– Where Safety Works –
Health and Safety Plan
REV. 2
Message from the Executive Office….
The safety and well-being of our employees is our management’s
first priority. Costello Industries will ensure safe working
conditions on all job sites, and eliminate any unsafe, unsanitary
or hazardous conditions found in the workplace. Safety policies
and management practices, however, are not sufficient by
themselves - safety is the responsibility of each employee. It is
the duty of every employee to adhere to all health and safety
rules, policies and procedures. It is also the responsibility of all
employees to always maintain a focus on safe practices. Safe
judgment and common sense are key.
This booklet has been prepared in an effort to make you aware of
how we can safely approach the potential hazards inherent in
many construction projects. The policies and practices that are
put forth in the following pages will not cover every possible
situation that may arise; I ask that you adhere to these
guidelines, but that you also adopt a “work safe” philosophy.
Best regards,
__________
John Costello
President
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TABLE OF CONTENTS
Subject
Page
Safety Statement
4
Assignment of Responsibilities
4
OSHA Training
7
Right to Know / Hazard Communication
7
Bloodborne Pathogen
8
Lockout/Tagout
9
Personal Protective Equipment (PPE)
10
Hearing Protection
10
Respiratory Protection
11
Safety Violations and Employee Discipline
11
Substance Abuse
12
Crisis Management
13
Accident Reporting and Investigation
13
Worker’s Compensation and Returning to Work
14
Job Safety Analyses (JSA) Policy Statement
14
Tool Box Meetings
14
Flammable and Explosive Material
14
Safety on and Around Equipment
15
Traffic Control
15
Vehicles and Equipment on and/or off Job Sites
16
Company Vehicle Policy
16
Fire Prevention and Protection
21
Welding and Cutting
21
Call Before You Dig
22
Hand and Power Tools
22
Abrasive Blasting
22
Use of Electrical or Power Actuated Tools
22
Ergonomic Injury Prevention and Safe Lifting Plan Policy
23
Premises Liability Risk Control Policy
25
Emergency Action Plan
26
Top 10 Tips
28
Receipt of Health and Safety Handbook
29
3
Safety Statement
The safety of employees is of paramount importance. Our goal is to provide an accident-free work
environment. It is our policy to perform work in the safest manner possible, consistent with good
construction practices. To fulfill the requirements of this policy, an organized and effective safety program
must be carried out wherever work is performed.
Safety must be considered first. It is more important than production, schedule, quality and profit.
It cannot be compromised.
Safety is not only a responsibility of management; it is also a responsibility of every employee.
A commitment to safety is a commitment to doing things right – the first time. Ultimately, this
results in elimination of injury and optimization of all activities.
All accidents and injuries are preventable. All accidents are the result of unsafe acts or unsafe
conditions.
Every task must be performed with a concern for safety for our fellow employees, subcontractors,
customers, and the general public.
Our Commitment
The emphasis of our program is on prevention. We will look for unsafe acts and conditions that
can cause accidents rather than having to react to accidents. When we are faced with accidents
or incidents, we will work to analyze what happened and correct the problem to avoid future
mishaps.
We will maintain a safe and healthful working environment by assuring, at all times, that our
projects and personnel are in compliance with the company’s safety policies as well as federal,
state and local regulations.
We will minimize hazards through engineering controls, administrative controls and/or personal
protective equipment.
We will maintain an active and aggressive program to promote safety awareness among our
employees.
We will strive to provide the most advanced training and appropriate tools and equipment to
enable our workers to perform their jobs correctly and safely.
We will ensure the provision of high quality first aid, medical, and rehabilitative treatment for work
related injuries and illnesses.
It is the responsibility of all employees of this company, regardless of the capacity in which they
function, to make safety and health a prime concern. All employees will be accountable for their
safety performance.
The promotion, implementation and enforcement of the company’s safety and health plan are the
direct responsibility of all officers, management, and staff.
Only by the joint cooperation of employees and management in the observance of this policy can
we assure safe working conditions and obtain our goal of accident-free performance.
Assignment of Responsibilities
Senior Management
Senior Management shall promote an effective and efficient safety and health program structured to
eliminate or reduce loss or harm to employees, materials and equipment through systematic
endorsement, enforcement and assignment of program responsibilities.
Middle “Project” Management
The position of Middle Management is emphasized under this program because of the key management
role exercised by this department. The success of the company’s safety and health plan depends in large
measure on Middle Management’s input. Middle Management shall assist and support field management
in establishing, maintaining and enforcing an effective safety program through the following methods:
Recommend and assist in the development and initiation of both general and specific safety
training programs.
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Research and recommend specialized equipment, techniques and procedures designed to
prevent or minimize hazard potential.
Recommend and coordinate the purchase of all required safety equipment, apparel and supplies.
Maintain a current roster of all qualified First Aid-trained personnel. Coordinate the training or revalidating of approved emergency techniques.
Review and assure that there are valid and current equipment inspection reports.
Coordinate and provide projects with various safety posters, required employee notices and
government regulations.
Review Supervisors’ Accident Report Forms for causes of accidents and recommended
preventive actions.
Investigate all serious lost-time injuries and equipment damage through on-site inspections and
interviews. Provide a detailed report of cause and recommended preventive measures.
Investigate alleged OSHA violations and file a report of findings.
Accompany OSHA inspectors.
Require frequent safety status reports from each project.
Maintain appropriate safety reference materials, first aid supplies and personal protective
equipment.
Require submittal of a statement of the facts, cause of, reason for lack of safety precautions for,
and corrective action taken for each occurrence of personal injury, equipment damage and/or
citation issued.
Insure that Safety Committee inspections, “Tool Box Meetings” and weekly safety inspections are
regularly and routinely completed.
Maintain a lost time incidence rate equal to or better than the established company goal.
Require the completion of the Pre-Construction Surveys before any job commences.
Insure that a meeting be held between Middle Management and Field Management within 72
hours after a lost time accident to discuss possible causes for the injury and ways to prevent it
from occurring again.
Field Management
The key to achieving results in the field rests with supervision. The success of a safety program is no
different. The supervisory position automatically includes the responsibility to assure, at all times, that the
project and its personnel are in compliance with the company’s safety program as well as federal, state
and local regulations.
Conduct project safety inspections and review violations and recommend corrective action to
Middle Management.
Recommend disciplinary action for any employee who is observed violating, is a repeat violator of,
or unwilling to comply with, established or recommended safety/health policies and procedures.
Conduct special safety inspections with insurance company safety engineers.
Prepare and coordinate required project “Tool Box” talks.
The highest supervision on the project shall be responsible for the overall safety program on the
project. Field Management shall be responsible for insuring that subcontractors and suppliers
comply with the Company’s Health and Safety Program.
Getting the safety program organized and in operation at the start of job is important. Many
serious accidents can occur during mobilization and early weeks of construction, particularly
among new hires.
Consider safety factors in all of your operational planning, provide for personal protective
equipment, barricades, machine guards, warning signs, fire extinguisher, etc., ahead of need.
Plan to minimize hazards, just as you plan your production efforts.
Check out all heavy equipment operators carefully. Be sure they are qualified and complete the
daily portion of the equipment logs.
Hold weekly or more frequent supervisory meetings starting the first week of the project, even if
there are only several employees available to attend.
Establish a fixed time for “Tool Box” talks. See that each group leader holds regularly. It is
important to get the habit started at the beginning of the project. Insure that good discussion of
topic occurs at each session and return signed minutes to the home office.
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Never allow workers to short-cut safety for expediency. Safe working conditions will always give
you better costs in the long run.
Look for unsafe acts and conditions constantly. Correct them immediately.
Establish specific safety rules on matters of importance. Make sure they are known and
understood by all concerned. Enforce them constantly. Disciplinary action must be taken against
anyone who violates these rules for his or her own protection and the protection of others.
Provide for adequate temporary sanitary facilities with regular servicing (as dictated by each job).
Provide for drinking water from an approved local source to be dispensed from a labeled,
insulated container. Paper cups shall be provided at each drinking water container. Fresh water
shall be provided daily.
Provide for the protection of the general public throughout the duration of the project.
Be responsible for good housekeeping on the project.
Cooperate with the insurance carrier engineers and compliance officers.
