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Safety, Health & Environmental

Management System
Manual
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Safety, Health & Environmental


Management System
Manual
MANUAL #

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fact that I have read and understand the contents of this
manual. I will abide by all rules and regulations set forth in
this manual to the best of my ability.

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Moreno Group LLC and Subsidiaries


Safety, Health & Environmental Management System
Table of Contents
SECTION A
Safety, Health & Environmental Policy Statement
Safety, Health & Environmental Policy Statement ............................................................. 1 of 1
SECTION B
Safety, Health & Environmental Responsibilities
Safety, Health & Environmental Responsibilities ............................................................... 1 of 6
SECTION C
Audits and Assessments
Audits and Assessments .................................................................................................. 1 of 11
Safety, Health & Environmental Management System Change
Procedure ........................................................................................................................... 1 of 2
SECTION D
Contractor Safety, Health and Environmental Program
Contractor Safety, Health and Environmental Program ................................................... 1 of 13
SECTION E
Emergency Preparedness
Emergency Preparedness ................................................................................................ 1 of 19
SECTION F
Employee Participation
Employee Participation ....................................................................................................... 1 of 2
STOP Work Authority ......................................................................................................... 1 of 5
SECTION G
Hazard Control
Job Safety and Environmental Analysis ............................................................................ 1 of 9
SECTION H
Incident Reporting and Investigation
Incident Reporting / Medical Attention Procedure .............................................................. 1 of 7
Incident Investigation Procedure ...................................................................................... 1 of 11

Table of Contents (continued)


SECTION I
Occupational Health
Occupational Health Program ............................................................................................ 1 of 5
Abrasive Blasting .............................................................................................................. 1 of 12
Aluminum Protection ........................................................................................................ 1 of 10
Asbestos Abatement ........................................................................................................ 1 of 18
Back Injury Prevention ........................................................................................................ 1 of 3
Benzene.............................................................................................................................. 1 of 6
Bloodborne Pathogens ....................................................................................................... 1 of 9
Cadmium Protection ......................................................................................................... 1 of 15
Fitness to Work ................................................................................................................. 1 of 11
Hazard Communication Program ....................................................................................... 1 of 7
Hearing Conservation ......................................................................................................... 1 of 5
Heat Stress Management ................................................................................................... 1 of 5
Hexuvalent Chromium Protection ..................................................................................... 1 of 19
Hydrogen Sulfide H2S ......................................................................................................... 1 of 8
Lead Protection ................................................................................................................ 1 of 14
NORM Program ................................................................................................................ 1 of 42
Respiratory Protection ...................................................................................................... 1 of 21
SECTION J
Safe Work Practices
Air Tugger ......................................................................................................................... 1 of 22
Barricading.......................................................................................................................... 1 of 3
Confined Space Entry....................................................................................................... 1 of 20
Crane Policy ..................................................................................................................... 1 of 37
Electrical Safety ................................................................................................................ 1 of 17
Energy Isolation Procedure (Lockout / Tagout) ................................................................ 1 of 11
Excavation and Trenching Procedure .............................................................................. 1 of 15
Fall Protection ................................................................................................................... 1 of 15
Fire Prevention Plan ........................................................................................................... 1 of 7
Forklift Program .................................................................................................................. 1 of 8
Line Opening ...................................................................................................................... 1 of 6
Permit To Work ................................................................................................................. 1 of 12
Personal Protective Equipment .......................................................................................... 1 of 7
Powered Work Platform Safety ........................................................................................ 1 of 10
Scaffolding ........................................................................................................................ 1 of 10
Vehicle Safety ..................................................................................................................... 1 of 6

Table of Contents (continued)


Waterfront Safety Procedure .............................................................................................. 1 of 5
Welding, Burning, Cutting and Hot Work .......................................................................... 1 of 13
SECTION K
Safety, Health and Environmental Meetings
Safety, Health and Environmental Meetings ...................................................................... 1 of 5
SECTION L
Safety, Health and Environmental Performance Review
Safety, Health and Environmental Performance Review ................................................... 1 of 5
SECTION M
SH&E Training
New Employee Orientation / Safety, Health & Environmental Training ............................. 1 of 5
Short Service Employee Program ...................................................................................... 1 of 6
Sub Part O Training Plan ................................................................................................. 1 of 9

MORENO GROUP LLC AND SUBSIDIARIES SAFETY,


HEALTH AND ENVIRONMENTAL POLICY STATEMENT
Moreno Group LLC and Subsidiaries policy is to manage all operations that
embrace Safety, Health and Environmental performance as a core
organizational value.
Moreno Group LLC and Subsidiaries will promote our SH&E Management
System through proactive activities, which promote the eliminating of injuries,
while providing safeguards to promote employee health and to protect the
environment from harm.
Moreno Group LLC and Subsidiaries will accomplish our core value through
the following systems:
Establishing an Incident and Injury Culture where our culture believes all incidents
are preventable
Advise each manager, supervisor and employee of Safety, Health and
Environmental requirements and hold them accountable for performance.
Design and manage operations to provide work places free of recognized safety
hazards and to minimize environmental and human health impacts.
Comply with all laws and regulations governing Safety, Health and Environmental
protection.
Recognize the importance of Safety, Health and Environmental factors where
there is competition with economic factors.
Provide professional staff to support Safety, Health and Environmental efforts.
Monitor, evaluate and report performance in Safety, Health and Environmental
protection.
Provide training needed to protect Human, Environmental and physical resources.
Participate in industry programs designed to enhance knowledge, improve
technology, and maintain conformance with current laws and regulations.

Michel Moreno
CEO
January 2010

Moreno Group LLC and


Subsidiaries SH&E
Management System

Safety, Health &


Environmental (SH&E)
Responsibilities

Page: 1 of 6
Original: 01/01/2003
Revised: 01/01/2008

Safety, Health & Environmental (SH&E) Responsibilities


Purpose
The purpose of this procedure is to clearly define duties, responsibilities and lines of
authority for Moreno Group LLC and Subsidiaries Safety, Health & Environmental
(SH&E) program.
Scope
This procedure applies to all departments and areas at the Moreno Group LLC and
Subsidiaries facility or work-site. This procedure provides a broad overview of each
employees duties and responsibilities for SH&E in the workplace.
Responsibilities
The CEO and President or Designee is responsible for:
Holding facility managers and their subordinates accountable for a high level
of SH&E performance.
Monitoring the SH&E performance of Moreno Group LLC and Subsidiaries.
Approving of any newly developed or revised program.
Continually communicate to management and First Line Supervision the
employees responsibility, ability and obligation to use their STOP WORK
Authority without reprimand.
The Moreno Group Executive SH&E Team is responsible for:
Leading the development of an SH&E Management System that is
relevant and appropriate to the Business Units while focusing on the
welfare of the individual
Communicating expectations for SH&E performance for our organization
and stakeholders
Visibly demonstrating our personal commitment to achieve an Injury and
Incident Free (IIF) work environment and seeking the same level of
commitment from the entire organization
Challenging and empowering the Business Units to make SH&E happen
through personal relationships and teamwork

B1.1

Ensuring that we have the resources necessary to achieve World Class


SH&E performance
Monitoring the organizations SH&E performance to ensure we are
delivering on our IIF commitments
Implementing timely mid-course corrections, if necessary
Identifying and benefiting from Lessons Learned from other organizations,
and our Business Units
Acknowledging and celebrating group and individual accomplishments
Communication
stakeholders

SH&E

incidents

to

the

Organization

and

other

Providing assistance and support to our Business Unit Teams


Quarterly, as an executive SH&E Team audit a Business Units facility
Discuss, declare and expedite proper course of action for undecided
systems, procedures, ideas and/or situations identified at Business Unit
Management Teams
The Facility Manager or Designee is responsible for:
The overall SH&E program and the performance results achieved.
Assigning resources for implementation of the SH&E program.
Holding managers, first line supervisors, offshore superintendents and subcontractors accountable for a high level of SH&E performance.
Monitoring, measuring and managing the SH&E performance.
Authorizing the expenditures for SH&E.
Approving Safety, Health and Environmental policies as formulated by the
SH&E staff or others.
Actively participating in the SH&E program to show interest.
Maintain communication with the SH&E Department concerning our SH&E
performance.
Setting the example for all employees
Continually communicate to First Line Supervision the employees
responsibility and authority to STOP WORK without reprimand.

B1.2

Asking SH&E related questions of management and supervisory personnel,


on a regular basis, to demonstrate the importance of safety to management.
Reviewing and/or investigating the causes of all reported incidents, accidents
and injuries and approving corrective actions.
Participating and monitoring the company Behavioral Safety Process.
The Supervisory Personnel or Designee is responsible for:
Periodically inspecting work areas and equipment for compliance with work
rules and SH&E standards.
Instructing employees on the hazards of the job, how to work safely and
according to operating procedures, applicable SH&E policies and applicable
SH&E regulations.
Maintaining a safe and healthy workplace, ensuring good housekeeping,
proper illumination and ventilation, and the use of personal protective
equipment as required for each job.
Seeing that all injuries are promptly reported and properly treated.
Analyzing all process, operations and facilities for hazards and making
changes or recommendations to eliminate or control hazards.
Investigating the causes of all reported incidents, accidents and injuries,
completing the necessary reports and initiating control action as required.
Conducting employee safety, health and environmental meetings, new
employee job specific orientations and job / task hazard analyses.
Making each employee aware that violation of established safety, health and
environmental rules will result in disciplinary action.
Complimenting safe workers publicly and counseling unsafe workers
privately.
Participating in the company Behavioral Safety Process.
Setting the example for SH&E by complying with the safety rules and
procedures and displaying a positive attitude toward the safety program.
STOP WORK anytime any employee identifies or feels a condition or situation
is unsafe or not environmentally sound.

B1.3

The Engineering Personnel or Designee is responsible for:


Incorporating required safety features into the design of all equipment and
projects.
Maintaining knowledge of applicable safety regulations and standards and
incorporating these requirements into all designs.
Maintaining knowledge hazards or potential hazards within their areas of
responsibility and taking action to eliminate or control these hazards.
Serving as a resource to the organization providing engineering expertise as
required to improve overall SH&E program.
Developing safe operating and maintenance procedures and corresponding
training programs for new or modified equipment or processes.
Assisting in employee training on new or modified equipment / systems as
necessary.
Participating in workplace hazard assessments.
Coordinating selection and oversight management of contractors.
Participating in the company Behavioral Safety Process.
Communicate and involve the SH&E Department in any new equipment or
design changes to ensure the appropriate SH&E procedures are developed,
training is performed so these procedures can be implemented.
The SH&E Department or Designee is responsible for:
The Corporate SH&E Manager will be the SH&E Management System
Administrator.
Serving in a staff capacity as a Safety, Health and Environmental (SH&E)
resource to the organization.
Coordinating facility and site SH&E activities.

B1.4

Assisting with implementation of the SH&E program by.


-

Conducting new employee orientation / SH&E training programs.

Assisting supervisory personnel with Safety Meetings.

Conducting workplace observations, audits and inspections.

Assisting management and supervisory personnel during incident


investigations.

Helping determine appropriate corrective actions resulting from


incident investigations, SH&E inspection or audits.

Coaching supervisory personnel and employees when at-risk behavior


is observed.

Coordinating the facility and site first aid, medical and industrial hygiene
programs.
Maintaining and analyzing incident reports, injury and illness statistical data
and results of SH&E audits / inspections or observations.
Coordinating educational activities on SH&E for all management, supervisory
personnel and employees.
Conducting activities for stimulating and maintaining employee interest in the
SH&E program.
Serving on the safety, health and environmental committee (if applicable).
Reviewing and approving incident investigation reports.
Directing and monitoring a program of supervisory SH&E inspections and
audits.
Keeping informed on applicable governmental SH&E standards and codes.
Providing education, measurements, support and participation in the
Behavioral Safety Process.
Maintain communication with Management concerning SH&E performance
and/or issues.

B1.5

The Employee is responsible for:


STOP WORK anytime a condition or situation is unsafe or not
environmentally sound.
Performing only those jobs on which they have been trained and / or
authorized.
Working in accordance with safe job practices and complying with company
and client SH&E policies and procedures.
Using required Personal Protective Equipment.
Reporting unsafe conditions, practices or incidents immediately to supervisory
personnel. Shutdown work activity for an SH&E concern.
Serving on the safety committee, if asked.
Participating in the company Behavioral Safety Process.
Participating and co-operating in the Work Group Incident Investigation
Process.
Attending and actively participating in all safety, health and environmental
meetings, workplace hazard assessments and job safety & environmental
analysis development.

B1.6

Moreno Group LLC and


Subsidiaries SH&E
Management System

Audits and Assessments

Page: 1 of 11
Original: 01/01/2003
Revised: 09/01/2009

Audits and Assessments


Purpose
The purpose of Safety Inspections is to provide a consistent method of identifying and
evaluating the workplace environment for safety, health and environmental hazards.
Scope
This procedure applies to all Safety, Health and Environmental Audits and
Assessment activities for Moreno Group LLC and Subsidiaries. This policy applies to
all employees and area of operation for Moreno Group LLC and Subsidiaries.
Responsibilities
The Facility / Site Manager or Designee is responsible for:
Overseeing this procedure and ensuring all requirements are met.
Auditing the audits for compliance with this procedure.
Appointing facility / site supervisors / designees to be responsible for safety
audits, inspections and housekeeping activities.
The First Line Supervisor / Offshore Superintendent is responsible for:
Understanding and complying with this procedure.
Assuring employees follow good housekeeping practices.
Informing management of suggested improvements in housekeeping efforts.
Participating in and assuring safety audits, inspections and housekeeping
activities are conducted on a scheduled basis.
Developing a process to correct deficiencies discovered during safety audits,
inspections and housekeeping activities.
The Safety, Health and Environmental Department is responsible for:
Training, or coordinating the training of managers, supervisors and hourly
employees on conducting audits and assessments.
Periodically auditing the quality of supervisors' weekly assessments.
C1.1

Participating in the reviewing and commenting on audits and assessments


findings and corrective actions.
Providing support and resources to Management, First Line Supervision and
employees.
The Employee is responsible for:
Understanding and complying with the safety audits, inspections and
housekeeping requirements.
Conferring with supervision regarding any suggestions for improving the
safety audits, inspections and housekeeping efforts.
Actively participating in safety audits, inspections and housekeeping
programs.
Keeping their work areas clean.
Requirements
Management and the Safety, Health and Environmental Department shall conduct
monthly a work-site inspection. This inspection shall be documented on the Moreno
Group LLC and Subsidiaries Hazard Assessment Checklist (see Attachment 1).
Moreno Group LLC and Subsidiaries monthly Stormwater Pollution Prevention
Inspection will be included within this monthly inspection.
Work-site Inspections shall be conducted weekly by at least one or two hourly
employees with their First Line Supervisor or Superintendent. The inspection shall
be documented on following checklists:
Moreno Group LLC and Subsidiaries Hazard Assessment Checklist
(shop)(see Attachment 2)
Moreno Group LLC and Subsidiaries Offshore Weekly Hazard Assessment
Checklist (see Attachment 3)
Weekly Hazardous Waste, Paint, Solvent, Fuel and Oil Storage Area
Inspection Checklist (see Attachment 4)
Prior to or upon receiving clients equipment into Moreno Group LLC and
Subsidiaries facility the following checklist shall be completed:
Refurbish Equipment Checklist (see Attachment 5)
Prior to performing any work activities that may disturb the paint on equipment
identified as containing Lead Base Paint, the following checklist shall be completed:
Lead Job Safety Checklist (see Attachment 6)
C1.2

Periodically SH&E Department will visit Jobsites. During this visit the SH&E
personnel will perform a project assessment using the Moreno Group LLC and
Subsidiaries Jobsite Hazard Assessment Checklist. (See Attachment 7)
Prior to any Offshore Tool House being sent offshore, an Offshore Tool House
Checklist will be completed. A copy of this checklist will be sent offshore so the
receiving superintendent can review the checklist. (See Attachment 8)
During long duration jobs, the offshore superintendent will periodically inspect their
Offshore Tool House utilizing the Offshore Tool House Checklist.
Any unsatisfactory conditions that the supervisor is unable to correct will require a
work order to be issued. A copy of the signed and dated checklist along with any job
orders shall be forwarded to the Safety, Health and Environmental Department.
Additional inspections shall be required under the following circumstances:
Whenever new substances, processes, procedures, or equipment
are introduced into the work place that represent a new
occupational safety and health hazard.
Whenever the supervisor is made aware of a new or previously
unrecognized hazard.
As a part of an incident investigation.
Note: For equipment inspection requirements refer to specific program.
All inspections, findings and recommendations shall be communicated to the
employees at their Daily Safety Meeting.
Annually Safety, Health and Environmental Department and Management
will conduct an audit of the Moreno Group LLC and Subsidiaries Safety,
Health and Environment Management Systems.
At a minimum the following SH&E programs shall be evaluated during the
annual audit:
Confined Space Entry Program
Energy Isolation Procedure (Lockout/Tagout)
Respiratory Protection Program
Stormwater Prevention Plan
All checklists shall be maintained for a minimum of 3 years

C1.3

Attachment 1

C1.4

Moreno Group LLC and Subsidiaries Facility Monthly Management


Hazard Assessment Checklist
Date:
Time:
Location:
INSPECTION TEAM:

Facility Manager (Leader)

Legend:
Safe Check Mark
No X
NA - NA

A
A1
A2
A3
A4
A5
A7
A8

EXIT AISLES AND PASSAGEWAYS

(1)

(2)

(3)

Shop Yard Paint

(4)

(5)

(6)

(4)

(5)

(6)

Are exits & aisles unobstructed?


Are walkways free of welding leads, hoses, material,
etc.?
Are walkways free of slipping hazards?
Are open holes identified and barricaded with 3/8
wire rope?
Are materials/equipment stored such that sharp
objects will not interfere with the walkway?
Are scaffolding boards secured with number 9 wire?
Is the scaffolding floor at least 18 inches in width?

REMARKS:

B
B1
B2
B3
B4
B5

HOUSEKEEPING

(1)

(2)

(3)

Shop Yard Paint

Yard and shop clean and free of debris?


Are areas free of material spills and are dip pans
clean?
Adequate room to maneuver mobile equipment?
Trash (metal and waste) cans empty regularly?
All material stacked securely?

REMARKS:

C1.4.a.1

C
C1
C2
C3
C4
C5

FACILITY SIGNS

(1)

(2)

(3)

Shop Yard Paint

(4)

(5)

(6)

(4)

(5)

(6)

(4)

(5)

(6)

Material Safety Data Sheets (MSDS) and index


accessible for all on-site chemicals?
Units Start Automatically warning signs present?
All portable containers properly labeled?
Hearing Protection Required signs present where
noise exceeds 85 dBA?
All chemical drums properly labeled with lids
secured?

REMARKS:

D
D1
D2
D3
D4

FIRE PROTECTION

No Smoking by the flammable liquid cabinet or Yard


storage / usage area?

D6

Ignition sources 35 ft. away from Flammable liquid


cabinet?
Flammable liquids stored in Flammable Liquids
Cabinet?
All containers within Flammable Liquid cabinet or
Yard storage area sealed and labeled?
Flammable Liquid cabinet or Yard storage area clean
and orderly?

D8
D9

(2)

(3)

Fire extinguisher inspection within last 30 days?


Fire extinguishers fully charged with seal and tags in
place?
Fire extinguishers in designated location?
Fire extinguishers unobstructed and in good
condition?

D5

D7

(1)

Shop Yard Paint

REMARKS:

ELECTRICAL

E1

Are lights operational?

E2

Is the conduit in good condition and all wiring in


conduit?

C1.4.a.2

(1)

(2)

(3)

Shop Yard Paint

E
E3
E4
E5
E6
E7
E8
E9
E10

ELECTRICAL (continued)

(1)

(2)

(3)

Shop Yard Paint

(4)

(5)

(6)

(4)

(5)

(6)

Are all electrical control panels labeled as to function


and voltage?
Area in front of circuit breakers clear 36 inches?
Are electrical outlets not overloaded?
Are outlets in good condition?
Are cords on electrical tools in good condition?
All 3-prong extension cords in good condition? (i.e. no
tape, cuts, burns, etc.)
Are ground fault circuit interrupters (GFCI) provided
on all temporary electrical equipment?
Are portable electrical tools and cords inspected and
issued with proper color tag for the month?

REMARKS:

WELDING EQUIPMENT

F3
F4

Compressed gas and oxygen cylinders stored in


upright position with protective caps, properly
secured?
Oxygen and fuel gas cylinders separated (5 ft.
noncombustible barrier or 20 ft. separation)?
Are cylinders kept away from heat sources or stairs?
Are all cylinders secured?

F5

Are empty cylinders marked Empty?

F6

Are anti-flashback valves installed on cutting torches


and regulators?

F1
F2

F7
F8
F9
F10

(1)

(2)

(3)

Shop Yard Paint

Are welding leads completely insulated?


Are welding leads and torch hoses in good condition?
Are welding screens in good condition?
Are combustible and flammable materials stored 35 ft.
away from hot work area?

REMARKS:

C1.4.a.3

HAND AND POWER TOOLS

G1

Bench grinder and wire brush wheel appropriately


guarded (1/4 tongue)?
Space between tool rest and wheel 1/8?
Face Shield and Eye Protection Required sign
present at bench grinder?
Is the wheel secure?
Are guards on portable grinders, wire brush, etc?
Are handles on portable grinders?
Are guards enclosing all rotating and moving
equipment to prevent physical contact?
Are portable fans provided with full guards or screens
having opening inch or less?
Are pneumatic and hydraulic hoses on power
operated tools in good operating condition? (i.e. no
deterioration or damage)
Are pneumatic hose safely connected together with
safety pins or whip checks?
Are hand tools in good condition? (i.e. mushroomed
heads, broken or fractured handles, bent or worn
wrenches, handles wedged tightly in head of tools,
etc.)
Are cutting tools edges sharp so tool will move
smoothly without binding or skipping?
Are tools stored in dry, secure locations?
Are employees using the proper tool for the job?
Is there evidence employees are inspecting hand and
power tools prior to their use?

G2
G3
G4
G5
G6
G7
G8
G9
G10

G11

G12
G13
G14
G15

(1)

(2)

(3)

Shop Yard Paint

(4)

(5)

(6)

(4)

(5)

(6)

REMARKS:

H
H1
H2
H3
H4

EMERGENCY RESPONSE

(2)

Emergency Preparedness and Hazardous Waste


Contingency plans available?
Emergency phone numbers available?
Visitor access controlled?
Are Smoke Detectors and Emergency Lighting located
in offices operational?

REMARKS:

C1.4.a.4

(1)

(3)

Shop Yard Paint

Offices

PERSONAL PROTECTIVE EQUIPMENT

I1

Employees wearing Hard Hats, Safety Glasses, Proper


Clothing and Steel Toed Boots?
Employees wearing face shields when applicable?
Employees wearing hearing protection when needed?
All respirators sanitized and properly stored?
Employees wearing respirators when applicable?
Employees using fall protection properly?
PPE locker well maintained and organized?
Paint Yard Supply Air System checked for CO?

I2
I3
I4
I5
I6
I7
I8

(1)

(2)

(3)

Shop Yard Paint

(4)

(5)

(6)

___________Reading

REMARKS:

PORTABLE LADDERS

J1

Ladder rungs clean and in good condition? (i.e. loose,


corroded, bent, cracked or etc.)
Ladder hinges in good working condition? (i.e. loose,
bent, broken or etc.)

J2
J3
J4
J5
J6

(1)

(2)

(3)

Shop Yard Paint

(4)

(5)

(6)

(4)

(5)

(6)

Ladder locking mechanism working properly?


Ladder side rails/legs in good condition?
Does ladder sit properly when the ladder is in place or
extended?
Ladder safety shoes in good condition and in place?

REMARKS:

CHECKLISTS

K1

Tailgate Safety Meeting conducted daily?

K2

Daily Forklift Checklist completed daily?

K3

Daily Cherry Picker / Web Sling Checklist completed


daily?

K4

Weekly Chain Inspection Form completed?

K5

Aerial Lift pre use Checklist completed?

(1)

(2)

(3)

Shop Yard Paint

REMARKS:

C1.4.a.5

L
L1
L2
L3
L4

YARD MOBILE EQUIPMENT

(1)

(2)

(3)

Shop Yard Paint

(4)

(5)

(6)

Are crane and forklift operators operating equipment


properly?
Are mobile equipment operators obeying the 5 mph
speed limit?
Are employees operating Aerial Lifts properly?
Are employees operating Aerial Lifts wearing proper
Fall Protection?

REMARKS:

SCAFFOLDING

M1

Does the scaffolding have a toprail, midrail, and toe boards


protecting all edges?
Are the toprail, midrail and toe boards installed properly?
Are swing gates provided on scaffolding?
If there is a potential to drop material and/or equipment from the
scaffolding, is the area beneath and around the scaffolding
barricaded with red Danger tape?
Has the scaffolding been inspected by a competent person who has
signed and dated the yellow tag?
Does the yellow tag indicate 100% tie off/fall protection required or
indicated any other hazards associated with the scaffold (i.e.
missing midrail, etc.) identified?
Does the ladder extend 3 feet past the scaffolding landing? If not, is
it identified on the scaffold tag as a hazard?

M2
M3
M4
M5
M6
M7

REMARKS:

C1.4.a.6

SAFE

AT
N/A
RISK

Environmental
EA

STORMWATER DRAINAGE SYSTEM

SAFE

AT
N/A
RISK

SAFE

AT
N/A
RISK

SAFE

AT
N/A
RISK

EA1 Is there accumulated sediment or debris in ditches, storm sewers or


inlets?
EA2 Are potential pollutants stored or used nearby?
EA3 Is there evidence of pollution in or near stormwater drainage
structures?

REMARKS:

EB
EB1
EB2
EB3
EB4
EB5
EB6
EB7

USED OIL / DIESEL STORAGE


Is the Used Oil / Diesel storage tanks leaking?
Are containers of used oil / diesel piled up around the tank?
Is there evidence of spills or leaks?
Is the tank clearly labeled Used Oil?
Is the tank and its secondary containment clear of accumulated
liquids and debris?
Is the secondary containment in good condition?
Is there evidence of overflow of pollutants from secondary
containment onto the ground?

REMARKS:

EC
EC1

HAZARDOUS WASTE STORAGE


This area is inspected weekly. Check that inspections are being
done and review the inspection forms.

REMARKS:

C1.4.a.7

DRUMMED PRODUCT DISPENSERS


(solvent dispenser, oil dispenser bank)

ED
ED1
ED2
ED3
ED4
ED5
ED6
ED7

SAFE

AT
N/A
RISK

SAFE

AT
N/A
RISK

SAFE

AT
N/A
RISK

Is each drum clearly labeled?


Are drums stored off the ground?
Is there evidence of spills or leaks?
Are drip pans and or secondary containment clean and in good
condition?
Are pumps or dispensing valves clean and not leaking?
Are tops of drums, drip pans and secondary containment free of
trash and debris?
Is the spill kit complete and in good condition?

REMARKS:

EE
EE1
EE2

OPEN-TOP TRASH CONTAINERS


Is there evidence of leakage of pollutants onto the surrounding
ground?
Is there trash on the ground around the containers?

REMARKS:

SOLVENT RECOVERY UNIT

EF
EF1
EF2
EF3
EF4
EF5
EF6
EF7

Are containers of used paints and solvents kept closed until


processing?
Is there evidence of spills or leaks?
Is the area kept neat and free of trash and debris?
Are waste paint solids not on the ground?
Is the satellite accumulation area drum clearly marked Hazardous
Waste Paint Solids?
Is the satellite accumulation area drum kept covered when not in
use?
Is there more than one drum of hazardous waste in the satellite
accumulation area? If so is it dated and no more than three days
from when it was filled and dated?

REMARKS:
C1.4.a.8

EG

OUTDOOR PAINT AND SOLVENT STORAGE

EG1
EG2
EG3

Are product containers in contact with the ground?


Is there evidence of spills or leaks?
Is there accumulated trash or debris?
Are paints and solvents stored away from drainage ways and
surface waters or otherwise isolated from them?
Are there walkways for easy access to containers?
Is the area clean and neat?
Are containers tightly sealed?
Is there an over-accumulation of used paint, thinners and cleaning
solvents waiting for recycling?
Are used paint, thinner and cleaning solvents waiting to be recycled
kept in tightly sealed and clearly labeled containers in a centralized
location?

EG4
EG5
EG6
EG7
EG8
EG9

SAFE

AT
RISK

SAFE

AT
N/A
RISK

SAFE

AT
N/A
RISK

N/A

REMARKS:

EH
EH1
EH2
EH3
EH4
EH5

PAINT AND SOLVENT STORAGE TRAILER


Is there evidence of spilled materials?
Is the trailer and surrounding area neat and free of trash and
debris?
Is the paint stored in a neat and orderly manner and out of traffic
areas?
Are there unlabeled or clearly outdated products which should be
disposed or recycled?
Is the loading/unloading area clean and fully accessible?

REMARKS:

EI
EI1
EI2
EI3
EI4

OUTDOOR FABRICATION AND REFURBISHING


AREAS
Are there concentrated accumulations of waste from metal grinding
or welding activities on the ground?
Are there open liquids containers?
Is there trash or debris accumulation?
Are spent abrasives washing into the drainage network?

C1.4.a.9

EI
EI5
EI6
EI7
EI8

OUTDOOR FABRICATION AND REFURBISHING


AREAS (continued)

SAFE

AT
N/A
RISK

SAFE

AT
N/A
RISK

SAFE

AT
N/A
RISK

Are there unmarked containers, product or waste?


Are materials containers in contact with the ground and subject to
corrosion?
Is paint being mixed outside of the designated paint mixing area?
Are cleaning solvents being used outside of the designated paint
equipment cleaning area?

REMARKS:

EJ
EJ1
EJ2
EJ3

STRUCTURAL STEEL AND FABRICATED


STRUCTURE STORAGE AREAS
Are storage areas neat and free of trash and debris?
Is there evidence of spills or leaks?
Is there evidence of concentrations of welding or grinding waste on
the ground?

REMARKS:

EK
EK1

FABRICATION SHOP
Is there evidence of spills, leaks, welding waste, floor sweepings,
grinding waste, etc. on the ground surrounding the shop?

REMARKS:

C1.4.a.10

Attachment 2

C1.5

Moreno Group LLC and Subsidiaries Facility Weekly Hazard


Assessment Checklist
Date:
Time:
Location:
Supervisor (Leader)

INSPECTION TEAM:

A
A1
A2
A3
A4
A5
A6
A7
A8

EXIT AISLES AND PASSAGEWAYS

SAFE

AT
N/A
RISK

SAFE

AT
N/A
RISK

Are exits & aisles unobstructed?


Are walkways free of welding leads, hoses, material, etc.?
Are walkways free of slipping hazards?
Are doors operating properly?
Are open holes identified and barricaded with 3/8 wire rope?
Are materials/equipment stored such that sharp objects will not
interfere with the walkway?
Are scaffolding boards secured with number 9 wire?
Is the scaffolding floor at least 18 inches in width?

REMARKS:

B
B1
B2
B3
B4
B5

HOUSEKEEPING
Yard and shop clean and free of debris?
Are areas free of material spills and are dip pans clean?
Adequate room to maneuver mobile equipment?
Trash (metal and waste) cans dumped regularly?
All material stacked securely?

REMARKS:

C1.5.a.1

HAZARD COMMUNICATION

C1

Material Safety Data Sheets (MSDS) and index accessible for all
on-site chemicals?

C2

All portable containers properly labeled?

C3

All chemical drums properly labeled with lids secured?

SAFE

AT
N/A
RISK

SAFE

AT
N/A
RISK

SAFE

AT
N/A
RISK

REMARKS:

FIRE PROTECTION

D1
D2
D3
D4

Fire extinguisher inspection within last 30 days?


Fire extinguishers fully charged with seal and tags in place?
Fire extinguishers in designated location?
Fire extinguishers unobstructed and in good condition?
No Smoking by the flammable liquid cabinet or paint storage /
usage area?
Ignition sources 35 ft. away from Flammable liquid cabinet?
Flammable liquids stored in Flammable Liquids Cabinet?
All containers within Flammable Liquid cabinet or paint storage area
sealed and labeled?
Flammable Liquid cabinet or paint storage area clean and orderly?

D5
D6
D7
D8
D9

REMARKS:

E
E1
E2
E3
E4
E5
E6
E7
E8
E9
E10

C1.5.a.2

ELECTRICAL
Are lights operational?
Is the conduit in good condition and all wiring in conduit?
Are all electrical control panels labeled as to function and voltage?
Area in front of circuit breakers clear 36 inches?
Are electrical outlets not overloaded?
Are outlets in good condition?
Are cords on electrical tools in good condition?
Are all 3-prong extension cords in good condition? (i.e. no tape,
cuts, burns, etc.)
Are ground fault circuit interrupters (GFCI) provided on all
temporary electrical equipment?
Are portable electrical tools and cords inspected and issued with
proper color tag for the month?

REMARKS:

WELDING EQUIPMENT

F3
F4

Compressed gas and oxygen cylinders stored in upright position


with protective caps, properly secured?
Oxygen and fuel gas cylinders separated (5 ft. noncombustible
barrier or 20 ft. separation)?
Are cylinders kept away from heat sources or stairs?
Are all cylinders secured?

F5

Are empty cylinders marked Empty?

F6

Are anti-flashback valves installed on cutting torches and


regulators?

F1
F2

F7
F8
F9
F10

SAFE

AT
N/A
RISK

SAFE

AT
N/A
RISK

Are welding leads completely insulated?


Are welding leads and torch hoses in good condition?
Are welding screens in good condition?
Are combustible and flammable materials stored 35 ft. away from
hot work area?

REMARKS:

G
G1
G2
G3
G4
G5
G6
G7
G8

HAND AND POWER TOOLS


Bench grinder and wire brush wheel appropriately guarded (1/4
tongue)?
Space between tool rest and wheel 1/8?
Face Shield and Eye Protection Required sign present at bench
grinder?
Is the wheel secure?
Are guards on portable grinders, wire brush, etc?
Are handles on portable grinders?
Are guards enclosing all rotating and moving equipment to prevent
physical contact?
Are portable fans provided with full guards or screens having
opening inch or less?

C1.5.a.3

HAND AND POWER TOOLS

G9

Are pneumatic and hydraulic hoses on power operated tools in


good operating condition? (i.e. no deterioration or damage)
Are pneumatic hose safely connected together with safety pins or
whip checks?
Are hand tools in good condition? (i.e. mushroomed heads, broken
or fractured handles, bent or worn wrenches, handles wedged
tightly in head of tools, etc.)
Are cutting tools edges sharp so tool will move smoothly without
binding or skipping?
Are tools stored in dry, secure locations?
Are employees using the proper tool for the job?
Is there evidence employees are inspecting hand and power tools
prior to their use?

G10
G11
G12
G13
G14
G15

SAFE

AT
N/A
RISK

SAFE

AT
RISK

REMARKS:

PERSONAL PROTECTIVE EQUIPMENT

H1

Employees wearing Hard Hats, Safety Glasses, Proper Clothing


and Steel Toed Boots?

H2
H3
H4
H5
H6
H7

Employees wearing face shields when applicable?


Employees wearing hearing protection when needed?
All respirators sanitized and properly stored?
Employees wearing respirators when applicable?
Employees using fall protection properly?
PPE locker well maintained and organized?

REMARKS:

C1.5.a.4

N/A

I
I1
I2
I3
I4
I5
I6

PORTABLE LADDERS

SAFE

AT
N/A
RISK

SAFE

AT
N/A
RISK

SAFE

AT
N/A
RISK

Ladder rungs clean and in good condition? (i.e. loose, corroded,


bent, cracked or etc.)
Ladder hinges in good working condition? (i.e. loose, bent, broken
or etc.)
Ladder locking mechanism working properly?
Ladder side rails/legs in good condition?
Does ladder sit properly when the ladder is in place or extended?
Ladder safety shoes in good condition and in place?

REMARKS:

J
J1
J2
J3
J4

YARD MOBILE EQUIPMENT


Are crane and forklift operators operating equipment properly?
Are mobile equipment operators obeying the 5 mph speed limit?
Are employees operating Aerial Lifts properly?
Are employees operating Aerial Lifts wearing proper Fall
Protection?

REMARKS:

SCAFFOLDING

K
K1

Does the scaffolding have a toprail, midrail, and toe boards


protecting all edges?

K2
K3

Are the toprail, midrail and toe boards installed properly?


Are swing gates provided on scaffolding?
If there is a potential to drop material and/or equipment from the
scaffolding, is the area beneath and around the scaffolding
barricaded with red Danger tape?
Has the scaffolding been inspected by a competent person who
has signed and dated the yellow tag?
Does the yellow tag indicate 100% tie off/fall protection required or
indicated any other hazards associated with the scaffold (i.e.
missing midrail, etc.) identified?
Does the ladder extend 3 feet past the scaffolding landing? If not, is
it identified on the scaffold tag as a hazard?

K4
K5
K6
K7

REMARKS:
C1.5.a.5

SLINGS (Wire, Chain and Nylon)

SAFE AT RISK

L1

Is the identification tag attached to sling?

RFSI

L2

Are there 10 randomly broken wires in one rope lay?

RFSI

L3

Are there 5 broken wires in one strand in one lay?

RFSI

L4

Is there wearing or scraping of original diameter of outside wire?

RFSI

L5

Is there kinking, gouging, bird caging or other damage?

RFSI

L6

Is there evidence of corrosion or heat damage?

RFSI

L7

Are there end attachments that are cracked or deformed?

RFSI

L8

Is the hook cracked?

RFSI

L9

Has the hook been opened more than 15% of normal throat
opening measured at the narrowest point?

RFSI

L10

Is the hook twisted more than 10 degrees from the plane of the
unbent hook?

RFSI

L11

Are safety latches in good condition?

RFSI

L12

Is there evidence of melting or charring of any of the sling surface?

RFSI

L13

Is there evidence of acid, caustic or heat burns?

RFSI

L14

Is there evidence of snags, punctures, tears, cuts or fraying?

RFSI

L15

Is the RED stitch showing?

RFSI

L16

Are rigging chains of Alloy Grade Lifting Chain

RFSI

L17

Are all rigging hardware Crosby or equivalent? (i.e. hooks, pad


eSafe, etc.) If no, take out of service and replace with Crosby or
equivalent.

L18
L19
L20

Are slings stored in designated location?


Are taglines returned to designated location?
Are there taglines available at the designated location?

REMARKS:

C1.5.a.6

Note: "RFSI" - Remove From Service Immediately

RFSI

N/A

M
Chain
size,
inches

CHAIN SLING INSPECTION


Minimum Allowable Chain Size at Any Point of Link
(Circle size of chain being inspected)
Minimum
Serial No. ___________
Serial No.
___________
allowable
Serial No.
Serial No.
___________
chain size,
Serial No.
Serial No.
___
inches

13

3/8

19

25

5/8

31

19

7/8

13

1 1/8
1
1 3/8

29

1 3/4

64
64
64

64
32

OK

REMOVE FROM
SERVICE

4 5 64

16
32

1 3 32

13

16
13
1 32

Inspection of Crane and Sling Hooks


M2

Is hook cracked?

M3

M5

Has the hook been opened more than 15% of the normal
throat opening measured at the narrowest point?
Has the hook been twisted more than 10 degrees from
the plane of the unbent hook?
Is the safety latch in working condition?

M6

Are load and retain points secure?

M7

Is the chain corroded?

M4

___________
___________
___________
______

SAFE

AT RISK

C1.5.a.7

Attachment 3

C1.6

Moreno Group LLC and Subsidiaries Jobsite Weekly


Hazard Assessment Checklist
Date:
Time:
Superintendent:
Location:
INSPECTION TEAM:

EXIT AISLES AND PASSAGEWAYS

A
A1
A2
A3

SAFE

AT
RISK

N/A

SAFE

AT
RISK

N/A

Are work area exits & aisles unobstructed?


Are walkways free of welding leads, hoses, material, etc.?
Are walkways free of slipping hazards?

A4

Materials/equipment stored such that sharp objects will not


interfere with the walkway?

A5

Are open holes identified and barricaded with 3/8 wire rope and
hurricane fencing?

A6

Are barricades properly used?

A7

Are material storage areas barricaded by caution tape or other


means?

REMARKS:

B
B1
B2
B3
B4
B5

HOUSEKEEPING
Are work areas clean and free of debris?
Are work areas free of material spills and are dip pans clean?
Adequate room to maneuver?
Trash (metal and waste) cans dumped regularly?
All material stacked securely?

REMARKS:

C1.6.a.1

FIRE PROTECTION

C1
C2
C3
C4
C5

Fire extinguisher inspection within last 30 days?

C6
C7
C8

C9

C10

C11

SAFE

AT
N/A
RISK

Fire extinguishers fully charged with seal and tags in place?


Fire extinguishers in designated location?
Fire extinguishers unobstructed and in good condition?
Ignition sources 35 ft. away from Flammable Materials?
Is there a trained fire watch designated during all Hot work activities
and is there the appropriate number of fire watch (i.e. On each level,
etc.)?
Is there a continuous gas detection meter calibrated and being used
by the fire watch?
Does the fire watch remain on site 30 minutes after hot work is shut
down?
Is platform shut-in at the SSV, if welding or burning is performed
within 10 of well bay or production area? If not, is the operators
MMS Approved Welding and Burning Plan being followed? If not,
Shut Down Hot Work!!!
Are equipment containing hydrocarbon or flammable substances
relocated 35 horizontally from work area? If relocation is
impractical, is equipment shielded?
Are equipment containing hydrocarbon or flammable substances at
lower levels where slag sparks could fall, relocated 35 horizontally
from point of impact? If relocation is impractical, is equipment
shielded?

REMARKS:

LOCKOUT / TAGOUT

D
D1
D2
D3
D4
D5

Is a group lockout / tagout box provided in the toolhouse?


Does the box contain adequate amount of Supervisor locks(S Series)?
Does the box contain adequate employee locks for the size of crew (E
Series)?
Are DO NOT OPERATE tagout tags provided in the group lock box?
Are lockout / tagout procedures being followed per DII procedure?

REMARKS:

C1.6.a.2

SAFE

AT
RISK

N/A

ELECTRICAL

E
E1
E2
E3

SAFE

AT
RISK

N/A

All 3-prong extension cords in good condition? (i.e. no tape, cuts,


burns, etc.)
Are ground fault circuit interrupters (GFCI) provided on all
temporary electrical equipment?
Cords on electrical tools in good condition?

REMARKS:

WELDING EQUIPMENT

F
F1

Compressed gas and oxygen cylinders stored in upright position


with protective caps, properly secured?

F2

Oxygen and fuel gas cylinders separated (5 ft. noncombustible


barrier or 20 ft. separation)?

F3

Cylinders kept away from heat sources or stairs?


Empty cylinders marked Empty?

F4
F5

Are anti-flashback valves installed on cutting torches and


regulators?

F6

Are welding machines ESDs identified?

F7
F8
F9

Welding leads completely insulated?

SAFE

AT N/A
RISK

Welding leads and torch hoses in good condition?


Are welding screens in good condition?

F10

Are welding machine frames grounded to platform if placed on


wooden decks?

F11

Is welding machine attached to the platform ESD system? If Safe,


has the nut in the Versa Valve been removed?

F12

Is welding machines skid pan clean and plugged?

REMARKS:

C1.6.a.3

HAND AND POWER TOOLS

G1
G2

Are guards on portable grinders?


Are handles on portable grinders?
Are guards enclosing all rotating and moving equipment to
prevent physical contact?
Are pneumatic and hydraulic hoses on power operated tools in
good operating condition? (i.e. no deterioration or damage)
Are pneumatic hose safely connected together with safety pins
and whip checks?
Are hand tools in good condition? (i.e. mushroomed heads,
broken or fractured handles, bent or worn wrenches, handles
wedged tightly in head of tools, etc.)
Are cutting tools edges sharp so tool will move smoothly without
binding or skipping?
Are tools stored in dry, secure locations?
Are employees using the proper tool for the job?
Is there evidence employees are inspecting hand and power tools
prior to their use?

G3
G4
G5
G6
G7
G8
G9
G10

SAFE

AT
RISK

N/A

SAFE

AT
RISK

N/A

REMARKS:

H
H1
H2
H3
H4
H5
H6
H7
H8
H9
H10
H11
H12
H13
C1.6.a.4

PERSONAL PROTECTIVE EQUIPMENT


Are employees wearing Hard Hats, Safety Glasses, Proper
Clothing and Steel Toed Boots? (i.e. clear safety glasses at night)
Are employees wearing face shields when applicable (i.e. grinding,
burning, welding, and buffing operations)?
Are employees wearing hearing protection when needed?
All respirators sanitized and properly stored?
Are employees wearing respirators when applicable?
Are employees using fall protection properly (i.e. anchor devices,
100% tied off, etc.)?
Are employees using hand protection?
Is the PPE provided in tool house well maintained and organized?
Are the employees inspecting their PPE?
Is there a Fall Protection Rescue System on location and is the
location of the Rescue System identified on the JSEA? (If working
at elevated elevations or over the side, etc.)
Are the Fall Protection Yo-Yo certifications current?
Are only engineered horizontal life-lines used and is there
adequate clearance between lifeline and lower level?
Are welders wearing Hard Hats while welding?

REMARKS:

PORTABLE LADDERS

I
I1

Ladder rungs clean and in good condition? (i.e. loose, corroded,


bent, cracked or etc.)

I2

Ladder hinges in good working condition? (i.e. loose, bent, broken


or etc.)

I3
I4
I5
I6
I7

SAFE

AT
N/A
RISK

Ladder locking mechanism working properly?


Ladder side rails/legs in good condition?
Does ladder sit properly when the ladder is in place or extended?
Ladder safety shoes in good condition and in place?
Are ladders secured to structure at top when in use?

REMARKS:

J
J1
J2

RIGGING EQUIPMENT

J3
J4

Are chain slings - Alloy Grade 80?

J6
J7
J8
J9

AT
N/A
RISK

Are Crosby or equivalent rigging hardware (i.e. shackles, hooks,


etc.) provided? (i.e. Stamped or embossed Safe Working Load and
Manufacturer)
Is the tool house pre-slung? Is sling tagged and in good condition?
Are chain or wire rope slings being used tagged and meets API RP
2d requirements? (i.e. kinking, broken wires, distortion, heat
damage, dent hooks, bad end attachments, metal corrosion or
metal loss)

J5

SAFE

Are nylon slings being used tagged and meets API RP 2d


requirements? (acid or caustic burns, melting or charring, holes,
tears, cuts, snags, broken or worn stitches, excessive abrasion or
knots)
Is air tugger in good condition? Is a manufacture eye provided?
Does the crane operator have their certification on them?
Do the riggers have their cards on them or does the superintendent
have their training documentation on location?
Are taglines being used on all lifts? If so, are enough taglines being
used on the load?

