufacturer. 

The label must contain:  

• The chemical name of the contents 
• The appropriate hazard warnings 
• The name and address of the manufacturer 

All secondary containers will be labeled as to their contents with a reference to the original

label. Employee Information and Training 

All employees will be provided information and training on the following items through the
Cirks  Construction Inc. safety training program and prior to starting work with hazardous
substances: 

1. An overview of the requirements of the Hazard Communication Standard, including their 

rights under this regulation. 
2. Information regarding the use of hazardous substances in their specific work areas. 3.
The location and availability of the written hazard communication program. The program 
will be available from the job site specific superintendent. 
4. The physical and health hazards of the hazardous substances in use. 5. Methods and
observation techniques used to determine the presence or release of  hazardous
substances in the work area. 
6. The controls, work practices, and personal protective equipment that is available for 
protection against possible exposure. 
7. Emergency and first aid procedures to follow if employees are exposed to hazardous 
substances. 
8. How to read labels and Safety Data Sheets (SDS) to obtain the appropriate hazard 
information. 

Hazardous Non-Routine Tasks 

Infrequently, employees may be required to perform hazardous non-routine tasks. Prior to 
starting this work, each involved employee will be given information by his or her supervisor 
about hazards to which they may be exposed during such activity. 

This information will include: 

• The specific hazards 

• Protective and safety measures which must be utilized
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• The measures the company has taken to lessen the hazards, including special 
ventilation, respirators, the presence of another employee, emergency  procedures,
etc. 

Informing Outside Contractors and Vendors 

To ensure that outside contractors are not exposed to our hazardous materials, and to ensure 
the safety of the contractor’s employees, it will be the responsibility of the supervisor to provide 
outside contractors the following information: 

• The hazardous substances under our control that they may be exposed to while  at
the work site. 
• The precautions the contractor's employees must take to lessen the possibility of 
exposure. 

We will obtain from outside contractors and vendors the name of any hazardous substances
the  contractor's employees may be using at a work site or bringing into our facility. The
contractor  must also supply a copy of the material safety data sheet relevant to these
materials.  

Employee Rights Under The Hazard Communication Standard 

At any time, an employee has the right to: 

• Access the SDS folder, and the Hazard Communication Program. 

• Receive a copy of any environmental sampling data collected in the workplace.
• See their employment medical records upon request.
 June 2015 Page 25 
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Written Hazard Communication Plan 

The management of KDC Construction is committed to preventing accidents and ensuring

the  safety and health of our employees. We will comply with all applicable federal and state
health  and safety rules and provide a safe, healthful environment for all our employees. This
written  hazard communication plan is available at the following location for review by all
employees:  [Intranet, Office & at each job site location. 

Identifying hazardous chemicals 

Found within the SDS Master Book is a list that identifies all hazardous chemicals with a 
potential for employee exposure at this workplace. Detailed information about the physical, 
health, and other hazards of each chemical is included in a Safety Data Sheet (SDS); the 
product identifier for each chemical on the list matches and can be easily cross-referenced
with  the product identifier on its label and on its Safety Data Sheet. 

Identifying containers of hazardous chemicals 

All hazardous chemical containers used at this workplace will either the original
manufacturer’s  label -- that includes a product identifier, an appropriate signal word, hazard
statement(s),  pictogram(s), precautionary statement(s) and the name, address, and
telephone number of the  chemical manufacturer, importer, or other responsible party -- OR a
label with the appropriate  label elements just described; OR workplace labeling that includes
the product identifier and  words, pictures, symbols, or combination that provide at least
general information regarding the  hazards of the chemicals. 

The safety director, Stuart Nakutin and all superintendents will ensure that all containers
are  appropriately labeled. No container will be released for use until this information is
verified.  Workplace labels must be legible and in English. Information in other languages
is available  upon request. 

Keeping Safety Data Sheets (previously known as Material Safety Data Sheets) 

Safety Data Sheets are readily available to all employees during their work shifts.
Employees  can review Safety Data Sheets for all hazardous chemicals used at this
workplace. 

The Safety Data Sheets are updated and managed by Stuart Nakutin, KDC’s safety director. If
a  Safety Data Sheet is not immediately available for a hazardous chemical, employees can
obtain  the required information by calling Stuart Nakutin at 714-400-5023. 

Training employees about chemical hazards 

Before they start their jobs or are exposed to new hazardous chemicals, employees must
attend  a hazard communication training that covers the following topics: 
• An overview of the requirements in OSHA’s hazard communication rules.
• Hazardous chemicals present in their workplace. 
 • Any operations in their work area where hazardous chemicals are used. • The
location of the written hazard communication plan and where it may be  reviewed. 
• How to understand and use the information on labels and in Safety Data Sheets.
• Physical and health hazards of the chemicals in their work areas.
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• Methods used to detect the presence or release of hazardous chemicals in the  work
area. 
• Steps we have taken to prevent or reduce exposure to these chemicals. • How
employees can protect themselves from exposure to these hazardous  chemicals
through use of engineering controls/work practices and personal  protective
equipment. 
• An explanation of any special labeling present in the workplace. 
• Emergency procedures to follow if an employee is exposed to these chemicals. 

Stuart Nakutin is responsible to ensure that employees receive this training. After attending
the  training, employees will sign a form verifying that they understand the above topics and
how the  topics are related to our hazard communication plan. 

Informing contractors and other employers about our hazardous chemicals 

If employees of other employer(s) may be exposed to hazardous chemicals at our

workplace  (for example, employees of a construction contractor working on-site) It is the
responsibility of  the job site superintendent to provide contractors and their employees with
the following  information: 
• The identity of the chemicals, how to review our Safety Data Sheets, and an 
explanation of the container and pipe labeling system. 
• Safe work practices to prevent exposure. 

The job site superintendents will also obtain a Safety Data Sheet for any hazardous chemical
a  contractor brings into the workplace. 

Hazard Communication Safety Data Sheets 

The Hazard Communication Standard (HCS) requires chemical manufacturers, distributors,

or  importers to provide Safety Data Sheets (SDSs) (formerly known as Material Safety Data 
Sheets or MSDSs) to communicate the hazards of hazardous chemical products. As of June
1,  2015, the HCS will require new SDSs to be in a uniform format, and include the section 
numbers, the headings, and associated information under the headings below: 

Section 1, Identification includes product identifier; manufacturer or distributor name,

address,  phone number; emergency phone number; recommended use; restrictions on use. 
Section 2, Hazard(s) identification includes all hazards regarding the chemical; required
label  elements. 
Section 3, Composition/information on ingredients includes information on
chemical  ingredients; trade secret claims. 
Section 4, First-aid measures includes important symptoms/ effects, acute, delayed;
required  treatment. 
Section 5, Fire-fighting measures lists suitable extinguishing techniques, equipment;
chemical  hazards from fire. 
Section 6, Accidental release measures lists emergency procedures; protective
equipment;  proper methods of containment and cleanup.

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Section 7, Handling and storage lists precautions for safe handling and storage,
including  incompatibilities. 
Section 8, Exposure controls/personal protection lists OSHA's Permissible Exposure
Limits  (PELs); Threshold Limit Values (TLVs); appropriate engineering controls; personal
protective  equipment (PPE). 
Section 9, Physical and chemical properties lists the chemical's characteristics. 
Section 10, Stability and reactivity lists chemical stability and possibility of
hazardous  reactions. 
Section 11, Toxicological information includes routes of exposure; related symptoms,
acute  and chronic effects; numerical measures of toxicity. 
Section 12, Ecological information* 
Section 13, Disposal considerations* 
Section 14, Transport information* 
Section 15, Regulatory information* 
Section 16, Other information, includes the date of preparation or last revision. 
*Note: Since other Agencies regulate this information, OSHA will not be enforcing Sections
12  through 15(29 CFR 1910.1200(g)(2)). 

Employers must ensure that SDSs are readily accessible to employees.

 June 2015 Page 28 
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Fall Protection 
Cirks Construction Inc. has the following requirements for fall protection at all of our

worksites. Fall Protection is Required 

When working where there is a hazard of falling 6 ft. or more from the perimeter of a  
structure, unprotected sides and edges, leading edges, through shaft ways and
openings,  sloped roof surfaces steeper than 7:12, or other sloped surfaces steeper than
40 degrees  not otherwise adequately protected, fall protection is 100% mandatory, in
addition it is  also required when working on all temporary elevated platforms (example:
scissor and  boom lifts). 

Fall Protection Types 

One of the following four types of fall protection systems will be used when our employees are 
exposed to fall hazards of 6 feet or more:  

1. Standard guardrails, safety cables, or floor hole covers 

2. Personal fall arrest systems 
3. Positioning device systems 
4. Personal fall restraint systems 

Standard Guardrails, Safety Cables, or Covers 

These are the easiest and most cost effective methods of providing fall protection and have a 
very high success rate. Standard guardrails, safety cables, floor hole, and sky light covers are 
our preferred means of fall protection on job sites. The following rules will be followed when  
using them: 

1. Railings shall be constructed of wood or in an equally substantial manner from other 

materials. They shall consist of a top rail, not less than 42 inches or more than 45 inches  in
height, measured from the upper surface of the top rail to the floor, platform, runway, or 
ramp level. The mid-rail shall be halfway between the top rail and the floor, platform, 
runway, or ramp. "Selected lumber" free from damage that affects its strength shall be 
used.  

2. Wooden posts shall be no less than 2 inches by 4 inches in cross section, spaced at 8- foot
or closer intervals.  

3. Wooden top railings shall be smooth and of 2-inch by 4-inch or larger material. Double,   1-
inch by 4-inch members may be used for this purpose provided that one member is 
fastened in a flat position on top of the posts and the other fastened in an edge-up  position
to the inside of the posts and the side of the top member. Mid-rails shall be of at  least 1-
inch by 6-inch material.  
4. The rails shall be placed on the side of the post that will afford the greatest support and 
protection. 

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5. All railings, including their connections and anchorage, shall be capable of withstanding,
without failure, a force of at least 250 pounds applied to the top rail within 3 inches of the 
top edge in any outward or downward direction at any point along the top edge. When  the
250 pound test load is applied in a downward direction, the top edge of the guardrail 
should not deflect to a height less than 42 inches above the walking/working level.  

6. Mid-rails, screens, mesh, intermediate vertical members, solid panels, and equivalent 
members shall be capable of withstanding, without failure, a force of at least 150 pounds 
applied in any downward or outward direction at any point along the mid-rail, screen, 
mesh, or other intermediate member. 

7. Railings exposed to heavy stresses from employees trucking or handling materials shall 
provide additional strength by the use of heavier stock, closer spacing of posts, bracing,  or
by other means. 

8. The ends of the rails will not overhang the terminal posts, except where such overhang 
does not constitute a projection hazard. 

9. Railings will be of a smooth surface to prevent injury to an employee from punctures or 
lacerations, and to prevent snagging of clothing. 

10. Steel banding and plastic banding shall not be used as top rails or mid-rails. 

11. Railings receiving heavy stresses from employees trucking or handling materials shall 
provide additional strength by the use of heavier stock, closer spacing of posts, bracing,  or
by other means.  

12. Floor, roof, and skylight openings shall be guarded by a standard railing with toe boards  or
a cover. Coverings shall be capable of safely supporting the greater of 400 pounds or  twice
the weight of worker(s) and material(s) placed thereon.  

13. Coverings shall be secured in place to prevent incidental removal or displacement, and 
they should bear a pressure sensitized, painted, or stenciled sign with legible letters not 
less than one inch high, stating: "Opening--Do Not Remove." Markings of chalk or keel 
should not be used.  