Participate in all company safety-training programs.
Field Management will be held accountable for maintaining or improving the lost time incident rate
goal.
Notify middle management of an OSHA inspection.
Employees
It is the duty of all employees to know the following safety rules and to do their work in compliance with
these rules. It is also the duty of all employees to make full use of safeguards provided for their
protection.
Report all unsafe conditions to your supervisor immediately.
Report all injuries, not matter how slight, to your supervisor or Middle Management immediately.
The written injury report must be submitted to Middle Management within 24 hours of the
accident.
Wear a hard hat and safety glasses on the job site at all times. Additional personal protective
equipment may be required during operations as specified by the supervisor, job conditions or
client. This could include work gloves, reflector vest, car protection, steel toe boots, etc.
Dress properly, wear appropriate work clothes (pants and shirt). Loose clothing or un-tucked
clothing is not permitted. Short pants are not permitted. Do not wear excess jewelry.
Wear goggles (or a face shield over your glasses) while you are jack hammering, sand blasting,
grinding, drilling, cutting or using power activated tools, working with chemical or hot substances,
or as required by field conditions.
Wear ear protection when operating a jackhammer, using power actuated tools or doing any work
producing excessive noise.
Wear a respirator or a dust mask when working in or around dusty areas or while operating
equipment that produces dust. Wear the proper protection when you are exposed to noxious
fumes or gases. Always check with Field Management if these conditions exist.
Practice good housekeeping at all times. Do not leave materials in aisles, walkways, stairways,
roads, sidewalks or other work areas with means of access or egress.
Fall protection: Guardrails, Personal Fall Arrest Systems (PFAS) or other acceptable prevention
measures are required wherever an employee is exposed to a fall hazard of 6 feet or more.
Covers or guardrails are required where there are floor openings between levels.
Keep all tools in safe working condition and inspect all tools before use. Never use defective tools
or power equipment. Report them to your supervisor immediately.
Never operate any machine or power tool unless all guards and safety devices are in place and in
proper operating condition.
Do not operate or let anyone else operate any machinery, equipment or vehicles that you or they
are not qualified (or authorized) to use.
Do not ride on any part of any vehicle or equipment that was not designed for passengers or
drivers. Seatbelt use is required when traveling on public roads or highways.
Whenever possible, sling all lifted loads with tag lines. Be alert and keep out from under overhead
loads, and never let anyone walk under your overhead loads.
Horseplay, practical jokes and fighting will not be tolerated at any time.
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The possession, use or being under the influence of alcohol or controlled substances is strictly
prohibited, whether at a jobsite, on company property, in any company buildings including trailers,
or in any company vehicle (refer to Substance Abuse section of this handbook).
All posted safety rules must be obeyed and must not be removed without proper authorization.
Obey ALL posted traffic signs at ALL times and all traffic laws when operating a motor vehicle.
Firearms or weapons are not allowed at any time (a) on any jobsite (b) on any company property
(c) in any company buildings including trailers (d) in any company vehicle.
Hair growing over the collar shall be contained underneath a hard hat (male or female). Facial
hair must comply with the requirements of the job.
Compressed gas cylinders must be kept upright and secured at all times, full or empty.
A fully charged fire extinguisher must be present while using torches, welding, cutting metal with a
cut off saw or doing any work which produces sparks or flame.
Welders shall wear approved hard hat / face shield combination and heavy, long sleeved shirts or
leather protection with pockets that have buttoned flaps (or no pockets).
Welders should not wear lightweight outer garments while welding. Never carry disposable
lighters, lighter fluid or matches while welding or torching.
Welders must wear high top leather boots (fully laced).
Vehicles and equipment must be shut off when being lubricated, refueled, adjusted or when not in
use. Follow lockout/tagout requirements.
All employees must comply with ALL federal, state and local OSHA safety regulations at all times.
Most importantly, when in doubt, ASK. Ask your supervisor or Middle Management whenever
there is something about your work that you do not understand
OSHA Training
As required by the owner or authorized agency, the company will comply with all OSHA regulations and
OSHA 30 training.
Safety Compliance Programs
Right to Know / Hazard Communication
This program complies with the OSHA Hazard Communication Standard by compiling a hazardous chemicals
list, by using MSDS’s, by ensuring that containers are labeled, and by providing employees with training. This
program applies to all work operations in our company where employees may be exposed to hazardous
substances under normal working conditions or during an emergency situation.
Under this program, employees will be informed of the contents of the Hazard Communication Standard, the
hazardous properties of chemicals with which they work, safe handling procedures, and measures to take to
protect themselves from these chemicals. Employees will also be informed of the hazards associated with
non-routine tasks.
List of Hazardous Chemicals
A list of all hazardous chemicals will be maintained. The master list of chemicals identifies all of the chemicals
used in the company. Each list also identifies the corresponding MSDS for each chemical.
Labels and Other Forms of Warning
It will be ensured that all hazardous chemicals used by Costello Industries are properly labeled and
updated, as necessary. Labels should list the chemical identity, appropriate hazard warnings, and the
name and address of the manufacturer, importer or other responsible party.
Non-Routine Tasks
When employees are required to perform hazardous non-routine tasks a special training session will be
conducted to inform them of the hazardous chemicals to which they might be exposed and the proper
precautions to take to reduce or avoid exposure.
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Training
Everyone who works with or is potentially exposed to hazardous chemicals will receive initial training on
the Hazard Communication Standard and the safe use of those hazardous chemicals. Whenever a new
hazard is introduced, additional training will be provided.
The training plan will emphasize these items:
Summary of the standard and this written program.
Chemical and physical properties of hazardous materials (e.g., flash point, reactivity).
Physical hazards of chemicals (e.g., potential for fire, explosion, etc.).
Health hazards, including signs and symptoms of exposure, associated with exposure to
chemicals and any medical condition known to be aggravated by exposure to the chemical.
Procedures to protect against hazards (e.g., personal protective equipment required, proper use
and maintenance of personal protective equipment, work practices or methods to assure proper
use and handling of chemicals, and procedures for emergency response).
Where MSDS’s are located, how to read and interpret the information on both labels and MSDS’s
and how employees may obtain additional hazard information.
Contractors
Outside contractors will be notified of any chemical hazards that may be encountered in the normal course
of their work with Costello Industries. Such notification will include the labeling system in use, the
protective measures to be taken, and the safe handling procedures to be used. In addition, contractors will
be notified of the location and availability of MSDS’s. Each contractor bringing chemicals on-site must
provide the company with the appropriate hazard information on these substances, including the labels
used and precautionary measures to be taken in working with these chemicals.
Bloodborne Pathogen
Scope
Costello Industries is dedicated to the protection of its employees from on-the-job injuries. All employees
of Costello Industries have the responsibility to work safely on the job. The purpose of this plan is to
ensure that our employees are aware of pathogenic microorganisms that are present in human blood and
other body fluids that can cause disease such as HVB, hepatitis B virus or HIV, human immunodeficiency.
Employees must be aware of how to handle possible exposure to these pathogens when encountered
during the course of regular work activities.
Procedure
Should an accident or incident occur in which an employee sustains an injury, or happens upon a
suspected bodily fluid spill during the normal course of their duties, universal precautions shall be
observed to prevent contact with blood and other potentially infectious materials. (A universal precaution is
an approach to infection control in which all body fluids shall be considered potentially infectious
materials.) Disposable gloves shall be worn when making contact with blood, mucous membranes, other
potentially infectious materials and non-intact skin.
When feasible, such as when an employee cuts their finger and only requires a Band-Aid, that employee
should be responsible for his or her cleaning up of any contaminated areas. Alternatively, a designated
person who is trained to use the proper materials while decontaminating could do any clean up. If the
bodily fluid spill is major, an outside qualified decontamination service may be utilized. Contaminated
surfaces shall be cleaned with an appropriate disinfectant such as bleach, and shall be done immediately
after any spill of blood or other potentially infectious materials on any surface.
All cleanup materials shall be disposed of properly in a plastic bag that can be sealed.
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Training
Any Costello Industries employee who may be potentially "exposed" to a bodily fluid spill will receive initial
training and any necessary retraining on Bloodborne Pathogens Safety including the safe, effective use of
universal precautions.