C1.6.a.5

REMARKS:

K
K1

K2

K3
K4
K5
K6
K7
K8
K9
K10
K11
K12
K13
K14
K15
K16
K17
K18
K19
K20
K21
K22
C1.6.a.6

(IF At-Risk Remove From Service Immediately)

PAINTING / BLASTING JOBS


Are employees mixing paint wearing proper PPE (Long sleeves,
Apron, Safety Glasses, Faceshield, Rubber Gloves, and mask
OV Respirator)?
Are employees wearing proper PPE during painting operations
(Long sleeves, safety glasses, supplied air respirator / hood and
gloves?
Are employees wearing proper PPE during blasting operations
(Long sleeves, safety glasses, supplied air respirator / hood,
hearing protection and gloves)?
Are all mask OV respirators provided by Moreno Group LLC and
Subsidiaries (3M 5000 series with OV cartridge and pre-filter)?
Are employees utilizing Blasthoods or Paint Hoods during spray
painting operations? (Employees may only utilize mask OV
respirators with Project Managers or designees approval)
Are all employees who wear respirators clean shaven?
Is paint being mixed in drip pans?
Is waste paint being poured into properly labeled waste drums?
Do all paint cans, solvent cans and waste drums have covers in
place when not being emptied or filled?
Is there evidence that equipment is being inspected? (Verify
condition of equipment)
Are dead man controls operational on all blast hoses?
Are On/Off safety valves on air line hoses and are they in arms
reach of blast nozzle?
Are On/Off safety valves turned off when blast nozzle is not in
use?
Are pressure gauges on paint pots in good condition and readable
(i.e. not covered with paint)?
Is the cable on the air spider in good condition (manufactured eye,
no broken wires, no arching)?
Is the air spider frame in good condition? (i.e. not bent, etc.)
Are air spiders being utilized properly (proper tie-off, proper anchor
point for spider and employee)?
Is the air spider oil level within the oil lubricator adequate?
Is the correct transfer cable being utilized on all spiders with
certification tag (i.e. transfer chain, certified transfer cable)?
Are air compressors equipped with carbon monoxide sensors and
providing Grade D breathing air?
Are CO2 monitor certification papers onsite and calibration records
up to date?
Are employees utilizing LOTO when needed?

SAFE

AT
N/A
RISK

REMARKS:

PAPERWORK

L
L1
L2
L3
L4
L5
L6
L7

Has the crew been issued a work/hot work permit and is it current?
Is the Behavioral Safety Observation process being used? If so,
are the cards being discussed in the SH&E Meeting and is the
participation at an appropriate level?
Did the Superintendent complete the Short Service Employee
Mentor Form?
Are Short Service Employees identified with a SSE sticker on hard
hats?
Is the Short Service Employees Mentor providing them direction?
Is the Offshore Tool House Checklist being used?
Verify condition of Offshore Tools House (i.e. neat, orderly, tools
tagged out, etc.)?

L9

Is Crane Operator performing and documenting a daily crane


inspection?
Does the Superintendent have the correct Moreno Group LLC and
Subsidiaries Paperwork (i.e. incident reports, SH&E Meeting, Work
Group Investigation, SH&E Training)

L11
L12

AT
N/A
RISK

SH&E Meeting conducted daily? Is the Meeting content good?

L8

L10

SAFE

Is the crew performing Weekly Hazard Assessments of their work


area?
Is the Fitness for Duty Certificate / Medical Questionnaire being
completed at the first SH&E meeting?

REMARKS:

C1.6.a.7

SCAFFOLDING

M1

Does the scaffolding have a toprail, midrail, and toe boards


protecting all edges?
Are the toprail, midrail and toe boards installed properly?
If there is a potential to drop material and/or equipment from the
scaffolding, is the area beneath and around the scaffolding
barricaded with red Danger tape?
Has the scaffolding been inspected by a competent person who
has signed and dated the yellow tag?
Does the yellow tag indicate 100% tie off/fall protection required or
indicated any other hazards associated with the scaffold (i.e.
missing midrail, etc.) identified?
Does the ladder extend 3 feet past the scaffolding landing? If not,
is it identified on the scaffold tag as a hazard?

M2
M3
M4
M5
M6

SAFE

AT
N/A
RISK

SAFE

AT
N/A
RISK

REMARKS:

TEAM WORK OF THE CREW

N
N1

Is the crew members working together?

N2

Is the crew members communicating to each other concerning job


task, hazards, etc.?

N3
N4

Is the crew providing proper communication to crane operator?

N5

N6

N7

Is the crew following the JSEA?


Are the crews following all applicable Safe Work Practices (i.e.
Lockout/Tagout, Line Opening, Crane Operations, Fall Protection,
etc.)?
Are the crews utilizing containment pan while opening process
lines? If so, is the containment pan grounded and/or bonded to the
process line?
While the employees are working, are they aware of their
surroundings (i.e. pinch points, employees working next to them,
etc.)?

REMARKS:

C1.6.a.8

Attachment 4

C1.7

WEEKLY HAZARDOUS WASTE, PAINT, SOLVENT, FUEL & OIL


STORAGE AREA INSPECTION CHECKLIST
Date:
Time:
Location:

INSPECTION TEAM:

Supervisor (Leader)

* If SAFE, provide location, remedial action taken and date of action in REMARKS.
** If NO, document in REMARKS.

HAZARDOUS WASTE CONTAINERS


STORAGE AREA CONTAINMENT

A
A1

Cracks or gaps in walls or base of containment area?

A2

Cracks or gaps in walls or base of containment area?

SAFE

AT
RISK

N/A

REMARKS:

B
B1
B2
B3

HAZARDOUS WASTE STORAGE AREA

SAFE

AT
RISK

N/A

Are hazardous waste containers properly marked and dated?


Is each container ID readable easily from access area?
Are dates of storage on any haz-waste containers 75 days from
today? (If SAFE, notify responsible person to arrange for containers
removal from facility.)

B4
B5
B6

Are the hazardous waste containers in good condition?


Are access areas unobstructed and free of debris?
Are all containers holding haz-waste closed and relief valves in
place?

REMARKS:

C1.7.a.1

HAZARDOUS WASTE SATELLINE


ACCUMULATION AREA

C
C1
C2
C3

Is hazardous wash container properly marked?


Is hazardous waste container in good condition?

C4

If haz waste over 55 gallons, has overage container been marked


with date excess began accumulating?

C5

(If SAFE, container must be removed within 3 days of date on


container)

SAFE

AT
RISK

N/A

Is haz waste container closed except when adding waste?

REMARKS:

PAINT AND SOLVENT STORAGE AREA

D1
D2
D3
D4
D5

Any evidence of leaking on base beneath containers?

D6

If SAFE, were they capped during inspection?

SAFE

AT
RISK

N/A

SAFE

AT
RISK

N/A

Any spills or leaks evident on base beneath containers?


All empty paint/solvent containers removed from storage area?
If SAFE, were they removed during inspection?
All paint/thinner/solvent containers properly capped?

REMARKS:

EMERGENCY EQUIPMENT

E
E1

Is fire equipment accessible and in good working condition? If


NO, why?

E2

Is a devise available able to summon emergency assistance?

E3

Is spill prevention equipment available?

E4

If SAFE, supplies in good condition?

REMARKS:

C1.7.a.2

FUEL AND OIL STORAGE TANKS

F
F1

SAFE

AT
RISK

N/A

Any spills, leaks, or corrosion evident on tanks?

REMARKS:

G
G1
G2
G3
G4
G5

PERSONAL PROTECTIVE EQUIPMENT

SAFE

AT
N/A
RISK

Employees wearing Hard Hats, Safety Glasses, Proper Clothing


and Steel Toed Boots?
Employees wearing face shields when applicable?
Employees wearing hearing protection when needed?
All respirators sanitized and properly stored?
Employees wearing respirators when applicable?

REMARKS:

H
H1
H2
H3

EQUIPMENT

SAFE

AT
RISK

N/A

Are Deadman controls operational on Blast Hoses?


Are Safety Pins and Whip Checks in place on all hoses?
Are Items being blasted secured in place?

REMARKS:

C1.7.a.3

Attachment 5

C1.8

MORENO GROUP AND SUBSIDIARIES


REFURBISH DECK SAFETY CHECKLIST
Date:
Time:
Location:
Supervisor (Leader)

INSPECTION TEAM:

A
A1
A2
A3
A4
A5
A6
A7
A8

A9

A10

A11

A12

SAFETY

SAFE

AT
RISK

N/A

Has paint samples been taken to analyze for lead content? *If
paint contains lead refer to Lead Job Safety Checklist
Has deck been grounded prior to work? *If no, deck needs to be
grounded prior to work.
Are there any open holes or missing handrails? *If Safe, all holes
and handrails must be corrected prior to work beginning.
Are there adequate walkways going up on the deck?
Has the deck been checked for NORM content? *If Safe, copy of
NORM free certificate needs to be provided by customer. If no,
deck needs to be checked for NORM.
Has production equipment, pipes and etc. been cleaned and
gassed free prior to any cutting or welding should be performed?
Has deck been checked for hidden hazards such as items hidden
underneath beams and flanges?
Has deck been checked for rusted handrails, stair treads, grating,
and stairway handrails? *Rusted and damaged items need to be
repaired with new grating or steel.
Has production equipment such as skidpans and living quarters
been checked for flammable or explosive material that could catch
fire when hot work is being conducted? *If no, skids and
miscellaneous areas on deck that may contain flammable or
explosive material needs to be cleaned out.
Have lifelines been installed on areas of deck where grating is
being removed during demolition work? *Lifelines need to be
installed on all areas where grating has been removed or there is
potential for a fall.
Has scope of work been communicated to all involved parties?
*Communication between crafts should be established before work
operations begin to prevent injuries from multiple job tasks being
performed.
Have tarps and visqueen been installed on deck for any blasting
operations that may be performed on painted surfaces that contain
lead? *Enclosure of deck is required before blasting begins.
C1.8.a.1

REMARKS:

ENVIRONMENTAL

B1

B2

SAFE

AT
RISK

N/A

SAFE

AT
RISK

N/A

Are there any containers or drip pans with liquids that have the
potential of spilling?
*If Safe, containers and drip pans need to be covered that nothing
can spill until containers are properly disposed of and drip pans
are cleaned?
Are there any unlabeled containers of liquid? *If Safe, Customer,
Facility Manager and SH&E Department needs to be notified so
that containers can be properly disposed of.

REMARKS:

EMERGENCY EQUIPMENT

C
C1

Is fire extinguisher accessible and in good working condition? *If


No, ensure fire extinguishers are placed on platform before
starting work.

REMARKS:

C1.8.a.2

Attachment 6

C1.9

MORENO GROUP AND SUBSIDIARIES


LEAD JOB SAFETY CHECKLIST
This checklist must be completed prior to any work on deck containing lead and must be
maintained during job and once job is completed.
Customer Name:______________________________ Job No. ______________________
Lead sample Results: ________________________________________________________
SAFE

NO

N/A

PRIOR TO WORKING
Has everyone that will be
working on the job been blood
level lead tested?
Has everyone one that will be
working on the job had
pulmonary function tests?
Has everyone that will be
working on the job been fit
tested for respirators?

SAFE

NO

N/A

SAFE

NO

Has everyone that will be


working on the job has lead
training within one year?
Has barricades been placed
around the job and the
proper warning signs
posted?
Is Decon trailer setup prior to
work?

DURING JOB
Has air monitoring been
performed for all job functions
and around perimeters of the
work area?
Are all employees wearing
proper PPE when working on
the lead surface? (respirators
required anytime lead paint is
disturbed)

N/A

SAFE AT RISK N/A

Make sure that no one is


smoking anywhere inside
the barricade of the lead
job?
Has job specific lead
program been completed?

ENVIRONMENT
Has wind breakers been setup
to make sure that lead is not
leaving work area?
Has Decon trailer wastewater
been tested prior to being
disposed of on the ground?
(Until sample has been taken
all waste water from Decon
must be stored in drums until
sample results indicate that
sample is safe to dispose of)

SAFE AT RISK N/A

SAFE AT RISK N/A

Has something been placed


on the ground to capture all
of spent sand?
Has sand been tested prior
to being hauled off site? (All
sand from a lead job must
be hauled offsite, no matter
if the results come back
positive or negative)

REMARKS:

INSPECTION TEAM:

Date:

C1.9.a.1

Attachment 7

C1.10

Moreno Group LLC and Subsidiaries SH&E Department Jobsite


Hazard Assessment
Checklist
Date:
Time:
Superintendent:
Location:
INSPECTION TEAM:

A
A1
A2
A3
A4
A5
A6
A7

EXIT AISLES AND PASSAGEWAYS

SAFE

AT
N/A
RISK

SAFE

AT
N/A
RISK

Are work area exits & aisles unobstructed?


Are walkways free of welding leads, hoses, material, etc.?
Are walkways free of slipping hazards?
Materials/equipment stored such that sharp objects will not interfere
with the walkway?
Are open holes identified and barricaded with 3/8 wire rope and
hurricane fencing?
Are barricades properly used?
Are material storage areas barricaded by caution tape or other
means?

REMARKS:

HOUSEKEEPING

B
B1
B2
B3
B4
B5

Are work areas clean and free of debris?


Are work areas free of material spills and are dip pans clean?
Adequate room to maneuver?
Trash (metal and waste) cans dumped regularly?
All material stacked securely?

REMARKS:

C1.10.a.1

FIRE PROTECTION

C
C1
C2
C3
C4
C5
C6
C7
C8

C9

C10

C11

SAFE

AT
RISK

N/A

SAFE

AT
RISK

N/A

Fire extinguisher inspection within last 30 days?


Fire extinguishers fully charged with seal and tags in place?
Fire extinguishers in designated location?
Fire extinguishers unobstructed and in good condition?
Ignition sources 35 ft. away from Flammable Materials?
Is there a trained fire watch designated during all Hot work
activities and is there the appropriate number of fire watch (i.e. On
each level, etc.)?
Is there a continuous gas detection meter calibrated and being
used by the fire watch?
Does the fire watch remain on site 30 minutes after hot work is
shut down?
Is platform shut-in at the SSV, if welding a burning is performed
within 10 or well bay or production area? If not, is the operators
MMS Approved Welding and Burning Plan being followed? If not,
Shut Down Hot Work!!!
Are equipment containing hydrocarbon or flammable substances
relocated 35 horizontally from work area? If relocation is
impractical, is equipment shielded?
Are equipment containing hydrocarbon or flammable substances
at lower levels where slag sparks could fall, relocated 35
horizontally from point of impact? If relocation is impractical, is
equipment shielded?

REMARKS:

LOCKOUT / TAGOUT

D
D1
D2
D3
D4
D5

Is a group lockout / tagout box provided in the toolhouse?


Does the box contain adequate amount of Supervisor locks(S
Series)?
Does the box contain adequate employee locks for the size of
crew (E Series)?
Are DO NOT OPERATE tagout tags provided in the group lock
box?
Are lockout / tagout procedures being followed per DII procedure?

REMARKS:

C1.10.a.2

ELECTRICAL

E
E1
E2
E3

SAFE

AT
N/A
RISK

SAFE

AT
N/A
RISK

All 3-prong extension cords in good condition? (i.e. no tape, cuts,


burns, etc.)
Are ground fault circuit interrupters (GFCI) provided on all
temporary electrical equipment?
Cords on electrical tools in good condition?

REMARKS:

WELDING EQUIPMENT

F
F1

Compressed gas and oxygen cylinders stored in upright position with


protective caps, properly secured?

F2

Oxygen and fuel gas cylinders separated (5 ft. noncombustible barrier or


20 ft. separation)?

F3
F4
F5

Cylinders kept away from heat sources or stairs?

F6

Are welding machines ESDs identified?

F7

Are mufflers and exposed hot surfaces insulated? (Welding Machines / Air
Compressors)

Empty cylinders marked Empty?


Are anti-flashback valves installed on cutting torches and regulators?

F8
F9
F10

Welding leads completely insulated?

F11

Are welding machine frames grounded to platform if placed on wooden


decks?

F12

Is welding machine attached to the platform ESD system? If Safe, has the
nut in the Versa Valve been removed?

F13

Is welding machines skid pan clean and plugged?

Welding leads and torch hoses in good condition?


Are welding screens in good condition?

REMARKS:

C1.10.a.3

HAND AND POWER TOOLS

G
G1
G2

Are guards on portable grinders?

G3

Are guards enclosing all rotating and moving equipment to prevent


physical contact?

G4

Are pneumatic and hydraulic hoses on power operated tools in good


operating condition? (i.e. no deterioration or damage)

G5

Are pneumatic hose safely connected together with safety pins and whip
checks?

G6

Are hand tools in good condition? (i.e. mushroomed heads, broken or


fractured handles, bent or worn wrenches, handles wedged tightly in
head of tools, etc.)

G7

Are cutting tools edges sharp so tool will move smoothly without binding
or skipping?

G8
G9

Are tools stored in dry, secure locations?

G10

Are handles on portable grinders?

Are employees using the proper tool for the job?


Is there evidence employees are inspecting hand and power tools prior
to their use?

REMARKS:

C1.10.a.4

SAFE

AT
RISK

N/A

PERSONAL PROTECTIVE EQUIPMENT

H1

Are employees wearing Hard Hats, Safety Glasses, Proper Clothing and
Steel Toed Boots? (i.e. clear safety glasses at night)

H2

Are employees wearing face shields when applicable (i.e. grinding,


burning, welding, and buffing operations)?

H3
H4
H5

Are employees wearing hearing protection when needed?

H6

Are employees using fall protection properly (i.e. anchor devices, 100%
tied off, etc.)?

H7
H8
H9

Are employees using hand protection?

H10
H11
H12

SAFE

AT
N/A
RISK

SAFE

AT
N/A
RISK

All respirators sanitized and properly stored?


Are employees wearing respirators when applicable?

Is the PPE provided in tool house well maintained and organized?


Are the employees inspecting their PPE?
Is there a Fall Protection Rescue System on location and is the location of
the Rescue System identified on the JSEA? (If working at elevated
elevations or over the side, etc.)
Are Fall Protection Rescue System Drills being conducted each hitch?
Are the Fall Protection Yo-Yo certifications current?

H13

Are Fall Prevention techniques / fall elimination being utilized and


addressed? (ie. Scaffolding up to work area, ensuring proper work
surfaces)

H14

Are only engineered horizontal life-lines used and is there adequate


clearance between lifeline and lower level?

H15

Are scaffold builders utilizing yo-yos attached to structural members during


scaffold erection, instead of tying off to the scaffold when available?

H15

Are welders wearing Hard Hats while welding?

REMARKS:

PORTABLE LADDERS

I
I1

Ladder rungs clean and in good condition? (i.e. loose, corroded,


bent, cracked or etc.)

I2

Ladder hinges in good working condition? (i.e. loose, bent, broken


or etc.)

I3
I4
I5
I6
I7

Ladder locking mechanism working properly?


Ladder side rails/legs in good condition?
Does ladder sit properly when the ladder is in place or extended?
Ladder safety shoes in good condition and in place?
Are ladders secured to structure at top when in use?

REMARKS:

C1.10.a.5

RIGGING EQUIPMENT

J
J1

Are Crosby or equivalent rigging hardware (i.e. shackles, hooks,


etc.) provided? (i.e. Stamped or embossed Safe Working Lead and
Manufacturer)

J2

Is the tool house pre-slung? Is sling tagged and in good condition?

J3

Are chain or wire rope slings being used tagged and meets API RP
2d requirements? (i.e. kinking, broken wires, distortion, heat
damage, dent hooks, bad end attachments, metal corrosion or
metal loss)

J4

Are chain slings - Alloy Grade 80?

J5
J6
J7
J8
J9

SAFE

AT
RISK

N/A

SAFE

AT
RISK

N/A

Are nylon slings being used tagged and meets API RP 2d


requirements? (acid or caustic burns, melting or charring, holes,
tears, cuts, snags, broken or worn stitches, excessive abrasion or
knots)
Is air tugger in good condition? Is a manufacture eye provided?
Does the crane operator have their certification on them?
Do the riggers have their cards on them or does the
superintendent have their training documentation on location?
Are taglines being used on all lifts? If so, are enough taglines
being used on the load?

REMARKS:

PAINTING / BLASTING JOBS

K1

Are employees mixing paint wearing proper PPE (Long sleeves, Apron,
Safety Glasses, Faceshield, Rubber Gloves, and mask OV
Respirator)?

K2

Are employees wearing proper PPE during painting operations (Long


sleeves, safety glasses, supplied air respirator / hood and gloves?

K3

Are employees wearing proper PPE during blasting operations (Long


sleeves, safety glasses, supplied air respirator / hood, hearing protection
and gloves)?

K4

Are all mask OV respirators provided by Moreno Group LLC and


Subsidiaries (3M 5000 series with OV cartridge and pre-filter)?

K5

Are employees utilizing Blasthoods or Paint Hoods during spray painting


operations? (Employees may only utilize mask OV respirators with
Project Managers or designees approval)

K6
K7
K8

Are all employees who wear respirators clean shaven?

K9

Do all paint cans, solvent cans and waste drums have covers in place
when not being emptied or filled?

Is paint being mixed in drip pans?


Is waste paint being poured into properly labeled waste drums?

K10

Is there evidence that equipment is being inspected? (Verify condition of


equipment)

K11

Are dead man controls operational on all blast hoses?

C1.10.a.6

K12

Are On/Off safety valves on air line hoses and are they in arms reach of
blast nozzle?

K13

Are On/Off safety valves turned off when blast nozzle is not in use?

K14

Are pressure gauges on paint pots in good condition and readable (i.e.
not covered with paint)?

K15

Is the spider pre-use inspection checklist being completed prior to each


use?

K16

Is the cable on the air spider in good condition (manufactured eye, no


broken wires, no arching)?

K17

Is the air spider frame in good condition? (i.e. not bent, etc.)

K18

Are air spiders being utilized properly (proper tie-off, proper anchor point
for spider and employee)?

K19

Is the air spider oil level within the oil lubricator adequate?

K20

Is the correct transfer cable being utilized on all spiders with certification
tag (i.e. transfer chain, certified transfer cable)?

K21

Are air compressors equipped with carbon monoxide sensors and


providing Grade D breathing air?

K22

Are CO2 monitor certification papers onsite and calibration records up to


date?

K23
K24

Are employees utilizing LOTO when needed?


Are air compressor mufflers and other exposed hot surfaces insulated?

REMARKS:

L
L1
L2
L3
L4
L5
L6
L7
L8
L9
L10
L11
L12

PAPERWORK

SAFE

AT
N/A
RISK

SH&E Meeting conducted daily? Is the Meeting content good?


Has the crew been issued a work/hot work permit and is it current?
Is the Behavioral Safety Observation process being used? If so,
are the cards being discussed in the SH&E Meeting and is the
participation at an appropriate level?
Did the Superintendent complete the Short Service Employee
Mentor Form?
Are Short Service Employees identified with a SSE sticker on hard
hats?
Is the Short Service Employees Mentor providing them direction?
Is the Offshore Tool House Checklist being used?
Verity condition of Offshore Tools House (i.e. neat, orderly, tools
tagged out, etc.)?
Is Crane Operator performing and documenting a daily crane
inspection?
Does the Superintendent have the correct Moreno Group LLC and
Subsidiaries Paperwork (i.e. incident reports, SH&E Meeting, Work
Group Investigation, SH&E Training)
Is the crew performing Weekly Hazard Assessments of their work
area?
Is the Fitness for Duty Certificate / Medical Questionnaire being
completed at the first SH&E meeting?
C1.10.a.7

REMARKS:

SCAFFOLDING

M
M1
M2
M3
M4
M5
M6

SAFE

AT
RISK

N/A

Does the scaffolding have a toprail, midrail, and toe boards


protecting all edges?
Are the toprail, midrail and toe boards installed properly?
If there is a potential to drop material and/or equipment from the
scaffolding, is the area beneath and around the scaffolding
barricaded with red Danger tape?
Has the scaffolding been inspected by a competent person who
has signed and dated the yellow tag?
Does the yellow tag indicate 100% tie off/fall protection required or
indicated any other hazards associated with the scaffold (i.e.
missing midrail, etc.) identified?
Does the ladder extend 3 feet past the scaffolding landing? If not,
is it identified on the scaffold tag as a hazard?

REMARKS:

TEAM WORK OF THE CREW

N1

Is the crew members working together?


Is the crew members communicating to each other concerning job
task, hazards, etc.?
Is the crew providing proper communication to crane operator?
Is the crew following the JSEA?
Are the crews following all applicable Safe Work Practices (i.e.
Lockout/Tagout, Line Opening, Crane Operations, Fall Protection,
etc.)?
Are the crews utilizing containment pan while opening process
lines? If so, is the containment pan grounded and/or bonded to the
process line?
While the employees are working, are they aware of their
surroundings (i.e. pinch points, employees working next to them,
etc.)?

N2
N3
N4
N5

N6

N7

REMARKS:

C1.10.a.8

SAFE

AT
N/A
RISK

JSEA FORM EVALUATION

O
O1
O2

O3

O4

O5

O6

SAFE

AT
RISK

N/A

Header Information:
Was all header information provided?
Sequence of basic job steps:
Are the job steps defined at an appropriate level of detail?
Is a pre-job safety meeting included?
Is a site inspection included?
Have any SSE been identified?
Potential Accidents or hazards:
Have potential accidents and hazards been identified?
Do they appear to be job-specific?
Was a checklist on back of the JSEA used to help identify hazards?
Recommended Safe Job Procedure:
Do job procedures appear to be job-specific?
Are job procedures clear and at appropriate level of detail?
Do procedures cover entire job from pre-job to post-job
requirements?
Have mentors been assigned to any SSE personnel?
Are Responsible Parties identified for each step?
Were lockout/tagout requirements identified?
Were barricading requirements identified?
Were communications requirements identified?
PPE Requirements
Have all required PPE been specified on the form?
Have all potential accidents or hazards been addressed either
through safe job procedures, PPE or both?
Other:
Has the JSEA form been signed by all employees involved in the
job?
Was a Crane Lift Plan required? If so, was it prepared?
Were the crew, scope or conditions of the job changed during the
job?
If so, was the JSEA form reviewed, modified, and re-signed as
required?
Is the fall rescue plan on back of JSEA being utilized whenever
employees are using fall protection?

REMARKS:

C1.10.a.9

P
P1

JSEA EMPLOYEE INTERVIEW


Tell me how the JSEA was communicated to you and the crew?

P2

What was your part in the developing of the JSEA, identifying of hazards and
setting Recommended Safe Procedures / Protection?

P3

In addition to the information provided on the JSEA, would you like to see
anything added to the JSEA (i.e. form, JSEA for Task, etc.) If any, what hazards
did you feel were not identified on the JSEA?

P4

When did you receive JSEA training?

P5

What would you do if the conditions changed during your task? (i.e. production
employees started pulling samples from a vessel?)

P6

In identifying the hazards of the task was the checklist on back of the JSEA
utilized? If so, where did you conduct this checklist?

C1.10.a.10

Q
Q1

How was the task JSEA developed and communicated with your personnel?

Q2

How do you involve your personal in the development of the JSEA?

Q3

When did you receive JSEA Training?

Q4

Describe any barriers or successes you have experienced implementing the


JSEA process?

Q5

If conditions change during a task, what do you expect your employees to do?
Have you communicated your expectations to them?

Q6

In identifying the hazards of the task was the checklist on back of the JSEA
utilized? If so, where did you conduct this checklist?

JSEA SUPERVISOR INTERVIEW

C1.10.a.11

R
R1

JSEA JOB OBSERVATION


Were the proper people in attendance?

R2

Was there full involvement by personnel present? (Hourly through Supervisors,


and representatives of all companies) Why, Why Not?

R3

Were the hazards of the job identified and properly addressed? If not, explain.

R4

Were there any observed difficulties implementing the JSEA process? Explain.

R5

Were there any changes in job scope, conditions or personnel? Were they
properly addressed?

R6

Were responsibilities clear?

R7

Were safe job procedures defined and/or followed?

C1.10.a.12

JSEA Scoring Key:


1 = Almost Never (0-20%)
2 = Less than half the time (21-50%)
3 = Most of the Time (51-80%) 4 = Almost All the Time (81-94%) 5 = Always (95-100%)

S
S1
1.1
1.2
1.3
S2
2.1
2.2
2.3
2.4
2.5
2.6

JSEA SCOREBOARD

1 2 3 4 5

Pre Job Planning:


Appropriate personnel initiate JSEA in advance of the job.
The basic job steps are clearly written and include
appropriate level of detail.
Pre-job safety meetings and site inspections are conducted
and include all persons involved in the job.
Hazard Identification and Mitigation Planning:
Potential hazards are adequately identified and described.
Safe job procedures or PPE are specified to address all
hazards which were identified.
Responsibilities for hazard mitigation are clearly defined.
All job personnel actively participate in Hazard Identification.
All employees involved in job sign off on JSEA form.
Was a jobsite inspection performed at site of task?

S3

Job Execution:

3.1

Jobs are conducted in accordance with the JSEA (job steps,


safe job procedures, responsibilities, PPE).
Jobs are adequately supervised.
Changes to job scope, personnel, and/or site conditions are
properly managed.

3.2
3.3
S4
4.1
4.2

Employee Qualifications:
SSE employees are identified and mentors assigned.
Were the employees able to effectively communicate to you
the scope of their job and JSEA?

Add the score from each line item to get the..


Divide the Total Score by 70 (Max possible score) to get.

Total Score: __________


Percent: __________

C1.10.a.13

Attachment 8

C1.11

Moreno Group LLC and Subsidiaries Offshore Tool House


Inspection Checklist
Coatings Division
Superintendent
Job Number
Job Location
Customer Name
Note: Moreno Group LLC and Subsidiaries Offshore Tool House Inspection Checklist
provides guidelines to the Tool Room Personnel when inspecting, preparing and
organizing offshore tool houses. The Offshore Superintendent upon receiving their
tool house should examine their tool house and this inspection checklist. Upon their
approval this form shall be submitted to the Offshore Manager for review and filing.

INSPECTION TEAM:

CHAIN COME ALONG

A
A1
A2
A3

SAFE

AT
RISK

N/A

Chain Intact?
Latch intact and hook not stretched?
Is chain kinked or Arced?

REMARKS:

GAUGES

AT

N/A

RISK

B2

Are gauges in good condition? (glass not cracked or broken,


readable)
Do gauges needles move freely?

B3

Is the calibration sticker affixed to gauge?

B1

SAFE

REMARKS:

C1.11.a.1

HAND TOOLS

SAFE

AT
RISK

N/A

Are hand tools in good condition? (i.e. mushroomed heads,


broken, fractured or bent handles, handles wedged tightly in
head of tools, etc.)
Are cutting tools edges sharp so tool will move smoothly without
binding or skipping?
Are tools stored in dry, secure locations?

C1
C2
C3

Are wrenches in good condition? (teeth not excessively worn or


gears move freely)
Are pinch bars excessively bent?
Are pinch bars edges not broken?

C4
C5
C6

Are screwdrivers in good condition? (tips not dent and handle


intact)
Are channel locks in good condition? (teeth not excessively
worn)
Are the hacksaw blades sharp and intact?

C7
C8
C9

REMARKS:

AIR HOSE GENERAL

D
D1
D2
D3
D4
D5
D6
D7

SAFE

AT
RISK

NA

Bull hose W/Boss clamps provided and in good


condition?
Blast hose in good condition?
Paint lines in good condition?
Hood line in good condition?
Whip checks spring mechanism working properly?
Are safety pins provided for air hose connections?
Check for grommets on air hoses?

REMARKS:

EXTENSION CORDS

E1

All 3-prong extension cords in good condition? (i.e. no tape,


cuts, burns, etc.)

E2

Are ground fault circuit interrupters (GFCI) provided on all


temporary electrical equipment?

E3
E4

Are temporary lights that are provided operational?


Are guards on lights in place?
Are all extension cords and/or electrical tools have a
Warning Source of Ignition When in Use sticker place on
each cord or tool?

E5
C1.11.a.2

SAFE

A
RISK

N/A

REMARKS:

PAINTING BLASTING & EQUIPMENT

F1

Is list of MSDS (for paint and solvents) provided?

F2

Are containment pans provided for paint pots, mixing and


storage?
Are paint screens and tarps in good condition ( no holes, not
torn)?
Are dead man controls on blast nozzles working properly and in
good condition ( not corroded are jammed)?

F3
F4
F5

Is a safety on/off valve provided on air line in arms reach of blast


nozzle?

F6

Are blast hoods & aprons provided and in good condition?

F7

Are enough inner and outer shields provided?

SAFE

AT
RISK

N/A

REMARKS:

PNEUMATIC TOOLS AND HOSES

G1

Are pneumatic and hydraulic hoses on power operated tools in


good operating condition? (i.e. no deterioration or damage)
Are pneumatic hose safely connected together or provided with
safety pins or whip checks?
Are socket retainers provided?
Are oilers installed on power tools?

G2
G3
G4

SAFE

AT
RISK

N/A

REMARKS:

I
I1
I2
I3
I4

PERSONAL PROTECTIVE
EQUIPMENT

SAFE

AT
RISK

N/A

Is caution/hazard tape provided?


Are safety glasses provided and in good condition? (clear and
tinted)
Are hard hats provided?
Are face shields provided and in good condition? (clear and
tinted)
C1.11.a.3

PERSONAL PROTECTIVE
EQUIPMENT (continued)

SAFE

AT
RISK

N/A

Is fall protection in good condition?

I5

I6
I7
I8
I9
I10

Webbing Cuts, Fraying, Abrasion, Burns, Chemical


Exposure
Buckles Deformed, Corrosion, Rust, Chemical
Exposure
Snaps
Gate works freely, Double action works,
Deformed,
corrosion, Rust Chemical Exposure
Are 3M (5000 series) mask OV respirators provided with
pre-filters and in good condition?
Are the brakes on the retractable lifelines operational?
Are material handling gloves provided?
Are chemical / impact goggles provided?
Are tyvek suits provided?

REMARKS:

SHACKLES

K
K1
K2
K3

Is the cotter pin present?

K4

Are shackles Crosby or equivalent? If no, take out of service


and replace with Crosby or equivalent.

SAFE

AT
RISK

N/A

Is the capacity of the shackle indicated?


Is the shackle in good condition?

REMARKS:

L
L1
L2
L3
L4
C1.11.a.4

FIRST AID KIT


Is the first aid kit an USCG Approved First Aid Kit?
Is the kit in good condition?
Is there a Bloodborne Pathogens kit available?
Is the kit full?

SAFE

AT
RISK

N/A

REMARKS:

LOCKOUT / TAGOUT

M
M1
M2
M3
M4

SAFE

AT
RISK

N/A

Is a group lockout / tagout box provided in the


toolhouse?
Does the box contain Supervisor locks (S1 S8)?
Does the box contain adequate employee locks for the size of
crew (E Series)?
Are DO NOT OPEN tagout tags provided in the
group lock box?

REMARKS:

SLINGS (Wire, Chain)

N1

Is the identification tag attached to sling?

N2

Are there 10 randomly broken wires in one rope lay?

N3
N4
N5

Are there 5 broken wires in one strand in one lay?


Is there wearing or scraping of original diameter of outside wire?

N6

Is there evidence of corrosion or heat damage?

N7

Are there end attachments that are cracked or deformed?

N8

Is there evidence of melting or charring of any of the sling


surface?

N9

Is there evidence of acid, caustic or heat burns?

N10
N11
N12

SAFE AT RISK N/A

Is there kinking, gouging, bird caging or other damage?

Are rigging chains of Alloy Grade Lifting Chain


Are clamps provided for cables?
Are all rigging hardware Crosby or equivalent? (i.e. hooks, pad
eSafe, etc.) If no, take out of service and replace with Crosby or
equivalent.

REMARKS:

BEAM CLAMPS

O
O1

SAFE

AT
RISK

N/A

Are beam clamps clearly marked and permanently


stamped with load rating?

REMARKS:
C1.11.a.5

SCAFFOLDING / SCAFFOLD BOARDS

P1

Are scaffold boards smooth and free of tripping hazards?

P2

Are there any cracks?

P3

Are the board warped?

P4

Are the boards stamped OSHA Approved?

P5

Are scaffolds free of rust and / or corrosion?

P6

Do pin latches work properly?

SAFE

AT
RISK

N/A

REMARKS:

AIR SPIDERS / AIR TUGGERS

Q1

Are manufacture eSafe provided on Air Tuggers? (required)

Q2

Is wire rope on air tuggers in good condition? (see Section


M2-M6)

Q3

Is the brake on the air tugger operational?

Q4

Is there evidence that the cable on the air spider has been
arched?

Q5

Is the air spider oil level within oil lubricator okay?

Q6

Is there a manufactured eye provided on the air spider?

Q7

Is the air spider frame in good condition? (not bent, etc.)

Q8

Rub a glove hand along wire rope on drum assembles to


check for broken wires? (see Section M Number M2-M6)

SAFE

AT
RISK

N/A

REMARKS:

TOOL HOUSE INSPECTION

R
R1

Is the tool house door hinges in good condition? (i.e. not


corroded, pitted, etc.)

R2

Is the tool house door in good condition? (i.e. not corroded,


pitted, etc.)

R3

Is the tool house floor in good condition? (i.e. not corroded,


pitted, etc.)

R4

Is the tool house lifting eSafe in good condition? (i.e. not


corroded, pitted, etc.)

R5

Is the internal shelving in good condition?

REMARKS:
C1.11.a.6

SAFE

AT
RISK

N/A

Superintendent Approval
Print Name:
Signature:
Date:
NOTE: Fax back to offshore manager after approval.

C1.11.a.7

Moreno Group LLC and Subsidiaries Offshore Tool House


Inspection Checklist
Construction Division
Superintendent
Job Number
Job Location
Customer Name
Note: Moreno Group LLC and Subsidiaries Offshore Tool House Inspection Checklist
provides guidelines to the Tool Room Personnel when inspecting, preparing and
organizing offshore tool houses. The Offshore Superintendent upon receiving their
tool house should examine their tool house and this inspection checklist. Upon their
approval this form shall be submitted to the Offshore Manager for review and filing.

INSPECTION TEAM:

CHAIN WIRE COME ALONG

SAFE

AT

N/A

RISK

A1
A2

A3

A4

Chain Intact?
Latch intact and hook not stretched?
Wire Not Damaged?
Are there 10 randomly broken wires in one rope lay?
Are there 5 broken wires in one strand in one lay?
Is there kinking, gouging, bird caging or other damage?
Is there evidence of corrosion or heat damage?
Is chain kinked or Arced?

REMARKS:

PIPE JACKS

B
B1
B2
B3
B4
B5

SAFE

AT

N/A

RISK

Pipe Jacks have not been welded on?


Do Pipe Jacks operate smoothly?
Is the washer present?
Are pipe jack legs in good condition? (not dent or cracked)
Are jack heads in good condition? (not dent, worn or cracked)

REMARKS:

C1.11.b.1

HAND TOOLS

C
C1
C2
C3
C4

AT
RISK

N/A

SAFE

AT
RISK

N/A

Are hand tools in good condition? (i.e. mushroomed heads,


broken, fractured or bent handles, handles wedged tightly in head
of tools, etc.)
Are cutting tools edges sharp so tool will move smoothly without
binding or skipping?
Are tools stored in dry, secure locations?
Are wrenches in good condition? (teeth not excessively worn or
gears move freely)

C5
C6

Are pinch bars excessively bent?


Are pinch bars edges not broken?

C7

Are screwdrivers in good condition? (tips not dent and handle


intact)
Are channel locks in good condition? (teeth not excessively worn)
Are the hacksaw blades sharp and intact?

C8
C9

SAFE

REMARKS:

D
D1
D2
D3
D4
D5
D6
D7

GRINDERS AND ELECTRICAL EQUIPMENT


Is the ground plug present, or is the tool double insulated?
Is the cord of the tool in good condition? (not frayed)
Is the guard in place? (required to be in place)
Is the handle in place? (required to be in place)
Is the RPMs of blade equal to grinders RPMs?
Does the bevel machine chain move freely?
Does each electrical tool have a Warning Source of Ignition
When in Use Sticker placed on it?

REMARKS:

C1.11.b.2

E
E1
E2
E3
E4
E5

EXTENSION CORDS / LIGHTS

SAFE

AT
RISK

N/A

All 3-prong extension cords in good condition? (i.e. no tape,


cuts, burns, etc.)
Are ground fault circuit interrupters (GFCI) provided on all
temporary electrical equipment?
Are temporary lights that are provided operational?
Are guards on lights in place?
Does each extension cords or non classified (Class 1, Div 1)
lights have a Warning Source of Ignition When in Use sticker
place on it.

REMARKS:

WELDING EQUIPMENT

F
F1
F2
F3
F4
F5
F6
F7
F8

SAFE

AT
RISK

N/A

Compressed gas and oxygen cylinders stored in upright


position with protective caps, properly secured?
Oxygen and fuel gas cylinders separated (5 ft. noncombustible
barrier)?
All cylinders secured?
Welding leads completely insulated?
Welding leads in good condition?
Are welding tarps in good condition?
Do the welding machines start?
Does the Emergency Shutdown Device (ESD) on welding
machines work?

REMARKS:

PNEUMATIC TOOLS AND HOSES

G1

Are pneumatic and hydraulic hoses on power operated tools in


good operating condition? (i.e. no deterioration or damage)
Are pneumatic hose safely connected together or provided with
safety pins or whip checks?
Are socket retainers provided?
Are oilers installed on power tools?

G2
G3
G4

SAFE

AT
RISK

N/A

C1.11.b.3

REMARKS:

GAUGES

H
H1
H2
H3
H4
H5

SAFE

AT
RISK

N/A

Are gauges in good condition? (gauge glass not cracked,


scratched or broken)
Do gauges needles move freely?
Is the calibration sticker affixed to gauge?
Are anti flashback and check valves provided on regulators?
Are regulators in working condition?

REMARKS:

PERSONAL PROTECTIVE
EQUIPMENT

I
I1
I2
I3

I4

I5
I6
I7
I8
I9

Are safety glasses provided and in good condition? (clear and


tinted)
Are hard hats provided?
Are face shields provided and in good condition? (clear and
tinted)
Is fall protection in good condition?
Webbing Cuts, Fraying, Abrasion, Burns, Chemical
Exposure
Buckles Deformed, Corrosion, Rust, Chemical
Exposure
Snaps
Gate works freely, Double Lock works, Deformed,
corrosion, Rust Chemical Exposure
Are anchor points provided? (anchor pads, beamers, hand
grips, etc.)
Are the brakes on the retractable lifelines operational?
Are material handling gloves provided?
Are chemical / impact goggles provided?
Are tyvek suits provided?

REMARKS:

C1.11.b.4

SAFE

AT
RISK

N/A

TORCHES

J
J1

Are anti-flashback and check valves provided?

J2

Are torch tips in provided and in good condition?

J3
J4

Are the torch tip orifice provided?

J5

SAFE

AT
RISK

N/A

Is an o-ring kit included?


Are gas and oxygen hoses in good condition or repaired
properly?

REMARKS:

K
K1
K2
K3
K4

SHACKLES

SAFE

AT
RISK

N/A

a.
Is the cotter pin present?
Is the capacity of the shackle indicated?
Is the shackle in good condition?
Are shackles Crosby or equivalent? If no, take out of service
and replace with Crosby or equivalent.

REMARKS:

L
L1
L2
L3
L4

FIRST AID KIT

SAFE

AT
RISK

N/A

b.
Is the first aid kit an USCG Approved First
Aid Kit?
c.
Is the kit in good condition?
d.
Is there a Bloodborne Pathogens kit
available?
e.
Is the kit full?

REMARKS:

C1.11.b.5

SLINGS (Wire, Chain and Nylon)

M1

Is the identification tag attached to sling?

M2

Are there 10 randomly broken wires in one rope lay?

M3

Are there 5 broken wires in one strand in one lay?

M4

Is there wearing or scraping of original diameter of outside


wire?

M5

Is there kinking, gouging, bird caging or other damage?

M6

Is there evidence of corrosion or heat damage?

M7

Are there end attachments that are cracked or deformed?

M8

Is the hook cracked?

M9

Has the hook been opened more than 15% of normal throat
opening measured at the narrowest point?

M10

Is the hook twisted more than 10 degrees from the plane of the
unbent hook?

M11

Are safety latches in good condition?

M12

Is there evidence of melting or charring of any of the sling


surface?

M13

Is there evidence of acid, caustic or heat burns?

M14
M15
M16

Is there evidence of snags, punctures, tears, cuts or fraying?

M17

Is the RED stitch showing?


Are rigging chains of Alloy Grade Lifting Chain
Are all rigging hardware Crosby or equivalent? (i.e. hooks, pad
eSafe, etc.) If no, take out of service and replace with Crosby
or equivalent.

REMARKS:

C1.11.b.6

SAFE

AT
RISK

N/A

N
N1
N2
N3
N4

LOCKOUT / TAGOUT

SAFE

AT
RISK

N/A

Is a group lockout / tagout box provided in the toolhouse?


Does the box contain Supervisor locks (S1 S8)?
Does the box contain adequate employee locks for the size of
crew (E Series)?
Are DO NOT OPEN tagout tags provided in the group lock
box?

REMARKS:

O
O1

BEAM CLAMPS

SAFE

AT
RISK

N/A

Are beam clamps clearly and permanently stamped


with load rating?

REMARKS:

SCAFFOLDING / SCAFFOLD BOARDS

P1

Are scaffold boards smooth and free of tripping


hazards?

P2

Are there any cracks?

P3

Are the board warped?

P4

Are the boards stamped OSHA Approved?

P5

Are scaffolds free of rust and / or corrosion?

P6

Do pin latches work properly?

SAFE

AT
RISK

N/A

REMARKS:

AIR SPIDERS / AIR TUGGERS

Q1

Are manufacture eSafe provided on Air Tuggers? (required)

Q2

Is wire rope on air tuggers in good condition? (see Section M2M6)

Q3

Is the brake on the air tugger operational?

Q4

Is there evidence that the cable on the air spider has been
arched?

Q5
Q6
Q7

Is the air spider oil level within oil lubricator okay?


Is there a manufactured eye provided on the air spider?
Is the air spider frame in good condition? (not bent, etc.)
Rub a glove hand along wire rope on drum assembles to check
for broken wires? (see Section M Number M2-M6)

Q8

SAFE AT RISK N/A

C1.11.b.7

REMARKS:

TOOL HOUSE INSPECTION

R1

Is the tool house door hinges in good condition? (i.e. not


corroded, pitted, etc.)

R2

Is the tool house door in good condition? (i.e. not corroded,


pitted, etc.)

R3

Is the tool house floor in good condition? (i.e. not corroded,


pitted, etc.)

R4

Is the tool house lifting eSafe in good condition? (i.e. not


corroded, pitted, etc.)

R5

Is the internal shelving in good condition?