14. Ladder-way floor openings or platforms shall be guarded by standard railings with  standard
toe boards on all exposed sides, except at the entrance to the opening, with the  passage
through the railing either provided with a swinging gate or so offset that a person  cannot
walk directly into the opening.  
15. Floor holes, into which persons can incidentally walk, shall be guarded by either a  standard
railing with standard toe boards on all exposed sides, or a floor hole-cover of  standard
strength and construction that is secured against incidental displacement.  While the cover
is not in place, the floor hole should be protected by standard railings.  

16. Wall openings, from which there is a drop of more than 4 feet, and the bottom of the  
opening is less than 3 feet above the working surface, shall be guarded with either a 
standard rail or intermediate rail or both. 

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17. An extension platform outside a wall opening onto which materials can be hoisted for 
handling shall have side rails or equivalent guards of standard specifications. One side  of
an extension platform may have removable railings in order to facilitate handling 
materials.  

18. Wall opening protection barriers shall be of such construction and mounting that, when in 
place at the opening, the barrier is capable of withstanding a load of at least 250 pounds 
applied in any direction (except upward).  

19. All elevator shafts in which cages are not installed and which are not enclosed with solid 
partitions and doors shall be guarded on all open sides by standard railings and toe 
boards.  

20. A full body harness and lanyard are required when using scissor and boom

lifts. Personal Fall Arrest Systems 

Personal fall arrest systems consist of a full body harness and the most appropriate connecting 
device attached to suitable anchorage. The system does not actually stop you from falling, but 
catches you and safely stops you from hitting the level below. Fall arrest systems will be our 
preferred means of protection when standard guardrails, safety cables, or covers are not 
practical. The following rules, in addition to the manufacturer’s requirements and OSHA 
regulations, will be observed: 

1. Ropes and straps (webbing) used in lanyards, lifelines, and strength components of body 
harnesses shall be made from synthetic fibers except when they are used in conjunction 
with Hot Work where the lanyard may be exposed to damage from heat or flame.  

2. Anchorages used for attachment of personal fall arrest equipment shall be independent  of
any anchorage being used to support or suspend platforms and capable of supporting  at
least 5,000 pounds per employee attached, or shall be designed, installed, and used  as
part of a complete personal fall arrest system which maintains a safety factor of at  least
two; and under the supervision of a qualified person.  
3. The attachment point of the body belt shall be located in the center of the wearer's back.  The
attachment point of the body harness shall be located in the center of the wearer's  back
near shoulder level or above the wearer's head.  

4. Where practical, the anchor end of the lanyard shall be secured at a level not lower than  the
employee's waist, limiting the fall distance to a maximum of 4 feet.  

5. Harnesses, lanyards, and other components shall be used only for employee protection  as
part of a personal fall arrest system and not to hoist materials.  

6. Personal fall arrest systems and components subjected to impact loading shall be 
immediately removed from service and shall not be used again for employee protection until
inspected and determined by a competent person to be undamaged and suitable for  reuse. 

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7. Cirks Construction Inc. shall provide for prompt rescue of employees in the event of a fall  or
shall assure that employees are able to rescue themselves.  

8. Personal fall arrest systems shall be inspected prior to each use for wear, damage and  other
deterioration, and defective components shall be removed from service.  

9. Any lanyard, safety harness, or drop line subjected to in-service loading, as distinguished 
from static load testing, shall be immediately removed from service and shall not be used 
again for employee safeguarding.  

10. Personal fall arrest systems shall not be attached to guardrails, unless the guardrail is 
capable of safely supporting the load.  

11. Each personal fall arrest system shall be inspected not less than twice annually by a 
competent person in accordance with the manufacturer's recommendations. The date of 
each inspection shall be documented.  

12. Personal fall arrest systems will be rigged such that an employee can neither free fall  more
than 4 feet, nor contact any lower level. 

13. Personal fall arrest systems will bring an employee to a complete stop. They will also  limit
maximum deceleration distance an employee travels to 3.5 feet and have sufficient 
strength to withstand twice the potential impact energy of an employee free-falling a 
distance of 6 feet, or the free-fall distance permitted by the system, whichever is less.  

Positioning Device Systems  

Positioning device systems are designed to allow employees to work with both hands free at 
elevated locations. By their very nature, they provide some level of fall protection. They are not 
as effective as railings or fall arrest systems. Positioning device systems may be used together 
with a fall arrest system for greater safety. Their use shall conform to the following provisions:  
1. Positioning devices shall be rigged such that an employee cannot free fall more than 2 
feet.  

2. Positioning device systems shall be inspected prior to each use for wear, damage, and  other
deterioration and defective components shall be removed from service.  

3. Body belts, harnesses, and components shall be used only for employee protection (as  part
of a personal fall arrest system or positioning device system) and not to hoist  materials.  

4. The use of non-locking snap hooks is prohibited.  

5. Anchorage points for positioning device systems shall be capable of supporting two times 
the intended load or 5,000 pounds, whichever is greater.  

Personal Fall Restraint Systems

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Fall restraint systems are designed to prevent the wearer from reaching the edge or danger
area  and thus prevent them from falling. Only full body personal fall arrest systems may be
used for  personal fall restraint.  

1. Body belts shall be at least one and five-eighths (1-5/8”) inches wide.  

2. Anchorage points used for fall restraint shall be capable of supporting 5,000 lbs.  

3. Restraint protection shall be rigged to allow the movement of employees only as far as  the
sides of the working level or working area. 
 June 2015 Page 33 
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Aerial Lift Safety Procedures 

Standard Procedures 

To ensure safe practices, the following general procedure is used when an authorized user
uses  an aerial platform lift: 

1. Obtain any necessary authorization to use the lift. 

2. Check the last pre-start inspection for any comments or notes. 

3. Perform a pre-start inspection on the lift, document the inspection, and place it in the 
reserved storage location on the lift. 

4. Perform a workplace inspection in the area that the lift will be used. 

5. Inspect and place your personal fall arrest systems. Note: Self-retracting lifelines are 
prohibited in scissor lifts.  

6. Extend and adjust the outriggers, stabilizers, extendible axles, or other stability  enhancing
means. 

7. Ensure that the guardrails are installed and are in place. 

8. Ensure that the load being placed on the lift is within the rated capacity of the

lift. 9. Test the controls of the lift. 

10. Ensure that all personnel on the lift have been trained and authorized to operate or work 
on the platform.  

Platform Qualifications 

These are the specifications for platforms and the following criteria shall be met to be an 
approved platform on a lift: 

1. Platform width shall be not less than 24 inches and shall have a slip resistant surface. 

2. The platform shall have a guardrail system around its periphery. It is removable or can  be
lowered. The means used to secure it in the normal operating position shall be  readily
accessible for inspection and maintenance. 

3. The guardrail system shall include a top rail that is between 42 and 45 inches high, a  mid-
rail that is approximately half-way from the platform to the top rail, and a toe board  that is
at least 3 ½ inches high. 
When to use personal fall protection 

When operating articulating or boom type lifts that are equipped with lanyard tie off points, the 
use of fall protection equipment is required. If special circumstances exist that encourage the 

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operator to use fall protection on vertical aerial platform lifts, they must tie off to a proper tie off 
point that is not attached to or part of the aerial platform lift itself.  

ANSI A92.6 series states that a worker need only be protected from falling by a properly
designed and maintained guardrail system. However, if the guardrail system is less than
adequate or the worker leaves the safety of the work platform, an additional fall protection
device would be required. The general scaffolding fall protection provision found in
1926.451(g)(1)(vii) reads in part, "[f]or all scaffolds not otherwise specified in this section, each
employee shall be protected by the use of personal fall arrest systems or guardrails systems.” 

Markings and Decals 

In addition to any other markings or decals that are placed on the lift by the 
manufacturer, the following information shall be displayed on all aerial platform lifts in
a  clearly visible, accessible area, and in a durable manner: 

1. The make, model, serial number, and manufacturer’s name and

address. 2. The rated workload, including rated number of occupants. 

3. The maximum platform height. 

Safe Operation During Operation 

1. Attention shall be given towards the direction of travel, clearances above, below and on  all
sides. 

2. Employees shall not sit or climb on the guardrails of the aerial lift. 

3. Planks, ladders, or other devices shall not be used on the work platform. 

4. An aerial lift shall not be moved when the boom is elevated in a working position with 
employees in the basket. 

5. Aerial lift shall not be placed against another object to steady the elevated

platform. 6. Aerial lift shall not be used as a crane or other lifting device. 

7. Aerial lift devices shall not be operated on grades, side slopes, or ramps that exceed the 
manufacturer's recommendations. 
8. The brakes shall be set and outriggers, when used, shall be positioned on pads or a  solid
surface. 

9. Speed of aerial lift devices shall be limited according to the conditions of the ground 
surface, congestion, visibility, slope, location of personnel, and other factors that may 
cause hazards to other nearby personnel. 

10. Stunt driving and horseplay shall not be permitted.

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11. Booms and elevated platform devices shall not be positioned in an attempt to jack the 
wheels off the ground. 

12. The area surrounding the elevated platform shall be cleared of personnel and equipment 
prior to lowering the elevated platform. 

13. All equipment must be secured on the inside of the aerial lift. 

14. Operators are to call for assistance if the platform or any part of the machine becomes 
entangled. 

Inspections 

The inspection process is a critical step in preventing aerial lift incidents that are caused from 
faulty or worn out equipment. Aerial platform lifts that are not in proper operating condition
shall  be removed from service until the problems have been corrected by an authorized and
trained  maintenance technician. 

Pre-Start Inspections 

Before each day’s use or at the beginning of each shift that the aerial platform lift is used it
shall  be given a pre-start inspection, which is a visual inspection and functional test that
includes the  following criteria: 

1. Operating and emergency controls. 

2. Safety devices. 

3. Personal protective devices. 

4. Air, hydraulic, and fuel system leaks. 

5. Cables and wiring harness. 

6. Loose or missing parts. 

7. Tires and wheels. 

 8. Placards, warnings, control markings, and operating manual(s). 

9. Outriggers, stabilizers, and other structures. 

10. Guardrail system and other items specified by manufacturer.

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Aerial Platform Lift Pre-start Inspection Form 

The pre-start inspection shall be performed prior to each day’s or shift’s use of the aerial 
platform lift by an authorized and trained user of the lift.  

Check off the items that have been inspected or mark the N/A box if the item does not apply
to  the lift being inspected. Place any comments in the space provided below. If there are any
of  these items that are not satisfactory place the lift out of service until the item is corrected. 

Lift Provider: 

Make of lift: Model of lift: Serial #:  Inspector’s Name: Date of Inspection: 

Item Inspected Okay Not Okay N/A 

Operating controls    Emergency controls    Safety devices    Personal protective
devices    Pneumatic system (leaks)    Hydraulic system (leaks)    Fuel system
(leaks)    Cables    Wiring harness    Loose/missing parts (locking pins/bolts…)   
Tires and wheels    Placards and Warnings    Operational Manual   
Outriggers/Stabilizers    Guardrail system and locking gate    Other items:    

   

   

   

   

   

Comments: 
Inspector’s Signature: Date:

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Electrical Safety & Lock-out / Tag-out Program 

Cirks Construction Inc. has developed the following procedures to protect our employees and 
reduce the risk of incidents. We will also conduct a periodic review of electrical safety, energy 
control procedures, and lock-out / tag-out, at least annually, to ensure that the procedure and
the  requirements of this section are being followed.  

This procedure is binding upon all employees. All employees will be instructed in the 
significance of electrical safety, energy control procedures, and lock-out / tag-out. Each new 
employee shall be instructed by their supervisor in the purpose and use of these procedures.  

All Equipment and Installations 

1. Only trained, qualified, and authorized employees will be allowed to make electrical  repairs
or work on electrical equipment or installations.  

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

3. All energized equipment and installations will be de-energized prior to the  commencement of
any work. If the equipment or installation must be energized for test  or other purposes,
special precautions will be taken to protect against the hazards of  electric shock.  

4. All equipment shall be locked out to protect against incidental or inadvertent operation  when
such operation could cause injury to personnel. Do not attempt to operate any  switch,
valve, or other energy-isolating device bearing a lock. 

