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1 Safety Manual Rev. 3/2018
Transcript of Safety Manual - foothillsenergyservices.com › ... › 2020 › 04 › FESI-Safety-Manu… ·...
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Safety Manual
Rev. 3/2018
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Table of Contents
3. Code of Safe Practices
4. Definitions
9. Section 1, General Rules
11. Section 2, Hazard Communication
13. Section 3, Lock Out Tag Out
16. Section 4, Injury and Illness Prevention Program
Appendix C
20. Section 5, Portable Fire Extinguisher Program
25. Section 6, Emergency Action Plan
31. Section 7, Bloodborne Pathogen Program
33. Section 8, Heat Illness Prevention Program
36. Section 9, Excavations
38. Section 10, PPE
41. Section 11, Fall Protection Program
49. Section 12, Rigging Equipment Policy
50. Section 13, Hearing Protection Policy
51. Section 14, Ladder Safety
52. Section 15, Electrical Safety
59. Section 16, Tool Safety
64. Section 17, Material Handling and Storage
64. Section 18, Drug and Alcohol Policy
78. Section 19, Harassment Policy
78. Section 20, Fleet Safety
82. Section 21, Confined Space
82. Section 22, Return To Work Policy
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82. Section 23, Violations and Disciplinary Action Plan
Code of Safe Practices
Foothills Energy Services, Inc. will maintain a safety and health program conforming to the best
practices of organizations of this type. To be successful, such a program must embody the
proper attitudes toward injury and illness prevention on the part of supervisors and employees,
but also between each employee and his or her co-workers. Only through such a cooperative
effort can a safety program in the best interest of all be established and preserved.
• Always wear Personal Protective Equipment (PPE) appropriate for the job. Employees
must wear all required PPE and any other such equipment specified by the company.
Suitable eye, ear, head, foot, and hand protection must be worn when the worker is
exposed to hazards.
• Report all injuries to your supervisor at the time they occur, no matter how minor.
• Only lift what you can safely handle. Ask for help when heavy objects are to be lifted or
moved. And always lift correctly or use the appropriate lifting equipment.
• Refrain from fighting, horseplay, and throwing objects at all times.
• Ask if you are unsure of the safe way to do a task.
• Never block aisles, workspaces, fire extinguishers, exit doors, and control cabinets.
• Employee must use tools and equipment in a proper and safe manner. Never use
defective hand tools.
• No employee will hitch a ride on any moving equipment.
• Smoking is prohibited near flammable liquids or combustible material.
• Drinking alcoholic beverages, intoxication, or the possession of illegal drugs on
company property, or being under the influence of alcohol or any other illegal
substances is not and will not be permitted.
• Do not operate any machine or other equipment unless you are specifically trained and
authorized to do so.
• Machines and work areas must be kept clean always. Good housekeeping is essential
to safe efficient work.
• Remember the position of all safety switches and how to activate them. Safety devices
such as guards, covers, lockout devices, control switches, etc. must be used properly.
• When you move from one work area to another, always take the safest route. Do not
take shortcuts through restricted areas, between moving equipment or under
suspended loads.
• Do not jump off any elevated platforms. Always use the ladders or stairs and three
points of contact.
• Never use compressed air to dust yourself off. Never point compressed air at fellow
workers.
• Never place a tool where it can injure you or anyone else by rolling, slipping, or falling.
When using tools on an elevated platform, keep them in a container or otherwise
secured from falling.
• Notify area supervisor immediately of any hazardous working conditions.
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• Anyone ordering a hazardous product must require the SDS sheets accompany the
product.
• Any employee engaging in conduct inconsistent with his/her medical restrictions or
which operates to further or lengthen the period of work related disabilities will be
subject to discipline.
• Jewelry, rings, bracelets, watch, chains, key chains, ties, and loose or ragged clothing
should not be worn, as these items might catch causing serious accidents such as the
loss of fingers or hands.
• Keep the floor clean and dry of oil and water.
• Scrap and refuse materials should be placed in proper containers. Keep your general
work area free from clutter and obstacles.
Definitions
Accident / Incident
An unplanned, unexpected, or undesirable event that results in damage, personal injury, or
harm to machinery, personnel, or property.
Affected Employee
An employee whose job requires him/her to use a machine or equipment on which servicing, or
maintenance is to be performed under lockout/tagout, or whose job requires him/her to work in
an area in which such servicing or maintenance is to be performed.
Attendant
An employee assigned to remain immediately outside the entrance to an Enclosed Space or
Confined Space to render assistance as needed to employees inside the space.
Authorized Person
An employee who has permission from the Management or the Person-In-Charge to enter a
designated work area and perform specific work tasks.
Authorized Person (LOTO)
An employee who locks out or tags out machines or equipment to perform servicing or
maintenance on that machine or equipment.
Bonding
The electrical interconnection of conductive parts, designed to maintain a common electrical
potential.
Bracket / Master Grounding
A grounding method where temporary Ground Sets are installed on both sides of the work site.
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Cable, Conductor or Line
A material usually in the form of a wire, cable, or bus bar suitable for carrying an electric current.
This cable, conductor or line may contain an outer jacket of insulation or unjacketed bare
metallic wire / cable.
Clearance
The unobstructed (clear) distance between two objects measured surface to surface.
Cluster Bar / Cluster Bar Support
A terminal that is temporarily attached to the structure to support (it may serve to establish an
equipotential zone) and provide a bar that will accommodate at least two grounding clamps and
may have terminals to accommodate grounding cables.
Competent Person
An employee who is capable of identifying existing and predictable hazards in the surroundings
or working conditions which are unsanitary, hazardous, or dangerous to personnel, and who has
the authorization to take prompt corrective measures to eliminate them.
Confined Space
A space that:
• Is large enough and so configured that an employee can bodily enter and perform
assigned work; and
• Has limited or restricted means for entry or exit (e.g., tanks vessels, silos, storage bins,
vaults, and pits); and
• Is not designed for continuous occupancy.
Customer
An organization or entity that purchases services from the company.
De-energized
Disconnected from all sources of electrical energy.
Dielectric
An insulating medium that intervenes between two conductors or metallic surfaces.
Energized (Live)
Supply energy, typically kinetic or electrical energy, to something.
Energy Source
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An electrical, mechanical, hydraulic, pneumatic, chemical, thermal, nuclear, hydro, gravitational
or other energy source that when released could cause injury to an individual.
Entrant
An employee who enters a Confined Space to perform work tasks.
Equipotential / Equipotential Work Zone (EPZ)
• An identical state of electrical potential for two or more items. For the purposes of
Personal Protective Grounding (PPG), a near-identical state of electrical potential.
• A work zone that is placed at a near-identical state of electrical potential by the
installation of Personal Protective Grounding devices.
Excavation
Any man-made cut, cavity, depression, or trench in an earth surface that is formed by earth
removal.
Excavation, Trench
A narrow excavation in which the depth is greater than the width.
Exposed (Electrical)
Any electrical conductor, cable, part or equipment which is accessible to personnel and which is
not shielded from contact.
Extended Reach
The full reach (extended arm and hand) of an employee in any direction which includes the
length of any conductive object(s) in the hand. See also, Minimum Approach Distance.
Fall-Arrest System
Also called Personal Fall-Arrest System (PFAS). A system consisting of a body harness,
lanyard, connectors, and anchorage, with or without an energy-absorbing device, to limit the
forces an employee can experience during a fall.
Fall-Prevention System
A system which may include a positioning device system intended to prevent an employee from
falling from an elevation.
Flame Resistant (FR)
Any material which prevents, terminates, or inhibits combustion following the application of a
flaming or non-flaming source of ignition.
Ground Sets
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A system of ground clamps and jacketed cables suitable for carrying fault current.
Grounded
A conducting connection, whether intentional or accidental, by which an electrical circuit or
equipment is connected to earth, or an equal potential to earth.
Insulating Protective Equipment (IPE)
Devices such as blankets, line hose, hard plastic, covers, insulating covers, hot sticks, mats,
and other devices that are installed to insulate and isolate energized conductors or parts.
Insulated
Separated from other conducting surfaces by a dielectric (including air space offering a high
resistance to the passage of current.
Isolated
Physically separated, electrically and mechanically, from other conducting surfaces or electrical
sources of energy.
Job Briefing
A meeting conducted at the job site by the Person-In-Charge of the work that focuses on the
site-specific hazards and controls associated with the work to be performed.
Live-Line Work
Work activities performed on Energized conductors or equipment with a phase-to-phase voltage
exceeding 600 bolts using the hot-stick technique.
Management
A business unit, person or group of persons assigned responsibility for a department, business
unit or entity.
Minimum Approach Distance (M.A.D.)
The closest distance an employee is permitted to approach an energized or grounded object.
Near Miss
An unplanned event that did not result in injury, illness, or damage-but had the potential to do
so.
Overhead Ground Wire (OHGW)
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Single or multiple Grounded wire(s) placed above phase conductors for the purpose of
intercepting lightning strikes in order to protect the phase conductors from direct strikes.
Personal Protective Equipment (PPE)
Equipment such as safety glasses, hard hats and other items donned to protect personnel from
a known hazard.
Person-In-Charge
An employee designated, identified, or assigned supervisory duties.
Personal Ground
A temporary grounding conductor installed at the same location as the workers. A personal
ground is installed for the primary purpose of individual protection and to establish an
equipotential zone (EPZ).
Primary Zone
An area identified as the M.A.D. around any Energized or potentially Energized object.
Qualified Person
An employee knowledgeable through training and experience in the construction, operation and
associated hazards of the electric power system, equipment, or tools.
Rubber Glove Method
A work practice in which the employees don rubber protective insulating gloves and sleeves
rated for the exposure of the highest phase-to-phase voltage.
Secondary (ies)
The conductors originating at the low-voltage secondary winding of a distribution transformer.
Working Load Limit (WLL)
Also called Safe Working Limit (SWL). The maximum weight or force that may be applied to a
product, designated by the manufacturer, with respect to the center line of the product, or the
designated loading area.
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Section 1: General Rules
Safety and Health Policy
The safety, health and well being of all employees is a major focus of Foothills Energy Services,
Inc. (FESI). We are committed to providing our employees with a safe and rewarding work
environment. FESI is accepting this responsibility and requires the unqualified cooperation from
every employee.
Objective and Purpose
This Safety Manual is intended to safeguard the lives of the employees, customers, business
partners and the public with whom contact is made through our daily operations.
An attempt has been made to identify rules covering individual precautions that shall be taken to
ensure workplace safety. Employees shall not only abide by the following rules and regulations
but should take any additional precautions which may be necessary to protect themselves,
fellow employees, and the public.
Responsibilities
• Management Commitment and Employee Involvement
• Work Site Analysis
• Hazard Prevention and Control
• Safety and Health Training
Information Transfer
As it relates to safety, information from the client shall be attained relating to the work to be
performed on their system (i.e. Nominal voltages, Induced voltages, Environmental conditions,
and conflicts.)
Management
Management shall support, implement and be accountable for:
a. Ensuring that its employees and subcontractors are instructed of hazardous
conditions revealed via the information transfer provided by the client.
b. Accident prevention within the business unit / department
c. Assigning only Competent and Qualified Person(s)-In-Charge who understand and
uphold these rules.
d. Ensuring that each employee receives an Employee Safety Manual and that the
Person-In-Charge has a copy of the Safety Manual.
e. Ensuring work is completed in compliance with company rules, & regulatory
requirements.
f. Provide safety training, skills training and Person-In-Charge training with adequate
time allotted for training.
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g. Providing and ensuring the proper use and maintenance of all required protective
equipment, tools, and protective devices.
h. Ensuring Safety Committee meetings are performed and actively participate in these
meetings.
i. Actively participating and supporting Incidents and Near Miss investigations.
j. Identifying and developing controls to address safety concerns prior to introducing a
new process, procedure, equipment, or material.
k. Implementing fair and consistent disciplinary action when safety violations are
identified.
l. Ensuring periodic inspections of job sites are completed, and
m. Performing periodic inspections of job sites.
Person-In-Charge
The Person-In-Charge shall support, implement and be accountable for the following:
a. Ensuring every employee working under his or her direction is working safely.
b. Stopping work activities when personnel place themselves in a potentially hazardous
or life-threatening situation.
c. Ensuring the execution of work in a safe manner and for the job performance of
every employee under his or her direction.
d. Ensuring that a detailed Job Briefing is completed prior to the start of work
operations and if the tasks change significantly.
e. Performing safety meetings.
f. Assigning tasks only to Qualified Persons who can complete the task.
g. Observing job sites daily and correcting unsafe acts or conditions.
h. Instructing every employee on the reporting of Accidents.
i. Ensure that Authorized and Qualified Persons perform inspections of tools and
equipment and prohibit the use of tools or equipment judged to be unsafe.
j. Safeguarding the work site, including employees, the public and the environment
from identifiable hazards.
Safety Manager / Coordinator
The Safety Manager shall support, implement and be accountable for the following:
a. Providing guidance, assistance and interpretation of the rules contained in this
Safety Manual.
b. Communicating with Management to ensure safety rules are effective and
implemented properly.
c. Assisting Management and Person-In-Charge with the safe completion of work
tasks.
d. Providing updates on new regulations.
e. Developing, revising, and reviewing training programs for regulatory compliance.
f. Auditing work site for compliance with safety rules, company, and customer rules.
g. Documenting work-site audits and communicating deficiencies to Management.
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h. Ensuring corrective measures are implemented and verifying their effectiveness.
i. Providing safety and health support to the Management, Person-In-Charge, and
employees.
j. Providing safety and health training to employees.
k. Providing support with Incident investigation including follow up and completion of
corrective action identified during the investigation.
l. Coordinating, monitoring, and providing technical support for safety committees.
Employee
Every Employee:
a. Shall be responsible for conforming to the rules contained in the Safety Manual and
rules implemented by the company.
b. Shall comprehend and implement the rules that apply to the work performed.
c. Shall identify unsafe acts or conditions and report them to the Person-In-Charge, and
FESI will not retaliate for raising concerns or reporting any unsafe conditions.
d. Has the authority to stop the work task. If the work site appears unsafe, each
employee has the responsibility and authority to discuss this concern with the
Person-In-Charge and correct the hazard prior to beginning the work task.
e. Shall preform a visual inspection of safety devices, tools, machinery, and equipment
for defects prior to use.
f. Shall use and operate safety devices, tools, machinery, and equipment in the proper
manner.
g. Shall immediately report any injuries, Near Misses, or damage to the Person-In-
Charge.
h. Shall maintain a professional appearance while on duty. Loose hair, jewelry or
articles of clothing shall be controlled to prevent accidental contact with exposed
Energized conductors or equipment or rotating parts. Clothing shall be work properly
and in a professional manner.
i. Shall attend and participate in Job Briefings and safety meetings.
Qualified / Competent Person
The Qualified or Competent Person shall:
a. Ensure compliance with the rules and procedures required for the process or task.
b. Immediately correct any developing, recognized, or created hazard that may
endanger employees, the public or property.
c. Maintain up to date credentials/certifications and qualifications for the work.
d. Ensure required documentation is properly completed.
Safety Committee
Shall hold monthly meetings and participate in improving the safety of the work
environment. During those meetings discuss, among other things, accident reports, safety audit
results, changes to existing safety policies, etc.
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Section 2: Hazard Communication
To ensure chemical safety in the workplace, information about the identities hazards of the
chemicals must be available and understandable to workers. OSHA's Hazard Communication
Standard (HCS) 29 CFR 1910.1200 requires the development and dissemination of such
information:
▪ Chemical manufacturers and importers are required to evaluate the hazards of the
chemicals they produce or import, and prepare labels and safety data sheets to convey
the hazard information to their downstream customers;
▪ All employers with hazardous chemicals in their workplaces must have labels and safety
data sheets for their exposed workers, and train them to handle the chemicals
appropriately.
1. Foothills Energy Services, Inc. Policy
To ensure that information about the dangers of all hazardous chemicals used by our
company is known by all affected workers, the following hazard communication program
has been implemented. Under this program, workers will be informed of the
requirements of the OSHA Hazard Communication Standard, the operations where
exposure to hazardous chemicals may occur, and how workers can access this
program, as well as labels and SDSs
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This program applies to any chemical which is known to be present in the workplace in
such a manner that workers may b exposed under normal conditions of use or in a
foreseeable emergency. All work areas that involve potential exposure to chemicals are
part of the hazard communication program. Copies of the hazard communication
program are available in the Safety Office for review by any interested worker.
Ben Schreiner is the program coordinator, with overall responsibility for the program,
including reviewing and updating this plan as necessary.
2. Container Labeling
All containers received for use will be clearly labeled in accord with the requirements of
HazCom 2012, including a product identifier, pictogram, hazard statement, signal word,
and precautionary statements, as well as the supplier’s contact information (name and
address).
Each work area will ensure that all secondary containers are labeled with the original
supplier’s label or with an alternative workplace label.
3. Safety Data Sheets (SDSs)
Copies of the SDSs for all hazardous chemicals to which workers are exposed or are
potentially exposed will be kept in the Safety Office. Workers may also find SDSs
information online at https://www.msdsdigital.com/msds-online-search.
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4. Employee Information and Training
Every worker who will be potentially exposed to hazardous chemicals will receive initial
training on the Hazard Communication Standard and this program before starting work.
5. Hazards of Non-Routine Tasks
Periodically workers are required to perform non-routine tasks that are hazardous. Prior
to starting work on such projects, workers will be given information by the safety
department about the hazards that may be encountered.
6. Informing Other Employers/Contractors
It is the responsibility of Foothills Energy Services, Inc., and employees to provide other
employers and contractors with information about hazardous chemicals that their
workers may be exposed to on the work site and suggest precautions for workers. If an
alternative workplace labeling system is used the other employers will be provided with
information to understand the labels to which their workers may have exposure.
7. List of Hazardous Chemicals
A list of all known hazardous chemicals in the workplace is attached to this program.
See Attachment #
8. Program Availability
A copy of this program will be made available, upon request, to workers, their
designated representatives, and OSHA.
Section 3: Control of Hazardous Energy Sources
(Lockout/Tagout)
In response to OSHA Standard CFR 1910.147 FESI has developed the following procedure.