REMARKS:

C1.11.b.8

SAFE

NO

N/A

Superintendent Approval
Print Name:
Signature:
Date:
NOTE: Fax back to offshore manager after approval

C1.11.b.9

Moreno Group LLC


and Subsidiaries
SH&E Management
System

SH&E Management System


Change Procedure

Page: 1 of 2
Original: 01/01/2003
Revised: 01/01/2008

SH&E Management System Change Procedure


Purpose
The purpose of this procedure is to establish a method for Moreno Group LLC and
Subsidiaries to develop, revise and distribute changes or additions to SH&E
Management System.
Scope
The scope of this procedure entails the controlled movement/distribution of all
documents for SH&E Management.
Responsibilities
The Facility / Site Manager / Offshore Manager, First Line Supervisor / Offshore
Superintendent or Designees is responsible for:
Understanding and complying with revisions to Moreno Group LLC and
Subsidiaries SH&E Management System.
Approving of any newly developed or revised program.
Assuring SH&E Management System Manuals are updated with the
revisions.
Implementing the changes or additions into the overall SH&E Management
System.
The Safety, Health and Environmental Department is responsible for:
The Corporate SH&E Manager will be the SH&E Management System
Administrator.
Developing procedures to meet or exceed industry and / or regulatory
requirements and / or standards.
To provide training to management and supervision pertaining to the changes
or additions to the SH&E Management System.
Maintain an ongoing list of those individuals assigned a SH&E Management
System Manual.

C2.1

The Employee is responsible for:


Understanding and complying with the changes or additions to the SH&E
Management System.
Requirements
The SH&E Department will develop and / or revise the SH&E Management System
with managements approval. The SH&E Management will be revised due to any of
the following situations:
New or Revised Regulatory Requirements
New or Revised Industry Standards
Deficiencies identified during an Audit or Assessment of SH&E Management
System
The addition of a new system or product or service line.
Upon the completion of the development of the revision, the SH&E Department will
issue the revisions to all SH&E Management System Manual owners.
Once manuals owners have time to read and understand the SH&E Management
System revision, the SH&E Department will conduct an orientation to address the
revision.
After this orientation, Management and Supervision will be expected to implement
the revisions.

C2.2

Moreno Group LLC and


Subsidiaries SH&E
Management System

Contractor Safety, Health


and Environmental
Program

Page: 1 of 13
Original: 01/01/2003
Revised: 5/01/2009

Contractor Safety, Health and Environmental Program


Purpose
The purpose of this program is to provide guidelines to evaluate Moreno Group LLC
and Subsidiaries Contractors Safety, Health and Environmental performance and to
communicate the minimum safety, health and environmental requirements for the
protection of Company and Contractor employees, property and the environment.
Scope
The scope of this program describes procedures for implementing Moreno Group
LLC and Subsidiaries Contractor Safety, Health and Environmental Management
Program. This program contains the necessary elements of a Contractor Safety,
Health and Environmental Management Program to serve a variety of end users.
This program requires Contractors (including Subcontractors) to abide by Moreno
Group LLC and Subsidiaries and their Clients Safety, Health and Environmental
polices and procedures, applicable government regulations as well as recognized
industry standards and practices.
Responsibilities
The Facility Manager / Offshore Manager or Designee is responsible for:
Providing the appropriate resources to implement this program.
Communicating to contractors Moreno Group LLC and Subsidiaries Safety,
Health and Environmental expectations and requirements.
The Yard Foreman / Offshore Superintendent is responsible for:
Utilizing those contractors who have completed Moreno Group LLC and
Subsidiaries Contractor Safety, Health & Environmental evaluation process.
Conduct or coordinate the Contractor SH&E Orientation.
Monitor the Contractors Safety, Health and Environmental performance during
the project.
Audit Contractors jobsites while performing Moreno Group LLC and Subsidiaries
designated hazard assessments. Ensure Contractors are developing and utilizing
a job specific Job Safety and Environmental Analysis for their job tasks.

D1.1

Communicate issues to the Facility Manger or Offshore Manager as soon as


possible.
The Project Manager is responsible for:
Submitting to contractors Moreno Group LLC and Subsidiaries Generic Safety,
Health and Environmental Questionnaire.
Utilizing those contractors who have completed this Contractor Safety, Health &
Environmental evaluation process.
Tabulate and provide to the SH&E Department the man hours accumulated by
contractors.
The Safety, Health and Environmental Department is responsible for:
Evaluating Moreno Group LLC and Subsidiaries Contractors Generic Safety,
Health and Environmental Programs per this program.
Assisting Facility Management in communicating Moreno Group LLC and
Subsidiaries Safety, Health and Environmental Programs expectations and
requirements.
Assisting the Yard Foreman or Offshore Superintendent in conducting or
coordinating Moreno Group LLC and Subsidiaries Contractor Safety, Health and
Environmental Orientation and hazard assessments.
Holding Subcontractor accountable for their SH&E Performance
Obtain from Project Managers man hour accumulated by subcontractors and
provide to our clients upon request.
Requirements
Evaluation Requirements
To ensure that Contractors are capable of effectively managing the safety, health
and environmental requirements of proposed work/projects in accordance with
Moreno Group LLC and Subsidiaries or Clients requirements, all Contractors will
undergo a qualification evaluation prior to beginning work at any Moreno Group LLC
and Subsidiaries or Client location. Contractors that work onsite and have significant
exposure to risk due to the type of jobs or number of personnel on location may be
subject to a more comprehensive evaluation.
In addition, Contractors will be held accountable for the safety, health and
environmental performance of their Subcontractors. Subcontractors must also meet
the requirements of this plan and undergo a performance evaluation. The
performance of the Subcontractors will be reflected in the Contractors performance
evaluation.
D1.2

Qualification
Pre-qualification
Safety, Health and Environmental performance are important parameters in the
Contractor selection process. The pre-qualification process consists of the review of
the Contractors SH&E statistical performance.
Statistical Performance
To initiate an evaluation of a prospective Contractors safety, health and
environmental performance, Moreno Group LLC and Subsidiaries will request that all
Contractors complete a Generic Safety, Health and Environmental Questionnaire
(see Attachment 1).
The questionnaire is designed to collect relevant information on historical safety,
health and environmental performance. The acquired information will be utilized to
compare the prospective Contractors performance to that of other Contractors within
the similar work classifications.
Pre-qualification criteria information
The following selection criteria will be utilized for this initial pre-qualification stage:
Experience Modification Rate (EMR) for the past three years (NCCI rate)
Total recordable incident rates for injuries and illnesses for the past three years
for the business unit or region that the Contractor is operates from;
Number of fatalities experienced in the past three years for the business unit or
region that the Contractor operates from; and
Number of regulatory/legal citations, penalties and/or sanctions issued against
the Contractor within the past three years for the business unit or region that the
Contractor operates from.
Pre-qualification performance cut-off
Current EMR should not exceed 1.00, or the previous three-year average should
not exceed 1.25
And
The average of the last two of the previous three years total recordable incident
rate should not exceed the most current national BLS rate for the corresponding
businesses.
If the Contractor fails to qualify within the above restrictions, the Contractor
qualification process will be terminated until such a time that the Contractor meets
with Moreno Group LLC and Subsidiaries and provide sufficient information to
D1.3

indicate a significant improvement in their SH&E program. The Contractor will be


formally notified regarding rejection from the qualification process and the reason(s)
thereof. If the Contractor meets the above criteria, proceed with the qualification
process.
The incident rates will be determined from the most current edition of the U.S.
Bureau of Labor Statistics publication.
Safety, Health and Environmental Management System Assessment
Moreno Group LLC and Subsidiaries or designated representative may conduct
interviews with the prospective Contractors safety, health and environmental and
management personnel regarding the management of their Safety, Health and
Environmental program (see Attachment 2). A relative score regarding the results of
this assessment shall be assigned to the Contractor. (see Attachment 4)
Contractor Facility or Jobsite Assessment
When warranted, Moreno Group LLC and Subsidiaries or designated
representative(s) may conduct a visual (on-site) audit of the prospective Contractors
operating facilities and/or Jobsite (see Attachment 3). In the event that it is not
possible to conduct the site assessment within this phase of the evaluation process,
the Contractor shall be conditionally accepted for work pending the completion of a
site assessment. A site assessment shall be completed during the Contractors initial
job assignment and forwarded to the Contractor Administrator for evaluation
completion. The Contractor may not be allowed to perform any other jobs until the
evaluation is completed and the Contractor is assigned their rating status.
A relative score shall be assigned to the Contractor regarding the results of this
assessment and shall be used to help determine the prospective Contractors rating
(see Attachment 4).
Contractors that can not be evaluated via a site assessment, i.e. Contractors that
provide only personnel to Moreno Group LLC and Subsidiaries, will be required to
provide alternative information in support of their performance qualifications.
Information in addition to that provided by the Contractor may also be obtained
through the following processes;
Interviews with Contractor Management
Letters of commendation from other companies for which the Contractor is or has
worked
Interviews with Contractor personnel
Review of resources available to the Contractor to meet Moreno Group LLC and
Subsidiaries, government and Industry requirements

D1.4

Contractor Safety, Health and Environmental Program Rating


The data acquired from the Generic Safety, Health and Environmental
Questionnaire, Safety, Health and Environmental Management System and Facility
Assessments may be used to develop a composite qualification score for the
prospective Contractor. An applicable score shall be given to the Contractor for each
criteria component. (See Attachment 4)
PRE-QUALIFICATION COMPOSITE SCORE TABLE _
Criteria
Range
Scores
================================================
TRIR
50% of BLS Avg.
+25
(previous year)
50% to BLS Avg.
+15
EMR
(previous year)

< 1.0
>1- 1.25

+15
+10

Site Assessment

Maximum

+15

SH&E Mgmt.
Process
Assessment

Maximum

+45

Fatality

Within past year


Within past 2 years
Within past 3 years

- 15
- 10
-5

[Maximum allowable score is 100]


Feedback & Expectations
When it has been determined that a Contractor has met all of Moreno Group LLC
and Subsidiaries or Client qualification requirements, the Contractor may then be
added to a list of accepted Contractors.
Accepted Contractors (approved, conditional) may perform work requiring immediate
attention, provided that a current contract or master service agreement is on file. .
All accepted Contractors shall be forwarded a copy of the requirements as outlined
in Moreno Group LLC and Subsidiaries Safety, Health and Environmental
Handbook.
Contractors that fail to meet Moreno Group LLC and Subsidiaries pre-qualification
requirements shall be formally notified regarding the reason(s) for rejection and
associated restrictions as defined by the Facility Management.
Contractor Safety, Health and Environmental Qualification Review
All accepted Contractors safety, health and environmental performance shall be
D1.5

re-evaluated at determined intervals. The scope of the review shall be as follows:


Contractors rated as Accepted
Submission of PQF every three years unless warranted
Three years comprehensive re-assessment (qualification)
Contractors rated as Conditional
Annual Pre-qualification Form (PQF) or equivalent
At a minimum, Annual comprehensive re-assessment (qualification)
At any time that a Contractors Safety, Health and Environmental performance
deteriorates significantly a comprehensive re-qualification may be requested by
Moreno Group LLC and Subsidiaries Facility Management.
Contractors rated as Rejected (red)
Two years from current assessment date, Rejected contractor may appeal to
Moreno Group LLC and Subsidiaries for a re-assessment (qualification).
Note: Should a Rejected contractor be used due to an existing contract and/or
equipment at our facilities, the Facility Manager must approve the use of said
contractor in writing. The Yard Manager / Offshore Superintendent or designee will
monitor the contractors performance on a continual base while they are on Moreno
Group LLC and Subsidiaries or our Clients location.
Intervention Use
In an emergency situation, it may not be feasible to pre-qualify a Contractor prior to
selection. In such cases, it is recommended that the Facility Manager attempt to
acquire a completed PQF (or equivalent) and a copy of the Safety, Health and
Environmental Management Program of the prospective Contractor. The Moreno
Group LLC and Subsidiaries Facility Manager, Yard Manager and SH&E
Department Representative should review the acquired information. Once the team
agrees to use the Contractor, they should outline the project task and the
Contractors performance expectations. Upon the completion of this process the
Facility Manager must authorize the initiation of work in writing. Moreno Group LLC
and Subsidiaries should have company supervision during the duration of this
contractors project.
Examples of intervention work are:
Environmental Releases
Fire & Explosions
Evacuation Situations
Other critical activities as approved by Facility Management
D1.6

Safety, Health and Environmental Orientation


The Moreno Group LLC and Subsidiaries Yard Foreman / Offshore Superintendent
or designee shall conduct or coordinate a Contractor Safety, Health and
Environmental Orientation for all the contractors employees. The orientation should
be conducted prior to beginning work and include the following information:
Confirm SH&E Training Documentation is on-site (see attachments).
Instructions to the Contractor to report any unique hazards that may develop
from their work activities to the Moreno Group LLC and Subsidiaries Yard
Foreman, First Line Supervisors or Offshore Superintendents.
Instructions to the Contractor to report any hazards identified by them and all
incidents to the Moreno Group LLC and Subsidiaries Yard Foreman, First Line
Supervisors or Offshore Superintendents
Requirements to conduct Daily SH&E Meetings and/or Job Safety &
Environmental Analysis.
Work-in-progress Activities
The purpose of work-in-progress activities are to ensure that Safety, Health and
Environmental objectives are being achieved and managed.
The Yard Foreman / Offshore Superintendents or designee shall monitor the
Contractors job performance and conformance with SH&E requirements. Work-inprogress audits will be incorporated into the Weekly or Monthly Hazard Assessment
processes. Upon completion of the work-in-progress audits, the Yard Foreman /
Offshore Superintendent or designee should provide counseling to the Contractor
and/or take action as required. This counseling shall be documented and retained
and forwarded to the Project Manager of the project to discuss with the Contractors
Management.
As part of the Work-in-progress processes documentation may be requested to
verify that Contractors are conducting daily tailgate meetings, and new worker
orientation. This shall be documented during Moreno Group LLC and Subsidiaries
Hazard Assessments Checklist (Weekly).
Moreno Group LLC and Subsidiaries Inc. Project Managers will tabulate and provide
to the SH&E Department on a quarterly bases the man hours accumulated by the
subcontractors on our projects. The SH&E Department will provide these man hours
to our clients upon request.
Trade Secrets
Employers shall make all information necessary to those persons responsible for
compiling the process safety information required by CFR 1910.119(d) without
regard to trade secrets status of such information:
D1.7

Assisting in the development of the process hazard analysis (required by


paragraph (e) of the standard
Responsible for developing the operating procedures required by paragraph
(f)
Involved in incident investigations required by paragraph (m)
Emergency planning and response required by paragraph (n) and
Compliance audits within paragraph (o).
Nothing in this paragraph shall preclude the employer from requiring the person
to whom the information is made available under paragraph (p)(1) of 1910.119 to
enter into a confidentiality agreement not to disclose the information as set forth
in 29 CFR 1910.1200.
Pre and Post Job Meetings
As required all Contractors and Subcontractors will be expected to participate in all
Pre and Post Job Meetings. Pre meetings may be used to communicate SH&E
Expectations, Scheduling of Personnel, Materials and Project, and Review of Project
Scope. Post Job meetings may be utilized to review project performance. At a
minimum the following areas shall be reviewed: SH&E Performances (lagging and
leading indicators), the meeting of project schedule requirements, and any lesson
learned during the project.

D1.8

Attachment 1

D1.9

SAFETY, HEALTH AND ENVIRONMENTAL


GENERIC QUESTIONNAIRE
(Form: SSQ 1.0)
NAME OF COMPANY AND ADDRESS:

Date: ______________________________

__________________________________

Contact: ____________________________

__________________________________

Form Completed by: __________________

__________________________________

Phone #: ___________________________

__________________________________

Fax #: _____________________________

__________________________________

SIC # _____________________________

Please describe the services your company provides:


Please see attached cover letter.
The information requested must be for the local Division, District, Branch, etc. of your
company. We are not interested in overall statistics at a national or international
level. All Information must be documented.
1.

Please describe the area or region this questionnaire applies (i.e. local Division,
District, Branch).

2.

In the table below, provide the three most recent full years of incident information for
your company. See "Attachment 1, Definition of Terms" for details.
In addition to completing the tables, attach copies of your company's OSHA 300
log for the last three full years. If your company is not required to complete an
OSHA 300 log, provide copies of other appropriate industry-related
documentation, e.g. ADC, etc. We require verification of the EMR/discount rate
information, see "Attachment 1" for details.

Exposure
Incidence Number of
Average
Number of
or
Rate of
Lost
Year Number of
Recordable
Employee
Recordable Workday
Employees
Cases
Hours
Cases
Cases

Incidence
Rate of
Lost
Workday
Cases

Number of
Lost
Severity
Workdays
Rate

EMR

Number of
Fatalities

3.

Specify the basis for exposure or employee hours (8 hr shifts, 12 hr shifts, 24 hrs, etc.)

4.

If your company is self-insured, what is your discount rate?


Comments _________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________

D1.9.a.1

5.

Has your company received any inspections from a regulatory agency during the last
three years?
Yes____ No____
If yes, please provide details: ____________________________________________
___________________________________________________________________

6.

Has your company received any citations from a regulatory agency during the last
three years?
Yes____ No____
If yes, please provide details: ____________________________________________
___________________________________________________________________

7.

Are all documents, pertaining to this questionnaire, available for auditing?


Yes____ No____
If no, please explain:___________________________________________________
___________________________________________________________________

8.

Please respond to ALL items with "Yes ,No, or N.A." Do not leave any items
unanswered. (Estimated Percentage of Employees should reflect the percentage of
employees who are required to have the training - not the percentage of the total
number of employees in your organization):

PROGRAMS/TRAINING

Reference
Source

Program
Documented
and Written
Yes/No/NA

API T-1

API RP T-1

Bloodborne Pathogens

OSHA 29 CFR
1910.1030(g)(2)

Confined Space Entry Entrant Level

OSHA 29 CFR
1910.146(g)

Confined /space Entry Attendant Level

see above

Confined Space Entry Supervisor Level

see above

Confined Space Entry


Rescuer

see above

Cranes

API RP 2D

Defensive Driving

OSHA Proposed

DOT HM-126F Hazmat


Employee

DOT 49 CFR
172.704

Drug Awareness

DOT 46 CFR
16.401 & 391.119

D1.9.a.2

Estimated
Percentage of
Employees
Receiving
Training

Frequency of
Training for
Individual
Employees

Individual
Employee
Training
Documented
Yes/No/NA

PROGRAMS/TRAINING

Reference
Source

Program
Documented
and Written
Yes/No/NA

Electrical Safety

OSHA 29 CFR
1910.332

Emergency Response

OSHA 29 CFR
1910.38(a)

First Aid/CPR

OSHA 29 CFR
1910.151(b)

Forklifts

OSHA 29 CFR
1910.178(l)

Generic Safety Orientation

OSHA 29 CFR
1910.119(h)(3)

H2S

MMS 30 CFR
250.67

HAZCOM

OSHA 29 CFR
1910.1200(h)

Hazwoper - Awareness Level

OSHA 29 CFR
1910.120

Hazwoper 8 Hour

see above

Hazwoper 24 Hour

see above

Hazwoper - 40 Hour

see above

Hazwoper Supervisor 8 hour

see above

Hearing Conservation

OSHA 29 CFR
1910.95

Incipient Fire Fighting

OSHA 29 CFR
1910.157(g)

Lead Worker

OSHA 29 CFR
1926.62(l)

Lead Supervisor

see above

Lockout/Tagout - Authorized
Person

OSHA 29 CFR
1910.147(c)(7)

Lockout/Tagout -Affected
Person

see above

Lockout/Tagout - Other

see above

Personal Protective Equip.

OSHA 29 CFR
1910.132(f)

Process Safety Mgmt.

OSHA 29 CFR
1910.119(g)(1)

Production Safety Systems T-2

MMS 30 CFR
250.214

Respiratory Protection

Welding and Burning

Estimated
Percentage of
Employees
Receiving
Training

Frequency of
Training for
Individual
Employees

Individual
Employee
Training
Documented
Yes/No/NA

OSHA 29 CFR
1910.134(e)(5)
OSHA 29 CFR
1910.252(a)(2)(xii)
(c)
MMS 30 CFR
250.52

D1.9.a.3

PROGRAMS/TRAINING

Reference
Source

Program
Documented
and Written
Yes/No/NA

Well
Control/Completion/Workover

MMS 30 CFR
250.212-213

Manual Lifting Techniques

N/A

Rigging/Material Handling

N/A

Supervisory Skills

N/A

Survival Craft

N/A

Total Quality Management

N/A

Water Survival (classroom)

N/A

Water Survival (practical)

N/A

Work/Post Injury Management

N/A

Estimated
Percentage of
Employees
Receiving
Training

Frequency of
Training for
Individual
Employees

Individual
Employee
Training
Documented
Yes/No/NA

9.

Please provide any additional information on other industry-specific programs or


training, including written procedures, which your company provides to employees:
___________________________________________________________________

10.

Does your company comply with the Process Safety Management provisions found in
29 CFR 1910.119 and/or API RP 75?
Yes____ No____
Comments: __________________________________________________________
___________________________________________________________________

11.

Does your company have scheduled documented employee safety meetings?


Yes____ No____
If yes, how often: _____________________________________________________

12.

Who conducts the safety meetings? Job Title:

13.

What managers/supervisors participate in the safety meetings?


JobTitles: ___________________________________________________________

14.

Are meetings reviewed and critiqued by manager/supervisors?

Yes____ No____

15.

What were the topics or issues discussed at the last two safety meetings?
Topics/Issues:

Meeting Date:________________________

Topic/Issues:

Meeting Date:________________________

D1.9.a.4

16.

Does your company hold on-site (tailgate/toolbox/pretour) safety meetings?


Yes____ No____
If yes, how often?_____________________________________________________

17.

Who conducts these safety meetings? Job Title: ____________________________


Is documentation available?

Yes____ No____

18.

Does your company perform Job Safety Analysis (JSA)?

Yes____ No____

19.

Does your company provide/require the following personal protective equipment:


___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________

20.

COMPANY
PROVIDED

COMPANY
REQUIRED

Hard hats(ANSI-Z89.1)
(29 CFR 1910.135)

NA___

Yes___No___

Yes___No___

Safety shoes(ANSI-Z41.1)
(29 CFR 1910.136)

NA___

Yes___No___

Yes___No___

Eye protection(ANSI-Z87.1)
(29 CFR 1910.133)

NA___

Yes___No___

Yes___No___

Hand protection
(29 CFR 1910.132)

NA___

Yes___No___

Yes___No___

Hearing protection
(29 CFR 1910.95)

NA___

Yes___No___

Yes___No___

Fall protection
(29 CFR 1910.129)

NA___

Yes___No___

Yes___No___

Respiratory protection
(29 CFR 1910.134)

NA___

Yes___No___

Yes___No___

Personal Flotation Devices


(33 CFR 142.45)

NA___

Yes___No___

Yes___No___

In addition to regulatory required the Personal Protective Equipment , what other PPE
is required or supplied? _______________________________________________
___________________________________________________________________

D1.9.a.5

21.

If any, please describe or list: ____________________________________________


___________________________________________________________________

22.

Does your company have a written policy regarding drug screening or testing of your
employees?
Yes____ No____ Comments: ___________________________________________
___________________________________________________________________

23.

Does your drug testing program conform to DOT requirements?


Yes____ No____
Comments: _________________________________________________________
___________________________________________________________________

If yes, which set of DOT regulations is your drug testing program designed to satisfy?

24.

Federal Aviation Administration

Yes____ No____

United States Coast Guard

Yes____ No____

Research and Special Projects Administration - Pipeline

Yes____ No____

Federal Railroad Administration

Yes____ No____

Federal Highway Administration

Yes____ No____

Indicate the circumstances in which your company's employees may be subject to


drug screening.
( ) Employment
( ) Random

25.

( ) Probable Cause
( ) Post Accident

( ) Periodic
Other:

Does your company have policy requiring written accidents/incident reports (spills,
injuries, property damage, etc.)?
Yes____ No____

26.

Does your company conduct accident/incident investigations?

Yes____ No____

If yes, please attach a brief outline of procedures: ___________________________


___________________________________________________________________

27.

Does your company document, investigate, and discuss near miss accidents?
Yes____ No____
If yes, is documentation available?

D1.9.a.6

Yes____ No____

28.

Are accident/incident reports reviewed by managers/supervisors? Yes____ No____

29.

Does your company use subcontractors?

Yes____ No____

If yes, explain: ________________________________________________________


___________________________________________________________________

30.

Does your company review the safety management systems of subcontractors?


Yes____ No____

31.

Does your company verify that subcontractors meet or exceed your safety and training
requirements?
Yes____ No____
If no, explain: ________________________________________________________
___________________________________________________________________

32.

Describe the programs utilized to monitor the safety performance of your company to
determine progress (for example, management meetings, safety committee/team,
statistical reports, etc.):
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________

33.

Does your company have a safety manual with a clearly written safety policy
endorsed by upper management?
Yes____ No____ Comments: ___________________________________________

34.

Does your company perform safety audits/reviews?

Yes____ No____

If yes, are safety audits documented? Yes____ No____


35.

Who reviews the safety audit/review and how often? Job Title:
Comments: ________________________________________________________

36.

Does your company involve its employees in health, safety, and environmental
awareness programs?
Yes____ No____
If yes, describe how they are involved: ____________________________________

D1.9.a.7

37.

Who in your company is responsible for coordinating your health, safety and
environmental program? Job Title:
Is safety a full time responsibility for this position?

Yes____ No____

If no, list the percentage of time devoted to safety:


38.

Does your company have a Safety Incentive/Recognition Program. Yes____ No____


If yes, please describe: ________________________________________________

39.

Does your company have a written environmental program?

Yes____ No____

If yes, describe the training and documentation aspects of the program:


__________________________________________________________________
40.

Is your company required to have any Federal, state, or local licenses or permits to
perform your service(s) (for example, NORM, asbestos, DOT, etc.)?
Yes____ No____
List types of licenses/permits and state of issue:
__________________________________________________________________

Having completed this survey, do you have any additional comments or questions to
discuss?
__________________________________________________________________
__________________________________________________________________

D1.9.a.8

DEFINITION OF TERMS
Year
List the three most recent full calendar years. Specify months, if less than a full
year.
Average Number of Employees
List the average number of employees worked during the year. An employee shall
be defined as any person engaged in activities for an employer from whom direct
payment for services is received. Included are working owners and officers.
Exposure or Employee Hours
List the total number of hours worked during the year by all employees, including
those in operating, production, maintenance, transportation, clerical, administrative,
sales, and other activities.
Number of Recordable Cases
List the total number of recordable cases that occurred during the year. A
recordable case will be defined as any work-related injury case requiring more than
first aid, and all occupational illnesses. Recordable cases include all occupational
illnesses, and all occupational injuries resulting in lost workdays - either days away
from work or days of restricted work activity, medical treatment other than first aid,
loss of consciousness, restriction of work or motion, temporary or permanent
transfer, or the termination of an injured or ill employee.
Incidence Rate of Recordable Cases

Number of recordable cases X 200,000


Exposure or employee hours

Number of Lost Workday Cases


List the total number of lost workday cases that occurred during the year. A lost
workday case will be defined as any recordable case that results in death or lost
workdays with days away from work. For the purposes of this questionnaire,
recordable cases that result in lost workdays with restricted activity should not be
added in this column. Only recordable cases that result in one or more days away
from work should be counted.
Incidence Rate of Lost Workday Cases

Number of lost workday cases X 200,000


Exposure or employee hours

Number of Days Away from Work


List the total number of lost workdays experienced by all employees during the year.
For the purposes of this questionnaire, lost workdays with restricted activity should
not be added in this column. Only recordable cases that result in one or more days
away from work should be counted.
Severity Rate

Total number of lost workdays X 200,000


Exposure or employee hours

D1.9.a.9

EMR - Experience Modification Rate


We require verification for the EMR and discount rate data requested in the
questionnaire. Any of the following methods would be acceptable:
A letter from your insurance agent, insurance carrier, or state fund (on their
letterhead) verifying the EMR or discount rate data listed above; or
A copy of the last three years' Experience Rating Calculation Sheets, which
your insurance carrier should forward to you annually; or
A copy of the page of your last three years' insurance policies that show the
modification rate and the coverage period.
Number of Fatalities
List the total number of fatalities that result from occupational injuries or illnesses.
Deaths, which occur in the workplace but are not the result of occupational injuries
or illnesses should not be included.
Additional Information
Additional information concerning injury and illness recordkeeping can be found in
29 CFR 1904 and OSHA's "Recordkeeping Guidelines for Occupational Injuries and
Illness" booklet.

D1.9.a.10

Attachment 2

D1.10

CONTRACTOR SAFETY, HEALTH AND ENVIRONMENTAL


MANAGEMENT SYSTEM ASSESSMENT
Contractor Name: ________________________________________________________________
Location: _______________________________________________________________________

SH&E System Component

Acceptable

Needs Improvement

Not Acceptable

SH&E Plan
SH&E Staff
SH&E Work Procedures
Substance Abuse & Contraband
Audits & Inspections
Employee Training
New Hires
Continuous
Management
Records Management
Hazard Control
Emergency Preparedness
Sub-Contractors

N/A

SH&E Manual
Incident Reporting & Investigation
SH&E Meetings
Acceptable Components: ________ X 3 =

_______

Needs Improvement

_______

________ X 1 =
Total Score

_______ Transfer total score to Contractor


Composite Score Worksheet

Conducted by: ___________________________________________________________________


Date: __________________________________________________________________________

D1.10.a.1

Attachment 3

D1.11

CONTRACTOR FACILITY ASSESSMENT CHECKLIST


Contractor Name: _________________________________________________________________
Location: _______________________________________________________________________
Activity Observed: ________________________________________________________________

Acceptable

Needs
Improvement

Not
Acceptable

N/A

HOUSEKEEPING
Are aisles clear and unobstructed?
Are waste containers emptied?
Are work areas clean and organized?
Are work areas adequately illuminated?

TOOLS & EQUIPMENT


Are tools/equipment in good condition?

Are the correct tools/equipment being used?

PERSONAL PROTECTION EQUIPMENT


Is the necessary PPE available and being used:
Hard Hats
Eye Protection
Face Protection
Respiratory Equipment
Foot Protection
Hand Protection
Proper Work Clothing
Hearing Protection
Personal Floatation Devise

D1.11.a.1

Acceptable

Needs
Improvement

Not
Acceptable

N/A

WORK PRACTICES
Are employees working in a safe manner?
Are employees obeying posted warning signs?
Did the company conduct a pre-job meeting?
Are items properly locked and tagged?
Are work permits completely filled out?
Are work permits posted?
Are containers properly labeled?
Are MSDS readily available?
Is material handing equipment being
properly operated?
Is material handling equipment being
inspected?
Is machinery adequately guarded?
Is adequate fire protection
equipment on location?
Are fall hazards adequately controlled?
Are flammable substances properly stored?
Is spill containment provided for chemical
distribution areas?
Are adequate first aid facilities provided?

Acceptable Components: ________ X 0.5 =


Needs Improvement:

_______

[N/As will be credited for 0.5 point]

________ X 0.25 = _______


Total Score

_______

Transfer total score to Contractor


Composite Score Worksheet

Conducted by: ___________________________________________________________________


Date: __________________________________________________________________________

D1.11.a.2

Attachment 4

D1.12

CONTRACTOR COMPOSITE SCORE WORKSHEET

Contractor: ________________________________________________________
Incident Rates

_________

EMR

_________

SH&E Management Systems Assessment

_________

Site Assessment

_________
Sub-total

_________

Deductions
Fatalities

_________
Sub-total

_________

TOTAL SCORE

_________

RATING

Approved

80 - 100

Conditional

60 - 79

Non-Acceptable

< 60

Performed by: _____________________________________________________


Date: ____________________________________________________________

D1.12.a.1

Attachment 5

D1.13

Below are minimal requirements for Moreno Group LLC and Subsidiaries Facilities

D1.13.a.1

Moreno Group LLC and


Subsidiaries SH&E
Management System

Emergency
Preparedness

Page: 1 of 19
Original: 01/01/2001
Revised: 01/01/2010

Emergency Preparedness
Purpose
The purpose of the emergency preparedness plan is to provide methods of
evacuation of Moreno Group LLC and Subsidiaries facilities during emergency
situations.
Scope
To provide minimum requirements for safe evacuation of Moreno Group LLC and
Subsidiaries Facilities for potential emergency situations.
Responsibilities
The Facility / Facility Manager or Designee is responsible for:
Providing the necessary leadership and resources to execute this procedure
Develop, implement and continuously evaluate a Facility / Office Site Specific
Emergency Evaluation Procedure.
Assuring evacuation routes are established and clearly marked
Establishing a head count procedure
The First Line Supervisor or Sub-Contractor is responsible for:
Understanding and complying with their Facilitys Emergence Evacuation Plan.
Overseeing the activities of personnel to ensure emergency reporting and
response procedures are followed.
Conduct a head count of their personnel upon arriving to the designated
assembly area.
Updating and answering their employees questions pertaining to this plan.
The Safety, Health and Environmental Department is responsible for:
Provide assistance to Facility Management and the First Line Supervision in the
development, implementation and continuous improvement of their Site Specific
Emergency Evacuation Plan.
Coordinating and conducting Emergency Preparedness Training.
E1.1

The Employee is responsible for:


Understanding and complying with their Facilitys Emergency Evacuation Plan.
Completing the required training on this procedure.
Conferring with supervision as to any suggestions to improve emergency
reporting and response procedures.
Responding to emergencies to the extent of their abilities and training.
Definitions
Conditions - Indicates that winds, surges or waves, flooding or any combination of
those typical of a hurricane or a tropical storm are possible.
Convection - Atmospheric motions that are predominately vertical, resulting in the
transport of properties such as heat and moisture vertically. Cumulus clouds and
thunderstorms are examples of phenomena associated with convection.
Designated Assembly Area - An area that employees for the facility will assemble at
during an emergency. The Facility Manager or designee will determine the facility
Designated Assembly Area.
Hurricane Hunters - A reserve group of the U.S. Air Force that flies reconnaissance
flights into tropical disturbances, tropical storms and hurricanes to gather data, which
aids in tracking and forecasting tropical weather systems.
Hurricane Rain / Flooding - Hurricanes and weaker tropical cyclones can cause
tremendous rainfall and result in massive flooding. Historically, most deaths in
tropical cyclones are associated with fresh water flooding.
Storm Surges - Increase in sea level water height from the average water height with
no hurricane. Some hurricane deaths are associated with storm surges, but far
fewer than in the past because widespread evacuations have been implemented.
Typically, the stronger the hurricane winds, the greater the storm surge height.
Tornado - Recognized as a funnel-shaped cloud that spins rapidly and extends
towards the ground from the base of a thundercloud.
Tropical Cyclone - A warm-core low-pressure system which develops over tropical
and sometimes sub-tropical waters and has an organized circulation.
Tropical Depression - A tropical cyclone in which maximum sustained surface winds
are 38 mph (38 knots) or less. Tropical depressions characteristically have one or
more closed isobars.
Tropical Disturbance - A discrete system of organized convection that originates in
the tropics and maintains its identity for 24-hours or more.
E1.2

Tropical Storm - A tropical cyclone in which maximum sustained surface winds are
39 mph to 73 mph. Tropical storms are given names. The same names continues if
the circulations happen to strengthen to hurricane intensity.
Requirements
Each Facility / Office Manager shall develop and implement a site specific
Emergency Evaluation Plan for their facility. Attachment 1 contains a generic office
building Emergency Evacuation Plan that may help facilitate in the development of
the Site Specific Plan for Office Buildings.
Prior to the development of any office Site Specific Emergency Evacuation Plan, the
office manager shall ensure our plan does not conflict with the evacuation plan
developed by the building owner and/or Management Company. The plan should
either be posted in the facility or made readily available for the employees to review.
Coordinator of Emergency Action Plan
All Supervisors shall be responsible for updating, answering any questions and
explaining employees responsibilities under this plan.
Decision to Evacuate
In the event of fire, explosion, bomb threats or bad weather it may be necessary to
evacuate the site or an area of the facility. If the need arises, the Facility Manager or
his designee should make the decision. Evacuation should be ordered if a situation
could endanger life or health of the personnel.
Evacuation Alert Procedure
The Facility Manager or his designee who orders the evacuation will make an
announcement over the public address system that the site must be evacuated due
to an emergency situation. If the public address is not working, alert other
occupants by word of mouth and/or by radio. If an area is to evacuate, an
announcement will be made indicating said area is to be evacuated and closed off.
Do not enter that area until the barricades are removed. After the evacuation alert
has been made, the person ordering the evacuation will call the local emergency
agency or 911, if needed.
Evacuation Procedure
Fabrication Yards
Upon hearing the announcement or alarm, all personnel on site will stop whatever
they are doing. All equipment, tools and power sources should be turned OFF before
evacuating facility (provided it is safe to do so). Personnel working in offices will
close office doors, windows, and other doors on the way out and proceed directly to
designate emergency exits. Department managers shall ensure that all occupants in
their area are out of their offices and conference rooms and that their area is
completely vacated. Turn off the lights in each office and close the doors. Notify the
E1.3

Facility Manager that your area is vacated and proceed to evacuate yourself.
Evacuation routes shall be located in strategic locations throughout the facility.
While employees are evacuating, they shall try not to walk through smoke or vapor
clouds. If employees are caught in such a situation, they shall make notice of wind
socks to determine wind direction; they shall then walk at right angles to the wind
direction to exit the cloud and to find an upwind evacuation route. Wind socks are
located at the top of the east and west ends of both fabrication buildings and the top
of the pile rack.
The evacuation route plan will show the evacuation route; emergency exits. After
exiting shops, work areas or buildings, all personnel will exit the site by the nearest
exit. All personnel will meet at Designated Assembly Area for a head count. The
Facility Manager and/or the SH&E department will be the last to evacuate. They will
then proceed to the Designated Assembly Area. After the site has been evacuated,
a decision will be made if further steps must be taken.
If handicapped or disabled personnel are in the group being evacuated, a two-man
team is to be designated by the department manager to assist. The two-man team
and the disabled person shall be the last to evacuate, to avoid the possibility of
being shoved by individuals coming from behind them. The team is to inform the
Facility Manager that the disabled persons are evacuated.
Support Offices within Fabrication Facilities
Upon hearing the announcement or alarm, all personnel will stop whatever they are
doing. Personnel working in buildings will close windows, doors and all doors on the
way out. They will proceed directly to designate emergency exits.
Department managers shall ensure that all occupants in their area are out of their
offices and conference rooms and that their area is completely vacated. Turn off the
lights in each office and close office doors. Notify the Facility Manager that your area
is vacated and proceed to evacuate yourself. Evacuation routes shall be located in
strategic locations throughout the facility.
The evacuation route plan will show the evacuation route, emergency exits and fire
extinguisher locations. After exiting the buildings, all personnel will exit the site to the
appropriate Designated Assembly Area for a headcount.
The Facility Manager and/or designee will be the last to evacuate. They will then go
to the Designated Assembly Area.
If handicapped or disabled personnel are in the group being evacuated, a two-man
team is to be designated by the Facility Manager to assist. The two-man team and
the disabled person should be the last people to evacuate, to avoid the possibility of
being shoved by individuals coming from behind them. The team is to inform the
Facility Manager that the disabled persons are out.

E1.4

Procedure to account for personnel


Upon arriving to the designated assembly area, each supervisor or designee shall
account for their personnel. Upon completion of the head count, the supervisor shall
notify the Facility Manager or his designee of the total number of personnel present
and total number missing. The receptionist(s) shall use the visitor logbook account
for all visitors.
Training / Bi-Annual Drills
During the initial Facility Orientation employees and visitors shall receive training on
this procedure. In addition to the initial facility orientation, employees shall received
additional training on their assigned responsibilities (Fire Warden, etc.) under this
plan anytime these responsibilities change or this plan changes. Each facility
evacuation plan shall be kept in writing, maintained and available to all employees
and visitors to review. Any questions or concerns shall be addressed to the Facility
Manager or designee.
Bi-Annual Drills are to be conducted by Facility Management.
managers are to be notified as to the timing of these drills.

All department

Participation in the drills is mandatory for all Facility occupants (whether employees
or visitors).
After the drill has been conducted Facility Management, Supervision and the SH&E
Department shall meet to critique the drill. Minutes of this critique meeting should be
kept and maintained.

Extinguishing Fires
If it is determined that the fire can be controlled with fire extinguishers, another
member of the staff must be alerted of the fire emergency to assist with
extinguishing the fire and to alert the Facility Manager or his designee of the fire
emergency. If the fire cannot be controlled with fire extinguishers, the Local Fire
Department must be called and the site evacuated.
In Case of Fire or Fire Alarm (simple procedure)
Notification
If you see smoke, flames, smell smoke, or hear a fire alarm, immediately call the
Local Fire Department (911).
If you think you smell a peculiar or unfamiliar odor, immediately call the Local Fire
Department (911):
Information to be given to the Fire department:
What is on fire
E1.5

Address
Type of occupancy
Telephone number
Listen to dispatcher; always let dispatcher hang up first.
Emergency procedures if you see smoke, flames or smell something burning:
Isolate fire (close door, if possible)
Call the fire department
Make announcement on PA system
Evacuate
Extinguish fire
Emergency procedures in the event of an alarm only:
Notify fire department
Minimum procedures: proceed to Designated Assembly Area for further
instruction and head count.
Important Things to Know
When the Fire Department arrives, the officer is in charge
Special Instructions for the Mobility Impaired
Individuals having any mobility impairment need to be considered prior to any
need for evacuation. It is necessary for department managers to ensure
assistance is available for any mobility-impaired employee that may require
special assistance in the event of an evacuation. A list of these employees
shall be kept with this plan.
After Hours
If you see smoke, flames, smell smoke, or hear a fire alarm, do the following:
Isolate the fire by closing the door.
Notify the fire department by calling 911.
NEVER assume that someone else has called the Local Fire Department.
Threats
If anything suspicious occurs (such as threatening phone calls), remain calm, and
get as much specific information as possible (i.e. location of bomb or intentions), try
to keep the person on the phone, and notify the Facility Manager immediately. Try
to get as much information from the caller as possible as to the nature and details of
the threat.
E1.6

Keep all written threats, notes on threatening calls or unusual occurrences so that
the Facility Manager can evaluate the threat.
The Facility Manager is to notify the Safety, Health and Environmental Department
for instructions in the event of any threatening calls or situations.
Violent Disturbances
Workplace violence can be of various types and origins. Upon Notification of a
violent act or disturbance, which threatens the facility or employees, the Facility
Manager or designee will immediately, contact local authorities?
Any employee may make this initial notification once that employee is secured in a
safe area.
The following information should be obtained:
Location of disturbance
Number of distracters
Distracters activities
Identification of distracters
The Facility Manager or designee will asses the situation and determine the
appropriate course(s) of action based upon the available information. If necessary,
public address notification of the disturbance will be communicated to all personnel.
Employees are to remain clear of disturbance and should not attempt to resolve the
conflict. Local authorities may be contacted to address appropriate situations.
The Facility Manager or designee shall secure the area of a violent disturbance to
preserve anything that maybe considered evidence and must not allow any items to
be removed or disturbed unless directed by Law Enforcement Authorities.
The Facility Manager or designee should lock down the facility and not allow anyone
to enter the facility without prior approval from the Facility Manager or designee.
The Facility Manger or designee shall also work with authorities to secure any
witness statements.
Be alert to any suspicious personnel, visitors or objects.
Medical Emergencies
Personnel: Call the immediate supervisor and the SH&E Department
Call 911, if an ambulance is needed.
Supervisor: Call your immediate manager to report the injury or illness

E1.7

If the injured/ill person is sent to the hospital, the employees immediate


supervisor or designated individual should accompany him/her to assist at the
hospital until relatives arrive.
Designated Company Physicians:
New Iberia, La./ Lafayette La.
Med Xcel
106 Heritage Parkway
Broussard, LA 70518
(337) 856-7500

Iberia General Hospital


2315 E. Main St.
New Iberia, LA 70560
(337) 364-0441

Our Lady of Lourdes


611 St. Landry Dr.
Lafayette, LA 70506
(337) 289-2000
Harvey, La.
Dr. David Reiss
Elmwood Industrial Medical Center
5800 Plauche Center
Harahan, LA 70123
(504) 733-5885

West Jefferson Medical Center


1101 Medical Center Blvd.
Marrero, LA 70072
(504) 347-5511

J. Serio, M.D.
Health South7772A Highway 23
Belle Chasse, La. 70037
(504) 349-6363
Dr. Neil Notaroberto (Eye Doctor)
1939 Hicory Avenue Suite 101
Harahan, La.
(504) 737-3456
Houma, La.
Occupational Medical Services
Dr. Sweeny or Dr. Davis
144 Valhi Lagoon Crossing
Houma, La 70360
(985) 223-0032

E1.8

Terrebonne General Medical Center


8166 Main Street
Houma, LA 70360
(985) 873-4141

Lake Charles, La
Business Health Partners
299 B Cities Service Highway
Sulphur, La. 70663
(337)626-1011
Fax : (337) 626-0656

Lake Charles Memorial Hospital


1900 W Gauthier Rd,
Lake Charles, LA 70605
(337) 480-7000
Christus St Patrick Hospital
8559 Gulf Hwy,
Lake Charles, LA 70607
(337) 474-7238

Port Sulphur, La
Plaquemines Medical Center
374 Civic Drive
Port Sulphur, la 70083
(985) 564-3344
Mobile, Al.
Infirmary Health System
Doug Daniel (contact)
305 N. Water Street
Mobile, Al.
(251) 431-5800
Baytown, TX
Bay Coast Medical Ctr.
2610 S Highway 146
Baytown, TX
(281) 420-6100
Bay Coast Medical Ctr.

San Jacinto Methodist Hospital


4401 Garth Rd.
Baytown, TX
(281) 420-8600
San Jacinto Methodist Hospital

Corpus Christi, TX
Bay Area-Corpus Christi Med
7101 S Padre Island Dr.
Corpus Christi, TX
(361) 761-1200

Columbia Bay Area Medical Ctr.


7101 S Padre Island Dr.
Corpus Christi, TX
(361) 985-1200

E1.9

Columbia Doctors Regional Med


3315 S. Alameda St.
Corpus Christi, TX
(361) 857-1400

Heart Hospital
7002 Williams Dr.
Corpus Christi, TX
(361) 761-6800

Emergency Room
2606 Hospital Blvd.
Corpus Christi, TX
(361) 902-4151

Northwest Regional Hospital


13725 Fm 624
Corpus Christi, TX
(361) 241-4243

Spoh Hospital
600 Elizabeth St.
Corpus Christi, TX
(361) 885-0854

Thomas Moloney
Nueces Occupational Med. Clinic
7406 Up River Road
Corpus Christi, Tx. 78409
(361) 289-2890
(361) 289-2963 (fax)

Galveston, TX
University of Texas Med. Ctr.
301 University Blvd.
Galveston, TX 77555
(800) 335-0065
Houston, TX
Patricia Janki, M.D.
12080 East Freeway
Houston, TX 77029
(713) 330-4325
(713) 330-1910 (fax)

E1.10

Pasadena, TX
Bayshore Medical Ctr.
4000 Spencer Hwy.
Pasadena, TX
(713) 944-6666

Harris County Hospital Dist.


