Appendix E - Granger Construction Safety _ Health Program Manual.pdf

Granger Safety & Health Program v7

Table of Contents Tab 1 - Safety & Health Policy Administration 4

A.1. Introduction

A.2. Safety & Health Mission Statement

A.3. MIOSHA/OSHA Compliance Policy and Procedure Directive

A.4. Safety and Health Program Organization

A.5. Safety Team Organization and Assignment of Responsibilities

A.6. Hazard Communication and Safety Training

A.7. Enforcement of Safety Rules and Disciplinary Procedures

A.8. Job Site Safety Administration

A.9. Subcontractor Management

A.10. Equal Employment Opportunity and Affirmative Action Policy

A.11. Harassment Prevention Policy

A.12. Violence Prevention Policy

A.13. Drug-Free Workplace Policy

A.14. Emergency Plans

A.15. First Aid

A.16. Chemical Hazard Communication Policy (CHCP)

A.17. Hexavalent Chromium Exposure Policy

A.18. Respirable Crystalline Silica Policy

A.19. Respiratory Protection Policy

A.20. Lead Policy

A.21. Cadmium Policy

A.22. Asbestos Policy

A.23. Mold Policy

A.24. Pollution Incident Prevention Policy

Tab 2 - Operations 104

B.1. General Rules

B.2. Masonry Wall Bracing

B.3. Personal Protective Equipment (PPE)

B.4. Welding and Cutting

B.5. Handling and Storage of Material

B.6 Excavation, Trenching and Shoring

B.7. Cranes

B.8. Powered Industrial Trucks

B.7. Fixed and Portable Ladders

B.8. Scaffolds and Scaffold Platforms

B.9. Fire Protection and Prevention

B.9. Tools

B.10. Demolition

B.11. Guarding of Walking and Working Areas

B.12. Concrete Construction

B.13. Steel Erection

B.14. Aerial Work Platforms

B.15. Confined Space

B.16. Fall Protection and Prevention

B.17. Electrical Safety

B.18. Hazardous Energy Control – Lock-out / Tag-out Policy (LOTO)

B.19. Hot Work

B.20. Employee Protection

Tab 3 - Supporting Items – Appendix of Forms 238

C.1. Attachments Trade Contractor Project Specific Safety Plan GCC Site Specific Safety Plan - Reference Guide Trade Contractor Pre-Task Hazard Analysis Plan Pre-Task Safety Analysis

SEVERE ACCIDENT – CRISIS POSTER

Severe Accident Crisis Poster Emergency Action Plan Notice to Contractors and Visitors OSHA / MIOSHA Inspection Safety Violation Warning Accident Investigation Report Witness Report Pre-Dig Worksheet Confined Space Entry Permit Energized Electrical Work Permit / Job Safety Plan Safety Correction Report (Near-Miss or Hazard)

Federal Poster Safety Training Roster and Sign-In Sheet Respiratory Hazards & Equipment Acknowledgement Respirator Care & Maintenance Record

PERMIT REQUIRED CONFINED SPACE ENTRY PROGRAM (PRCSEP)

MAN BASKET INSPECTION REPORT

Property Damage Report Crawler Equipment, Telescoping Forklift, Backhoe and Loader Daily Checklist Crane Initial Load Test Checklist Crane Daily Inspection Log Crane – Job Safety Analysis Form Aerial Work Platform Swing Stage Initial Test Safety & Health Program

Tab 1 - Safety & Health Policy Administration

A.1. Introduction

Safety: The Tool for All Trades

The Granger Construction Company Safety Policy aims to minimize the hazards and risks associated with construction operations. Our objective for all Granger Construction Company projects is 0 incidents.

Participation by every member is essential to accomplishing these objectives. This manual has been created to ensure the Granger Construction Company Safety and Loss Prevention policies and procedures are understood and implemented at every phase.

Granger employees and subcontractors have an obligation to adhere to the guidelines in this manual. In addition to these guidelines, all trade standards apply. These standards are outlined in Michigan Occupational Safety and Health Administration (MIOSHA)/(OSHA) Federal Occupational Safety & Health Administration and American National Safety Institute (ANSI) directives. Neglecting the Granger Safety and Loss Prevention policy may result in suspension or termination.

The Granger Construction Company Safety Policy was completely updated as of February 12, 2024, and should be read in its entirety. The last page contains a Policy Acknowledgement and Acceptance (SF015WI) form that must be signed by the project manager and site supervisors and returned to the Granger field office before commencing work.

Other forms referenced in this manual are included as exhibits in the Appendix or are available through Granger on-site personnel.

A.2. Safety & Health Mission Statement

People are our most important resource, and employees are our most important asset. Personal safety and health are essential and integral to our operations and our overall success as a company and as team members. Safety and Health are, therefore, our highest priorities, a primary responsibility that must not be compromised.

We will provide a safe and healthful workplace free from recognized hazards where our employees feel secure and proud to perform quality work. We will always establish and insist on safe work methods and practices. Our goal is zero accidents and zero defects, and we will strive for continuous improvement to achieve and maintain our performance in these areas.