Scope
The purpose of the procedure is to prevent injury to personnel and/or damage to machinery.
This procedure shall be used to assure that machinery is isolated from potentially hazardous
energy sources and is locked out before personnel begin working on the machine or equipment.
This procedure does not cover normal production operations.
Servicing and/or maintenance which takes place during normal production operation is covered
if:
1. An employee is required to remove or bypass a guard or other safety devices; or
2. An employee is required to place any part of his/her body into an area on a
machine or piece of equipment where work is actually performed upon material
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being processed or where work is actually performed upon material being
processed or where an associated danger zone exists during a machine
operating cycle.
Responsibilities
It is the responsibility of the Safety Manager/Coordinator to assure that all affected and
authorized employees or outside contractors performing work (i.e., installation, maintenance,
setup, cleaning, etc.) are instructed in and comply with requirements of this procedure.
Definitions
Affected Employee
An employee whose job required him/her to use a machine or equipment on which servicing, or
maintenance is to be performed under lockout/tagout, or whose job requires him/her to work in
an area in which such servicing or maintenance is to be performed.
Authorized Person
An employee who locks out a machine or equipment to perform servicing or maintenance.
Important Note
An affected employee and an authorized person may be the same person.
Zero Energy State
The release of all stored energy from a power source.
Tagout Device
The process of attaching a tag to a disconnect tagout switch or other energy isolating device to
warn other not to restore energy to the tagged equipment.
Lockout Device
A device that utilizes a positive means to hold an energy-isolating device in a position to prevent
energization of a machine or equipment (Hasp with lock and key).
Training
All affected and authorized employees shall be trained in the lockout/tagout procedure.
Training shall be conducted initially, and retraining provided whenever there is a change in job
assignments, a change in machines, equipment or processes that present a new hazard or
when there is a change in procedure. Retraining shall also be provided when periodic
inspections reveal a need.
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The Supervisor and/or Safety Manager will review Control of Hazardous Energy Sources with
each employee. Training shall include:
1. Recognition of applicable hazardous energy sources.
2. The type of magnitude of energy sources.
3. Methods and means necessary for energy isolation and control.
4. A copy of Control of Hazardous Energy Sources shall be provided to each employee.
Employees must sign the Employee Training Record, a copy of which will be filed in employee’s
personnel file.
Outside Contractors
Outside contractors must be informed of Foothills Energy Services, Inc. lockout/tagout program
and procedures.
Administration and Responsibilities
Employer Responsibilities
The Safety Manager will train, and periodically re-instruct employees regarding the
requirements of lockout/tagout procedures.
Supervisors will enforce compliance with requirements of lockout/tagout.
The Safety Manager will provide employees with personal locks and tags for use in protecting
themselves.
Effective facilities for locking and tagging power sources and process systems must be provided
to protect exposed employees from possible injury.
Employee Responsibilities
Each employee will receive, shall know, understand, and follow established locking and tagging
safety rules and procedures.
Employees will be provided with personal locks and tags for their use in protecting themselves.
Consult with your supervisor or person-in-charge when there is a question regarding the correct
procedure before any work is performed.
General Responsibilities
Only the authorized person will perform lockout, or tagout procedures. The authorized person
will notify all affected employees.
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An authorized person and an affected employee may be the same people when the affected
employee’s duties also include performing maintenance, or service on a machine or equipment,
which must be locked or tagged out.
Attachment 4 Lockout/Tagout Checklist
Attachment 5 Lockout/Tagout Procedure Sheet
Attachment 6 Periodic inspection Certification
Section 4: Injury and Illness Prevention Program
Accident Investigation
Scope
To develop an effective accident investigation program total commitment is needed from all
branches of the company, with a lot of the investigation being done by the first line supervisors.
Purpose
To establish an accident investigation program that will help Foothills Energy Services Inc.
reduce the amount of down time and stop the reoccurrence of unwanted and costly accidents.
Definitions
Accident
An unexpected occurrence that may or may not result in injury, property, equipment, or product
damage, which usually interrupts work.
Near Miss
A Close Call, no one was hurt, or damage done, but the potential for injury and expenses was
there.
Procedure
1. Reporting – It is the employee’s responsibility to immediately report all accidents,
unsafe conditions, near misses and incidents to his/her supervisor no matter what the
severity.
2. Investigating – Determine if it was a non-injury accident or an accident that caused
personal injury. You should investigate both accidents the same way with level of
seriousness establishing the amount of management involvement.
3. Analysis - First determine if it was a preventable accident and then list the items
damaged. Then review the relationship of the accident with the role of the job and
determine if there was an unsafe condition or an unsafe act present.
4. Correcting – In correcting the problem, cooperation is needed from top management all
the way down to the part-time workers. Reviewing past loss runs will aid in trying to pick
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out any trends, or any repeat offenders that might need refresher training. The safety
committee will then discuss the accident with the information presented to them and try
to prevent reoccurrence.
5. Follow-up – Follow-up describes the items that need to be repaired or replaced, date of
initial action, date of completion, and a remark section. A good follow-up is necessary to
prevent further accidents.
Supervisor Role
Accident investigation is the responsibility of all levels of FESI management, but to establish a
good program will require the help of first line supervisors. This is needed because the
supervisors are the closest link management has to the working conditions, and the employees
who do the jobs. A goo supervisor also will know the details needed in performing the job and
also enforce the company rules.
In having the first line supervisors reporting all accidents it shows the employees that accident
prevention will be taken seriously.
Supervisors need to know about accident causes and what methods should be taken when
investigating an accident. They also need to know about close calls. In most cases the
supervisor knows the jobs responsibilities and can pick out unsafe conditions.
Supervisors need to react immediately to prevent reoccurrence of the accident. This might
include retraining, eliminating a machine or adding a safety device all that is dependent on the
type of accident.
OSHA Record Keeping Regulation (29 CFR 1904)
OSHA Injury and Illness Recordkeeping and Reporting
An OSHA 300 Log is a list of all recordable injuries and illnesses at the place of employment.
Employers with more than 10 employees are required to keep a record of serious work-related
injuries and illnesses. Minor injuries requiring first aid only do not need to be recorded.
This information helps employers, workers and OSHA evaluate the safety of a workplace,
understand industry hazards, and implement worker protections to reduce and eliminate
hazards, preventing future workplace injuries and illnesses.
The OSHA 300A must be posted from February 1 – April 30. These records can be found in the
safety department office.
Employee Training
Employee safety training is provided to the employee during normal business hours. The
training will be conducted by qualified training staff in the Apprenticeship department or by the
Safety department personnel, or by other qualified outside representatives. During monthly all
staff safety meetings videos will be used as awareness training. These videos cover a variety of
topics and are available for viewing by any employee at any time. The training will be
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documented regardless of the training method or instructor, using standardized Training Sign in
Sheets.
Record Keeping
Documents related to the Injury and Illness Prevention Plan are to be kept in a safe and
convenient location. Documents that are to be kept include:
• Records relating to site inspections and periodic safety inspections.
• Identified unsafe conditions
• Employee safety training records including names of all attendees, date, instructor, and
training material covered
• Safety meeting Documentation
• Hazard correction reports
• Accident, Injury, and Illness, investigation reports
Identifying Workplace Hazards
Annual, regular, and random safety inspections of the worksite, mechanic shop, and
administrative office buildings shall be conducted when the company adopts the Injury and
Illness Prevention Program. These regular inspections will be supplemented with additional
inspections whenever new processes, procedures, or machinery is introduced to the workplace.
Generally, managers, supervisors and safety department personnel are responsible for the
identification and correction of safety hazards that employee’s face. Managers, and
Supervisors shall check for any safety hazards with each visit and provide immediate verbal
feedback when hazards are observed. Hazard identification can also be reported by using the
Hazard Identification form.
Communicating Workplace Hazards
Supervisors, Managers, and Safety Department personnel are responsible for communicating
with all workers about safety and health issues in a form readily understood by all workers. All
personnel are encouraged to report all unsafe work conditions and recognized hazards. The
safety department and safety committee are resources for the communication of workplace
hazards. A representative from these resources will inform workers of hazard correction and
safety related activities. Each worker has stop work authority and the ability to communicate
recognized hazards without fear of reprisal. These same resources are responsible for
providing access to the required information pertinent to their work assignments.
Correcting Workplace Hazards
Hazards discovered during an inspection must be corrected by the Managers, Supervisors, or
Safety department personnel, or by the cooperation of these departments. Hazards are to be
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corrected as quickly as possible after the discovery of the hazard, based on the severity.
Specific procedures that can be used to correct hazards include but are not limited to:
• Stop work authority
• Tag out of equipment (do not operate)
• Retraining of workers
If necessary Managers, and supervisors can seek assistance to correct known hazards. If a
condition cannot be corrected safely then all workers need to be removed from the area until
qualified personnel can make the necessary corrections.
Investigating Accidents, Injuries and Illnesses
Accident and Injury Reporting
Accidents must be reported to a supervisor immediately. The accident will be investigated to
the appropriate level regardless of the severity. The investigation team will know their roles
and responsibilities prior the beginning of any investigation. The investigation team will use and
maintain the proper equipment to assist with the investigation, collection and securement the
evidence. Witnesses will be interviewed promptly and separately, then the information will be
reviewed with them so all information is clear and detailed.
Workers who are ill or injured on the job must report the illness or injury to their manager or
supervisor immediately. If immediate medical treatment is needed beyond first aid, call 911. If
an injury or illness is nonlife threatening but may require more than first aid the worker may be
taken to an urgent care. The urgent care locations for the work areas are listed in the front of
the Injury and Illness Prevention Program. The Manager or Supervisor that the injury or illness
is reported to, must ensure that the worker gets the appropriate care immediately, then also
insure that the proper departments are notified.
Accident and Injury Investigation
The accident and injury investigation is to be performed by the Safety Department in
cooperation with the supervisor or the manager. The procedure that shall be used to investigate
an accident or injury includes these steps.
• First an injury report is to be filled out and turned in to the Safety Department by the
Supervisor.
• Interview the witnesses promptly and separately
• Reassure the witnesses of the investigations purpose
• Direct the questioning to clarify the witnesses statements
• Summarize the events back to the witness to ensure clarity.
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• Injuries that require hospitalization will be reported to OSHA within 24 hours, and
accidents that result in death will be reported to OSHA within 8 hours.
• Investigate the scene of the incident for causative factors
• Review established procedures to ensure they were adequately followed
• Review training records to ensure the injured worker was adequately trained
• Take corrective actions
• Record all findings with written documentation and actions taken to avoid reoccurrence.
The safety committee should review the documented findings. The safety committee will review
all accident or injury investigation reports to ensure the investigation was complete and
thorough. The findings will then be used to establish corrective action and follow up procedures
in a timely manner. The results will also be used as a tool to prevent reoccurrence.
Ensuring Compliance
All Foothills Energy Services employees are responsible for the safety of themselves and their
coworkers. All workers shall comply with applicable regulations, policies, and safety
procedures. All performance in maintaining a safe and healthful work environment will be used
in worker evaluations. Injuries will not be reported in performance evaluations and will not be
used to discriminate against workers. An unsafe act may however be recorded in the
performance evaluation. Standard disciplinary actions will be taken, at management’s
discretion, because of not following safety policies, procedures and the code of safe practices,
up to and including termination.
Appendix C:
Section 7.1: Pandemic Preparedness Program
Purpose
Management shall ensure the development, maintenance, and administration of a written pandemic
preparedness program for employees with occupational exposure.
Scope
This program applies to all Foothills Energy Services employees, all contractors and vendors performing
work on company property as well as all other individuals who are visiting or have business with our
company.
Responsibilities
• Management is responsible for the development and review of this program.
• Management is responsible for appropriate employee training
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• Employees must comply with the procedures outlined in this policy.
• Management and supervisors are responsible for the enforcement of this policy.
Procedure
This program will address the safe practices to avoid further spread of a pandemic type virus or disease.
• Using other methods of greeting other than a hand shake.
• Washing hands at regular intervals for at least 20 seconds.
• Where hand washing is not available hand cleanser or sanitizer stations will be provided where
possible.
• Avoid touching your face and cover coughs and sneezes with tissue.
• Disinfect office surfaces, vehicles and equipment.
• Use electronic means of communications such as video conferencing and conference calls when
possible.
• Avoid gatherings of more than 10 people in any one place.
• Follow CDC guidelines and local agencies for other more specific instruction.
• Periodic training shall be performed with CDC guidelines.
Exposure Control Plan
This program will address the strategy for controlling exposure to pandemic events.
• When possible employees will be allowed to work from home.
• Video conferencing and phone conferencing will be utilized instead of face to face meetings.
• If face to face meetings are necessary they will only be performed in open areas, outdoors or
well ventilated locations.
• When employees must meet a social distance of 6 feet shall be maintained at all times.
• If an employee feels ill they need to communicate with their supervisor and stay away from any
facilities or work locations until further notice.
• If an employee communicates an illness related to the pandemic to their supervisor the
supervisor will notify all effected employees and management for potential treatment
instructions.
• If a large number of employees fall ill the remaining employees will continue to utilize safe
practices to keep themselves healthy and management will review and revise a plan to best
continue with work schedules.
• If inoculations are available then employees will be reasonably expected to obtain appropriate
vaccines and immunizations to continue work.
Vehicles, equipment and tools shall be cleaned regularly to avoid surfaces becoming contaminated and
be a potential transmission source. Bleach wipes and alcohol based cleaners shall be used to wipe down
these locations to limit exposure.
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• Parts of the vehicles and equipment that should be disinfected include but are not limited to the
following, steering wheels or steering controls, equipment controls, radio knobs, door handles,
gear shift and seat belts.
• Tools that are shared by employees should be sanitized for use by the next person to limit
exposure.
Plan Review
Foothills Energy Services program administrator and management will review and revise the Pandemic
Preparedness Program annually and as needed. Testing the program may require more frequent reviews
and revisions. And following the pandemic a review will be conducted to asses the programs
effectiveness.
Section 5 - Portable Fire Extinguisher Program
Reference Standard
Occupational Safety and Health Administration: Portable Fire Extinguishers 29 CFR 1910.157.
Purpose
This procedure establishes minimum standards for the placement, use, maintenance and
testing of portable fire extinguishers. Preserving life must always be considered as the primary
goal when dealing with emergency response activities including the use of portable fire
extinguishers.
Scope
This procedure applies to all of company employees, contractors and vendors performing work
on company property, and all other individuals who are visiting or have business with our
company.
Responsibilities
• Management is responsible for the development and review of this program.
• Management is responsible for appropriate employee training.
• Management and supervisors are responsible for the enforcement of this program.
• Employees must comply with all procedures outlined in this policy.
• Contractors and vendors must comply with all procedures outlined in this policy.
Agent Weight
Dry chemical and dry powder 50-350 lbs.
Foam 33 gal.
Carbon dioxide 50-100 lbs.
Halon and halon replacements 50 lbs. or more
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Procedure
Fire Extinguisher Selection:
Fire extinguishers must be selected based upon the hazard(s) present in the area and the
expected types of fires that could result from them. The potential hazard must determine both
the type and capacity of the fire extinguisher. All fire extinguishers provided in our facility must
be UL approved.
Selection Guide:
Fire Hazards Class
Agent Selection
Fire Hazards Class
Agent Selection
Class A 1.Water Class B 1. Ordinary dry/Purple K chemical
2. Foam 2.Multi-purpose dry chemical 3.Multipurpose
dry chemical 3.Halon
4. Halon 4.Halon substitutes 5. Halon
replacement 5.Carbon dioxide
Class C 1.Ordinary dry/Purple K chemical
Class D Dry powder selected for the specific combustible metal
2.Multipurpose dry chemical
Class K Wet chemical (potassium-based liquids)
3.Halon 4.Halon substitutes 5.Carbon dioxide
Placement:
Placement of fire extinguishers must conform with the following guidelines:
1. Travel Distance:
a. Class A—75 feet or less;
b. Class B—50 feet or less;
c. Class C—based on the appropriate pattern for existing class A or B hazards;
d. Class D—75 feet or less; and
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e. Class K—Close to the hazard:
2. Hazard—travel distance to a fire extinguisher for high hazard areas must be lower
than the maximum allowed travel distance;
3. Ease of access—fire extinguishers in areas that are difficult to access must be
placed closer so that response to a fire must not be delayed;
4. Permanent location—all fire extinguishers must have a permanent location
consisting of a wall mount, a fire extinguisher cabinet or a vehicle bracket;
5. Damage—all fire extinguishers must be placed in locations that minimizes the
possibility of damage or obstruction by traffic or work activities in the area; and
6. Marking—all fire extinguisher locations must be conspicuously marked with signs or
other indicators.
Care and Maintenance
1. Keep fire extinguishers unobstructed and in clear view at all views.
2. Trained facility personnel should inspect fire extinguishers periodically and maintain
a written record of their inspection. The inspection must verify that each fire extinguisher:
• Is in its proper location;
• Is in adequate physical condition;
• Has a pressure gage within operable range (if so equipped);
• Has an unobstructed nozzle; and
• Has an adequate amount of agent (lift the extinguisher to verify it is not too light,
a possible indication the fire extinguisher may have lost some of its contents).
3. A certified fire extinguisher contractor must inspect each fire extinguisher
every year. Keep record of these inspections and any repairs that derive from them.
4. Remove from service any fire extinguisher after it is used, until it is inspected and
recharged by the contractor.
5. Remove from service any fire extinguisher if it is damaged, involved in an accident
where damage could result or if the extinguisher shows sign of corrosion, until it is inspected
and recharged by the contractor.
6. Label or make sure that each fire extinguisher is labeled with its operating
instructions and the class of fire(s) that it is designed to fight.
7. Make sure that all stored pressure dry chemical extinguishers that require a 12-year
hydrostatic test are emptied and subjected to applicable maintenance procedures every 6 years.