925 Shaw Ave.
Pasadena, TX
(713) 740-8180

Kirkwood Medical Associates


Occupational Clinic
4001 Preston, Suite 100
Pasadena, Texas 77505
(281) 249-2244
(281) 249-2281 fax

Memorial Hospital Pasadena


908 Southmore Ave #370
Pasadena, TX
(713) 475-5803

Occupational Medical Care


Louis F. Puig, M.D.
3692 E. Sam Houston Pkwy. S.
Suite 100
Pasadena, TX
(281) 998-2323
(281) 998-2329
Texas City, TX
Mainland Medical Ctr.
6801 Emmett F Lowry Expy
Texas City, TX
(409) 938-5000

International
Cabinda, Angola
Ludmed, Ida.
Rau de Macau
Cabinda, Angola
Phone: +244-2312-24755
Fax: +224-2312-23358

E1.11

Luanda, Angola
Talatona Clinic
Rua S10 Sector Talatona Zona CCB2
proximo ao Belas shopping
Telephone:
923 330 843
Fax: 222 399263
Emergency after Hours: 923 330 845

Air Ambulance Service


International SOS Assistance
(Pty) Ltd
Open 24 hours a day
Telephone:
27(11) 541 1300 / 1350
Fax: 27 11 541 1076

Ilha Clinic
Rua Murtala Mohamed - Clinica
Sagrada Eperana
Telephone:
923 330 845 / 917 485 834
Fax: 222 309 033
Attn: International SOS Angola, Lda
Port of Spain, Trinidad
Port of Spain General Hospital
Charlotte Street, Port of Spain
Trinidad, West Indies
Telephone: +1 809 623 2951

Couva District Hospital


Couva, Central Trinidad, WI
Telephone: +1 809 636 2411

Puerto Ordaz, Venezuela


Ceciamb Clinic
Avenida Atlantico, Edificio CCCCD,
Local Pt-1, Urbanization Rio Caura
Puerto Ordaz City, Bolivar State,
Venezuela
Phone Number: 00-58-286-9522658
Fax Number:
00-58-286-9519383

E1.12

Serpentine Road Family Clinic/


Dermatology/Physiotherapy
4 Serpentine Road
St. Clair
Port of Spain
Telephone: 868-622-4331
Princes Town District Hospital
Princes Town, Trinidad, WI
Telephone: +1 809 655 2255
655-2255 (Tel)

Uyapar Hospital
Jardin Levante, AltaVista Sur
Puerto Ordaz City, Bolivar State,
Venezuela
Phone: 00-58-286-9622072 or
00-58-286-9625159

Hurricane Procedures
Hurricane season is from June through November, with the majority of hurricanes
occurring during August and September. The best defense against storm damage is
alertness and prior preparation. For instructions covering hurricane preparedness
and evacuation procedures, personnel should become familiar with their local
hurricane preparedness plans that are specific to that region, district or area.

Hurricane Alerts Categories


Tropical Storm Watch - Tropical Storm conditions are possible in your area within
the next 36-hours.
Tropical Storm Warning - Tropical Strom conditions are expected in your area within
24-hours.
Hurricane Watch - Hurricane conditions are possible in your area within the next 36hours.
Hurricane Warning - Hurricane conditions are expected in your area within 24-hours.
Saffir-Simpson Scale
Hurricanes vary in wind strength, central barometric pressure, size storm surge
height and destructive potential. A classification scale, which includes Categories 1
to 5, commonly used rate the damage potential of a hurricane is called the SaffirSimpson Scale.
Category
5
4
3
2
1

Winds (MPH)
> 155
131 -155
111 - 130
96 - 110
74 - 94

Storm Surge
> 18
13 - 18
9 - 12
6 - 8
4 - 5

Phases of Hurricane Evacuation Plan


Phase I (General Hurricane Season Precautions) - Automatically will go into effect
on June 1 and will remain in effect throughout hurricane season (June 1 through
October 31).
Phase II (Pre-Hurricane Procedure) - Automatically go into effect whenever a
hurricane or tropical storm enters into or threatens to form anywhere in the Gulf of
Mexico.
Phase III (Securing for Hurricane and Preparing for Evacuation) - Will only go into
effect upon orders from the Facility Manager or designee. The decision to place a
facility in Phase III status will be based upon evaluating the intensity, position and
forward speed of the storm; the wind and sea conditions in each area; the location,
E1.13

condition and accessibility of each facility and decisions of Local and/or State
authorities.
Phase IV (Facility Evacuation) - Will go into effect upon orders from the Facility
Manager or designee but can be expected to automatically follow Phase III. It may
be applied to a facility, but not necessarily our entire operations simultaneously.
Phase I (General Hurricane Season Precautions)
During Phase I, all workplace assessments shall be performed per the Audit
and Assessment section of this manual. Deficiencies are to be documented, a
work-order developed and issued to the supervisor to be repaired promptly.
All loose material and equipment on facility are to be properly stored and
maintained in a secure manner.
All junk items to be classified as such and sent for disposal or scrap recycler.
All facilities must verify that they have an ample supply of rope, tarpaulin or
clear, heavy, plastic wrap available.
All Supervisors and Facility Managers are to maintain and keep in their
possession a current list of correct addresses and telephone numbers to
personnel under their authority.
Phase II (Pre-Hurricane Procedure)
Secure all loose material and / or equipment
Make sure all Diesel tanks and filled.
Make sure all Used Oil tanks are pumped out.
Make sure all containment and drip pans are pumped out.
Make sure any Hazardous Waste generated at facility is scheduled for
immediate pick-up by Approved Hazardous Waste Disposal Company (see
Process Specific Waste Management Plan within the Hazardous Control
section of this manual).
Phase III (Securing for Hurricane and Preparing for Evacuation)
Stop all compressors.
Secure all equipment and buildings.
Collect all hand held radios and place in a safe but secure location.
Move all unsecured portable fire extinguishers to tool room.
E1.14

Move all gas cylinders into secured racks or firmly secured to building or
structure.
Move all mobile equipment to safe and secure location of facility. The
Operator shall provide the key to the equipment to their Supervisor.
Lower and secure all booms to aerial lifts, cherry pickers and cranes.
Ensure all paints, solvents, lube oils, etc. are placed within a secured
buildings or containment area.
Ensure all hazardous materials within containment area are properly secured
within containment.
All files on company computers shall be backed up. Back-up tapes shall be
provided to employees Supervisor. The Supervisor shall place the back-up
tapes within a safe and secure location.
Notify Supervisor upon completion of securing operations. Wait for facility
evacuation orders from Facility Manager or designee.
Phase IV (Facility Evacuation)
Notify Supervision to order employees to evacuate facility in an orderly
fashion.
Facility Manager or designee will turn off the electricity to facility and
implement Moreno Group LLC and Subsidiaries Energy Isolation Procedure
(Lockout / Tagout). Electricity should not be turned off until all employees
have left the facility.
Ensure all gates and entrances to facility and buildings are locked.
Returning to Facility after Storm
Facility Manager or designee and SH&E Department will perform an Audit
and Assessment to determine if facility is safe for employees to enter.
Assign facility electrician to evaluate and determine if it is safe to turn on
facility electricity.
Prior to Facility Manager or designee removing their lock and tag on facility
electricity and turning on electricity, the entire facility shall be notified
electricity will be turned on.
Thunder Storm or Tornado Procedures
Lightning can strike as far as 10 miles from the area where it is raining. Thats about
E1.15

the distance you can hear thunder. According to the National Weather Service, if
you can hear thunder, you are within striking distance.
All fabrication facilities utilize Weather Sentry Construction Pro to make
determinations regarding lightning & or severe weather conditions.
In the event lightning is visible or thunder is audible, Weather Sentry will provide
data relevant in making recommendations for the best interest of employee safety.
All facilities will adhere to the following when making a recommendation:
-

Once it has been determined that lightning is within a 20 mile radius, an


alert will be issued within the facility.
After it has been determined that lightning is within a 10 mile radius, the
SH&E Department will advise Facility Management to shut down all
outdoor activities

Tornadoes most frequently occur in the Midwestern, southern, and central states
between the months of March and September.
Tornado Alert Categories
Tornado Watch - Indicates that the weather conditions could result in a tornado.
Tornado Warning - Indicates that a tornado has been sighted or detected by radar.
Thunder Storm or Tornado Preparation and Evacuation
During a tornado watch, listen to the radio or television for current information.
DO NOT tie up telephone lines by calling the weather bureau, except to report
a tornado.
During a tornado warning, be prepared to take immediate cover for protection.
During a thunder storm remove employees from all structures within facility,
when time allows lay down all aerial lifts, cherry pickers and cranes boom,
turn off mobile equipment and remove yourself from the equipment.
Remain calm. Go to the closest building and remain against an inside wall of
the lowest floor. Remain away from windows and stay inside during the storm.
If the building is occupied during a thunder storm or a tornado is sighted in the
vicinity, stay away from the perimeter of the building and areas where glass is
present.
Leave your office and close the door, proceed to the first floor, stay in the
hallways or rooms with no glass. If the tornado is very close, sit or kneel
down in the hallway or a low laying area within the facility, place your head as
close to your lap as possible and protect your head and neck with your hands
and arms.
E1.16

Do not attempt to evacuate the building, unless the Facility Manager or


designee instructs you to.

Emergency Preparedness Plan Review and Training


This procedure and/or the site specific emergency evacuation procedure should be
reviewed with the employees should one of the following occur:
When the plan is developed or the employee is assigned initially to a job.
When the employees responsibilities under the plan changes
Or should this plan change
Employees will receive emergency evacuation training upon hire. Bi-annual Drills
are used to reinforce this training and to identify any opportunities for improvement
within the plan.

E1.17

Attachment 1

E1.18

Generic Office Building Emergency Evacuation Plan


(i) TABLE OF CONTENTS

1.0

FIRE NOTIFICATION AND RESPONSE

2.0

EMERGENCY PROCEDURE PRIORITIES

3.0

FIRE WARDENS

4.0

EMERGENCY EVACUATION RESPONSE

5.0

FIRST-AID INCIDENCE RESPONSE

6.0

MEDICAL EMERGENCY RESPONSE

7.0

TERRORISM / BOMB THREAT RESPONSE

8.0

SEVERE WEATHER RESPONSE

9.0

REFERENCE DATA

E1.18.a.1

1.0

FIRE NOTIFICATION AND RESPONSE


A.

If the following is reported to you, or if you see smoke, or flames, or


smell something burning, or hear a Fire Alarm, IMMEDIATELY:
Call the Fire Department
DIAL 9, 911
Call the building SH&E Representative or Management: (Phone
Number)
Activate the Fire Alarm Pull Station if Alarm is not sounding.
Report any change in conditions to the Fire Department and the
Building Fire Safety Director.

B.

If you think you smell a peculiar or unfamiliar odor, IMMEDIATELY:


Call the Building Fire Safety Director or Management: (Phone
Number)

C.

Information to be given to the Fire Department:


What is the Emergency? (Alarm, Smoke, Flames, etc.)
Address
Type of Occupancy: (High Rise Office Building)
What Floor:______Room#______Telephone # calling from_____
(Let The Dispatcher Hang Up First!)

1.0

EMERGENCY PROCEDURE PRIORITIES


A.

If the following is reported to you, or if you see Smoke, or Flames, or


smell something burning, IMMEDIATELY (If SAFE to do so):
Isolate the Fire by closing the door to your office or conference
room!
Call the Fire Department, building Fire Safety Director, and activate
the Fire Alarm Pull Station, if the Alarm is not sounding.
Evacuate Using EXIT Stairwells to a safe area. Relocation to
three or more levels below the fire floor is generally adequate.
Fire Extinguishment (is optional and only if all of the above has
been completed, you have been properly trained to use a fire
extinguisher, and would be using the extinguisher ONLY for
incipient stage fire fighting purposes in a life saving event.)
NOTE: The recommended action is to Evacuate and let the Fire
Department take care of the fire.

E1.18.a.2

B.

Emergency procedures In the event of an ALARM ONLY:


Minimum procedure: Prepare to evacuate by going to the EXIT
stairwell door, if there is any evidence of fire, evacuate the floor to a
safe area (three or more floors below the fire).
When safe to do so, report any condition changes noted to the Fire
Department and the Building Fire Safety Director.

3.0

FIRE WARDENS
3.1

Each floor of a building shall be under the direction of the Fire


Wardens for the evacuation of occupants in the event of a fire or fire
alarm.

3.2

Each Fire Warden shall be familiar with the Fire Safety Plan, the
location of exits and the location and how to activate the fire alarm.

3.3

In the event of a fire or fire alarm the Fire Warden (when it can be
done safely), shall:

3.4

Notify the fire department as specified in the approved Fire Safety


Plan.

3.5

Shall see that all occupants are notified of the fire or fire alarm, and
shall instruct occupants as per the Fire Safety Plan.

3.6

Direct the evacuation of the floor in accordance with directions


received and the following guidelines:
Fire Wardens shall notify the Facility Manager of all mobility-impaired
occupants that may require special assistance in the event of an
evacuation. Occupants not requiring assistance will evacuate first. This
avoids the possibility of the person(s) in need of assistance being
bumped and/or falling down, thus slowing evacuation and/or causing
injury.
If there is evidence of fire, the person(s) having mobility impairment
should be positioned near the fire exit stairwell that is located farthest
away from the fire. If fire conditions pose a personal threat, the Fire
Warden or person assisting should enter into the fire exit stairwell with
the person(s) needing special assistance and wait for the Fire
Department.
If fire conditions pose a personal threat in the stairwell, the MobilityImpaired person(s) should be evacuated to a safe location. Fire
Wardens shall have someone notify the fire department of all MobilityImpaired occupants that have required special assistance in
evacuating the affected areas of their location.

E1.18.a.3

4.0

EMERGENCY EVACUATION RESPONSE


When an emergency is announced by the buildings Public Address (PA)
system, Fire Wardens, or activated Strobe Lights on your floor, THE
ORDERLY EVACUATION OF PERSONNEL SHALL BE AS FOLLOWS:
A. CALMLY PROCEED
STAIRWELL

(WALK)

TO

THE

NEAREST

SAFE

EXIT

KEEP TO THE RIGHT IN HALLWAYS


IF PATH TO EXIT IS BLOCKED, PROCEED TO ANOTHER EXIT
DO NOT USE ELEVATORS

B. FOLLOW FIRE WARDEN INSTRUCTIONS


NOTE:

IF NO FIRE WARDEN IS PRESENT, FOLLOW THE


INSTRUCTIONS BROADCAST OVER THE PA SYSTEM.

C. DO NOT ENTER THE STAIRWELL UNTIL ADVISED!


D. HOWEVER, if there are no instructions and unsafe conditions exist, THEN
EVACUATE to at least three floors below the Floors affected by fire or
smoke.
E. And, if you see FIRE, SMOKE or smell something burning on your floor,
THEN EVACUATE to at least three floors below the Floors affected by fire
or smoke.
F. WHEN ENTERING THE STAIR WELL:

ENTER THE STAIRWELL (in a single line)


KEEP TO THE RIGHT DOWN THE STAIRS (merge with others)
FOLLOW FIRE WARDEN OR PA SYSTEM INSTRUCTIONS TO
EITHER:
Evacuate three floors below the Floors affected by fire or smoke, or
Evacuate the building

SHOULD YOU BE REQUIRED TO EXIT THE BUILDING, PROCEED TO


THE PARKING LOT (Provide Specific Directions)
USE CARE CROSSING THE STREET!
NOTE: DO NOT RETURN TO YOUR OFFICE or Leave the area until the Fire
Wardens have given the All Clear to either return to offices or depart the
area.

E1.18.a.4

G. STAIRWELL RE-ENTRY POINTS


When attempting to evacuate at least three floors below the involved fire
floors, it will be necessary to find a re-entry floor. Unfortunately all floors
cannot be re-entered as some doors are locked out by the occupant.
Also, re-entry points are different for each stairwell as show in the chart
below:
Stairwell Re-Entry Chart

Stairwell Entry / Re-entry Diagram

Floor

12
11
10
9
8
7
6
5
4
3
2
1

North Tower
Stair "A" Stair "B"
Roof
Roof
Access
Access

South Tower
Stair "C" Stair "D"
No Roof Roof
Access
Access

Outside only

Floor

12
11
10
9
8
7
6
5
4
3
2
1

Re-entry doors to the 1st floor and they exit to the


outside
No Stairwell Re-Entry
Stairwell Re-entry

5.0

FIRST AID
In the event of a first-aid incidence, personnel should IMMEDIATELY notify
their First Line Supervisor and/or Manager. First Aid will be provided as
needed by qualified individuals per our Incident Reporting / Medical Attention
Procedure within our SH&E Management System.
First-Aid and Emergency Response kits are located as indicated in the
Emergency Evacuation Plot Plan.

E1.18.a.5

6.0

MEDICAL EMERGENCY RESPONSE


Emergency response assistance may include, but may not be limited to
performing the following:
A.

In the event of a medical emergency, personnel should IMMEDIATELY


CALL / Notify 9, 9 1 1 for Emergency Response.
Notify the nearest COMPANY First-Aid Responder (see Section 5
above) and be prepared to assist First-Aid Responder as directed.
NOTE: First-Aid and Emergency Response kits are located as
indicated on the Emergency Evacuation Plan.

B.

Provide all primary information to the 9-1-1 dispatchers regarding:


Your name
COMPANY Name, address and telephone number (see below)
Nature of emergency

C.

Follow any instructions as directed by the 9-1-1 dispatchers.


Notify COMPANY management personnel (see Section 9)
Notify building Manger or Security (after hours)

7.0

TERRORISM / BOMB THREAT RESPONSE


7.1 Terrorism
In the event that a terrorist act is perceived or is actually committed in this
facility, all personnel should use their own judgment in following these
procedures.
These procedures are only guidelines and should be followed ONLY if it is
SAFE TO DO SO:
EVACUATE THE BUILDING IMMEDIATELY!
DIAL 9, 911 (as soon as possible) and that may be
from an outside telephone or your Cell Phone
Also, if possible, activate the nearest
Fire Alarm Box as you leave the building
NOTE: When evacuating the building, DO NOT gather in groups outside the
building as the safest procedure for evacuation during a Terrorist Threat is to
scatter as far away from the building as quickly as you can.

E1.18.a.6

7.2

BOMB THREAT

In the event of a bomb threat received by telephone, personnel should


consider gathering as much information as possible from the threatening
caller. If possible (and safe to do so) alert your supervisor or one of the
management staff while the caller is on the line.
The Bomb Treat checklist (see Attachment 1) and the following guidelines are
offered to assist personnel in obtaining as much information as possible from
the threatening caller.
Be calm, courteous and listen carefully.
Get as much information as possible from the caller, but avoid the
impression you are working from a checklist.
Take notes; try to get the callers remarks word for word.
It is very important to obtain answers to these questions:

When is the bomb going to explode?

Where is the bomb right now?

What does the bomb look like?

What is the bomb made of? (Obtain details about its parts)

What will cause the bomb to explode?

Who placed the bomb? Why?

What is your name? Where are you now?

Try to keep the caller talking. If necessary, pretend difficulty with your
hearing. Try to weave these general questions into the conversation:
What did you say? Im sorry I didnt understand what you said.
How do I know this is not a joke?
What group do you represent?
Why are you doing this?
After the call has been terminated, IMMEDIATELY NOTIFY Company
management personnel and building management personnel. Be prepared to
provide your notes and checklist.
NOTE: It may NOT be best to INFORM other personnel of the threat.
Company management and building management staff will notify the proper
municipal authorities, at which time, an emergency evacuation response
and/or building search may result.

E1.18.a.7

8.0

SEVERE WEATHER RESPONSE


An Automatic Severe Weather Warning Radio is located at the main reception
desk in 700 N. This alert system will provide early warning when severe
weather or other hazardous event is immanent.
In the event of severe weather such as hurricanes or tornados, personnel
should employ practical means to secure their work area and ensure their
personal safety.
We are generally offered time for preparation in anticipating hurricane
conditions, whereas tornado conditions may require an emergency response.
See Emergency Preparedness Section of SH&E Management System.
A.

At a minimum, preparations for hurricane conditions should include:


Close window blinds.
Power-down all electrical components in your work area.
If possible, relocate all electrical components (computers, printers,
etc.) away from windows.
Secure the document contents of your work area (desk contents,
files etc.) and relocate away from windows.
All lighting should be off and all interior doors should be closed prior
to vacating the facility.

B.

Tornado condition response should include:


Following the guidelines in the MORENO GROUP LLC AND
SUBSIDIARIES Emergency Preparedness Plan location within our
SH&E Management System in addition to but is not limited to:
Closing window blinds (if safe to do so).
Power-down all electrical components in your work area (if time
permits).
Gather in an area of the building that is safe from shattered
windows and flying objects.
If Emergency Evacuation of the building is required, evacuate to a
safe area away from the hazards of falling glass, fallen live
electrical lines, and find shelter from the hazards of flying or falling
objects until the storm has subsided.

E1.18.a.8

9.0

EMERGENCY RESPONDER CONTACT INFORMATION


9.1

Fire Wardens

Fire Warden

Title

Location

Ext.
No.

Alternate Fire
Wardens

Ext.
No.

Fire Warden Contacts

9.2

Building Management Personnel


Building Management Contacts

E1.18.a.9

9.3

Company Management Personnel


Manager

9.4

Ext. No.

Location

Emergency Evacuation / Fire Warden Area Maps are located in all


offices and contain the following information:
Location of EXIT Stairwells
Location Fire Hoses & Extinguishers (to be used only by
the Fire Dept.)
Fire Alarm Pull Boxes
Fire Alarm Strobe Lights
First/CPR Kits
Fire Wardens and Alternate Fire Wardens
Room Numbers and Conference Room Locations

The names, locations, and telephone numbers of Emergency


Responders.

E1.18.a.10

Attachment 2

E1.19

BOMB THREAT CHECKLIST

The caller was most probably:


Male
Female
Young Adult
Middle-Aged
The caller seemed to be:
Sober
Calm
Rational
Sincere
Joking
The caller talked:
Loud
A deep voice
Fast
With a lisp
With good pronunciation

Drunk
Excited
Irrational
Righteous

Child
Older Person

Teenager

Mentally Disturbed
Angry
Coherent
Determined

Nervous
Emotional
Incoherent
Laughing

Soft
Raspy
Slow
With a stutter
With a disguised voice

With a high pitch


With a nasal sound
Slurred
Pleasant
With an undisguised voice

The callers language was:


Highly Educated
Good
Poor
Full of slang words or expressions (Please include them in comments).

Profane

The caller had an accent that I would say was:


Local Not local (where?___________)

Foreign (where?_________)

The caller seemed to be familiar with Company?


Building
Equipment

Plans

In the background I could hear


Party Noises
Bar Sounds
Music
House Sounds
Street Sounds
Airport Sounds
Factory Machines
Office Machines
Voices
Quiet
The origin of the call seemed to be:
Local
Long Distance

Operations

Personnel

Another person or persons


Animal Sounds
Trains
Other: ________________

Car Phone

From within the building

Callers remarks, word for word where possible: _________________________________________

E1.19.a.1

Moreno Group LLC and


Subsidiaries SH&E
Management System

Employee Participation

Page: 1 of 2
Original: 01/01/2003
Revised:

Employee Participation
Purpose
It is the purpose of the Safety, Health and Environmental Management System to
involve employees in the identifying, evaluating and eliminating safety, health and
environmental hazards and at-risk behaviors in the workplace.
Scope
The scope of this program is to identify those processes that promote employee
involvement within Moreno Group LLC and Subsidiaries Safety, Health and
Environmental Management System.
Responsibilities
The Facility Manager / Offshore Manager or Designee is responsible for:
Reviewing all Incident Reports and Work Group Investigations
Participating in Supplemental Incident Investigations.
Reviewing all Hazard Assessments Checklists (weekly)
Coordinate and Participate in Monthly Management Hazard Assessments
Provide resources to First Line Supervisors so items identified on the Hazard
Assessment Checklist can be corrected.
Attending and participating at all monthly SH&E Management meetings.
Attending and participating in Monthly Supervisor Meetings.
Participating in team-based behavioral safety observations.
The First Line Supervisors / Offshore Superintendent is responsible for:
Coordinating and Conducting Incident Reporting and Work Group Investigations
Perform at least once per week the Hazard Assessment Checklist.
Facilitate the correction of those items identified on Hazard Assessment Checklist.
Conduct a daily SH&E meeting.
F1.1

Attending and participating in Monthly Supervisor Meetings.


Coordinate and participate at least one team-based behavioral safety
observation per week.
The SH&E Department is responsible for:
Assist supervision with Incident Reporting and Work Group Investigation
processes.
Auditing Hazard Assessment Checklists.
Participating in the Monthly Management Hazard Assessment.
Coordinating and participating in Monthly SH&E Management meetings.
Participating in the team-based behavioral safety observations.
Conduct and Coordinate required SH&E training.
The Employee is responsible for:
Participate in the Incident Reporting process and Work Group Investigation
process.
Participate in Hazard Assessment as requested.
Attend and participate in SH&E meetings.
Attend and participate in required SH&E training.
Participate in the behavioral safety observation process.

F1.2

Moreno Group LLC


and Subsidiaries
SH&E Management
System

Stop Work Authority

Page: 1 of 5
Original: 01/01/2005
Revised:

Stop Work Authority


Purpose
The purpose of this program is to formally establish Moreno Group LLC and
Subsidiaries employees and contractors right to utilize their Stop Work Authority
without any repercussions.
Scope
The scope of this program is to outline the protocols Moreno Group LLC and
Subsidiaries employees and contractors are to utilize to suspend individual tasks or
group operations when the control of SH&E risk is not clearly established or
understood.
It is the policy of Moreno Group LLC and Subsidiaries that:
All employees and its contractors have the authority and obligation to stop
any task or operation where concerns or questions regarding the control of
SH&E risk exist,
No work will resume until all stop work issues and concerns have been
adequately addressed, and
Any form of retribution or intimidation directed at any individual or company
for exercising their authority as outlined in this program will not be tolerated.
As with any policy, accountability for non-compliance will follow established
Company procedures or contract requirements.
Roles and Responsibilities
The Facility / Site Manager or Designee is responsible for:
Establishing clear expectation to exercise Stop Work Authority.
Maintaining a culture where Stop Work Authority is exercised freely.
Resolve Stop Work Authority conflicts when they arise and hold those
accountable that chose not to comply with established Safe Work Practices or
Stop Work Authority policies.
Reviewing of Behavioral Safety Observations for Stop Work Authority
F2.1

Maintain communication
performance.

with

SH&E

Department

concerning

SH&E

The First Line Supervisor / Offshore Superintendent is responsible for:


Create and maintain a culture within their workgroup to exercise Stop Work
Authority freely.
Honor their employees request for Stop Work.
Ensure all Stop Work Authority issues are fully resolved prior to starting
work again.
Supports those employees who utilizes their Stop Work Authority and
ensures the Stop Work Authority is properly reported and reviewed.
Reviewing of Behavioral Safety Observations for Stop Work Authority.
Proactively recognize employees participation within the Stop Work
Authority process.
The Safety, Health and Environmental Department is responsible for:
Monitoring compliance with the requirements of this program.
Maintaining of associated documents, processes and training materials.
Reviewing of Behavioral Safety Observations and identification of Stop Work
Authority.
Identification of trends, sharing of learnings and publication of required
information.
Maintain communication with Management concerning SH&E performance
and/or issues
The Employee is responsible for:
Initiating Stop Work Authority when they feel it is warranted.
Notify

their

Supervisor

upon

utilizing

their

Stop

Work

Authority.

Support fellow employees who initiate their Stop Work Authority.


Ensure reason for their use of Stop Work Authority is resolved completely
prior to resuming work.
Reporting the use of their Stop Work Authority on a Behavioral Safety
Observation Card.
F2.2

Requirements
Intervention Protocol
In general terms, the Stop Work Authority process involves a stop, notify, correct
and resume approach for the resolution of a perceived unsafe work actions or
conditions.
The following steps should be utilized as the framework for employees to initiate
their Stop Work Authority.
Step Protocol Instruction
1

When a person identifies a perceived unsafe condition, act, error,


omission, or lack of understanding that could result in an undesirable
event, a Stop Work Authority shall be immediately initiated with the
person(s) potentially at risk.

If the supervisor is readily available and the affected person(s) are not in
immediate risk, the Stop Work Authority should be coordinated through
the supervisor. If the supervisor is not readily available or the affected
person(s) are in immediate risk, the Stop Work Authority shall be
initiated directly with those at risk.

Stop Work Authority should be initiated in a positive manner by briefly


introducing yourself and starting a conversation with the phrase I am
using my Stop Work Authority because. Using this phrase will clarify
the users intent and set expectations as detailed in this procedure.

Notify all affected personnel and supervision of the Stop Work Authority
issue. If necessary, stop associated work activities, remove person(s)
from the area, stabilize the situation and make the area as safe as
possible.

All parties shall discuss and gain agreement on the Stop Work Authority
issue.

If determined and agreed that the task or operation is OK to proceed as is


(i.e., the Stop Work Authority initiator was unaware of certain facts or
procedures) the affected persons should thank the initiator for their
concern and proceed with the work.

If determined and agreed that the stop work issue is valid, then every
attempt should be made to resolve the issue to all affected persons
satisfaction prior to the commencement of work.

F2.3

If the Stop Work Authority issue cannot be resolved immediately, work


shall be suspended until proper resolution is achieved. When opinions
differ regarding the validity of the Stop Work Authority issue or adequacy
of the resolution actions, the Manager over the First Line Supervisor shall
make the final determination. Details regarding differences of opinion and
resolution actions should be included in the documented report.

Positive feedback should be given to all affected employees regarding


resolution of the stop work issue. Under no circumstances should
retribution be directed at any person(s) who exercise in good faith their
Stop Work Authority as detailed in this program.

10

All Stop Work Authority and associated detail shall be documented and
reported on a Behavioral Safety Observation Card.

Reporting
All Stop Work Authority exercised under the authority of this program shall be
documented on Moreno Group LLC and Subsidiaries Behavioral Safety Observation
Card. The employee will be responsible for checking the Stop Work Authority Used
box on the front of the card. The description of the Stop Work Authority issue and
used shall be written on the back of the observation card within the Safe, Stop
Work or At - Risk Comment section
.
Behavioral Safety Observations shall be reviewed by the First Line Supervisor
during the pre-shift SH&E Meeting. Cards indicating Stop Work Authority shall be
reviewed during this meeting in order to:
Measure participation
Determine quality of interventions and follow-up
Trend common issues and identify opportunities for improvement
Facilitate sharing of learnings
Feed recognition programs.
The SH&E Department will regularly publish details regarding the number of Stop
Work Authority actions reported by location as well as details regarding common
trends and learnings.

F2.4

Follow-up
It is the desired outcome of any Stop Work Authority that the identified safety,
health or environmental concern(s) be addressed to the satisfaction for all involved
individuals prior to the resumption of work. Although most issues can be adequately
resolved in a timely fashion at the job site, occasionally additional investigation and
corrective actions may be required to identify and address root causes.
Stop Work Authority issues that required additional investigation or follow-up will be
handled utilizing existing protocols and procedures for incident investigation and
follow-up.
Recognition
The First Line Supervisor should informally recognize individuals when they exercise
their authority to Stop Work Authority or demonstrate constructive participation in a
Stop Work Authority intervention. This informal recognition need be no more than
an expression of appreciation for a job well. Additionally, formal recognition of
selected examples of Stop Work Authority and those responsible should be made
during regularly scheduled safety meetings.
For those employees, the First Line Supervisor feels has demonstrated excellent
SH&E Participation may nominate them to their Manager for an Above and Beyond
Safety Award.
Training
Training regarding this Stop Work Authority Policy and Program will be conducted
as part of Moreno Group LLC and Subsidiaries New Employee Orientation / SH&E
Training. Additionally, a review of the Stop Work Authority shall be completed as
part of all field location safety briefings and regularly in safety meetings.
Documentation of all training and reviews shall be maintained as per established
procedures.

F2.5

Moreno Group LLC


and Subsidiaries
SH&E Management
System

Job Safety
and Environmental Analysis
(JSEA)

Page: 1 of 9
Original: 01/01/2001
Revised: 10/01/2009

Job Safety and Environmental Analysis (JSEA)


Purpose
The purpose of this procedure is to establish a formal process for evaluating and
controlling existing or potential workplace hazards, and to ensure the information is
communicated to all affected personnel.
Scope
It is the policy of Dynamic Industries, Inc. for the task First Line Supervisor or
Offshore Superintendent to undertake formal workplace hazard assessments to:
A. Identify hazards and risks of the workplace and provide information to all
affected personnel.
B. Provide information to all affected personnel.
C. Eliminate, control and/or minimize hazards in the workplace.
D. Satisfy client and/or regulatory requirements.
Routine tasks such as but not limited too rolling up hoses or leads, moving a bucket
or general clean up activities may or may not be incorporated into JSEAs.
The Facility / Site Manager / Offshore Manager or Designee is responsible for:
Provide the needed leadership, commitment, employee empowerment, and hold
personnel accountable for the implementation of this procedure.
Communicating to work force their commitment to the stopping of work, if any
unsafe condition or situation is present.
Auditing compliance with this procedure.
Including JSEA development within Performance Measures
The First Line Supervisor / Offshore Superintendent is responsible for:
Facilitating the development, review, and documenting of Job Safety and
Environmental Analysis with their personnel per this policy.
Utilizing the Job Safety and Environmental Analysis within their Daily SH&E
Meeting with their personnel.

G1.1

Jointly performing and periodically reviewing with their personnel and


communicating with affected personnel the Job Safety and Environmental
Analysis.
Incorporating the results of Job Safety and Environmental Analysis into
applicable Safe Work Procedures.
Upon notification of changes with condition(s) or situation(s) related to the current
task, develop a new Job Safety and Environmental Analysis or revise the prior
Job Safety and Environmental Analysis to meet the changes.
Audit JSEA process to ensure employees are following Job / Task steps as
outline in JSEA.
The Safety, Health and Environmental Department is responsible for:
Training or coordinating the training of managers, supervisors and hourly
employees on developing and documenting Job Safety and Environmental
Analysis.
Periodically auditing the quality of First Line Supervisors or Offshore
Superintendents Job Safety and Environmental Analysis and provide feedback
to them during SH&E Meeting, Safety Alerts or SH&E Training.
Participating in the development in Job Safety and Environmental Analysis.
The Employee is responsible for:
Actively participating in the development and reviewing of Job Safety and
Environmental Analysis.
Incorporating the results of the Safety, Health and Environmental meeting and
Job Safety and Environmental Analysis into their daily activities.
Completing assigned activities as coordinating party per the JSEA.
Advising their supervisor when the conditions or situations of the current task
changes.
Requirements
Job Safety and Environmental Analysis (JSEA) is the process of
identifying/evaluating hazards and implementing control measures to eliminate
and/or reduce the potential for an incident.
The First Line Supervisor or Offshore Superintendent and their crew shall perform a
pre-task hazard review prior to developing the JSEA. The back of the JSEA shall be
used to perform this review. Any hazards identified during this process shall be
identified in the Potential SH&E Concerns section of the JSEA. Within the
G1.2

Recommended Safe Procedure/Protection Section shall identify how the hazards will
be either eliminated or how exposure to the hazard(s) will be minimized.
Job Safety and Environmental Analysis shall be developed daily for tasks
conducted. JSEA preparation is a group activity coordinated by the First Line
Supervisor or Offshore Superintendent. The supervisor will complete the first draft
of the JSEA form. The supervisor or task leader will be responsible for engaging all
employees working on the job in the review process:
reviewing the proposed sequence of job steps,
identifying hazards
determining the necessary safeguards.
assigning responsible individual(s)
The JSEA review meeting shall be held immediately preceding the work, so that the
actual work environment will be known and the JSEA can be used to familiarize the
crew with the job. The completed JSEA form must be reviewed and signed by all
who will work on the job and posted at the jobsite. The job supervisor shall
communicate the JSEA to affected personnel within work area.
Note: At anytime a new task is started or the current tasks condition(s) or
situation(s) change work must STOP and the JSEA must be updated or rewritten.
Monitoring the JSEA Process
Management is accountable for ensuring that periodic audits of the JSEA process
are conducted. Audit findings should be documented and communicated to those
responsible for implementing the process. Improvement actions should be identified
and implemented to address any shortfalls identified in the audit process.
Routine Monitoring
On-site supervisors shall routinely monitor the JSEA process on their jobs. They
should check to see that:
the process is being applied effectively,
safety and environmental hazards are being identified and addressed
the right people are involved in JSEA preparation
JSEAs are followed once the job commences
Jobs are suspended and JSEAs modified when conditions change.
Shortfalls identified during routine monitoring should be corrected immediately at the
local level. If this is not possible, the next level of supervision should be engaged.
G1.3

Documentation
The Hazard/Risk Assessment should be documented using the Job Safety and
Environmental Analysis form (see Attachment 1-Offshore and/or (see Attachment 2Dynamic facilities) (see Attachment 3 - JSEAs for loading and unloading Trucks)
Job Safety and Environmental Analysis Steps
The basic steps in completing a Job Safety and Environmental Analysis are: (see
Attachment 4 for Job Safety and Environmental Analysis Flow Chart)
Step 1: Select the Job for Analysis
First, define the job to be analyzed. Large work packages should be divided into
smaller jobs or tasks, and these should be analyzed using the JSEA process.
Jobs suitable for JSEA can be performed in a day or less. JSEA shall be written in
detail to the way the job shall be performed. Examples include:
Operating a piece of machinery
Making an equipment repair
Installing Piping
Perform a jobsite Hazard Review utilizing the Pre-task Hazard Assessment
Inspection Checklist on back of JSEA.
Step 2: Break the Job down into Steps (Basic Job Steps)
The job should be broken down into a sequence of steps, or actions, required to
perform the job. The breakdown should not be so detailed that an unnecessarily
large number of steps result, or so general that basic steps are not recorded.
To determine the basic job steps, ask:
What action starts the job?, then
What must be done next?
And so on, until the entire job is described.
Note: Consider if simultaneous activities may affect the operation of this task?
The description of each step should begin with an action word, like Remove,
Open, Weld, Secure, etc.
Pre-job preparations (inspections, lock-out / tag-out, etc.) and post-job requirements
(clean-up, removal of locks and tags, etc.) should be included in the job steps.
G1.4

The job steps should be reviewed with experienced employees and those who will
do the work to be sure that the order is correct and no steps have been left out.
Step 3: Identify Hazards and Potential Accident Causes (Potential SH&E Concerns)
The purpose of this step is to identify all potential hazards associated with each step.
Hazards introduced by the work environment and the job tasks should both be
considered. Any hazards identified on the Pre-task Hazard Assessment Inspection
Checklist (back of JSEA) shall be identified within this portion of the JSEA.
The following questions can be used to help identify hazards:
Is there a danger of striking against, being struck by, or making other
undesired contact with an object or machinery?
Can an employee be caught in, by, or between objects or machinery?
Is there potential for a slip, trip or fall on the same level or to another?
Can employees strain themselves by pushing, pulling, lifting, bending, or
twisting?
Are all energy sources (electrical, mechanical, and process) controlled for
protection?
Are there hazards associated with simultaneous activities, which may affect
this task?
Other resources, such as Hazard Assessments, Work Permits or etc., can also be
used to identify hazards.
Record the hazards identified in the Potential SH&E Concerns column of the JSEA
form using the following format: Undesired result + hazard. For example, Struck
by hammer, Slip on wet floor, Shocked by electric motor, Burned by hot metal,
Fall from elevated work platform.
Step 4: Develop Solutions (Recommended Safe Procedure / Protection)
Next, those involved in the job must recommend safe job procedures, or protection,
to prevent the Potential SH&E Concerns identified in Step 3. Potential solutions
must be observable acts and may include:
Find a new way to do the job.
Change the physical condition that creates the hazard
Change the work procedure
Use proper safety equipment or safe practices
G1.5

Reduce the task frequency (particularly helpful in maintenance and material


handling)
A solution must be developed for each hazard identified. Solutions should be
recorded in the Recommended Safe Procedure / Protection column of the JSEA
form. Precisely state what to do and how to do it. Job Steps should be modified, if
necessary. If steps are modified, they should be reviewed again to see if any new
hazards have been introduced.
Required safety equipment and PPE should be recorded on the JSEA form.
Note: Assign specific individual(s) the responsibility for implementing the safe
procedures or protection required. Identify this individual(s) within the Coordinating
Party column of the JSEA.
Step 5: Review and Buy-in
All workers should review the completed JSEA form. They should indicate their
agreement with the Job Steps to be performed and the safety precautions to be
taken by signing the form. At this point, work may begin.
Any other people or groups that may be impacted by the work described on the
JSEA should be made aware of the planned work and associated hazards or
interface concerns. This can be accomplished through the locations Permit to Work
System, planning meetings or other site-specific methods of communication.
At this point, work may begin.
Step 6: Modify JSEA If Conditions Change
The job must be suspended (stopped) and the JSEA must be reviewed if the
conditions surrounding the job change, for example:
The work environment changes due to simultaneous activities, weather, or
other causes
The personnel on the job change
The tools or equipment to be used change
Before work can resume:
The JSEA must be modified to reflect changes
Changes must be communicated to all involved and affected personnel
The workers must sign off on the modified form

G1.6

Attachment 1

G1.7

COATINGS DEPARTMENT
JOB SAFETY AND ENVIRONMENTAL ANALYSIS
Job #

Customer

Location

Date

Page

of

New JSEA:
Revised JSEA:

Y or N
Y or N

Job or Task

Detailed Job Steps

Potential SH&E Concerns

Conduct Inspection of worksite

Employees not familiar with worksite or


potential hazards of task

Conduct Pre-Task JSEA Development /


Review Meeting, and Inspection of
Required PPE and tools/equipment

-Unfamiliar with task to be performed


-SSE involved in task N/A
1. ___________
2. ___________
3. ___________
4. ___________
- Employees can not speak English
- Communication
- Defective tools / equipment / PPE
- Using unapproved or home made tools or
lifting devices

Receive applicable permits from


Operations
Utilize STOP WORK Authority if
conditions change or any other
uncertainty in job task.

Not authorized to perform work (i.e. permit


work, hot work, line opening, etc.)
- Job steps change
-New employee for task
-Employee identify new hazard or feels
uncomfortable or does not understand task steps
-No gloves or wrong gloves worn
- Rings being worn
- Hands placed in between items that could
move
- Hands placed on tools in non designated
location

5.

Discuss Hand Placement within task


Ensure to address hand placement
within each job task step in addition to
this review

Recommended Safe
Procedures/Protection

Responsible Party

All employees involved in task inspect worksite using


the inspection form on back of JSEA Yes
No
- Review JSEA and Post at site
- Assign mentor with SSE N/A
- Identify communication process to be used
__________________________
- Bilingual employees will cover entire JSEA with non
English speaking employees
- Bilingual employees will work with non English
speaking employees
- Repair or replace defective tools / equipment / PPE
-Use only approved tools or lifting devices
- Identify method and location of Fall Protection Rescue
Method____________ Location___________
Receive Permit(s) from Operations

Everyone involved in task

-STOP WORK, notify supervisor and resolve all reasons


for STOP WORK before restarting task
-Review and/or revise JSEA

Everyone involved in task

Everyone involved in task


Mentors Name ______________

Superintendent/Supervisor

-Ensure proper gloves are worn


- No rings to be worn during task
1_____________________________
2_____________________________
3_____________________________
4

Safety Equipment Required for this Task (Check all applicable). Inspect all PPE Prior to beginning Task.
Hard Hats:
Work Vest (PFD):
Fire Extinguishers/Firewatch:
Safety Shoes:
Face Shields:
LockOut / TagOut:
Safety Glasses:
Chemicals/Impact Goggles/Gloves:
Work Permit Required:
Leather, Cotton or Nitrile Gloves:
Hearing Protection:
Scaffolding:
Safety Harness & Anchor Device 100%:
Fall Protection Rescue System:
Gas Detection Meter:

Employee Review and Approval Signatures


1.
6.
2.
7.
3.
8.
4.
9.
5.
10.

This document certifies as a hazardous assessment for Personal Protective Equipment. Hot Work Activities require the review of the Gas Cutting/Welding Safety Guidelines prior to commencement
of work activities.
DII SAFETY 018 1F

SEGURAS RAPID PRESS 337-365-0749

G1.7.a.1

G1.7.a. 2

DII SAFETY 018 1B

SEGURAS RAPID PRESS 337-365-0749

COATINGS DEPARTMENT
JOB SAFETY AND ENVIRONMENTAL ANALYSIS

G1.7.a. 2

DII SAFETY 018 2F

SEGURAS RAPID PRESS 337-365-0749

G1.7.a. 2

DII SAFETY 018 2B

SEGURAS RAPID PRESS 337-365-0749

CONSTRUCTION DEPARTMENT
JOB SAFETY AND ENVIRONMENTAL ANALYSIS
Job#

Customer

Location

Date

Page

of

New JSEA:
Revised JSEA:

Y or N
Y or N

Job or Task

Detailed Job Steps

Potential SH&E Concerns

Recommended Safe
Procedures/Protection
All employees involved in task inspect worksite using
the inspection form on back of JSEA Yes
No
- Review JSEA and Post at site
- Assign mentor with SSE N/A
- Identify communication process to be used
__________________________
- Bilingual employees will cover entire JSEA with
non English speaking employees
- Bilingual employees will work with non English
speaking employees
- Repair or replace defective tools / equipment / PPE
- Use only approved tools or lifting devices
- Identify method and location of Fall Protection
Rescue Method____________ Location___________
Receive Permit(s) from Operations

Everyone involved in task

-STOP WORK, notify supervisor and resolve all


reasons for STOP WORK before restarting task
-Review and/or revise JSEA

Everyone involved in task

Conduct Inspection of worksite

Employees not familiar with worksite or potential


hazards of task

Conduct Pre-Task JSEA Development /


Review Meeting, and Inspection of
Required PPE and tools/equipment

-Unfamiliar with task to be performed


-SSE involved in task N/A
1. ___________
2. ___________
3. ___________
4. ___________
- Employees can not speak English
- Communication
- Defective tools / equipment / PPE
- Using unapproved or home made tools or lifting
devices

Receive applicable permits from


Operations
Utilize STOP WORK Authority if
conditions change or any other
uncertainty in job task.