We are a team, and each of us will have an absolute commitment to safety as our fundamental focus. We will all be genuinely involved in this endeavor at all times, and we will each do our parts. In so doing, we will be leaders in our industry, and we will all be safe and successful together. We owe this to ourselves, each other, our families, our customers, and our community.

We have established our Safety and Health Program to eliminate work-related injuries, illnesses, and accidents.

We expect to improve operations and reduce personal and financial losses. This should decrease costs, increase productivity, and raise employee morale. The ultimate result will be greater overall satisfaction for our company's principals, personnel, and customers.

All personnel, at all levels, have the right to be safe, the responsibility to work safely, and a duty to be involved in safety and health operations. Our Safety and Health Policy mandates, as a job requirement, that every individual exercise these rights and responsibilities with genuine commitment. Our Program provides a structure within which all personnel have assigned responsibilities so they can function effectively to carry out this mandate.

Management shall develop and maintain an effective Safety and Health Program. We will do this with ongoing employee involvement. Our Company Safety Director, in conjunction with our Safety Team, shall inform employees of applicable safe practices, rules, and regulations and coordinate safety communications, employee training, team meetings, authorized inspections, procedures for corrective actions, reports of injuries, illnesses, incidents and observed hazards, accident investigations, recommendations, actions, and advice. Employees and our Safety Teams will assist him.

All Employees shall immediately report all accidents, injuries, and hazards, whether serious or minor, to their Supervisor, who shall inform the Safety Team Leader. They shall also inform him of any safety information and ideas they may have. We have an Open-Door Policy and encourage communication with the Safety Director on any safety matter. All Employees are personally responsible for preventing accidents and hazard exposures in operations and work areas that they control. This includes following safe work practices, obeying company rules and directives, and using proper personal protective equipment. Employee performance in this regard will be measured along with their overall performance.

Safety inspections and evaluations shall be conducted regularly. Inspections shall evaluate each job's actual hazards and operations, considering the probability of an accident, release, or exposure and the severity of potential injury and illness. The safety supervisor in charge of inspections shall use our Jobsite Safety Audit Form.

Safety Team meetings and discussions shall be conducted monthly or as conditions and situations merit. They shall involve all Safety Team members when practical. When we identify various hazards, potential hazards, and safety issues applicable to our operations, we will promptly determine the appropriate action and pursue it.

We will determine adequate and suitable corrective actions and implement them by means of:

1. Written Action Plans and Operating Procedures

2. Training of Employees and Enforcement of Compliance

3. Obtain and Implement use of Means and Materials for Control and Protection

Many of the potential hazards identified are routinely controlled or protected against so that there is no serious hazard exposure, and some written plans exist and have been implemented. In these cases, we will review performance and revise plans as needed.

This Safety and Health Program will be a fundamental and integral part of our daily operations. We must support it fully, be genuinely involved, and do our part. We are all responsible for succeeding in this and our overall business as individuals and a company. We owe this to ourselves, each other, our families, our customers, and our community.

Glenn D. Granger President

A.3. MIOSHA/OSHA Compliance Policy and Procedure Directive

It is our policy to comply with all applicable Standards and Rules of the Michigan Occupational Safety and Health Act (MIOSHA) (PA 154), Federal Occupational Safety Health Administration (OSHA), and amendments and orders pursuant thereto. We shall do this as part of our overall Safety and Health Program. In the process, we shall, from time to time, write and implement individual Plans, Programs, and Operating Procedures to identify and control specific hazards, ensure safe work practices, inform, train, and protect personnel, and generally provide for safe working conditions.

Where an individual Plan, Program, or Operating Procedure is written, the applicable MIOSHA/OSHA Standards and Rules will be attached and made a part thereof. We shall also include available On-Site Consultation Abatement Advice (OSC), Occupational Health Advice (OH) or BSR/CET publications or guidance therefrom, and Operating Procedures to implement the Plan or Program. Nothing in any Plan, Program, or Operating Procedure shall be intended to conflict with the Standard, and nothing shall be construed to authorize or allow violation of the Standard.

Where a Plan is not individually written in whole or in part, the applicable MIOSHA/OSHA Standards and Rules along with this Directive and any OSC or OH we possess shall become our Program and shall be used. A list of these Standards, Rules, OSC, OH, and BSR/CET publications is attached to this Directive. Also included is a list that classifies safety and health issues and correlates applicable Standards, Rules, OSC, and OH with each issue.

Consult this Safety and Health Issues Classification matrix and the referenced documents and use them as a Program.

Managers shall ensure that this Directive, all MIOSHA/OSHA Standards and Rules, and all applicable Plans, Programs, and Operating Procedures are kept on file, up to date, and readily available in each Workplace they manage. They shall designate specific Supervisors and Safety Team personnel to oversee and implement them.

Designated responsible personnel shall be familiar with them and ensure their implementation. All personnel shall follow them and related instructions and seek direction where needed.

A master copy of all these materials shall be kept on file electronically in the Corporate Office Safety department. It is available to copy or review as needed. A copy of any applicable item will be made available to an employee upon request for relevant work-related purposes.

We shall also comply with the requirements of and may implement the use of materials from other programs and policies of our organization.