5. Safety grounds shall always be used where there is a danger of shock from back feeding  or
other hazards. 

6. Polyester clothing or other flammable types of clothing shall not be worn near electrical 
circuits. Cotton clothing is much less likely to ignite from arc blast. Employees working  on
live circuits shall be provided Nomex or equivalent fire resistant clothing. 

7. Suitable eye protection must be worn at all times while working on electrical equipment. 

8. Always exercise caution when energizing electrical equipment or installations. Take  steps to
protect employees from arc blast and exploding equipment in the event of a fault. 
9. All power tools will be grounded or double insulated. Tools with defective cords or wiring 
shall not be used. 

10. Suitable temporary barriers or barricades shall be installed when access to open
enclosures  containing exposed energized equipment is not under the control of an
authorized person. 

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Energized Equipment or Systems  

Work shall not be performed on exposed energized parts of equipment or systems until the 
following conditions are met:  

1. Responsible supervision has determined that the work is to be performed while the 
equipment or systems are energized.  

2. All work is conducted in accordance with the requirements of NFPA Standard 70E for 
Electrical Safety. 

3. Involved personnel have received instructions on the work techniques and hazards  involved
in working on energized equipment and appropriate equipment to perform the  job has been
provided.  

4. Suitable personal protective equipment has been provided and is used. Suitable  insulated
gloves shall be worn for voltages in excess of 300 volts, nominal.  

5. Suitable eye protection, including face shield and safety glasses or goggles, has been 
provided and is used.  

6. Suitable arc flash and arc blast protection is provided for high voltage

work. 7. Fire resistant clothing such as Nomex suits shall be worn. 

8. Where required, suitable barriers, barricades, tags, or signs are in place for personnel 
protection.  

After the required work on an energized system or equipment has been completed, an 
authorized person shall be responsible for:  

1. Removing from the work area any personnel and protective

equipment.  2. Reinstalling all permanent barriers or covers.  

De-energized Equipment or Systems 

A qualified person shall be responsible for completing the following before working on de
energized electrical equipment or systems, unless the equipment is physically removed from
the  wiring system:  

1. Notifying all involved personnel.  

2. Locking the disconnecting means in the "open" position with the use of lockable devices, 
such as padlocks, combination locks, or disconnecting of the conductor(s) or other  positive
methods or procedures which will effectively prevent unexpected or inadvertent  energizing
of a designated circuit, equipment, or appliance.  

3. Tagging the disconnecting means with suitable incident prevention tags. 

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4. Effectively blocking the operation or dissipating the energy of all stored energy devices 
which present a hazard, such as capacitors or pneumatic, spring-loaded and like 
mechanisms. This may require the installation of safety grounds. 

5. Testing the equipment to ensure it is de-energized. 

Energizing (or Re-energizing) Equipment or Systems  

A qualified and authorized person shall be responsible for completing the following before 
energizing equipment or systems that have been de-energized:  

1. Determining that all persons are clear from hazards which might result from the  equipment
or systems being energized including arc blast or explosions caused by  unexpected
faults.  

2. Removing locking devices and tags. Only the employee who placed them may remove 
locking devices and tags. Locking devices and tags shall be removed upon completion of 
the work and after the installation of the protective guards or safety interlock systems. 

Incident Prevention Tags  

Suitable incident prevention tags shall be used to control a specific hazard. Such tags shall 
provide the following minimum information:  

1. Reason for placing tag.  

2. Name of person placing the tag and how that person may be

contacted.  3. Date tag was placed.  

Lock-out / Tag-out 
Machinery or equipment capable of movement shall be stopped and the power source de
energized or disengaged, and locked out. If necessary, the moveable parts shall be 
mechanically blocked or secured to prevent inadvertent movement during cleaning, servicing or 
adjusting operations unless the machinery or equipment must be capable of movement during 
this period in order to perform the specific task. If so, the hazard of movement shall be 
minimized.  

Equipment or power driven machines equipped with lockable controls, or readily adaptable to 
lockable controls, shall be locked out or positively sealed in the "off" position during repair work 
and setting-up operations. In all cases, incident prevention signs or tags shall be placed on the 
controls of the equipment or machines during repair work.  

Cirks Construction Inc. will ensure a competent person provides a sufficient number of incident
prevention signs or tags and padlocks, seals, or other similarly effective means that may be 
required by any reasonably foreseeable repair. 

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Sequence of Lockout Procedure  

1. Notify all affected employees that a lockout is required and the reason therefore. 

2. If the equipment is operating, shut it down by the normal stopping procedure (such as: 
depress stop button, open toggle switch). 

3. Operate the switch, valve, or other energy isolating devices so that the energy source(s) 
(electrical, mechanical, hydraulic, other) is disconnected or isolated from the equipment. 

4. Stored energy, such as that in capacitors, springs, elevated machine members, rotating  fly
wheels, hydraulic systems, and air, gas, steam or water pressure, must also be  dissipated
or restrained by methods such as grounding, repositioning, blocking, or bleeding down.  

5. Lockout energy isolating devices with an assigned individual lock. 

6. After ensuring that no personnel are exposed and as a check on having disconnected the 
energy sources, operate the push button or other normal operating controls to make  certain
the equipment will not operate. CAUTION: Return operating controls to neutral  position
after the test.  

Procedure Involving More Than One Person  

If more than one individual is required to lock out equipment, each shall place his or her own 
personal lock on the energy isolating device(s). One designated individual of a work crew or a 
supervisor, with the knowledge of the crew, may lock out equipment for the whole crew. In such 
cases, it may be the responsibility of the individual to carry out all steps of the lockout
procedure  and inform the crew when it is safe to work on the equipment. Additionally, the
designated  individual shall not remove a crew lock until it has been verified that all individuals
are clear.  

Testing Equipment During Lockout 

In many maintenance and repair operations, machinery may need to be tested, and for that 
purpose energized, before additional maintenance work can be performed. This procedure
must  be followed:  

1. Clear all personnel to safety.  

2. Clear away tools and materials from equipment. 

3. Remove lockout devices and re-energize systems, following the established safe  procedure. 

4. Proceed with tryout or test.  

5. Neutralize all energy sources once again, purge all systems, and lockout prior to  continuing
work. 

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Equipment design and performance limitations may dictate that effective alternative worker 
protection be provided when the established lock-out procedure is not feasible.  

Restoring Equipment to Service 

After the work is completed and the equipment is ready to be returned to normal operation, this 
procedure must be followed:  

1. Remove all non-essential items.  

2. See that all equipment components are operationally intact, including guards and safety
devices. Repair or replace defective guards before removing lockouts.  

3. Remove each lockout device using the correct removal sequence. 

4. Make a visual check before restoring energy to ensure that everyone is physically clear of 
the equipment. 
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Driving Safety Policy 

Cirks Construction Inc. has established the following guidelines and procedures for our drivers 
and vehicles to protect the safety of individuals operating any motor vehicle on company 
business. Protecting our employee drivers, their passengers, and the public is of the highest 
priority. The commitment of management and employees is critical to the success of this 
program. Clear communication of, and strict adherence to, the program's guidelines and 
procedures are essential. 

Our primary goal is to maintain a high level of safety awareness and foster responsible driving 
behavior. Driver safety awareness and responsible driving behavior will significantly decrease 
the frequency of motor vehicle incidents and reduce the severity of personal injuries and 
property damage.  

Drivers must follow the requirements outlined in this program. Violations of this program may 
result in disciplinary action up to, and including, suspension of driving privileges or dismissal. 

Our program consists of the following elements: 

• Driver selection 
• Driver training 
• Vehicle use policy 
• Vehicle inspection and preventive maintenance 
• Incident investigation 

Driver Selection 

Only company authorized and assigned employees are allowed to drive company vehicles. 
Prior to being authorized and assigned, Cirks Construction Inc. will check for the following
items: 

• A valid un-restricted driver license. 

• A current motor vehicle driving record with no more than 2 points and no serious  or
major violations. 

Cirks Construction Inc. will also check driving records of all employees authorized to drive on 
company business on an annual basis. 

Employees that do not meet these requirements are not authorized or allowed to drive
company  vehicles or drive their own vehicle on company business. 

Driver Training 

All employees driving company vehicles and personal vehicles on company business will be 
given a copy of the Driving Safety Rules and Company Vehicle Use Policy and required to
 read  and sign for them. Safe driving will also be periodically covered at company safety
meetings.

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Company Vehicle Use Policy 

Cirks Construction Inc. has established the following policies pertaining to company vehicles: 

1. Only authorized employees may drive Cirks Construction Inc. vehicles.  2. Seat belts

must be worn at all times per the law.  

3. No employee is permitted to drive Cirks Construction Inc. vehicles while impaired by 
alcohol, illegal or prescription drugs, or over the counter medications. 

4. Employees shall not engage in any activities that distract them from driving while  operating
vehicles. This includes eating, reading maps, texting, looking for reports or  files, and
talking on a cell phone without a hands free device. 

5. All incidents involving Cirks Construction Inc. vehicles must be reported to the office 
immediately. 

6. Employees with two or more preventable incidents in a three year period or that obtain  three
points on their driving record, will be subject to a loss of their driving privileges or  have
their driving privileges restricted. 

Vehicle Inspection and Preventive Maintenance 

All Cirks Construction Inc. vehicles must be inspected by the driver prior to each use. 
Mechanical defects will be repaired immediately. The safety director and general 
superintendent will periodically spot check company vehicles to determine their condition. 

Vehicle inspections will include: 

• Lights 
• Turn signals 
• Emergency flashers 
• Tires 
• Horn 
• Brakes 
• Fluids 
• Windshield condition and wiper condition 
• Mirrors 
All vehicles will also be maintained in accordance with the manufacturers’ recommendations. It 
is the responsibility of the individual assigned the vehicle to ensure proper maintenance and 
repairs are performed. If your vehicle is not safe, do not drive. 

Incident Investigation 

All incidents in Cirks Construction Inc. vehicles will be investigated by the supervisor, manager 
or safety director. Where possible, witness statements will be obtained and photos used to 
document the scene of the incident and the damage. Police reports will also be obtained 
whenever possible. The following guidelines will be used to help determine preventability.
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Auto Incident Preventability Guide 

This guide will assist in determining whether our driver could have prevented the incident. An 
incident is preventable if the driver could have done something to avoid it. Drivers are
expected  to drive defensively. Which driver was primarily at fault, which received a traffic
citation, or  whether a claim was paid has no bearing on preventability. If there was anything
our driver  could have done to avoid the collision, then the incident was preventable. 

An incident was non-preventable when the vehicle was legally and properly parked or when 
properly stopped because of a highway patrol officer, a signal, stop sign, or traffic condition. 
When judging incident preventability, here are some general questions to consider: 

1. Does the investigation indicate that the driver considers the rights of others, or is there 
evidence of poor driving habits that need to be changed? 

2. Does the investigation indicate driver awareness? Such phrases as "I did not see," "I  didn't
think," "I didn't expect," or "I thought" are signals indicating there probably was a  lack of
awareness and the incident was preventable. An aware driver should think,  expect, and
see hazardous situations in time to avoid collisions. 

3. Was the driver under any physical stresses that could have been contributory? Did the 
incident happen near the end of a long day or long drive? Did overeating contribute to 
fatigue? Did the driver get prior sufficient sleep? Is the driver's vision faulty? Was the  driver
feeling ill? 

4. Was the vehicle defective without the driver's knowledge? Was a pre-trip inspection  done,
and would they have discovered the defect? A car that pulls to the left or right   when the
driver applies the brakes, faulty windshield wipers, and similar items are  excuses, and a
driver using them is trying to evade responsibility. Sudden brake failure,  loss of steering, or
a blowout might be defects beyond the driver's ability to predict.  However, pre-trip
inspections and regularly scheduled maintenance should prevent most  of these problems.
If either of these are the cause of the incident, then the incident was  probably preventable
by the driver. 
5. Could the driver have exercised better judgment by taking an alternate route through  less
congested areas to reduce the hazardous situations encountered? 