"Exposure" means that an employee encounters a bodily fluid spill, or comes in contact with a sharp
object that may be contaminated with a Bloodborne Pathogen, in the course of employment.
Our goal is to ensure employee comprehension and understanding of this important topic, including being
aware that they may be exposed these hazardous substances during the normal course of their duties.
Our Safety Manager or his designate asks for input from employees regarding the training they have
received, and their suggestions for improving it. In this way, we hope to reduce any incidence of
Bloodborne Pathogen exposure.
Training Content
Training content is organized so all Costello Industries employees receive the same level of training on
Bloodborne Pathogens annually. In addition to this annual training, we conduct Tool Box Talks periodically
as refresher level training. The training plan emphasizes these elements:
Summary of the standard and this written program, including what hazardous bodily fluids may be
present at our client sites
The potential consequences of accidental contamination with these types of bodily fluids
The proper method to protect or safeguard from exposure to these bodily fluids.
Enforcement
Constant awareness of and respect for hazardous materials, and compliance with all safety rules are
considered conditions of employment. Costello Industries reserves the right to issue disciplinary warnings
to employees, up to and including termination, for failure to follow the guidelines of this program.
Lockout/Tagout
This Lockout/Tagout program will help safeguard employees from the unexpected startup of machines or
equipment or release of hazardous energy while they are performing servicing or maintenance.
Basic Rules
All equipment shall be locked/tagged out to protect against accidental or inadvertent operation
when such operation could cause injury to personnel.
Do not attempt to operate any switch, valve, or other energy-isolating device where it is
locked/tagged out.
Training
Each authorized employee shall be trained in the recognition of hazardous energy sources and the
methods and means necessary for energy isolation and control. Each affected employee
shall be instructed in the purpose and use of the energy control procedure. All other employees whose
work operations may be in an area where lockout/tagout could occur shall be instructed about the
procedures relating to the restarting or re-energizing of machines which are locked/tagged out.
Steps for Lockout/Tagout
The authorized employee or supervisor will notify all affected employees that a lockout/tagout
system is going to be utilized.
If the machine is operating, shut it down by the normal stopping procedure. The authorized
employee will then identify the energy isolating devices defined in the procedure.
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Isolate all hazardous energy. Turn off all electrical switches. Disable main power.
After ensuring that no personnel are exposed, perform a complete test. Push start buttons and
test circuits on all normal operating controls to make certain the equipment will not operate.
Authorized employees are to work only with other authorized employees while performing
lockout/tagout operations.
Upon job completion, the authorized employee or supervisor will notify affected employees that
lockout/tagout is ready to be removed. The authorized employee(s) may now remove their
respective lockout/tagout devices.
Personal Protective Equipment (PPE)
The majority of our work is done within work zones on active roadways; thus it is imperative that each
member of our team be as visible as possible to motorists, fellow employees and any other persons within
or adjacent to a work zone. Our corporate safety and health policy requires that all employees wear
proper protective equipment (PPE) during their work shifts (ie: Hard hats, reflective safety vests, safety
glasses, ear plugs, work gloves, etc).
General PPE Rules
Hard hats shall be worn on all projects and around shop areas at all times.
Employees working on a pavement maintenance crew which is not subject to overhead hazards
or owner restrictions (limited to crack sealing, infrared and pavement fabric jobs) have the option
of wearing either a reflective hat or a reflective yellow safety cap.
Safety goggles are to be worn by all employees when exposed to flying materials and dust.
Face and respiratory protection shall be worn when employees are exposed to flying particles or
dust (see Respiratory Protection section).
Appropriate gloves shall be worn when handling wire, mesh, rough or sharp edged material,
lumber with splinters and projecting nails or when handling other hazardous material. Leather or
leather soled gloves are recommended.
Only substantial heavy soled shoes or boots shall be worn on the job. Safety (steel) toe shoes are
recommended for all workers. Low cut shoes or sneakers are not allowed.
Earplugs or muffs are to be worn when in an area of high noise level (see Hearing Protection
Policy).
Everyone shall wear appropriate clothing for all duties to be performed. Large pockets, loose
flowing ties, finger rings, exposed watch or key chains, cuffed trousers or loose, torn clothing are
dangerous and must not be worn around machinery or when climbing ladders while working on
structures.
All field personnel (while working on a public right of way) must wear a reflective safety vest, and
will be required to use a flag and/or a sign paddle. Reflectorized garments will be worn at night.
Oxyacetylene welding or cutting without the proper protection is prohibited.
A welder must wear flame resistant gauntlet gloves except when engaging in light work. A fivepound fire extinguisher must be readily accessible.
Hearing Protection
In some work situations it is not feasible to reduce noise levels or duration of employee exposure to noise.
Exposure to high noise levels can cause hearing loss or impairment. It can also create physical and
psychological stress. There is no cure for noise-induced hearing loss.
Employees working in excessively noisy areas must wear hearing protection. Hearing protection
devices inserted in the ear must be fitted or determined individually by a competent person. Ear
muffs or plugs should be used for work when an employee is exposed to excessive noise levels
for extended periods of time.
Cotton is not an acceptable substitute for prescribed hearing protection.
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Respiratory Protection
Appropriate respiratory devices will be provided to employees when there is a possibility of harmful
exposure. Employees must wear respiratory protective devices at all times when there is a possible
exposure to hazardous materials. Only respirators tested and certified by the National Institute for
Occupational Safety and Health (NIOSH) will be used. Also important is that cartridges and related
equipment selected for use be appropriate for the hazardous substances(s) encountered.
Respiratory Protection Program - (Voluntary)
General Policy
Costello Industries has conducted a hazard assessment of its operations with the goal of establishing an
effective PPE program. As a result of this assessment, our company has concluded that all respirator
use by our employees is VOLUNTARY. Costello Industries provides air-filtering respirators (N95
Disposable) for employees to use if they choose. All requirements for a respiratory protection program
and training have been met. References: OSHA Standards Respiratory Protection (29 CFR 1910.134).
Responsibilities
All Employees shall follow the requirements of this Respiratory Protection Program.
Employees
All employees who voluntarily choose to wear an N95 paper filtration respirator will complete an Appendix
D voluntary use form (see below).
Management
•
Implement the requirements of this program;
•
Provide a selection of respirators as required;
•
Enforce all provisions of this program; and
•
Our Safety Manager shall administer the respiratory protection program.
Program Administrator
•
Review sanitation/storage procedures.
•
Ensure respirators are properly stored, inspected and maintained;
•
Monitor compliance for this program;
•
Provide training for affected Employees; and
•
Review compliance and ensure proper application in the field of all respirators.
Designated Occupational Health Care Provider
•
Review medical questionnaires filled out by employees who use respirators voluntarily
Safety Violations and Employee Discipline
A “Minor” violation is a safety violation that occurs without intent to bypass safety regulations and is not
likely to cause serious physical injury or death to yourself or another employee.
A “Serious” violation occurs when an employee bypasses a safety regulation that could cause an accident
that would most likely result in serious physical harm or death to yourself or others.
A “Willful” violation occurs when an employee intentionally neglects a safety rule or regulation which puts
himself or others in direct and immediate danger or serious physical harm or death.
Any violation of a company rule or procedure that is not defined specifically in the above definitions will be
classified by Middle Management at the time of occurrence. Penalties will then be determined. Costello
Industries reserves the right to alter the penalties for any violation in any class up to and including the
maximum penalty as determined by the circumstances of the violation or the attitude of the employee in
question.
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The following is a list of safety violations by class. The number of each violation and the penalty assigned
to each are as follows:
Type of Violation
st
1 Minor
nd
2 Minor
rd
3 Minor
st
1 Serious
st
1 Willful
Penalty
Verbal Warning
Written Warning
Termination
Termination
Termination
Substance Abuse
Costello Industries, Inc. has an obligation to its employees, contractors and the public at large to take the
necessary and reasonable steps to assure safety in the workplace. The use of alcohol and drugs poses a
serious threat to all of us, and we intend to do all we can to maintain a safe, healthy and productive
working environment. Therefore, the company has adopted the following policies.