Not authorized to perform work (i.e. permit work,


hot work, line opening, etc.)
- Job steps change
-New employee for task
-Employee identify new hazard or feels
uncomfortable or does not understand task steps

Discuss Hand Placement within task


Ensure to address hand placement within
each job task step in addition to this
review

-No gloves
- Rings being worn
- Hands placed in between items that could move
- Hands placed on tools in non designated
location

5.

Responsible Party

Everyone involved in task


Mentors Name ______________

Superintendent/Supervisor

-Ensure proper gloves are worn


- No rings to be worn during task
1_____________________________
2_____________________________
3_____________________________
4

Safety Equipment Required for this Task (Check all applicable). Inspect all PPE Prior to beginning Task.
Hard Hats:
Work Vest (PFD):
Fire Extinguishers/Firewatch:
Safety Shoes:
Face Shields:
LockOut / TagOut:
Safety Glasses:
Chemicals/Impact Goggles/Gloves:
Work Permit Required:
Leather, Cotton or Nitrile Gloves:
Hearing Protection:
Scaffolding:
Safety Harness & Anchor Device 100%:
Fall Protection Rescue System:
Gas Detection Meter:

Employee Review and Approval Signatures


1.
6.
2.
7.
3.
8.
4.
9.
5.
10.

This document certifies as a hazardous assessment for Personal Protective Equipment. Hot Work Activities require the review of the Gas Cutting/Welding Safety Guidelines prior to
commencement of work activities
DII SAFETY 016 1F

SEGURAS RAPID PRESS 337-365-0749

G1.7.a.5

G1.7.a.6

DII SAFETY 016 1B

SEGURAS RAPID PRESS 337-365-0749

CONSTRUCTION DEPARTMENT
JOB SAFETY AND ENVIRONMENTAL ANALYSIS

DII SAFETY 016 2F

SEGURAS RAPID PRESS 337-365-0749

G1.7.a.5

G1.7.a.6

DII SAFETY 016 2B

SEGURAS RAPID PRESS 337-365-0749

Attachment 2

G1.8

JOB SAFETY AND ENVIRONMENTAL ANALYSIS


Job#

Customer

Location

Date

Page

of 2

New JSEA:
Revised JSEA:

or N
or N

Job or Task Loading Equipment and/or material onto Trucks Trailer or Bed

Detailed Job Steps

Potential SH&E Concerns

Conduct Inspection of trucks


trailer or bed, surrounding area,
lifting equipment, equipment
and/ or material to be loaded.

Conduct Pre-Task JSEA


Development, JSEA Review /
Pre-lift Meeting, and Inspection
of Required PPE, Tools, Lifting
Equipment and Rigging

- Employees not familiar with worksite or


potential hazards of task
- Holes in the surface trailer or bed
- Truck not in designated loading area
- Poor lighting
- Poor surface around truck
- Weight of equipment or material unknown
- Lifting equipment over capacity of lifting
equipment.
- Equipment not designed to be lifted by
forklift
- Forks too small for equipment to be
loaded or offloaded
- The weight of the equipment or material is
over the capacity of the equipment at the lift
angle
- Defective Lifting Equipment
- Lifting Equipment Capacity is under the
weight of the equipment or material to be
loaded
-Unfamiliar with task to be performed
-SSE involved in task N/A
- Poor Communication
- Defective tools / equipment / PPE
- Time of Day

Receive applicable permits


from Operations

Not authorized to perform work (i.e. permit


work, hot work, line opening, etc.)

Utilize STOP WORK


Authority if conditions change
or any other uncertainty in job
task.

Discuss Hand Placement within


task Ensure to address hand
placement within each job task
step in addition to this review

- Job steps change


-New employee for task
-Employee identify new hazard or feels
uncomfortable or does not understand task
steps
-No gloves
- Rings being worn
- Hands placed in between items that could
move
- Hands placed on tools in non designated
location

DII SAFETY 013F

Recommended Safe Procedures/Protection

Responsible Party

- All employees to inspect the trucks trailer or bed


- If holes in surface of the trucks trailer or bed STOP WORK,
Refuse to load the truck.
- Move truck to designated loading area
- Move truck into a well lighted area
- Move truck to area with a more even surface
- Identify weight of equipment or material before lifting.
-Utilize lifting equipment thats lifting capacity is greater than the
weight of the equipment to be lifted
- Utilize lift equipment that is designed to lift the equipment or
material
- If forks are too small to lift equipment, utilize cherry picker /
crane
- Ensure capacity of lifting equipment is over the weight of
equipment / material to be lifted, if not, reposition lift equipment,
change lift equipment, if neither will work STOP WORK and
notify First Line Supervisor
- Perform Pre-use Inspection of Lifting Equipment

Everyone involved in task

- Review JSEA and Post at site


- Assign mentor with SSE N/A
- Identify communication process to be used:
___________________________________________
- Repair or replace defective tools / PPE
- Perform Pre-use inspection of lifting equipment and rigging,
remove from service accordingly
- No loading or unloading of equipment or material will occur
during night time hours without managements approval
Receive Permit(s) from Operations

Everyone involved in task


Mentors Name ______________

-STOP WORK, notify supervisor and resolve all reasons for STOP
WORK before restarting task
-Review and/or revise JSEA

Everyone involved in task

Superintendent/Supervisor

-Ensure proper gloves are worn


- No rings to be worn during task
1_____________________________
2_____________________________
3_____________________________
4
SEGURAS RAPID PRESS 337-365-0749

G1.8.a.1

Have Driver turn the trucks engine off


before identifying the location where
equipment and/or material shall be
placed onto the trailer or bed.

- Driver moving truck


- Weight of equipment is not distributed
properly on trailer or bed

- Driver to turn off engine before unsecuring his load


- Driver will instruct Equipment Operator where to place
equipment and/or material
- Designate a Signal Person
- Identify Sequence in which equipment / material
will be Loaded.

Driver and Equipment Operator(s)

Designated Signal Person is:


1.________________

1. ________________________________
2._________________________________
3._________________________________
4._________________________________
5._________________________________
6._________________________________
7._________________________________
8._________________________________
9._________________________________
7

Have Driver remain in a protective area


away from the operations until loading
process is over.
Protective Area
:________________________
Loading of Truck trailer or bed

- Driver approaches operations


- Driver starts engine while loading

- STOP Loading Process and report situation to First


Line Supervisor

Equipment Operator(s) and Riggers

- Driver steps out of protective area


- Load is not stable
- Load shifts unexpected
- Rigging fails
- Personnel places himself between load and
other equipment or material
- Improper hand signals
- Load is not in control
- Load swings
- Rigging too high to remove from block

Equipment Operator(s) and Riggers

Allow driver out of protective area to Tie


down his load

- Drive does not have correct PPE


- Another piece of equipment or material
needs to loaded
- Straps / Binders Fail

- If driver exits protective area STOP WORK and Notify


First Line Supervisor.
- Ensure block is over the load
- Use adequate number of taglines
- Do not place yourself in between in the load and other
equipment, or material
- Use proper hand signals
- Watch the load at all times do not turn your back to the
load.
- Utilize ladder to remove rigging from block with
another employee holding ladder
- Driver to wear all required PPE
- Ask Driver to return to the protective area before
loading additional equipment and/or material
-Inspect straps/binders and stand clear while tightening

Employee Review and Approval Signatures


Hard Hats: Required

Individuals Involved with Task Signature


1.

Individuals Involved with Task Signature


2.

Safety Shoes: Required

3.

4.

Safety Glasses: Required

5.

6.

Cotton Gloves / Leather Gloves: Required

7.

8.

Hearing Protection: Required for Equipment Operators

9.

G1.8.a.2

DII SAFETY 013B

Equipment Operator and Driver

Drivers Signature:

SEGURAS RAPID PRESS 337-365-0749

JOB SAFETY AND ENVIRONMENTAL ANALYSIS


Job#

Customer

Location

Date

Page

1 of 2

New JSEA:
Revised JSEA:

or N
or N

Job or Task: Off Loading Equipment and/or material from Trucks Trailer or Bed

Responsible Party

Detailed Job Steps

Potential SH&E Concerns

Recommended Safe
Procedures/Protection

Conduct Inspection of trucks


trailer or bed, surrounding area,
lifting equipment, equipment
and/ or material to be off loaded.

- All employees to inspect the trucks trailer or bed


- If holes in surface of the trucks trailer or bed STOP WORK,
Refuse to load the truck.
- Move truck to designated loading area
- Move truck into a well lighted area
- Move truck to area with a more even surface
- Identify weight of equipment or material before lifting.
-Utilize lifting equipment thats lifting capacity is greater than
the weight of the equipment to be lifted
- Utilize lift equipment that is designed to lift the equipment or
material
- If forks are too small to lift equipment, utilize cherry picker /
crane
- Ensure capacity of lifting equipment is over the weight of
equipment / material to be lifted, if not, reposition lift equipment,
change lift equipment, if neither will work STOP WORK and
notify First Line Supervisor
- Perform Pre-use Inspection of Lifting Equipment

Everyone involved in task

Conduct Pre-Task JSEA


Development, JSEA Review /
Pre-lift Meeting, and Inspection
of Required PPE, Tools, Lifting
Equipment and Rigging

- Employees not familiar with worksite or


potential hazards of task
- Holes in the surface trailer or bed
- Truck not in designated loading area
- Poor lighting
- Poor surface around truck
- Weight of equipment or material unknown
- Lifting equipment over capacity of lifting
equipment.
- Equipment not designed to be lifted by
forklift
- Forks too small for equipment to be
loaded or offloaded
- The weight of the equipment or material is
over the capacity of the equipment at the lift
angle
- Defective Lifting Equipment
- Lifting Equipment Capacity is under the
weight of the equipment or material to be
loaded
-Unfamiliar with task to be performed
-SSE involved in task N/A
- Poor Communication
- Defective tools / equipment / PPE
- Time of Day

Everyone involved in task


Mentors Name ______________

Receive applicable permits from


Operations

Not authorized to perform work (i.e. permit


work, hot work, line opening, etc.)

- Review JSEA and Post at site


- Assign mentor with SSE N/A
- Identify communication process to be used:
___________________________________________
- Repair or replace defective tools / PPE
- Perform Pre-use inspection of lifting equipment and rigging,
remove from service accordingly
- No loading or unloading of equipment or material will occur
during night time hours without managements approvals.
Receive Permit(s) from Operations

Utilize STOP WORK Authority


if conditions change or any other
uncertainty in job task.

-STOP WORK, notify supervisor and resolve all reasons for


STOP WORK before restarting task
-Review and/or revise JSEA

Everyone involved in task

Discuss Hand Placement within


task Ensure to address hand
placement within each job task
step in addition to this review

- Job steps change


-New employee for task
-Employee identify new hazard or feels
uncomfortable or does not understand task
steps
-No gloves
- Rings being worn
- Hands placed in between items that could
move
- Hands placed on tools in non designated
location

DII SAFETY 014F

Superintendent/Supervisor

-Ensure proper gloves are worn


- No rings to be worn during task
1_____________________________
2_____________________________
3_____________________________
4
SEGURAS RAPID PRESS 337-365-0749

G1.8.a.3

Have Driver turn the trucks engine off


before removing is securing devices,
before we identify equipment numbers

- Driver moving truck while someone is


on top of trailer or bed.
- Tie downs are thrown over equipment
hitting someone.
- Tie down device pops unexpected hitting
driver.

- Driver to turn off engine before unsecuring his load


- Driver shall position himself to ensure secure device
does not hit him when unsecuring
- Designate a signal person
- Identify Sequence in which equipment / material
will be Off Loaded.

Driver and Equipment Operator(s)

Designated Signal Person is:


1.___________________

1._____________________________
2._____________________________
3._____________________________
4._____________________________
5._____________________________
6._____________________________
7._____________________________
8._____________________________
9._____________________________
7

Have Driver remain in a protective area


until loading process is over.
Protective Area:
________________________

- Driver starts engine while loading


- Driver approaches operations

- STOP Loading Process and report situation to First


Line Supervisor

Equipment Operator(s) and Riggers

Off Loading of Truck trailer or bed

- Driver steps out of protective area


- Load is not stable
- Load shifts unexpected
- Rigging fails
- Personnel places himself between load
and other equipment or material
- Improper hand signals
- Load is not in control
- Load swings
- Rigging too high to remove from block
- Hole is identified after removing some
equipment or material from trailer or bed

Equipment Operator(s) and Riggers

Allow driver out of protective area to


Tie down his load

- Drive does not have correct PPE


- Another piece of equipment or material
needs to loaded

- If driver exits protective area, STOP WORK and


Notify First Line Supervisor.
- Ensure block is over the load
- Use adequate number of taglines
- Do not place yourself in between in the load and
other equipment, or material
- Use proper hand signals
- Watch the load at all times do not turn your back to
the load.
- Utilize ladder to remove rigging from block with
another employee holding ladder
- If hole in trailer or bed is identified during the off
loading of equipment or material STOP WORK and
notify First Line Supervisor
- Driver to wear all required PPE
- Ask Driver to return to protective area before loading
additional equipment and/or material
-Inspect straps/binders and stand clear while tightening

Employee Review and Approval Signatures


Hard Hats: Required All Task Personnel

Individuals Involved with Task Signature


10.

Individuals Involved with Task Signature


11.

Safety Shoes: Required All Task Personnel

12.

13.

Safety Glasses: Required All Task Personnel

14.

15.

Cotton Gloves / Leather Gloves: Required All Task Personnel

16.

17.

Hearing Protection: Required for Equipment Operator(s)

18.

G1.8.a.4

DII SAFETY 014B

Equipment Operator and Driver

Drivers Signature:

SEGURAS RAPID PRESS 337-365-0749

JOB SAFETY AND ENVIRONMENTAL ANALYSIS


Job#

Customer

Location

Date

Page

of 2

New JSEA:
Revised JSEA:

or N
or N

Job or Task Loading / Offloading Material from Closed In Truck Trailer

Detailed Job Steps

Potential SH&E Concerns

Recommended Safe Procedures/Protection

Responsible
Party

Conduct Inspection of trucks trailer


or bed, surrounding area, lifting
equipment, equipment and/ or
material to be loaded / offloaded.

Conduct Pre-Task JSEA


Development, JSEA Review / Prelift Meeting, and Inspection of
Required PPE, Tools, Lifting
Equipment and Rigging

- All employees to inspect the trucks trailer or bed


- If holes in surface of the trucks trailer or bed STOP WORK, Refuse
to load the truck.
- Move truck to designated loading area
- Move truck into a well lighted area
- If hazardous materials, ensure MSDS are reviewed and precautions
identified on MSDS are followed.
- Move truck to area with a more even surface
- Identify weight of equipment or material before lifting.
-Utilize lifting equipment thats lifting capacity is greater than the
weight of the equipment to be lifted
- Utilize lift equipment that is designed to lift the equipment or material
- If forks are too small to lift equipment, utilize cherry picker / crane
- Ensure capacity of lifting equipment is over the weight of equipment /
material to be lifted, if not, reposition lift equipment, change lift
equipment, if neither will work STOP WORK and notify First Line
Supervisor
- Perform Pre-use Inspection of Lifting Equipment
- Review JSEA and Post at site
- Assign mentor with SSE N/A
- Identify communication process to be used:
___________________________________________
- Repair or replace defective tools / PPE
- Perform Pre-use inspection of lifting equipment and rigging, remove
from service accordingly
- No loading or unloading of equipment or material will occur during
night time hours without managements approval
Receive Permit(s) from Operations

Everyone involved in
task

- Employees not familiar with worksite or potential


hazards of task
- Holes in the surface trailer or bed
- Truck not in designated loading area
- Poor lighting
- Poor surface around truck
- Hazardous Materials
- Weight of equipment or material unknown
- Lifting equipment over capacity of lifting
equipment.
- Equipment not designed to be lifted by forklift
- Forks too small for equipment to be loaded or
offloaded
- The weight of the equipment or material is over
the capacity of the equipment at the lift angle
- Defective Lifting Equipment
- Lifting Equipment Capacity is under the weight
of the equipment or material to be loaded
-Unfamiliar with task to be performed
-SSE involved in task N/A
- Poor Communication
- Defective tools / equipment / PPE
- Time of Day

3
4

Determine if driver will be assisting


with the offloading process (ie.
Using pallet jack, dolly, etc.)
Receive applicable permits from
Operations
Utilize STOP WORK Authority if
conditions change or any other
uncertainty in job task.
Discuss Hand Placement within task
Ensure to address hand placement
within each job task step in addition
to this review

DII SAFETY 015F

Not authorized to perform work (i.e. permit work,


hot work, line opening, etc.)
- Job steps change
-New employee for task
-Employee identify new hazard or feels
uncomfortable or does not understand task steps
-No gloves
- Rings being worn
- Hands placed in between items that could move
- Hands placed on tools in non designated location

-STOP WORK, notify supervisor and resolve all reasons for STOP
WORK before restarting task
-Review and/or revise JSEA

Everyone involved in
task
Mentors Name
______________

Superintendent/Superv
isor
Everyone involved in
task

-Ensure proper gloves are worn


- No rings to be worn during task
1_____________________________
2_____________________________
3_____________________________
4

SEGURAS RAPID PRESS 337-365-0749

G1.8.a.5

Have Driver turn the trucks engine

- Driver moving truck


- Sequence in which equipment / material will be off
loaded.

- Driver to turn off engine before unsecuring his load


- Designate a Signal Person
- Identify Sequence in which equipment / material will be
Off Loaded.

1. ________________________________
2._________________________________
3._________________________________
4._________________________________
5._________________________________
7

Equipment / Material removed from


truck trailer:
Identify Method for getting material /
equipment out of truck trailer:
________________________________
________________________________
________________________________
________________________________
________________________________

- If Driver is assisting if the offloading of truck trailer:


- Driver places himself in a pinch point.
- Using strap / rigging and forklift to slide material to
back of trailer so it can be removed.
- Strap / rigging failure.
- Load gets hung up
- Load tips over.- Driver steps out of protective area
- Load is not stable
- Load shifts unexpected
- Rigging fails
- Personnel places himself between load and other
equipment or material
- Improper hand signals
- Load is not in control
- Load swings

________________________________
_______________________________________
________________________________
_______________________________________
________________________________
_______________________________________
________________________________
_______________________________________

Setting equipment / material down in


yard

Allow driver out of protective area to


close the trailer.

Personnel in the area of the operation.


Material not properly stacked.
Load shifts unexpectedly.
Personnel being pinned by load if material tips
over.
- Drive does not have correct PPE
- Another piece of equipment or material needs to
loaded
- Straps / Binders Fail

Employee Review and Approval Signatures

- List specific pinch points and where driver / personnel need


to be positioned.
__________________________________________

- Have driver bring material to back of trailer and then return


to front of trailer before load is taken out of trailer.
- If driver will not be assisting in the offloading, driver needs
to be removed from truck trailer and placed in a protective
area.
- If using strap / rigging and forklift to slide material to back
of trailer so it can be removed, make sure no one is in truck
trailer during the operation.
- Inspect all rigging equipment to be used.
- Inspect load to ensure it will not get hung
up while being skidded.
- Identify where rigging needs to be placed
to ensure load will not tip over.
- If driver exits protective area STOP WORK and Notify First
Line Supervisor.
- Ensure block is over the load
- Use adequate number of taglines
- Do not place yourself in between in the load and other
equipment, or material
- Use proper hand signals
- Watch the load at all times do not turn your back to the load.
- Remove all non-essential personnel from the area.
- If stacking material, ensure stack is stable.
- Use adequate number of taglines to stabilize load.
- Ensure everyone remains clear of load when it is set
down.
- Driver to wear all required PPE
- Ask Driver to return to the protective area before loading
additional equipment and/or material
-Inspect straps/binders and stand clear while tightening

Individuals Involved with Task Signature

Equipment Operator(s)
and Riggers

Equipment Operator(s)
and Riggers

Equipment Operator and


Driver

Individuals Involved with Task Signature

Hard Hats: Required

20.

Safety Shoes: Required

21.

22.

Safety Glasses: Required

23.

24.

Cotton Gloves / Leather Gloves: Required

25.

Hearing Protection: Required for Equipment Operators

27.

DII SAFETY 015B

Designated Signal
Person is:
1._____________

__________________________________________

19.

G1.8.a.6

Driver and Equipment


Operator(s)

26.
Drivers Signature:
SEGURAS RAPID PRESS 337-365-0749

Attachment 3

G1.9

JSEA PROCESS MAP

Sr. Mgmt.

Supervisor

Task
Leader

Periodically Audit the JSEA Process and Communicate Audit Findings (As part of SH&E MS)

Select
Job for
Analysis
(Step 1)

Perform
Jobsite
Hazard
Review

Prepare Draft
JSEA *
(Steps 2-4)

Review JSEA
w/ Crew
(Step 5)

Routinely Monitor Jobs to verify


JSEA process is being implemented
properly. Communicate JSEA with
other affected personnel.

Modify JSEA
to address
changes

Sign JSEA
Form to
indicate
Agreement
(Step 5)

Y
Review JSEA /
Give Feedback
(Step 5)

Crew

Customer
Notes:

*
**

Changes?
(Step 5)

Post JSEA
at Job Site
and
Conduct Job
as described
in JSEA

Keep JSEAs on
file for future
reference and
audits

Y
Job
Changes?
**
(Step 6)

Participate
As
Appropriate

Monitor
Job

Steps refer to the Process Description in the JSEA Program


Modify existing JSEAs for similar tasks, if available (Steps 2-4)
If Job Scope, Personnel or Work Environment change, modify JSEA as needed. (Step 6)

G1.9.a.1

Moreno Group LLC and


Subsidiaries SH&E
Management Systems

Incident Report / Medical


Attention Procedure

Page 1 of 7
Original: 01/01/2001
Revised: 01/01/2010

Incident Reporting / Medical Attention Procedure


Purpose
The purpose of this program is to provide guidelines for reporting incidents to
Moreno Group LLC and Subsidiaries.
Scope
This program addresses the responsibilities of the supervisor upon the notification of
an incident.
Responsibilities
The Facility / Site Manager or Designee is responsible for:
Providing support and resources to implement this program.
Providing emergency contact numbers, approved first aid kits and bloodborne
pathogens kits at all job sites.
The Yard Foreman / Offshore Manager is responsible for:
Arrange proper transportation of injured employee to medical facility.
Notifying Safety, Health and Environmental Department of incident.
Providing medical facility approval for Medical Treatment, if Safety, Health
and Environmental Department is unavailable.

The First Line Supervision / Offshore Superintendent is responsible for:


Communicating to employees to report all incidents.
Notifying Yard Foreman or Offshore Manager of all incidents.
Provide needed information to Yard Foreman or Offshore Manager for
transportation to medical facility.
Providing to Yard Foreman or Offshore Manager completed incident reports.

The Safety, Health and Environmental Department is responsible for:


Inspecting and maintain facilities first aid kits.
Providing assistance to operations in the transporting of injured party.
Post Injury Management of the incident and appropriate record all injuries.
The Tool Room is responsible for:
Providing United States Coast Guard (USCG) approved first aid kits and
bloodborne pathogens kits in all offshore tool houses.
The Employee is responsible for:
Reporting all incidents, no matter how minor, including Near Misses
immediately to their First Line Supervisor or Superintendent.
Requirements
All incidents (i.e. Injury, Illness (Occupational), Property Damage, Fire, Crane
Incident, Information Only (Non Occupational) Vessel Collision no matter how minor
including shall be reported immediately to the employees supervisor (see
Attachment 1 The First Line Supervisor shall complete the First Report of Injury or
Occupational Illness / Property Damage Report (see Attachment 2).
Incident Reporting
Upon notification of an incident, the supervisors initial duty is to confirm that
the employee is not injured and does or does not need medical attention.
Anytime there is doubt; medical attention shall be sought.
If the employee does not require medical attention, the supervisor shall
completely fill out the First Report of Injury or Occupational Illness / Property
Damage Report (see Attachment 2) and Moreno Group LLC and
Subsidiaries Work Group Investigation Form (see Incident Investigation
Procedure). Near Miss Incidents shall be reported on the Moreno Group LLC
and Subsidiaries Observation/Near Miss Card. The First Line Supervisor or
Superintendent and their Manager should determine if a Near Miss should
have a Work Group Investigation conducted. The supervisor shall obtain a
copy of any Third Party Accident Reports and attach these reports to the
incident documents.
The supervisor shall notify their immediate Manager.
The Manager will notify the SH&E Department of the incident.
The supervisor shall forward to their immediate Manager the completed
incident reports within 24 hours.

Upon receiving incident documents the Manager shall review and forward to
the SH&E Department.
Medical Attention Required:
Should the injured employee require medical attention, the supervisor shall
notify his immediate Manager.
Prior to notifying the SH&E Department the Manager shall arrange
transportation to closest company designated medical facility. If the SH&E
Department is unable to arrive at the medical facility prior to the injured
partys arrival, the Manager shall Fax the Approval for Medical Attention
(see Attachment 3) to the medical facility.
The supervisor shall complete the First Report of Injury or Occupational
Illness / Property Damage Report (see Attachment 2).and the Moreno Group
LLC and Subsidiaries Work Group Investigation (see Incident Investigation
Procedure). The supervisor shall obtain a copy of any Third Party Accident
Report and attach these reports to the incident documents.
The supervisor shall forward to their immediate Manager the completed
incident reports within 24 hours.
Upon receiving the incident documents, the Manager shall review, approve
and forward documents to the SH&E Department.
First Aid
All Moreno Group LLC and Subsidiaries facilities will have readily available approved
first aid kit located in the Safety, Health and Environmental Department. All Offshore
tool houses will be provided with a USCG Approved First Aid Kit and Bloodborne
Pathogens Kit.
Inspection of First Aid Kits
Weekly the Facility Management and the Safety, Health and Environmental
Department shall be responsible for checking and maintaining the First Aid Kits
located at each facility. The tool room shall be responsible for providing fully stocked
USCG first aid kits which is a weather proof container with sealed packages of each
type of item in all offshore tool houses prior to sending the offshore tool house
offshore.
Training
First Line Supervisors, Offshore Superintendents and the Safety, Health and
Environmental Department shall be trained in American Heart CPR, First Aid and
Bloodborne Pathogens. Retraining will be annual for American Heart CPR and
Bloodborne Pathogens and every two years for First Aid. These records will be
maintained by the Safety, Health and Environmental Department.

Emergency Eye / Body Wash Stations


Emergency eye / body wash stations should be provided with in 10 feet of those
areas where corrosive materials are being handled and/or stored.

Emergency Contact Numbers


Facility Manager shall be responsible for posting emergency contact numbers.
These numbers should include following contacts:
Medical Facilities
Fire Departments
Spill Response Companies
Police Department
All emergency numbers shall be established prior to commencement of a project to
ensure timely response for an emergency situation.
Incident Involving Subcontractor
All incidents involving of a Subcontractor Companys or their employees shall be
documented on our First Report of Injury or Occupational Illness / Property Damage
Report (see Attachment 2).
Reporting procedures for Subcontractor Companys incidents shall be performed
using our Incident Reporting procedures (see Attachment 1).
Recording of Injuries
All injuries will be classified and recorded in accordance with the OSHA
Recordkeeping Guidelines.

Attachment 1

Moreno Group LLC and Subsidiaries Incident Reporting Procedure Flow Chart
Incident
Supervisor Notifies Division
Manager to arrange
transportation to medical facility

Employee Notifies
Supervisor
Supervisor confirms
employees need for
medical attention

Supervisor notifies
Client of Incident
Division Manager notifies SH&E
Department
Division Manager
reviews with and
provides forms to
SH&E Department

YES
Medical
Attention
Needed

NO

SH&E representative
arrives at medical
facility prior to injured

employee
Supervisor completes Incident
Report & Incident Investigation
forms and faxes to Division
Manager

Supervisor Notifies Division


Manager

Division Manager Notifies and


provides forms to SH&E
Department

SH&E Department notifies upper


management

Supervisor completes
Incident Report &
Incident Investigation
forms and faxes to
Division Manager

NO

YES

SH&E representative
performs Post Injury
Management

Division Manager faxes Approval


for Medical Attention to medical
facility

SH&E representative meets injured


employee at medical facility and
performs Post Injury Management

SH&E Department
notifies Division
Manager and Upper
Management of
employee condition

Attachment 2

FIRST REPORT OF INJURY OR OCCUPATIONAL ILLNESS /


PROPERTY DAMAGE REPORT

Type of
Injured Party
Incident

Injury

Occupational Illness

Property Damage

Information Only
Fire
(Non-Occupational)
Crane Incident
Vessel Collision

L. Name: ________________________ FI: ______

Moreno employee
Subcontractor

MI: ______ SSN: __________________

Address: __________________________City: _______________ State: _______ Zip: _______


Birthday: ___\___\___ Age: ____ Sex: ___ Years Experience: ___ Occupation:_______________
Phone No.: _________________________ Alt. Phone No.: _______________________________

When

When Injury/Illness Occurred:

Employee Injured During Working Hours: Yes ___ No ___

Date: ___\___\___ Did Employee Stop Work: Yes ___ No___


Time (24-hour format HH:MM): ___________
Date Reported to Moreno Group LLC and Subsidiaries: ____\____\___

Facility
Information

Facility Name: ____________________________ Parish: ________________________________


Facility Owner: ___________________________

State: _________________________________

City / Town: ______________________________ Phone No.: ____________________________


Contact Person: __________________________ Job No.: _______________________________

Vessel
Informa- Body Part
tion

Vessel Name: ______________________________ Vessel Owner: _________________________


Contact Person: ____________________________ Contact Phone No. ______________________
Head Face Ear (L/R) Eye (L/R) Nose Mouth Tooth
Neck

Shoulder (L/R)

Hand (L/R)
Hip (L/R)

Arm (L/R)

Finger or Toe
Leg (L/R)

Torso

Knee (L/R)

Elbow (L/R)
Internal
Ankle (L/R)

Wrist (L/R)
Back
Foot (L/R)

Description
of Incident
Property
Damage

Owner Name: __________________________________ Contact No.: _______________________


Address: _____________________________ City: _______________ State: _______ Zip: _______

Witnesses

Describe the Property and Damage: ___________________________________________________


________________________________________________________________________________
Name: _______________________________________ Phone No.: _________________________
Address: ___________________________ City: _______________ State: _______ Zip: _________
Name: ______________________________________ Phone No.: __________________________
Address: ___________________________ City: _______________ State: _______ Zip: _________

Signature Medical Information

Supervisor's Signature: _____________________________________ Date: ______/______/______


Medical Attention Authorized: Yes _____ No _____ Date of Authorization: _____/_____/______
Name: ____________________________________ Phone No.: ___________________________
Address: ____________________________ City: _______________ State: _______ Zip: ________
Did Doctor Release Employee for Work: Yes ____ No ____ Full Duty ____ Restricted Duty ____
Describe restrictions if any:
_______________________________________________________________________________
Return to work within 24 hours: Yes ____ No____
Within 72 hours: Yes ____ No ____

COVERAGE: STATE OF ___________ LONGSHORE____________ INTERNATIONAL__________

Attachment 3

MORENO GROUP LLC AND SUBSIDIARIES


APPROVAL FOR MEDICAL ATTENTION

Date
Medical Facility
Address

Please render medical attention to _______________________, which is an employee of Moreno


Group LLC and Subsidiaries Nature of injury: _________________________________________
Authorized By: _________________________________________________________________
Title: _________________________________________________________________________
Please send all reports and bills to:

Moreno Group LLC and Subsidiaries


P.O. Box 9406
New Iberia, La. 70562
Attn: SH&E Department

Doctors Statement
Name of injured employee
Date of Treatment
Will the employees physical condition allow him or her to return to
work
Should physical condition permit
employee to return to work, is the work

Regular Duty

Yes

No

Restricted Duty

If restricted, Please state the reason(s) for Restricted Duty:

Date to return for follow-up treatment:_______________________________________________


Date:___________________ Attending Physician:____________________________________

Moreno Group LLC and


Subsidiaries SH&E
Management System

Incident Investigation
Procedure

Page: 1 of 11
Original: 02/09/1998
Revised: 12/01/2009

Incident Investigation Procedure


Purpose
The purpose of this document is to provide a uniform method for investigating
incidents to promote the following:
Prevent incident recurrence.
Identify conditions that could cause a similar incident.
Recognize areas for improvements within management systems.
Demonstrate commitment to workplace safety.
Increase employee confidence in workplace safety.
Scope
The scope of Moreno Group LLC and Subsidiaries incident investigation
procedure is to investigate Safety, Health and Environmental related incidents
with the intent of identifying causes and taking proper corrective actions.
Investigations will be conducted with the objective of finding the causes and not
placing blame.
No Disciplinary action will be imposed as a result of the information provided
during an investigation, unless there is a clear, verifiable evidence of negligence
or disregard of a company safety rule or procedure or misrepresentation of the
facts.
Responsibilities
The Facility Manager/ Offshore Manager/ Yard Foreman or Designee is
responsible for:
Providing necessary resources for investigation including staff support
when requested.
Evaluate incident information gather during the Workgroup Incident
Investigation and assign a risk valve for this incident.
Conducting Supplemental Incident Investigations (see Attachment 2).
Reviewing and approving investigation reports and any control items.
Providing resources necessary for the
recommendations and any control actions.

completion

of

approved

H2.1

Retention of incident reports and supporting documentation for five (5) years.
Conducting a 30-day follow-up on all outstanding recommendations and
providing management with a monthly exception list of all overdue action
items.
Overseeing this policy and insuring all requirements are met.
Auditing compliance with this policy.
Understanding and complying with this policy / procedure.
Timely notification of management and Safety Department concerning
incidents occurring in their areas of responsibilities
Preservation of the incident scene until released to the investigation team.
Investigating or participating in the investigation of all job related accidents,
injuries, illnesses or near-miss events that occur in their area(s).
Completing the Workgroup Incident Investigation (Attachment 1).
Assuring adequate short-term interim measures are taken to allow safe
resumption of work.
Completing any assigned report recommendations.
Communication of report findings and corrective actions to subordinates.
Documentation of investigation findings and corrective actions and submitting
to the Facility / SH&E Department / designee for filing.
Issuing the Workgroup Incident Investigation Form to the Facility / Site
Manager within 24 hours.
The Safety, Health and Environmental Department is responsible for:
Reviewing all completed Workgroup Incident Investigation Forms and
Witness Statements.
Participating in the actual investigation of accidents or incidents with the
potential for serious personal injury, property damage or damage to the
environment.
Assignment of a unique report number that will be entered on all reports,
attachments and / or evidence.

H2.2

Providing Incident Investigation Training to Management and First Line


Supervision.
To develop Safety Alerts pertaining to the incident to ensure lesson learned
from the Workgroup Investigation is communicated throughout the
organization and implemented.
The Employee is responsible for:
Understanding and complying with this policy / procedure.
Reporting all incidents to their Supervisor / designee immediately.
Completing the Employee / Witness Statement (Attachment 3) when he or
she is involved in or witnesses an accident or injury.
Participating on investigation teams as required.
Definitions
Incident an event that causes, or could cause, personnel injuries and/or property
loss. Incident examples include the following: all personnel injuries (regardless of
severity), spills or releases of hazardous materials, fires, explosions, and vehicle
accidents.
Incident Category -- A classification system, used by the Safety Department, based
on Bureau of Labor Statistics and Company guidelines to determine the incident
type for recordkeeping, statistical, and investigation purposes.
Near Miss a condition, situation, or event having the potential to cause personnel
injuries and/or property loss.
Root Cause a specific action, non-action, event, condition, etc that is the
fundamental or underlying basis for an incident occurrence.
Work Group An investigation team composed of the affected employee(s), the
affected employee(s), and at least one or more peer employees.
Requirements
Personnel shall report all incidents immediately to their supervisor.
All incidents, may be investigated using this procedure. The Work Group
Investigation (see procedure) shall be conducted the same day the incident
occurred.
A Supplemental Investigation is required for all OSHA Days Away From Work
incidents. The Supplemental Investigations shall be conducted as soon as the
required investigation team can be assembled. The following is a list of numerical
risk factors and recommended Supplemental Investigation Team members:
H2.3

Vice President (Chair Person)


Offshore Manager (Offshore incident)
Yard Foreman (Onshore incident)
Offshore Superintendent (Offshore incident)(if possible)
Supervisor (Onshore incident)
Safety, Health and Environmental Department Representative
Work Group Investigation Team (if possible)
Applicable Documents and Forms
Work Group Investigation Report From all work-group investigations shall
be conducted using the Moreno Group LLC and Subsidiaries Work Group
Investigation Report Form (see Attachment 1). A detailed narrative may be
attached to the report form if additional space for documentation is necessary.
The Original form is forwarded to the Yard/Offshore Managers following the
investigation (see Attachment 1). If a supplemental investigation is to be
conducted, a copy of the Work Group Investigation Report should be attached
to the Supplemental Investigation Form. Copies of the completed Work
Group Form shall be forwarded to the Safety, Health and Environmental
Department and all members of the investigation team.
Supplemental Investigation Report Form all supplemental investigations
shall be conducted using the Supplemental Investigation Report Form (see
Attachment 2). The original Work Group Investigation Report is used as
preliminary information. A copy of the Work Group Report should be attached
to the Supplemental Investigation Report Form. A detailed narrative may be
attached to the report form if additional space for documentation is necessary.
Copies of the completed Supplemental Investigation Report Form shall be
forwarded to all members of the investigation team. The original form is
forwarded to the Safety Department following the investigation.
Document Recordkeeping the original Work Group Investigation Report
Form and the original Supplemental Investigation Report Form shall be
returned to the Safety, Health and Environmental Department for
recordkeeping. All incident investigation reports shall be retained by the
Safety, Health and Environmental Department for five years.
Procedures
Incidents are reviewed using a two-part system starting with an investigation
conducted by the immediate work group involved with the incident and, if
applicable, progressing to an investigation involving additional members of
management, employee representatives, and safety representatives.
Work Group Investigation All incidents may be investigated by a
Work Group Investigation Team the same day the event occurs. The
Work Group Investigation Team consists of the affected employee(s),
affected employee(s) supervisor/offshore superintendent (chairperson)
and all available members of the immediate work group. If the affected
H2.4

employee is not able to attend the investigation, the work group shall
meet the day of the incident to gather information and conclude the
investigation when the affected employee is available. In some cases,
more than one work group may be included in the Work Group
Investigation.
Use the Work Group Investigation Form to document team findings
and recommendations (see Procedure Section for guidelines for
conducting a Work Group Investigation). The completed investigation
form is forwarded to the Yard Foreman/Offshore Manager who shall
review the work group investigation. The Yard Foreman/Offshore
Manager will arrange for a supplemental investigation (if required) or
forward the form to their Facility Manager for review and approval then
the Safety, Health and Environmental Department for tracking and
follow-up.
Supplemental Investigation All incidents involving an OSHA Days
Away From Work incidents shall receive a supplemental investigation.
The Yard/Offshore Manager who reviewed the Work Group
Investigation has the responsibility to arrange for the Supplemental
Investigation. Use the Supplemental Investigation Form to document
team findings and recommendations.
The purpose of the
supplemental investigation is to involve the appropriate level of
managers and employee representatives in the more-serious incident
reviews to aid with identifying underlying causes, corrective actions,
and assign action-item responsibilities. Use the Work Group
Investigation Report as preliminary information for the supplemental
investigation. A copy of the completed Work Group Investigation form
shall be attached to the Supplemental Investigation Form.
Conducting a Work Group Investigation
The following guidelines are provided to promote consistent incident
investigation methods using the Work Group Investigation Form. Elements of
each section of the Work Group Investigation Form are included along with
suggested items for discussion.
Information Block Print the employees name, date and time of the
incident, job classification, area or work unit where the incident
occurred, specific incident location, the date and time the incident was
reported, and the employees supervisor.
Investigation Team Members Print the names of all team members
present during the Work Group Investigation. This is not a signature
block.
Incident Information
Incident Description Print or write legibly a complete
description of the incident, i.e. What happened, who was
H2.5

involved, materials, vessel numbers or equipment, etc.


Include a map or hand drawn diagram of vehicle, equipment,
or personnel locations if applicable.
Witness (es) enter the names of persons who saw the
event. (see Attachment 3
Immediate Corrective Actions What actions (such as
barricading, personnel notifications, instructions, equipment
repair, etc.) were taken to abate any unsafe conditions?
Contributing Factors
Material, Equipment, Personal Protective Equipment (PPE),
and Environment What materials (i.e. Forms, lumber, fuels,
scaffolds, etc.), and environmental factors (i.e. Site
condition, weather, time-of-day, etc.) may have contributed
to the incident? The type of equipment, condition, and
specific parts involved are important. PPE use, or non-use,
that may have contributed to the incident should be listed
(i.e. Not wearing hardhat, gloves, faceshield, safety glasses,
fall protection, etc.).
Training Were the affected employees trained in the tasks
being performed? Does new training need to be developed
or does present training need revised? (Safety Department
confirm that applicable training is documented and current
after the investigation is completed).
Safety Systems Were any permits or approvals required
for the task? If yes, were they properly completed? (Safety
Department Is the task covered by an auditing system?
Does one need to be developed?
Human Factors/Ergonomics What shift was the affected
employee working and what part (beginning, middle, end) of
the shift did the incident occur? Was the person trying to
save time or effort? Did the person have a deadline to
meet? Was it inconvenient for the person to obtain
necessary safety equipment? Did the design of tools or
workstations contribute to the incident?
Task Instructions Was there a Work Order associated with
the job? If yes, list the number and attach a copy to the
investigation form. Were job instructions given for the task?
Was there an unclear or conflicting assignment of
responsibility? Rules and Procedures Review established
safety rules and/or procedures that apply to the incident?
Were they adequate? Were the rules followed? If not, list
deficiencies. Does a new rule or procedure need to be
H2.6

developed or a present one revised to address incident


concerns? (Some suggested documents to review would
include Safety Manual, applicable JSEAs)
Other List any applicable events or circumstances which
do not fit the above categories.
Root Causes
Use analysis of the Incident Information and Contributing
Factors as aids in determining the root causes of the incident.
Preventive Actions/Recommendations
Use this block to list actions or recommendations which the
team views will correct current conditions or prevent future
incidents. Indicate the person responsible for completing the
recommendation and the target date to be entered in the
tracking system.
Yard Foreman/Offshore Manager Review
Supplemental Investigation Required if for all OSHA Days
Away From Work incidents.
Sign-off The Supervisor/Offshore Superintendent, Yard
Foreman/Offshore Manager, Safety, Health and
Environmental Department representative and Vice
President of respected area must sign and date the form
following their review.
Distribution Send the original (Record Copy) to the Safety,
Health and Environmental Department. All investigation
team members should receive a copy of the investigation
report as well as individuals assigned action-item
responsibilities.
Conducting a Supplemental Investigation
The following guidelines are provided to promote consistent supplemental
investigation methods using the Moreno Group LLC and Subsidiaries
Supplemental Investigation Form.
Details of each section of the
Supplemental Investigation Form are included along with suggested items for
discussion.
Information Block Print the date of the Supplemental Investigation
and names of the Team Members. This is not a signature block.
Review of Work Group Investigation The Supplemental Team will
review the Work Group Investigation for preliminary information.
H2.7

Supplemental Incident Information List information that


may have been revealed after the Work Group Investigation
was completed.
Supplemental Contributing Factors List contributing
factors, which may have not been included in the Work
Group Investigation.
Supplemental Root Causes List the root causes which the
Supplemental Investigation Team has formulated.

Management Systems
Administrative Controls Was inadequate staffing or time
allotment a factor? Were priorities unclear or conflicting?
Engineering Controls Were standards, specifications,
and/or design adequate? Were Management of Change
procedures followed?
Preventative Maintenance/Inspection Was the work
scheduled properly? Were the proper parts used? Was an
improper extension of service life/inspection period made?
Other List applicable management systems not included
above.
Additional Preventive Actions/Recommendations List
preventive actions or recommendations, which were not
included in the Work Group Investigation.
Incident Investigation Training
The SH&E Department will provide Incident Investigation Training to all
Management, First Line Supervision / Offshore Superintendents and/or any
designated individuals responsible for incident investigations. This training should
include incident investigation techniques, tools to be use (i.e. cameras, drawings,
etc.) during the investigation and Dynamic Industries, Inc. Incident Investigation
process / procedure to help ensure contributing factors and root causes that are
associated with the incident are appropriately identified and preventive actions /
recommendations are recommended and implemented to completion to prevent any
reoccurrence.

H2.8

Attachment 1

H2.9

MORENO GROUP LLC AND SUBSIDIARIES


WORK GROUP INVESTIGATION
EVERY EFFORT SHOULD BE MADE TO ACCURATELY AND COMPLETELY FILL OUT THIS DOCUMENT. ADDITIONAL
INFORMATION PERTINENT TO THE INVESTIGATION MAY BE AVAILABLE AT A LATER DATE; THEREFORE, THIS
DOCUMENT CANNOT BE CONSIDERED AS ALL INCLUSIVE.
Employees Name
Date/Time of Incident
Job Classification
Incident Site
Location of Incident (Be Specific)

Employees Supervisor

Date/Time Reported

INVESTIGATION TEAM MEMBERS (Print name legibly)


Supv.
2.
3.
INCIDENT INFORMATION

Investigation Date:

4.

7.

5.

8.

6.

9.

Incident Description (What happened and Where):

Witness(es):
Immediate corrective actions:

CONTRIBUTING FACTORS Did any of the following factors contribute to the Incident (Check Yes/No If
yes, explain)

Material, Equipment, Personal Protective Equipment and Environment: Yes

Training: Yes

No

Safety Systems: Yes

No

Human Factors/Ergonomics: Yes

Task Instructions: Yes

No

Rules and Procedures: Yes

Other: Yes

No

No

No

No

ROOT CAUSES

PREVENTIVE ACTIONS/RECOMMENDATIONS (Attach additional forms as necessary)


Preventive Actions/Recommendations

Person Responsible for


Completion

Target Completion
Date

1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.

YARD FOREMAN/OFFSHORE MANAGER REVIEW


SUPPLEMENTAL INVESTIGATION
REQUIRED (OSHA Days Away From Work Incident) ATTACH THIS FORM TO THE SUPPLEMENTAL
INVESTIGATION

NOT REQUIRED COMPLETE DISTRIBUTION

SIGN-OFF
Offshore Supt/Supervisor

Date:

Yard Foreman/Offshore Manager

Date:

Safety Manager/Safety Representative

Date:

Vice President

Date:

Attachment 2

H2.10

Moreno Group LLC and Subsidiaries Supplemental Investigation


INVESTIGATION TEAM MEMBERS (Print name legibly)
Chair.

Investigation Date:

4.

8.

1.

5.

9.

2.

6.

10.

3.

7.

11.

REVIEW OF WORK GROUP INVESTIGATION


SUPPLEMENTAL INCIDENT INFORMATION

SUPPLEMENTAL CONTRIBUTING FACTORS

SUPPLEMENTAL ROOT CAUSES

H2.10.a.1

ROOT CAUSES

PREVENTIVE ACTIONS/RECOMMENDATIONS (Attach additional forms as necessary)


Preventive Actions/Recommendations

Person Responsible for


Completion

1.
2.
3.
4.
5.

