Method of Approach

Our firm provides asbestos and lead abatement and microbial services including, but not limited to, assessment, site investigation, remediation, removal, disposal of waste and final clearances by accredited laboratories. Our procedures in handling all ACM classified materials will follow

OSHA approved guidelines.

Native emphasizes the importance of communication and flexibility while relying on a consistent method of approach to client relations, estimation, project management and project direction and completion. Company policies and procedures have been reviewed and approved by Owners and Managers prior to implementation so that a consistent product may be provided to every Client.

When Native receives an Abatement/Remediation Project Request from the Client, the project will be assigned to an Estimator and Project Manager who will contact the designated Using

Agency representative. The scope of the project will be thoroughly reviewed with the Using

Agency Representative and a walk of the site to observe site location, site conditions and known hazards will be conducted. The scope of the work and any other site-specific information such as waste receptacle location, water and electricity availability, security measures, replacement materials and scheduling will be reviewed. Plans for content removal, storage and any other site-specific needs will be reviewed at this time as well. Once the information is gathered, any project specifications, drawings and information gathered at the site visit will be used to appropriately bid the project. A price, schedule and list of any concerns or limitations will be provided with the bid package.

Native’s Project Managers are involved with the project from the moment the client has a need until the last invoice for the project is paid. Our firm works at keeping Project Managers on each project consistent so that the line of communication is clear and traceable. For this contract it will be important that Project Managers ensure that all facets of the project are in compliance with the Unit Price Book and Open Book Pricing guidelines.

Native Environmental uses the following methods to estimate, schedule and manage projects:

• Project Set up and Schedule - Once an Estimator/Project Designer has visually reviewed a project along with the specifications for each project, the project is broke out using a computer based spread sheet that is kept up to date using Industry Standards and historical data. After the bid has been prepared and the proposal has been submitted and accepted, the project is sent to an Operations Management team then reviews the breakdown of the project including the labor and material estimates and the time frame.

Any questions regarding the project are directed to the Estimator and/or the Consultant for the project. An on-site meeting is then scheduled with Operations and the

Superintendent that is assigned to the project to discuss the required specifications for the project and to discuss the best way to engineer the project. The schedule is reviewed. The project is then kept on schedule by daily site visits by the Superintendent. The

Superintendent calls in the hours, percent complete and job costs daily, to Operations which then put the information on a spread sheet to be reviewed at the weekly staff meetings.

• Changes in Scope - Through good planning, estimating and review of plans and specifications, we will try and avoid change orders where possible. If a legitimate change in the scope of work arises, we will inform the Client or authorized representative about the change prior to beginning the additional work. The cost of the work will be evaluated and a change order request will be submitted for approval the Client.

• Dispute Resolution – Our Company will try to gain resolution to claims, disputes or any other project issues as quickly as possible by utilizing our Quality Control Plan and effective communication with all personnel involved in the project. If this is not possible, we will work diligently with Client personnel and other personnel involved in the dispute to come to a satisfactory resolution. Our firm will maintain documentation to assist in compiling any information that may be needed to resolve a dispute.

• Construction Safety – Our Company employs a Safety Officer who will use training, documentation, communication and our internal Corporate Health and Safety Plan to ensure that our workers, vendors and the public are taken into consideration during our projects. Daily tailgate safety meetings will be utilized to talk about safety protocols and to discuss information that needs to be addressed from the previous day’s work. Our

Corporate Health and Safety Program are available for review upon request.

Native shall report directly to the owner representative or consultant as directed by the owner.

We shall furnish a written estimate based on a fixed price base on the provided project scope of work, using the rates submitted with this solicitation. Once the estimate has been accepted by the owner, our firm shall be responsible for completing the work in the desired time frame. We will be under the direction of the owner who shall have control over of the following aspects:

determination of project completeness, review and approval of work schedules, approval of clean-up procedures, approval of the use of certain equipment, personnel, materials, services and/or procedures, establishment of proper safety protocol, stop work orders for conditions concerning personnel safety, unsafe activities, procedures or unnecessary work. For projects that arise without the oversight of a consultant, all completed removal and disposal shall be approved by the owner representative at the end of the project.