Alcohol
The possession, use, purchase, sale or transfer of alcohol on company property (including the parking
lot), or in company vehicles (either owned by or leased to the company) while on company business, is
strictly prohibited. Employees may not consume alcohol on or off company property during working hours,
lunch periods, breaks or relief periods. Employees may not report to work under the influence of alcohol.
“Under the influence”, for purposes of this policy, means that the employee is affected by alcohol or drugs
or the combination of both in any detectable manner. This may be established by professional opinion, a
scientifically valid test or in some cases by observation of impairment of physical or mental ability, such as
slurring of speech, difficulty in maintaining balance, etc.
Prescription Medication and Legal Drugs
The company recognizes that employees sometimes use legal prescription or over-the-counter drugs to
alleviate or cure medical conditions. These drugs may impair judgment, coordination, or other senses, or
otherwise adversely affect the employee’s ability to perform work in a safe and productive manner.
Therefore, employees using legal drugs that are likely to affect the safety of themselves, fellow
employees, or customers, must notify a company manager who will determine if normal job duties may be
continued or accommodated. By this policy the Company in no manner seeks to discover whether
employees have a medical disability or the nature or severity of such disability.
Illegal Drugs and Substance Abuse
Illegal drugs and substances are those which cannot be legally obtained, including controlled dangerous
substances and controlled substance analogs, as well as those drugs which, although legal, have been
illegally obtained (i.e. prescribed drugs not being used for prescribed purposes, including amphetamines
and barbiturates). Examples of illegal drugs include: marijuana, cocaine, crack, heroine, morphine,
phencyclidine (PCP), hallucinogens, narcotics, etc. The possession, use, purchase, sale or transfer of
any amount of an illegal drug or substance on company property, in company vehicles, or while on
company business is strictly prohibited. Employees may not use or consume illegal drugs or substances
on or off company property during working hours, lunch periods, or break or relief periods. Employees
may not report to work under the influence of illegal drugs or substance.
Discharge for Substance Abuse
A violation of any of the above rules is grounds for immediate discharge. In addition, employees convicted
of illegal drug charges will also be discharged, and Costello Industries, Inc. reserves the right to take such
action if employees are involved with illegal drugs or substances in a manner considered detrimental to
the interest of Costello Industries, Inc., i.e. such as if the employee engages in the purchase or sale of
illegal drugs away from Costello Industries premises, on the employee’s own non-working time.
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Drug Paraphernalia
Employees are prohibited from bringing drug paraphernalia onto company property at any time. Any
employee violating this rule shall be subject to immediate discipline, up to and including discharge.
Reporting Substance Abuse Violations
Each employee is required to immediately report any violation of the company’s policy on alcohol, drugs
and controlled substances to his or her supervisor. An employee who fails to report such a violation is
subject to disciplinary action, up to and including discharge.
Inspection of Lockers, Possessions and Vehicles
When Costello Industries has reason to believe that an employee is in violation of the company’s alcohol
and drug policies, he or she may be asked to submit immediately to a search of his or her person and/or
to make his or her locker, lunch box, briefcase, purse, package, personal belongings, desk, vehicles, or
any other belongings available for inspection. Such search or inspection shall always be conducted in the
presence of at least one witness other than the company representative performing the search or
inspection, and the contents resulting from such search shall be inventoried. Entry onto the Costello
Industries property constitutes consent to search and inspection. Refusal to consent to search or
inspection shall be considered grounds for which an employee may be disciplined, up to and including
discharge.
Crisis Management
Construction is one of the most dangerous occupations in the world. The hazards posed by construction
work have been found to be significant.
The following steps should be taken immediately should an accident with injuries occur:
Call 911 and request medical emergency assistance. Give detailed directions to the area where
the injured are located.
Shut down the job and do not move anything at the scene.
Certified personnel should administer first aid (if appropriate).
Call the home office and speak to Middle Management or Senior Management.
Gather all employees in one central location away from any injured.
Start to gather the facts surrounding the accident.
Do not speak to anyone about the incident unless you are directed to do so by your supervisor
(i.e. especially the media).
Once the appropriate parties have gathered their facts the crew can be dismissed.
Accident Reporting and Investigation
An accident is defined as: “An occurrence in a sequence of events which usually produces unintended
injury, death or property damage.”
Any accident that occurs, no matter how minor it may be, must be reported on proper Costello accident
reporting forms. Field Management must investigate the accident as soon as possible to get the facts in
order to determine the cause of the accident, the factors contributing to the cause of the accident, and
prescribe corrective action to ensure this type of accident does not occur again.
After completing the investigation, an accident report MUST be submitted on the proper Costello
Industries accident reporting form by the supervisor to Middle Management within 24 hours of notification
of the incident.
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Accident Checklist
Get the facts
Determine the cause
Determine the method of prevention
Take action
Report to management
Follow up
Worker’s Compensation and Returning to Work
Should you become ill or injured as a result of your job with Costello Industries, you may be eligible for
Worker’s Compensation benefits. Any work related illness, injury, or accident (no matter how minor) must
be reported immediately to your supervisor. Failing to immediately report an injury, accident, or illness
may result in a delay or a rejection of Worker’s Compensation benefits. Both you and your manager will
be asked to complete an Accident Report Form. The Company will make available to you a panel of
medical practitioners to provide initial medical treatment and assessment for work related illness and
injury. You will be required to provide documentation from the treating physician that you are capable of
returning to work, (in any capacity). Questions regarding Worker’s Compensation benefits should be
directed to your supervisor.
Costello Industries adopts an aggressive, but sensible “Return-to-Work” program. First and foremost is
the concern for the injured employee’s treatment and rehabilitation. It is the company’s mission to enable
the injured employee to return to work as soon as possible. Sometimes, because of physical limitation
caused by injury, the employee is temporarily unable to assume their regular job. In such cases the
company will attempt to modify the duties of the employee’s job to conform to their medical limitations. At
other times, the employee may be assigned to perform the duties of a completely different job until their
restrictions are lifted. The goal is to ensure that the employee is both active and performing functions that
are helpful to the company, while placing the employee on a path toward resuming their normal job.
Job Safety Analyses (JSA) Policy Statement
Costello Industries is committed to the process of job safety analysis (JSA) as an effective method of
hazard recognition and control. The JSA is a documented, systematic process that identifies and
assesses existing and potential health and safety hazards associated with particular tasks or jobs.
Controls are developed to eliminate or effectively manage these hazards, and then integrated into the
safety program.
High-risk jobs and tasks are to be considered and completed first. Jobs that are dangerous, new,
modified or rarely performed would be considered high risk. The remaining jobs and tasks would be
completed in order of priority. It should be understood that this process will take a considerable amount of
time to complete. The expectation from OSHA is to have a plan to complete the high and moderate risk
jobs in a reasonable time frame.
Tool Box Safety Meetings
Field Management must plan and conduct a five to ten minute safety meeting on the job once a week.
Supervisors must encourage employee participation through questions and discussion. The meeting must
be documented on the meeting form itself with the signature of those employees who were present. This
must be submitted to Middle Management for proper record keeping.
Flammable and Explosive Material
Gasoline must never be used as a cleaning agent. A solvent with a high flash point must be used.
There shall be no siphoning of gasoline by the mouth. Ingestion of gasoline can be fatal.
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Fuel cans are to be approved type and not stored near combustible material or adjacent to areas
where welding or cutting is performed.
Smoking is not permitted in fueling areas.
Only authorized persons shall handle explosives.
Compressed air is not to be used to blow dirt from clothing, played with or blown at another
person.
Oxygen and acetylene bottles are to be stored in an upright position with tops on and well
secured.
Oxygen cylinders in storage shall be separated from fuel gas cylinders or combustible materials,
especially oil or grease, a minimum distance of 20 feet or by a noncombustible barrier at least five
feet high having a fire-resistant rating of at least one-half hour.
Safety on and Around Equipment
Only authorized persons shall be allowed to operate or ride on trucks or other equipment.
Operators of mobile equipment must not allow anyone to ride on running board, catwalks, steps,
buckets or draw bars.
Operators and drivers must be sure that windshield, lights, and windows are clean and free from
obstruction.
Seat belts shall be provided and must be used on/in applicable equipment. This is a mandatory
policy and applies to anyone who drives, operates or is a passenger on/in company
equipment or vehicles.
Operators should always check to make certain that other people are in the clear before they
initially start their equipment.