SIGN-OFF
INVESTIGATION TEAM MEMBERS:
1.

Date:

2.

Date:

3.

Date:

4.

Date:

5.

Date:

6.

Date:

7.

Date:

8.

Date:

9.

Date:

10.

Date:

H2.10.a.2

Target Completion
Date

Attachment 3

H2.11

Incident Investigation Employee / Witness Statement


Employee Name:
Employee Address:

Company:
Employee Supervisor:
Employee SSN:
Incident Date:
Incident Time:
Incident Location:
To the employee involved or the employee who witness the incident- Briefly explain in your own
words the circumstances that led to the incident occurring. Also include your involvement in the
incident. Your comments are important to help determine the causes of the accident and correct any
unsafe conditions. Thank you.

I have written the above statement and certify that it is true to the best of my knowledge.
Employee / Witness Signature:
Date of Signature:
Supervisors Signature:
Date of Signature:

H2.11.a.1

Moreno Group LLC


and Subsidiaries SH&E
Management System

Occupational Health
Program

Page 1 of 5
Original: 01/01/2001
Revised: 05/01/2008

Occupational Health Program


Purpose
The purpose of this program is to provide a systematic method for identifying,
evaluating and controlling workers exposures to harmful substances.
Scope
The scope of this program is to protect the health of personnel working at Moreno
Group LLC and Subsidiaries by preventing or minimizing exposures to harmful
substances. An Industrial Hygiene exposure assessment will be conducted. Based
on the assessment findings Moreno Group LLC and Subsidiaries will take the
appropriate corrective action to eliminate or reduce the amount of the known
exposure. Contract employees may also be included with respect to certain job
tasks: however, routine employee exposure monitoring for contract workers will be
the responsibility of the contractor.
Responsibilities
The Facility Manager or Offshore Manager or Designee is responsible for:
Providing the support and/or resources to the appropriate departments to
implement occupational health hazard assessments to identify occupational
health hazards and manage the hazards per this program.
The First Line Supervisor / Offshore Superintendent is responsible for:
Providing assistance and support to appropriate departments to conduct
occupational health hazard assessments
Implementing Safe Work Procedures outline in Moreno Group LLC and
Subsidiaries Safety, Health and Environmental programs to minimize
potential health exposure to employees
The Safety, Health and Environmental Department is responsible for:
Coordinating the applicable industrial hygiene monitoring.
Communicating industrial hygiene monitoring reports to employees involved
in monitoring.
Coordinating the applicable training
Coordinating applicable evaluations per this program
I1.1

The Human Resource Department is responsible for:


Maintaining employee records within employees medical record files.
Providing to an employee representative, access to medical records upon
written request to obtain employees medical records.
The Employee is responsible for:
Completing the necessary training as prescribed by the applicable regulatory
requirements.
Adhering to the requirements of this procedure and the safe work practices
outlined in Moreno Group LLC and Subsidiaries Safety, Health and
Environmental programs.
Requirements
The industrial hygiene hazard assessment is to identify, evaluate and control
employee exposures within Moreno Group LLC and Subsidiaries operations. The
Safety, Health and Environmental Department will oversee hazard assessment
activities to ensure workers are provided a safe and healthful work environment.
Material Safety Data Sheets (MSDSs), process flow diagrams and standard
operating procedures shall be reviewed during this assessment to fully evaluate the
potential for exposure. From experience it is known that the following list of harmful
substances may be associated with upstream exploration and production activities in
the Oil and Gas Industry and downstream operations:
- Noise

- NORM

- Lead

- H2S

- Heat/Cold exposure

- Silica

Should a Hazard Assessment identify a potential work place exposure, Moreno


Group LLC and Subsidiaries will conduct adequate sampling to statistically support
the data findings to reflect true personnel exposure. As a result of this data, Moreno
Group LLC and Subsidiaries will assess potential worker exposures Company wide
by developing an exposure profile for each target job. Exposure criteria as defined
by OSHA.

I1.2

In addition to specific exposure programs, Moreno Group LLC and Subsidiaries will
implement the following general programs:
- Hazard Communication

- Personal Protective Equipment

- Hearing Conservation

- Bloodborne Pathogens

- NORM

- Respiratory Protection

- Lead

- Asbestos

- H2S

- Benzene

An industrial hygiene hazard assessment will be conducted once every five years for
all facilities and shall be consistent with the hazard analysis requirements of the
companies Safety, Health and Environmental Policies. The results of these
assessments will be included into the facility hazard assessments in accordance
with the Moreno Group LLC and Subsidiaries Safety, Health and Environmental
Management System.
Exposure Control Measures
The measures to be utilized to control worker exposure will be determined by the
nature of the chemical or physical agents and the level of exposure identified by the
hazard assessment. The following outlines the various methods of control measures
(but not limited to) available to Moreno Group LLC and Subsidiaries to eliminate or
reduce the worker exposure time or the reduction of contaminant the worker is
exposed to.
Process or Material Changes
The substitution of a hazardous material for one that is less harmful to
health
Change or alteration of a process or operating procedure
Engineering Controls
Isolation or enclosure to reduce the number of employees exposed
Isolation or enclosure of a worker in a control booth or area
Wet methods to reduce the generation of dust
Local exhaust ventilation at the point of generation or dispersion of
contaminants
General or dilution ventilation
Shielding devices
I1.3

PPE Controls
Personal protective equipment
Good housekeeping and maintenance
Administrative Controls
Adjusting work schedules, rotating job assignments, etc.
Medical surveillance to detect evidence of exposures
Personnel Training
Training and education to supplement all the above
A combination of the methods may be necessary to effectively control the workers
exposure to the chemical or physical agents.
Management is responsible for
providing the needed training, facilities, equipment and products to provide the
worker with a safe and healthful work place.
Monitoring Plan
Moreno Group LLC and Subsidiaries will utilize one or more of the following methods
to assist them in the hazard assessment. The Moreno Group LLC and Subsidiaries
Occupational Health Programs and Management of Change process will determine
the frequency and timing of required monitoring.
Personal Personal monitoring is the measurement of worker specific exposure to a
potentially hazardous substance identified by each specific program and the
programs exposure profile for each target job. The monitor will be placed as close
as possible to the site at which the contaminant enters the body. For instance, when
sampling for noise the device will be place as close to the ear as possible. When
sampling for respirable contaminates the monitoring or capture device will be placed
as close to the workers breathing area as possible without affecting his comfort.
Environmental Environmental monitoring is used to monitor the concentrations of a
contaminant in a general area of the workplace as close to the worker as possible.
Biological Biological monitoring measures the changes in composition of body
fluid, tissues or expired air to detect the level of contaminant absorption. For
instance, Personnel placed in a lead exposure abatement program will have blood
analyzed for lead content.

I1.4

Medical Medical examinations are used to evaluate the physiological and


psychological response to a contaminant. These types of examinations may
include, medical and work history, x-rays, blood and urine tests, pulmonary function
tests, audiometric exams, vision etc.
Administrative
Employee Notification The Safety, Health and Environmental Department will be
responsible for notifying an employee as required by the specific Occupational
Health Program in which the employee may be covered under.
Medical Surveillance The Safety, Health and Environmental Department will be
responsible for identifying employees who shall be placed into a medical
surveillance program. The examination criteria shall be outlined in the specific
Occupational Health Program applicable.
Recordkeeping The results of all exposure monitoring and medical evaluations are
confidential and will be maintained in the employees medical file. This file shall be
located in the Human Resource Department. Access to these documents shall be
in accordance with 29 CFR 1910.1020 Access to Employee Exposure and Medical
Records.

I1.5

Moreno Group LLC and


Subsidiaries SH&E
Management System

Abrasive Blasting

Page: 1 of 12
Original: 01/01/2004
Revised: 04/15/2009

Abrasive Blasting
Purpose
The purpose of this procedure is to establish a formal process for blasting operations
and to give a basic outline of expectations and procedures.
Scope
This is intended to be a minimum standard for Moreno Group LLC and Subsidiaries
facilities for the safe work practices and procedures while performing abrasive
blasting.
The Facility / Site Manager / Offshore Manager or Designee is responsible for:
Provide the needed leadership, commitment, employee empowerment, and hold
personnel accountable for the implementation of this procedure.
Communicating to work force their commitment to the stopping of work, if any
unsafe condition or situation is present.
Auditing compliance with this procedure.
Being knowledgeable of the applicable safety and health regulations associated
with this program.
The First Line Supervisor / Offshore Superintendent is responsible for:
Understanding and complying with this procedure.
Ensuring that all employees are working safely while blasting operations are
being conducted and perform a pre-job check of all equipment and PPE before
work commences.
Conduct pre-job safety meetings and JSEAs with all affected personnel to
identify scope of work, associated job hazards involved, proper precautions for
work planned and PPE.
If scope of work changes, Stop All Work and relate information to all affected
personnel by means of safety meeting and JSEA.
Continually communicate employees responsibility to use their Stop Work
Authority.

I2.1

The Safety, Health and Environmental Department is responsible for:


Training or coordinating the training of managers, supervisors and hourly
employees on the Abrasive Blasting procedure.
Periodically auditing the quality of checklists, JSEAs and safety meeting forms
to ensure they reflect safe practices.
Periodic auditing of abrasive blasting operations to ensure that all applicable
precautions indicated on the JSEA are being implemented and that all safe work
practices are being followed.
Participating in pre-job safety meetings and JSEAs on a periodic basis to ensure
compliance.
Performing/coordinating IH monitoring as needed.
The Employee is responsible for:
Actively participating in the development and review of the Abrasive Blasting
program.
Performing pre-job check of all equipment and PPE to ensure that they are in a
safe condition.
Ensuring that all safe work practices are being implemented while performing
blasting tasks and report all incidents associated with blasting operations.
Employees are also responsible for using Stop Work Authority anytime a
condition arises that is potentially unsafe.
Completing assigned activities in a safe manner.
Advising their supervisor when the conditions or situations of the current task
changes.
Definitions
Abrasive Blasting - the forcible application of an abrasive to a surface by pneumatic
pressure, hydraulic pressure, or centrifugal force.
Abrasive Blasting Respirator - a continuous flow airline respirator constructed so that
it will cover the wearers head, neck, shoulders and upper torso to protect him from
rebounding abrasive.
Silicosis - is characterized by shortness of breath, fever and bluish skin. It could be
diagnosed as pulmonary edema (fluid in lungs), pneumonia or tuberculoses. Silica
dust causes severe fungal infections, to develop this condition could be fatal

I2.2

Requirements
The Abrasive Blasting program is to implement Safe Work Practices and controls
when working with abrasive blasting material and equipment. Exposure can be the
result of operations that are being performed with abrasive blasting and can include
the following:
1. Respiratory implications from improper use of personal protective equipment.
2. Exposure to affected employees in adjacent areas to those where abrasive
blasting tasks are being performed.
3. Hearing conservation when working with abrasive blasting equipment or
around areas where abrasive blasting operations are being conducted.
4. Risk of injury from malfunctioning of blasting equipment or from improper
maintenance of such, or as the result of blasting operations.
5. Exposure to substances such as lead on painted material that is blasted.
The Painting and Blasting Foreman is responsible for the implementation and
enforcement of this procedure, as well as other procedures that pertain to the scope
of work being performed.
The SH&E Department shall assist in routine auditing of the procedure and
implementation of the procedure to ensure that the procedure is being complied
with.
Employees performing work must comply with the provisions of this procedure as
per training and instructions received, and wear all protective equipment required.
Hazards
A respiratory hazard, called silicosis, is the prevalent hazard. There are 3 types of
silicosis:
1. Chronic/classic: The most common, usually occurring after 10 years of
exposure to low concentrations. Symptoms may or may not be obvious.
Some symptoms in late stages of silicosis may include fatigue, shortness of
breath, chest pain or respiratory failure.
2. Accelerated silicosis: Can occur after only 5-10 years of high exposure to
respirable crystalline silica.
3. Acute silicosis: Occurs after a few weeks to a few years following exposure to
extremely high concentrations of crystalline silica.
Exposure occurs during many different construction activities. The most severe
exposures have occurred during abrasive blasting with sand to remove paint and
rust from surfaces. Silica dust causes severe fungal infections to develop; this
condition could be fatal.
I2.3

Methods of Compliance
Methods of compliance that reduce or eliminate the risk of exposure include
Engineering Controls, Administrative Controls, Safe Work Practices and Training.
Engineering Controls
Engineering Controls, methods of isolating or removing a hazard from the
workplace, are one of the most effective methods of hazard reduction. Engineering
controls will be utilized to eliminate and / or reduce the exposures of respiratory
hazards associated with abrasive blasting below the PEL. Examples of the
engineering controls to be utilized is:
Ventilation
Containing of area utilizing screens or heavy canvas
The use of alternative blast media
Recovery Systems
Blasting Rooms or cabinets
Deadman controls on airlines.
Personal and area air sampling will be performed per Moreno Group LLC and
Subsidiaries Occupational Health section of this manual. Air monitoring results
should confirm that the engineering controls, administrative controls, Safe Work
Practices and Personal Protective Equipment being utilized are protecting the
employee from hazards related to abrasive blasting. Should air monitoring results
indicate the hazards are not controlled under the NIOSH PEL, the abrasive blasting
process will be stopped until appropriate controls are reevaluated and implemented.
The following minimum Personal Protective Equipment shall be worn at all times
during the abrasive blasting process:
Respiratory Protection (Supplied-Air Respirator helmet or bullet hood with
inner shield)
Hearing Protection
Gloves (leather)
Steel toed shoes
When needed, Tyvek Suit to be worn over work clothes

I2.4

The main type of respiratory protection for personnel using blast equipment will be a
Supplied-Air Respirator (SAR) otherwise known as a helmet or bullet hood. This
protects the user by protecting his head, respiration, neck, and shoulders. The
regulator is carried on the waist normally, using a belt clip. The hood constantly
blows breathing air on the user, which keeps the hood at a slight positive pressure
above ambient atmospheric pressure. This pressure will prevent contaminants from
entering the hood, since air is escaping out.
The air used for Supplied Air Respirators shall be of Grade D breathing air, which is
air of high purity. Grade D breathing air must meet the following standards:
Oxygen 19.5%-23.5%
Hydrocarbons - 5 mg per cubic meter or less
Carbon Monoxide - 10ppm or less
Carbon Dioxide - 1000ppm or less
Lack of noticeable odor
Suitable in-line air purifying sorbent beds and filters shall be used to ensure
breathing air quality. Sorbent beds and filters shall be maintained and replaced or
refurbished periodically following the manufactures recommendations.
If oil lubricated compressor is providing air to the airline respirator, the following
conditions shall be confirmed:
High temperature or carbon monoxide alarm or both, to monitor carbon
monoxide levels. If only high temperature alarms are used, the air supply
shall be monitored at intervals (i.e. at least daily) sufficient to prevent carbon
monoxide in the breathing air from exceeding 10 ppm.
Air lines and fittings that supply respirable air shall not be interchangeable to other
services.
All respirators shall be cleaned in warm water with a mild detergent or with a cleaner
recommended by the manufacturer and properly stored after each use.
Administrative Controls
Administrative controls will be utilized when the Facility Manager or designee
determines or is advised that engineering controls are not providing adequate
protection. Administrative controls can consist of the following:
Scheduling of the abrasive blasting process
Rotating Job Assignments
Medical Surveillance
I2.5

Medical Surveillance
All employees who run the risk of coming in contact with airborne silica dust will go
through the following procedures:
Pre-employment physical with a physician. This will include a medical &
occupational history to collect data on a workers past exposure.
Pulmonary function test (PFT) and evaluation by medical personnel for preemployment and annually there after.
Respirator Protection Questionnaires to be filled out be employees and
evaluated by medical personnel.
Chest X-rays for pre-employment physical and every three (3) years there
after.
Quantitative or Qualitative fit test to assess the adequacy of respirator fit preemployment and annually there after. Note: all personnel taking either fit
test must be clean-shaven!
More frequent examinations may be necessary for workers at risk or acute or
accelerated silicosis. Exams should include at least the following:
Medical and Occupation history to collect data on worker exposure
Chest X-ray
Pulmonary Function Testing
Annual Evaluation for Tuberculosis
The utilization of personal air monitoring and medical evaluations by the Company
Physician will determine if more frequent examinations should be conducted.
Anytime an employee is diagnosed with silicosis, the State Health Department and
OSHA will be notified. All cases of silicosis are recordable under the OSHA
Recordkeeping guidelines.
Safe Work Practices
Methods that reduce the exposure during a task or procedure will be used to
minimize exposure. All employees who have the potential of coming in contact with
blasting operations shall follow the following Safe Work Practices:
Know which work operations can lead to silica exposure. Signage will be
utilized to identify these areas within the facility.
I2.6

Employees should employ the use of hand-washing and hygiene facilities


before eating, drinking or smoking and after a job has been completed.
Do not eat, drink, use tobacco, products, or apply cosmetics in areas where
there is dust containing crystalline silica.
Wash hands and face before eating, drinking, smoking, or applying cosmetics
outside of the exposure area.
If possible, change into disposable or washable work clothes at the worksite;
shower (where available) and change into clean clothing before leaving the
worksite.
All PPE should be thoroughly cleaned or disposed of, if applicable.
Attachment 1)

(see

Areas adjacent to blasting operations shall be properly protected with the use
of sand screens to prevent emissions to areas other than blasting areas.
Tarps or screens should be installed whenever airborne emissions become
an irritant to adjacent work areas where employees are working, or where
there is a safety issue, as in blasting on lead painted surfaces. Tarps or
screens that are installed on lead painted structures that will be blasted will be
approved by the SH&E Department prior to any blasting activities beginning.
Employees shall follow the procedure for hooking up blast hoses. (See
Attachment 2)
Housekeeping
Good housekeeping involves a regular schedule of housekeeping activities to
remove accumulations of dust and debris. The schedule should be adapted to
exposure conditions at a particular worksite.
Supervision
Good supervision is another important work practice. It provides needed
support for ensuring that workers follow proper work practices. By directing a
worker to position the exhaust hood properly or to improve work practice, a
supervisor can do much to minimize unnecessary employee exposure to
airborne contaminants.
Various types of blasting media may be used, depending on client
specifications. Precautions should be made with each media type and safe
work practices implemented as such.
Material safety data sheets are to be referenced for each blasting media to be
utilized and all appropriate precautions should be taken as indicated in data
sheets regarding safety, health and environmental concerns.
I2.7

Blasting nozzles are equipped with dead-man controls to allow the operator to
start and stop blasting with one hand.
Dead-man controls shall never be taped or wired open. This would not allow
the operator to shut down blasting rapidly, should the need occur.
Pressure pots (i.e. sand pots) shall meet the most current ASME Boiler and
Pressure Vessel Code requirements
Pressure pots shall have all associated equipment (i.e. locking valves,
gauges, etc) identified within attachment 2.
Energy Isolation Procedures (i.e. Lockout / Tagout) shall be followed prior and
during the loading of all pressure pots (i.e. sand pots). Only the Offshore
Superintendent or designated Foreman shall open sand pots.
Machines, hoses and equipment (i.e. deadman controls, sand pots, etc.) must
be inspected daily with deficiencies logged down. Defective equipment must
be replaced immediately before work is resumed.
All hoses shall have safety pins and whipchecks on the connectors to prevent
inadvertent disconnection.
Never adjust nozzle with the abrasive flowing.
Respirators shall be inspected before each use and during cleaning, and shall
be cleaned after each use. Respirator inspection shall include the following:
o Check for function, tightness of connections, and the condition of the
different parts including, but not limited to, the face piece, head straps,
valves, connection tube, cartridges, and filters.
o Check plastic and rubber parts for pliability and signs of deterioration.
o All inspections shall be done per manufacturers specifications.
o If using respirators, do not alter the respirator in any way.
All areas that are adjacent to blasting operations shall be properly guarded
against sand emissions by the use of blasting screens or tarpaulin. No
blasting shall be conducted until all areas are appropriately guarded and all
areas are protected.
All vehicles should be parked in designated areas and not within
contaminated areas.
The SH&E Department shall make final approval prior to blasting on surfaces
that contain lead based paint.
I2.8

Training
All employees subject to potential silica exposures shall be provided information
about adverse health effects, work practices, Hazard Communication, Safe Work
Practices and use and care of personal protective equipment. The following training
topics will perform as part of Moreno Group LLC and Subsidiaries New Employee
Orientation / SH&E Training and as needed there after:
Signs and Symptoms of silicosis
Hazards associated with abrasive blasting.
Methods and equipment used for personnel protection including respiratory
protection.
Safe Work Practices to be utilized for abrasive blasting operations.
Personal hygiene practices associated with blasting operations.
Inspection, care, proper use and storage of personal protective equipment
and respiratory equipment.

I2.9

Attachment 1

I2.10

I2.10.a.1

Attachment 2

I2.11

PROCEDURE FOR HOOKING UP


BLAST HOSE AND TWIN LINE
The following is a procedure for hooking up the blast hose and the twin lines to prevent twin lines from getting
crossed over to another blast hose.
1) Each section of blast hose will be laid out with its twin lines. The blast hose and twin lines will be
taped together.
2) When connecting sections of blast hose and twin lines, the blast hose will have a safety pin in the
crowfoot connection and a whip check will be installed on both ends of the blast hose connections.
3) A deadman is connected to the end of the twin line once the needed length of blast hose and twin
lines has been connected together. Note: The twin line that connects to the deadman MUST have a
safety shutoff valve in the Supply Air line.(Refer to Picture 1)

Safety Shutoff Valve

Deadman

Picture 1
4) When connecting the twin lines to the control valves on the sand pot a qualified employee will connect
the Supply Airline of the twin lines to the Supply Air Fitting on the control valve of the sand pot.
(Refer to picture 2)

Supply Air Fitting

to deadman

Picture 2
5) The Return Airline coming from the deadman to the control valve on the sand pot will not be
hooked up to the control valve on the sand pot at this time.
6) The qualified employee will open the valve to supply air to the control valves. He will hold the return
airline and have the blaster activate the deadman. If air comes out of the return line then he will
have the blaster release the deadman. This verifies that this twin line is connected to the correct
deadman. (refer to picture 3)
I2.11.a.1

Valve to supply air


to the control valves

Picture 3
7) The qualified employee will connect the return airline to the pilot valve. (refer to picture 4)

Pilot Valve for the


return airline from
the deadman

Picture 4

8) The qualified employee will then label the control valve. Labeling can be color tape, duct tape labeled with a
number or duct tape with the blasters name. The blaster will label the deadman the same as the control valve
on the sand pot. (Refer to picture 5 &6)

Picture 5

I2.11.a.2

Picture 6

Attachment 3

I2.12

Revised Abrasive Pot Illustration


Never Open Hatch Cover on Top of Pot Without Reviewing all
JSEAs & DII Policies & Procedures Required for Job Task.
Top Hatch & Cam Lock Assembly Beneath Cam
Lock Lid (Insure that the Vessel is not pressurized
prior to Releasing Cam Locks.

Lower Rack &


Insert Pins
Before Travel
Primary Bleed
Off Valve. 1
Locking Ball
Valve. Apollo
Part # 70-106-01
Manufacturer
(Conbraco Ind.,
Inc.) Lock Out /
Tag Out
hardware
Required.
Ventura Bleed
Off to eliminate
ice plugging.
Inspection
Plate

Aluminum
Cam Lock Lid
Lock Out
Device

Pressure Relief
Valve, Secondary
Pressure Gauge,
Secondary Bleed
Off Valve

Primary
Pressure
Gauge
Auto Air
Valve Pilot
Valve 1
Choke Valve

1 Ball Valves
Thompsons
Valves

Insert Pin before


travel & Removal

Air Inlet, 2 Locking Ball


Valve Apollo Part # 70-108-01
Manufacturer (Conbraco Ind.,
Inc.
Lock Out / Tag Out Hardware
Required!

I2.12.a.1

Moreno Group LLC


and Subsidiaries SH&E
Management System

Aluminum Protection

Page: 1 of 10
Original: 01/12/2005
Revised: 05/01/2008

Aluminum Protection
Purpose
The purpose of this program is to establish and implement practices and procedures
for protecting the health of Moreno Group LLC and Subsidiaries employees who
may be exposed to aluminum on the job. This program also establishes methods for
complying with the OSHA Construction Industry Air Contaminants, 29 CFR
1910.1000.
Scope
The scope of this program applies to all Moreno Group LLC and Subsidiaries
projects and employees involved with aluminum construction projects and activities.
This program also applies to all subcontractors, working under the direct control of
Moreno Group LLC and Subsidiaries, involved with aluminum construction projects
and activities. Subcontractors must provide all manpower, supplies, equipment,
training, and medical examination and testing necessary to comply with this
program.
Responsibilities
The Facility Manager / Yard Foreman or designee is responsible for:
Informing the SH&E Department of the any upcoming project that may have
the potential of containing aluminum exposure.
Inform any subcontractors that may be working on the project that aluminum
exposure may be possible.
Ensure that subcontractors understand and comply with this policy.
The First Line Supervisor is responsible for
Understanding and complying with this policy / procedure.
Designating employees for the project and ensuring that a list of employees is
provided to the SH&E Department to report to the Medical Review Officer to
be placed in a medical surveillance program and receive all necessary
surveillance prior to job commencing, such as Pulmonary Function Testing
and questionnaire, as well as chest X-rays.

I3.1

Coordinate with the SH&E Department to see if all designated


employees have received aluminum training and / or up to date. If
training is needed, coordinate with the SH&E Department date and
time for which training will take place.
Ensuring that barricade and applicable warning signs have been
posted prior to the startup of the project.
Ensuring that all safety measures are being followed throughout the
project.
Performing with and without the SH&E Department a pre-job
inspection and continuous monitoring of jobsite to ensure that all safe
work practices are being done.
Coordinating with the SH&E Department at the end of the project or
when any employee is removed from the project that those employees
all go to the Medical Review Officer and receive chest X-rays.
The Safety, Health and Environmental Department is responsible for
Coordinating with First Line Supervisor to determine which projects
and employees will be working with aluminum and have potential
exposure.
Perform any training, such as respiratory training and fit testing, as well
as pre-job aluminum training, for all employees that need this training.
Coordinating and performing any air monitoring which may be
required, as well as coordinating any medical surveillance needed with
the Human Resources Department.
Daily audit jobsites, along with First Line Supervisors, to ensure
compliance with this procedure.
Scheduling of third party air monitoring and notifying personnel of
monitoring results.
The Human Resources Department is responsible for
Authorizing all employees to go to the Medical Review Officer and
receive any medical surveillance that is needed for aluminum projects.
Maintaining all medical records for all employees that will work on the
project.

I3.2

Informing the SH&E Department of any employee that is unsuitable to


work on the project due to problems with chest X-rays or medical
conditions that do not allow employee to wear a respirator.
Authorizing all employees to return to the Medical Review Officer for a
follow-up medical surveillance once project is complete or if employee
has been removed from the project.
The Employee is responsible for
Understanding and complying with this policy/procedure.
Immediately reporting to his immediate supervisor any problem, which
may arise, or any symptoms of aluminum exposure.
DEFINITIONS
8-hour TWA Concentration - 8-hour Time-Weighted Average concentrations
for airborne contaminants - common units for reporting daily airborne
aluminum exposures. This is the aluminum exposure received per day
expressed as a constant exposure for eight (8) hours at a steady state
concentration.
Aluminum - Aluminum is the most abundant metal and the third most
abundant element, after oxygen and silicon, in the earths crust. It is widely
distributed and constitutes approximately 8 percent of the earths surface
layer. However, aluminum is a very reactive element and is never found as
the free metal in nature. It is found combined with other elements, most
commonly with oxygen, silicon, and fluorine. Aluminum metal is light in
weight and silvery-white in appearance. Since pure aluminum is very soft,
aluminum is often mixed with small amounts of other metals to form aluminum
alloys, which are stronger and harder.
Competent Person - One who is capable of identifying existing and
predictable aluminum hazards in the surroundings or working condition and
who has authorization to take prompt corrective measures to eliminate them.
HEPA filter - High Efficiency Particular Air filter - Filters that remove 99.97%
of all particulate 0.3 microns or greater in diameter.
mg/m - Milligrams per cubic meter of air.
airborne concentration of aluminum.

Common units for reporting

NIOSH/MSHA - National Institute of Occupational Safety and Health/Mine


Safety and Health Administration - Federal agencies which conduct research
on safety and health issues and test and certify respirators.

I3.3

PEL - OSHA requires employers of workers who are occupationally exposed


to aluminum to institute engineering controls and work practices to reduce
and maintain employee exposure at or below permissible exposure limits
(PEL's). The employer must use engineering and work practice controls, if
feasible, to reduce exposures to or below an 8-hour time-weighted average
(TWA) of 15 mg/m for total aluminum or 5 mg/m for respirable fractions.
REQUIREMENTS
PERMISSIBLE EXPOSURE LIMIT
The Permissible Exposure Limit (PEL) for airborne aluminum exposure is
fifteen (15) mg/m , as an 8-hour TWA concentration. This is the maximum 8hour average concentration of total aluminum that an employee may be
exposed to during each work day.
Whenever workers airborne total aluminum exposures exceed or are
expected to exceed the PEL, the following will be implemented for the work
project:
Competent person
Employee information and training
Employee medical surveillance
Airborne respirable aluminum exposure monitoring
Record keeping
PPE / Housekeeping
No employee will be exposed to airborne aluminum above the PEL without
proper protection.
The following methods will be used, as feasible and effective, for maintaining
airborne aluminum exposures below the PEL:
Engineering controls, such as general area ventilation for
containments, local exhaust ventilation for spot removal, vacuum
blasting or vacuum equipped power tools. When ventilation for
containments is used, manometers and/or velometers, will be used to
evaluate the mechanical performance of the ventilation system
Warning signs
Hygiene facilities and practices

I3.4

Protective work clothing and equipment


Respiratory protection
Housekeeping
During the period that respirators are worn, the protection factor of the
specific respirator may be used to determine employees exposure to
airborne aluminum and to achieve compliance with the PEL.
COMPETENT PERSON
All work activities where employee airborne aluminum exposures may exceed
the PEL will include a competent person in both the planning and performing
stages of projects involving aluminum exposure.
The competent person will be a person with training and experience in
conducting jobs involving airborne aluminum exposure. The competent
person will have the capability of identifying hazards and the authority to take
immediate action to eliminate them.
The competent person will be at the work site at all times while airborne
aluminum exposure activities are in progress. They may have other job
duties, but must be able to monitor work continuously for hazards or
deficiencies, and the authority to take immediate corrective action.
EMPLOYEE INFORMATION AND TRAINING
All employees who work on projects where airborne aluminum exposures are
known to or expected to be at or above the PEL will be provided information
and training on the hazards of airborne aluminum and measures for
controlling these hazards and protecting health.
Employees will receive initial comprehensive airborne aluminum training
before performing work that may involve airborne lead exposure. This
training will be repeated annually as a refresher course.
The content of airborne aluminum training will include:
The specific nature of activities or operations that may result in
airborne aluminum exposure above the Action Level
The health effects and risks of airborne aluminum exposure
OSHA standards and guidelines for airborne aluminum exposure
Engineering controls, including containments and ventilation systems

I3.5

Work practices for controlling airborne aluminum exposure, including


information, warning signs, housekeeping, protective clothing and
proper hygiene facilities and practices
Respiratory protection for controlling airborne aluminum
including fit testing
Methods for monitoring airborne aluminum
exposures

exposure,

concentrations and

The medical surveillance program including medical removal


When conducting airborne aluminum exposure activities on a multi-employer
work site, Moreno Group LLC and Subsidiaries will notify other employers of
the nature of the aluminum exposure system in effect, and the potential need
to take measures to protect their employees. Notification to other employers
will contain the following:
NOTICE - MORENO GROUP LLC AND
SUBSIDIARIES IS PERFORMING ACTIVITIES AT THIS JOB SITE THAT
MAY CREATE AIRBORNE ALUMINUM . ALL CONTRACTORS AT THIS
JOB SITE SHALL REMAIN CLEAR OF ANY ALUMINUM EXPOSURE
AREA. ACCESS INTO ALUMINUM EXPOSURE AREA IS CONTROLLED
BY THE MORENO GROUP LLC AND SUBSIDIARIES JOB FOREMAN.
ONLY TRAINED, QUALIFIED WORKERS ARE PERMITTED TO ENTER
ALUMINUM EXPOSURE AREAS AND MUST WEAR RESPIRATORS AND
PROTECTIVE CLOTHING.
MEDICAL SURVEILLANCE
All employees who may be exposed to airborne aluminum above the PEL or
who may be required to wear a respirator will be provided initial and periodic
medical examinations.
All employees who may be exposed to airborne aluminum above the PEL will
be provided with initial and periodic biological monitoring in the form of blood
sampling and analysis of aluminum. Employees will be tested both pre and
post-job to determine blood serum amounts of aluminum and to ensure that
levels are below twenty-four (24) micrograms/cubic meter.
All employees who are temporarily removed from aluminum exposure due to
elevated blood aluminum levels or at the recommendation of a physician may
be reassigned other job duties at the site that do not involve exposure to
airborne aluminum above the PEL.
Chest X-rays will be performed on all employees that are required to work on
aluminum projects to ensure lung capacity in performing these tasks. Chest
X-rays will be performed on all employees both pre and post-job.

I3.6

WARNING SIGNS
Warning signs will be posted in the work area around activities where
airborne aluminum exposures may exceed the PEL. The work area can be
demarcated by Yellow Caution tape.
Signs will be posted at every accessible side of the work area. These signs
will be easily visible from a distance so that employee can read the sign and
take necessary protective measures before entering the work area. Signs will
read as follows: WARNING, ALUMINUM WORK AREA.
The competent person will control access of persons into work area.
All persons entering work areas will wear protective clothing and respirators.
Eating, drinking, smoking, and chewing is prohibited in work areas and any
area where airborne aluminum exposure may exceed the PEL.
CONTAINMENTS
Where required by federal, state, or local regulation, the project sponsor, or
the project owner, containments will be constructed and used as specified.
The purpose of containments is to restrict or prevent the spread of airborne
aluminum or debris to surrounding areas or the environment. While the
proper use of containments can help protect the public and the environment,
they generally cause a significant increase in airborne aluminum
concentrations in the work area. Containments may increase the potential for
higher employee aluminum exposures. Therefore, the use of well designed
exhaust ventilation and the use of more protective respirators may be
necessary to properly protect workers.
Containments may include any of the following:
Rigid or flexible barriers or sheets surrounding the work area
Complete unventilated enclosures built around the work area
Complete enclosures maintained under negative pressure by exhaust
ventilation with exhaust air filtration
Containments may also require the construction and use of platforms or
scaffolding. These may be stationary or movable, ground supported or
suspended.

I3.7

PERSONAL HYGIENE PRACTICES


All employees whose airborne aluminum exposures may exceed the
Permissible Exposure Limit will, at a minimum wash, their hands and face
before breaks, at lunch and at the end of each work shift.
An adequate number of clean lavatory and hand washing facilities will be
provided. These will comply with the OSHA Standard, 29 CFR 1926.51,
Sanitation.
PROTECTIVE CLOTHING AND EQUIPMENT
Protective clothing and equipment will be worn by all employees whose
airborne aluminum exposures may exceed the Permissible Exposure Limit.
Protective clothing and equipment will be provided at no cost to the
employee.
Protective clothing will include disposable full body coveralls.
Other
protective equipment will include faceshields, hats, gloves, shoes or
disposable shoe covers, eye protection, and hearing protection as
appropriate.
Disposable protective clothing will be used for no more than one (1) work day.
They will be disposed of properly. Protective clothing and equipment will be
worn by all employees performing the following activities where aluminum
emissions are present unless exposure monitoring proves otherwise: When
abrasive blasting, cleanup of expendable abrasives, abrasive blasting
enclosure construction, movement and removal, power tool cleaning with and
without dust collection systems, manual scraping, manual sanding, manual
demolition of structures, heat gun applications, welding, cutting, torch burning,
chemical stripping and lead contamination/emergency clean-up activities.
All employees involved in welding on aluminum structures will be required to
wear long sleeved shirts, chaps, neck protection, etc. to prevent exposure to
ultraviolet radiation and prevention of flash-burns from welding arc. Two
forms of eye protection (glasses and faceshield / welding shield) will be
required during any cutting or welding operations. Additionally, hand
protection will be worn at all times to prevent burns, cuts, etc.
RESPIRATORY PROTECTION
Respiratory protection will be used in combination with engineering controls
and work practices to maintain employee airborne aluminum exposures below
the Permissible Exposure Limit.
Respirators will be worn by all employees, other contractors, inspectors, or
observers who may be exposed to airborne aluminum at or above the
Permissible Exposure Limit.

I3.8

The selection, use, maintenance, and inspection of respirators will be


according to Moreno Group LLC and Subsidiaries Respiratory Protection
Program. Qualifications for respirator users are also contained in this
program. Below is the type of respirator that will be utilized when aluminum
exposure is above the Permissible Exposure Limit:
3M 6000 Series face respirator w/ P100 particulate filters
P95 particulate irritant facemask
In additional to respiratory protection, Moreno Group LLC and Subsidiaries
will implement both general and specific ventilation to ensure that all
exposure is minimized while employees are working on aluminum structures.
Ventilation will be setup as to not impact surrounding areas and in such a
manner to adequately ventilate the work area to exposures below PEL, if
possible. If ventilation fails to achieve the goal of lowering exposure to below
PEL, respiratory protection will be implemented, as well as continuous
ventilation.
EXPOSURE MONITORING
For each work project, personal air samples will be collected to determine
airborne aluminum exposures to employees performing tasks involving
aluminum exposure. Full shift (at least 7 hours) air samples will be collected
for each job classification in each work area. The air samples will be taken
for the shift with the highest expected exposure level. Moreno Group LLC
and Subsidiaries will implement employee protective measures until results
of the employee exposure assessment are received. The competent person
will be responsible to ensure that exposure monitoring is performed.
Where initial monitoring indicates that aluminum exposures are below the
PEL, and where work activities and conditions will remain the same as at the
time of initial sampling, additional monitoring need not be repeated for that
work project. A written record of the air monitoring data will be kept at the job
site.
Where initial monitoring indicates that airborne aluminum exposures are
below the PEL, additional representative exposure monitoring will be
conducted at least once every six (6) months for that work project. Where
initial monitoring indicates that aluminum exposures are above the PEL,
additional representative exposure monitoring will be conducted at least once
every three (3) months. Representative monitoring should be conducted
during the beginning of each different phase of the project or when changes
occur to determine range or exposures for aluminum removal and clean-up
activities.
All air samples will be collected and analyzed according to NIOSH 7082
Method or equivalent. All samples will be analyzed by laboratories accredited

I3.9

under the Laboratory Accreditation Program of the American Industrial


Hygiene Association for metals analysis.
All exposed employees will be notified in writing of the monitoring results
within five (5) days after receiving these results.
Initial exposure monitoring may not be required when previously collected
data has conclusively determined that current job condition exposure levels
will be less than the PEL.
HOUSEKEEPING
Accumulations of aluminum-containing dust and debris generated by work
activities will be removed and cleaned daily.
All persons doing the clean-up will be trained in performing aluminum
activities, respirator qualified, and participate in the medical surveillance
program. Respirators and protective clothing will be worn by all persons
doing the cleanup unless exposure monitoring proves otherwise.
Wherever feasible, HEPA-filtered vacuum cleaners will be used for
housekeeping.
All aluminum-containing dust and debris will be collected into sealed
containers. The waste will be tested to determine whether it will be disposed
as hazardous or non-hazardous waste.
RECORDKEEPING
All records relating to training, medical examinations, blood aluminum
monitoring, exposure monitoring, and project specific requirements will be
maintained by Moreno Group LLC and Subsidiaries, for the employees length
of employment plus 30 years.
OTHER RELEVANT INFORMATION
The compliance program will be kept available at the work site for
examination by an affected employee or authorized person/agency.
The compliance program will be revised and updated at least annually.

I3.10

Moreno Group LLC


and Subsidiaries SH&E
Management System

Asbestos

Page: 1 of 18
Original: 01/01/2008
Revised: 06/01/2009

Asbestos Program
Purpose
The purpose of this program is to provide for Moreno Group LLC and Subsidiaries
employees and contractors an acceptable method for managing an environment that
shows potential for employee exposure to asbestos that is at or above the Permitted
Exposure Level. (PEL)
Scope
The scope of this document will be to describe methods of eliminating or
minimizing exposures to Asbestos by the following methods:
Asbestos Identification,
Engineering Controls and Procedures,
Personal Protective Equipment (PPE),
Employee Training Requirements,
Employee Medical Requirements,
Administrative Control.

Moreno Group LLC and Subsidiaries will make every reasonable effort to ensure
that no employee is exposed to an airborne concentration of asbestos in excess of
the current PEL, but provides contingency for exposure that includes, at a minimum,
medical surveillance.
This program applies to all work where one of our employees may be occupationally
exposed to asbestos. All work related to abatement, construction, alteration, or
repair, including painting and decorating, during the removal of Asbestos Containing
Material (ACM) within dry walls, insulation, floor tile, etc. The Moreno Group LLC
and Subsidiaries, Facility Manager is responsible for its implementation, and copies
of this written program may be obtained from this person.

I4.1

Responsibilities
The Facility Manager / Site Manager or Designee is responsible for:
Understand and comply with the requirements of this procedure. Ensure that
personnel with potential for exposure to asbestos are placed into any
mandated medical surveillance program

Ensure that all work activities and documentation of this program are
maintained on site, during the course of activities that have potential to
precipitate employee possible exposure to asbestos.
Ensure that personnel performing asbestos monitoring are qualified to do so,
and are adequately trained to the degree that monitoring results can be
considered reasonably accurate.
Audit compliance with the procedure.
The First Line Supervisor or Designee is responsible for:
Understand and comply with the procedure.
Confer with Facility/Site Mgr., SH&E Dept., or Designee as to any potential or
suspected asbestos exposure.
Ensure that personnel assigned to tasks that involve potential asbestos
exposure are placed into any mandated medical surveillance program that is
appropriate for asbestos
Ensure that employees performing tasks with potential for asbestos exposure
are adhering to all rules set out in the Job Safety and Environmental Analysis
(JSEA), including use of all appropriate PPE.
Make suggestions to Management and/or other appropriate individuals
concerning improved asbestos management techniques or procedures.
Initiate resolution of any situation in which an employee has exercised his/her
Stop Work Authority.
The SH&E Department or designee is responsible for:
Understand and comply with procedure.
Coordinate and conduct (or cause to be conducted) all asbestos related
training, (to include, but not limited to) all elements of appropriate Respiratory
Protection Program.

I.4.2

Coordinate placement of employees into any mandated Medical Surveillance


Program as per OSHA Standard, or Company Physician recommendation.
Coordinate training on Instrumentation and Procedure for all relevant aspects
of our asbestos monitoring program.
Make suggestions to Management and/or other appropriate individuals
concerning improved asbestos management techniques or procedures.
Provide to HR Dept. any Personal Monitoring Result that is considered to be
a potential for exposure, for placement into employees medical file.
Provide to employee written notification of his/her asbestos exposure.
The Human Resource Department or designee is responsible for:
Understand and comply with procedure
.
Maintain records of employees exposures, and subsequent medical
examinations performed by Moreno Group LLC and Subsidiaries Approved
Physicians.
Assist in placement of employees, who are required to do so, into a medical
surveillance program that is appropriate for possible asbestos exposure.
The Employee is responsible for:
Understand and comply with this procedure.
Understand that Stop Work Authority is their duty should they observe an
unsafe condition or activity, and that the Stop Work Authority will not be
overridden until such time that the problem(s) have been remediated, or until
such time that supervision determines that the condition or activity is not
unsafe.
Abide to all posted signs and labels identifying Asbestos Containing Material
and / or Presumed Asbestos Containing Material and do not disturb this
material unless authorized by a Competent Person and trained to do so.
Understand and follow all task specific Job Safety and Environmental
Analysis (JSEA) evaluations, including use of all required PPE.
Notify their supervisor immediately should they observe a condition that may
lead to an exposure to asbestos.

I4.3

The Host Facility is responsible for:


Host facilities are responsible for posting warning signs and labels on vessels,
lines, bulkheads, or other fixtures that contain or are otherwise associated
with asbestos.
Responsible for providing a site-specific Training/Orientation.
Definitions
Acute effect means an adverse effect on the human body with symptoms of
high severity coming quickly to a crisis. Acute effects are normally the result
of short-term exposures and short duration.
Acute exposure means a single exposure to a toxic substance that result in
severe biological harm or death. Acute exposures are usually characterized
as lasting no longer than a day.
Asbestos includes chrysotile, amosite, crocidolite, tremolite asbestos,
anthophyllite asbestos, actinolite asbestos, and any of these minerals that
have been chemically treated and/or altered.
Asbestos-containing material (ACM) means any material containing more
than 1% asbestos.
Assistant Secretary means the Assistant Secretary of Labor for
Occupational Safety and Health, U.S. Department of Labor, or designee.
Authorized person means any person authorized by the employer and
required by work duties to be present in regulated areas.
Building/facility owner is the legal entity, including a lessee, which
exercises control over management and record keeping functions relating to a
building and/or facility in which activities covered by this standard take place.
Certified Industrial Hygienist (CIH) means one certified in the practice of
industrial hygiene by the American Board of Industrial Hygiene.
Chronic means an adverse effect on the human body with symptoms that
develop slowly over a long period of time or that frequently recur. Chronic
effects are the result of long-term exposure and are of long duration. Chronic
health concerns include lung cancer, asbestosis, mesothelioma and cancer to
the stomach and colon.
Competent Person is a person who is capable of identifying existing
exposure hazards in the workplace, and selecting appropriate control
strategy(s) to address them, and who has authority to take prompt corrective
measures to eliminate them.
I.4.4

Director means the Director of the National Institute for Occupational Safety
and Health, U.S. Department of Health and Human Services, or designee.
Employee exposure means that exposure to airborne asbestos that would
occur if the employee were not using respiratory protective equipment.
Exposure to asbestos has shown but may lead to but not limited to lung
cancer, asbestosis, mesothelioma, and cancer of the stomach and colon.
Fiber means a particulate form of asbestos 5 micrometers or longer, with a
length-to-diameter ratio of at least 3 to 1.
Friable means material that can be crumbled with hand pressure and is
therefore likely to emit fibers.
High-efficiency particulate air (HEPA) filter means a filter capable of
trapping and retaining at least 99.97 percent of 0.3 micrometer diameter
mono-disperse particles.
Homogeneous area means an area of surfacing material or thermal system
insulation that is uniform in color and texture.
Industrial hygienist means a professional qualified by education, training,
and experience to anticipate, recognize, evaluate and develop controls for
occupational health hazards.
Non-Friable means a material that generally does not emit airborne fibers
unless subjected to sanding or sawing operations.
PACM means presumed asbestos containing material.
Presumed asbestos containing material means thermal system insulation
and surfacing material found in buildings constructed no later than 1980. The
designation of a material as "PACM" may be rebutted pursuant to paragraph
(j)(8) of this section.
Regulated area means an area established by the employer to demarcate
areas where airborne concentrations of asbestos exceed, or there is a
reasonable possibility they may exceed, the permissible exposure limits.
Surfacing ACM means surfacing material which contains more than 1
percent asbestos.
Surfacing material means material that is sprayed, troweled-on or otherwise
applied to surfaces (such as acoustical plaster on ceilings and fireproofing
materials on structural members, or other materials on surfaces
for acoustical, fireproofing, and other purposes).