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8. All portable extinguishers shall be hydrostatically tested at the intervals listed in the
following table:
Type of Extinguisher Test Interval (Years)
Soda acid (stainless steel shell) 5
Cartridge operated water and/or
antifreeze
5
Stored pressure water and/or
antifreeze
5
Wetting agent 5
Exceptions: hydrostatic testing may be required more frequently when:
• The cylinder or shell threads are damaged;
Type of Extinguisher Test Interval (Years)
Foam (stainless steel shell) 5
Aqueous Film Forming foam (AFFF) 5
Loaded stream 5
Dry chemical with stainless steel 5
Carbon dioxide 5
Dry chemical, stored pressure, with
mild steel, brazed brass or aluminum
shells
12
Dry chemical, cartridge or cylinder
operated, with mild steel shells
12
Halon 1211 12
Halon 1301 12
Dry powder, cartridge or cylinder
operated with mild steel shells
12
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• There is corrosion that has caused pitting (including corrosion under removable
name plate assemblies);
• The extinguisher has been burned in a fire; or
• A calcium chloride extinguishing agent has been used in a stainless-steel shell.
Fire Extinguisher Use
There is nothing in our facility that is worth a human life. No employee is required to
use a fire extinguisher. Operating a fire extinguisher is a voluntary action.
• Only trained personnel are authorized to use a portable fire extinguisher.
• Fire extinguishers must only be used on incipient stage fires.
• When using a fire extinguisher:
- Alert employees who are at immediate risk from the fire;
- Activate the facility fire alarm;
- Use the PASS acronym for operation; and
- Report all fire extinguisher use to the program administrator.
• Operational safety rules for fire extinguisher use:
- Fight only incipient stage fires;
- Use a fire extinguisher that is approved for the class of fire you are trying to
extinguish;
- Always keep an exit path open behind you;
- Stay low to avoid heat and smoke;
- Do not turn your back on a fire, even after you think you have extinguished it;
and
- Avoid breathing smoke; ventilate the area after extinguishing the fire.
Training
• Only trained and authorized employees can use fire extinguishers in the facility.
• Employees will receive training after they are authorized to use fire extinguishers and
become familiar with the hazards involved with incipient stage firefighting. Training will
also be repeated annually for all authorized personnel.
• Employees who are not authorized to use fire extinguishers must be advised that their
only duties in a fire are: notification and evacuation.
• Training will consist of classroom training and can be supplemented with hands on
training when necessary. In all cases, employee safety will be stressed over property
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conservation. Additional training will be provided for any personnel who are assigned to
operate wheeled fire extinguishers.
Section 6: Emergency Action Plan Program
Reference Standard
Occupational Safety and Health Administration Subpart E, Emergency Action Plans: 29
CFR 1910.38
Purpose
This procedure establishes minimum procedures for responding to various emergencies
in our facility.
Scope
This procedure applies to all our company employees, all contractors and vendors
performing work on company property, and all other individuals who are visiting or have
business with our company.
Responsibilities
• Management is responsible for plan development and periodic review of this plan.
Management is also responsible for appropriate employee training.
• Management and supervisors are responsible for enforcement of this program.
• Employees shall comply with all procedures outlined in this policy.
• Contractors and vendors shall comply with all procedures outlined in this policy.
Procedure
Overview
All actions taken during an emergency will serve to protect the life and safety of employees,
contractors, visitors, and our facility neighbors. To the extent possible, we will minimize damage
to property and the environment. Our emergency response activity will never knowingly
jeopardize the safety of any individual.
Evacuation Routes and Maps
All evacuation exit routes are permanent and are maintained as accessible and passable
always. Evacuation maps are posted at various locations throughout our facility. These maps
reflect the location of the evacuation routes, exits and evacuation destination locations.
Accounting for Personnel
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Employee roster sheets will be used for personnel accounting following an evacuation.
Supervisors or designees will be responsible for using the roster sheets to accomplish a head
count immediately following evacuation. Visitor, Contractor and Vendor Logs will be used to
account for individuals in these groups.
Individuals who have disabilities that may impair their ability to evacuate will be encouraged to
discuss the issue with Human Resources or another member of management. Necessary
arrangements will be made confidentially to assist with evacuation.
Contractors, Vendors and Visitors
Contractors, vendors, and visitors should evacuate to the outdoor area adjacent to the door
through which they entered and signed the Visitor/Contractor Log. The receptionist or an
alternate will perform the head count. During severe weather evacuations contractors, vendors
and visitors should evacuate to the Shelter area assigned to their host.
Fire Emergency
Employees discovering a fire will take the following action:
• Alert others in the area who are at risk and notify a member of management who will
initiate the 911 Notification System
• Initiate the fire alarm procedure
• Turn off involved equipment
• Consider using a fire extinguisher, it trained and authorized to do so.
• Evacuate
• Upon being alerted of a fire evacuation, all employees, visitors, contractors, and vendors
will:
a) Turn off equipment (if safe to do so)
b) Walk in an orderly and quiet manner to the exit closest to you not blocked by fire,
smoke or other hazards and exit the building.
c) Do not delay evacuation or re-enter hazardous areas to retrieve personal
possessions such as keys, coats, purses, or lunches.
d) Report to designated fire Evacuation Location for head count.
e) Stay together with their assigned group until further instructions are given.
f) The facility will not be reoccupied until approved by the fire department.
Note: The supervisor or other designated employee will be the last to exit the
department. Check lavatories and other cut-off rooms to assure evacuation and will close doors
upon leaving.
Medical Emergency
In the event of a medical emergency the following actions will be taken:
• Notify a member of management who will initiate the 911 Notification System.
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• Evaluate scene safety-if there is any concern all personnel should stay at a safe
distance.
• Do not move the ill/injured person (unless she or he is in danger from their
surroundings)
• Avoid all contact with blood and other bodily fluids (never attempt to provide first
aid unless you are trained and equipped to do so)
• A calm employee may stay with ill/injured person to provide comfort.
• The supervisor will assign at least two employees to wait for the EMS responders
at the parking lot entrance and guide the responders to the scene of the
emergency.
• All uninvolved personnel should clear the area.
• If there has been any blood or bodily fluid release, trained personnel will clean
and sanitize the area after the emergency phase has concluded.
Severe Weather
A weather alert radio is monitored in our facility at all times. In the event that a warning
is issued for our facility the following actions will be taken:
• Turn off equipment (if safe to do so)
• Walk in an orderly and quiet manner to the designated severe weather
Evacuation Location.
• A head count will be conducted to account for all personnel.
• When the severe weather warning expires personnel will be released from the
shelter
Note: The supervisor or other designated employee will be the last to exit the
department. Check lavatories and other cut-off rooms to assure evacuation and will
close doors upon leaving.
Hazardous Chemical Spill or Release
Hazardous chemical spills or releases can be recognized visually by seeing evidence of
a chemical escaping from its’ normal containment or by detecting an unusual odor. If a
chemical spill is suspected all personnel will do the following:
• Alert others in the area who are at risk and notify a member of management who
will initiate the 911 Notification System.
• Turn off equipment (if safe to do so)
• Walk in an orderly and quiet manner to the exit closest to you not blocked by the
chemical release.
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• Report to designated fire Evacuation Location for head count.
• The Emergency Coordinator or another member of management will observe the
wind direction if applicable and determine the best shelter area for evacuated
personnel.
• Stay together with their assigned group until further instructions are given.
• The facility will not be reoccupied until approved by the fire department.
No employee will take any action other than defensive actions to attempt to control a
hazardous chemical spill or release unless s/he has been trained and equipped to
respond.
Electrical Utility Failure
In the event of an electrical failure the following procedure will be followed:
• If the failure is in a partial area of the facility notify a supervisor or member of
management.
• Turn off equipment using normal controls.
• Expect sudden equipment restart-stay away from the point of operation and other
moving surfaces.
• Do not attempt to move around dark areas-supervisors will use flashlights to
guide employees to a safe area to wait for power restoration.
• After power is restored follow supervisor’s directions for equipment restart.
Workplace Violence
Workplace violence will be handles as follows:
• Any employee who witnesses a violent act, threat of violence or is otherwise
concerned should report it to member of management.
• If immediate action is necessary, s/he will:
a) advise personnel most at risk to take shelter behind closed doors or to
evacuate to other areas of the facility.
b) contact emergency services or delegate another person to do so.
c) notify the Emergency Coordinator who will evaluate the situation, meet the
police, expand the evacuation, and coordinate a head count.
• If immediate action is not deemed necessary, the member of management will
notify the Emergency Coordinator of the incident. The Emergency Coordinator
will begin an immediate investigation and evaluate the threat to personnel.
Emergency Duties
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Emergency Coordinator
• Verify that necessary Emergency Services have been notified.
• Coordinate the employee accounting procedure in the case of evacuation
emergency.
• Meet responding Emergency Service units and:
a) Issue a situation report
b) keep in contact to provide needed information
c) advise them of evacuation status (during evacuation emergencies)
• Issue updated instructions to personnel as necessary taking into account comfort
of evacuees, duration of the evacuation, time of day, etc.
• Coordinate incidents of workplace violence.
Supervisors
• Assist with responding to all emergencies and communicate emergency
instructions to employees.
• Communicate facts surrounding an emergency occurring in their area to the
Emergency Coordinator.
• Develop plans to assist employees with disabilities to evacuate safely.
• Verify all employees are evacuated before leaving.
• Perform the head count procedure to account for all employees and
communicate missing personnel to the Emergency Coordinator.
• Be the initial contact and coordinator for incidents involving workplace violence.
Critical Operations Duties
Employees who are required to remain behind during evacuation, or who are assigned
special response duties, will be fully trained, and equipped to ensure their safety and
readiness.
Training
At a minimum, training will be conducted:
• Upon hire
• When this plan changes
• When employee duties change
Training will consist of:
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• Methods of alerting employees of an emergency
• Employee duties upon discovering an emergency
• Evacuation routes and Evacuation Locations
• Procedures to be followed upon notification of emergency
Medical Services
First Aid and Medical Supplies
Management shall ensure that adequate first aid and blood borne pathogen supplies are readily
available and maintained at all work sites.
First aid supplies shall be inspected and restocked.
Eye-wash stations shall be provided in garage areas, shop area and chemical use/storage
locations. Eye-wash equipment shall be inspected monthly.
Section 7: Bloodborne Pathogens Program
Reference Standard
Occupational Safety and Health Administration (OSHA); Bloodborne Pathogens, Subpart Z, 29
CFR 1910.1030
Purpose
Management shall ensure the development, maintenance, and administration of a written
bloodborne pathogens program for employees with occupational exposure.
Scope
This program applies to all our company employees, all contractors and vendors performing
work on company property as well as all other individuals who are visiting or have business with
33
our company. Note: This training guide does not apply to HIV and HBV research laboratories
and HIV and HBV production facilities.
Responsibilities
• Management is responsible for the development and review of this program.
Management is also responsible for appropriate employee training.
• Management and supervisors are responsible for the enforcement of this program.
• Employees must comply with all procedures outlined in this policy.
• Contractors and vendors must comply with all procedures outlined in this policy.
Procedure
Exposure Control Plan
There are only two possibilities for bloodborne pathogens exposure in our facility:
• While responding to an illness or injury to provide first aid care; or
• When cleaning and sanitizing a bodily fluid spill.
Additionally, an employee could experience unintended exposure from contact with blood or
OPIM.
Accordingly, there are no direct engineering controls available. Our exposure control plan is:
• Only designated personnel who are trained, authorized, and equipped to respond to
medical emergencies and or bodily fluid spills will do so. All other personnel will avoid
contact and notify their supervisor if a spill or exposure incident is encountered;
• While responding to bodily fluid spills, an appropriate level of PPE will be worn including:
a) Safety glasses—Incidents with minimal exposure potential (e.g. a laceration with
spurting, arterial bleeding);
b) Disposable liquid-proof gloves—All incidents;
c) Apron (or disposable suit) and shoe covers—Incidents with a potential of bodily
fluid becoming airborne or incidents in which response personnel could walk
through a spill or move against material contaminated with a spill; or
d) Barrier mask and/or Bag Valve Mask—Incidents requiring mouth-to-mouth or
mouth-to-nose breathing;
e) Adequate supplies of personal protective equipment are kept in the following
locations and are available for employee use (at no cost to employees):
Regulated waste (such as contaminated dressings and bandages) and other materials will be
double bagged in red biohazard bags and disposed of as regulated waste using an approved
disposal contractor. We do not use any medical sharps;
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All potentially contaminated surfaces will be cleaned and sanitized with an approved sanitizing
solution or will be disposed of as contaminated medical waste. Personnel performing this duty
will be trained in all aspects of this plan and will be required to wear appropriate PPE as outlined
above;
After performing necessary duties personnel will clean, sanitize, remove and discard any
contaminated PPE;
All personnel are required to wash their hands with soap and warm water. (Handwashing
facilities or waterless skin sanitizer when potable water is remote from the scene) is will be
available to use when potable water is remote from the scene) immediately after removing PPE;
If an exposure is suspected, any employee, trained or untrained, should immediately:
• Wash exposed skin surfaces with large amounts of soap and warm water;
• Rinse exposed mucus membranes with large quantities of warm water;
• Report any actual or suspected exposure incident to their supervisor or the plan
administrator. The employee will immediately be referred to a physician or other
licensed health care provider for a confidential follow-up (at no cost to the
employee);
Plan Review
The program administrator will review and revise this plan annually and as needed.
Training
All employees who are authorized to respond to potential exposure incidents will be
trained annually regarding this exposure control plan and their duties.
Employees who have no occupational contact with potentially contaminated materials
will receive awareness training upon hire.
Section 8: Heat Illness Prevention
The purpose of the Heat Illness Prevention Program is to meet the requirements set
forth in the Standard and to serve as a required supplement of the Injury and Illness Prevention
(IIP) Program. This program establishes procedures and provides information to ensure that
Foothills Energy Services, Inc. employees are knowledgeable in the prevention and recognition
of heat stress to ensure their own safety and the safety of others.
Responsibilities
Health and Safety Coordinator
• Establish and update the written Heat Illness Prevention Program;
35
• Provide consultation/training to departments who fall within the program; and
• Assist departments in determining when, where, and how shade and water is
provided.
Supervisors
• Identify and maintain records of all tasks/employees that are required to work
outdoors where potential heat illness could occur;
• Require all potentially impacted employees to receive proper training on heat
illness prevention and comply with all appropriate procedures;
• Maintain training records;
• Ensure that adequate water is available at the beginning of each shift and
throughout the work day;
• Ensure access to shade for purposes of a preventative recovery period is
available during the work day; and
• Follow proper procedures to contact emergency medical services in the event
medical assistance is required.
Employees
• Awareness and compliance with all appropriate heat illness prevention
procedures while performing assigned duties;
• Employees are ultimately responsible for drinking adequate amounts of hydrating
fluids when the environmental risk factors for heat illness are present;
• Ensure access to a shaded area is available to recover from heat related
symptoms;
• Inform their supervisor if shade and/or water are inadequate;
• Report symptoms of heat related illness promptly to their supervisor; and
• Follow proper procedures in the event medical assistance is required.
Basic Requirements
Provision of Water
Employees will have access to potable drinking water. Water will be fresh, pure, suitably
cool and provided to employee free of charge. The water will be located as close as practicable
to the areas where employees are working. Where water is not plumbed, or otherwise
continuously supplied, it will be provided in sufficient quantity at the beginning of the work shift.
Sufficient quantity is defined as enough to provide one quart per employee per hour for drinking
for the entire shift. The frequent drinking of water, as described in the training section, will be
encouraged.
High-Heat Procedures
The following high-heat procedures will be implemented when the temperature exceeds
95º Fahrenheit:
36
• Designate one or more employees on each worksite to call for emergency medical
services, and allow other employees to call for emergency services when no designated
employee is available;
• Remind employees throughout the work shift to drink plenty of water; and
• Pre-shift meetings before the commencement of work should review high heat
procedures, encourage employees to drink plenty of water and remind employees of
their right to take a cool-down rest when necessary.
Heat Illness Types
Heat Cramps, Heat Exhaustion and Heat Stroke
Precautions to Prevent Heat Illnesses
• Condition yourself for working in hot environments. Start slow and build up to more
physical work. Allow your body to adjust over a few days (acclimatization).
• Drink plenty of liquids – hydration is a continuous process. Do not wait until you are
thirsty! By then, there is a good chance that you are already on your way to being
dehydrated. Electrolyte drinks, such as a sports drink, ae good for replacing both water
and minerals lost through sweating. Never drink alcohol, and avoid caffeinated
beverages like coffee and soda, as these liquids can have the opposite effect and can
actually increase the level of dehydration.
• Take frequent breaks, especially if you notice you are getting a headache or you start
feeling overheated.
• Assure that adequate water is available at the jobsite before work begins.
• Wear lightweight, light colored clothing when working out in the sun.
• Immediately report all unsafe conditions and/or concerns to your supervisor.
37
Section 9: Excavations
38
General
• Competent Person(s) shall be at the work site at all times while employees are working
in excavations.
o Another competent person shall be designated if the original competent person is
unable to be present.
• Only Qualified and Authorized Persons shall work in or around excavations.
• The local utility-locating service shall be notified in accordance with the locating service
requirements prior to the start of excavating activities. The Person-In-Charge shall verify
that the notification and marking is completed.
• Compliance with local area rules shall determine the distance from each side of the
utility-locate mark.
• Final locations of underground utilities shall be determined by safe means prior to
mechanical excavation. If unable to determine location by safe means, stop work and
contact Management/Supervision before proceeding.
• Exposed utilities and encumbrances shall be adequately supported and protected from
damage.
• Employees, pedestrians and vehicular traffic shall be protected from excavation hazards
to the level determined by the Competent Person.
• Excavations shall be barricaded if left open past the end of the work shift to the level
determined by the Competent Person. Barricades shall be capable of deterring access
to the excavation from expected sources, e.g., pedestrians, vehicular traffic, etc.
Warning tape is not considered to be an effective barricade for this application.
• Excavations performed within the buffer zone to buried facilities shall be done by non-
destructive means.
• If the Competent Person suspects the presence of, or the potential for, a Hazardous
Atmosphere in excavations in excess of four (4) feet deep, the atmosphere shall be
tested. Testing shall determine the work procedures in compliance with Confined Space
safety rules.