6. Could the driver have done anything to avoid the incident? 

7. Was the driver's speed safe for conditions? 

8. Did the driver obey all traffic signals? 

9. Was the driver's vehicle under control? 

Intersection Collisions 

Failure of our driver to yield the right-of-way, regardless of who has the right of way, as 
indicated by stop signs or lights, is preventable. The only exception to this is when the driver is 

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properly proceeding through an intersection protected by lights or stop signs and the driver's 
vehicle is struck in the extreme rear side of the vehicle. Regardless of stop signs, stoplights, or 
right-of-way, a defensive driver recognizes that the right-of-way belongs to anyone who 
assumes it and should yield accordingly.  

Questions to consider: 

1. Did the driver approach the intersection at a speed safe for

conditions? 2. Was the driver prepared to stop before entering the

intersection? 

3. At a blind corner, did the driver pull out slowly, ready to apply the

brakes? 4. Did the driver look both ways before proceeding through the

intersection? Sideswipes 

Sideswipes are often preventable. Defensive drivers do not get into a position where they can 
be forced into another vehicle or another vehicle can be forced into them. Defensive drivers 
continuously check for escape routes to avoid sideswipes. For two lane roads, this means a 
driver should pass another vehicle only when absolutely certain that he or she can safely 
complete the pass. A driver should also be ready to slow down and let a passing vehicle that 
has failed to judge safe passing distance back into the lane. A driver should make no sudden 
moves that may force another vehicle to swerve. If a driver sideswipes a stationary object
while  taking evasive action to avoid striking another car or a pedestrian, such an incident may
not be  preventable. However, you should consider what the driver could have done or failed to
do  immediately preceding the evasive action to be in the position of no other options. 
A driver is also expected to anticipate the actions of an oncoming vehicle. Sideswiping an 
oncoming vehicle is often preventable. Again, evasive action, including leaving the roadway, 
may be necessary if an oncoming vehicle crosses into the driver's lane. Drivers are expected
to  allow merging vehicles to merge smoothly with them, and to merge smoothly on controlled 
access highways. Drivers are expected to be able to gauge distances properly when leaving a 
parking place and enter traffic smoothly. 

Questions to consider: 

1. Did the driver look to front and rear for approaching and overtaking traffic immediately 
before starting to pull away from the curb? 

2. Did the driver signal before pulling away from the curb? 

3. Did the driver look back rather than depend only upon rear-view mirrors? 

4. Did the driver start into traffic only when this action would not require traffic to change its 
speed or direction in order to avoid his or her vehicle? 

Head-on Collisions

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A head-on collision with a vehicle traveling in the wrong lane may be preventable if the driver 
could have pulled off the road or taken other evasive action to prevent a collision. However,
the  driver should never drive into the other lane to avoid the oncoming vehicle. If the driver
swerved  off the road to avoid a head-on collision, the incident is non-preventable. The driver in
this case  made a good defensive driving decision, taking the lesser of two evils. 

Many skidding conditions are caused by rain, freezing rain, fog, and snow, which all increase 
the hazard of travel. Oily road film, which builds up during a period of good weather, causes
an  especially treacherous condition during the first minutes of a rainfall. Loss of traction can
be  anticipated, and these incidents usually are preventable. Driving too fast for conditions is
the  most common reason why these types of incidents are preventable.  

Questions to consider: 

1. Was the driver operating at a safe speed considering weather and road conditions? 

2. During inclement weather, was the driver keeping at least twice the safe following  distance
used for dry pavement? 

3. Were all actions gradual? 

4. Was the driver anticipating ice on bridges, in gutters, ruts, and near the curb? 

5. Was the driver alert for water, ice, or snow in shaded areas, loose gravel, sand, ruts,  etc? 
If a driver goes off the road or strikes another vehicle because of skidding, the incident is 
preventable.  

Pedestrian Incidents 

All types of pedestrian incidents, including collisions with pedestrians coming from between 
parked cars, are usually considered preventable. There are few instances where the action of 
pedestrians is so unreasonable that the operator could not be expected to anticipate such an 
occurrence.  

Questions to consider: 

1. Did the driver go through congested areas expecting that pedestrians would step in front  of
the vehicle? 

2. Was the driver prepared to stop? 

3. Did the driver keep as much clearance between his or her vehicle and parked vehicles,  as
safety permitted? 

4. Did the driver stop when other vehicles had stopped to allow pedestrians to

cross? 5. Did the driver wait for the green light or stop for the caution light?

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6. Was the driver aware of children and prepared to stop if one ran into the

street? 7. Did the driver give all pedestrians the right-of-way? 

8. Did the driver stop for a school bus that was stopped and properly signaling that 
passengers were loading or unloading? 

Backing Incidents 

Backing a vehicle into another vehicle, an overhead obstruction, or a stationary object is 
normally preventable. The fact that someone was directing the driver in backing does not 
relieve the driver of the responsibility to back safely. 

Questions to consider: 

1. Did the driver plan ahead so that he or she could have pulled forward out of the parking 
space instead of backing? 

2. Was it necessary to drive into the narrow street, dead-end alley, or driveway from which  he
or she backed up? 
3. If the driver could not see where he or she was backing: Did the driver try to get  someone to
guide him or her?  

4. Did the driver look all around the vehicle before backing up? Did the driver back up 
immediately after looking?  

5. Did the driver use the horn while backing up? Were the back-up lights working? 6.

Did the driver look to the rear without relying totally on the rear-view mirror? 7. If the

distance was long, did the driver stop, get out, and look around occasionally? 8. Did

the driver back up slowly? 

9. Did the driver judge clearances accurately? 

Parking Incidents 

Doors on our driver's parked vehicle that are damaged when opened on the traffic side are 
considered preventable incidents. The driver is responsible to see that the traffic side is clear
of  traffic before any doors on that side are opened. 

In most cases, if our driver strikes a parked vehicle's opening door while driving, it is
considered  preventable. Usually our driver can see from a sufficient distance that the parked
vehicle is occupied, and should therefore be prepared to stop, move closer to the center line,
or change  lanes.  

It is a driver's responsibility to park the vehicle so that it will remain stationary. A runaway type 
incident is preventable and blaming such a collision on defective parking brakes or other
holding 

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devices are inadequate excuses. A good pre-trip inspection and maintenance program will 
eliminate most opportunities for this type of incident being the result of mechanical failure. 

Incidents occurring when vehicles are properly and legally parked are considered non
preventable. Incidents occurring while a vehicle is double-parked or in a "No Parking" zone is
preventable. 

Questions to consider: 

1. Was the vehicle parked on the proper side of the road? 

2. Was it necessary to park there, or was there a safer only slightly less convenient place 
nearby? 

3. Did the driver have to park on the traveled part of the highway, on the curve, or on the  hill? 
 4. When required, did the driver warn traffic by emergency warning

devices? 5. Did the driver park parallel to the curb? 

6. Was it necessary to park so close to an alley or directly across from a

driveway? Collision with Obstructions  

Obstructions can be avoided if the driver knows the height and width of the vehicle, pays 
attention to posted clearances, and takes the time to properly judge clearances. 

Cargo Incidents 

The incident should be considered preventable if the investigation shows a mechanical defect
of  which the driver was aware, a defect the driver should have found by inspecting the vehicle,
or  the driver caused the incident by rough and abusive handling. It is a driver's responsibility
to  secure cargo properly to prevent shifting, loss, or damage. Cargo should be safely stowed
to  prevent flying objects that can strike or distract the driver. 

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Driving Safety Rules 

Motor vehicle incidents continue to be the leading cause of workplace death in the nation. In 
1995 alone, 1,329 workers were killed on the job in auto incidents. That’s one employee death 
every 7 hours of every day. 

Motor vehicle incidents are:* 

• The leading cause of death at work. 

• The leading cause of death for people age 15 to 24. 
• The second most common cause of death for people age 25 to 44. 
• The third most common cause of death for people age 45 to 64. 
 • The fifth most common cause of death for all ages behind heart disease, cancer, 
stroke, and lung disease. 

*Source: 1995 statistics from the National Institute of Occupational Safety and Health (NIOSH) 
and the Bureau of Labor Statistics (BLS). 

Fortunately, auto incidents are often preventable. By driving defensively and using good 
judgment, you can significantly reduce your chances of being hurt or killed in a motor vehicle. 
The following defensive driving tips are designed to help you avoid incidents and injuries from 
your fleet operations. 

These rules are mandatory for all employees driving Cirks Construction Inc.

vehicles: 1. Personal and off duty use of Cirks Construction Inc. vehicles is

prohibited. 

2. Only authorized employees may drive Cirks Construction Inc. vehicles. No other family 
members may drive company vehicles. 

3. Seat belts must be worn at all times per the law. Hundreds of studies over the years  have
proven, without a doubt, that seat belts save lives. This is true even in crashes  involving
fire and water submersion. Properly worn seat belts actually absorb crash  forces that;
otherwise, would be transferred to your body. If the seat belts in your vehicle  are
inoperative or defective, have them repaired or replaced immediately. You should  wear the
lap belt low across your hips and have the shoulder strap directly across your  chest. You
also need to keep the belt tight. There should not be more than an inch  between your body
and the belt at any point. 

4. No employee is permitted to drive Cirks Construction Inc. vehicles while impaired by 
alcohol, illegal or prescription drugs, or over the counter medications. The use of drugs  or
alcohol while driving, or prior to driving, significantly increases your chances of having  an
incident. It should be at least eight hours from the time you take a drink until  operating a
vehicle. You should also avoid the use of prescription or over the counter  medicines that
make you drowsy.  

5. All incidents involving Cirks Construction Inc. vehicles must be reported to the office 
immediately.

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6. Employees with two or more preventable incidents in a three year period, or that obtain 
three points on their driving record, will be subject to a loss of their driving privileges or 
have their driving privileges restricted. 
7. Get the big picture while driving. Keep your eyes aimed high and try to anticipate  hazards
and other drivers’ mistakes. You should be looking well ahead of where you  are. You
should also always leave yourself an out in case the other driver does the  unexpected. 

8. Maintain a safe following distance at all times. Approximately 1/3 of all auto incidents  are
rear end collisions. You should be at least two seconds behind the vehicle in front of  you to
allow yourself sufficient time to stop. Do not tailgate. Following distances should  be
increased for larger vehicles or if in slippery or rainy conditions. 

9. Avoid passing on two lane roads. Head on collisions are the most common cause of 
fatalities. You should also turn on your headlights while driving on two lane roads. This 
helps oncoming traffic see and avoid you. Never pass another vehicle on blind turns or 
hills. 

10. Inspect the vehicle for mechanical defects prior to each trip. Test your brakes as soon  as
you start out to insure they are properly operating. Worn tires can make your vehicle 
difficult to control or stop. 

11. Avoid dialing the phone, reading maps, or other distracting activities while driving.  These
actions take your eyes off the road and often cause you to swerve. Pull over into  a safe
parking area before making that call. 

12. Never drive faster than road conditions warrant. Slow down when road conditions are  poor
(rain, fog, night) and never exceed posted speed limits. 

13. Always signal when changing lanes or turning. Always signal well in advance when 
changing lanes or turning and make sure to check your blind spot for other vehicles.  Also,
avoid driving in someone else’s blind spot. If they can’t see you; they don’t know  you are
there. 

14. Use caution when passing any stopped vehicle, especially near intersections or cross 
walks. 

15. Aggressive driving has become a significant problem in the past few years. Don’t do it. 
Avoid tailgating, rapid lane changes, speeding, and hand gestures to bad drivers. You 
never know; they may be armed. If you are being tailgated, change lanes and let them 
pass. It’s really not worth getting killed over. 