I4.5

Thermal System Insulation (TSI) means ACM applied to pipes, fittings,


boilers, breeching, tanks, ducts or other structural components to prevent
heat loss or gain.
Thermal System Insulation ACM means thermal system insulation which
contains more than 1 percent asbestos.
Exposure Assessment and Monitoring
Initial Exposure Assessment
Competent Moreno Group managers or supervisors will evaluate all asbestos
operations (some exceptions exist only when we are involved in Class IV work) for
the purpose of predicting whether exposure levels during the planned asbestos work
can be expected to exceed the PELs, and thus whether additional monitoring, and
other precautions are required.
Our competent person will conduct all initial exposure assessments.
In known PACM or ACM work environments we will presume that our employees are
exposed in excess of the TWA and excursion limit and implement the necessary
protective measures, until we conduct exposure monitoring and determine that
workers will not be exposed in excess of the PEL of .1 fiber per cubic centimeter of
air as an eight (8) hour time-weighted average (TWA), or make a negative exposure
assessment.
The initial exposure assessment requirement can be satisfied by two methods:
A negative exposure assessment demonstrating that the activity involving
the asbestos material is unlikely under all foreseeable conditions to result in
concentration above the PEL.
Initial exposure monitoring determined from breathing zone air samples that
are representative of the 8-hour TWA and 30-minute short-term exposures.
Monitoring
Third party monitoring firms will be used for personnel exposure and area monitoring
that complies with all OSHA requirements.
Employee Notification
Employees will be notified as to the monitoring results, in a manner that is consistent
with current privacy laws, mandated by federal guidelines and regulations.

I.4.6

Medical Surveillance
A medical surveillance program will be instituted for all employees who for a
combined total of 30 or more days per year are engaged in Class I, II, and III work or
are exposed at or above the PEL.
When our employees are required by the standard to wear a negative pressure
respirator, we make sure those employees are physically able to perform the work
and use the equipment as determined by a physician. Documentation of pulmonary
function tests, fit tests, and respirator training is available through the SH&E
Department.
We ensure that all medical examinations and procedures are performed by or under
the supervision of a licensed physician, and are provided at no cost to the employee
and at a reasonable time and place.
Our medical surveillance program includes the following:
1. Medical examinations and consultations
Medical examinations and consultations are available to each employee as
required by the OSHA Standard. .
When our employee is assigned to an area where exposure to asbestos may
be at or above the PEL for 30 or more days per year, or engage in Class I, II,
or III work for a combined total of 30 or more days per year, a medical
examination must be given within 10 working days following the thirtieth day
of exposure; and at least annually thereafter.
2. Information provided to the physician
The following information will be provided to the examining physician:
A copy of the asbestos standard including Appendices D, E, and I. (as
requested)
A description of affected employees' duties as they relate to their exposure.
The employees' representative exposure level or anticipated exposure level.
A description of any personal protective and respiratory equipment used or to
be used.
Information from previous medical examinations that is not otherwise
available to the examining physician.
3. Physician's written opinion
The written opinion of the examining physician should minimally contain the
results of the medical examination and diagnostic procedures.
I4.7

Recordkeeping
Data
Where we rely on IH Monitoring and Product Sampling that demonstrates that
products made from or containing asbestos or the activity involving such products or
material are not capable of releasing fibers of asbestos in concentrations at or above
the permissible exposure limit and/or excursion limit under the expected conditions
of processing, use, or handling, the product data will minimally include:
The testing protocol, results of testing, and/or analysis of the material for the
release of asbestos.
A description of the operation exempted and how the data support the
exemption.
Other data relevant to the operations, materials, processing, or employee
exposures covered by the exemption.
We maintain this record for the duration of the employer's reliance upon such data.
Exposure Measurements
An accurate record of all measurements taken to monitor employee exposure to
asbestos as prescribed by the OSHA Standard will be maintained.
Note: We may utilize the services of competent organizations such as industry trade
associations and employee associations to maintain the records required by this
section.
This record includes at least the following information:
The date of measurement.
The operation involving exposure to asbestos that is being monitored.
Sampling and analytical methods used and evidence of their accuracy.
Number, duration, and results of samples taken.
Type of protective devices worn, if any.
Name, social security number, and exposure of the employees whose
exposures are represented.
We will maintain this record for at least thirty (30) years.

I.4.8

Medical Surveillance
We have established and do maintain an accurate record for each employee subject
to medical surveillance.
The record includes at least the following information:
The name and social security number of the employee.
A copy of the employee's medical examination results, including the medical
history, questionnaire responses, results of any tests, and physician's
recommendations.
Physician's written opinions.
Any employee medical complaints related to exposure to asbestos.
We make sure that this record is maintained for the duration of employment plus
thirty (30) years.
Training and Training Records
Training will be provided to all employees who maybe potential exposed to Asbestos
Containing Material prior to their initial assignment and annually thereafter if
required. All employee training records will be kept for one (1) year beyond the last
date of employment.
Data to Rebut PACM
Where the building owner and we have relied on data to demonstrate that PACM is
not asbestos-containing, we maintain such data for as long as they are relied upon
to rebut the presumption.
Competent Person Requirements
At the worksite covered by this plan, we have designated Moreno Group LLC and
Subsidiaries Construction Manager, and Moreno Group LLC and Subsidiaries
Environmental Manager, or their qualified agent as our competent person, having
the qualifications and authorities for ensuring worker safety and health.
Inspections
In addition to our initial inspection, the designated competent person will visit the job
sites to supervise the following:
For Class I jobs, on-site inspections are made at least once during each work shift,
and at any time an employee requests one.

I4.9

For Class II, III, and IV jobs, on-site inspections are made at intervals sufficient to
assess whether conditions have changed, and at any reasonable time an employee
requests.
On all worksites where our employees are engaged in Class I or II asbestos work,
our competent person will perform or supervise the following duties, as applicable:
Set up the regulated area, enclosure, or other containment.
Ensure (by on-site inspection) the integrity of the enclosure or containment.
Set up procedures to control entry to and exit from the enclosure and/or area.
Supervise all employee exposure monitoring required by this section and
ensure that it is conducted as required by paragraph (f) of this section.
Ensure that employees working within the enclosure and/or using glove bags
wear respirators and protective clothing as required.
Ensure through on-site supervision, that employees set up and use,
engineering controls, use work practices and personal protective equipment
in compliance with all requirements
Ensure that employees use the hygiene facilities and observe the
decontamination procedures.
Ensure that through on-site inspection, engineering controls are functioning
properly and employees are using proper work practices.
Competent Person Training
Our competent person has received the following training for Classes I and II
asbestos work:
1. All aspects of asbestos removal and handling, including: abatement, installation,
removal and handling.
2. The contents of the asbestos rule.
3. The identification of asbestos.
4. Removal procedures where appropriate.
5. Other practices for reducing the hazard.
6. All PPE Requirements.
Our competent person has received the following training for Classes III and IV
asbestos work in addition to the above.
I.4.10

1. Aspects of asbestos handling appropriate for the nature of the work, to include
procedures for setting up glove bags and mini- enclosures.
2. Practices for reducing asbestos exposures.
3. Use of wet methods.
4. The contents of this standard.
5. The identification of asbestos.
This training includes successful completion of a course that is consistent with EPA
requirements for training of local education agency maintenance and custodial staff.
Regulated areas
Operations, where airborne concentrations of asbestos exceed or there is a
reasonable possibility they may exceed a PEL, are conducted within a regulated
area. All regulated areas shall be identified by the OSHA required signs and labels.
Demarcation
The regulated area is demarcated in a manner that minimizes the number of
persons within the area and protects persons outside the area from exposure to
airborne asbestos. When critical barriers or negative pressure enclosures are used,
they may demarcate the regulated area. Warning signs are posted stating the
particular hazard(s), as well as access requirements or limitations such as PPE
requirements.
Access
Access to regulated areas is limited to authorized persons and to persons authorized
by the OshAct or federal regulations.
Respirators
All persons entering a regulated area where employees are required to wear
respirators are supplied with an appropriate respirator. Third Party air monitoring
shall help identify the appropriate NIOSH approved respirator for the tasks.
Respirators will be provided at no cost to the employee per the Moreno Group, LLC
and Subsidiaries Respiratory Protection Program.
Prohibited Activities
We make sure that our employees do not eat, drink, smoke, chew tobacco or gum,
or apply cosmetics in a regulated area.

I4.11

Competent Persons
Our competent person will supervise all asbestos work performed within regulated
areas.
Communication of Hazards:
We understand the importance of communicating asbestos hazard information at
this job site, and will do so in all necessary manners. Areas where an asbestos
exposure hazard maybe present the regulated area shall be identified by signs and
labels that meeting the OSHA requirements.
Methods of Compliance
Our methods of compliance set operation-specific and exposure-triggered work
practices for conducting asbestos work. Each job is specific and the methods of
compliance will include the following required and optional procedures.
The following basic engineering controls and work practices are a part of all
asbestos operations at this jobsite regardless of the levels of exposure.
1) Vacuum cleaners equipped with HEPA filters to collect all debris and dust
containing ACM or PACM.
2) Wet methods, or wetting agents, to control employee exposures during asbestos
handling, mixing, removal, cutting, application, and cleanup, except where we
demonstrate that the use of wet methods is infeasible due to for example, the
creation of electrical hazards, equipment malfunction, and, in roofing.
3) Prompt clean-up and disposal of wastes and debris contaminated with asbestos
in leak-tight containers.
In addition to the requirements noted above for all asbestos operations we use the
following control methods to achieve compliance with the TWA permissible exposure
limit and excursion (STEL) limit.
Local exhaust ventilation equipped with HEPA filter dust collection systems.
Enclosure or isolation of processes producing asbestos dust.
Ventilation of the regulated area to move contaminated air away from the
breathing zone of employees and toward a filtration or collection device
equipped with a HEPA filter.
Wherever the feasible engineering and work practice controls described
above are not sufficient to reduce employee exposure to or below the
permissible exposure limit and/or excursion limit we will use them to reduce
employee exposure to the lowest levels attainable by these controls and shall
supplement them by the use of respiratory protection.
I.4.12

Prohibitions
We never use the following work practices and engineering controls for work related
to asbestos or for work which disturbs ACM or PACM, regardless of measured levels
of asbestos exposure or the results of initial exposure assessments:
High-speed abrasive disc saws that are not equipped with point of cut
ventilator or enclosures with HEPA filtered exhaust air.
Compressed air to remove asbestos, or materials containing asbestos, unless
the compressed air is used in conjunction with an enclosed ventilation system
designed to capture the dust cloud created by the compressed air.
Dry sweeping, shoveling, or other dry clean-up of dust and debris containing
ACM and PACM.
Employee rotation as a means of reducing employee exposure to asbestos.
Class I and II Requirements
All Class I and Class II work, including the installation and operation of the control
system is supervised by our competent person.
For all indoor Class II jobs, where we have not produced a negative exposure
assessment, or where during the job changed conditions indicate there may be
exposure above the PEL, or where we do not remove the ACM in a substantially
intact state, we will use adequate methods and practices to ensure that airborne
contaminates do not exit the regulated area.
Class III Requirements
We conduct Class III asbestos work using engineering and work practice controls
which minimize the exposure to our employees performing the work and to
bystander employees. We will use:
Wet methods.
When feasible, local exhaust ventilation.
Where the disturbance involves drilling, cutting, abrading, sanding, chipping,
breaking, or sawing of thermal system insulation or surfacing material we
will use impermeable dropcloths, and will isolate the operation using minienclosures or glove bag systems or another isolation method.
Where we do not have a "negative exposure assessment," or where
monitoring results show the PEL has been exceeded, we will contain the
area using impermeable dropcloths and plastic barriers or their equivalent,
or shall isolate the operation using another control system.
I4.13

Our employees performing Class III jobs, involving the disturbance of


thermal system insulation or surfacing material, or where we do not produce
a "negative exposure assessment" or where monitoring results show a PEL
has been exceeded, wear respirators selected, used and fitted in
accordance with our Respiratory Protection Program
Class IV Requirements
Employees trained in our asbestos awareness training program will be allowed to
work Class IV asbestos jobs.
Respiratory Protection
We provide respirators and ensure they are used in the following circumstances:
During all Class I asbestos jobs.
During all Class II work when the ACM is not removed in a substantially intact
state.
During all Class II and III work not performed using wet methods, except for
removal of ACM from sloped roofs when a negative exposure assessment
has been made and the ACM is removed in an intact state.
During all Class II and III asbestos jobs where we do not conduct a negativeexposure assessment.
During all Class III jobs where TSI or surfacing ACM or PACM is being
disturbed.
During all Class IV work performed within regulated areas where employees
performing other work are required to wear respirators.
During all work covered by this section where employees are exposed above
the TWA or excursion limit.
In emergencies.
Respirator Selection
Where respirators are used we select and provide, at no cost to out employees, the
appropriate respirator. We ensure that the employee uses the respirator provided.
We provide a tight fitting powered, air-purifying respirator in lieu of any negativepressure respirator specified in Table 1 whenever: (a) an employee chooses to use
this type of respirator, and (b) this respirator will provide adequate protection to the
employee. In addition, we provide a half-mask air purifying respirator, other than a
disposable respirator, equipped with high efficiency filters whenever our employees
perform:

I.4.14

Class II and III asbestos jobs where we do not conduct a negative exposure
assessment.
Class III jobs where TSI or surfacing ACM or PACM is being disturbed.
Selection criteria when employees are in regulated area where Class I work is
being performed, a negative exposure assessment of the area has not been
produced, and the exposure assessment of the area indicates the exposure
level will not exceed 1 f/cc as an 8-hour time weighted average, we provide
the employees with one of the following respirators:
(A) A tight-fitting powered air-purifying respirator equipped with high efficiency
filters;
(B) A full facepiece supplied-air respirator operated in the pressure demand
mode equipped with HEPA egress cartridges; or
(C) A full facepiece supplied-air respirator operated in the pressure demand
mode equipped with an auxiliary positive pressure self-contained
breathing apparatus. A full facepiece supplied-air respirator operated in
the pressure-demand mode equipped with an auxiliary positive pressure
self-contained breathing apparatus must be provided under such
conditions when the exposure assessment indicates exposure levels
above 1 f/cc as an 8-hour time weighted average.
Respirator Program
We have developed a respiratory protection program to satisfy the requirements of
an asbestos related project.
Respirator Fit Testing
We make sure that the respirator issued to each employee exhibits the least
possible facepiece leakage and that the respirator is fitted properly. We perform
either quantitative or qualitative face fit tests:
Before any of our employees are required to use any respirator with a
negative or positive pressure tight-fitting facepiece;
Whenever a different respirator facepiece (size, style, model, or make) is
used;
At least annually;
Whenever the employee reports, or our company, the physician or other
licensed health care professional (PLHCP), supervisor, or Program
Administrator makes visual observations of, changes in the employee's
physical condition that could affect respirator fit. Such conditions include, but
I4.15

are not limited to, facial scarring, dental changes, cosmetic surgery, or an
obvious change in body weight; and
When the employee, subsequently after passing a qualitative or quantitative
fit test, notifies the company, Program Administrator, supervisor, or PLHCP
that the fit of the respirator is unacceptable. That employee will be retested
with a different respirator facepiece.
See the Moreno Group, LLC and Subsidiaries Respiratory Protection Program for
Details.
Protective Clothing
We provide and require the use of protective clothing, such as coveralls or similar
whole-body clothing, head coverings, gloves, and foot coverings for:
Any employee exposed to airborne concentrations of asbestos that exceed
the TWA and/or STEL.
This site when a required negative exposure assessment is not produced.
Any employee performing Class I operations which involve the removal of
over 25 linear or 10 square feet of TSI or surfacing ACM and PACM.
Laundering
We ensure that laundering of contaminated clothing is done so as to prevent the
release of airborne asbestos in excess of the TWA or STEL.
Contaminated Clothing
Contaminated clothing is transported in sealed impermeable bags, or other closed,
impermeable containers, and be labeled.
Inspection of Protective Clothing
Our competent person examines work suits worn by our employees at least once
per work shift for rips or tears that may occur during performance of work. When rips
or tears are detected while an employee is working, they will be immediately
mended, or the work suit shall be immediately replaced.
Hygiene Facilities and Practices for Employees
Our hygiene facilities and practices requirements for this job are as required by
OSHA regulations.
Smoking in Work Areas
We ensure that employees do not smoke in regulated work areas where they have
increased potential for exposure to asbestos because of activities in that work area.
I.4.16

Housekeeping
Vacuuming
When we select vacuuming methods we always use HEPA filtered vacuuming
equipment. The equipment is used and emptied in a manner that minimizes the
reentry of asbestos into the worksite.
Waste Disposal
Asbestos waste, scrap, debris, bags, containers, equipment, and contaminated
clothing will be collected and disposed of in sealed, labeled, impermeable bags or
other closed, labeled, impermeable containers.
Care of Asbestos-Containing Flooring Material
Waste and debris and accompanying dust in an area containing accessible thermal
system insulation or surfacing ACM/PACM or visibly deteriorated ACM:
Is not dusted or swept dry, or vacuumed without using a HEPA filter.
Is promptly cleaned up and disposed of in leak tight containers.
Specifically:
We assess all asbestos operations for their potential to generate airborne
fibers.
Our designated competent person conducts an initial exposure assessment
immediately before or at the initiation of an operation to document expected
exposures, and that the assessment is completed in time to comply with
requirements triggered by exposure data or the lack of a "negative exposure
assessment."
We perform periodic monitoring and additional monitoring when required.
When required, we implement a medical surveillance program for all
employees when for a combined total of 30 or more days per year engage in
Class I, II, or III work or are exposed at or above the PEL, or when employees
are required to wear negative-pressure respirators.
We maintain objective data, monitoring, medical surveillance, training, and
building owner notification records when required and for the time periods
indicated in the asbestos rule.
Our asbestos competent person is qualified, authorized, and has the proper
training to ensure worker safety and health.
Our respirator program is in place.
I4.17

Our Class I, II, and III asbestos work, and all other operations where airborne
concentrations of asbestos exceed or there is a possibility the may exceed a
PEL, are conducted within regulated areas.
We understand that the communication of asbestos hazards is vital to prevent
further overexposure and that we have specific duties under the asbestos rule
to communicate those hazards through written notifications, signs, labels and
employee information and training.
Multi-employer worksites
We Will:
Inform other employers on the site of the nature of our work through SH&E
Meetings and/or Site Orientations.
Relay information of the existence of regulated areas.
Take correct measures to ensure personal working adjacent to regulated
areas are removed from the affected area until any breach within the
containment is repaired or perform an initial exposure assessment is
performed per OSHA 1926.1101(f).

I.4.18

Moreno Group LLC


and Subsidiaries
SH&E Management
System

Back Injury Prevention

Page 1 of 4
Original: 05/06/2003
Revised: 02/01/2010

Back Injury Prevention


Purpose
The purpose of this program is to provide a method for identifying, evaluating
and controlling workers exposures to manual lifting hazards.
Scope
The scope of this program is to identify potential manual lifting hazards,
identify proper manual lifting techniques, and identify when alternative lifting
means need to be utilized.
Responsibilities
The Facility Manager or Offshore Manager or Designee is responsible for:
Providing the leadership and resources needed to implement this
program to minimize workers exposures to manual lifting hazards at
Moreno Group LLC and Subsidiaries facilities and customer facilities.
Understanding and complying with the requirements of this procedure.
Ensure all new operations are evaluated to eliminate manual lifting
hazards
The First Line Supervisor / Offshore Superintendent is responsible for:
Understanding and complying with the requirements of this procedure.
Ensuring that employees comply with the requirements of this
procedure.
Planning and providing alternative lifting means anytime the need
arises.
Periodically evaluate worksite for potential hazards and unsafe acts
involving manual lifting techniques.
Correct or train employees on proper lifting techniques

I5.1

The Safety, Health and Environmental Department is responsible for:


Coordinating or conducting training for all personnel in proper lifting
techniques and potential lifting hazards.
Evaluating Program to ensure compliance
The Human Resource Department is responsible for:
Communicating to management when certain employees cannot meet
the requirements of this plan.
The Employee is responsible for:
Understanding and complying with the requirements of this procedure.
Communicating to supervisors any suggestions or concerns related to
this procedure.
Reporting any injury, incident or near miss to the Supervisor or Safety,
Health and Environmental Department.
Requirements
Moreno Group LLC and Subsidiaries will establish a Recommended Weight
Limit (RWL) not to exceed 75 pounds for all manual lifting. This limit may
decrease for awkward objects (i.e. long loads, unbalanced loads, etc.) or
repetitive (i.e. repeating) lifting.
Manual Lifting Guidelines
Anytime manual lifting is performed, employees must use the following
guidelines:
Inspect the work area and ensure that you have a clear path to carry
the load, and a place to set it down.
Size up the load before lifting. Test by lifting one of the corners or
pushing.
Center the body above the load to be lifted.
Bend at the knees. Note: This item is the single, most important aspect
of lifting.
Ensure that you have a firm grip on the load to be lifted.
Lift straight up, smoothly and let your legs do the work, not your back!
I5.2

Do not twist or turn your body once you have made the lift.
Bend at the knees to set the load down.
Minimize the amount of lifts as much as possible.
Alternative Lifting Methods
For objects that exceed 75 pounds, or for any awkward (i.e. not proportional)
or long loads (extends beyond ones body), the following methods should be
utilized to be prevent possible injuries:
Utilizing two or more employees for a lift. It is critical that whenever
multiple employees are involved in a single lift, everyone
communicates to each other, and the load is balanced out between the
employees.
Mechanical lifting devices (Cranes, forklifts, dollies, chain falls, comea-longs, etc.) should be utilized for loads exceeding the RWL per
employee.

I5.3

Load Chart
Load
Can of Welding Rods
Welding Wire Spool
Fluxcore feeder without wire
Fluxcore feeder with wire
Roll of submerged arc wire
1 foot 6 XX pipe
1 foot 4 schedule 80 pipe
1 foot 4 XX pipe
1 foot 2 schedule 80 pipe
1 foot 2 XX pipe
1 foot 8 schedule 80 pipe
1 foot 12 x50 I-beam
1 foot 4 x 13 I-beam
1 foot 6 x 25 I-beam
1 foot 6 x 15 I-beam
20 joint handrail pipe
Steel Grating (1)
6 600 pound flange
4 150 pound flange
8 Foot Section Handrail (3
posts)
3 x 20 x 1 Sheet of Grating
5 gallon bucket paint
2.5 gallon pale of zinc powder
Paint Pot empty
Paint Pot with Paint
Blasting sand in bag
1 k tugger
Scaffold Board
Aluminum Peg Board 20
Aluminum Peg Board 12
50 foot of welding lead
6 ton chain fall (Jet)
3 ton chain fall (Budgit)
12 ton snatch block
6 ton Come-A-Long
35 Ton Shackle
55 Ton Shackle
Mag drill
Sheet of plywood
Beam Clamp
Tripod
Pipe Jack

I5.4

Estimated Weight
50 pounds
44 pounds
30 pounds
74 pounds
60 pounds
54 pounds
15 pounds
40 pounds
5 pounds
9 pounds
44 pounds
50 pounds
13 pounds
25 pounds
15 pounds
55 pounds
7.34 pounds per ft2
73 pounds
16.5 pounds
120 pounds
440 Pounds
75 pounds (Average)
100 pounds
58 pounds
88 pounds
100 pounds
120 pounds
20 pounds
130 pounds
70 pounds
60 pounds
55 pounds
80 pounds
55 pounds
60 pounds
45 pounds
90 pounds
40 pounds
50 pounds
45 pounds
35 pounds
18 pounds

Moreno Group LLC


and Subsidiaries SH&E
Management System

Benzene Procedure

Page: 1 of 6
Original: 01/01/2005
Revised: 01/01/2007

Benzene Procedure
Purpose
The purpose of this standard is to communicate to employees the potential hazard
when exposed to Benzene and to establish uniform procedures to be followed by
Moreno Group LLC and Subsidiaries employees for benzene exposures. It is based
on 29 CFR 1910.1028 requirements.
Scope
Moreno Group LLC and Subsidiaries employees may be potentially exposed to
benzene while working at a host contractor facility or while working on pipelines and
around crude oil. As part of the Hazard Communication standard and other
regulations under, such as Process Safety Management, the Host Company will
relay the potential exposure information to management officials prior to start of the
job.
Responsibilities
The Facility Manager / Site Manager or Designee is responsible for
Understanding and complying with the requirements of this procedure.
Ensuring that personnel with potential exposures to benzene are placed
within a medical surveillance program that includes respiratory protection and
trained.
Ensure that all work activities and documentation of this program is kept onsite during the course of activities with potential exposures to benzene.
Ensuring that personnel performing benzene monitoring at work locations are
trained in the use of monitoring equipment.
Auditing compliance with this procedure.
The First Line Supervisor or Designee is responsible for:
Understanding and complying with this procedure.
Conferring with Facility / Site Manager or designee or SH&E Department as
to any potential benzene exposure.

I6.1

Ensuring personnel assigned to task with potential benzene exposures have


been place within a medical surveillance program that includes respiratory
protection and are trained.
Ensuring employees performing tasks with potential benzene exposures are
following the Job Safety and Environmental Analysis (JSEA) and utilizing all
appropriate Personal Protective Equipment for the task.
Notify Facility / Site Manager or designee and the SH&E Department of any
suggestions to improve job task that will reduce potential exposure to
benzene.
Resolve any situation in which an employee utilizes their Stop Work Authority
due to an unsafe condition or exposure.
The SH&E Department is responsible for:
Understanding and complying with this procedure.
Coordinating or conducting Benzene and Respiratory Protection Training.
Coordinating the placement of employees within a medical surveillance
program that includes respiratory protection.
Coordinating or conducting training on the monitoring equipment to be utilized
for benzene monitoring.
Advise Facility / Site Manager or designee or First Line Supervisor of any
suggestions to minimize employees exposure to potential benzene
exposures.
Obtain and provided to the Human Resource Department any personal
monitoring results for benzene exposures so they can be placed within the
employees medical records file.
Notify in writing all employees of their results from the personal monitoring.
The Human Resource Department is responsible for:
Understanding and complying with this procedure.
Coordinating the placement of employees within a medical surveillance
program that includes respiratory protection.
Maintaining medical records of employees potential exposures and
examinations performed by Moreno Group LLC and Subsidiaries Approved
Physicians

I6.2

The Employee is responsible for:


Understanding and complying with this procedure. If a hazardous
concentration of benzene is detected, notify your supervisor immediately.
Utilizing Stop Work Authority anytime they feel at risk.
Notify their immediate First Line Supervisor of the need to Stop Work and do
not begin until reason to Stop Work is resolved.
Following the task specific Job Safety and Environmental Analysis (JSEA)
and wearing all required Personal Protective Equipment at all times.
Employees shall be knowledgeable of these requirements and shall comply
with them. If a hazardous concentration of benzene is detected, notify your
supervisor immediately.
The Host Facility is responsible for:
Host facilities are also responsible for posting warning signs and labels on
vessels and lines that contain benzene, and providing other types of
information as appropriate.
Responsible for providing a Site Specific Training / Orientation.
Requirements
General Information
Benzene (C6H6, CAS Registry Number 71-43-2) is a highly toxic, flammable liquid
or gas that is extremely dangerous even in low concentrations. In a liquid state,
Benzene is a colorless to light-yellow with an aromatic odor.
Benzene can enter the body by skin contact, inhalation, and sometimes ingestion.
Short term exposures can cause irritation to the eyes and respiratory tract, and may
cause giddiness, breathlessness, euphoria, and perhaps a headache. Long-term
(chronic) exposures will cause various blood disorders ranging from anemia to
leukemia, an irreversible, fatal disease. OSHA regulates benzene as a cancer
hazard.
Permissible Exposure Limit
The permissible exposure limit (PEL) established by OSHA for benzene is 1 part per
million (ppm) for eight (8) hours, which is the concentration to which a normal,
healthy adult can be exposed for eight hours without harm. For short term situations,
OSHA allows exposures averaged to 5 ppm for any 15-minute period. The standard
also establishes an "Action Level" (AL) of 0.5 ppm over the 8-hour day, which may
require certain "action" - such as wearing of respirators, etc. to take place

I6.3

Precautions
All employees must realize the hazard of benzene and acquire a thorough
knowledge of this poisonous material. Moreno Group LLC and Subsidiaries and / or
host facility will conduct air monitoring to determine the concentrations of benzene
routinely present or where it may be present, and for those areas that exceed the
OSHA PEL, establish regulated work areas - designed to control who enters the
area and what types of protective equipment are required. Extreme care must be
used when working in regulated areas or on piping or equipment, such as operating
any valve, line, bleeder, etc., which may contain benzene. Where benzene is
present, engineering controls such as isolation, or administrative controls will be
utilized first to protect the workers. In certain circumstances, however, personal
protective equipment may be required. This has been addressed in the chapter of
this manual for PPE, and may require respirators, protective clothing, eye, face, and
splash protection, etc.
Monitoring
The presence of benzene may be determined with portable detection devices that
are available for use. These devices will primarily include direct reading instruments,
such as Draeger colorimetric tubes and pump, or others that are available through
equipment rental agencies.
These detection devices are available by contacting the Facility Manager or
Designee, and / or the SH&E Department. In addition, our consultant AESI or
another third party to determine the concentration of benzene that may be present
during certain operations may conduct air monitoring for exposure assessment.
These records will be kept in accordance with OSHA regulations
Based on exposure monitoring results, Moreno Group LLC and Subsidiaries will
develop and implement engineering and I or work practice plan to minimize
exposures. This plan will be developed and maintained by the Facility Manager or
Designee, Human Resources and Safety, Health and Environmental Department.
The plans will be reviewed and revised as necessary and appropriate based on the
most recent exposure monitoring data.
Monitoring Devices
Portable Benzene Detection Devices
These devices may be used when fixed systems are not adequate or not present.
These units will be rented from Total Safety, Inc. or another vendor, and will give an
audible alarm at a pre-determined level of benzene, usually 0.5 ppm. They are
maintained and calibrated before each use by the Rental Company or the Safety
Supervisor, which will use a calibration gas.
Medical Monitoring
Moreno Group LLC and Subsidiaries employees who are exposed at or above the
Action Level of 0.5 ppm for 30 or more days per year, medical monitoring is provided
I6.4

free of charge. Moreno Group LLC and Subsidiaries Approved Medical Facilities will
be provided a copy of the OSHA standard. These facilities will perform medical
examinations and tests to monitor the health of Moreno Group LLC and Subsidiaries
employees during the time they have a potential for an exposure at or above the
Action Level.
Training
The host facility will be responsible for providing site specific training to our
personnel. In addition to the host facility site specific training, Moreno Group LLC
and Subsidiaries will also train our employees as to the hazards of benzene during
our Hazard Communication training and prior to any potential exposure to benzene.
As part of employee training for each job, this information will be relayed to our
employees, so they are aware of the location and hazards associated with benzene,
as well as methods used to reduce or control exposures.
At host facilities, regulated areas are established where the PEL can or may be
exceeded. A detailed copy of the OSHA regulation governing benzene can be
reviewed by any employee or their designated representative in the Site Office,
available from the Facility / Site Manager or designee, and / or the SH&E
Department. This is also the source for additional exposure information and other
pertinent written plans and programs
Personal Protective Equipment (PPE) and Respiratory Protection
The level of Personal Protective Equipment (PPE) shall be determined during the
initial job planning process and/or during the development of the task Job Safety and
Environmental Analysis (JSEA). PPE may include but not limited to Chemical
Goggles, Face Shield, Aprons, Chemical Suits, Chemical Gloves and Chemical
Boots.
Respiratory protective equipment is to be utilized when exposed to hazardous
concentrations of benzene. Only approved respiratory protection will be used. For
exposures up to 10 ppm, half face air purifying respirators with organic vapor
cartridges (black) can be used. Supplied air respiratory equipment, such as airline
respirators with escape bottles or self-contained breathing apparatuses (SCBAs)
shall be utilized for escape or emergency conditions. Refer to the Moreno Group
LLC and Subsidiaries Respiratory Protection Program within our SH&E Management
System Manual for additional information.
No one is permitted to wear a respirator unless they have been properly trained, fittested, and received medical clearance, and only NOISH-certified respirators can be
used.
Evacuation I Escape I Emergency Procedures
Prior to entry on to the site where benzene may be present, check with the owner I
operators to determine what their specific emergency plans address and always
I6.5

follow their requirements. They may assign a coordinator to assist with these
matters.
Whenever an unsafe level of benzene is detected, do not panic. The following
escape method will be followed:
1. Put on a 5 minute escape air pack (if available).
2. Evacuate cross wind then upwind of the emission to a safe area.
3. Alert others of hazard.
4. Call your supervisor from a safe area. Stand by in safe area for instructions from
your supervisor and return to work area only when it has been determined that it
is safe to return.
Equipment Opening
Maintenance
Anytime process equipment, i.e., piping, vessels, instruments, drain lines, blinds,
etc., which may contain benzene is entered or opened in any area, or if work is to be
performed where benzene may be present, those involved must wear the
appropriate level of Personal Protective Equipment and Respiratory Protection while
performing the work. All line opening or equipment opening shall be performed in
accordance of our line opening procedures.

I6.6

Moreno Group LLC


and Subsidiaries
SH&E Management
System

Bloodborne Pathogens

Page: 1 of 9
Original: 06/08/1998
Revised: 05/01/2008

Bloodborne Pathogens
Purpose
Moreno Group LLC and Subsidiaries seeks to limit employee exposure to blood and
other infectious materials in compliance with OSHA 29 CFR 1910.1030. This
program identifies those employees who are occupationally exposed, and addresses
both the means by which the exposure can be reduced or eliminated and the
procedure for evaluating an exposure incident.
Scope
Safety, Health and Environmental Department Representatives, depending upon
their work assignments, may be occupationally exposed to bloodborne pathogens
including human immunodeficiency virus (HIV) and the Hepatitis B Virus (HBV). The
Occupational Exposure to Bloodborne Pathogens Standard (29 CFR 1910.1030)
addresses this risk and aims to reduce occupational exposure.
Responsibilities
The Facility Manager / Offshore Manager or Designee is responsible for:
Understanding and complying with the requirements of this procedure.
Ensuring that personnel are informed of bloodborne pathogen safeguards.
Offering Hepatitis B Vaccine (HBV) to all personnel whom may be exposed.
Auditing compliance with this procedure.
The First Line Supervisor / Offshore Superintendent is responsible for:
Understanding and complying with this procedure.
Conferring with Facility Management or SH&E Department as to any
possible bloodborne pathogen exposure
Advising Facility Management of any suggestions to improve the
Bloodborne Pathogen Procedure.
The Safety, Health and Environmental Department is responsible for:
Understanding and complying with this procedure.
I7.1

Coordinating or conducting Bloodborne Pathogens training for personnel.


Communicating to the Company Physician to establish any Bloodborne
Pathogen exposure has occurred.
Auditing compliance with this procedure.
The Employee is responsible for:
Understanding and complying with this procedure.
Conferring with First Line Supervisor or Offshore Superintendent as to any
possible bloodborne pathogen exposure.
Advising First Line Supervisor or Offshore Superintend of any suggestions
to improve the Bloodborne Pathogen Procedure.
Requirements
Exposure Determination
Category I Employees
Employees in the following job classification(s), because of the nature of their job
duties, have been determined to be occupationally exposed to blood or other
potentially infectious materials without regards to the use of personal protective
equipment:
Safety, Health and Environmental Department Representatives
Hereafter, employees of this type will be identified as Category I employees.
Exposure may be anticipated from such tasks as cleaning and dressing wounds,
burn care, and disposing of contaminated objects or fluids. These employees shall
receive training annually on Bloodborne Pathogens.
Category 2 Employees
Other employees, who render first aid or CPR, not in the normal scope of their job
duties but as a collateral duty, may be exposed to blood or other potentially
infectious materials without regards to the use of personal protective equipment.
Hereafter, employees of this type will be identified as Category 2 employees.
Methods of Compliance
Methods of compliance that reduce or eliminate the risk of exposure include
Universal Precautions, Engineering Controls, Work Practice Controls, and the use of
personal protective equipment (i.e. gloves, ventilation shield or mask, etc.).

I7.2

Universal Precautions
All blood and certain body fluids are to be treated as if they are infectious for HIV,
HBV, or any other bloodborne pathogen. This method of infection control, known as
Universal Precautions, will be utilized in any situation that involves potential
exposure to blood or other potentially infectious materials.
Engineering Control
Engineering Controls, methods of isolating or removing a hazard from the
workplace, are one of the most effective methods of hazard reduction. Engineering
controls should be employed first and, if the hazard remains, personal protective
equipment will also be used. Engineering controls include the use of sharps
disposal containers, disposable airway equipment or resuscitation bags, and pocket
mouth-to-mouth resuscitation devises for CPR. These controls should be examined
and maintained or replaced on a regular schedule to ensure their effectiveness.
Work Practices
Methods that reduce the exposure during a task or procedure will be used to
minimize exposure. Hands and other skin surfaces, which come in contact with
blood or other potentially infectious materials, must be washed immediately with
soap and water. In the event that running water is unavailable, antiseptic towelettes
may be used. Hands will be washed with soap and water as soon as possible.
Contaminated needles and sharps will be disposed of into a sharp container without
recapping. Sharps may only be recapped using a one-handed technique in
emergency situations.
Puncture coded, resistant, color and leak proof containers will be utilized for disposal
of contaminated sharps.
Eating, drinking, smoking, applying cosmetics, and handling contact lenses is
prohibited in areas where exposure is likely to occur.
Food and drink will not be stored in or on refrigerators, cabinets, shelves, or counter
tops where blood or other potentially infectious materials are present.
All procedures involving blood or potentially infectious materials shall be handled in
a way which minimizes splashing, spraying, and spattering.
Specimen containers for blood or other potentially infectious materials will be placed
in leak-proof and puncture resistant containers and labeled with the appropriate
biohazard label.

I7.3

Labels/Signs
Biohazard warning labels of florescent orange or orange-red letters, identified in the
appendix, will be used to identify blood or other potentially infectious materials.
Color-coded red containers. or bags may be used in place of labels. Specifics on
labeling requirements can be found in the appendix.
Personal Protective Equipment
Personal protective equipment will be utilized at all times to prevent contaminated
materials from passing to the employee's clothing, skin, eyes, mouth or mucous
membranes. Latex gloves are provided and will be worn when contact with the
hands is anticipated. Gloves will be disposed of in the appropriate container after
use. Masks, goggles, and face shields will be worn whenever splashing, spraying,
or splattering is anticipated. Gowns, aprons, and other protective clothing should be
used if a large contamination is possible.
All personal protective equipment is to be removed when leaving the work area or
emergency scene and disposed of in an appropriate container.
Regulated Waste
All contaminated items including sharps, disposable linens, disposable equipment,
broken glass, and disposable personal protective equipment are considered
regulated waste.
All contaminated sharps will be placed in closeable, puncture resistant, leak proof
and color-coded containers.
All other regulated waste and full sharps containers will be placed in a regulated
waste container for disposal in accordance with local, state, and federal regulations.
Records Will be kept as required.
Contaminated Laundry
Disposable linens including sheets, pillowcases, and towels will be used to eliminate
the need for laundering. Contaminated items will be placed in a regulated waste
container as specified in the section on Regulated Waste.
Housekeeping
All contaminated reusable equipment, work surfaces, and environmental areas will
be cleaned as soon as possible with an appropriate disinfectant such as a 1 to 10
concentration of bleach to water. Instruments, which may rust, may be placed in an
appropriate solution such as Cidex for disinfecting.
Appropriate personal protective equipment will be worn during decontamination
procedures.

I7.4

Broken glassware will be picked up using mechanical means such as tongs, or


brush and dustpan.
Hepatitis B Vaccination
The Hepatitis B Vaccination series will be offered (see attachment 1) without charge
to all Category I employees following training on the efficiency, safety, method of
administration and benefits of the vaccine shall be obtained within 10 days of
assignment unless documentation of previous receipt of the vaccination series is
provided, antibody testing reveals immune status, or medical reasons prevent
vaccination.
Employees may refuse the vaccination and must sign the declination statement.
(see Attachment 2)
Moreno Group LLC and Subsidiaries will keep documentation of employee
vaccination status and/or declination statements.
Category 2 employees will be offered the immunization series within 24 hours of
rendering first aid in a situation involving the presence of blood or other potentially
infectious materials by notifying the Safety, Health and Environmental Department.
Notification of Incident
An employee who has an occupational exposure to blood or other potentially
infectious materials should report the occurrence immediately to his/her supervisor
and the Safety Coordinator.
Incident Assessment
During Supervisor's initial assessment of the incident, determination needs to be
made concerning potential exposure to bloodborne pathogens. To assist supervisor
in the determination, the following may be contacted:
Local Company approved physician
Safety, Health and Environmental Department
The following situations, which may occur during first aid response, are exposures,
which should be considered significant risks for communicable disease transmission
(Defined "Exposure Incidents"):
Injuries such as needle sticks, cuts, or puncture wounds with objects that
have been contaminated by blood
Contamination of open wounds or mucous membranes by blood or body
fluids, such as blood splashed in the eye; or direct contact with blood
during mouth-to-mouth resuscitation without a barrier mask
Extensive and/or prolonged contamination of intact skin with blood
I7.5

Based on information developed during management of the incident, a preliminary


determination needs to be made: There was "No Exposure", a "Potential Exposure",
or a defined "Exposure incident". This determination and the basis for it, needs to
be explained to the employee, and documented by supervisor.
Exposure Evaluation Follow-Up

"No Exposure"
Supervisor needs to document in local files the information related to the incident.
If the preliminary assessment of the incident indicates a "Potential Exposure" or a
defined "Exposure Incident" occurred, the exposed employee must be offered
Hepatitis B Vaccination series, as a post-exposure preventative, within 24 hours of
the incident, unless the employee has previously received the complete Hepatitis B
Vaccination series; or Antibody testing has revealed that the employee is immune; or
the vaccination is not advised for medical reasons.
Employee will complete a "Consent" or "Declination" form depending on acceptance
choice.
Hepatitis B Vaccination program will be administered by a licensed, registered
nurse, or licensed physician knowledgeable of the bloodborne pathogens standard.

"Exposure Incident"
If it is determined by management or a medical professional that a defined
"Exposure Incident" has occurred, then a confidential medical evaluation and followup of the incident will be made by a physician or Safety Coordinator.
Medical counseling will be made available to any employee who has been exposed.
Request for clinical evaluation and testing will be referred to the companys
physician.
Awareness Sessions
During the New Employee Orientation / SH&E Training, new employee will receive
awareness information on preventive controls and procedures for avoiding contact
with bloodborne pathogens.
Recordkeeping
Moreno Group LLC and Subsidiaries will retain all records associated with this
guideline including employee training, hepatitis B vaccination documentation and
post exposure medical records.
The Human Resource Department shall maintain all medical records. These records
will be maintained in a confidential manner for the duration of employment plus 30
I7.6

years within. Employees or their representative may access these records by


providing this department with a written request. The transfer of these records shall
comply with the requirements of 29 CFR 1910.1020(h).
The Safety, Health and Environmental Department will maintain all training records
for a minimum of three years.

I7.7

Attachment 1

I7.8

Moreno Group LLC and


Subsidiaries
TO:
FROM:

Facility Manager.

RE:

Hepatitis Vaccine
DO NOT DISCARD THIS FORM
ROUTE TO OPERATIONS DEPARTMENT.
ON COMPLETION OF VACCINATION PROCESS

Thank you for making one of the most important decisions of your
career! This vaccine will offer you protection from Hepatitis B for about
five years. After that time you should consider getting an antibody test
since the exact length of effective immunization is not currently known.
Please follow these instructions for your current vaccination.
1.

The vaccine should remain refrigerated at all times. (For


transport it may remain out no more than 2 - 3 hours.)

2.

The vaccine must be given in the Deltoid muscle.

3.

Each vial contains a single dose (I ml).

4.

It is extremely important that the injections be received on time.


Your schedule is written in below.
INJECTION 1: DATE:

BY:

INJECTION 2: DATE:

BY:

INJECTION 3: DATE:

BY:

Please remember to properly dispose of syringes and other sharp


objects.

I7.8.a.1

Attachment 2

I7.9

HEPATITIS B VACCINATION
DECLINATION FORM

An employee who chooses not to accept the vaccine must sign the following
statement of declination of hepatitis B vaccination. This statement can only be
signed by the employee following appropriate training regarding hepatitis B, hepatitis
B vaccination, the efficacy, safety, method of administration, and benefits of
vaccination, and that the vaccine and vaccination are provided free of charge to the
employee. The statement is not a waiver; employees can request and receive the
hepatitis B vaccination at a later date if they remain occupationally at risk for
hepatitis B.

DECLINATION STATEMENT

I understand that due to my occupational exposure to blood or other potentially


infectious materials I may be at risk of acquiring Hepatitis B virus (HBV) infection. I
have been given the opportunity to be vaccinated with hepatitis B vaccine, at no
charge to myself. However, I decline hepatitis B vaccination at this time. I
understand that by declining this vaccine I will continue to be at risk of acquiring
hepatitis B, a serious disease. If in the future I continue to have occupational
exposure to blood or other potentially infectious materials and I want to be
vaccinated with hepatitis B vaccine, I can receive the vaccination series at no charge
to me.