• Employees shall be protected from spoils, materials or equipment that could pose a
hazard by falling or rolling into excavations. Protection shall be provided by placing and
keeping such materials or equipment at least two (2) feet from the edge of the
excavation, or by the use of retaining devices that are sufficient to prevent materials or
equipment from falling or rolling into excavations, or by a combination of both, if
necessary.
• The Competent Person shall inspect excavations prior to employees entering the trench
and after each change in conditions.
• Excavations exceeding twenty (20) feet in depth in which employees may enter shall be
designed and engineered by a professional engineer.
• The Competent Person shall complete the Excavation / Trenching form prior to
employees entering the excavation.
• Employee Protection
• Employees shall be protected from cave-ins and falling objects in excavations of any
depth.
39
• Excavations at or exceeding five (5) feet in depth which employees may enter shall have
protective methods installed for employee protection. Methods to provide protection are
sloping, benching, shielding or shoring.
• Sloping or benching shall comply with the angles specified:
o Class A soil; ¾:1 53°
o Class B soil; 1:1 45°
o Class C soil; 1½:1 33°
• Employees shall be provided with safe means of entry and egress. Ladders or ramps
shall be stationed within twenty-five (25) feet of any employee in the excavation. Ramps
shall be designed such that an employee can walk upright.
• The Competent Person shall determine the appropriate fall protection system for
employees working near excavations.
• Employees working near traffic shall wear approved retro-reflective clothing.
• Employees working near machinery shall wear approved high-visibility clothing.
• Equipment shall be positioned to eliminate the potential of cave-ins. If equipment is
required to be at the edge of an excavation, the excavation shall be shored or braced to
prevent displacement or cave-in.
• Employees shall not cross excavations exceeding two (2) feet in width and four (4) feet
in depth. Excavations exceeding these dimensions that are to be crossed shall have
appropriate walkways with guard rail systems.
• Unattended wells, pits, shafts, boreholes, etc. shall be covered.
• Employees working near or adjacent to wells, pits, shafts, boreholes, etc. that cannot be
covered and are larger than three (3) feet in diameter and four (4) feet in depth shall
implement the following:
• Establish a highly visible zone at a minimum of six (6) feet from each side of the
excavation.
• Employees crossing into the identified zone shall be protected from falls by a personal
fall-arrest system or proper fall restraint.
• Employees shall not enter wells, pits, shafts, boreholes and other confined excavations
without approval from Management and Safety.
• NOTE: Wells, pits, shafts in excess of four (4) feet may be classified as a Confined
Space.
• Electrically Qualified Persons exposing, working on or near, working in close proximity
to, or hand excavating near Energized underground electrical conductors shall wear
appropriate rubber insulating PPE.
• If displacement, cracking, settling or other hazards are present or develop, all employees
shall exit the trench and the Competent Person shall evaluate the condition.
• Employees shall not re-enter an excavation until the hazard has been corrected to
permit safe entry.
Soil Classification / Soil Testing
• The Competent Person shall classify the soil materials.
o The soil classification shall be based upon a minimum of one visual observation
and one manual analysis.
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• Multiple soil types may be present and the least stable soil type shall determine the type
of protection to be implemented.
• The Competent Person shall determine the protective system based upon the soil
classification.
• Shoring and Shielding
• Shoring and shielding components shall have the manufacturer data at the work site.
• Shoring and shielding shall be capable of withstanding the intended loads and installed
per manufacturer specifications.
• The Competent Person shall inspect the shoring or shielding each day, if conditions
change or if the components are altered.
• Shoring or shielding with visible damage that compromises the integrity of the system
shall not be installed. If components are damaged during use, all employees shall exit
the excavation immediately; then the component shall be repaired or replaced.
• Installation of the components shall be performed so that employees are protected at all
times.
• Removal of the components shall be performed so that employees are protected at all
times. If employees must enter the excavation for removal, then removal shall occur
from the bottom of the trench and proceed upward. Jacks or braces shall be released
slowly to prevent collapse.
• Protective systems for excavations exceeding twenty (20) feet in depth shall be
designed by a professional engineer.
• Damage to Underground Utilities
• If underground utilities (electric, water, communications, sewer, gas, storm water, TV)
are damaged, the facility owner and Management shall be immediately notified.
• The area shall be barricaded and unauthorized personnel shall be kept at a safe
distance.
• If a gas facility is damaged:
o Evacuate non-essential personnel from the area;
o Eliminate sources of ignition;
o Secure the damaged area;
o Contact the operator; and
o If buildings are in the area, warn and notify the occupants downwind.
Section 10: Personal Protective Equipment (PPE)
Introduction
Engineering controls will be implemented first to ensure the safety of our workers. When
Personal Protective Equipment (PPE) or Administrative procedures are used, the hazard(s) is
still present in the environment. The PPE device merely acts as a barrier between the hazard
and employee. Improper use or failure of the device means the employee is exposed directly to
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the hazard. If it is not possible to eliminate or reduce the exposure, PPE becomes the best
protection method.
Personal Protective Equipment (PPE) includes all clothing and accessories designed to create a
barrier against workplace hazards.
Employee Training
An essential part of any PPE program is employee education. Employees need to be told why
they must wear safety glasses, gloves, or special clothing. We need to get them involved and
make sure that they have participated in eliminating or reducing hazards as much as possible
through engineering or administrative controls. Then, when asked to wear PPE, they are far
more likely to comply.
Each employee required to use Personal Protective Equipment (PPE) will be trained in the
following:
• When PPE is necessary;
• What PPE is necessary;
• How to properly wear and adjust PPE;
• The limitations of the PPE;
• The proper care, maintenance, and useful life of the PPE.
Each employee must demonstrate an understanding of the training. This will be accomplished
by requiring the employee to put on, take off and adjust the PPE. Retraining will take place
when:
• PPE changes;
• Changes in the workplace render previous PPE obsolete;
• Lack or improper use of PPE by employee.
Employee training will be documented on the attached PPE training certification form.
Compliance Enforcement
Enforcement in using PPE is essential, but it must be applied consistently across the board. For
example, if all employees are required to wear safety glasses, then all visitors and contractors
must wear them. It is especially important that management demonstrate support by wearing
PPE when in PPE designated areas.
Equipment Selection / Purchasing
Our equipment selection procedure should include employees who will be wearing the PPE,
safety manager, purchasing manager, and supervisor. Other than prescription safety glasses
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and safety shoes, management will pay for all required or mandated PPE. When possible, PPE
purchased will carry the ANSI, SEI and/or NIOSH label.
Evaluation
At least annually management will review injury and illness records and talk with employees
who use the PPE to determine if PPE is effective in preventing injuries. If our on-the-job hazards
and protection changes, OSHA requires that our employees receive new PPE training.
Promoting PPE Use
When possible, employees will be offered choices on the devices they wear. When employees
have control/say in PPE use, it increases compliance and reduces health costs.
Since employees come in many shapes ad sizes, to ensure optimum fit and comfort, PPE will
be offered in 2 or more sizes whenever possible. If PPE does not fit properly; it is less likely to
be worn and is less likely to be effective.
Cleaning, Maintenance and Storage
All tools must be kept clean and in good condition to work well. PPE is no different. OSHA says
that employees who use PPE on the job must know how to care for and maintain it properly.
Our training program and the PPE manufacture’s instruction will help install and remove PPE
properly to keep it in good condition and protect oneself. PPE should be inspected prior to each
use by employees to check for damage.
PPE should be cleaned after each use before storing it. All single use or damaged PPE will be
disposed of in the proper manner. PPE will be stored in its assigned place to avoid conditions
that could damage it, such as heat, light, moisture, etc.
Employee Acceptance
The following “5E’s” are methods to overcome employee’s objections to wearing PPE.
1. Employee Involvement – The more involved employees are in the selection of PPE, it’s
training and enforcement, the higher rate of acceptance.
2. Exemplify the Policy – Be a good example. Everyone should be required to follow the
PPE Policy. This is particularly important for managers.
3. Educate Employees – Train employees in the need and use of PPE. Find ways to get
them involved in the training process.
4. Emphasize with Employees – Some problems are easy to resolve. The earplugs may
be ineffective against a noise hazard. Show the employee how to properly use the ear
protectors.
5. Enforce Policy Uniformly – This is essential. Be uniform, consistent and fair.
Disciplinary Actions
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The discipline of employees for PPE rule violations will be left to the discretion of the supervisor
but documented in writing.
Eye and Face Protection
Employees must use appropriate eye /face protection when exposed to eye or face hazards.
Head Protection
OSHA standard hardhats shall be worn at all job site and yard locations.
Foot Protection
Employees must wear protective footwear when working in areas where there is a danger of
foot injuries due to falling or rolling objects, or objects piercing the sole and where employees’
feet are exposed to electrical hazards.
Hand Protection
Employees are required to use appropriate hand protection when employees hands are
exposed to hazards such as those from skin absorption of harmful substances, severe cuts or
lacerations, severe abrasions, chemical burns, thermal burns and harmful temperature
extremes. Employees shall base selection of the appropriate hand protection on evaluation of
the tasks being performed, conditions present, duration of use and the hazards and potential
hazards identified.
Respiratory Protection Program—Use of Respirators
Respirators are an effective method of protection against designated hazards when properly
selected and worn. All tasks are typically well below the exposure limits defined in OSHA silica
standard Table 1. If a task approaches the lower exposure limits a respiratory protection plan will
be followed. Respirator use is encouraged, even when exposures are below the exposure limit
(see Silica standard table 1), 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 you. 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 we do
not require the use of a respirator and you choose to use your own, you need to take certain
precautions to be sure that the respirator itself does not present a hazard.
If using a voluntary respirator, you should do the following:
1. Read and heed all instructions provided by the manufacturer on use, maintenance, cleaning
and care, and warnings regarding the respirators limitations.
2. Choose respirators certified for use to protect against the contaminant of concern. National Institute for Occupational Safety and Health (NIOSH) 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.
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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.
If Foothills Energy Services employees are required to perform work that exposes them to the lower exposure limits on OSHA’s Table 1, then all necessary safety precautions will be taken. A full respiratory program including fit test training will be implemented. Respiratory Protection
Respiratory Protection Program—Use of Respirators
Section 11 - Fall Protection Safety Program
Reference Standard
This procedure is developed in accordance with provisions as outlined in the OSHA
safety standards for General Industry (Part 1910), Subpart D: Walking and Working
Surfaces, specifically 29 CFR 1910.21 – Definitions; 29 CFR 1910.22 – General
Requirements; 29 CFR 1910.23 – Guarding Floor & Wall Openings and Holes; and 29
CFR 1910.24 – Fixed Industrial Stairs.
Purpose
This policy establishes how Foothills Energy Services, Inc. will enhance safe working
conditions at this facility through the establishment of specific walking and working
surface requirements and protection from fall hazards.
Scope
This policy applies to all Foothills Energy Services, Inc. employees and all company
contractors, visitors or vendors.
Responsibilities
Senior management will:
• Require the full application and integration of this policy into daily
operations, as applicable, in all areas of responsibility and with all direct
reports;
• Assess managers and supervisors on their ability to apply this policy in
their areas of responsibility; and
• Provide fall protection to affected employees.
The Safety Administrator will administer all aspects of this policy to include:
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• Maintaining and updating the written program as required;
• Coordinating necessary training for all affected employees;
• Providing necessary technical assistance to managers and supervisors;
and
• Periodically assessing the effectiveness of this program and its
implementation in all affected areas of the company.
Managers and supervisors will:
• Know how this policy applies to those under their direct control;
• Integrate and enforce the provisions of this policy in their areas of
responsibility;
• Periodically audit the effectiveness of this policy in their areas of
responsibility;
• Coordinate training for all affected employees;
• Provide appropriate coaching and corrective action when necessary to
ensure this policy is fully integrated; and
• Investigate and document all incidents that result in employee injury.
All affected employees will:
• Integrate the provisions of this policy into their daily activities as
applicable;
• Follow all training, instructions and directives relative to this policy;
• Seek clarification whenever there are questions concerning the
application of this policy into daily operations;
• Bring to management’s attention any unsafe or hazardous condition or
practice that may cause injury to themselves or other employees; and
• Report any incident that causes injury to an employee, regardless of its
nature.
Policy Evaluations and Updates
It is our goal to maintain a safety program that is understandable, effective and one that
promotes a safe work environment. Any employee can make recommendations for
improvement to this program or any other aspect of our safety system. These
suggestions should be directed to any member of management, any safety committee
member or to the safety administrator.
As a matter of policy, this program will be reviewed on an annual basis by the safety
administrator to determine if all aspects still meet the needs of this organization. If there
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are significant events that take place during the year that indicate the program is less
than effective, an immediate evaluation will be conducted and appropriate steps taken to
increase the reliability of this plan.
Fall Hazard Survey
Prior to implementing fall protection procedures, authorized facility personnel will
conduct a fall hazard survey to identify all real or potential fall hazards.
When conducting the fall hazard survey, the person or persons conducting the survey
must be familiar with fall hazard definitions and the work environment. When conducting
the survey, consideration must also be given for specialized maintenance functions such
as cranes, tops of machines and roof work.
The fall hazard survey will identify one or more methods to eliminate or control each
identified hazard and will identify the responsible person(s) and completion date(s) for
protective measures to be resolved.
Fall hazard survey reports must be revised or re-written whenever there is a change to
the task, process, structure or equipment that would render past surveys obsolete.
Training
All employees will receive some level of training relative to fall protection. All employees
will receive awareness-level training, which is designed to convey the concept of
elevated platforms and performing work at elevated heights.
Any employee who has the requirement to perform work at heights as a part of their job
will have practitioner-level training that describes the steps that have been taken to
provide fall protection measures and when additional measures must be employed.
Specifically, this training will include:
• Recognition of fall hazards;
• Methods to eliminate or control fall hazards; and
• Specific requirements as outlined in various standards.
The training frequency will be as follows:
• Awareness-Level Training: Provided to employees who do not have job
responsibilities that involve working at elevated heights. Training will be
provided within the first week of employment or re-assignment into a new
area. Refresher training will be provided when conditions in the
workplace warrant new training; and
• Practitioner-Level Training: Provided to employees who have job
responsibilities that will require them to work on or at elevated heights.
Training must be provided before the employee is required to perform any
job that will have them working at an elevated height. Practitioner-level
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training will be provided on an annual basis or whenever conditions in the
work environment warrant more frequent training (such as when new
equipment with new working platforms is delivered to the facility.)
Elements of the training will include:
• Nature of fall hazards to which employees may be exposed;
• Correct procedures for erecting, maintaining, disassembling and
inspecting fall protection systems;
• Use and operation of controlled access zones, guardrails, personal fall
arrest systems, safety nets, warning lines and safety monitoring systems;
• Role of each employee in the safety monitoring system (if one is used);
• Limitations of the use of mechanical equipment during roofing work on
low-slope roofs;
• Correct procedures for equipment and materials handling as well as
storage and erection of overhead protection;
• Requirements of the OSHA Fall Protection Standard, 29 CFR 1926,
Subpart M; and
• Requirements for reporting incidents that cause injury to an employee.
Walking-Working Surfaces – General Requirements
The following requirements will apply to all walking and/or working areas in the facility.
The responsible manager for each area shall periodically survey their areas of
responsibility to ensure these requirements are being met. When necessary,
adjustments to physical conditions shall be made to meet these requirements.
Housekeeping: Passageways, storerooms and service rooms will be kept clean, orderly
and in a sanitary condition. In all areas of the facility, workroom floors must be
maintained in a clean, and as much as possible, dry condition. Where wet conditions
exist, management will install proper drainage or, when drainage is impossible, mats
should be used to keep workers’ feet on a dry surface.
Aisles and Passageways: All aisles and passageways will have sufficient safe
clearances when material handling equipment is in operation. Consideration shall be
given to the type of work performed in all areas so there is no competition between
people and moving equipment. At a minimum, aisles and passageways must be at least
22 inches wide. Sufficient space for people must always be maintained in aisles and
passageways.
All aisles and passageways will be kept clear of obstructions and maintained in good
repair, and all permanent aisles will be marked either with tape or with paint.
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Floor Loading Protection: Load rating plaques will be conspicuously posted appropriate
locations throughout the facility. At no time will load limits be exceeded in any location.
This is particularly true when equipment is stored on top of mezzanine areas, office
areas or other single-storied areas.
Floor or Wall Openings
Stairway Openings: Standard railings will be provided on all exposed sides except at the
stairway entrance.
Stairway Railings and Guards: Every flight of stairs having four or more risers (steps) will
be equipped with a standard stair railing as described below:
• On stairways less than 44 inches wide with both sides enclosed, at least one
handrail on the right side descending;
• On stairways less than 44 inches wide having one side open, at least one stair
railing on the open side;
• On stairways less than 44 inches wide but with both sides open, one stair railing
on each side;
• On stairways more than 44 inches wide but less than 88 inches wide, one
handrail on each enclosed side, one stair railing on each open side; and
• On stairways 88 inches or more wide, one handrail on each enclosed side, one
stair railing on each open side and one intermediate stair railing located
approximately midway of the width.
Stairway Railing and Handrail Specifications: The following provides guidance on how all
railings and handrails will be constructed. When purchasing equipment, these
requirements must be followed:
• A stair railing system must be of similar construction to a guardrail system except
that the vertical height may not be more than 34 inches or less than 30 inches
from the upper surface of the top rail to the surface of the tread; and
• The height of the handrails may not be more than 34 inches nor less than 30
inches from upper surface of the handrail to surface of the tread, with a clearance
of not less than 3 inches between the handrail and wall.
Fixed Industrial Stairs: All fixed industrial stairs, purchased or installed, must meet the
following requirements:
• Fixed stairs will be provided for access from one level to another where
operations necessitate normal travel between levels and for access to operating
platforms for any equipment that requires routine attention;
• Fixed stairs must be capable of carrying a load five times the normal live load
anticipate with a minimum ability to safely carry a moving, concentrated load of
1,000 pounds;
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• Fixed stairs must have a minimum width of 22 inches;
• Fixed stairs will be installed at angles to the horizontal of 30 to 50 degrees.