16. Intersection collisions are also a significant problem. These are often caused by  someone
running the red light. You should always be under control when approaching  an
intersection and be prepared to stop if the light changes. 

17. Slow down and look for trains at all railroad crossings. Even with modern signals and 
gates, hundreds of cars are hit by trains each year at grade crossings.

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18. Use your low beams while driving in fog and slow down. If you can’t see, pull over into a 
safe parking area and wait for better visibility. Do not stop in the traffic lanes. You will 
almost certainly be hit by another vehicle if you do. 

19. Always walk behind the vehicle before backing. This will insure that there are no people  or
objects behind you that you cannot see from the driver’s seat. You should also make  sure
that all loads are properly secured to prevent them from moving. Numerous  incidents are
caused by objects that have fallen off company vehicles. 

20. Yield the right of way until you are sure the other driver is going to stop. Just because   you
have the legal right of way doesn’t mean you should always take it. Always yield the  right
of way to emergency vehicles. 

Defensive Drivers 

• Expect the unexpected. 

• Anticipate bad driving by others. 
• Look ahead for hazards. 
• Always leave themselves an out. 
• Always drive under control. 
• Obey the rules of the road.
 June 2015 Page 52 
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Driving Safety Rules - Company Vehicle Policy Receipt 

This is to certify that I have received a copy of the Cirks Construction Inc. Driving Safety Rules
and  Company Vehicle Policy. I have read these instructions, understand them, and will comply
with  them while driving company vehicles.  

I also understand that I am to report any incident (no matter how minor) to the office
immediately. 

I understand that failure to abide by these rules will result in disciplinary action and possible  
suspension of my driving privileges, which may prevent my ability to continue employment for
Cirks  Construction Inc. 

Print Name: _______________________________________ Date:

_______________________ Signature:

_____________________________________________________________________ Copy:

Employee File
 June 2015 Page 53 
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Confined Space Operations 

Occasionally in our work, we may encounter confined spaces. Confined space work requires 
special safety precautions to ensure that employees are not overcome by dangerous air 
contaminants or oxygen deficiency. In some cases, there may be fire or explosion hazards in 
confined spaces that do not exist in open areas. Many workers have been killed or seriously 
injured in confined spaces. To avoid this, Cirks Construction Inc. employees must adhere to
the  following rules. This section prescribes minimum standards for preventing employee
exposure  to dangerous air contamination or oxygen deficiency in confined spaces. In some
cases, extra  precautions may be necessary. As always, if you are unsure ask for assistance. 

Definitions 

A confined space has the following properties:  

1. Existing ventilation is insufficient to remove dangerous air contamination or oxygen 

deficiency that may exist or develop.  

2. Ready access or egress for the removal of a suddenly disabled employee is difficult due  to
the location or size of the opening(s).  

3. The area is not designed for continuous human occupancy. 

4. One means of access and egress. 

Dangerous air contamination means an atmosphere presenting a threat of causing death, 

injury, acute illness, or disablement due to the presence of flammable or explosive, toxic, or 
otherwise injurious or incapacitating substances.  

Dangerous air contamination due to the flammability of a gas or vapor is defined as an 
atmosphere containing the gas or vapor at a concentration greater than 20 percent of its lower 
explosive (lower flammable) limit (LEL).  

Dangerous air contamination due to a combustible particulate is defined as a concentration 

greater than 20 percent of the minimum explosive concentration of the particulate.  

Dangerous air contamination due to the toxicity of a substance is defined as the atmospheric 
concentration immediately hazardous to life or health. This definition of dangerous air 
contamination due to the toxicity of a substance does not preclude the requirement to control 
harmful exposures to toxic substances at concentrations less than those immediately
hazardous  to health or life.  

Oxygen deficiency is an atmosphere containing oxygen at a concentration of less than 19.5 

percent by volume.  

Oxygen rich is an atmosphere containing oxygen at a concentration of more than 22 percent

by  volume. This creates additional fire hazards.
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Typical Confined Spaces 

• Vaults 
• Pits 
• Tubs 
• Vats 
• Ducts 
• Boilers 
• Silos 
• Sewers 
• Compartments 

Prior to Confined Space Entry 

1. Written understandable operating and rescue procedures shall be developed and shall  be
provided to affected employees via a detailed job hazard analysis. The operating 
procedures shall include provision for the surveillance of the surrounding area to avoid 
hazards such as drifting vapors from tanks, piping, and sewers.  

2. All employees, including standby persons if needed, will be trained in the operating and 
rescue procedures, including instructions as to the hazards they may encounter.  

3. Any lines, pipes, or hoses which may convey flammable, injurious, or incapacitating 
substances into the space shall be disconnected, blinded, or blocked off by other  positive
means to prevent the development of dangerous air contamination or oxygen  deficiency
within the space. The disconnection or blind shall be located or done in such  a manner that
inadvertent reconnection of the line or removal of the blind is effectively  prevented.  

4. The space shall be emptied, flushed, or otherwise purged of flammable, injurious, or 
incapacitating substances to the extent feasible.  

5. The air shall be tested with an appropriate device or method to determine whether 
dangerous air contamination or an oxygen deficiency exists and a written record of such 
testing results shall be made and kept at the work site for the duration of the work.  Affected
employees or their representative shall be afforded an opportunity to review  and record the
testing results.  

6. Where interconnected spaces are blinded off as a unit, each space shall be tested and  the
results recorded. The most hazardous condition found shall govern the entry  procedures to
be followed.  

Confined Space Entry if Tests Show No Hazard 

If dangerous air contamination or oxygen deficiency does not exist within the space, as 
demonstrated by tests performed in accordance with the pre-entry procedures, entry into and 
work within the space may proceed subject to the following provisions: 
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1. Air testing, in accordance with the pre-entry procedures, shall be conducted with  sufficient
frequency to ensure that the development of dangerous air contamination or oxygen
deficiency does not occur during the performance of any operation.  

2. Work stops, employees exit, and additional precautions are taken if dangerous air 
contamination or oxygen deficiency does develop. 

Confined Space Entry if Tests Show Hazards are Present or are Likely to Develop 

Where the existence of dangerous air contamination or oxygen deficiency is demonstrated by 
tests performed in accordance with the pre-entry procedures or if the development of
dangerous  air contamination or an oxygen deficiency is imminent, the following requirements
shall also  apply:  

1. Existing ventilation shall be augmented by appropriate means.  

2. When additional ventilation has removed dangerous air contamination or oxygen  deficiency
as demonstrated by additional testing conducted (and recorded), entry into  and work within
the space may proceed.  

3. No source of ignition shall be introduced until the implementation of appropriate  provisions

of this section have ensured that dangerous air contamination due to  flammable or
explosive substances does not exist.  

4. Whenever oxygen-consuming equipment such as welding torches, furnaces, and the like 
are to be used, measures shall be taken to ensure adequate combustion air and exhaust 
gas venting.  

5. To the extent feasible, provision shall be made to permit ready entry and exit.  

6. Where it is not feasible to provide for ready exit from spaces equipped with automatic  fire
suppression systems employing harmful design concentrations of toxic or oxygen
displacing gases, or total foam flooding, such systems shall be deactivated. Where it is  not
practical or safe to deactivate such systems, the use of respiratory protective  equipment,
such as a Self-Contained Breathing Apparatus (SCBA), shall apply during  entry into and
work within such spaces.  

Confined Spaces Where Dangerous Air Contamination Cannot be Removed by Ventilation 

It is the policy of Cirks Construction Inc. to only work in a confined space if it can be made
safe  by the means listed above. We will not work in confined spaces where there is an
ongoing  hazard of air contamination or oxygen deficiency. These operations require extra
measures and  precautions beyond our immediate ability to perform.
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Company Policy for Permit-Required Confined Spaces  

The superintendent and the safety director will identify permit-required confined spaces in our 
company’s workplaces. Employees will be required to obtain a permit to enter or work in those 
spaces. Prior to entry, the superintendent and the safety director will assess the conditions
and  hazards, and decide if workers will enter a permit space. The superintendent and the
safety  director will be responsible for testing and monitoring atmospheric conditions as
required.  Procedures will be initiated to eliminate or control the hazards in the space including,
but not  limited to, the following: 

• Specifying acceptable entry conditions. 

• Providing each authorized entrant or that employee’s authorized representative 
with the opportunity to observe any monitoring or testing of permit spaces. 
• Isolating the permit space. 
• Purging, flushing, or ventilating the permit space as necessary to eliminate or  control
atmospheric hazards. 
• Providing pedestrian, vehicle, or other barriers as necessary to eliminate or  control
atmospheric hazards. 
• Re-evaluating or verifying that conditions in the permit space are acceptable for  entry
throughout the duration of an authorized entry. Employees and their 
representatives are entitled to request additional monitoring at any time. 
• Canceling entry permits once the work is completed, or conditions change, so  that
occupation of the confined space is no longer safe. 

Cirks Construction Inc. will provide and maintain the following equipment at no cost to 
employees, and ensure that employees use the equipment properly: 

• Testing and monitoring equipment required for atmospheric conditions

• Ventilating equipment 
• Communications equipment 
• Personal protective equipment where engineering controls do not eliminate  hazards,
or threat of hazards 
• Lighting equipment 
• Barriers and shields as required 
• Equipment, such as ladders, needed for safe ingress and egress by authorized 
entrants 
• Rescue and emergency equipment, except to the extent that the equipment is 
provided by rescue services 
• Any other equipment necessary for safe entry into and rescue from permit  spaces
 June 2015 Page 57 
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An attendant will be designated for each area for the purpose of testing and monitoring 
conditions and personnel anytime employees are assigned to confined spaces. Personnel 
involved in a confined space activities will be designated as attendant, entry supervisor, or 
authorized entrant, and assigned specific duties relating to confined entry procedures as 
follows: 
Authorized attendants are those who monitor entrants’ activities from outside the space. 
Attendants have the following duties and responsibilities: 

• Knowing the permit-space hazards, including the symptoms and consequences  of

exposure. 
• Knowing how many entrants are in permit space. 
• Staying out of the space during entry operations. 
• Keeping in contact with entrants. 
• Ordering an evacuation for hazardous condition. 
• Keeping unauthorized persons away from the space. 
• Activating rescue procedures. 

Authorized entrants are those permitted by an employer to enter a permit space. Entrants
have  the following duties and responsibilities: 

• Knowing the permit-space hazards, including the symptoms and consequences  of

exposure. 
• Using equipment properly. 
• Communicating regularly with the attendant. 
• Notifying the attendant immediately of hazardous conditions. 
• Leaving the space immediately during a hazardous condition or when the  attendant
orders an evacuation. 
The entry supervisor makes sure attendants and entrants follow entry-permit procedures. The 
entry supervisor is responsible for the following: 

• Knowing the permit-space hazards, including the symptoms and consequences  of

exposure. 
• Verifying that the entry permit is accurate and current. 
• Stopping entry operations and canceling the entry permit when permit-space  work is
done or during a hazardous condition. 
• Ensuring that responders will be available in an emergency. 
• Removing any unauthorized person who enters the space. 
 • Ensuring that entry operations are consistent if another authorized person must 
replace an attendant or an entrant.  
Prior to beginning any work at a new job-site, the superintendent and the safety director will 
verify the closest emergency medical and rescue service’s ability to respond to a confined 
June 2015 Page 58 
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space emergency. The number for the verified emergency service will be prominently posted 
on the permit at the permit entry portal. In the event of an emergency requiring emergency 
service response, the assigned attendant will notify the entry supervisor who is responsible for 
contacting emergency services. 

This service will be determined by the superintendent and the safety director to be qualified to 
provide emergency requiring emergency rescue and medical services in the event of a
confined  space emergency. The attendant will remain on station to assist in evacuating the
space and  prevent the entry of unauthorized rescue personnel.  