A.4. Safety and Health Program Organization

All personnel, at all levels, have the right to be safe, the responsibility to work safely, and a duty to be involved in safety and health operations. Our Safety and Health Policy mandates, as a job requirement, that every individual exercise their rights and perform their responsibilities with genuine commitment. Our Program provides a structure within which all personnel have assigned responsibilities so they can function effectively to carry out this mandate.

Examples of duties are as follows:

1. Management shall develop and maintain an effective Safety and Health Program and

a. Establish policies and procedures that will effectively eliminate, control, or protect employees from recognized hazards in the workplace.

b. Provide financial and personnel resources to accomplish approved policies.

c. Ensure implementation of engineering, education, and enforcement measures.

d. Pre-employment physicals should be included in the hiring process and when changing into certain job functions and different environments.

2. The Safety Director shall implement, supervise, and maintain the Program and

a. Guide and coordinate the Safety Team and/or direct employees on safety issues as needed.

b. Ensure maintenance of records, reports, documents, and compliance with regulations.

c. Be familiar with applicable safety and health laws, rules, standards, and practices.

d. Act to prevent serious injury or damage to property or the environment.

e. Acquire materials and services and allocate employee time as needed.

e. Enforce safety rules and evaluate the performance of the Program and personnel.

f. Liaison with outside entities, including regulatory agencies.

3. The Safety Team and/or specified Members or Employees shall perform as directed and

a. Inform and train employees on safety practices, rules, and regulations.

b. Investigate accidents, near misses, and employee complaints & file reports.

c. Perform inspections and hazard analyses and recommend corrective actions.

d. Report to the Safety Director and assist with designated responsibilities.

e. Project Managers have direct responsibility for the enforcement of our safety Program.

f. Superintendents/Foremen shall ensure the performance of all day-to-day job site safety activities.

4. All Employees shall work safely and avoid hazards to themselves or others, and

a. Learn and follow all general and specific safety rules for their job.

b. Use only safe work practices; learn how to do it before acting.

c. Report accidents, hazards, and unsafe situations to their supervisor.

d. See the Safety Director with serious concerns if needed.

e. Reckless or willful endangerment of oneself, others, or property may be cause for severe discipline, including dismissal and possible prosecution.

f. Be responsible for ensuring they are physically and mentally fit to perform their job functions safely. If employees cannot perform their duties safely due to physical or mental state, they are responsible for notifying their supervisor. Employees must take responsibility for their safety and not report to work in a condition to endanger their fellow workers' safety.

5. All Subcontractors shall work safely and avoid hazards to themselves or others and

a. Comply with the General Contractor’s safety program, MIOSHA/OSHA, and trade standards.

b. Comply with all safety requirements in the General Contractor’s Front End Bid Documents.

A.5. Safety Team Organization and Assignment of Responsibilities

We have developed a Safety and Health Program with the involvement of employees who are knowledgeable and dedicated to ensuring a safe and healthful work environment. Such employees, including Job-site Safety Leaders, will form a Safety Team. They will assist the Safety Director in implementing and maintaining the effectiveness of our Program on an ongoing basis.

The Safety Director and the Safety Team shall inform employees of applicable safe practices, rules, and regulations and coordinate their safety communication and training. They shall conduct safety meetings, inspections, and accident investigations, recommend corrective actions, keep reports of injuries, illnesses, incidents, and observed hazards, and seriously consider employee complaints, reports, and suggestions.

We are dedicated to workplace safety and health and will diligently promote it. Every employee must support the Program and be genuinely involved. Each person is individually responsible for preventing accidents and hazard exposures in their operations and work areas, including the assignments below.

Companywide responsibility for supervision is as follows:

Designee/Coordinator: Safety and Health Issues or Hazards

Brian Goodman: Safety Director

Denise Styx: Safety Administrator; Reports of Accident, Inspections, Man-hours, TBTs, Work Comp Coordination

Job Site Safety Leader: Ensure compliance with all safety issues at their job site. The Project Engineer or Superintendent shall be the Job Site Safety Leader unless another person is specifically assigned.

Every Employee and Contractor: See A.9 in this manual.

A.6. Hazard Communication and Safety Training

Hazard communication and safety training shall be provided to all Granger Construction Company employees and shall include the following:

1. Safety Inspections

2. Accident Investigations

3. Hazardous Materials

4. Flammables and Compressed Gasses

5. Personal Protective Equipment, Clothing and Respirators

6. Hand and Power Tool Safety

7. Confined Space Entry

8. Lock Out and Electrical Safety

9. Back and Joint Injury Prevention (proper lifting techniques)

10. Scaffolds, Ladder Safety and Fall Prevention

11. Emergency Response and First Aid

12. Fire Prevention, Protection and Extinguishing

13. Guarding of Machines and Equipment

14. Welding and Torching

15. Safety Program Review and General Safety Rules

16. Health Hazards, Asbestos and Lead

17. Mobile Equipment and Forklifts

18. Driving Safety

19. Material Handling, Storage, Lifting and Moving

20. Excavation, Trenching and Shoring

21. Walking and Working Areas, Signals, Signs and Tags

22. Silica Standard

23. Tunnels, Shafts, Cofferdams, Caissons

24. Masonry Walls and Concrete, Steel and Precast Erection, HazWoper, Demolition & Blasting

Weekly Toolbox Talks on a wide variety of issues will also be conducted. The foreman of each job at the job site will conduct these weekly and provide them electronically. They will have all employees on their job site enter their names on the attendance roster and return it to the corporate office.