• All stair treads must be slip-resistant;
• Stairway platforms may be no less than the width of the stairway and a minimum
of 30 inches in length, measured in the direction of travel;
• Standard railings must be provided on the open sides of all exposed stairways
and platforms, and handrails must be provided on at least one side of closed
stairways; and
• The vertical clearance above any stair tread to an overhead obstruction must be
at least 7 feet, measured from the leading edge of the tread.
Floor Opening or Hole: Every floor opening or hole must be guarded by either a railing system
with toe boards along all exposed sides or a load-bearing cover. When the cover is not in place,
the roof, floor opening or hole must be protected by a removable guard railing.
Protection of Wall Openings/Holes: Every wall opening from which there is a drop of more than
four feet will be guarded by a railing system. Where there is a potential of exposure to falling
objects, a removable toe board will be provided.
NOTE: The next section on open-sided floors and platforms is very important because it
addresses most fall protection issues.
Protection of Open-Sided Floors and Platforms: Every open-sided floor or platform four feet or
more above the adjacent floor or ground level must be guarded by a standard railing and toe
board on all open sides except where there is an entrance to a ramp, stairway or fixed ladder.
The railing systems are required to have a toe board wherever a person can pass beneath the
open sides or there is moving machinery.
NOTE: When a working platform is adjacent to dangerous equipment, there must be a standard
railing and toe board regardless of the height difference.
Fall Protection Hierarchy
The following hierarchy, or preferred order of control, will be used to choose methods to
eliminate or control fall hazards:
• Eliminate the need to work at height;
• Use of engineering controls such as guardrails and/or work platforms;
• Use of personal positioning system to prevent a fall;
• Use of a personal fall arrest system; and
• Administrative controls.
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Securing the work area. Overhead work shall not be performed when there are other
people directly underneath the overhead work. If other people need to be in the
immediate area, then steps must be taken to secure the work area and the safety of
people working below overhead work. This may include the use of head protection (hard
hats) or other guards to keep debris from falling on people below the overhead work.
Whenever possible, work below overhead work will be suspended until the overhead
work is complete.
A sign reading “workers overhead” shall be put in the area where workers are performing
overhead work to warn people who may be passing through the work area. The area
directly beneath the overhead work must be secured to prevent unauthorized people
from entering the area.
Scissors lifts. When using a scissors lift, occupants will be protected from falling by
restraint systems, fall arrest systems or guard rails. Fall restraint/arrest systems are not
required where protection is afforded by guardrails and where the occupant does not
step above the platform of the lift.
Audits and Inspection
On an annual basis, overhead working areas will be surveyed to ensure proper fall
protection methods.
Enforcement
Constant awareness of and respect for fall hazards, as well as compliance with these
and all other company safety rules, are considered conditions of employment at Foothills
Energy Services, Inc.. The crew supervisor of foreman reserves the right to issue
disciplinary warnings to employees, up to and including termination, for failure to follow
the guidelines in this plan.
Accident Response and Investigation
When an accident occurs, you must notify management. Management will either
promptly rescue injured workers (directly or indirectly through a third party) or provide
workers the equipment to rescue themselves.
All incidents that result in injury to workers and near misses, regardless of their nature,
must be reported and investigated. All incidents will be investigated as soon as possible
to identify the cause and means of prevention of future occurrences.
In the event of an incident, this Fall Protection Plan will be reviewed to determine if
additional provisions or practices, procedures or training should be implemented to
prevent similar incidents in the future.
When an employee is exposed to a fall in excess of 4 feet and protective measures such as
catch platforms, guardrails, and safety nets are not practical, the employee shall be protected by
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the use of fall-arrest equipment or positioning devices such as harnesses, lanyards, lifelines,
and rope grabs. When choosing fall-arrest equipment or positioning devices, employees should
consider the type of work to be performed and limiting the shock load on the body of the wearer
in the event of a fall.
Employees shall rig fall-arrest equipment so that they cannot free fall more than 6 feet or
contact any lower object. When positioning devices are used, they shall be rigged to limit free
fall to 2 feet. Anchorage points for fall-arrest equipment and positioning devices shall be
capable of supporting a shock load and located above the employee’s harness attachment
point.
Employees shall avoid the following lanyard snap-hook connections to help eliminate the
possibility of accidental disengagement:
- Snap-hooks without locks.
- Two (or more) snap-hooks connected to one D-ring.
- Two snap-hooks connected to each other.
- A snap-hook back on its integral lanyard.
- Improper dimensions of the D-ring, rebar, or other connection to the snap-hook
dimension.
- Snap-hooks may not be connected to loops made in webbing-type lanyards.
Horizontal lifelines should be limited to two persons at one time between supports.
When vertical lifelines are used, each employee shall be protected by a separate lifeline. The
lifeline shall be properly weighted at the bottom and terminated to preclude a device such as a
rope grab from falling off the line.
All fall-arrest equipment and positioning devices shall be inspected for cuts, cracks, tears or
abrasions, undue stretching, overall deterioration, mildew, operational defects, heat damage, or
acid or any other type of corrosion. Equipment showing any defect will immediately be
withdrawn from service. All fall-arrest equipment will meet all OSHA standards.
All fall-arrest equipment and positioning devices should be stored in a cool dry place which is
not subjected to direct sunlight.
Employees shall not use fall-arrest equipment or positioning devices until they have had training
by a qualified person.
Fall-arrest equipment shall be used on poles by qualified employees when such conditions as
ice, high winds, design of structure, or the presence of contaminants exist that could cause the
employee to lose grip of footing.
The company will conduct prompt investigations should the need arise. A thorough
investigation will be conducted in the event of a fall near miss or other serious incident.
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Section 12: Rigging Equipment Policies
• Rigging equipment shall be sufficient strength, proper type, and safe for its intended use.
• Rigging equipment shall not be loaded beyond its rate working load limit.
• Before every use, all slings, fasteners, and attachments shall be inspected for damage
or defects by a qualified person. Damaged or defective rigging equipment shall
immediately be removed or taken out of service.
• Absolutely no makeshift devices shall be used for rigging equipment.
• Slings shall not be shortened or lengthened with knots bolts or other makeshift devices.
• Slings used in a basket hitch shall have the load balanced to prevent slippage.
• Slings shall be securely attached to the load using hooks with retaining devices or the
use of shackles or another positive latching device.
• Slings shall be padded or protected from the sharp edges of their loads.
• Slings shall be long enough to provide the maximum practical angle between the sling
leg and the horizontal plane of the load.
• Only hooks with approved retaining devices shall be used. Hooks shall never be rigged
so that they are point loaded at the tip of the hook.
• Rigging equipment when not in use shall be removed from the immediate work area.
• Tag lines shall be used when lifting material overhead, or material that can get out of
control.
• Absolutely no employee shall be under a suspended load under any circumstances.
Section 13: Hearing Protection
• Foothills Energy Services employees shall wear hearing protection at all times in posted
areas and when operating air powered tools, air compressors, jackhammers, concrete
cutting saws and when work activities include decibel levels above permissible noise
exposure limits.
• When exposed to noise of 85 dBA (decibels) for more than 8 hours, 88 dBA for more
than 4 hours, 97 dBA for more than 3 hours, 91 dBA for more than 2 hours, 94 dBA for
more than 1.5 hours, 97 dBA for more than .5 hours, or 106 dBA for more than .25
hours, employees must wear appropriate hearing protection.
• Hearing protection shall be inspected daily by the employee and periodically by the
safety personnel. Hearing protection that is defective shall be removed from service and
replaced immediately.
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• If base line audiometric testing is required it will be performed on employees that are
exposed to noise levels that are above the permissible noise exposure limits for an 8
hour weighted average. These tests will be within the first 6 months the employee is
exposed, and after 24 hours without exposure to noise above the permissible limits.
Records of these tests will be maintained and updated by Foothills Energy Services
safety personnel and its support staff.
• Hearing protection will be provided by Foothills Energy Services for employees exposed
to said limits. Hearing protection types provide include; ear plugs, ear muffs, and
molded ear protectors. These protectors shall comply with OSHA standards 29 CFR
1910.95.
• If the noise exposure limits change, or shift in any way, employees will be notified in
writing within 20 days.
• Hearing protection will be evaluated for the specific noise environments in which the
protector will be used.
• Areas where noise exposure limits are at 90 dBA or greater will be posted.
• Yearly training for employees exposed to excessive noise will be conducted by safety
personnel.
• Area dosimetry tests were performed, and the results found that all areas consistently
demonstrated levels below the actionable level.
Section 14: Ladder Safety
• All ladders shall be inspected frequently and regularly. Ladders with weakened, broken
or missing steps, broken side rails, or other defects shall be tagged and removed from
service.
• Ladders shall be sufficiently strong for their intended use. Ladders weight limits shall
never be exceeded.
• Portable metal ladders and other conductive ladders shall not be used in the vicinity of
exposed energized lines and equipment.
• Nonconductive ladders may be used in specialized situations but they must be properly
marked.
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• When ascending or descending ladders, employees shall have both hands free and shall
face the ladder.
• Only one employee shall work from a ladder at one time; if two employees are required
then a second ladder will be used.
• Only Foothills Energy Services-owned ladders shall be used by employees.
• Ladders shall not be used as scaffold platforms, or any other use, which it was not
designed.
• Boxes, chairs, etc., shall not be used as ladders.
• All ladders must be capable of supporting at least 2.5 times the maximum intended load
without failure.
• All extension ladders will be placed against the top support at a ratio of 4:1.
• When working from a portable ladder, the ladder must be securely placed, held, tied or
otherwise made secure to prevent slipping or falling.
• The use of step ladders above 20 feet is prohibited and the use of extension ladders
above 24 feet is strongly discouraged.
• Ladders of all types should never be left in place when the employees leave the work
area for an extended period of time. The ladders should be laid on the ground until the
employee returns to the work area.
• Portable ladders shall not be used without nonskid bases, and not placed against an
unsafe support.
• Straight ladders shall not be climbed beyond the third step from the top.
• When dismounting from a ladder at an elevated position, the employee shall ensure that
the ladder side rails extend at least 3 feet above the dismount position and the hand rails
are present.
• For additional information regarding Foothills Energy’s policy regarding ladder safety
refer to OSHA standards.
Section 15: Electrical Safety
All FESI employees with a job that requires them to work on or near energized circuits or parts
of equipment that have energized parts shall be given the appropriate required training.
Appropriate documented training will ensure proper safe work practices and prevent injuries
including electrical shock, and or, damage to equipment.
• Electrical work “hot work” will only be performed by qualified employees and trainees
under direct supervision.
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• When qualified FESI employees are performing work on or in association with energized
lines at least two (2) trained persons shall be on site and need to be trained in CPR/First
Aid/AED.
• Daily safety briefings will be conducted before any work will begin and all crew members
will be in attendance.
• Daily safety briefings will be documented with signatures of all attendees.
• The person-in-charge will explain what tasks need to be completed and who will
complete them.
• Proper Personal Protective Equipment (PPE) shall be worn by FESI personnel while
engaged in their daily work activities.
• Appropriately rated fire retardant (FR) clothing shall be worn based on specific tasks,
location, or situations Arc rated FR clothing is required if there is arc flash potential
present. It is imperative that all FESI employees recognize that arc-rated FR clothing
may not prevent all burn injuries in the event of an arc flash exposure. This type of
clothing is intended to reduce the amount or degree of injury.
• A minimum of 8 cal/cm shall be worn by all FESI personnel when the potential for an arc
flash exists.
• Conductive apparel, rings, bracelets, watches, etc. shall not be worn unless covered or
rendered non-conductive.
• PPE can insulate workers from the potential hazards of working on or near energized
lines or equipment. PPE including FR clothing, rubber gloves, rubber sleeves, line hose,
rubber blankets, fiberglass covers, and guards.
• Apply flexible line hose or blankets on energized overhead lines or energized parts of
underground cabinets when work is to be done on or near them. Insulated barriers or
shields are applied to the nearest and lowest lines first to protect the worker as they
progress toward the line that is to be worked on. Fiberglass dividers, shields, barriers,
and covers shall be used in underground cabinets to protect workers from energized
parts.
• When not in use protective rubber items should be stored and maintained to ensure they
are not damaged by tools, chemicals, or other outside elements. Rubber items should
be stored in special compartments as to keep them clean and free from damage.
• Rubber protective equipment shall be inspected before each use, after each use, and
following an event that may have caused potential damage.
• Protective rubber items shall be tested in accordance with OSHA/ANSI standards.
• Electrical systems should be considered live and energized until they are tested,
grounded, and proven to be dead.
• Only qualified employees may work on or near exposed energized lines or parts of
energized equipment. Note: an employee who is undergoing training (i.e. apprenticeship
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training) and has demonstrated the ability to do the work safely with direct supervision of
a qualified person, can then perform these duties.
• Qualified employees shall adhere to the Minimum Approach Distance (MAD).
Additionally, all crews shall follow “ground-to-ground”, “cradle-to-cradle, and “lock-to-
lock” when a qualified lineman is working on any structure that has exposed energized
parts.
Minimum approach distances ensure that workers do not approach or take any conductive object closer to the energized parts. If the work is performed at elevations greater than 3,000 ft (900m) above mean sea level, the minimum approach distance must be determined by multiplying the distances by the correction factor corresponding to the altitude at which the work is performed.
Altitude Correction Factor
3,000' (900m) 4,000' (1,200m) 5,000' (1,500m) 6,000' (1,800m) 7,000' (2,100m) 8,000' (2,400m) 9,000' (2,700m) 10,000' (3,000m) 12,000' (3,600m) 14,000' (4,200m) 16,000' (4,800m) 18,000' (5,400m) 20,000' (6,000m)
1.00 1.02 1.05 1.08 1.11 1.14 1.17 1.20 1.25 1.30 1.35 1.39 1.44
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• Ground-to-ground: When a qualified FESI employee is climbing a structure that has
exposed energized parts shall wear appropriately rated rubber gloves and sleeves and
applicable fall protection until they are finished with their task and safely back on the
ground.
• Cradle-to-cradle: When a qualified FESI employee is in an aerial device, i.e. bucket
truck, and will be performing work on or near exposed energized parts they shall wear
the required PPE and rubber gloves and sleeves from the point that the bucket leaves
the landing platform until it returns to its landing platform.
• Lock-to-lock: When a qualified lineman is working on energized underground equipment
the lineman shall wear all appropriate PPE including rubber gloves and rubber sleeves
from when they unlock the equipment until the work is completed and the equipment is
closed and the lock is returned. Rubber gloves and sleeves can be removed when the
energized parts are sufficiently covered or de-energized.
• Vehicles and machinery being operated near energized lines shall remain 10 feet or
more from the energized surfaces.
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• FESI employees are not allowed to enter areas where natural light is not sufficient to
work on energized line or any other work action until temporary lighting is in place.
Only intrinsically safe lighting equipment approved for the hazardous location shall
be used.
Underground T&D General
• Only Qualified and Authorized Persons will perform work on underground transmission or distribution systems.
• Cables shall be treated as Energized until identified and proven to be De-energized, tested and Grounded.
• Work procedures shall be inclusive of ET&D Partnership Best Practices.
• Management shall develop and implement a Site-Specific Task Plan for work tasks involving cables containing lead or asbestos.
• Employees shall receive the proper training and certification prior to working on asbestos or lead-sheathed cable.
• Exposed Energized cables in excavations or vaults that are not to be worked on shall be covered (Insulated) and protected to prevent accidental contact or damage. Blast- suppression blankets may be necessary in certain environments.
• Barriers, barricades or Isolating materials shall be installed to prevent employees from encroaching on the M.A.D. to Exposed Energized equipment.
• Employees carrying, moving or transporting materials shall always maintain appropriate clearances from Energized parts.
• When two or more employees are working on Energized circuits or equipment and within reach of each other, only one phase shall be worked at a time.
• When removing animals, weeds, vines, grass, vegetation or other materials from any underground equipment, the employee shall:
• Don rubber insulating protective gloves and sleeves; or
• Use approved live-line tools.
• Rubber insulating protective gloves and sleeves shall be worn when opening and closing the doors of Energized equipment.
• Visible door hinges of each enclosure shall be checked for damage prior to opening. Both hands shall be used to keep positive control of the enclosure. Doors with blocking devices incorporated shall be blocked to prevent the door from closing.
• All required PPE shall be donned prior to the start of work.
• FR garments shall have the appropriate arc rating for the anticipated exposure:
• Full body FR garment(s) is required;
• Insulated gloves and sleeves with protectors are considered arc rated;
• Heavy-duty work shoes or boots are considered arc rate and;
• Hard hats ANSI/SEA 87.1-2009 Type I Class E are also considered arc rated.
• Equipotential zones (EPZ) will be established for the protection of employees where possible.
• The Job Briefing shall identify any back-feed potential.
• Prior to opening equipment, if windows are present, check the position of the switch blades.
Switching Procedures • Customer switching procedures shall be adhered to.
• Prior to re-closing any circuits, the Person-In-Charge shall ensure the following occurs:
• Inspect the circuit;
• All grounds removed and;
• Personnel and public are clear of the circuit.
• Prior to opening circuits, the Person-in-Charge shall ensure the following occurs:
• Non-load rated switches shall require the use of an appropriately rated load-break tool;
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• Opening of jumpers shall require an amperage measurement and safeguards to prevent an arc flash;
• Live-line tools shall be used for switching operations. • LOTO and PPE requirements shall be followed when operating hand-operated switching
controls.
• Employees shall maintain a safe distance from view ports, hinged doors, and blast chutes during switching operations.
De-energized Work Rules • Prior to working on De-energized equipment, the Person-In-Charge shall ensure:
• Customer switching, tagging and line-clearance rules are implemented.
• The line or circuit has been tested, Grounded and EPZ has been established.
• Before working on a primary cable in a trench or a pull box containing more than one primary circuit:
• Positively identify the cable to be worked on by utilizing a phase-pulse indicator or similar tool.
• Appropriate PPE shall be worn if contact could be made with Energized jacketed cable.
• After the cable to be worked has been identified, the cables not being worked may be re-energized after safeguards are provided to protect the employees and the Energized cables from inadvertent damage (e.g., Insulate or Isolate the cables).
• Cables to be worked on shall be Grounded at points as close to the work area as possible.