Cirks Construction Inc. will evaluate a prospective rescue and emergency service’s ability to 
respond to a rescue summons in a timely manner, considering the hazard(s) identified. What 
will be considered timely will vary according to specific hazard(s) identified and will vary 
accordingly to the specific hazards involved in each entry. For example, §1910.134, 
Respiratory Protection, requires that standby person(s) be provided that are capable of 
immediate action to rescue employee(s) wearing respiratory protection while in work areas 
defined as IDLH at atmospheres. 

The superintendent and the safety director will evaluate a prospective rescue service’s ability,
in  terms of proficiency with rescue-related tasks and equipment, to function appropriately
while  rescuing entrants from the particulate permit space or types of permit spaces identified.
The superintendent and the safety director will select a rescue team or service from those 
evaluated that: 

• Has the capability to reach the victim(s) with in a time frame that is appropriate  for the
permit space hazard(s) identified. 
• Is equipped for and trained in performing the needed rescue services. 
The superintendent and the safety director will inform each rescue team or service of the 
hazards they may confront when called on to perform rescue at the site. The superintendent 
and the safety director will provide the rescue team or service selected with access to all
permit  spaces from which rescue may be necessary so that the rescue service can develop 
appropriate rescue plans and proactive rescue operations. 

Cirks Construction Inc. employees who have been designated to provide permit space rescue 
and emergency services will be instructed in and adhere to the following measures: 

• The superintendent and the safety director will provide affected employees with  the
personal protective equipment (PPE) needed to conduct permit space  rescues
safely and train affected employees so they are proficient in the use of  that PPE, at
no cost to those employees. 
 • The superintendent and the safety director will train affected employees to  perform
assigned rescue duties and ensure that such employees successfully  complete the
training required to establish proficiency as an authorized entrant. 
• The superintendent and the safety director will train affected employees in basic  first-
aid and cardiopulmonary resuscitation (CPR) and will ensure that at least  one
member of the rescue team or service holding a current certification in first  aid and
CPR is available.

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To facilitate non-entry rescue, retrieval systems or methods will be used 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 will 
meet the following requirements: 

• Each authorized entrant will use a chest or full body harness, with a retrieval line 
attached at the center of the entrant’s back, above the entrant’s head, or at  another
point which presents a profile small enough for the successful removal of  the
entrant. 
• The other end of the retrieval line will 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. A mechanical device  will be
available to retrieve personnel form vertical type permit spaces more than  5 feet
deep.  
If an injured entrant is exposed to a substance to a substance for which a Material Safety Data 
Sheet (MSDS) or other similar written information is required to be kept at the work site, that 
MSDS or written information will be made available to the medical facility treating the exposed 
entrant.  

In the event that an IDLH (Immediately Dangerous to Life and Health) entry is deemed 
necessary, The superintendent and the safety director will first contact the designated 
emergency response service, and ensure that emergency service is available on site before 
allowing entry into the confined space.  

The assigned entry supervisor will be responsible for providing first aid where necessary after
contacting emergency services. No employee will enter a permit-required confined space 
without first completing an entry permit and having the entry supervisor sign the permit. The 
steps of the entry-permit procedure include the following: 

• Obtain an entry permit prior to entering the space. 

• Accomplish all pre-permit activities required for entering the space, including 
atmospheric testing, controlling hazards, having required equipment on hand,  and
providing for emergency services.  
• Complete all items on the entry permit. 
 • Have the entry supervisor authorize and sign the permit. If any item on the  permit is
checked “NO” (meaning not yet completed or available), the permit will  not be
signed.  
• Attach a copy of the entry permit outside the entry portal of the confined space. Keep
it there until the entry operations are completed and the supervisor cancels  the
permit. 
• Proceed with entry operations. 
Atmospheric monitoring will be performed regularly during confined space operations to
ensure  that conditions do not exist, or change, to threaten employee safety. Ventilation of
confined  spaces is required before entry, during monitoring and throughout the operation.
Monitoring or  re-evaluation of conditions may be requested at any time during the operation by
any employee, 

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or employee representative, who suspects that changes have occurred which might present a 
hazard to personnel. 

All proposed entrants, attendants, and entry supervisors will participate in the review of the 
initial atmospheric monitoring, and the completion and review of the entry permit. Procedures 
for coordination entry operations for multiple employers working simultaneously as authorized 
entrants in a permit space, so that employees of one employer do not endanger the
employees  of any other employer include the following:  

• When Cirks Construction Inc. makes arrangements to have another contractor 

perform work that involves permit space entry, Cirks Construction Inc. will: 
• Inform the contractor that the workplace contains permit spaces and that permit 
space entry is allowed only through compliance with Cirks Construction Inc. permit
space program. 
• Apprise the contractor of the elements, including the hazards identified and Cirks 
Construction Inc. experience with the space, which make the space in question a 
permit space. 
• Apprise the contractor of any precautions or procedures that Cirks Construction  Inc.
has implemented for the protection of employees in or near permit spaces  where
contractor personnel will be working. 
• Coordinate entry operations with the contractor, when our Cirks Construction Inc.
personnel and the contractor’s personnel will be working in or near permit  spaces. 
• Debrief the contractor at the conclusion of the entry operations regarding any 
hazards confronted or created in permit spaces during entry operations.  
In addition to complying with the permit space requirements that apply to Cirks Construction 
Inc., each contractor who is retained to perform permit space entry operations will: 
 • Obtain any available information regarding permit space hazards and entry 
operations from Cirks Construction Inc. entry supervisor. 
• Coordinate entry operations with the entry supervisor, when both Cirks  Construction
Inc. personnel and the contractor’s personnel will be working in or  near permit
spaces. Inform Cirks Construction Inc. entry supervisor of any  hazards confronted
or created in permit spaces. 
• Inform Cirks Construction Inc. entry supervisor of any hazards confronted or  created
in permit spaces, either during the entry operation or through a  debriefing. 
If more than one confined space is to be monitored by a single attendant, the means and 
procedures that will be used in order to enable the attendant to respond to emergencies in one 
or more permit spaces that he/she is monitoring work include: 

• Continuously maintains an accurate count of authorization entrants in the permit 

spaces and ensures that the means used to identify authorized entrants  accurately
identifies who is in the permit space.

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• Remains outside the permit spaces during entry operations until relieved by  another
attendant. 
• Communicates with authorized entrants as necessary to monitor entrant status  and to
alert entrants of the need to evacuate the space. 
• Monitors activities inside and outside the space to determine if it is safe for  entrants to
remain in the space. Orders the authorized entrants to evacuate the  permit spaces
immediately under any of the following conditions if the attendant: 

o Detects a prohibited condition. 

o Detects the behavioral effects of hazard exposure in an authorized entrant. 
o Detects a situation outside the spaces that could endanger the authorized 
entrants. 
o Cannot effectively and safely perform all the duties required. 
o Summon rescue and other emergency services as soon as the attendant
determines that authorized entrants may need assistance to escape from 
permit space hazards. 
o Performs no duties that might interfere with the attendant’s primary duty to 
monitor and protect the authorized entrants. 
Multiple confined space entry operations will be under the direct control of the entry
supervisor,  who will be available on site. The entry supervisor: 

• Verifies that rescue services are available and that the means for summoning  them
are operable. 
 • Verifies, by checking that the appropriate entries have been made on the permit,  that
tall tests specified by the permit have been conducted, and that all  procedures and
equipment specified by the permit are in place before endorsing  the permit and
allowing entry to begin. 
• Knows the hazards that may be faced during entry, including information on the 
mode, signs or symptoms, and consequences of the exposure. 
• Determines, whenever responsibility for a permit space entry operation is  transferred,
and at intervals dictated by the hazards and operations performed  within the space,
that entry operations remain consistent with terms of the permit  and that acceptable
entry conditions are maintained.  
• Removes unauthorized individuals who enter or who attempt to enter the permit 
space during entry operations. 
• Terminates the entry and cancels the permit as required. 
The superintendent and the safety director will have the authority to cancel an entry permit
upon  completion of the assigned task, upon finding unsuitable conditions or preparation, or if 
unsuitable conditions develop. The entry supervisor will ensure that all personnel have exited 
the space, that equipment, tools, and materials have been removed, and that no condition
which  might create a hazard has been left unresolved. The entry supervisor will then mark the
permit 

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cancelled, sign the space provided for cancellation, and present the cancelled permit to the 
superintendent and the safety director for filing in records. 

The Permit Required Confined Space Program will be reviewed in the event of an 
incident/injury, near miss, if employee complains, or at least annually using the cancelled entry 
permits as reference. Revisions will be made to the program as necessary to ensure the safety
of our employees. 
 June 2015 Page 63 
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Respiratory Protection 
Occasionally our work may necessitate the use of respirators to protect against air 
contaminants. Due to the limitations of respirators and their uncomfortable nature, Cirks 
Construction Inc. will make every effort to provide other means of protection, such as local 
exhaust ventilation, or substitution of less hazardous material, prior to requiring employees to 
wear them. 

When it is clearly impractical to remove harmful dusts, fumes, mists, vapors, or gases at their 
source, or where emergency protection against occasional or relatively brief exposure is 
needed, Cirks Construction Inc. will provide, and the employee exposed to such hazard shall 
use, approved respiratory equipment.  

Whenever respirators are required to be used to control harmful exposures, only respiratory 
equipment approved for that purpose shall be used and such equipment shall be approved by 
the National Institute for Occupational Safety and Health (NIOSH). Only parts approved for the 
specific respirator system shall be used for replacement.  

General Respiratory Protection Guidelines 

1. Atmospheric contamination will be prevented wherever feasible through engineering 

controls such as enclosure or confinement of the operation, general and local exhaust 
ventilation, or substitution of less toxic materials. When effective engineering controls  are
not feasible, or while they are being instituted, appropriate respirators shall be used. 

2. Cirks Construction Inc. shall identify and evaluate the respiratory hazard(s) in the 
workplace; this evaluation shall include a reasonable estimate of employee exposures to 
respiratory hazard(s) and an identification of the contaminant's chemical state and  physical
form. Where we cannot identify or reasonably estimate the employee  exposure, the
atmosphere shall be considered to be Immediately Dangerous to Life or  Health (IDLH). 

3. Respirators shall be provided when such equipment is necessary to protect the health of  the
employee.  

4. Only NIOSH-certified respirators shall be used. The respirator shall be used in  compliance
with the conditions of its certification. 

5. Cirks Construction Inc. will provide respirators that are applicable and suitable for the 
purpose intended. The Company shall select and provide an appropriate respirator  based
on the respiratory hazard(s) to which the worker is exposed and workplace and  user
factors that affect respirator performance and reliability. 

6. Respirators shall be selected from a sufficient number of respirator models and sizes so 
that the respirator is acceptable to, and correctly fits, the user. 
7. The safety director shall act as the Program Administrator who is qualified by  appropriate
training or experience that is commensurate with the complexity of the  program to
administer or oversee the respiratory protection program and conduct the  required
evaluations of program effectiveness.
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8. Cirks Construction Inc. will provide respirators, training, and medical evaluations at no  cost
to the employee. 

9. Cirks Construction Inc. will provide a medical evaluation to determine the employee's  ability
to use a respirator, before the employee is fit tested or required to use the  respirator in the
workplace. We may discontinue an employee's medical evaluations  when the employee is
no longer required to use a respirator. 

10. Cirks Construction Inc. will ensure that employees using tight-fitting face-piece  respirators
pass an appropriate Qualitative Fit Test (QLFT) or Quantitative Fit Test  (QNFT). 

11. Cirks Construction Inc. will establish and implement procedures for the proper use of 
respirators. These requirements include prohibiting conditions that may result in face piece
seal leakage, preventing employees from removing respirators in hazardous 
environments, taking actions to ensure continued effective respirator operation  throughout
the work shift, and establishing procedures for the use of respirators in IDLH 
atmospheres. 