A.7. Enforcement of Safety Rules and Disciplinary Procedures

The measures outlined below constitute the minimum acceptable disciplinary procedure for enforcement of safety rules.

Assault, reckless endangerment of oneself or others, or willful destruction of property is cause for immediate termination and possible legal action. Other violations and hazardous actions are cause for the following minimum disciplinary procedures:

1. First Violation: Verbal and Written warning with a copy for personnel file. Use Safety Violation Warning

(SF075FR).

2. Second Violation: Written warning with a copy for personnel file and 1-3-day suspension without pay, pending severity of the infraction.

3. Third Violation: Written warning, copy for personnel file, and termination.

Serious misbehavior and aggravating factors may warrant more severe discipline. The number of persons placed at risk, the severity of injury and/or property damage that can be expected, and repeated violations or apparently willful disregard for safety or safety rules will be considered when determining discipline. The extent of discipline is at the sole discretion of management.

Physical inspections of work areas must be conducted to ensure employee compliance with safety rules and policies.

The Granger Safety Director shall oversee the disciplinary program, and all Granger supervisors shall enforce it.

A.8. Job Site Safety Administration

INSPECTIONS AND CORRECTIONS - The job-site Safety Leader, Foreman, or designee will tour each job site, communicate, and coordinate with others as needed to observe and control hazards as follows:

1. Identify and record safety and health hazards, as well as their severity and probability.

2. Determine the corrective and protective actions necessary to safeguard personnel and prevent accidents, injuries, and illnesses.

3. Determine the parties responsible or assign designated employees to carry out corrective actions, and the instructor communicates with them or performs action necessary to correct the hazardous situation.

4. Follow up to ensure timeliness and adequacy of corrections.

ACTION PLANS should include methods of correction in the following order of preference:

1. Eliminate the hazard by removing it or substituting a non-hazardous alternative.

2. Control its exposure potential by effective guarding, shielding, or engineering.

3. Protect persons from exposure by providing and enforcing the use of personal protective equipment.

4. Train workers in safe work practices and methods.

5. Reduce exposures and protect others by coordinating contractors' and employees' work periods, areas, methods, communications, and means of protection.

A GENERAL JOB-SITE SAFETY INSPECTION or evaluation and action plans for corrections shall be done:

1. Before a job commences, it should be done in consultation with our Safety Director.

2. Jobsite Safety Audits shall be conducted bi-weekly, and safety actions will be recorded.

3. Weekly for new or continuing items introduced at the weekly or other safety meetings.

4. Daily for specific items requiring daily checks and identifying new hazards.

HAZARD COMMUNICATION, SAFETY TRAINING, AND INSTRUCTION - When a serious potential hazard exists and is not eliminated or adequately controlled:

1. Affected workers must be informed of

a. The hazard, its type and seriousness,

b. The planned corrective actions

c. The means and methods for their personal protection and precautions

d. Their personal responsibility to use protections, precautions, and safe work practices as trained and instructed.

2. Training and instruction must be provided adequately and appropriately for the seriousness and type of hazard and work practices required to prevent injury.

REGULAR SAFETY MEETINGS shall be held for routine training, reporting, and discussion, including communication of hazards and coordination of operations among contractors and employees. These shall include:

1. Daily Safety huddles should be conducted before the start of each work shift for all employees on site. Weekly Toolbox Talks should be coordinated as applicable with activities for each week. Attendance rosters should be completed and returned to the corporate office.

2. More extensive companywide safety meetings quarterly or as needed. Topics shall be arranged periodically, e.g., annually, and include the issuance of our Program to all employees.

A.9. Subcontractor Management

All Subcontractors shall be subject to strict safety enforcement. Safety plans, training documents, and safety statistics will be reviewed to determine whether a contractor is qualified.

Some job sites may require each sub-contractor to submit their safety statistics for Granger review. Job sites require each contractor to submit their company's EMR, RIR, DART, fatality rate, and OSHA 300 Log before being allowed on-site. These job sites have a maximum rate established for each safety category. If each contractor does not meet the safety requirements, they will not be allowed to work on Granger Projects. Granger shall conduct a post-job safety performance review. This review is designed to create “learning lessons” for any safety-related issues on the job. Sub-contractors who have not been compliant with all Granger safety procedures may not be allowed to contract with Granger on future jobs.

Subcontractor Responsibilities:

1. Each Subcontractor, regardless of tier, is solely responsible for the safety and health of its employees and all lower-tiered vendor and subcontract employees. Full compliance with OSHA and ANSI Standards incorporated by reference, Federal, State, Local, Environmental, Owner, and Granger Construction Safety Requirements, and required Safety Procedures are mandatory.

2. Subcontractor employees who enter a project must complete the Granger and/or Owner’s (including 3rd Party) new-hire Safety Orientation Training Program. The Subcontractor Safety Orientation Training Program shall be documented and be available for review upon request.