• Concentric cables shall have the neutral/shield Bonded to the Grounded conductor prior to working on the conductor to dissipate the capacitive charge.
• Prior to performing work on a Grounded cable, the cable shall be tested and then spiked to ensure it is De-energized.
• Employees shall be removed from the spiking location. Employees shall not remain in vaults, trenches, or underground locations during spiking operations.
• Spiking operations shall only be performed with the appropriate live-line spiking tool and the cable shall be Grounded on each side of the work location prior to spiking.
• Spiking devices shall be connected with a hot stick and shall be operated remotely by a hot stick or hydraulic-powered means. Spiking devices shall never be applied or operated without the proper live-line tools.
Energized Work Rules • All employees must maintain a minimum of five (5) feet of clearance from all open cabinets.
Employees encroaching within the five (5) feet clearance limitation shall have all appropriate PPE donned.
• NOTE: • The five foot distance is an administrative demarcation arc around open cabinets or
enclosures required by the ET&D Best Practices. • Employees shall only be in contact with one phase at any time.
• Energized underground conductors or equipment shall never be handled by hand without appropriate PPE.
• Elbows shall only be moved with hot sticks and with extreme caution. Switch cabinets, pad-mount transformers and other Energized equipment that are open shall have a qualified attendant at all times.
URD Circuits • Prior to performing work on a Grounded cable, the cable shall be tested and then spiked to
ensure it is De-energized and Grounded.
• Employees shall be removed from the spiking location. Employees shall not remain in vaults, trenches, or underground locations during spiking operations.
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• Spiking operations shall only be performed with the appropriate live-line spiking tool and the cable shall be Grounded on each side of the work location prior to spiking.
• Spiking devices shall be connected with a hot stick and shall be operated remotely by a hot stick or hydraulic-powered means. Spiking devices shall never be applied or operated without the proper live-line tools.
Pulling Cables • Employees shall perform visual inspections of all equipment to ensure equipment is properly
rated (WLL) for the pull.
• Employees shall be positioned in locations “out of the bite” and at safe distances from rigging and pulling equipment in anticipation of failure of any component.
• Conductive pulling equipment shall not be pushed, blown or pulled by vacuum into ducts or energized areas where contact with Energized lines or equipment may occur unless all Energized parts are securely covered by proper IPE.
• Employees shall not remain in vaults or enclosures on the pulling end during the pulling operation.
Directional Boring • Prior to directional drilling, Management and Safety shall develop and implement a Site-
Specific Task Plan.
• Operators, tenders and other employees shall be Qualified and Authorized for the specific equipment.
Pot Holing • Prior to hydro pot-holing, Management and Safety shall develop and implement a Site-
Specific Task Plan.
• All pot-holing activities will be performed by Qualified and Authorized Persons.
• Pot-holing for utilities is required when excavating under, over, near or adjacent to existing utilities.
• All utility-locate procedures shall comply with local area rules. (Reference state or local mandates.)
• Employees pot-holing near Energized electrical cables shall wear rubber insulating protective gloves and dielectric boots rated for the phase-to-phase voltage.
Substations General
• Only Qualified and Authorized Persons shall perform work in substations.
• The Person-In-Charge shall ensure personnel entering or leaving a supervisory-controlled substation notify the Customer representative. Customer requirements for FR clothing must be adhered to.
• Work procedures shall be inclusive of ET&D Partnership Best Practices.
• Employees shall maintain appropriate M.A.D. from Energized bays and equipment.
• Management or the Person-In-Charge shall obtain permission from the Customer representative prior to parking or driving into substation yards.
• Gates shall be locked when substations are unattended.
• Conductive fencing and temporary conductive fencing shall be bonded to the Grounding grid. Equipment parked inside energized substations overnight should be bonded to a ground source.
• Temporary perimeter fencing shall have the same warning signs as a permanent perimeter fence.
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• Employees shall not work below other employees unless the task requires employees to be below other employees. When this is required, the following shall be completed:
• Employees shall communicate the work plan, and
• Communication methods to warn employees of falling objects shall be identified and implemented.
• Bussing, lines, conductors and equipment shall be considered as Energized unless tested, Grounded and EPZ is established.
• Employees carrying or moving materials in an Energized yard shall ensure:
• M.A.D. is not encroached; • Safe travel paths are identified; and
• Lengthy objects shall either be handled below the shoulders or handled by a person on each end.
• Employees shall only climb on structures or equipment that is stable, secured and capable of supporting the total weight of the employee, tools and material.
• Storage trailers, support equipment and material shall be stored in areas that do not interfere with ingress, egress, bussing or the structures.
• Storage trailers placed in Energized yards shall be Bonded to the Grounding grid.
• Spotters are required for any vehicle traveling in an Energized section of a substation.
• Flammable liquids shall be stored in an NFPA approved storage container or cabinet in areas away from Energized equipment.
• Management shall develop and implement a Site-Specific Task Plan when working on hydrogen or nitrogen filled equipment.
• Employees shall not intentionally drop items to the ground or throw items to elevated employees.
• Hand lines shall be utilized for the hoisting and lowering of tools and materials. Small or loose materials shall be contained in a tool bag.
• Scrap materials are permitted to be dropped to the ground in a designated area and personnel shall be removed from the area.
• Breakers shall be Grounded on both sides.
• If one side is not part of the clearance, that side shall be identified as Energized and properly barricaded or Isolated.
• Back-feed potential shall be ascertained for all work tasks.
• Newly installed substation equipment shall be Isolated from the existing substation equipment and not connected until the final phase of construction.
• Newly installed ground grid shall be Isolated from the existing grid and not connected until the final phase of construction.
• Motor-operated devices within the clearance shall be disabled and rendered inoperative.
• The Person-in-Charge shall ensure the crew members are aware of the grounding plan, Energized sections, locations of PPG and identifying the breakers or switches that shutdown or Isolate the work area.
• Bonds are required prior to making any modifications to the ground grid which could create a difference in potential.
Section 16: Hand Tools
• All tools, regardless of ownership, shall be of an approved type and maintained in
good condition. Tools are subject to inspection at any time. A foreman has the
authority and responsibility to condemn unserviceable tools, regardless of ownership.
• Defective tools shall be tagged to prevent their use, and they shall be removed from
the jobsite.
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• Employees shall always use the proper tool for the job performed. Substitute tools
shall only be used with proper authorization and under supervision.
• Hammers with metal handles, screwdrivers or knives with metal continuing through
the handle and metallic measuring tapes shall not be used on or near energized
electrical circuits or equipment.
• Tools shall never be place unsecured on elevated places.
• As impact tools such as punches, chisels, etc., become cracked, they shall be
dressed, repaired, or replaced before use continues.
• Drills, Chisels, punches pipes or ground rods shall be held with suitable holder or
tongs (not with hands) while being struck by another employee.
• Wrenches with sprung or damaged jaws shall not be used.
• Tools with sharp edges shall be stored and handled so that they will not cause injury.
Wooden handles that are loose, cracked or splintered shall be replaced no repaired.
• All cutting tools such as saws, wood chisels. Drawknives of axes shall be kept in
suitable guards or in special compartments.
• Tools shall not be left lying around where they may cause a person to trip or
stumble.
• The insulation of hand tools shall not be depended up on to protect users from
shock.
General Tools
▪ Powered tools shall only be operated, repaired or maintained by Qualified, Competent, and Authorized Persons.
▪ Tools shall be kept in good condition, inspected and maintained. ▪ Tool guards shall be inspected prior to use. ▪ Broken, damaged or faulty tools shall be tagged Out Of Service and removed from service
until repaired, inspected and tested. ▪ Portable powered tools (air, electric, hydraulic and fuel) shall have a constant pressure switch
that turns the tool off when released. ▪ Tool implements (drill bits, dies, saw blades, etc.) shall only be changed or replaced while the
tool is disconnected from the power source. ▪ Implements shall be properly rated for the speed and type of material. ▪ Guards shall be installed while the tool is in use. ▪ Tools shall not be issued or supplied in a defective condition. ▪ Hoses or electric cords shall not be used to raise or lower tools. ▪ Tools shall be stored in designated locations and per manufacturer guidelines. ▪ Tools shall only be used for their intended purpose (e.g., using a screw driver as a chisel,
using your hand as a hammer is not the intended purpose). ▪ Non-sparking tools shall be provided in areas where flammable atmospheres are present. ▪ Employees shall don all required PPE as identified by the manufacturer or the company prior
to tool operation.
Personal Tools
• Personal tools shall be inspected prior to use and maintained per the manufacturer’s specification.
• Defective personal tools shall be tagged Out Of Service and removed from service.
Fuel (Gas, Diesel) Powered Tools
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• Fuel-powered tools shall be used in well-ventilated areas.
• Fuel-powered tools shall not be operated in basements, inside of buildings, Confined Spaces or Enclosed Spaces without exhausting outside the work area, and adequate ventilation inside the work area.
• Employees shall have adequate ventilation while operating fuel powered tools.
• Fuel-powered tools shall be shut off during refueling, servicing or maintenance.
• Fuel-powered tools shall have fire extinguishing equipment readily available as identified by the Job Briefing.
Powder Actuated Tools • Only Qualified and Authorized Persons shall use powder-actuated tools.
• Appropriate PPE shall be donned prior to operating powder-actuated tools.
• Loaded tools shall not be left unattended and only loaded prior to use.
• Cartridges, used or misfired shall be disposed of properly.
• Shells, unused cartridges and power cartridges shall be stored properly in secured areas.
• Powder-actuated tools shall not be pointed at anyone.
• Powder-actuated tools shall be inspected prior to use and to ensure the tool is in proper operating condition.
Electric Powered Tools • Electric-powered tools shall not be used if there is damage to the electrical cord,
sheathing, insulation, or strain relief.
• Electric-powered tools shall be powered by round three-wire cords or be double insulated.
• Electric-powered tools shall have the proper supply sources and overcurrent protection. • Electric-powered tools shall have all attachments firmly secured, seated or affixed.
• Stand-based pipe threading machines shall have foot controls.
Chop, Demolition and Concrete Saws • Operators shall inspect the machine and attachments prior to use.
• Operators of chop saws and concrete saws shall wear appropriate PPE.
• Operators of demolition saws shall wear appropriate hearing protection, face protection, eye protection and leg protection.
• The RPM rating of the cutting disc or blade shall exceed the rated RPM of the saw.
• Blade rotation shall match the rotation of the power unit.
• The blade shall be properly installed and secured.
• When cutting concrete or masonry, wet methods shall be implemented where feasible. Dry cutting shall require the use of adequate ventilation and appropriate respiratory protection.
Air Compressors and Pneumatic Tools • Compressed air exceeding thirty (30) p.s.i. shall not be used to remove debris from
employees or clothing.
• Air tanks shall be drained daily of accumulated liquid.
• Air pressure shall be cut off from tools prior to disconnection.
• Cold climates require proper maintenance to prevent freeze-up.
• Hoses shall not be exposed to burning, crushing, solvents or other harmful substances.
• Hose couplings shall be secured with an approved pin or whip-check device.
• Hoses shall be repaired using a compression crimp method. (Water hose clamps are not mitted).
• Pressure-relief valves (safety valves) shall be checked periodically. • Rated operating pressures shall not be exceeded.
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Hydraulic Powered Tools • Only Qualified and Authorized Persons shall operate hydraulic powered tools.
• Hydraulic-powered tools shall have approved fluids per the manufacturer’s specifications.
• Fluid levels shall be checked to ensure proper operation.
• Manufacturer’s recommended operating pressures shall not be exceeded.
• Hydraulic-powered tools used on Energized equipment shall have non-conductive hoses.
• Couplings shall be inspected to ensure they are seated and connected.
• Couplings shall have covers (caps) installed when not in use to keep connections clean and free of contaminants or damage.
• Hydraulic-powered tools shall be designated for the type of system to which they are designed.
Hand Tools • Hand tools shall be used for the intended purpose.
• Hand tools shall have proper handles for use.
• Impact tools shall be kept free of mushroomed heads. (e.g., chisels, punches)
• Cheaters or extensions shall not be used on hand tools unless the tool is designed for the purpose.
• Conduit benders shall only be used for bending conduit.
• Operators shall be aware of and avoid pinch points when using hand tools.
Chain Saws • Only Qualified and Authorized Persons shall operate chain saws.
• When employees are working from the pole, a Site Specific Task Plan shall be implemented and reviewed by Management and Safety.
• Operators of chain saws shall wear appropriate PPE to include face, eye, hand, and leg protection.
• Leg protection is not required when working from the bucket.
• Anti-kickback devices shall be in place and operational.
• Employees shall maintain a safe distance from the operator and saw while the tool is in use.
• Guards shall be maintained in place and operational during operation.
Arc Welders Electric or Fuel Powered
• Only Qualified and Authorized Persons shall use electric arc welders.
• Leads, stingers and connectors shall be properly maintained.
• Cables connected to the rod holder end (stinger) shall be free of damage.
• Welding operations shall have appropriate barriers to protect personnel from the arc.
• Current carrying parts shall be properly insulated.
• Grounding cables shall be properly attached as close as possible to the welding location.
• When unattended, the electrode shall be removed from the holder (stinger).
Fixed Machinery • Fixed machinery shall only be operated by Qualified and Authorized Persons.
• Machines not designed for continuous operation shall be shut off when unattended or when work is complete.
• Exposed rotating parts of machinery shall be guarded.
• Point-of-operation guarding shall be installed and operational.
• Machinery shall be hard-wired; temporary wiring is not permitted.
• Operators shall wear appropriate PPE for the machinery.
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• Implement (bits, blades, etc) replacements or machinery repairs shall require proper lockout/tagout procedures.
Jacks and Jack Stands • Jacks and jack stands shall not be loaded beyond their rated capacity.
• Jacks shall be centered under the load and blocks or jack stands shall be placed under the load.
• Jacks and jack stands shall be inspected prior to each use and when subjected to shock or impact.
• Jacks and jack stands shall be supported when placed on uneven or soft ground.
• Blocking or jack stands shall be installed when employees work under a load.
• Jacks used in freezing weather shall have appropriate fluids.
Grinders
• Face shields with safety glasses or goggles shall be donned when operating grinders.
• Grinding discs shall be visually inspected prior to each use.
• Guards shall be in place and operational.
• Handles shall be in place and operational.
• Grinding disks that have been dropped, acquired moisture or stored improperly shall not be used.
• Manufacturer-supplied guards shall be in place and operational.
• The RPM rating of the disc shall exceed the RPM of the grinder.
• Employees shall not stand in front of a grinder when it is started.
• Grinders shall not be used on soft materials (wood, copper, brass).
• Personnel shall be kept away from the spark trail. • A ring test shall be performed
Bench Grinders • Work rests shall be kept adjusted closely to the wheel with a maximum opening of one-
eighth (⅛) inch.
• Tongue-guard openings shall be adjusted to one-quarter (¼) inch.
• Spark guards shall be installed and maintained as specified by the manufacturer.
• Shields shall be installed and maintained as secondary protection for the face and eyes.
• Bench grinders shall be permanently affixed to a stable surface.
Hoists and Come-Alongs • Hoists and come-alongs shall be legibly identified with the maximum capacity.
• Cables, chains or straps of the hoist or come-along shall not be wrapped around a load. Proper rigging shall be used to secure the load.
• Employees shall use hoists and come-alongs in accordance with the manufacturer’s recommendations.
• Hoists and come-alongs shall be inspected prior to use.
• Hoists and come-alongs shall be attached to anchorages rated at or greater than the rating of the load or hoist.
• Hoists with nylon straps designed for support of Energized conductors shall be Isolated from the structure.
Power Tools • The non-current metal parts of portable electric tools such as drills, saws, and grinder
shall be effectively grounded when connected to a power source unless:
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The tool is an approved double-insulated type, or The tool is connected to the power supply by means of an isolating transformer or other isolated power supply, such as a 24-V dc system.
• All powered tools shall be examined before use to ensure general serviceability and the presence of all applicable safety devices. The electric cord and electric components shall be given an especially thorough examination.
• Power tools shall be used only within their capability and shall be operated in accordance with the instructions of the manufacturer.
• All tools shall be kept in good repair and shall be disconnected from the poser source while repairs are being made.
• Electrical tools shall not be used where there is a hazard of flammable vapors, gases or dusts.
• Tools connected to a central power supply, including portable and vehicle-mounted generators (not isolated) and not double-insulated shall be protected by a Ground Fault Circuit interrupter (GFCI) or by an assured ground system.
• Any cord and plug-connected equipment supplied by other than premises wiring shall comply with one of the following:
1. Equipped with a cord containing an equipment-grounding conductor connected to the tool frame.
2. Double insulated. 3. Connected to power supply through an isolating transformer with an ungrounded
secondary.
Section 17: Material Handling and Storage
• An employee shall obtain assistance in lifting heavy objects or use heavy equipment.
• When two or more persons carry a heavy object that is to be lowered or dropped, there shall be a prearranged signal for releasing the load.
• When two or more persons are carrying an object, each employee, if possible, should face the direction in which the object is being carried. Employees shall not attempt to lift beyond their capacity. Caution shall be taken when lifting or pulling in an awkward position. The right way to lift is easiest and safest. Crouch or squat with the feet close to the object to be lifted; secure good footing; take a firm grip; bend the knees; keep the back vertical; and lift by bending at the knees and using the leg and thigh muscles.
• Employees should avoid twisting or excessive bending when lifting or setting sown loads.
• When moving a load horizontally, employees should push the load rather than pull it.
• When performing a task that requires repetitive lifting, the load should be positioned to limit bending and twisting. The use of lift tables, pallets, and mechanical devices should be considered.
• When gripping, grasping, or lifting an object such as a pipe or board, the whole hand and all the fingers should be used. Gripping, grasping and lifting with just the thumb and index finger should be avoided.
• In areas not restricted to qualified employees only, materials and equipment may not be stored closer to energized lines or exposed energized parts of equipment than the following distances plus the maximum sag and side swag swing of all conductors.
1. For lines and equipment energized at 50kv or less, the distance is 10 feet.
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2. For lines and equipment energized at more than 50kv, the distance is 10 feet plus 4 inches for every 10kv over 50kv.