Before backing up any type of equipment, the driver will sound the horn. If the vehicle has an
obstructed rear view, a back up alarm will be employed, or the driver shall be directed by a
signalman.
Machine guards must be kept in place at all times except when making repairs. When making
repairs, the equipment must be de-energized and, when appropriate, locked out.
No piece of equipment shall be repaired or fueled when the motor is running.
Jacks or chain hoists should not be depended on to support vehicles under which people are
working. Blocks are to be used to protect the workers in the event the jacks or hoist fails.
Riding material platforms are prohibited unless equipped with appropriate safety devices.
If a power line is contacted, all personnel should be kept away from the machine. The operator
should stay with the machine until the boom is cleared.
Before getting off equipment, operators shall lower all buckets, blades and/or brooms to the
ground.
Equipment that is not in proper condition shall be locked out of service and tagged.
Ladders are to be of proper design and tied off whenever possible. Do not go up or down a ladder
without the free use of both hands. If material or tools have to be handled, use a rope to lift or
lower them. Always face the ladder when climbing or descending.
Traffic Control
When work encroaches upon or is in the close proximity to traveled roadways, traffic control
measures will be utilized in accordance with the authorizing agency, and following State or Federal
standards for uniform traffic control signs and devices.
Barricades and warning and direction signs of sufficient size and number will be placed at
appropriate locations to warn the public of lane closures and other traffic control measures.
The condition of traffic control devices will be monitored continuously to ensure their proper
operation.
Traffic control devices should be removed or covered upon completion of the work protected by
such devices.
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All personnel on any project who are exposed to motor vehicle traffic will wear reflective vests or
other equivalent high visibility apparel. In some cases, reflective pants may be required.
As required by the owner or authorized agency, certified personnel or uniformed police officers will
be utilized to assist with maintenance and protection of traffic.
Traffic persons will be trained as required by the owner or authorized agency. As required by the
owner or authorized agency, traffic control supervisory personnel will be trained and certified in
traffic control.
NOTE: Traffic control signs and devices will conform to the “Manual of Uniform Traffic Control
Devices for Streets and Highways”, published by the U.S. Department of Transportation or
State Equivalent.
Vehicles and Equipment on and/or off Job Sites
Backup alarms are mandatory on all company trucks and equipment and on all subcontractor
trucks and equipment.
As required by the owner or authorized agency, warning lights shall be utilized on all trucks and
equipment in or around each job site.
The Federal Motor Carrier Safety Regulations apply to all employers, employees and commercial
motor vehicles, which transport property or passengers in interstate commerce.
Every employee must be knowledgeable of and comply with all regulations contained in the Motor
Carrier Safety Regulations in 49 CFR.
Every driver shall be instructed regarding, and shall comply with, all applicable regulations in this
manual.
All motor vehicle equipment and accessories shall be maintained in compliance with these
regulations.
Company Vehicle Policy
Policy Statement
The Costello Industries Vehicle Policy establishes guidelines and procedures to be followed to protect the
safety of individuals operating any company motor vehicle on or off company business. Protecting our
employee drivers, their passengers and the general public is of the highest priority to the Company.
The commitment of management and employees is critical to the success of this policy. Clear
communication and strict adherence to the policy’s guidelines and procedures are essential.
The primary goal of the Company Vehicle Policy is to maintain a high level of safety awareness and foster
responsible driving behavior. Driver safety awareness and responsible driving behavior will significantly
decrease the frequency of motor vehicle accidents and reduce the severity of personal injuries as well as
property damage. Personnel who are assigned company vehicles or those who may drive a company
owned vehicle from time to time, must follow the requirements outlined in this policy. Personnel who
violate this policy are subject to disciplinary action up to and including suspension of driving privileges or
termination.
A. Rules and Regulations
1. Company vehicles are to be used for business purposes only.
2. Driving a company vehicle is a “privilege” and not a “right” automatically granted by
acceptance of employment or continued employment. Company vehicles are assigned and to
be used only by the assigned driver. Use by anyone other than the assigned driver must be
pre-approved by management. (Note: Unless otherwise directed by management, the
“assigned driver” may operate other company vehicles provided they are licensed for that
equipment.)
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3. All Company Rules and applicable State, Federal and Local laws governing the use of
(company) vehicles on public or private property must be followed by the drivers and
passengers while in a company vehicle.
4. The person assigned responsibility of the company vehicle is responsible for the behavior and
conduct of all persons carried by the vehicle.
5. Possession and/or use of any controlled substance(s), drugs and/or any form of alcohol by
any person within a company vehicle or within the vicinity of a company vehicle is strictly
prohibited. This includes, but is not limited to, when the vehicle is in motion, parked, or being
repaired. This also includes on and off work hours, weekends, holidays or other non-work
period of time. Violation of this policy will cause the driving privileges of the person assigned
to the company vehicle to be immediately suspended or permanently revoked and/or may be
cause for immediate termination of employment as determined by management. Persons
assigned a company vehicle shall not allow alcoholic beverage containers, empty or full to be
transported or to accumulate in any company vehicle for any reason, at any time, including
reasons of “recycling”.
6. Any unlawful activity is forbidden while within or in the vicinity of a company vehicle, whether
or not the company vehicle is parked or in motion. This activity includes but not limited to,
firearms, weapons of any description, any contraband, controlled substance paraphernalia,
stolen property, or property that may be stolen. In addition, any items, conduct of activity that
is related in any way to gang activity, or other organized crime and any other activity that may
be deemed unlawful is prohibited while in the proximity, control or vicinity of a company
vehicle.
7. Passengers carried in company vehicles must be on legitimate company business.
Passengers are not allowed to ride in the back of pickup trucks for any reason, or for any
distance. This includes “point to point” on a construction jobsite or right of way. All
passengers must ride in the cab of company vehicles and be secured with a seatbelt. No
person is allowed to ride on any company or personal vehicle tailgate, fender, side wall,
bumper, running board, step, hood, or any other part of the company or personal vehicle other
than inside the cab, while conducting company business. This includes any off work hour,
weekend, holiday or other period of time and includes any off work site location.
8. Seatbelts are provided in company vehicles and shall be worn by all occupants while the
vehicle is in forward or reverse motion, regardless of speed or distance to be traveled.
Employees assigned a company vehicle have the responsibility for ensuring seatbelt
compliance or passengers while being transported in the vehicle. Passengers violating this
rule may cause the person responsible for the vehicle to lose driving privileges. Passengers
may be subject to disciplinary action as determined by management.
9. Transportation of any hitchhiker or non-authorized passenger is strictly prohibited in any
company vehicle at any time, location or hour.
10. The company will not pay for any motor vehicle moving or stationary violations. Such
violations are the responsibility of the person assigned to the company vehicle. Any person
receiving a vehicle code moving violation notice, while in control of any company vehicle, at
any time, including off/on work hours, weekends, holidays or other periods of time, is required
to notify their field manager in writing by email, facsimile, or other written means within 24
hours (twenty-four hours) of receipt of such notice; whether or not the violation has been
placed before any traffic court for final determination of fault. Failure to properly notify the
field manager within 24 hours (twenty-four hours) may be cause for immediate forfeiture of
company vehicle driving privileges, and/or termination of employment. In the event of
holidays or weekends, the person receiving a moving violation must report the violation to the
field manager at the beginning of regular business hours on the next regular business day. If
the report of violation is not received by the field manager by the end of the day following
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resumption of regular business hours, the employee will be considered in violation of this
policy and will be subject to disciplinary action as described in Part D.
11. Mechanical defect violations (e.g. headlights, windshields, turn signals, etc.) will be paid by
the company, however the person assigned responsibility for the company vehicle is obligated
by the policy to keep the vehicle in “sound” operating condition and to notify the company of
needed repair.
12. The person assigned responsibility for company vehicle operation is responsible to notify the
company of any lapse of vehicle registration or licensing.
13. Use of a motorcycle for company business is prohibited.
14. Smoking is not permitted in the vehicle.
15. Keys shall not be left in the vehicle while it is left unattended. Duplicate keys shall not be
placed in a “hidden” location of the vehicle. Personal items left in the vehicle are the
responsibility of the operator. The company cannot be held responsible and accountable for
personal items left or stored in the vehicle. Where agreements through the collective
bargaining require employers to provide a storage place for employee’s tools in the vehicle,
they shall be kept in a locked area as directed by the company. Laptop computers and other
electronic devices shall be removed from the vehicle when the vehicle is left unattended.