3. Subcontractors are solely responsible for providing the training and documentation for all necessary competent persons for each and any applicable project activities involving, but not limited to, excavations, temporary electrical, high-voltage electrical, ladders, scaffolds, respiratory protection, first aid, fall protection, aerial lifts, forklifts, rigging, silica, and cranes.

4. Subcontractors shall provide their employees with all necessary work task safety training in a timely manner to facilitate the safe and expeditious execution of their work. The subcontractor shall maintain training records for each of its employees and make these records available to Granger upon request.

Non-Supervisory Personnel

Arrangements will be made for all personnel to receive safety education detailing their responsibilities. In addition, training should include:

• Explanation of job site rules and regulations

• Brief overview of the project

• “Smoke-Free Initiative” (ban on smoking on project site)

• Procedures to follow when reporting unsafe acts, conditions, or accidents.

• First aid emergency training

• Training, when necessary, in any existing special hazards or conditions and

• Training in job site administrative procedures as necessary to carry out their portion of the work.

Supervisory Personnel

In addition to the training that is to be carried out for new personnel, all supervisory personnel should be trained in:

• OSHA and ANSI Rules and Regulations (OSHA 30-hour Minimum)

• Current first aid and CPR

• Accident investigation and reporting, and

• Special job site conditions.

5. Subcontractors shall complete a Site-Specific Safety Plan, which must be submitted and reviewed by Granger’s Safety Management Team prior to beginning work.

6. Subcontractors shall complete a Pre-Task Analysis, Job Hazard Analysis, or Activity Hazard Analysis considering all safety hazards during the planning and scheduling of work operations to control potential injury and property damage hazards. This form must be completed prior to the start of work. Once Granger reviews and signs off on the form, the subcontractor may begin work.

a. Subcontractors shall complete a Pre-Task Analysis for each work activity.

b. It shall document identified training/certifications and task-specific PPE.

c. Once Granger has reviewed and accepted it, the Pre-Task Analysis shall be reviewed, communicated, and signed by each subcontractor’s employee involved with the task. The subcontractor may begin work after obtaining their employees' signatures.

d. The Pre-Task Analysis shall involve the Granger Project Team and the subcontractor’s safety representative.

e. The Pre-Task Analysis for the subcontractor must be communicated to all new employees/new hires who come to work for the subcontractor.

f. The Daily Pre-Task Safety Analysis shall be conducted daily to review the Pre-Task Analysis as well as location-specific details of the work operation.

7. Conduct and document the daily pre-task analysis review with their employees. Completed Pre-Task Safety

Analysis reviews shall be submitted to the Granger Project Team.

8. Subcontractors shall clearly communicate their position in the Safety Program to Supervisory Personnel and

Employees by stressing the importance of safety and loss control. Each Subcontractor shall ensure the active participation of its project management team in Granger’s Safety Program.

9. Appoint a Safety Representative who is trained, experienced, and capable of identifying existing and potential hazards in surroundings or working conditions that are hazardous or dangerous to an employee and who has the authority and knowledge to take prompt corrective measures to eliminate the hazards. The Safety Representative will be available to Granger to administer the Safety Program and will be the go-to person for Granger. A full-time time, non-working, dedicated Safety Representative may be required with high-risk work, high manpower, by contract, or as directed by Granger. Responsibilities of any Safety Representative will include:

a. Promote total project safety among all employees and visitors.

b. Represent the subcontractor in matters concerning safety.

c. Investigate all incidents and near misses involving their Contractor / Subcontractor, including lower-tier Contractors / Subcontractors, to determine causes and take action necessary to prevent reoccurrence.

d. Confirm the completion of the Pre-Task Analysis for all work tasks.

e. Confirm the completion of the Daily Pre-Task Safety Analysis for all work tasks.

f. Follow-up on all recommendations submitted by Granger, Owner Representative, OSHA, Insurance Audits, etc.

g. Confirm that each crew is participating in the Pre-Task Safety Analysis each day.

h. Conduct weekly safety toolbox talks with its employees and assure lower tier Contractors / Subcontractors and vendors hold their own meetings.

i. Comply with the Drug-Free Workplace Program.

j. Shall ensure that all employees attend the safety orientation before working on the project.

k. Assign a designated alternate to carry out these responsibilities in the absence of the Safety Representative.

10. Each subcontractor shall adhere to substance abuse testing requirements.

a. All subcontractors working on the project will participate in the project’s Substance Abuse Testing program.

A negative ten (10) panel drug screening administered by a third-party representative is required for project access. Work will commence contingent on a negative drug screen result. Designated Michigan projects will follow the MUST Program. Owner-required programs may supersede the above requirements.

b. Each employer shall monitor employees for behavior that may indicate drug or alcohol misuse or abuse. This is a drug—and alcohol-free project. No illicit drugs or alcohol are permitted on the premises.

c. Post-accident testing is required in the event of any injury suffered by an employee, a near miss, property damage, or as directed by Granger. Post-accident testing includes a ten (10) panel test and an alcohol test.