All work areas shall be regulated in accordance with all Federal State and Local regulations, signage shall also be posted around the perimeter of the regulated area warning potential visitors and contractors of the asbestos and/or lead dangers. Any equipment that is required to be taken out of the containment area shall be cleaned and stored in a secure area and shall wait for a decision from the owner before proceeding with the items. We will clean all containments using both wet wiping and vacuums with HEPA filters to the specifications provided by the consultant.

View windows shall also be utilized in the containments for inspections. Negative pressure shall be maintained at a minimum of -0.02 column inches of water pressure differential relative to outside pressure using manometers.

Native shall supply all labor, supervision, installed and consumable materials, equipment, services, testing devices, warehousing, tools, and all items necessary for the abatement of asbestos/lead containing or contaminated materials and restoration of work areas as required by this contract. We shall use only competent personnel who hold up to date asbestos or lead certificates as well as current physicals and fit tests. Any vendor personnel not employed for asbestos abatement and working in an adjacent area shall be informed of the locations and presence of ACM/LCM as set forth by Federal and State OSHA regulations. We shall work under the direction of the onsite Asbestos/Lead Consultant who has the authority to stop abatement activities at any time upon the determination that conditions are not within project specifications, applicable regulations, or unsafe conditions exist. The decision to stop work is solely at the discretion of the Using Agency or the Asbestos/Lead Consultant. Abatement work that has been ordered stopped shall not continue until the conditions have been corrected to the satisfaction of the Owner. Any delays caused by a stoppage due to improper working conditions identified by the

Asbestos/Lead Consultant, shall come at Native’s expense.

Our company shall conduct air monitoring of employees inside regulated areas and shall be in accordance with applicable regulations. We will comply with the following monitoring requirements: Area monitoring as may be needed to control the site in and/or adjacent to the points of entry, and exits from the regulated area, and in the vicinity of the negative air from the time it is established, and until final clearance is demonstrated. Final clearance for abatement projects shall show fiber concentrations equal to or less than the AHERA clearance concentration of 0.01 f/cc (by PCM) or 70 str/mm^2 (by TEM). The consultant shall be responsible for final air clearance. Should the clearance air monitoring need to be repeated due to a failure to meet

AHERA air clearance criteria, all associated costs, including the cost of additional consultant fees shall be at our expense. Final clearance for lead abatement shall be by wipe/soil methods as applicable. Clearance criteria shall be according to HUD Guidelines 1997 and analyzed by Flame

Atomic Absorption Spectrometry. A project close-out report of all air monitoring data shall be submitted to the owner or the consultant at the end of the project. Native shall furnish all air monitoring results (written) along with copies of all manifests, permits, etc. after the project has completed, if requested.

Native shall maintain existing areas that require repair. Areas that require repair due to asbestos/lead removal shall be identified and the owner notified in writing as to the extent of the repairs required. Re-establishment of the work area shall only occur following the completion of all cleanup procedures and after clearance air monitoring has been performed and documented to the satisfaction of the owner and/or consultant. We shall, as necessary, re-install all non-stationary items that were temporarily removed during the abatement process, and shall ensure that all such items are in the same condition as when they were removed. We shall, as necessary, re-establish to proper working order all mechanical, heating, ventilation, and air conditioning, lighting, and electrical systems that were shut down during the abatement process. We shall repair to the best of our abilities the original condition of all areas damaged as a result of our activities or the activities of his employees as well as any glue, tape residues or any trash resulting from abatement. We shall apply encapsulates, when acceptable, to surfaces where regulated asbestos containing material (RACM) was removed.