• Materials stored near energized lines or equipment must meet the spacing requirements of OSHA Standard 29 CFR 1910.269(k).
Section 18: DOT Drug and Alcohol Policy
Policy
Foothills Energy Services, Inc. is dedicated to the health and safety of our drivers. Drug and/or
alcohol use may pose a serious threat to the driver health and safety. Therefore, it is the policy
of FESI to prevent the use of drugs and abuse of alcohol from having an adverse effect on our
drivers.
The federal government has recognized the serious impact of drug use and alcohol abuse. The
Federal Motor Carrier Safety Administration (FMCSA) has issued regulations which require the
company to implement an alcohol and controlled substances testing program.
The purpose of the FMCSA-issued regulations is to establish programs designed to help
prevent accidents and injuries resulting from the misuse of alcohol or use of controlled
substances by drivers of commercial motor vehicles.
The company will comply with these regulations and is committed to maintaining a drug-free
workplace.
It is the policy of FESI that the use, sale, purchase, transfer, possession, or presence in one’s
system of any controlled substance (except medically prescribed drugs) by any driver while on
the company premises, engaged in company business, operating company equipment or while
the authority of FESI is strictly prohibited. Disciplinary action will be taken as necessary.
Neither this policy nor any of its terms are intended to create a contract of employment or
contain the terms of any contract or employment. The company retains the sole right to change,
amend, or modify any term or provision of this policy without notice. This policy is effective
January 1, 2016 and will supersede all prior policies and statements relating to alcohol and
drugs.
Responsibility
In accordance with 49 CFR 382.601 (a), each employer shall provide educational materials that
explain the requirements in Part 382 and the employer’s policies and procedures with respect to
meeting these requirements. The employers shall ensure that a copy of these materials is
distributed to each driver prior to the start of alcohol and controlled substances testing under
this part and to driver subsequently hired or transferred into a safety-sensitive function (i.e.,
operating a commercial motor vehicle as defined in 382.107 requiring a CDL).
Each driver hired or transferring into a safety sensitive function is responsible for reviewing the
content of the information presented to drivers. Each driver is responsible for asking questions
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about the procedures if the content is unclear to him/her. Drivers may pose follow-up questions
about the content of this policy and procedures to Designated Employer Representative (DER).
Drug and Alcohol Procedures
Regulatory Requirements
All drivers who operate commercial motor vehicles that require a commercial driver’s license
under 49 CFR Part 383 are subject to the FMCSA’s drug and alcohol regulations, 49 CFR Part
382.
Non-Regulatory Requirements
The Federal Motor Carrier Safety Regulations (FMCSRs) set the minimum requirements for
testing. The company’s policy in certain instances may be more stringent. This policy will
clearly define what is mandated by the FMCSRs and what company procedure is.
Who is Responsible
It is the company’s responsibility to provide testing for the driver that is in compliance with all
federal and state laws and regulations, and within the provisions of this policy.
The company will retain all records related to testing and the testing process in a secure and
confidential manner. FESI’s alcohol and drug program administrator who is designated to
monitor, facilitate, and answer questions pertaining to these procedures is:
Kayla Marr 4042 Kelty Rd PO Box 603 Franktown, CO 80116 303-660-0105 303-901-7170 (Cell)
The driver is responsible for complying with the requirements set forth in this policy. The driver
will not use, have possession of, abuse, or have the presence of alcohol or any controlled
substance more than regulation-established threshold levels while on duty. The driver will not
use alcohol within 4 hours of performing a “safety-sensitive” function. The driver must submit to
alcohol and controlled substances tests administered under Part 382.
All supervisors must make every effort to be aware of a driver’s condition when the driver is in
service of the company. The supervisor must be able to make reasonable suspicion
observations to determine if the driver is impaired in some way and be prepared to implement
the requirements of this policy if necessary.
Definitions
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When implementing and interpreting the drug and alcohol policies and procedures required by
the FMCSA, as well as the policies and procedures required by the company, the following
definitions apply:
Actual knowledge means actual knowledge by an employer that a driver has used alcohol or
controlled substances based on the employers direct observation of the driver, information
provided by the driver’s previous employer(s), a traffic citation for driving a Commercial Motor
Vehicle while under the influence of alcohol or a controlled substance, or a driver’s admission of
alcohol or controlled substance use under the provisions of Sec. 382.121. Direct observation as
used in this definition means observation of alcohol or controlled substance use and does not
include observation of driver or physical characteristics sufficient to warrant reasonable
suspicion testing under Sec. 382.307.
Adulterated specimen means a specimen that has been altered, as evidenced by test results
showing either a substance that is not a normal constituent for that type of specimen or showing
an abnormal concentration of an endogenous substance.
Alcohol means the intoxicating agent in beverage alcohol, ethyl alcohol, or other low molecular
weight alcohols including methyl and isopropyl alcohol.
Alcohol concentration (or content) means the alcohol in a volume of breath expressed in terms
of grams of alcohol per 210 liters of breath as indicated by an evidential breath test.
Alcohol screening device (ASD) means a breath or saliva device, other than an evidential breath
testing device (EBT) that is approved by the National Highway Traffic Safety Administration
(NHTSA) and placed on a conforming products list (CPL) for such devices.
Alcohol use means the consumption of any beverage, liquid mixture, or preparation including
any medication, containing alcohol.
Aliquot means a fraction part of a specimen used for testing. It is taken as a sample
representing the whole specimen.
Breath Alcohol Technician (BAT) means an individual who instructs and assists individuals in
the alcohol testing process and operates and evidential breath testing device (EBT).
Collection Site means a place designated by the employer where individuals present
themselves for providing a specimen of their urine to be analyzed for the presence of controlled
substances.
Commercial motor vehicle (CMV) A motor vehicle or combination of motor vehicles used in
commerce to transport passengers or property if the motor vehicle
• Has a gross combination weight rating (GCWR) of 11,794 kilograms or more (26,001
pounds or more) inclusive of a towed unit, with a gross vehicle weight rating (GVWR) of
more than 4,536 kilograms (10,000 pounds); or
• Has a GVWR of 11,794 kilograms or more (26,001 pounds or more); or
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• Is designed to transport 16 or more passengers, including the driver; or
• Is of any size and is used in the transportation of materials found to be hazardous for the
purposes of the Hazardous Materials Transportation Act and is required to be placarded
under the Hazardous Materials regulations (49 CFR part 172, subpart F).
Confirmatory drug test means a second analytical procedure to identify the presence of a
specific drug or metabolite which is independent of the initial test and which used a different
technique and chemical chromatography/mass spectrometry (GC/MS) is the only authorized
confirmation method for cocaine, marijuana, opiates, amphetamines, and phencyclidine)
Confirmatory validity test means a second test performed on a different aliquot of the original
urine specimen to further support a validity test result.
Consortium/Third Party Administrator (C/TPA) means a service agent that provides or
coordinates one or more drug and/or alcohol testing services to DOT-regulated employers.
C/TPAs typically provide or coordinate the provision of a number of such services and perform
administrative tasks concerning the operation of the employers’ drug and alcohol testing
programs. This term includes, but is not limited to, groups of employers that join together to
administer, as a single entity, the DOT drug and alcohol testing programs of its members (e.g.,
having a combined random testing pool). C/TPAs are not employers under the rules.
Controlled substances mean those substances identified in section 40.85. In accordance with
FMCSA rules, urinalyses will be conducted to detect the presence of the following substances:
• Marijuana metabolites.
• Cocaine metabolites.
• Amphetamines.
• Opiate metabolites.
• Phencyclidine (PCP).
Detection levels requiring a determination of a positive result shall be in accordance with the
guidelines adopted by FMCSA in accordance with the requirements established in 49 CFR,
section 40.87.
Initial test
analyte
Initial test
cutoff
concentratio
n
Confirmatory
test analyte
Confirmatory
test cutoff
concentration
Marijuana
metabolites
50 ng/mL THCA1 15 ng/mL
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Cocaine
metabolites
150 ng/mL Benzoylecgonin
e
100 ng/mL
Opiate
metabolites
Codeine/Morphin
e2
2000 ng/mL Codeine 2000 ng/mL
Morphine 2000 ng/mL
6-Acetylmorphine 10 ng/mL 6-
Acetylmorphine
10 ng/mL
Phencyclidine 25 ng/mL Phencyclidine 25 ng/mL
Amphetamines3
AMP/MAMP4 500 ng/mL Amphetamine 250 ng/mL
Methamphetami
ne5
250 ng/mL
MDMA6 500 ng/mL MDMA 250 ng/mL
MDA7 250 ng/mL
MDEA8 250 ng/mL
• Delta-9-tetrahydrocannabinol-9-carboxylic acid (THCA).
• Morphine is the target analyte for codeine/morphine testing.
• Either a single initial test kit or multiple initial test kits may be used provided the single
test kit detects each target analyte independently at the specified cutoff.
• Methamphetamine is the target analyte for amphetamine/methamphetamine testing.
• To be reported positive for methamphetamine, a specimen must also contain
amphetamine at a concentration equal to or greater than 100 ng/mL.
• Methylenedioxymethamphetamine (MDMA).
• Methylenedioxyamphetamine (MDA).
• Methylenedioxyethyalamphetamine (MDEA).
Designated Employer Representative (DER) means an individual identified by the employer as
able to receive communications and test results from service agents and who is authorized to
take immediate actions to remove employees from safety-sensitive duties and to make required
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decisions in the testing and evaluation processes. The individual must be an employee of the
company. Service agents cannot serve as DERs.
Dilute specimen means a specimen with creatinine and specific gravity values that are lower
than expected for human urine.
Direct observation means the observer must request the employee to raise his or her shirt,
blouse, or dress/skirt, as appropriate, above the waist; and lower clothing and underpants to
show, by turning around, that he/she does not have prosthetic device. After observer has
determined that the employee does not have such a device, he/she may permit the employee to
return clothing to its proper position for observation urination.
Disabling damage means damage that precludes departure of a motor vehicle from the scene of
the accident in its usual manner in daylight after simple repair.
• Inclusions. Damage to motor vehicles that could have been driven, but would have been
further damaged if so driven.
• Exclusions.
o Damage which can be remedied temporarily at the scene of the accident without
special tools or parts.
o Tire disablement without other damage, even if no spare tire is available.
o Headlamp or tail lamp damage.
o Damage to turn signals, horn, or windshield wipers that make them inoperative.
Driver means any person (volunteer or paid) who operates a commercial motor vehicle
and is required to have a CDL. This includes, but is not limited to:
• Full-time, regularly employed drivers
• Leased drivers
• Independent owner-operator contractors (employed directly or leased)
• Casual, intermittent, or occasional drivers.
Drug means any substance (other than alcohol) that is a controlled substance as
defined in this policy and 49 CFR Part 40.
Evidential Breath testing device (EBT) means a device approved by the National
Highway Traffic Safety Administration (NHTSA) for the evidential testing of breath at the
0.02 and 0.04 alcohol concentrations, placed on NHTSA’s conforming products list
(CPL) for “Evidential Breath Measurement Devices” and identified on the CPL as
conforming with the model specifications available from NHTSA’s Traffic Safety
Program.
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FMCSA means Federal Motor Carrier Safety Administration, U.S. Department of
Transportation.
Initial Drug Test (also known as a “Screening drug test”) means the test used to
differentiate a negative specimen from one that requires further testing for drugs or drug
metabolites.
Invalid result means the result reported by an HHS-certified laboratory in accordance
with the criteria established by HHS Mandatory Guidelines when a positive, negative,
adulterated or substituted result cannot be established from a specific drug or specimen
validity test.
Laboratory means any U.S. laboratory certified by HHS under the National Laboratory
Certification program as meeting the minimum standards of Subpart C of the HHS
Mandatory Guidelines for Federal Workplace Drug Testing Programs; or, in the case of
foreign laboratories approved for participation by DOT under Part 40.
Licensed medical practitioner means a person who is licensed, certified, and/or
registered, in accordance with applicable federal, state, local, or foreign laws, to
prescribe controlled substances and other drugs.
Medical Review Officer (MRO) A licensed physician (Doctor of Medicine or Osteopathy)
responsible for receiving laboratory results generated by an employer’s controlled
substances testing program, who has knowledge of substance abuse disorders and has
appropriate medical training to interpret and evaluate an individual’s confirmed positive
test results together with his or her medical history and any other relevant biomedical
information.
Negative Result means the result reported by an HHS-certified laboratory to an MRO
when a specimen contains no drug or the concentration of the drug is less than the
cutoff concentration for the drug or drug class and the specimen is a valid specimen.
Non-negative specimen means a urine specimen that is reported as adulterated,
substituted, positive (for drug(s) or drug metabolite(s)), and/or invalid.
Oxidizing adulterant means a substance that acts alone or in combination with other
substances to oxidize drugs or drug metabolites to prevent the detection of the drug or
drug metabolites, or affects the reagents in either the initial or confirmatory drug test.
Performing (a safety-sensitive function) means a driver is considered to be performing a
safety-sensitive function during any period in which he/she is actually performing, ready
to perform, or immediately available to perform any safety-sensitive functions.
Positive result means the result reported by an HHS-certified laboratory when a
specimen contains a drug or drug metabolite equal to or greater than the cutoff
concentrations.
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Prescription medications means the use (by a driver) of legally prescribed medication
issued by a licensed health care professional familiar with the driver’s work related
responsibilities.
Refusal to submit to an alcohol or controlled substances test means that a driver:
• Fails to appear for any test (except pre-employment) within a reasonable time,
as determined by the company, consistent with applicable DOT regulations,
after being directed to do so by the company. This includes the failure of a
driver (including an owner-operator) to appear for a test when called by a
C/TPA;
• Fails to remain at the testing site until the testing is complete (except pre-
employment if the driver leaves before the testing process begins);
• Fails to provide a urine specimen for any DOT required drug test (except pre-
employment if the driver leaves before the testing process begins);
• In the case of a directly observed or monitored collection in a drug test, fails to
permit the observation or monitoring of the driver’s provision of the specimen;
• Fails to provide a sufficient amount of urine when directed, and it has been
determined through a required medical evaluation, that there was no adequate
medical explanation for the failure;
• Fails or declines to take a second test the employer or collector has directed the
driver to take;
• Fails to undergo a medical examination or evaluation, as directed by the MRO
as part of the verification process, or as directed by the DER (in the case of pre-
employment drug test, the employee is deemed to have refuse to test on this
basis only if the pre-employment test is conducted following a contingent offer of
employment);
• Fails to cooperate with any part of the testing process (e.g., refuse to empty
pockets when directed by the collector, behave in confrontational way that
disrupts the collection process, fail to wash hands after being directed to do so
by the collector);
• For an observed collection, fails to follow the observer’s instructions to raise
his/her clothing above the waist, lower clothing and underpants, and to turn
around to permit the observer to determine if he/she has any type of prosthetic
or other device that could be used to interfere with the collection process.
• Possesses or wears a prosthetic or other device that could be used to interfere
with the collection process.
• Admits to the collector or MRO that he/she adulterated or substituted the
specimen.
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• Is reported by the MRO as having a verified adulterated or substituted test
result.
Safety-sensitive function means all time from the time a driver begins to work or is required to be
readiness to work until the time he/she is relieved from work and all responsibility for performing
work.
Safety-Sensitive Functions include:
• All time at a carrier or shipper plant, terminal, facility, or other property, or on any public
property, waiting to be dispatched, unless the driver has been relieved from duty by the
employer. This includes employees who are “eligible” at work to drive a CMV at anytime,
e.g., salespersons, clerks, secretaries, supervisors.
• All time inspecting equipment as required by section 392.7, “Equipment, Inspection, and
Use,” and section 392.8, “Emergency Equipment and Use,” or otherwise inspecting,
servicing, or conditioning any CMV at any time.
• All driving time, which is any time spent at the driving controls of a CMV in operation.
• All time, other than driving time, in or upon any CMV except time spent resting in a sleeper
berth.
• All time loading or unloading a vehicle, supervising or assisting in loading or unloading,
attending a vehicle being loaded or unloaded, remaining ready to operate the vehicle, or
giving or receiving receipts for shipments loaded or unloaded.
• All time repairing, obtaining assistance for, or remaining with a disabled vehicle.
Screening test technician (STT) is a person who instructs and assists employees in the alcohol
testing process and operates and alcohol screening device (ASD).
Split specimen collection means a collection in which the urine collected is divided into two
separate specimen bottles, the primary specimen (Bottle A) and the split specimen (Bottle B).
Stand-Down means the practice of temporarily removing an employee from the performance of
safety-sensitive functions based only on a report from a laboratory to the medical review officer
(MRO) of a confirmed positive test, an adulterated test, or a substituted test, before the MRO has
completed verification of the test results.
Substance Abuse Professional (SAP) is a person who evaluates employees who have violated a
DOT drug and alcohol regulation and makes recommendations concerning education, treatment,
follow-up testing and aftercare.
A Substance Abuse Professional (SAP) must be:
• A licensed physician (Doctor of Medicine or Osteopathy),
• A licensed certified psychologist,
• A licensed social worker
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• A licensed employee assistance professional, or a drug and alcohol counselor (certified
by the National Association of Alcoholism and Drug Abuse Counselors Certification
Commission (NAADAC); or by the International Certification Reciprocity
Consortium/Alcohol and Other Drug Abuse (ICRC); or by the National Board of Certified
Counselors Inc. and Affiliates/Masters Addictions Counselor (NBBC).
Substituted specimen means a urine specimen with creatinine and specific gravity values that
are so diminished or so divergent that they are not consistent with normal human urine.
Alcohol Prohibitions
Part 382, Subpart B, prohibits any alcohol misuse that could affect performance of safety-
sensitive functions.
This alcohol prohibition includes:
• Use while performing safety-sensitive functions;
• Use during the 4 hours before performing safety-sensitive functions;
• Reporting for duty or remaining on duty to perform safety-sensitive functions with the
alcohol concentration of 0.04 or greater;
• Use of alcohol for up to 8 hours following an accident or until the driver undergoes a
post-accident test; or
• Refusal to take a required test.