12. We shall provide each respirator user with a respirator that is clean, sanitary, and in  good
working order. The supervisor or manager shall ensure that respirators are  cleaned and
disinfected. 

13. All filters, cartridges, and canisters used in the workplace must be legibly labeled and 
color-coded with the National Institute for Occupational Safety and Health (NIOSH)
approval label that must not be removed. 

14. Training and information will be provided to employees who are required to use 
respirators. The training will be comprehensive, understandable, and recur annually or 
more often if necessary.  

15. The safety director shall conduct evaluations of the workplace to ensure that the written 
respiratory protection program is being properly implemented, and to consult with 
employees to ensure that they are using the respirators properly. 

16. Written information regarding medical evaluations, fit testing, and the respirator program 
shall be retained indefinitely. This information will facilitate employee involvement in the 
respirator program, assist us in auditing the adequacy of the program, and provide a 
record for compliance determinations by OSHA. 

17. Where respirator use is not required by a particular standard or hazard, Cirks  Construction
Inc. may provide respirators at the request of employees or permit  employees to use their
 own respirators if we determine that such respirator use will not  in itself create a hazard. If
voluntary respirator use is permissible, we shall provide the  respirator users with the
information contained in Appendix D of section 5144 8CCR; 
(Information for Employees Using Respirators When Not Required Under the
Standard). If employees choose to wear a dust mask, no medical evaluation or further
training will  be required. If they request to wear a respirator, even though it is not
required, they will  be included in the standard medical screening, fit testing, and
training program. 

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Respirator Selection Requirements 

The proper respirator for the job and hazard shall be selected. This selection will be made in 
accordance with CAL-OSHA or ANSI Z88.2-1980 standards. The correct respirator shall be 
specified for each job. The individual issuing them shall be adequately instructed to insure that 
the correct respirator is used. 

The manufacturers’ recommendations and literature will also be reviewed to determine if the 
respirator provides protection against the expected contaminants. For instance; dust masks do 
not provide protection against gasses or vapors. 

The safety director or another qualified individual shall review and approve all breathing air 
compressors and installations for compliance with appropriate OSHA regulations and safety
procedures prior to use. 

Respirators for Immediately Dangerous to Life or Health (IDLH) Atmospheres 

Cirks Construction Inc. shall provide the following respirators for employee use in IDLH 
atmospheres: 

• A full face-piece pressure demand SCBA certified by NIOSH for a minimum  service
life of thirty minutes, or 
• A combination full face-piece pressure demand Supplied Air Respirator (SAR)  with
auxiliary self-contained air supply. 
• Respirators provided only for escape from IDLH atmospheres shall be NIOSH
certified for escape from the atmosphere in which they will be used. 
• All oxygen-deficient atmospheres shall be considered IDLH. 

Respirators for Atmospheres that are not IDLH 

Cirks Construction Inc. shall provide a respirator that is adequate to protect the health of the 
employee and ensure compliance with all other OSHA statutory and regulatory requirements
under routine and reasonably foreseeable emergency situations. The respirator selected shall 
be appropriate for the chemical state and physical form of the contaminant. 
 For protection against gases and vapors; 

• An atmosphere-supplying respirator, or 

• An air-purifying respirator, provided that the respirator is equipped with an End of-
Service-Life Indicator (ESLI) certified by NIOSH for the contaminant; or if there  is
no ESLI appropriate for conditions in the workplace, we will implement a  change
schedule for canisters and cartridges that is based on objective  information or data
that will ensure that canisters and cartridges are changed  before the end of their
service life.  

For protection against particulates;

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• An atmosphere-supplying respirator; or 

• An air-purifying respirator equipped with a filter certified by NIOSH under 30 CFR  part
11 as a high efficiency particulate air (HEPA) filter, or an air-purifying  respirator
equipped with a filter certified for particulates by NIOSH under 42 CFR  part 84; or 
• For contaminants consisting primarily of particles with Mass Median  Aerodynamic
Diameters (MMAD) of at least 2 micrometers, an air-purifying  respirator equipped
with any filter certified for particulates by NIOSH. 

Medical Evaluation Procedures 

1. Employees shall not be assigned to tasks requiring the use of respirators unless it has  been
determined that they are physically able to perform the work while using the  required
respiratory equipment.  

2. Cirks Construction Inc. shall identify a Physician or Other Licensed Health Care 
Professional (PLHCP) to perform medical evaluations.  

3. The medical evaluation shall include any medical tests, consultations, or diagnostic 
procedures that the PLHCP deems necessary to make a final determination. 

4. Medical questionnaires and examinations shall be administered confidentially during the 

employee's normal working hours or at a time and place convenient to the employee.  

5. The employee shall have an opportunity to discuss the examination results with the 
PLHCP. 

6. The following information must be provided to the PLHCP before the PLHCP makes a 
recommendation concerning an employee's ability to use a respirator: 

• The type and weight of the respirator to be used by the employee; 

• The duration and frequency of respirator use (including use for rescue and  escape); 
 • The expected physical work effort; 
• Additional protective clothing and equipment to be worn; and 
• Temperature and humidity extremes that may be encountered. 

7. Cirks Construction Inc. shall provide the PLHCP with a copy of this written respiratory 
protection program and a copy of the OSHA regulations if they do not already have  them. 

8. In determining the employee's ability to use a respirator, Cirks Construction Inc. shall  obtain
a written recommendation regarding the employee's ability to use the respirator  from the
PLHCP. The recommendation shall provide only the following information:

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• Any limitations on respirator use related to the medical condition of the  employee, or
relating to the workplace conditions in which the respirator will be  used, including
whether or not the employee is medically able to use the  respirator; 
• The need, if any, for follow-up medical evaluations; and 
• A statement that the PLHCP has provided the employee with a copy of the  PLHCP's
written recommendation. 

9. If the respirator is a negative pressure respirator and the PLHCP finds a medical  condition
that may place the employee's health at increased risk if the respirator is used,  Cirks
Construction Inc. shall provide a Powered Air Purifying Respirator (PAPR) if the  PLHCP's
medical evaluation finds that the employee can use such a respirator; if a  subsequent
medical evaluation finds that the employee is medically able to use a  negative pressure
respirator, then we are no longer required to provide a PAPR. 

10. Cirks Construction Inc. shall provide additional medical evaluations that comply with the 
requirements of this section if: 

• An employee reports medical signs or symptoms that are related to ability to use  a
respirator; 
• A PLHCP, supervisor, or the respirator program administrator informs the  employer
that an employee needs to be reevaluated; 
• Information from the respiratory protection program, including observations made 
during fit testing and program evaluation, indicates a need for employee 
reevaluation; or 
• A change occurs in workplace conditions (e.g., physical work effort, protective 
clothing, and temperature) that may result in a substantial increase in the 
physiological burden placed on an employee. 

Fit Testing 
1. Cirks Construction Inc. shall ensure that an employee using a tight-fitting face-piece 
respirator is fit tested prior to initial use of the respirator, whenever a different respirator 
face-piece (size, style, model or make) is used, and at least annually thereafter. 

2. We shall conduct an additional fit test whenever the employee reports, or the employer, 
PLHCP, supervisor, or program administrator makes visual observations of, changes in  the
employee's physical condition that could affect respirator fit. Such conditions  include, but
are not limited to, facial scarring, dental changes, cosmetic surgery, or an  obvious change
in body weight. 

3. If after passing a QLFT or QNFT, the employee subsequently notifies the program 
administrator, supervisor, or PLHCP that the fit of the respirator is unacceptable, the 
employee shall be given a reasonable opportunity to select a different respirator face piece
and to be retested. 

4. The fit test shall be administered using an OSHA-accepted QLFT or QNFT protocol. 
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Usage Rules 

1. Cirks Construction Inc. shall not permit respirators with tight-fitting face-pieces to be  worn
by employees who have: 

• Facial hair that comes between the sealing surface of the face-piece and the face  or
that interferes with valve function; or 
• Any condition that interferes with the face-to-face-piece seal or valve function. 

2. If an employee wears corrective glasses or goggles or other personal protective  equipment,

we shall ensure that such equipment is worn in a manner that does not  interfere with the
seal of the face-piece to the face of the user. 

3. For all tight-fitting respirators, we shall ensure that employees perform a user seal check 
each time they put on the respirator.  

4. Appropriate surveillance shall be maintained of work area conditions and degree of 
employee exposure or stress. When there is a change in work area conditions or  degree of
employee exposure or stress that may affect respirator effectiveness, we shall  reevaluate
the continued effectiveness of the respirator. 

5. Respiratory equipment shall not be passed on from one person to another until it has  been
cleaned and sanitized. Respirators individually assigned should be marked to  indicate to
whom it was assigned. This mark shall not affect the respirator performance in any way.
The date of issuance should be recorded. 
6. When not in use, respirators shall be stored to protect against dust, sunlight, extreme 
temperatures, excessive moisture, or damaging chemicals. Plastic zip lock bags are 
suitable for storage. 

7. Cirks Construction Inc. shall ensure that employees leave the respirator use area: 

• To wash their faces and respirator face-pieces as necessary to prevent eye or  skin
irritation associated with respirator use; or 
• If they detect vapor or gas breakthrough, changes in breathing resistance, or  leakage
of the face-piece; or 
• To replace the respirator or the filter, cartridge, or canister elements. 

8. If the employee detects vapor or gas breakthrough, changes in breathing resistance, or 
leakage of the face-piece, we will replace or repair the respirator before allowing the 
employee to return to the work area. 

Maintenance, Inspection, and Care of Respirators 

1. The employer shall ensure that respirators are cleaned and disinfected using procedures 
recommended by the respirator manufacturer, provided that such procedures are of 

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equivalent effectiveness to OSHA regulations. The respirators shall be cleaned and 

disinfected at the following intervals: 

• Respirators issued for the exclusive use of an employee shall be cleaned and 
disinfected as often as necessary to be maintained in a sanitary condition; 
• Respirators issued to more than one employee shall be cleaned and disinfected 
before being worn by different individuals; 
• Respirators maintained for emergency use shall be cleaned and disinfected after 
each use; and 
• Respirators used in fit testing and training shall be cleaned and disinfected after  each
use. 

2. All respirators shall be stored to protect them from damage, contamination, dust,  sunlight,
extreme temperatures, excessive moisture, and damaging chemicals, and they  shall be
packed or stored to prevent deformation of the face-piece and exhalation valve. 

3. Emergency respirators shall be: 

• Kept accessible to the work area; 

• Stored in compartments or in covers that are clearly marked as containing 
emergency respirators; and 
 • Stored in accordance with any applicable manufacturer instructions. 

4. All respirators used in routine situations shall be inspected before each use and during 
cleaning. 

5. All respirators maintained for use in emergency situations shall be inspected at least 
monthly and in accordance with the manufacturer's recommendations, and shall be 
checked for proper function before and after each use. 

6. Emergency escape-only respirators shall be inspected before being carried into the 
workplace for use. 

7. Cirks Construction Inc. shall ensure that respirator inspections include the following: 

• A check of respirator function, tightness of connections, and the condition of the 

various parts including, but not limited to, the face-piece, head straps, valves, 
connecting tube, and cartridges, canisters or filters. 
• A check of elastomeric parts for pliability and signs of deterioration. 

8. In addition to the requirements above, self-contained breathing apparatus shall be  inspected
monthly.  

9. 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 

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level. The employer shall determine that the regulator and warning devices function 
properly. 

10. For respirators maintained for emergency use, Cirks Construction Inc. shall: 

• Certify the respirator by documenting the date the inspection was performed, the 
name (or signature) of the person who made the inspection, the findings,  required
remedial action, and a serial number or other means of identifying the  inspected
respirator. 
• Provide this information on a tag or label that is attached to the storage  compartment
for the respirator, is kept with the respirator, or is included in  inspection reports
stored as paper or electronic files. This information shall be  maintained until
replaced following a subsequent certification. 