Native shall be responsible for all site inspections, estimations of quantity of work, and recognition of unusual or special situations which may affect a timely and scheduled completion of the work. The owner’s representatives shall have access to the work site, materials, records, or any other relevant data. We shall provide proper facilities for such access and inspection. After the abated area has been cleaned, and before final clearance testing is performed, the consultant, in conjunction with our firm, shall inspect the area. During this inspection, areas that need further cleaning/refinement shall be identified, and any additional work shall be performed prior to the final clearance testing. Native shall ensure the negative air system remains in continuous operation until results of air clearance tests prove that the airborne fiber level is below 0.01 f/cc or predetermined clearance air level. Application of new surface treatment, if required, shall be specified by the owner and shall be done in accordance with the standards specified. If required by the owner, reinstallation of all fixtures and restoration of electrical power to all electrical fixtures is the responsibility of Native. We shall conduct an inspection to ascertain that all work, including containment tear down, has been accomplished pursuant to the project. The final inspection shall include the consultant and the authorized owner representative, as well as other required representatives if required. All regulated waste shall be disposed of at an approved waste disposal site in accordance to all applicable regulations.

In the event that a problem arises during a project we will try to gain resolution to claims, disputes or any other project issues as quickly as possible by utilizing our Quality Control Plan and effective communication with all personnel involved in the project. If this is not possible, we will work diligently with Client representatives and other personnel involved in the dispute to come to a satisfactory resolution. Native will maintain documentation to assist in compiling any information that may be needed to resolve a conflict. Any issues will be followed to resolution to ensure Client satisfaction.

Native actively ensures all employees have the appropriate training and certification in accordance with all regulatory standards that apply to the work being completed. In addition, continuing education covering changing regulation and regulatory interpretation is provided to all managers and if applicable employees. All onsite supervisors and superintendents are aware of local, state and federal regulations and are expected to comply. Prior to onsite work, all vendors will be given a brief course explaining the regulations they shall also abide by.

Native shall ensure that all NESHAP notifications are current, revisions are located onsite, and have been sent to the proper notification entity. We shall keep track of all labor, equipment and materials onsite for the owner’s approval. All project-related paperwork, as well as waste manifests and air monitoring results, shall be submitted within 30 days of completion of the project as a closeout, if requested by the owner. A site-specific health and safety plan shall be submitted before the start of any project based upon the project scope of work. A corporate health and safety plan is located at our main office and can be accessed whenever necessary.

Native uses this same general method of approach for mold abatement and has adapted the following Standard Operating Procedure specific to this type of abatement:

STANDARD

OPERATING PROCEDURE

Procedure No. MIC101 - A

Date: Revised 6/22

Subject: MICROBIAL REMEDIATION ACTIVITIES

I. Purpose and Scope

The purpose of this procedure is to prevent/minimize injuries/illnesses caused by the failure of employees to recognize and take precautions against the potential exposure to airborne fungal toxins.

It is the intent of this policy to protect employees from occupational exposure and illness associated with microbial remediation activities by requiring that only trained employees be permitted to perform work on projects, which involve microbial remediation.

This program includes in its scope, microbial remediation activities procedures, hazards, testing, and training requirements.

II. References

A. A. ACGIH Handbook - Threshold Limit Values for Chemical Substances and

Physical Agents & Biological Exposure Indices

B. B. Native Environmental Safety Procedure - Respiratory Protection

C. C. Native Environmental Safety Procedure - Personal Protective Equipment

MIC101-A

ASSISTANT SECRETARY- means the Assistant Secretary of Labor for Occupational Safety and

Health, U.S. Department of Labor, or designee.

COMPETENT PERSON- means one who is capable of identifying existing and predictable microbial hazards in the surroundings or working conditions and who has authorization to take prompt corrective measures to eliminate them.

DIRECTOR- means the Director, National Institute for Occupational Safety and Health (NIOSH), U.S. Department of Health and Human Services, or designee.

RESPIRATORY PROTECTION- means an appropriately selected respirator equipped with the required filters/cfm of grade "D" air to safely and effectively perform microbial remediation activities.

IV. IV. Responsibilities

A. A. CORPORATE SAFETY MANAGER

• • Ensure all management personnel are aware of the Microbial

Remediation Activities Program and procedures.

• • Ensure that training is provided to all authorized employees, affected, and other employees.

• • Enforce the program requirements.

• • Appoint a corporate program coordinator.

• • Provide necessary equipment for the Microbial Remediation Activities

Program.

• • Periodically audit the Microbial Remediation Activities Program.

B. B. GENERAL MANAGER

• • Ensure all subordinates are provided training on an annual basis and as required by this program.