(Exception: equipment may be kept in a locked portion of the vehicle, not visible from others.
16. It is strongly recommended that the windows be closed and the doors locked when operating
company vehicles. (Exception: non-air conditioned vehicles).
17. Persons driving their own vehicles for company use must provide proof of adequate insurance
relating to the vehicle that will be used. A copy of the policy declaration page identifying the
dates of coverage and the limits of liability must be provided to administration on an annual
basis. Adequate insurance limits for potential bodily injury must be secured and maintained on
each vehicle planned to be used by the vehicle custodian
B. Driver’s Licences
1. Operators of company vehicles must hold a current and valid driver’s license issued within the
United States for the type of vehicle the employee is operating, and with the proper
endorsements as required by the Department of Motor Vehicles (e.g. a Hazardous Materials
and Multiple-Axle endorsement). Employees willfully operating company vehicles without
proper endorsements will be subject to disciplinary action, including but not limited to loss or
restrictions of driving privileges or termination of employment.
2. Supervisors who knowingly or willfully require any employee to operate a company vehicle of
any description for which the employee does not have the proper license or proper
endorsement(s) will be subject to severe disciplinary action including termination of
employment.
3. Employees assigned responsibilities for driving company vehicles must report all status
changes or restrictions to their driver’s license immediately. Under no circumstance shall the
employee fail to report to field management within 24 hours (twenty four hours), upon
employee notification by the Department of Motor Vehicles, or law enforcement agency of the
employee’s driver’s license status change or restriction.
Such changes or restrictions includes but are not limited to revocation, restriction or
suspension (either permanent or temporary) of a driver’s license for:
 DUI
 Parole violation
 Habitual Offender
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




Substance Abuse violation
Gang related activity
Domestic violence
Aggressive driving behavior Careless and/or reckless driving
….or any other reason as determined by the Department of Motor Vehicles or other
law enforcement agency. Failure to abide by this rule will subject the employee to
disciplinary action, which may include but not limited to revocation or restriction of
company driving privileges, or termination of employment.
4. A current copy of the employee’s driver’s license(s) must be on file with the company at all
times.
5. Employee’s motor vehicle records will be checked at the discretion of the company at any time
for any reason.
C.
Vehicle Operation
1. Employees operating company vehicles are expected to observe the basic traffic laws as
endorsed by the state in which they are driving.
2. Employees operating company vehicles are not allowed to exceed posted speed limits or the
basic speed law.
3. Employees cited for, observed, or reported to be tailgating another vehicle on a public or
private roadway in a company vehicle regardless of on/off duty hours will be subject to
disciplinary action after a complete investigation.
4. Employees engaged in any of the following activity while in control of a company vehicle,
regardless of on/off work hours, whether on or off public or private property are subject to
disciplinary action as described in Part D of this policy:
a) Exhibition of speed (including tire spinning)
b) Racing
c) Unsafe lane changes
d) Failure to signal
e) Careless driving
f) Unsafe acceleration
g) Aggressive driving
h) Threatening another motorist or pedestrian with physical, verbal or other gestures that
may be interpreted as threatening.
i) Driving too fast for conditions
j) Carrying unsecured or unsafe loads
k) Failure to stop when involved in an accident
l) Failure to immediately report an accident
m) Any violation that carries a count of 2 (two) points in or out of the State of California
n) “At fault” accidents
D.
Disciplinary Action
1. Disciplinary action may include but is not limited in any way to the following:
a) Attend Driver’s Safety School (Driver’s Awareness Course) as provided through the
Nation Safety Council of State enforced program for first offender drivers. Proof of
attendance is required and the employees will bear all expenses.
b) Requirement to explain to the company officers, safety committee, insurance company or
any other representative why the offense was made and their intent to correct driving
habits.
c) Requirement to explain to others in a group (or in company safety meeting) why the
employee had to attend Driver’s Safety School and how they intend to operate a motor
vehicle in the future.
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d) Required probation of company vehicles for not less than 90 days from the date of citation
for more than 12 months.
e) Revocation of company vehicle driving privileges for not less than 30 days up to
permanent and complete revocation of driving privileges as long as the employee remain
employed by the company.
f) Immediate termination of the employment.
E. Noise, Cell Phones and Two-Way Radios
1. Employees are not allowed to play or increase the volume of any vehicle radio while the
employee in inside or outside the company vehicle, potentially creating a nuisance to the
surrounding area or distracting the driver from operating the vehicle in a safe manner.
Definition of nuisance under this policy will not be decided by the employee, but will be
determined by the company. This rule applies to whether the company vehicle is being used
on or off work hours and is located on public or private property during business hours,
weekends and holidays.
2. Cell phones and two-way radios can be used while driving, however the employee (driver)
must be connected to a “hands-free” device. If the conversation requires the operator to
become inattentive to his/her driving, the driver shall pull off the path of travel to a safe
location to engage in further communication. (e.g. no electronic texting, writing or searching
for a document while attempting to drive).
3. Employees shall not wear headphones while driving company vehicles on public or private
property under any circumstances at any time. Earpieces as provided with a “hands-free” cell
phone or two-way communication device are acceptable.
4. Any employee who continuously violates any provision of this part (E) and continues to cause
the company to take action to correct their behavior will be subject to termination without
further notice.
F. Vehicle Maintenance and Inspection
1. Drivers are responsible for ensuring the scheduled and daily maintenance and cleanliness of
their vehicles. The company will pay maintenance expenses unless the company has reason
to believe the vehicle has been purposely neglected or misused. Your vehicle should be
inspected each day before and after use, since you are solely responsible for its condition.
2. Employees are not to operate vehicles they suspect may be mechanically unsafe to drive until
certified to be safe by an approved mechanic employed or authorized by the company. Any
condition that renders the operation of the vehicle unsafe to operate shall be reported
immediately.
3. Accumulation of trash shall be removed from the vehicle each day. The dashboard, seats and
floor shall be free of any unsecured objects that are not a functional part of the vehicle.
(Exceptions: briefcase, purses, rolled blueprints. Hard-hats shall be placed in an approved
wire retainer of holder).
4. Mirrors (e.g. rearview) shall not have objects attached or hanging from them, including the
attachment of stickers unless they have been approved by the company or applied by the
vehicle manufacturer.
5. Decals, photographs, labels or stickers shall not be attached to any part of the vehicle unless
they have been approved my management or applied by the manufacturer for safety or
operational purposes.
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G. Accident Reporting
1. If you are involved in an accident and you are not injured, obtain as much information as
possible about the other driver(s).
2. Follow these guidelines if you are involved in an accident:
a) Cooperate with law enforcement agencies.
b) Do not admit guilt.
c) Obtain names and phone numbers of witnesses. Hand them a “witness card” and
request that they complete it prior to leaving the scene. Include this information with your
report.
d) Take photographs of the accident scene.
e) You may give the following information to others:
I. Your name
II. Your driver’s license number
III. Company contact information
IV. Company’s insurance company name and policy number
f) Contact the company immediately.
g) Follow the requirement for substance abuse testing. (Note: Failure to
comply with the substance abuse program will be constituted as
admitting being under the influence. If you are injured, the treating
medical facility will comply with our substance abuse regulations).
Fire Prevention and Protection
All responsible precautions will be followed in cooperation with local authorities to minimize fire
hazards. The telephone numbers of local fire fighting agencies will be posted at the office and be
available for each job site.
Appropriate portable fire extinguishers and hand tools will be available at the work site whenever
fire hazards exist.
Demonstrations and training should be provided to all personnel in the use of available “first aid”
fire fighting equipment.
All flammable and combustible materials will be properly stored.
Smoking and use of open flames will be prohibited in any area where these would present a
hazard. This prohibition is to be noted by the use of signs.
Gasoline and other flammable liquids will be stored and handled only in approved portable tanks
and safety cans.
Above ground fuel storage areas will be surrounded by a dike at least 12 inches high and of
sufficient size to contain the contents stored.