11. For repairs, Cirks Construction Inc. shall ensure that respirators that fail an inspection or 
are otherwise found to be defective are removed from service, and are discarded or 
repaired or adjusted in accordance with the following procedures: 
 • Repairs or adjustments to respirators are to be made only by persons  appropriately
trained to perform such operations and shall use only the respirator  manufacturer's
NIOSH-approved parts designed for the respirator. 
• Repairs shall be made according to the manufacturer's recommendations and 
specifications for the type and extent of repairs to be performed. 
• Reducing and admission valves, regulators, and alarms shall be adjusted or 
repaired only by the manufacturer or a technician trained by the manufacturer. 

Training 

1. Cirks Construction Inc. shall ensure that each employee required to use a respirator can 
demonstrate knowledge of at least the following: 

• Why the respirator is necessary and how improper fit, usage, or maintenance can 
compromise the protective effect of the respirator. 
• What the limitations and capabilities of the respirator are. 
• How to use the respirator effectively in emergency situations, including situations  in
which the respirator malfunctions. 
• How to inspect, put on and remove, use, and check the seals of the respirator.
• What the procedures are for maintenance and storage of the respirator. 
• How to recognize medical signs and symptoms that may limit or prevent the  effective
use of respirators. 

2. The training shall be conducted in a manner that is understandable to the employee.

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3. The training shall be provided prior to requiring the employee to use a respirator in the 
workplace. 

4. Retraining shall be administered annually, and when the following situations occur: 

• Changes in the workplace or the type of respirator render previous training  obsolete. 
• Inadequacies in the employee's knowledge or use of the respirator indicate that  the
employee has not retained the requisite understanding or skill. 
• Any other situation arises in which retraining appears necessary to ensure safe 
respirator use. 

5. The basic advisory information on respirators, as presented in Appendix D of Section  5144

of the California Code of Regulations (8CCR~5144), shall be provided to  employees who
wear respirators when such use is not required by this section or by the  employer. 
Program Evaluation 

1. The safety director shall conduct evaluations of the workplace as necessary to ensure  that
the provisions of the current written program are being effectively implemented and  that it
continues to be effective. 

2. The safety director and site superintendent shall regularly consult employees required to 
use respirators to assess the employees' views on program effectiveness and to identify 
any problems. Any problems that are identified during this assessment shall be  corrected.
Factors to be assessed include, but are not limited to: 

• Respirator fit (including the ability to use the respirator without interfering with 
effective workplace performance). 
• Appropriate respirator selection for the hazards to which the employee is  exposed. 
• Proper respirator use under the workplace conditions the employee encounters.
• Proper respirator maintenance. 

Recordkeeping 

1. Records of medical evaluations must be retained and made available in accordance with 
section 3204 (8CCR~3204). 

2. Cirks Construction Inc. shall establish a record of the qualitative and quantitative fit tests 
administered to an employee including: 

• The name or identification of the employee tested. 

• Type of fit test performed.

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• Specific make, model, style, and size of respirator tested. 

• Date of test. 
• The pass/fail results for QLFTs or the fit factor and strip chart recording or other 
recording of the test results for QNFTs. 
• Fit test records shall be retained for respirator users until the next fit test is 
administered. 

3. Program records will be retained in the Cirks Construction Inc. Human Resources 
department and shall be made available upon request to affected employees and to the 
Chief of the Division of Occupational Safety and Health or designee for examination and 
copying. 

Procedures for Cleaning Respirators 

1. Remove filters, cartridges, or canisters. Disassemble face-pieces by removing speaking 
diaphragms, demand and pressure-demand valve assemblies, hoses, or any  components
recommended by the manufacturer. Discard and replace any defective  parts. 

2. Wash components in warm [43 deg. C (110 deg. F) 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. 

3. Rinse components thoroughly in clean, warm [43 deg. C (110 deg. F) maximum],  preferably
running water and drain. 

4. When the cleaner used does not contain a disinfecting agent, respirator components  should
be immersed for two minutes in one of the following: 

• Hypochlorite solution (50 ppm of chlorine) made by adding approximately one 

milliliter of laundry bleach to one liter of water at 43 deg. C (110 deg. F). 
• Aqueous solution of iodine (50 ppm iodine) made by adding approximately 0.8 
milliliters of tincture of iodine (6-8 grams ammonium or potassium iodide/100 cc  of
45% alcohol) to one liter of water at 43 deg. C (110 deg. F). 
• Other commercially available cleansers of equivalent disinfectant quality when  used
as directed, if their use is recommended, or approved by the respirator 
manufacturer. 

5. Rinse components thoroughly in clean, warm [43 deg. C (110 deg. F) maximum],  preferably
running water and 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. 

6. Components should be hand-dried with a clean lint-free cloth or air-dried. 7.

Reassemble face-piece, replacing filters, cartridges, and canisters where necessary.

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8. Test the respirator to ensure that all components work properly. 

Information for Employees Using Respirators When

Not  Required  
Respirators are an effective method of protection against designated hazards when properly 
selected and worn. Respirator use is encouraged, even when exposures are below the 
exposure limit, to provide an additional level of comfort and protection for workers. However, if 
a respirator is used improperly or not kept clean, the respirator itself can become a hazard to 
the worker. Sometimes, workers may wear respirators to avoid exposures to hazards, even if 
the amount of hazardous substance does not exceed the limits set by OSHA standards. If your 
employer provides respirators for your voluntary use, or if you provide your own respirator, you 
need to take certain precautions to be sure that the respirator itself does not present a hazard. 
You should do the following: 

1. Read and heed all instructions provided by the manufacturer on use, maintenance, 
cleaning, care, and warnings regarding the respirators limitations. 

2. Choose respirators certified for use to protect against the contaminant of concern.  NIOSH,
the National Institute for Occupational Safety and Health of the U.S. Department  of Health
and Human Services, certifies respirators. A label or statement of certification  should
appear on the respirator or respirator packaging. It will tell you what the  respirator is
designed for and how much it will protect you. 

3. Do not wear your respirator into atmospheres containing contaminants for which your 
respirator is not designed to protect against. For example, a respirator designed to filter 
dust particles will not protect you against gases, vapors, or very small solid particles of 
fumes or smoke. 

4. Keep track of your respirator so that you do not mistakenly use someone else's  respirator.

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Ergonomics 
Studies have shown over the years that poorly designed and arranged work areas, awkward 
work postures, and repetitive motions can lead to a variety of injuries including carpal tunnel 
syndrome and tendonitis, which are often referred to as Repetitive Motion Injuries (RMIs). As 
with cancer, heart disease, and many other ailments, there are risk factors that increase an 
individual’s likelihood of developing RMIs. If the risk factors are reduced, so are the chances of 
being injured. While some of these risk factors, such as family history, cannot be controlled in 
the employment setting, many can. Including: 

• The force used to perform a task. 

• Posture while performing tasks. 
• The number of repetitions performed in a given time period. 
• Mechanical stresses such as hard surfaces. 

Cirks Construction Inc. has developed the following program designed to minimize RMIs. The 
program includes worksite evaluations, control of exposures that have caused RMIs, and 
training of employees.  

Worksite Evaluation and Exposure Reduction 

Each job, process, or operation of identical work activity that has resulted in at least two RMIs
or  a representative number of such jobs, processes, or operations shall be evaluated for 
exposures that have caused RMIs. Cirks Construction Inc. may request assistance from 
outside consultants for this purpose.  

Any exposures that have caused RMIs shall, in a timely manner, be corrected or if not capable 
of being corrected have the exposures minimized to the extent feasible. We shall consider 
engineering controls, such as work station redesign, adjustable fixtures or tool redesign, and 
administrative controls, such as job rotation, work pacing, or work breaks.  

Training 

Affected employees shall be provided training that includes an explanation of:  

• Cirks Construction Inc. program. 

• The exposures which have been associated with RMIs. 
• The symptoms and consequences of injuries caused by repetitive motion.
• The importance of reporting symptoms and injuries to their supervisor. •
Methods used to minimize RMIs.  

This training may be conducted as part of the regular safety meetings.

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Forklifts 
Each year about 100 workers are killed and almost 95,000 injured in industrial truck incidents 
across the country. To properly protect our employees from such incidents, Cirks Construction 
Inc. has adopted the following Forklift Safety Program.  
General 

Cirks Construction Inc. will ensure that each powered industrial truck operator is competent to 
operate a powered industrial truck safely, as demonstrated by the successful completion of the 
training and evaluation specified below. 

Prior to permitting an employee to operate a powered industrial truck (except for training 
purposes), Cirks Construction Inc. shall ensure that the employee has successfully completed
a  training program.  

Training Program Implementation 

Trainees may operate a powered industrial truck 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. 

Training shall consist of a combination of formal instruction (e.g., lecture, discussion,

interactive  computer learning, video, and written material), practical training (demonstrations
performed by  the trainer and practical exercises performed by the trainee), and evaluation of
the operator's  performance in the workplace. 

All operator training and evaluation shall be conducted by persons who have the knowledge, 
training, and experience to train powered industrial truck operators and evaluate their 
competence. 

Note: This section does not require that the training be given by any particular individual or 
organization. The trainer must only be able to demonstrate that they have appropriate 
knowledge, training, and experience to train others and evaluate their competence. 

Training Program Content 

Powered industrial truck operators shall receive initial training in the following topics: 

• Operating instructions, warnings, and precautions for the types of truck the  operator
will be authorized to operate. 
• Differences between the truck and the automobile. 
• Truck controls and instrumentation: where they are located, what they do, and  how
they work. 
• Engine or motor operation.

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• Steering and maneuvering. 

• Visibility (including restrictions due to loading). 
 • Fork and attachment adaptation, operation, and use limitations. 
• Vehicle capacity. 
• Vehicle stability. 
• Any vehicle inspection and maintenance that the operator will be required to  perform. 
• Refueling or charging and recharging of batteries. 
• Operating limitations. 
• Any other operating instructions, warnings, or precautions listed in the operator's 
manual for the types of vehicle that the employee is being trained to operate. 
• Workplace-related topics. 
• 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. 
• Narrow aisles and other restricted places where the vehicle will be operated.
• Hazardous locations where the vehicle will be operated. 
• Ramps and other sloped surfaces that could affect the vehicle's stability. 
• Closed environments and other areas where insufficient ventilation or poor  vehicle
maintenance could cause a buildup of carbon monoxide or diesel  exhaust. 
• Other unique or potentially hazardous environmental conditions in the workplace  that
could affect safe operation. 
• The requirements of this section. 

Refresher Training and Evaluation 

Refresher training, including an evaluation of the effectiveness of that training, shall be 
conducted to ensure that the operator has the knowledge and skills needed to operate the 
powered industrial truck safely. 

Refresher training in relevant topics shall be provided to the operator when: 

• The operator has been observed to operate the vehicle in an unsafe manner.
• The operator has been involved in an incident or near-miss incident. 
• The operator has received an evaluation that reveals that the operator is not 
operating the truck safely.

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• The operator is assigned to drive a different type of truck. 

 • A condition in the workplace changes in a manner that could affect safe  operation of
the truck. 

An evaluation of each powered industrial truck operator's performance shall be conducted at 
least once every three years. 

Avoidance of Duplicative Training 

If an operator has previously received training in a topic specified above, and such training is 
appropriate to the truck and working conditions encountered, additional training in that topic is 
not required if the operator has been evaluated and found competent to operate the truck
safely. 

Note: This section reduces the training requirement for previously trained operators provided
we  can demonstrate that the operator knows the material. Since some of the required training
is  unique to the area where the lift will be operated, we must still cover these areas even if
the  employee was previously trained. 

Certification 

Cirks Construction Inc. shall certify that each operator has been trained and evaluated as 
required by this paragraph. 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(s) performing the training 
or evaluation.
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