• • Ensure all training activities are documented and a copy of the training record is provided to the corporate program coordinator.

• • Handle concerns of employees.

• • Monitor and enforce compliance to the program.

• • Provide the necessary equipment needed for the Microbial Remediation

Activities Program.

• • Audit authorized employees at least quarterly on how they follow established Microbial Remediation Activities procedures. These audits shall be documented and submitted to the corporate program coordinator.

• • Notify the Program coordinator(s) of any equipment/process changes and/or modification.

• • Notify the program coordinator(s) of any changes/modifications, which effect work practices.

C. C. CORPORATE SAFETY COORDINATOR

• • Handle concerns of management/employees.

• • Provide training to management to enable them to train their employees.

• • Monitor and enforce compliance to this program.

• • Approve all Microbial Remediation Activities procedures.

• • Maintain a log of all training activities to ensure all employees have been provided training as required by this program.

• • Recommend/purchase the necessary equipment for the Microbial

Remediation Activities Program.

• • Monitor and maintain a log of Microbial Remediation Activities Site inspections.

• • Modify Microbial Remediation Activities procedures when work practices, equipment, and processes are changed or modified.

D. MICROBIAL SUPERVISOR

• • Ensure all subordinates are provided microbial Remediation Activities

Program training on an annual basis and as required by this program.

• • Document all training activities and provide a copy to the corporate program coordinator.

• • Handle concerns of employees.

• • Monitor and enforce compliance to the program.

• • Approve/monitor Microbial Remediation Activities conducted within work area.

• • Provide the necessary equipment needed for Microbial Remediation

Activities.

• • Audit authorized employees at least monthly on how they follow established Microbial Remediation procedures. These audits shall be documented and submitted to the corporate program coordinator.

D. E. AUTHORIZED EMPLOYEES (MICROBIAL WORKERS)

• • Complies with this written program and procedures.

• • Knows where to obtain information about Microbial related hazards and how to identify them.

• • Obtains and reads Microbial Remediation procedures prior to starting a job.

• • Obtains all necessary equipment indicated on the procedure prior to starting a job.

• • Obtains approval from Supervisor to conduct Microbial Remediation

• • Identifies hazards before the start of the job.

• • Notifies all affected and other classified employees before initiating or terminating any Microbial Remediation Activities procedure.

• • Notifies the Supervisor and the program coordinator immediately of any undetected hazards/exposures and provide a solution of how to eliminate/isolate them.

• • Suggests to the corporate program coordinator ways to improve procedures.

F. EMPLOYEES (AFFECTED / OTHER)

• • Understands the intent of this program.

• • Stays clear of Microbial Remediation procedures being enacted and its

V. V. Potential Hazards -

Microbial workers could be exposed to one or more of the following:

1. 1. Toxic Substance.

2. 2. Electrical shock from portable lights, tools, or assorted electrical equipment.

3. 3. Ventilation problems due to welding, cutting, and burning equipment.

4. 4. Mechanical equipment inadvertently activated, such as agitators and mixers.

5. 5. Physical hazards such as slipping, falling and falling objects.

6. 6. Physical deficiencies causing collapse due to fatigue, low resistance to temperature extremes and general poor health.

7. Contact with potentially poisonous animals and insects.

VI. VI. Training

A. A. Initial Training shall consist of classroom & hands-on training for all

Microbial Workers. Additional training shall be provided to all Microbial

Supervisors. In addition to the initial training all Microbial Workers and

Supervisors shall complete annual Microbial certification training.

Training shall include the following:

1. 1. NIOSH recommendations as it pertains to Microbial Remediation

Activities

2. 2. Native Environmental, LLC policy and procedures pertaining to

Microbial Remediation Activities operations

3. 3. Potential hazards involved

4. 4. Understanding reference materials (MSDS, NIOSH Pocket

Guides, Labels, etc.)