11. Subcontractors shall provide and enforce the use of all necessary Personal Protective Equipment (PPE) on all

Granger Projects:

a. Subcontractors shall assure 100% eye protection per (ANSI Z-87.1) in all work areas.

b. Prescription glasses must have rigid side shields or over the glass’s safety glasses are to be worn.

c. Subcontractor employees performing additional tasks requiring additional eye protection shall wear goggles and/or face shields. The Granger requires face shields with safety glasses for all grinding operations.

d. Hard hats are required for all Contractor / Subcontractor employees, vendors, and visitors. The hard hat shall conform to ANSI Z89.1 and OSHA standards.

e. Welding hoods must be attached to a hard hat as required.

f. Construction-grade work boots shall be worn on this project. Safety-toed boots and/or metatarsal boots will be required on projects required by the owner.

g. Work clothes shall include shirts with a minimum 4” sleeves. Full length work pants or overalls must be worn;

shorts are not permitted on the project. No nylon or polyester clothing will be worn when welding or burning with a torch set.

h. High visibility clothing (safety vests or safety-colored shirts) will be worn at all times for this project. Reflective High Visibility safety wear shall be worn as required around earth moving equipment and nighttime work operations.

i. Subcontractors shall provide hearing protection to employees where noise is measured above 85 decibels, normal conversation cannot be conducted, or when the area is posted as a noise hazard.

j. Subcontractors shall provide work gloves appropriate to the work task. The type of hand protection identified shall be included in the Pre-Task Analysis.

k. The subcontractor shall provide and maintain fall protection equipment and devices to assure compliance with Granger’s 100% Fall Protection Policy. The equipment necessary, but not limited to body harnesses, self-retracting lifelines (SRL), beam straps and clamps, and horizontal lifelines, are needed to address the fall protection exposures that your employees encounter properly. Dual self-retracting lifelines (SRL) shall be provided, if necessary, to maintain 100% Fall Protection. Horizontal lifelines shall be certified by a qualified engineer and/or the manufacturer.

l. Subcontractors shall provide respiratory protection if the work their employees perform causes an inhalation hazard. In addition to the respirator, the subcontractor shall have a written respirator program, provide training, perform a medical evaluation for the employee wearing the respirator, and perform a fit test with the respirator that the employee will be donning on the project. Subcontractors shall provide the Granger Project Team with documentation of such.

m. The subcontractors shall follow the product SDS of all chemicals and substances they are working with and provide the required and appropriate PPE as necessary for their employees.

n. Subcontractors shall submit a Daily Rigging Inspection form to the Granger Project Team weekly. The subcontractor's certified rigger shall complete this inspection before the use of any rigging.

o. Subcontractors shall submit a Monthly Fall Protection Inspect Form to the Granger Project Team. This inspection shall be completed by the designated Fall Protection Competent Person.

12. Provide properly guarded and maintained tools, machinery, and equipment.

13. Identify and inspect golf carts, trailers, forklifts, personnel lifts, and other mobile equipment with labels or signs indicating whether the subcontractor on-site owns, rents, leases, or uses the equipment.

14. Subcontractors shall utilize Ground Fault Circuit Interrupters (GFCI) if they are not already provided with

Temporary Power for all electrical equipment, tools, and cord sets.

15. Subcontractor employees shall inspect all electrical equipment, extension cords, and tools before each use.

Defective equipment shall be taken out of service and red-tagged “Do Not Use.”

16. Extension cords and leads shall be routed (overhead in high-traffic areas) to eliminate trip hazards.

17. Notify the Granger Project Team immediately of any incident or near miss that has caused or could cause injury or damage to property.

18. Incidents requiring medical treatment shall:

a. Get prompt medical attention for your employee if needed.

b. Ensure employees who receive medical attention obtain a medical work release form from the attending physician and present it to the Granger Project Team before they return to work.

c. Subcontractor shall agree to fully support Granger’s Return to Work program and honor Light Duty/Work restrictions.

18. Subcontractors shall cooperate thoroughly with the investigation of all incidents of personal injury, property damage, and near misses.

a. Subcontractors shall participate fully and provide knowledgeable Employees as requested for incident investigations meetings conducted by the Granger Project Team, the Owner, or any Government agency (OSHA) to determine causes and corrective actions.

b. Subcontractors shall submit a preliminary report of an incident and the findings, which must be submitted to the Granger Project Team within 24 hours.

c. The subcontractor’s project management will fully support and participate in any safety “Stand down” the Granger Project Team deems necessary to communicate and increase awareness of an incident.

d. Subcontractors will institute new training and procedures for their employees, if necessary, to prevent an incident from happening again.

19. Each subcontractor shall provide continuous clean-up and maintenance of its work areas, fabrication areas, break areas, and office trailers. Each subcontractor shall properly dispose of trash and waste daily. The separation of waste shall comply with all applicable local, state, and federal standards, as well as the Owner and Granger requirements for the project. Good housekeeping conditions must be maintained throughout the duration of the project.

20. Supply and maintain adequate fire protection equipment and provide training on the use of the equipment.

21. Subcontractors shall conduct daily documented pre-use inspections of all equipment, tools, and safety devices.

Inspection records shall be made available to Granger upon request. Use of any equipment by subcontractor employees shall be limited to those employees who have been trained to utilize the equipment.