An above ground fuel storage tank will be located at least 20 feet from any building or facility and
will be kept clear of weeds, debris and other combustible material.
At least one portable fire extinguisher having a rating of not less than 20BC will be maintained at a
distance between 25 to 75 feet from fuel storage and dispensing areas and will be carried on all
fuel trucks.
A fire alarm system will be established whereby employees and the local fire department can be
promptly alerted in the event of a fire emergency.
Welding and Cutting
Welding and cutting equipment will be inspected daily and will be maintained in good condition.
Gas hoses and electrical welding leads will be free of damage or defects.
When not in use, torch and cylinder valves will be closed, regulators will be removed and valve
caps will be replaced.
Non-current carrying metal parts of electrical welding machines and circuits used for other than
welding will be grounded.
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All fuel gas-oxygen welding and cutting equipment will have a reverse flow check valve between
the torch and regulator.
Compressed gas cylinders will be secured in an upright position. Oxygen cylinders in storage will
be separated from fuel gas cylinders and other combustible materials by at least 20 feet or by a
non-combustible barrier at least 5 feet tall. Valve caps will be secured on cylinders not in use.
Never choke a cylinder. Compressed gas cylinders will be moved by crane with approved lifting
apparatus only.
Fire extinguishers rated at least 10 ABC will be available at all cutting and welding operations.
All persons will be shielded from welding flash, sparks and slag. Combustible materials will be
protected from heat, molten metal and other ignition sources.
Welding and cutting will be performed only by persons experienced in safe welding and cutting
procedures.
Call Before You Dig
It is the company’s policy to comply with all state and federal “Call Before You Dig” regulations.
Hand and Power Tools
All hand and power tools will be used only for the purpose for which they are intended, and will be
maintained in safe working condition.
All required guards and safety devices will be in place and functioning properly.
All electric powered hand tools will be equipped with a constant pressure switch that will shut off
the power when the pressure is released. Any positive “On-Off” control switches or lock on
devices must be removed prior to first use.
The non-current carrying metal parts of electric tools will be grounded. When electrical tools are
connected to a temporary power source, the circuits will be protected by ground fault circuit
interrupters.
A daily visual inspection of all tool cord and plug connections on tools, required to be grounded,
must be accomplished by the user (to identify any defects prior to use). Inspection, testing, and
color coding of cords and plugs by a qualified person must be accomplished every three months
in accordance with Section 3-4-1.
Power-actuated tools will be used only by trained and certified personnel. Power-actuated tools
will be serviced and maintained only by qualified and authorized personnel.
Pneumatic impact tools will be equipped with safety clips for retainers to prevent tools from being
expelled from the barrel.
The connections of compressed air hose with a one inch inside diameter or greater will be pinned
or secured to prevent whipping in the event of separation.
Chain saws will be operated only by qualified operators in accordance with the manufacturer’s
operating instructions. Operators must wear appropriate eye, ear, hand and leg protection.
Chain saws without a kickback device are not to be used.
Abrasive cutoff saws will not be used to bevel pipe.
Abrasive Blasting
Abrasive blasting may create small airborne particles that can be drawn into the lungs. To prevent
silicosis, silica sand will not be used for this purpose.
Use of Electrical or Power Actuated Tools
All electrical equipment must be properly grounded or otherwise protected.
Only designated persons who have been instructed and trained in their safe use shall use poweractuated tools.
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No electrical tools shall be repaired or serviced while the power is still on.
Ergonomic Injury Prevention and Safe Lifting Plan Policy
The purpose of this program is to inform interested persons, including employees, that Costello Industries
is committed to improve our employees' comfort and well being by identifying and correcting ergonomic
risk factors on the job. This program applies to all work operations, both in the field and in the office areas.
Under this program, our Safety Committee will evaluate jobs that they have identified as having “problem
areas” and develop and implement solutions to reduce job-related worker injury and illness.
Our goal through this Ergonomics Program is to prevent the occurrence of work-related musculoskeletal
disorders by controlling or eliminating the risk factors that cause them. This program ensures that all
affected employees are aware of job-related risk factors and provides information and solutions to elevate
them. Costello Industries promotes continuous improvement for the efficiency, comfort, and well being of
all employees through a team effort of management and employee involvement.
The Committee members have been trained to recognize problem jobs, identify risk factors, and develop
solutions to reduce those factors. Elements of this training include the identification of workplace risk
factors; job analysis methods, implementation and evaluation of control measures, and teamwork skills.
Injury/Medical Management
We encourage all employees to immediately report any symptoms of discomfort that may be associated
with their job duties. In most cases, employees are to report to their immediate supervisor. Those
supervisors are responsible to recommend alternative work or medical evaluation for injured or ill
employees.
Supervisors record and file a written report from the first observation of illness or injury through all
subsequent follow-up activities. They are also responsible to forward information about the worker injury
or illness for recording on the Log of Work-Related Injuries and Illnesses.
Costello Industries’ employees are its greatest asset. Accordingly, we are committed to providing a safe
work environment for each employee. However, in the event that an injury is sustained on the job, you
must take the following steps to ensure prompt medical treatment and compensation benefits:
1. Report all injuries to your supervisor IMMEDIATELY—no matter how minor
2. If medical attention is necessary, report to your supervisor prior to leaving the facility.
3. Any non-life threatening medical emergency will be treated at a company authorized medical services
facility
Employees must submit all bills regarding the injury to Human Resources. Remember, medical bills and
benefits for work-related injuries may be covered under the Workers’ Compensation Act. Immediate
notification is necessary for timely payments. If you have any questions, please contact Human
Resources.
Every work procedure that causes a worker injury or illness will be investigated and reported. This
documentation provides vital information for the identification of job related risk factors so that the
problems can be corrected before other injuries occur.
After an injured employee has been treated by the health care provider, the following procedures are used
to monitor the recovery process and their return to work.
Costello Industries is committed to providing a safe work environment for its employees. If an employee
sustains an injury while employed by this company, every effort will be made to ensure the employee
receives quality medical care and is returned to work environment as soon as he/she is physically able.
Employees who may be able to return to work in a limited capacity, but who are temporarily not capable of
23
performing the full scope of their regular job duties, will receive a temporary job assignment through the
Costello Industries transitional, light duty, work program.
Job assignments will be based on specific medical restrictions established by a licensed physician. If
work is available for the injured employee and the physical requirements of such work do not violate any of
the medical restrictions, the employee will be required to perform the job assignment.
The Human Resources Department has developed a list of light and restricted duty jobs that have low
musculoskeletal risks. This list is a valuable resource for assigning duties to recovering employees until
they can resume their normal job functions. After verification of an employee's job-related injury or illness,
our Safety Committee will review this plan and re-evaluate the injured workers job function to determine if
additional practices, procedures, or redesign of the station could be implemented to prevent similar
injuries.
Identifying Problem Jobs
There are several methods used to identify problem jobs that are most likely to result in ergonomic
disorders. The Safety Committee initially reviewed and periodically monitors Costello Industries injury and
illness reports and workers' compensation data to identify patterns of ergonomic-related injuries and
illnesses.
In addition, jobs are evaluated for the following risk factors:
•
Rate and number of repetitions: performance of the same motion or motion patterns every few
seconds for more than two hours at a time.
•
Postures and limb positions: fixed or awkward work postures such as overhead work, twisted or bent
back, bent wrist, stooping, or squatting, for more than a total of two hours.
•
Loads/lifted: lifting, lowering, or carrying of anything weighing more than 25 pounds (11.34 kg) more
than once during the work shift.
•
Loads/static: holding a fixed or awkward position with arms or neck for more than ten seconds.
•
Muscle forces: continually pulling or pushing objects.
Solutions
When a job, process, or equipment has been evaluated, the Committee completes a risk factor checklist.
Through this checklist, problems are identified for correction and supervisors and employees in the
affected areas are notified. The Committee, in conjunction with those affected employees, will develop
possible solutions, choose the most appropriate, implement the changes, and follow up to determine the
effectiveness.
Employee Training
Costello Industries' management staff receives copies of this written ergonomics program and the
company's policy statement regarding ergonomics in our workplace. We train each employee who works
at a job with exposure to specific risk factors and each employee in a job where a work-related
musculoskeletal disorder has been recorded.