5. 5. Accepted Removal Methodologies

6. 6. Use of applicable safety instruments and equipment

7. 7. Safe working procedures

8. 8. Safe operating procedures

9. 9. Emergency Response

B. B. Additional Training for Microbial Supervisors shall include:

1. 1. Hazard recognition and protection

2. 2. Equipment maintenance and calibration

3. 3. Managing work-place emergencies

C. C. Specialized Training for rescue personnel - In addition to general training, all employees working within or providing assistance to other employees where an Immediately Dangerous to Life and Health level exists, or where all known or potential hazards are not positively controlled are instructed in:

1. 1. Respiratory protection to be used in emergency situations

2. 2. Rescue and emergency response duties and procedures

3. 3. Emergency equipment

4. 4. Ventilation

5. 5. Retrieval systems

6. 6. Patient Packaging and Stabilization

7. 7. Advanced First Aid and CPR

VII. VII. Sub-Contractor

A. A. The Sub-Contractor shall be informed that entry into microbial removal areas must be in compliance with all current local, state and federal regulations and/or recommendations.

B. B. The Sub-Contractor must make arrangements for their own training pertaining to microbial contaminants and the removal of microbial contaminated materials.

C. C. The Sub-Contractor shall be responsible to provide all necessary equipment needed for Microbial Remediation Activities. This includes all communications equipment, retrieval systems, air monitoring equipment, and removal equipment.

IX. Pre-Removal Procedures

A. A. The Microbial Supervisor will conduct a brief meeting with all employees involved to review the potential hazards and any appropriate procedures.

1. 1. The Microbial Supervisor will perform a thorough work area walkthrough and identify the scope of work involved, the removal methodologies, decontamination requirements and containerization of the generated waste.

2. 2. All Microbial workers and authorized persons inspecting the work area must be trained in Microbial Services.

B. B. Prepare the surface of the substrate as appropriate. The method used will be determined by the potential hazards as well as the type of work to be performed.

C. C. Lines which may convey flammable, injurious or incapacitating substances into the work area shall be disconnected, blinded or blocked off by other positive means in such a manner that inadvertent re-connection is prevented. All blinds must be recorded in a logbook.

D. D. Deactivation of Mechanical and Electrical Energy Sources: All energy sources are to be deactivated in accordance with Native

Environmental Lockout/Tagout procedures, and 29 CFR 1910.147.

X. X. Microbial Work Area Practices

A. A. A Microbial Supervisor will be stationed on the jobsite at all times when employees are working:

1. 1. The Microbial Supervisor will maintain continuous communication with the Microbial Workers and the working

Foreman.

2. 2. The Microbial Workers will alert the Supervisor whenever:

a. a. The Microbial Worker recognizes any warning sign or symptom of exposure to a dangerous situation.

b. b. The Microbial Worker detects a prohibited condition.

3. 3. Exit from the work area as quickly as possible whenever:

a. a. An order to evacuate is given by the Foreman or

Microbial Supervisor.

b. b. The Microbial Worker recognizes any warning sign or symptom of exposure to a dangerous situation.

c. c. An evacuation alarm is activated *.

A. Only intrinsically safe electrical lighting and equipment or portable battery lights will be used.

B. B. Only approved, grounded electrical equipment will be used, equipped with a Ground Fault Circuit Interrupter (GFCI) at the source of power supply.

C. C. Personal protective clothing and equipment will be used for employee protection as specified by the Microbial Remediation Work

Plan.

XI. XI. Program Update or Audit

Annually - When deficiencies are noted, audit and update the means, procedures, and practices for a safe working environment.

Annually - Inspect the Microbial Remediation Activity / Monitoring equipment for proper operation and calibration.

Annually - Or whenever duties change, audit and update the personnel roster.

Annually - Review previous job logs.

Annually - Update the duties and training of the Microbial Supervisors.

Annually - Update the duties and training of the Microbial Workers.

Annually - Update the duties and training of the rescue team.

Annually - Update the duties and training of Affected Employees.

Semi-annual - Review and update this written procedure

Quarterly - Check for the presence and condition of signs posted to ward of the presence of

Microbial Contaminants. Check means used to prevent unnecessary exposure to those materials.

Approved By:

REFERENCES

US Department of Labor

OSHA Safety & Health Standards

29 CFR 1926.1101

ASBESTOS