22. Assure that scaffolds are erected, maintained, and inspected daily by a Competent Person. The Competent

Person shall use a scaffold tagging system that identifies if the scaffold is safe to use. All scaffolding users shall be provided with awareness-level training. All scaffolding with work levels above six feet shall be protected by a handrail, or a fall protection system shall be utilized.

23. Subcontractors work and delivery vehicles, authorized for project use, shall not be unattended or parked within enclosed buildings. Vehicles shall be placed in designated areas and in a manner, which will not impede access of emergency apparatus/equipment. Personal vehicles shall not be allowed on the project unless approved by Granger.

24. Report all chemical and oil spills immediately to the Granger Project Team. The subcontractor shall be responsible for providing spill control, training, and clean up kits and be responsible for all costs associated with the spill.

25. Correct unsafe work habits of employees as soon as they are observed. Eliminate unsafe site conditions and promptly report those conditions you cannot eliminate to the Granger Project Team.

26. Attend all scheduled safety meetings, committee meetings, progress meetings, etc.

27. Cooperate fully with all other subcontractors in their respective safety programs.

28. Furnish all reasonable information as may be required by Granger concerning the safety of your operations, including but not limited to the following:

a. Copies of the subcontractor’s job file of Safety Data Sheets for substances/materials to be used on the Project prior to bringing substances/materials on site. An inventory log of all chemicals used on site shall be maintained.

b. Copies of completed Pre-Task Analysis.

c. Copies of equipment inspections, proof of training, and permitting to operate equipment, including but not limited to cranes, rough terrain forklifts, excavation equipment, and aerial lifts.

d. Proof of weekly Toolbox and Daily Pre-Task Safety Analysis Meetings to be submitted weekly.

e. Incident and Near Miss Reports shall be submitted for each occurrence.

f. Provide copies of all OSHA inspection reports to Granger, along with corrective action taken.

29. Provide and properly maintain warning signs and lights, barricades, railings, and other safeguards for the protection of workers and others on, about, or adjacent to the work, as required by the conditions and progress of the work and as directed by Granger.

30. Ensure that gasoline operated equipment is not operated in any enclosed buildings. During the construction phase when the building is not fully enclosed gasoline powered equipment shall be equipped with scrubbers. Scrubbers and mufflers for gasoline or diesel-powered equipment shall be per specification requirements. Subcontractors shall locate gasoline-operated equipment outside enclosed buildings or provide propane or electric power equipment for operation inside enclosed buildings.

31. A Pre-Dig Worksheet shall be completed prior to work starting on any excavation.

32. All subcontractors working on this project must utilize Granger’s Crane Action Plan. Granger Construction requires the use of a Certified Crane Operator as recognized by the National Commission for the Certification of Crane Operators (NCO) or an equivalent Accredited Testing Organization, which shall be approved by Granger's Corporate Safety. The Crane Action Plan requirements include:

a. Documentation of daily, monthly, and annual crane inspections.

b. Verification of operator certification (NCCCO / CCO required).

c. Prepare a detailed pre-lift Pre-Task Analysis and lifting plan.

d. A pre-lift meeting is required with all parties involved, including Granger, subcontractor employees, operators, and employees doing rigging.

e. Critical lifts, as defined in the Crane Action Plan, will require a Pre-lift meeting with the Granger Project Team.

f. Provide crane mats for all cranes used on Granger Projects. Crane mats are required for all surfaces, including concrete.

g. Documentation of the verified load weight of all planned crane lifts shall be provided to Granger as part of the Crane Action Plan. Load tests and certification records for all cranes shall be maintained.

A.10. Equal Employment Opportunity and Affirmative Action Policy

Granger Construction Company is committed to exercising and promoting fairness, honesty, and integrity in all business and employment practices. We are also committed to compliance with all applicable laws, standards, and regulations promulgated by governing authorities. Authorities considered in the development of this policy include the Equal Employment Opportunity Commission, Office of Federal Contract Compliance Programs, and Michigan Department of Civil Rights. This policy is intended to comply with applicable provisions of the Civil Rights Act of 1964 of the United States of America, Executive Order 11246, Section 503 of the Rehabilitation Act of 1973, the affirmative action provisions of VEVRAA, the Immigration Reform and Control Act of 1986 (IRCA), Title I of the Americans with Disabilities Act of 1990 (ADA), 42 USC, Chapters 21 and 126 and part 1981, 29 USC parts 206, 621-624, and 791 and Public Act 453 of the State of Michigan.

In this spirit, we are committed to providing work, a workplace, and a work environment with equal employment opportunities for all people without illegal harassment or discrimination. We will not discriminate, and we will not tolerate discrimination in any of our personnel practices against any qualified individual based on occupationally irrelevant prohibited factors. These factors include an individual’s race, color, religion, sex, national origin, ethnicity, disability, veteran status, and sexual orientation as specified and applicable under the governing regulations. We will also employ affirmative action to ensure equal employment opportunities.

We will make our policy known to the sources from which we receive employee applicants including trade unions, and coordinate with them to ensure compliance with this policy. Furthermore, we will inform our employees, management, staff, agents, contractors and other associated personnel of this policy and their rights and responsibilities, and we will provide them a copy of this policy where appropriate.