These are the ergonomic elements we teach to all employees:
•
How to recognize workplace risk factors associated with work-related musculoskeletal disorders and
the ways to reduce exposure to those risk factors.
•
The signs and symptoms of work related musculoskeletal disorders, the importance of early reporting,
and medical management procedures.
•
Reporting procedures and the person to whom the employee is to report workplace risk factors and
work-related musculoskeletal disorders.
•
The process Costello Industries is taking to address and control workplace risk factors, each
employee's role in the process, and how to participate in the process.
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•
Opportunity to practice and demonstrate proper use of implemented control measures and safe work
methods that apply to the job.
Each employee involved in job analysis will be trained in job analysis methods, especially as they relate to
identifying workplace risk factors, and evaluation and implementation of control measures.
This company will not implement any policy or practice which discourages reporting or which results in
discrimination or reprisal against any employee who makes a report.
Enforcement
Constant awareness of and respect for ergonomic hazards, and compliance with all safety rules are
considered conditions of employment. Costello Industries reserve the right to issue disciplinary warnings
to employees, up to and including termination, for failure to follow the guidelines of this program.
Premises Liability Risk Control Policy
Costello Industries maintains a single headquarters location at 123 Costello Road in Newington, CT.
There are two buildings, an office and warehouse/garage. There is very little traffic in and out of either
building primarily consisting of employees, vendors and various other visitors.
Costello has identified the following exposures that are addressed through formal inspection:
Snow and Ice (Seasonal)
Cracked Pavement
Debris
Other trip/fall hazard
Vehicles
Poor Lighting
Uneven Floor Surfaces
Slippery Surfaces
Housekeeping
The liability control policies and procedures for each are as follows:
Snow and Ice – This is a common hazard for Costello throughout the winter months. All driveway and
walking surfaces are plowed/cleared as soon as practicable after/during a storm. These same surfaces
are also salted and/or sanded and sand is added repeatedly until all surfaces are clear.
Cracked Pavement – All employees working at the HQ location are instructed to point out to
management any cracked surfaces or other dangerous walking hazards. Upon notice, Costello will repair
immediately.
Debris – From time to time loose debris may be discovered on driving/walking surfaces. Company policy
directs employees to clean it up immediately.
Other Trip/Fall Hazard – Company policy directs all employees to remove, repair or inform management
of any unsafe hazard on company property.
Vehicles – All vehicles are to be parked in striped parking spaces. Employees are directed to notify
management if unknown vehicles are on the premises or any vehicle is not parked in a designated space.
Poor Lighting – Costello maintains exterior lighting for all exterior paved areas. All employees are
directed to notify management if a light isn’t working. Repair/replacements are made immediately.
Uneven Floor Surfaces – All floors in Costello buildings are monitored and maintained regularly. All
employees are directed to either fix or report any deficiencies to management for immediate repair.
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Slippery Surfaces – This is directly related to ice from winter storms. See snow and ice above.
Housekeeping – From time to time as work is being done, there may be some minor housekeeping in the
garage area. Employees are directed to either clear/clean the area or report to management immediately.
This also applies to any wind-blown debris which might end up on Costello premises.
Emergency Action Plan (EAP)
Purpose
OSHA's requires Costello Industries to have a written Emergency Action Plan (EAP).
The overall EAP plan applies to all our jobsites where employees may encounter a fire, weather
or medical emergency.
Under this plan, our employees will be informed of the plan's purpose, preferred means of
reporting fires and other emergencies, types of evacuations to be used in various emergency
situations, and the alarm system.
Plan Coordinator Responsibilities
The Site Foreman is the Plan Coordinator has overall responsibility for the plan and will review
and update the plan as necessary. The Site Coordinator will:
Coordinate the company’s EAP with the Host Employer or Controlling Contractor’s
EAP
Insure that a procedure is in place to immediately notify the 911 emergency services,
in the event of an emergency affecting the facility or jobsite.
Post directions and communicate to all employees the location of the nearest medical
clinic as well as the contact number for the various emergency services such as fire,
police and ambulance.
Distribute procedures for reporting an emergencies, the location of fire exits, and exit
routes to each employee.
Conduct drills to acquaint the employees with evacuation procedures, and to judge
their effectiveness.
Insure that all local fire codes and regulations are satisfied as required.
Train designated employees in the use of fire extinguishers and the application of
medical first-aid techniques.
Report all emergencies as related to this plan to the site Controlling Employer
Emergency Reporting and Evacuation Procedure
Preparing for a disaster is a necessity for all companies. Life safety issues concentrate on
getting everyone out of the site safely in a controlled manner. It is vital to the success of this
plan that it be taken seriously and communicated to all employees. Drills will be held to test and
refine the procedures specific to this site. It is critical that all employees be aware of the plan
and responds in the event of an emergency.
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If an emergency occurs and an evacuation is deemed necessary, the Site Plan Coordinator
ensures that:
All employees are notified and evacuated and a head count is taken to confirm total
evacuation of all employees.
When practical, equipment is placed and locked in storage rooms or desks for
protection.
In the Event of Fire
In the event of a fire emergency detected by smoke/heat detectors, a drop in water pressure due
to sprinkler activation, or a manual alarm is sounded at our facility or on the jobsite, the
Evacuation Plan will be activated.
IT IS IMPERATIVE THAT THE JOBSITE BE EVACUATED IN AN ORDERLY MANNER EACH
AND EVERY TIME AN EVCAUTION IS ORDERED.
PROCEED TO THE DESIGNATED RALLY POINT AND REMAIN THERE UNTIL INSTRUCTED
OTHERWISE.
In the Event of a Weather Emergency
The Site Coordinator has access to the local and National Weather Service. When a severe
storm watch or tornado watch has been issued by the National Weather Service, the weather
page will sound, followed by a weather bulletin with further information. At that point, the Site
Foreman or his designee will determine if the warning affects our site location, and if so, warn
employees of the weather emergency.
In the event of a tornado, it is company policy to provide emergency warning and shelter. At the
time the tornado warning, all employees are responsible for evacuating to their assigned shelters
head counts once evacuation has been completed.
In the Event of a Medical Emergency
Rescue and medical aid may be necessary during emergency situations.
If available, needed designated first aid responders are to provide medical assistance within
their capabilities to employees requiring it during an emergency situation. Adequate first aid
supplies shall be readily available. The Site Coordinator will review this with the Controlling
Contractor to determine if site medical personnel are available
Should it become necessary, outside medical help will be requested by calling 911. Professional
emergency services responding in an emergency should be met upon their arrival on site and
directed to the location of the emergency.
Post Event Follow-up
The Safety Manager or Site coordinator will report all site emergency incidents to the site
Controlling Employer as required, and prepare all necessary written reports or outside agency
notifications as required.
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Top Ten Tips for Construction Workers
1.
Know your job.
2.
Use the right tools.
3.
Keep your work area clean and orderly.
4.
Use personal protective equipment.
5.
Handle material safely.
6.
Use ladders and scaffolds properly.
7.
Respect your equipment.
8.
Dress for the job.
9.
Follow the rules.
10.
If you do get hurt, report it immediately!
REMEMBER:
No job is so important and no task is so urgent that we cannot take the time to
perform our work safely.
WE ALL PLAY A KEY ROLE IN ENSURING SAFETY! BE ALERT - DON’T GET
HURT!
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HEALTH AND SAFETY HANDBOOK
ACKNOWLEDGEMENT OF RECEIPT
I have received a copy of the Costello Industries Health and Safety Handbook. I understand and
agree that it is my responsibility to read and familiarize myself with the policies and procedures
contained in the Handbook. If I have any questions, I understand that it is my responsibility to ask
my supervisor.
I understand that this guide may be amended at any time, and that the information contained in the
guide may be changed at any time at the sole discretion of the company, with or without prior notice
to me. My continued employment indicates my agreement to work under those changes.
I acknowledge that this guide supersedes all prior guide versions that may have been issued to me.
I understand that signing this Acknowledgment indicates my understanding of the above terms and
that this Acknowledgment will be placed in my company file.
(Please sign this Acknowledgment of Receipt and submit it to your supervisor).
______________________________
Employee Signature
_________________________
Date
Employee Name (please print) ___________________________________________
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