NOTE: Per FMCSA regulation (Sec. 382.505), a driver found to have an alcohol concentration
of 0.02 or greater but less than 0.04 shall not perform, nor be permitted to perform, safety
sensitive functions until the start of the driver’s next regularly scheduled duty period, but not
less than 24 hours following administration of the test.
Drug Prohibitions
Part 382, Subpart B, prohibits any drug use that could affect the performance of safety-sensitive
functions. These drug prohibitions includes:
• Use of any drug, except when administered to a driver by, or under the instruction of a
licensed medical practitioner, who had advised the driver that the substance will not affect
the driver’s ability to safely operate a commercial motor vehicle. (The use of marijuana
under California Proposition 215 or the use of any Schedule 1 drug under Arizona
Proposition 200 is not a legitimated medical explanation. Under federal law, the use of
marijuana or any Schedule 1 drug does not have a legitimate medical use in the United
States.);
• Testing positive for drugs; or
• Refusing to take a required test
Conditions for Employment
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A driver applicant who has refused a drug or alcohol test, failed a random, reasonable suspicion,
post accident, return-to-duty, follow-up alcohol test, or tested positive for controlled substance will
be considered for employment with Foothills Energy Services, Inc. if the following conditions
are met: NONE. We have a ZERO TOLERANCE POLICY.
Circumstances for Testing)
Pre-employment Testing (Sec. 382.301)
In accordance with section 382.301, all driver applicants will be required to submit to and pass a
urine drug test as a condition of employment.
Each driver applicant will be asked whether he/she has tested positive, or refused to test on any
DOT pre-employment drug test administered by an employer to which the driver applicant applied
for, but did not obtain, safety-sensitive transportation work during the last two years.
If the driver applicant admits that he/she has tested positive, or refused to test, on any DOT pre-
employment test, the driver applicant documents successful completion of the return-to-duty
process.
Job applicants, who are denied employment because of a positive test under another motor
carrier or under Foothills Energy Services, Inc’s DOT pre-employment testing, may reapply for
employment after: NEVER
The DOT return-to-duty process must be completed prior to operating commercial motor vehicles.
We will not hire anyone who has failed a prior drug test.
Driver applicant drug testing shall follow the collection, chain-of-custody, and reporting
procedures set forth in 49 CFR Part 40.
An employee of Foothills Energy Services, Inc. transferring to a safety-sensitive driving position
is also subject to and must pass a urine drug test as a condition of the transfer.
If the employee transferring into a safety-sensitive function does not pass his/her DOT pre-
employment drug screen, he/she will not be considered for employment.
Foothills Energy Services, Inc. will not require a pre-employment drug test if the following
conditions are met:
• The driver-applicant has participated in a controlled substances testing program that
meets the requirements of 49 CFR part 382 and part 40 (or another DOT agency’s
controlled substances testing program) within the previous 30 days;
• While participating in that program, the driver-applicant either was tested for controlled
substances within the past 6 months or participated in a random testing program for the
previous 12 months;
• No prior employer of the driver-applicant has records of a violation of
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• Part 382, Subpart B or the controlled substance prohibited conduct rules of another DOT
agency within the previous 6 months (section 382.301 (c)).
Foothills Energy Services, Inc. must contact the previous employer’s testing program prior to
using the driver and obtain the following information:
• The name and address of the program (usually the driver’s prior and/or current employer);
• Verification that the driver participates or participated in the program;
• Verification that the program conforms with the required procedures set forth in 49 CFR
Part 40;
• Verification that the driver is qualified under this rule, including that the driver has not
refused to submit to an alcohol or drug test;
• The date the driver was last tested for alcohol or drugs; and
• The results of any drug or alcohol test administered in the previous 6 months, and any
violations of the alcohol misuse or drug use rules.
Reasonable Suspicion Testing (Sec. 382.307)
If the driver’s supervisor or another company official designated to supervise believes a driver is
under the influence of alcohol or drugs, the driver will be required to undergo a drug and/or alcohol
test.
The basis for this decision will be specific, contemporaneous, articulate observations concerning
the appearance, behavior, speech, or body odors of the driver.
The driver’s supervisor or another company official will immediately remove the driver from any
and all safety-sensitive functions and take the driver or make arrangements for the driver to be
taken to a testing facility.
The person who makes the determination that reasonable suspicion exists to conduct an alcohol
test may not administer the alcohol test. Per FMCSA regulation, reasonable suspicion alcohol
testing is only authorized if the observations are made during, just preceding, or after the driver
is performing a safety-sensitive function.
Per FMCSA regulation, if the driver test 0.02 or greater, but less than 0.04, for alcohol the driver
will be removed from all safety-sensitive functions, including driving a commercial motor vehicle,
until the start of the driver’s next regularly scheduled duty period, but not less than 24 hours
following administration of the test.
If the alcohol test is not administered within two hours following a reasonable suspicion
determination, the program administrator will prepare and maintain a record stating the reasons
why the test was not administered within 2 hours.
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If the test was not administered within 8 hours after a reasonable determination, all attempts to
administer the test shall cease. A record of why the test was not administered must be prepared
and maintained.
DRUG TEST UPDATE
As part of the recordkeeping update, OSHA included anti-retaliation provisions that may impact
your current post-accident drug testing.
The new rule does not prohibit drug testing of employees, including drug testing pursuant to the
DOT rules or any other federal or state law. It only prohibits employers from using drug testing,
or the threat of drug testing, to retaliate against an employee from reporting an injury or illness.
Employers may conduct post-incident drug testing pursuant to state or federal law, including
Workers’ Compensation Drug Free Workplace policies, because section 1904.35(b)(1)(iv) does
not apply to drug testing under state workers’ compensation law or other state or federal law.
Random drug testing and pre-employment drug testing are also not subject to section
1904.35(b)(1)(iv).
Employers may conduct post incident drug testing if there is a reasonable possibility that
employee drug use could have contributed to the reported injury or illness. However, if
employee’s drug use could not have contributed to the injury or illness, post-incident drug testing
would likely only discourage reporting without contributing to the employer’s understanding of why
the injury occurred. Drug testing under these circumstances could constitute prohibited
retaliation.
For example, if an employee reports a bee sting, an injury caused by a lack of machine guarding
or a machine or tool malfunction, a repetitive strain injury or is injured as an innocent bystander
and the employer requires post-incident drug testing, then that testing could violate section
1904.35(b)(1)(iv) because it is unlikely that such injuries would be related to drug use by the
reporting employee. It would be reasonable however for an employer to require post-incident
drug testing for a worker who reports an injury experienced while operating a forklift or piece of
equipment or tool if the employee’s conduct contributed to the injury. Employers need not
specifically suspect drug use before post-incident testing, but there should be reasonable
possibility that drug use by the reporting employee could have contributed to the reported injury
or illness.
This explanation is directly from OSHA’s website. If ever challenged by OSHA it would come
down to the reasonableness of the drug testing to the particular employee who has report a work-
related injury or illness.
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In my opinion, a better approach would be to provide examples (and note the list is not all
inclusive) of when drug testing would be administered and would not be administered in the
company’s Drug Policy/Program. A change to the program would require training and
acknowledgement by all employees. Also, I would encourage employers to contact their medical
providers and inquire about their drug testing protocol. Many employers are still administering
drug testing 100% of the time. Employers can set up drug testing protocols with their Designated
Providers.
If an employee’s injury was suspicious and there appeared to be fault by the injured, a rapid test
would be the initial test. If the rapid test came back positive, then the sample would be tested
further. The sample would also be split in the event the employee contested the drug test results.
If the rapid test came back negative, then no additional screening would be required.
Section 19: Anti-Harassment Policy
Foothills Energy Services Inc. is an “equal opportunity employer.” The employer will not
discriminate and will take “affirmative action” measures to ensure against discrimination of any
employee or job applicant based on race, creed, color, national origin, or sex.
Section 20: Fleet Safety Program
Purpose
Foothills Energy Services Inc. recognizes that our employees are our most valuable asset and
the most important contributors to our continued growth and success. Our company is firmly
committed to the safety of our employees. FESI will do everything possible to prevent workplace
accidents and is committed to providing a safe working environment for all employees.
Motor vehicle accidents are the leading cause of work related fatalities. The environment in which
these accidents occur involves numerous complex factors, many of which are uncontrollable. The
purpose of FESI Fleet Safety program is to eliminate unnecessary injuries and fatal circumstances
by reducing those factors that we can control. We value our employees not only as employees
but also as human beings crucial to the success of their families, the local community and FESI.
To further this goal, our Company has developed a Fleet Safety Policy.
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Recruitment:
FESI focuses its initial efforts on driver selection through a variety of resources, beginning with
the job application. The application will require a perspective employee to do the following:
• List past driving experience, employers, and types of vehicles driven.
• Notify FESI of any motor vehicle violations for the last 3 years.
• List references.
Driver selection will be made upon completion of a formal interview, background check, reference
verification, review of the individual’s motor vehicle record (MVR) and a negative drug screen.
Authorizations will be obtained to contact prior employers and personal references.
MVR’s will be requested upon completion of a satisfactory interview and periodically thereafter at
a minimum of one per year. Management reserves the right to use its discretion in determining
an unsatisfactory MVR. An excessive number of violations in the past three years will be grounds
for an unsatisfactory MVR prohibiting hiring of a prospective employee or possible termination
and/or disciplinary actions of an active employee.
Drug/Alcohol Testing:
Initial and periodic random drug and alcohol testing is mandatory. Testing will be conducted by a
licensed medical facility designated by FESI. Any positive results will be grounds for termination.
Driving under the influence of alcohol or any other illegal substances will be grounds for
termination.
Training:
New hire and periodic training is required. Training will focus on but will not be limited to
defensive driving techniques. FESI will monitor driver habits to identify potentially unsafe
driving habits that require additional training and/or disciplinary actions. For those with multiple
accidents or moving violations, in one calendar year period, will be reviewed. Management
will determine what, if any, disciplinary action is needed and to identify possible training
opportunities.
Preventive Maintenance:
To maintain the safety and integrity of the vehicle, FESI will provide the necessary resources
to ensure all vehicles are operating properly. All routine motor vehicle maintenance will be
done according to the manufacture’s specifications. Critical components that must always be
controlled, maintained and promptly repaired are: brakes, tires, suspension, steering, lights,
mirrors, windows and windshield wipers.
Pre-Trip Inspections:
Employees are required to conduct pre-trip vehicle inspections. Any unsatisfactory result
requires a Fleet Hazard Identification form to be completed and forwarded to an employee’s
immediate supervisor. Thereafter, the identification form will be forwarded to the maintenance
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department to confirm the equipment malfunction, complete repairs, and sign off on the
completed identification form.
Placing a Vehicle ‘Out of Service’ :
The fleet administrator must conduct thorough post-trip vehicle inspections to ensure the
vehicle’s safety for its next driver. When a defect in the vehicle is found that qualifies it as
unsafe, unreliable, or unsafe for ordinary use, the fleet administrator must immediately take
the vehicle out of service and fill out the Fleet Hazard Identification Form indicating the nature
of the defect. The form should be forwarded to the maintenance department to confirm the
defect and repair it if possible.
Vehicle Inventory
Fleet Administrator will be responsible for maintaining a database of each vehicle’s make,
model, department, VIN number and license plate number. He or She will also manage and
update a log for each vehicle including its location at any given time and the person driving it.
The administrator will also take inventory of any minor defects or needed repairs and schedule
needed maintenance work as appropriate.
Company Vehicles for Personal Use:
Personal use of company vehicles is prohibited without prior permission from management. If
permission is granted, the employee assigned to the vehicle will be the only driver allowed to
operate the vehicle. In all other cases, use of the company vehicle is limited to travel, to and
from work, and work-related events. Any errand or travel that is not directly work related is
considered personal travel. The vehicle is not to be used for personal or entertainment
purposes. Employees are expected to use their discretion.
Specialty Vehicles
Golf carts and other specialty vehicles (including scooters, mules and quad vehicles) in use
on FESI property to move people and materials around the facility require specific precautions:
• Vehicles must travel at an acceptable speed, slowing down in wet or slippery
conditions.
• Vehicles must yield to pedestrians.
• Vehicles must keep to designated paths and roadways, staying off major streets.
Carts may not block traffic paths when parked.
• Vehicles may not carry more passengers than the cart is designed to accommodate.
If the vehicle is equipped with seat belt, they must be used.
• All passengers must keep hands, feet, and other body parts inside the vehicle.
• The driver must be aware of surroundings, pay attention to driving signs and warnings,
even if they are directed at autos and listening for warnings like emergency vehicle
sirens, children playing or other vehicles.
• Adhere to all applicable traffic laws.
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Driver Safety Policy
Motor vehicle accidents are a leading cause of work-related fatalities. The environment in
which these accidents occur involves numerous complex factors, many uncontrollable. The
purpose of FESI Driver Safety Policy is to provide the means to reduce such factors to
eliminate unnecessary injuries and fatal circumstances. We value our employees not only as
employees but also as human beings who are crucial to the success of their families, the local
community and FESI.
To further this goal, we have developed a Driver Safety Policy. This policy applies to all
employees, whether they are driving company vehicles, a rental vehicle for company business
or a personal vehicle for company business.
Policy Guidelines
Driver Eligibility:
Drivers must possess a valid driver’s license for the type of vehicle to be operated and keep
the license (s) with them at all times while driving.
Drug/Alcohol Testing
Initial and periodic random drug and alcohol testing is mandatory. Testing will be conducted
by a licensed medical facility designated by FESI. Any positive results will be grounds for
termination. Driving under the influence of alcohol or any other illegal substances will be
grounds for termination.
Insurance Requirements
Employees who use their personal vehicles for company business are required to carry
adequate limits of liability, with a suggested minimum of $100,000 for property damage and
$300,000 for bodily injury. A copy of the declaration page of your personal automobile
insurance policy must be provided to FESI annually at your renewal date.
Basic Vehicle Operation Guidelines:
Employees are required to adhere to the following basic vehicle operation principles:
• Always wear seat belts.
• Drive defensively. Always anticipate what other drivers on the road might do wrong
and plan your mode of escape. Never drive more than 10 hours during a 24-hour
period.
• When possible, avoid driving after midnight.
• Avoid driving in dangerous conditions, including drowsiness and inclement weather.
• Disabling or tampering with the Vehicles GPS is grounds for disciplinary measures.
• Remove any trash or belongings before returning vehicle to FESI.
Traffic Violations
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FESI is not responsible for any traffic violations or parking tickets acquired by violation of city
ordinance, state or federal laws regarding your driving habits and operation of your motor vehicle.
Any ticket issued is the employee’s responsibility, even if the ticket is issued while conducting
business for FESI.
Refueling Guidelines
For your safety when operating a vehicle, follow these guidelines:
• Turn off the vehicle’s engine while refueling.
• Never smoke, light matches or use lighter while refueling.
• Do not get into the vehicle during refueling, as this presents a flash fire hazard.
• Do not overfill or top off the vehicle’s fuel tank. The fuel dispenser shuts off automatically
when the tank is full.
• Never force the hold-open latch on the gasoline pump with any means other than the latch
provided.
Distracted Driving:
FESI is committed to employee’s safety, and for this reason firmly prohibits all behavior that
distracts employees while they are operating a company vehicle. General guidelines for behavior
while driving are as follows:
• Use of cellphones while driving is strictly prohibited – this includes all functions of the
cellphone including, but not limited to, phone calls, text messaging/SMS, email, MMS,
Internet use and camera use.
• Use of electronic devices – including laptops, PDA’s, cameras, and pagers – while driving
is strictly prohibited unless specifically outlined below.
• Passengers making or taking calls for the driver is permissible provided the interaction
does not affect the driver’s performance.
• Regular callers must be informed that you are unavailable while driving and be notified of
the best times to call based on your driving schedule.
• Employees who receive calls from co-workers who are driving are obligated to ask that
the co-worker call back at a more appropriate time.
Headset/Hands-Free Use
The use of headsets or hands-free devices while driving is permissible if:
• Device is preapproved by FESI for use
• Use of the device does not cause distraction (for example. Fiddling with the device or
taking eyes off the road to get it to function properly)
• Any dialing or use of the handset is handled while stopped or pulled to the side of the road
• Conversations do not interfere with the driver’s ability to drive safely
• Road conditions are generally good and do not threaten your safety
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Emergency Calls
The only exception to the cellphone use guideline is calls placed to 911. If placing or accepting
an emergency call, it should be kept short, with a hands-free option if available. The vehicle should
be pulled over if possible.
Section 21: Confined Space Policy
Foothills Energy Service does not allow employees in ANY Confined Space situation.
Section 22: Return to Work
All active employees who become temporarily unable to perform their regular job duties due to a
compensable work related injury may be eligible for transitory work duties within the provisions of
this program. Return to work tasks may be in the form of:
• Change duties within the scope of the employees’ current position
• Other available jobs for which the employee qualifies, outside of the scope of his or her
current position
• An altered schedule of work hours
Section 23: Violation & Disciplinary Action
Purpose
To support the enforcement of good safety performance and to eliminate repeated or continuing
safety violations using appropriate disciplinary measures.
Objective
The primary objective of the FESI Safety Program is to provide a safe work environment for all
employees. Each employee is individually responsible for complying with each of the provisions
of the FESI Safety Program, in addition to those safety instructions issued by the employee’s
foreman or supervisor, either verbally or in writing. However, when Safety Policies and
Procedures are violated, or individuals continue to be involved in accidents or infractions,
disciplinary action must be considered. The intent is to emphasize the severity of the situation
and bring about desired improvement.
Each employee will be given a safety orientation as a part of the general hiring process. During
this orientation, the company’s positive attitude toward working safety will be stressed and the
employee will be advised that safety is a condition of work. The safety program will be explained,
and safe responsibilities will be clearly defined.
Progressive Disciplinary Procedure
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When an employee is observed committing an unsafe act, the employee is to be informed by
means of the ‘Employee’s Reprimand Record’. The exact nature of the violation and what is
acceptable must be thoroughly explained to the employee. A copy of the written warning will be
given to the employee’s supervisor and a copy placed in the employee’s personnel file.
Disciplinary Action
Management will investigate and make decisions regarding actions taken. The disciplinary action
taken will be at the discretion of the supervision and take into account the severity of the violation.