With respect to discrimination based on these factors, we will not:

a. fail or refuse to hire or to discharge any individual, or otherwise to discriminate against any individual with respect to his compensation, terms, conditions, or privileges of employment, nor

b. separate or classify employees or applicants for employment in any way which would deprive or tend to deprive any individual of employment opportunities or otherwise adversely affect his status as an employee, nor

c. discriminate in admission to, or employment in, any program established to provide apprenticeship or other training.

Exceptions to the practice of non-discrimination are legally allowable and may be made in certain specific instances.

Exceptions include those certain instances where religion, sex, or national origin is a bona fide occupational qualification reasonably necessary to the normal operation of that particular business or enterprise, and also instances where such discrimination is imposed upon us in the interest of national security of the United States.

We may apply different standards of compensation, or different terms, conditions, or privileges of employment pursuant to a bona fide seniority or merit system, or a system which measures earnings by quantity or quality of production or to employees who work in different locations, provided that such differences are not the result of an intention to discriminate because of race, color, religion, sex, or national origin.

We may also give and act upon the results of any professionally developed ability test provided that such test, its administration, or action upon the results is not designed, intended, or used to discriminate because of race, color, religion, sex, or national origin.

We may differentiate upon the basis of sex in determining the amount of the wages or compensation paid or to be paid to employees if such differentiation is authorized by the provisions of section 206(d) of title 29 [section 6(d) of the Fair Labor Standards Act of 1938, as amended].

We are not required to grant preferential treatment to any individual or to any group because of the race, color, religion, sex, or national origin of such individual or group on account of an imbalance that may exist with respect to the total number or percentage of persons.

We will not discriminate against an individual because he has opposed any unlawful employment practice or because he has made a charge, testified, assisted, or participated in any manner in an investigation, proceeding, or hearing regarding the civil rights cited herein.

We will not print or publish or cause to be printed or published any notice or advertisement relating to employment indicating any preference, limitation, specification, or discrimination based on race, color, religion, sex, or national origin unless this is specifically designed as an affirmative action and done in compliance with all governing authorities.

We will keep certain records (I-9 forms) for the U.S. Immigration and Naturalization Service that verify our employees’ eligibility to work in the U.S. (i.e., proof of citizenship or authorization to work.

Any employee who believes that he or she has been harassed or discriminated against has the right and is encouraged to register a complaint, giving notice of the offense and requesting resolution. All such allegations will be investigated, and appropriate remedial action will be taken. Persons over whom we have control and who are found responsible for such discrimination will be held responsible.

In an effort to resolve complaints quickly and satisfactorily, an aggrieved employee is encouraged to register the complaint in writing with each of the following persons in sequence, allowing each an opportunity to take action, and then proceed to the next person if dissatisfied with the results:

1. the offending person

2. your direct supervisor

3. your department manager

4. the company President

If it is too uncomfortable to register the complaint at any of these levels, then that level should be skipped.

Each person who receives a complaint should take the complaint seriously. He or she should make a diligent effort to determine the facts and assess the facts to determine if a violation of company policy, a collective bargaining agreement, and/or employment law has occurred. If it has, the exact nature of the violation should be determined, along with the type of remedial action that is appropriate and satisfactory. Then, steps should be taken to implement the remedial action, including steps to prevent future violations. At all stages, documentation and records should be made, and higher company authority should be consulted as appropriate. In all cases, we will comply with all employment laws, then with binding collective bargaining agreements, and then with this and other company policies.

A.11. Harassment Prevention Policy

Overview

Harassment will not be tolerated. As required by applicable laws, the Granger Construction Company prohibits harassment of our employees and the employees of our contractors, clients, and suppliers in any form. Our intent is to create and maintain an environment that promotes respect and dignity for all individuals and is free of harassment and unduly offensive behavior. Harassment, as defined in various forms below, is in conflict with a harmonious and productive work environment. Violation of this harassment policy may result in severe disciplinary penalties, including immediate discharge.

To ensure our company is free of harassment, Granger Construction Company has implemented Preventing Sexual Harassment training. This training is mandatory for all Company employees. Sexual Harassment training will be an ongoing process and must be successfully passed every two years by all employees. The results of the training will be tracked and recorded in your personnel file. You will be contacted within the first month of your employment to execute the training.

Sexual and Gender Harassment

Sexual harassment is defined by law to include any unwelcomed sexual advance or touching, request for sexual favors, or other verbal, nonverbal, or physical communication of a sexual nature if:

1. submission to such conduct is a term or condition of employment or continued employment, whether explicitly or implicitly or

2. submission to or rejection of such conduct is used as a factor in decisions affecting the individual’s employment or

3. such conduct or communication substantially interferes with the individual’s employment or creates an intimidating, hostile, or offensive work environment.

Examples

Examples of prohibited sexual harassment would include the following:

1. offensive sexual flirtations

2. suggestive comments

3. sexual innuendo

4. jokes about sexual topics

5. use of sexually degrading words or humor.

6. insults or verbal abuse of a sexual nature

7. graphic verbal commentaries about an individual’s body

8. display of sexually suggestive objects or pictures.

9. vulgar words of a sexual nature

10. non-verbal, suggestive, or sexually insulting actions

11. such as leering, whistling, suggestive sounds, and obscene gestures

12. repeated requests or…