Employee Signature

Witness Signature

Employee Name (Print)

Witness Name (Print)

Date Signed

Date Signed

I7.9.a.1

Moreno Group LLC


and Subsidiaries
SH&E Management
System

Cadmium Protection

Page: 1 of 15
Original: 01/01/2007
Revised: 05/01/2008

Cadmium Protection
Purpose
The purpose of this program is to establish and implement practices and procedures
for protecting the health of Moreno Group LLC and Subsidiaries employees who
may be exposed to Cadmium on the job. This program also establishes methods for
complying with the OSHA Construction Industry Cadmium Standard, 29 CFR
1926.1127, 29 CFR 1910.1027.
Scope
The scope of this program applies to all Moreno Group LLC and Subsidiaries
projects and employees involved with potential Cadmium/Cadmium compound (Zinc
Galvanized) exposure when such work involves construction, alterations, and
repairs. The activities include, but are not limited to, wrecking, demolishing, and
salvaging structures where cadmium or cadmium-containing materials are present;
cutting, brazing, grinding, or welding (Flux on welding rods can contain cadmium
compounds), on surfaces that are painted with cadmium-containing paints (usually
high-heat pipes or vessels); and transporting, storing, and disposing of cadmium or
cadmium-containing materials on the site or location where construction activities
are performed.
Cadmium coatings are sacrificial corrosion protection coatings widely used on steel
and aluminum especially when exposed to alkaline and salt water environments.
They also possess a very low coefficient of friction and low electrical resistivity which
makes them ideal for corrosion protection coatings on threaded fasteners or
electrical connectors. These are most often used in critical or safety related
applications in the aerospace, electrical connector, defense, mining, nuclear, and
off-shore oil and gas industries.
This program also applies to all subcontractors, working under the direct control of
Moreno Group LLC and Subsidiaries, involved with Cadmium/Cadmium Compound
projects and activities. Subcontractors must provide all manpower, supplies,
equipment, training, and medical examination and testing necessary to comply with
this program.
Responsibilities
The Facility Manager/Site Manager/Yard Foreman or Designee is responsible for:
Informing the SH&E Department of the any upcoming project that may have
the potential of containing Cadmium.
.
I8.1

Inform any subcontractors that may be working on the project that the project
contains Cadmium.
Ensure that subcontractors understand and comply with this policy as well as
the Cadmium Employee Project Specific Protection Plan.
The First Line Supervisor is responsible for
Understanding and complying with this policy/ procedure as well as the
Cadmium Employee Project Specific Cadmium Protection Program.
Designating employees for the project and ensuring that those employees all
go to the Human Resources Department to get an authorization to go to the
Medical Review Officer and receive initial blood Cadmium levels prior to
performing any work on the project.
Coordinate with the SH&E Department to see if all designated employees
have received Cadmium training and or up to date. If training is needed
coordinate with the SH&E Department date and time for which training will
take place.
Ensuring that barricade and applicable warning signs have been posted prior
to the startup of the project.
Ensuring that all safety measures are being followed throughout the project.
Performing with the SH&E department the Cadmium Job Checklist and
performing this checklist throughout the project.
Coordinating with the Human Resources Department at the end of the project
or when any employee is removed from the project that those employees all
go to the Medical Review Officer and receive blood Cadmium levels.
The Safety, Health and Environmental Department is responsible for
Coordinating paint samples to have analyzed to determine if project contains
Cadmium.
Informing Facility Manager/Offshore Manager/Yard Foreman or designee of
the outcome of the sample analysis.
Perform any Cadmium training, any respiratory training and fit testing for all
employees that need this training.
Coordinating and performing any air monitoring which may be required.
Developing Cadmium Employee Project Specific Protection Plan.

I8.2

The Human Resources Department is responsible for


Authorizing all employees to go to the Medical Review Officer and receive an
initial blood/urine Cadmium testing as well as a respiratory analysis if needed.
Maintaining all medical records for all employees that will work on the project.
Informing the SH&E department of any employee that is unsuitable to work on
the project due to high Cadmium levels or medical conditions that do not
allow employee to wear a respirator.
Authorizing all employees to return to Medical Review Officer for blood/urine
Cadmium levels once project is complete or if employee has been removed
from project.
The Employee is responsible for
Understanding and complying with this policy/procedure as well as the
Cadmium Employee Project Specific Protection Plan.
Reporting to his immediate supervisor any problem, which may arise, or any
symptoms of Cadmium exposure.
Definitions
Authorized Person Any person who is authorized by the employer and required by
work duties to be present in regulated areas or any person authorized by the OSH
Act or regulations issued under it to be in regulated areas.
Cadmium - In its elemental form, cadmium is either a blue-white metal or a grayishwhite powder found in lead, copper, and zinc sulfide ores, but most cadmium
compounds are highly colored from brown to yellow and red. Some of Cadmiums
uses are: an electrode component in alkaline batteries, a stabilizer in plastics (PVC).
8-hour TWA Concentration - 8-hour Time-Weighted Average concentrations for
airborne contaminants - common units for reporting daily airborne Cadmium
exposures. This is the Cadmium exposure received per day expressed as a
constant exposure for eight (8) hours at a steady state concentration.
HEPA filter - High Efficiency Particular Air filter - Filters that remove 99.97% of all
particulate 0.3 microns or greater in diameter.
g/m - Micrograms per cubic meter of air. Common units for reporting airborne
concentration of Cadmium.
g/100g - Micrograms per 100 grams of whole blood. Common units for reporting
concentrations of Cadmium in blood samples. Also reported as g/dl (micrograms
per deciliter) of whole blood.
I8.3

NIOSH/MSHA - National Institute of Occupational Safety and Health/Mine Safety


and Health Administration - Federal agencies which conduct research on safety and
health issues and test and certify respirators.
Action Level
The Action Level means employee exposure, without regard to the use of
respirators, to an airborne concentration of Cadmium of 2.5 g/m , calculated as an
8-hour TWA.
Whenever workers airborne Cadmium exposures exceed or are expected to exceed
the Action Level, a written compliance program containing the following will be
implemented for the work project:
Authorized person
Employee information and training
Employee medical surveillance
Airborne Cadmium exposure monitoring per the exposure monitoring section
of this policy
Record keeping
The Action Level may be exceeded where Cadmium-containing compounds are
present and the following activities are performed: cadmium refining, casting,
melting, oxide production, sinter plant; crushing, milling, blending and all other
processes; mechanical plating, manual demolition of structures, welding, cutting,
torch burning, installation, removal, or demolition of Cadmium containing materials,
Cadmium burning and Cadmium contamination/emergency cleanup operations.
Permissible Exposure Limit
The Permissible Exposure Limit (PEL) for airborne Cadmium exposure is five (5)
g/m , as an 8-hour TWA concentration. This is the maximum 8-hour average
concentration of Cadmium that an employee may be exposed to during each work
day.
No employee will be exposed to airborne Cadmium above the PEL without proper
protection.
The following methods will be used, as feasible and effective, for maintaining
airborne Cadmium exposures below the PEL:
Engineering controls, such as general area ventilation for containments, local
exhaust ventilation for spot removal, vacuum blasting or vacuum equipped
power tools. When ventilation for containments is used, manometers and/or
velometers, will be used to evaluate the mechanical performance of the
ventilation system
I8.4

Warning signs
Hygiene facilities and practices
Protective work clothing and equipment
Respiratory protection
Housekeeping
During the period that respirators are worn, the protection factor of the specific
respirator may be used to determine employees exposure to airborne Cadmium and
to achieve compliance with the PEL. The protection factors listed in the respirator
selection table of Moreno Group LLC and Subsidiaries Respiratory Protection
Program. For example:
Measured airborne Cadmium concentrations at the workers breathing zone:
30 g/m ,8-hour TWA
Half-mask, air-purifying, negative pressure respirator with HEPA filters worn
all day: protection factor of 10
Employees daily Cadmium exposure: 3 g/m
Authorized Person
All work activities where employee airborne Cadmium exposures may exceed the
Action Level will include an Authorized person in both the planning and performing
stages of projects involving Cadmium exposure.
The Authorized person will be a person with training and experience in construction
jobs involving Cadmium exposure. The Authorized person will have the capability of
identifying hazards and the authority to take immediate action to eliminate them.
The Authorized person will be at the work site at all times while Cadmium exposure
activities are in progress. They may have other job duties, but must be able to
monitor work continuously for hazards or deficiencies, and the authority to take
immediate corrective action.
Employee Information and Training
All employees who work on projects where airborne Cadmium exposures are known
to or expected to be at or above the Action Level will be provided information and
training on the hazards of Cadmium and measures for controlling these hazards and
protecting health.
Employees will receive initial comprehensive Cadmium training before performing
work that may involve airborne Cadmium exposure. This training will be repeated
I8.5

annually as a refresher course. Training records will indicate employees name, date
of the training and name of the person who conducted the training. Training records
will be kept minimum 1 year.
The content of Cadmium training will include:
The specific nature of activities or operations that may result in airborne
Cadmium exposure above the Action Level
The health effects and risks of Cadmium exposure
OSHA standards and guidelines for Cadmium exposure
Engineering controls, including containments and ventilation systems
Work practices for controlling Cadmium exposure, including information,
warning signs, housekeeping, protective clothing and proper hygiene facilities
and practices
Respiratory protection for controlling Cadmium exposure, including fit testing
Methods for monitoring airborne Cadmium concentrations and exposures
The medical surveillance program including medical removal
Precautions for female employees who are pregnant.
Instructions to employees that chelating agents should not be used to remove
Cadmium from their bodies
When conducting Cadmium exposure activities on a multi-employer work site,
Moreno Group LLC and Subsidiaries will notify other employers of the nature of the
Cadmium exposure system in effect, and the potential need to take measures to
protect their employees. Notification to other employers will contain the following:
NOTICE - MORENO GROUP LLC AND SUBSIDIARIES IS PERFORMING
ACTIVITIES AT THIS JOB SITE THAT MAY CREATE AIRBORNE CADMIUM
DUST. ALL CONTRACTORS AT THIS JOB SITE SHALL REMAIN CLEAR OF
ANY CADMIUM EXPOSURE AREA. ACCESS INTO CADMIUM EXPOSURE
AREA IS CONTROLLED BY THE MORENO GROUP LLC AND SUBSIDIARIES
JOB FOREMAN. ONLY TRAINED, QUALIFIED WORKERS ARE PERMITTED TO
ENTER CADMIUM EXPOSURE AREAS AND MUST WEAR RESPIRATORS AND
PROTECTIVE CLOTHING.
Medical Surveillance
All employees who may be exposed to Cadmium at or above the Action Level for 30
or more days per year; or who may be required to wear a respirator will be provided
initial and periodic medical examinations.
I8.6

All employees who may be exposed to Cadmium at or above the Action Level for 30
or more days per year will be provided with initial and periodic biological monitoring
in the form of blood and urine sampling and analysis of Cadmium levels and Beta-2microglobulin in urine (B(2)-M), a low molecular weight protein.
All employees who are temporarily removed from Cadmium exposure due to
elevated blood Cadmium levels or at the recommendation of a physician may be
reassigned other job duties at the site that do not involve exposure to Cadmium
above the Action Level.
The specific components, requirements, and frequencies of medical examination,
blood Cadmium test, and medical removal protection benefits are provided in
Moreno Group LLC and Subsidiaries Medical Surveillance / Examination Program
for Cadmium Exposure and Respirator Use (see Attachment 1)
Warning Signs
Warning signs will be posted in the work area around activities where Cadmium
exposures may exceed the Permissible Exposure Limit. The work area can be
demarcated by Yellow Warning Tape.
Signs will be posted at every accessible side of the work area. These signs will be
easily visible from a distance so that employee can read the sign and take
necessary protective measures before entering the work area. Signs will read as
follows: DANGER, CADMIUM CANCER HAZARD CAN CAUSE LUNG AND
KIDNEY DISEASE, AUTHORIZED PERSONNEL ONLY, RESPIRATORS
REQUIRED IN THIS AREA.
The Authorized person will control access of persons into work area.
All persons entering work areas will wear protective clothing and respirators.
Eating, drinking, smoking, and chewing is prohibited in work areas and any area
where Cadmium exposure may exceed the Permissible Exposure Limit.
Containments
Where required by federal, state, or local regulation, the project sponsor, or the
project owner, containments will be constructed and used as specified.
The purpose of containments is to restrict or prevent the spread of Cadmiumcontaining dust or debris to surrounding areas or the environment. While the proper
use of containments can help protect the public and the environment, they generally
cause a significant increase in airborne Cadmium concentrations in the work area.
Containments may increase the potential for higher employee Cadmium exposures.
Therefore, the use of well designed exhaust ventilation and the use of more
protective respirators may be necessary to properly protect workers.

I8.7

Containments may include any of the following:


Rigid or flexible barriers or sheets surrounding the work area
Complete unventilated enclosures built around the work area
Complete enclosures maintained under negative pressure by exhaust
ventilation with exhaust air filtration
Containments may also require the construction and use of platforms or scaffolding.
These may be stationary or movable, ground supported or suspended.
Personal Hygiene Facilities and Practices
Clean change areas will be provided for all projects where employee airborne
Cadmium exposures may exceed the Permissible Exposure Limit. These clean
change areas will be equipped with storage facilities for street clothing and a
separate area for the removal and storage of Cadmium-contaminated clothing and
equipment. This change area will be designed and used so that contamination of
street clothing does not occur. Airborne Cadmium exposures in the change area will
be maintained below the Action Level.
Shower facilities will be provided for all projects where feasible when employee
Cadmium exposures exceed the Permissible Exposure Limit. Shower facilities will
comply with the OSHA Standard, 29 CFR 1926.51, Sanitation. All employee whose
airborne Cadmium exposures may exceed the Permissible Exposure Limit will
shower or at a minimum wash their hands and face at the end of each work shift.
Employees required to shower will not leave the workplace wearing any clothing
worn while performing Cadmium exposure activities.
Clean lunch areas will be provided for all projects where employee airborne
Cadmium exposures may exceed the Permissible Exposure Limit. Employee will
remove or clean their protective clothing and wash their hands and face before
eating, drinking or smoking. Airborne Cadmium exposures in the lunch area will be
maintained below the Action Level.
An adequate number of clean lavatory and hand washing facilities will be provided.
These will comply with the OSHA Standard, 29 CFR 1926.51, Sanitation.
Where required by federal, state, or local regulation; the project sponsor; or the
project owner; decontamination units will be constructed and used as specified.
These generally are maintained under negative pressure and contain clean change
rooms, showers and dirty equipment rooms.
Protective Clothing and Equipment
Protective clothing and equipment will be worn by all employees whose airborne
Cadmium exposures may exceed the Permissible Exposure Limit. Protective
clothing and equipment will be provided at no cost to the employee.
I8.8

Protective clothing will include washable or disposable full body coveralls. Other
protective equipment will include faceshields, hats, gloves, shoes or disposable shoe
covers, eye protection, and hearing protection as appropriate.
Disposable protective clothing will be used for no more than one (1) work day. They
will be disposed of as Cadmium-contaminated waste.
Reusable coverall will be collected at the end of each work day in closed containers.
Contaminated clothing will be cleaned by authorized laundries according to all
applicable federal, state, or local regulations pertaining to Cadmium-contaminated
laundry and water discharge. All containers of Cadmium-contaminated laundry will
be labeled as follows: CAUTION: CLOTHING CONTAMINATED WITH CADMIUM.
DO NOT REMOVE DUST BY BLOWING OR SHAKING. DISPOSE OF CADMIUM
CONTAMINATED WASH WATER IN ACCORDANCE WITH APPLICABLE LOCAL,
STATE OR FEDERAL REGULATIONS.
Reusable protective clothing (coveralls) worn where the exposure was above the
action level, will be laundered at least weekly, and clean coveralls provided daily to
employees
Protective clothing and equipment will be removed in the contaminated section of
the change area and will not be worn into any clean areas not contaminated with
Cadmium.
Protective clothing and equipment will be worn by all employees performing the
following activities where Cadmium-containing compounds are present unless
exposure monitoring proves otherwise: When abrasive blasting, cleanup of
expendable abrasives, abrasive blasting enclosure construction, movement and
removal, power tool cleaning with and without dust collection systems, manual
scraping, manual sanding, manual demolition of structures, heat gun applications,
welding,
cutting,
torch
burning,
chemical
stripping
and
Cadmium
contamination/emergency clean-up activities.
Emergency situations
In the event of emergency situations involving substantial releases of airborne
cadmium, the use of appropriate respirators and personal protective equipment will
be utilized. In addition, employees not essential to correcting the emergency
situation shall be restricted from the area and normal operations halted in that area
until the emergency is abated. Emergency plans shall be noted on Project Specific
Requirements (Attachment 2).
Respiratory Protection
Respiratory protection will be used in combination with engineering controls and
work practices to maintain employee airborne Cadmium exposures below the
Permissible Exposure Limit.

I8.9

Respirators will be worn by all employees, other contractors, inspectors, or


observers who may be exposed to airborne Cadmium at or above the Permissible
Exposure Limit.
The selection, use, maintenance, and inspection of respirators will be according to
Moreno Group LLC and Subsidiaries Respiratory Protection Program. Qualifications
for respirator users are also contained in this program. Select respirators from the
types listed below in Table 1. Any respirator chosen must be approved by the Mine
Safety and Health Administration (MSMA) or the National Institute for Occupational
Safety and Health (NIOSH).

I8.10

Table 1 Respiratory Protection for Cadmium Aerosols


Airborne Concentration of Cadmium or
Condition of Use
Not in excess of 50 ug/m3

Not in excess of 125 ug/m3

Airborne Concentration of Cadmium or


Condition of Use
Not in excess of 250 ug/m3

Respirator Required
mask air purifying respirator with
HEPA filters2,3
mask supplied air respirator
operated in demand (negative
pressure mode.)
Loose fitting hood or helmet
powered air-purifying respirator
with HEPA filters.3
Hood or helmet supplied air
respirator operated in continuous
flow mode that is type CE abrasive
blasting respirators operated in
continuous flow mode.
Respirator Required

Full facepiece air purifying


respirator with HEPA3
Tight fitting powered air-purifying
respirator with HEPA
Full facepiece supplied air
respirator operated in demand
mode.
mask or full facepiece supplied
air respirator operated in a
continuous-flow mode.
Full facepiece self-contained
breathing apparatus (SCBA)
operated in demand mode.
Not in excess of 5,000 ug/m3
mask supplied air respirator
operated in pressure demand or
other positive-pressure mode.
3
Not in excess of 10,000 ug/m
Full facepiece supplied air
respirator operated in pressure
demand or other positive pressure
mode, that is, type CE abrasive
blasting respirators operated in a
positive-pressure mode.
3
Greater than 10,000 ug/m , known
Full facepiece SCBA operated in
concentration, or fire fighting
pressure demand or other positive
pressure mode.
1
Respirators specified for higher concentrations can be used at lower concentrations
of Cadmium.
2
Full facepiece is required if the Cadmium aerosols cause eye or skin irritation at the
use concentration.
3
A high efficiency particulate filter (HEPA) means a filter that is 99.97 percent
efficient against particles of 0.3 microns size or larger.
I8.11

Exposure Monitoring
For each work project, personal air samples will be collected to determine airborne
Cadmium exposures to employees performing tasks involving Cadmium exposure.
Full shift (at least 7 hours) air samples will be collected for each job classification in
each work area. The air samples will be taken for the shift with the highest expected
exposure level. Moreno Group LLC and Subsidiaries will implement employee
protective measures until results of the employee exposure assessment are
received. The Authorized person will be responsible to ensure that exposure
monitoring is performed.
Where initial monitoring indicates that Cadmium exposures are below the Action
Level, and where work activities and conditions will remain the same as at the time
of initial sampling, additional monitoring need not be repeated for that work project.
A written record of the air monitoring data will be kept at the job site.
Where initial monitoring indicates that Cadmium exposures are at or above the
Action Level but at or below the PEL, additional representative exposure monitoring
will be conducted at least once every six (6) months for that work project. Where
initial monitoring indicates that Cadmium exposures are above the PEL, Moreno
Group LLC and Subsidiaries shall include in the written notice a statement that the
PEL has been exceeded and a description of the corrective action being taken by
the employer to reduce employee exposure to or below the PEL.
Additional monitoring shall be conducted whenever there has been a change in the
raw materials, equipment, personnel, work practices, or finished products that may
result in additional employees being exposed to cadmium at or above the action
level or in employees already exposed to cadmium at or above the action level being
exposed above the PEL, or whenever the employer has any reason to suspect that
any other change might result in such further exposure.
All air samples will be collected and analyzed according to NIOSH 7082 Method or
equivalent. All samples will be analyzed by laboratories accredited under the
Laboratory Accreditation Program of the American Industrial Hygiene Association for
metals analysis.
All exposed employees will be notified in writing of the monitoring results within five
(5) days after receiving these results.
Initial exposure monitoring may not be required when previously collected data has
conclusively determined that current job condition exposure levels will be less than
the Action Level.
Housekeeping
Accumulations of Cadmium-containing dust and debris generated by work activities
will be removed and cleaned daily.
All persons doing the clean-up will be trained in performing Cadmium activities,
respirator qualified, and participate in the medical surveillance program. Respirators
I8.12

and protective clothing will be worn by all persons doing the cleanup unless
exposure monitoring proves otherwise.
Wherever feasible, HEPA-filtered vacuum cleaners will be used for housekeeping.
All Cadmium-containing dust and debris will be collected into sealed containers.
The waste will be tested to determine whether it will be disposed as hazardous or
non-hazardous waste. Containers will be labeled as follows: DANGER CONTAINS
CADMIUM, CANCER HAZARD, AVOID CREATING DUST, CAN CAUSE LUNG
AND KIDNEY DAMAGE
Employees will not be permitted to remove Cadmium-containing dust from protective
clothing or equipment by blowing, shaking, or by any other means which disperses
Cadmium in the air.
Project Specific Requirements
The specific worker Cadmium protection requirements for each Cadmium-removal
project will be determined by Moreno Group LLC and Subsidiaries, the project
sponsor, and the project owner. The job specific requirements will be placed in
Attachment 2 - Cadmium Removal Project Specific Requirements. Enough detail
will be provided as to accurately outline the job specific requirements. This
attachment will be posted at the job site and maintained with the work records of the
project.
Recordkeeping
All records relating to training, medical examinations, blood Cadmium monitoring,
exposure monitoring, and project specific requirements will be maintained by
Moreno Group LLC and Subsidiaries, for the employees length of employment plus
30 years.
Other Relevant Information
The compliance program will be kept available at the work site for examination by an
affected employee or authorized person/agency.
The compliance program will be revised and updated at least annually.

I8.13

Attachment 1

I8.14

Medical Surveillance/Examination Program For


Cadmium Exposure And Respirator Use
Purpose
To establish and implement a program that meets, in substance, the medical
surveillance requirements of the OSHA Construction Industry Cadmium Standard,
29 CFR 1926.63 and by the OSHA Respiratory Protection Standard, 29 CFR
1926.103.
Scope
This program applies to all Moreno Group LLC and Subsidiaries, employees who
may be exposed to Cadmium in the course of their work and who are required to
wear respirators.
This program also applies to all subcontractors working under the direct control of
Moreno Group LLC and Subsidiaries Subcontractors must provide all manpower,
medical examination and testing, and other resources necessary to comply with this
program.
This program combines the medical surveillance and examination requirements of
the OSHA Construction Industry Cadmium Standard and the Respiratory Protection
Standard into one unified program.
Requirements
All medical examination will be conducted by or under the supervision of a licensed
physician.
All medical examination will be provided at no cost to the employee and at a
reasonable time and place.
Moreno Group LLC and Subsidiaries will provide the following information to the
examining physician:
A copy of the OSHA Construction Cadmium Standard, 29 CFR 1926.63,
including all Appendices.
A description of the employees duties as they relate to Cadmium exposure.
The employees representative or anticipated exposure level to Cadmium and
any other toxic substance they may be exposed to at work.
A description of any protective clothing and respirators to be used.
Information from previous examination(s) performed for Cadmium
exposure or respirator use, including past blood Cadmium results,
including all prior written medical opinions concerning the employee,
I8.14.a.1

that may be in the possession or control of Moreno Group LLC and


Subsidiaries.
Medical examinations provided by other employers or groups may be accepted by
Moreno Group LLC and Subsidiaries provided the following conditions are met:
The employee agrees to release all medical record of these examinations and
tests to Moreno Group LLC and Subsidiaries or their medical examination
provider.
All medical examinations and tests specified in this program were performed.
The physicians medical opinion is reviewed by Moreno Group LLC and
Subsidiaries medical provider or an additional medical opinion is provided.
Records of medical examinations and tests are confidential medical records.
Access to these records by employees, their designated representatives, or other
parties will be according to 29 CFR 1926.63, Access to Employee Exposure and
Medical Records.
Medical Surveillance
All medical surveillance will be performed by or under the supervision of a licensed
physician.
Initial Examination
Moreno Group LLC and Subsidiaries shall provide an initial (preplacement)
examination to all employees covered by the medical surveillance program required
in 29CFR1910.1027 (l)(1)(i) . The examination shall be provided to those employees
within 30 days after initial assignment to a job with exposure to cadmium or no later
than 90 days after the effective date of this section, whichever date is later.
Initial Exams will include the following:
A detailed medical and work history, with emphasis on: past, present, and
anticipated future exposure to cadmium; any history of renal, cardiovascular,
respiratory, hematopoietic, reproductive, and/or musculo-skeletal system
dysfunction; current usage of medication with potential nephrotoxic sideeffects; and smoking history and current status; and
Biological monitoring that includes, Cadmium in urine (CdU), standardized to
grams of creatinine (g/Cr); Beta-2 microglobulin in urine (B(2)-M),
standardized to grams of creatinine (g/Cr), with pH specified, as described in
Appendix F of the Satndard; Cadmium in blood (CdB), standardized to liters
of whole blood (lwb).

I8.14.a.2

Recent Examination
An initial examination is not required to be provided if adequate records show that
the employee has had an Initial Exam as outlined above within the past 12 months.
In that case, such records shall be maintained as part of the employee's medical
record and the prior exam shall be treated as if it were an initial examination.
Periodic Examinations
For currently exposed employees, who are subject to medical surveillance under
29CFR1910.1027 (l)(1)(i)(A), Moreno Group LLC and Subsidiaries shall provide the
minimum level of periodic medical surveillance which consists of periodic medical
examinations and periodic biological monitoring. A periodic medical examination
shall be provided within one year after the initial examination and thereafter at least
biennially. Biological sampling shall be provided at least annually, either as part of a
periodic medical examination or separately as periodic biological monitoring.
Periodic Medical Exams will include the following:
A detailed medical and work history, or update thereof, with emphasis on:
past, present and anticipated future exposure to cadmium; smoking history
and current status; reproductive history; current use of medications with
potential nephrotoxic side-effects; any history of renal, cardiovascular,
respiratory, hematopoietic, and/or musculo-skeletal system dysfunction; and
as part of the medical and work history, for employees who wear respirators,
questions 3-11 and 25-32 in Appendix D;
A complete physical examination with emphasis on: blood pressure, the
respiratory system, and the urinary system;
A 14 inch by 17 inch, or a reasonably standard sized posterior-anterior chest
X-ray (after the initial X-ray, the frequency of chest X-rays is to be determined
by the examining physician);
Pulmonary function test of forced vital capacity and forced expiratory volume.
Tests for blood pressure and resting heart rate.
Blood sample and analysis for Cadmium level; Cadmium in urine (CdU),
standardized to grams of creatinine (g/Cr); Beta-2 microglobulin in urine
(B(2)-M), standardized to grams of creatinine (g/Cr), with pH specified, as
described in Appendix F of the standard; and Cadmium in blood (CdB),
standardized to liters of whole blood (lwb).
Blood analysis, in addition to the analysis required under paragraph
(l)(2)(ii)(B), including blood urea nitrogen, complete blood count, and serum
creatinine;

I8.14.a.3

Urinalysis, in addition to the analysis required under paragraph (l)(2)(ii)(B),


including the determination of albumin, glucose, and total and low molecular
weight proteins;
For males over 40 years old, prostate palpation, or other at least as effective
diagnostic test(s); and
Any additional tests deemed appropriate by the examining physician.
Currently Exposed Employees
For currently exposed employees, who are subject to medical surveillance under
29CFR1910.1027 (l)(1)(i)(A), Moreno Group LLC and Subsidiaries shall provide the
minimum level of periodic medical surveillance as outlined above.
Emergency Examinations
In addition to the medical surveillance program in this section, Moreno Group LLC
and Subsidiaries shall provide a medical examination as soon as possible to any
employee who may have been acutely exposed to cadmium because of an
emergency. The examination shall include the requirements listed above, with
emphasis on the respiratory system, other organ systems considered appropriate by
the examining physician, and symptoms of acute overexposure; symptoms may
include mild irritation of the upper respiratory tract, a sensation of constriction of the
throat, a metallic taste and/or a cough.
A period of 1-10 hours may precede the onset of rapidly progressing shortness of
breath, chest pain, and flu-like symptoms with weakness, fever, headache, chills,
sweating and muscular pain. Acute pulmonary edema usually develops within 24
hours and reaches a maximum by three days.
Termination of employment examination
At termination of employment, the employer shall provide a medical examination in
accordance with the Periodic Examination section of this policy, including a chest Xray, to any employee to whom at any prior time the employer was required to
provide medical surveillance. However, if the last examination satisfied the
requirements of the Periodic Examination section of this policy and was less than six
months prior to the date of termination, no further examination is required unless
other actions were triggered in Initial Biological Monitoring or Medical Examinations.
For employees previously exposed, if the employer has discontinued all periodic
medical surveillance, no termination of employment medical examination is required.
Blood Cadmium Monitoring
Along with the initial and annual medical examinations have been addressed,
Moreno Group LLC and Subsidiaries will provide periodic biological monitoring for
Cadmium levels to each employee exposed to Cadmium above the Action Level.

I8.14.a.4

Blood Cadmium analysis will be performed by laboratories licensed by the US


Center for Disease Control (CDC) or which has received a satisfactory grade in
blood Cadmium proficiency testing from the CDC in the prior twelve (12) months.
If the employee's levels of CdU did not exceed 3 ug/g Cr and CdB did not exceed 5
ug/lwb, and B(2)-M did not exceed 300 ug/g Cr in the initial biological monitoring
tests, and if the results of the followup biological one year after the initial
examination confirm the previous results, the employer may discontinue all periodic
medical surveillance for that employee.
If the initial biological monitoring results for CdU, CdB, or B(2)-M were in excess of
the levels specified in (l)(3)(i), but subsequent biological monitoring results required
by (l)(3)(ii)-(iv) show that the employee's CdU levels no longer exceed 3 ug/g Cr,
CdB levels no longer exceed 5 ug/lwb, and B(2)-M levels no longer exceed 300 ug/g
Cr, the employer shall provide biological monitoring for CdU, CdB, and B(2)-M one
year after these most recent biological monitoring results. If the results of the
followup biological monitoring, specified in this paragraph, confirm the previous
results, the employer may discontinue all periodic medical surveillance for that
employee.
However, if the results of the follow-up tests indicate that the level of the employee's
CdU, B(2)-M, or CdB exceeds these same levels, the Moreno Group LLC and
Subsidiaries will provide annual medical examinations until the results of biological
monitoring are consistently below these levels or the examining physician
determines in a written medical opinion that further medical surveillance is not
required to protect the employee's health.
A routine, biennial medical examination is not required to be provided if adequate
medical records show that the employee has been examined within the past 12
months.
In that case, such records shall be maintained by the employer as part of the
employee's medical record, and the next routine, periodic medical examination shall
be made available to the employee within two years of the previous examination.
Employee will be informed in writing of their blood test results within five (5) working
days after receiving results. A statement that the physician has clearly and carefully
explained to the employee the results of the medical examination, including all
biological monitoring results and any medical conditions related to cadmium
exposure that require further evaluation or treatment, and any limitation on the
employee's diet or use of medications. Moreno Group LLC and Subsidiaries shall
promptly obtain a copy of the results of any biological monitoring provided by them
to an employee independently of a medical examination and, in lieu of a written
medical opinion, an explanation sheet explaining those results. Moreno Group LLC
and Subsidiaries shall instruct the physician not to reveal orally or in the written
medical opinion given to the employer specific findings or diagnoses unrelated to
occupational exposure to cadmium.

I8.14.a.5

Medical Removal Program


Employees shall be temporarily removed from work where there is excess exposure
to cadmium on each occasion that medical removal is required by actions triggered
by initial biological monitoring; periodic medical surveillance, or examination for
respirator use and on each occasion that a physician determines in a written medical
opinion that the employee should be removed from such exposure. The physician's
determination may be based on biological monitoring results, inability to wear a
respirator, evidence of illness, other signs or symptoms of cadmium-related
dysfunction or disease, or any other reason deemed medically sufficient by the
physician.
Employees temporarily removed from Cadmium exposure activities may be
assigned to other duties on-site that do not involve Cadmium exposure above the
Action Level.
For any employee who is medically removed from cadmium exposure activities,
Moreno Group LLC and Subsidiaries shall provide follow-up biological monitoring at
least every three months and follow-up medical examinations semi-annually at least
every six months until in a written medical opinion the examining physician
determines that either the employee may be returned to his/her former job status or
the employee must be permanently removed from excess cadmium exposure.
Respirator Use
Respirator Requirements. Respirators will be provided whenever an employees
exposure to Cadmium exceeds the Permissible Exposure Level, in work situations in
which engineering controls and work practices are not sufficient to reduce exposures
to or below the PEL, and whenever an employee requests a respirator.
Respirators will be selected from those approved for protection against Cadmium
dust, fume, and by the Mine Safety and Health Administration and the National
Institute for Occupational Safety and Health.
Respirators or combinations of respirators that will provide adequate protection to
the employee will be chosen by the Authorized person based on OSHA Industry
Cadmium Standard 29 CFR 1910.1027.
Each employee will be required to wear a half-mask, negative pressure respirator
will be qualitatively fit tested every six (6) months on the specific respirator that will
be used. Fit test procedures specified in the OSHA Construction Industry Cadmium
Standard, 29 CFR 1926.63, Appendix C will be followed. Full facepiece negative
pressure respirator will be quantitatively fit tested in accordance with Appendix C of
the standard.
Medical Exam - Requirements for respirator users will include examinations and
tests as deemed necessary by the examining physician to ensure the ability to wear
and utilize respiratory protection. These tests will be provided annually to
employees assigned to wear a respirator.

I8.14.a.6

Physicians Written Opinion - Medical Examinations


For each examination, Moreno Group LLC and Subsidiaries will obtain a written
opinion from the examining physician that contains the following:
Whether the employee has a detected medical condition that places them at
an increased risk or health effects from exposure to Cadmium
Any special protective measures to be provided to the employee or limitations
to be placed on the employees exposure to Cadmium
Whether the employee is medically qualified to wear a respirator and any
limitations of use, especially concerning negative pressure respirators
A statement that the employee has been informed by the physician of the
results of the medical examination, blood tests, urine tests, and of any
medical conditions that may result from Cadmium exposure
Moreno Group LLC and Subsidiaries will provide a copy of the examination and test
results and the physicians written opinion to the employee immediately after its
receipt.
Medical records of examinations and tests will be retained by Moreno Group LLC
and Subsidiaries for the employees length of employment plus 30 years.

I8.14.a.7

Attachment 2

I8.15

Moreno Group LLC and Subsidiaries Cadmium Exposure


Project Specific Requirements
PROJECT _______________________________________________________________
LOCATION ______________________________________________________________
DATES

_________________________________________________________________

SITE AUTHORIZED PERSON _______________________________________________


DESCRIPTION OF EACH ACTIVITY EMITTING CADMIUM ________________________
_________________________________________________________________________
EQUIPMENT USED _______________________________________________________
_________________________________________________________________________
WORKER TRAINING REQUIRED ____________________________________________
MEDICAL SURVEILLANCE REQUIRED _______________________________________
MECHANICAL VENTILATION EFFECTIVENESS ________________________________
_________________________________________________________________________
CADMIUM WORK AREA LOCATIONS ________________________________________
WARNING SIGNS NEEDED _________________________________________________
HYGIENE FACILITIES _____________________________________________________
EXPOSURE ASSESSMENT CONDUCTED _____________________________________
EXPOSURE ASSESSMENT RESULTS ________________________________________
ADEQUATE RESPIRATORY PROTECTION ____________________________________
RESPIRATORY FIT TEST REQUIRED ________________________________________
RESPIRATORY FIT TEST PERFORMED ______________________________________
PROTECTIVE CLOTHING __________________________________________________
HEPA VACUUMS NEEDED _________________________________________________
EMPLOYEE JOB RESPONSIBILITIES _________________________________________
_________________________________________________________________________
_________________________________________________________________________
I8.15.a.1

OPERATING PROCEDURES FOR WORKER DECONTAMINATION, DISPOSAL OF


PROTECTIVE CLOTHING, CLEANING EQUIPMENT, ETC... _______________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
EMPLOYEE NAME(S) _____________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
JOB DURATION AND EXPOSURE LEVELS ____________________________________
_________________________________________________________________________
OTHER CADMIUM REDUCTION ADMINISTRATIVE CONTROLS ___________________
_________________________________________________________________________
_________________________________________________________________________

I8.15.a.2

ALL CONTRACTORS ON SITE INFORMED OF POTENTIAL CADMIUM EXPOSURE


A DESCRIPTION OF THE SPECIFIC MEANS THAT WILL BE EMPLOYED TO ACHIEVE
OSHA COMPLIANCE.

IF ENGINEERING CONTROLS ARE REQUIRED, LIST THE

ENGINEERING PLANS AND STUDIES USED TO DETERMINE THE METHODS


SELECTED FOR CONTROLLING EXPOSURE(S) TO CADMIUM ____________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
LIST THE TECHNOLOGY CONSIDERED IN MEETING THE PEL ___________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
SCHEDULE FOR IMPLEMENTATION OF THE COMPLIANCE PROGRAM

___________

_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
EMERGENCY PLANS ______________________________________________________
_________________________________________________________________________
_________________________________________________________________________
CONSTRUCTION CONTRACTS/PURCHASE ORDERS

__________________________

_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________

I8.15.a.3

Moreno Group LLC


and Subsidiaries
SH&E Management
System

Fitness to Work

Page: 1 of 11
Original: 01/01/2006
Revised: 02/01/2010

Fitness to Work
Purpose
The purpose of this standard is to assure that employees are and remain able to
safely perform the essential functions of their jobs and arises out of concern that an
employee may have a health problem which could impact his or her ability to safely
and environmentally friendly perform the essential functions of his or her job and to
establish requirements and recommendations related to employee fitness to
continue work under such circumstances or return to work after illness or injury
which can reasonably be anticipated to affect the employees ability to perform the
essential functions of his or her job. This standard is intended to further both
offshore and onshore safety while complying with all state and federal laws such as
the Family Medical Leave Act and Americans with Disabilities Act.
Scope
The scope of this program describes the implementation of Moreno Group LLC and
Subsidiaries Fitness to Work Evaluations. The Fitness to Work Evaluations will
include both salary and hourly employees.
Responsibilities
The Facility Manager / Offshore Manager or designee is responsible for:
Understanding and complying with the requirements of this procedure.
Ensuring that personnel are informed of Moreno Group LLC and Subsidiaries
Fitness to Work Evaluations.
Verifying need for Fitness to Work when the employee has taken prescription
medicine or experienced an off the job injury, accident or sickness which can
reasonably be anticipated to affect the employees ability to perform the
essential functions of his or her job.
Informing the Human Resource Department of an employees need for a
Fitness to Work Evaluation under this program.
Consulting with the Human Resource Department and / or the SH&E
Department as necessary concerning employees taking prescription
medicine.
Approving or disapproving of work that exceeds the 2-hour extension or 3
consecutive days limits.
I9.1

The First Line Supervisor / Offshore Coordinator / Offshore Superintendent or


designee is responsible for:
Understanding and complying with this procedure.
Verifying when employees are taking prescription medicine, experienced an
off the job injury, accident or sickness.
Conferring with Facility Management / Offshore Management as to their
employees taking prescription medicine and / or experiencing an off the job
injury, accident or sickness which can be reasonably anticipated to affect their
ability to perform the essential function of their jobs.
For observing and monitoring employees physical and mental abilities to
perform the essential function of their jobs.
Notifying of the Facility Manager or Offshore Manager if employees work
activities will exceed the 2-hour work extension (i.e. greater than 16 hours) or
3 consecutive days of 16 hours.
The Safety, Health and Environmental Department is responsible for:
Providing assistance to the Facility Manager / Offshore Manager or designee
and the Human Resource Department through communication with Moreno
Group LLC and Subsidiaries Company Physician to the extent necessary to
comply with or implement this policy.
Providing assistance to the Human Resource Department in determining what
medical examinations are required and at what frequency.
The Human Resource Department is responsible for:
Establishing protocols with Moreno Group LLC and Subsidiaries Company
Physician concerning Fitness to Work Evaluations including the establishment
of a Cautionary Prescription Medication List.
Requesting Company Physicians verification of employees ability to continue
or return to work while taking prescription medicine or upon the employees
return to work following an illness or injury which can reasonably be
anticipated to affect the employees ability to perform the essential functions
of his or her job.
Maintaining all records as required by applicable laws and regulations.

I9.2

The Employee is responsible for:


Prior to starting or accepting an offshore job, or coming to work for
onshore workers, and for the duration of employment shall notify their
Offshore Superintendent or Offshore Coordinator / First Line Supervisor that
he or she is taking prescription or over the counter medication or has
experienced an on or off the job injury, accident or illness which he or she
reasonably believes might affect his or her ability to perform the essential
functions of his or her job.
Requirements
Under Moreno Group LLC and Subsidiaries Fitness to Work program evaluations will
be performed by our Company Physician under the following situations:
Post Job Offer and Acceptance
An applicant who has been offered and has accepted employment contingent upon
the successful completion of medical examination is required to meet all applicable
Fitness to Work Evaluations requirements (see Attachment 1) identified for his or her
prospective job assignment.
Change in Working Conditions of Job Assignment
An employee who has a substantial change in working conditions or job assignment
is required to meet all applicable Fitness to Work Evaluation requirements identified
for his or her prospective job assignment.
Substantial Change in Health Status
An employee who has experienced an off the job injury, accident or illness (but not
limited to fractures to bones, back injuries, sprains, significant car accidents, heart
attack, etc.) which can reasonably be anticipated to affect the employees ability to
perform the essential functions of his or her job.
Performance-Initiated Review
When First Line Supervisor / Offshore Superintendent or Offshore Coordinator or
other supervisory personnel have observed and identified failing or unsafe job
performance which is believed to be related to an employees taking prescription or
over the counter medication or otherwise related to the physical or mental which can
be anticipated to further affect the employees ability to perform the essential
functions of his or her job.
Continuing Impairment
When an employee remains absent from work for a prolonged period and must be
reassessed to update disability status for short term / long term disability, Family
Medical Leave Act and other similar leaves or absence.
I9.3

Return to Work
Before an employees return to work following any substantial illness, injury or
absence (but not limited to fractures to bones, back injuries, sprains, significant car
accidents, heart attack, etc.) which can reasonably be anticipated to affect the
employees ability to safely perform the essential functions of his or her job.
Overseas Assignments
Before an employee may accept an overseas assignment, they must first be
evaluated by the Company Physician to ensure the employees health is acceptable
for an overseas assignment.
Upon passing the physical for their overseas assignment, the employee will be
required to start the appropriate Immunizations for the country they will be traveling
to and working. These vaccines are recommended to protect travelers from illnesses
present in other parts of the world and to prevent the importation of infectious
diseases across international borders.
Vaccinations needed depends on a number of factors including destination, whether
our employees will be spending time in rural areas, the season of the year, the
employees age, the employees health status, and previous immunizations.
The vaccinations required for the destination will be confirmed by the Company
Physician and utilizing the CDC website (www.cdc.gov).
Other situations a Fitness to Work Evaluation may be required
When the employee's First Line Supervisor / Offshore Superintendent or Offshore
Coordinator observes and identifies or otherwise becomes aware of any medical
condition which can be anticipated to further affect the employees ability to safely
perform the essential functions of his or her job (e.g. such as the employee being
subject to unpredictable sudden unconsciousness in a hazardous situation). When
the employees observed and identified physical or mental condition can be
anticipated to subject the employee, co-workers, or the public to a substantial risk of
harm.
Procedure for Fitness to Work Evaluations
1) Human Resources Department is to obtain completed medical questionnaire
from all prospective employees and current employees who meet terms for
Fitness to Work Evaluations.
2) Human Resources Department is to arrange Substance Abuse Screening Test
for all prospective employees in adherence to Moreno Group LLC and
Subsidiaries Drug and Alcohol Policy.
3) Human Resources Department to arrange Medical Examination as part of the
conditional job offer acceptance process and for current employees who meet
terms for Fitness to Work Evaluations.
I9.4

4) Human Resources Department is to arrange a specific fitness, strength, and /


or other tests for any prospective employees that may merit further evaluation
based on observed or disclosed physical or mental conditions which can
reasonably be anticipated to affect the employees ability to perform the
essential functions of his or her job. Such test may include requesting the
prospective employee to describe or demonstrate how the employee can
perform specific and essential job related tasks with or without reasonable
accommodation.
Supervisor shall be aware of situations that indicate that an employee is not fit for
work. Some examples may include the following:
Failure to meet and/ or safely perform the essential functions of the job or the
requirements set forth in this Standard.
Physical inability to obtain or failure to maintain their certification for the
applicable job function.
Physical inability to evacuate per a locations emergency evacuation
procedure, and/or inability to fit or mobilize into an offshore platforms
emergency evacuation equipment.
Failure of Respirator Questionnaire, Pulmonary Function Exam, Chest XRays, Blood Work, etc.) for employees whose use of respirators is a required
aspect of their job (i.e. work in H2S environments, sand blasting and painting
operations, tank cleaning operations, certain welding operations, rescue
services, etc.).
Inability to physically perform duties as Rescue team member or other duties
placing unique physical demands on the employee.
First Line Supervisors, Offshore Superintendents or Offshore Coordinators shall
address Fitness to Work issues and situations by discussing them with their
immediate Manager, the Human Resources Department and SH&E Department as
necessary to ensure that the Fitness to Work issue is job related and necessary for
the employees performance of the essential functions of his job (within ADA
Compliance).
The issue should first be discussed with the involved employee and then with the
appropriate Management.
When discussing the issue the following aspects of American with Disabilities Act
(ADA) should be taken into consideration:
ADA prevents us from requiring medical exams and from asking disabilityrelated questions of the general employee population.
Medical examinations and disability-related questions may be asked on a
case-by-case basis in for cause situations where the employees supervisor
I9.5

has reliable and objective evidence indicating there may be a fitness-related


problem with an employee that poses a substantial risk of injury to the
employee, co-workers or assets.
ADA generally allows non-disability-related questions, e.g.:
- Can you perform these job functions?
- How are you feeling?
- Have you recently consumed alcohol? etc.
It also allows us to ask employees to perform tests that are not considered to be
medical evaluations, such as a drug tests and physical agility test when job related
and consistent with business necessity.
Fatigue Management
All individuals shall meet the following requirements for managing the risks
associated with fatigue:
Work shall be planned such that no one is scheduled to work for more than
14 continuous hours, including breaks. When unforeseen circumstances
require an employee to work beyond this limit the following requirements must
be met:
First Line Supervisors or Offshore Superintendents may be allowed a 2-hour
extension, after ensuring controls are in place to recognize and manage
fatigue.
Should the work activities exceed the 2-hour extension, the First Line
Supervisor or Offshore Superintendent must immediately notify their Facility
Manager or Offshore Manager for approval to continue their work activities.
No work activities shall exceed 18 hours unless prior approval is obtained
from the Vice President of the Division performing the work.
No employee shall continue work activities in excess of 16 continuous hours
including approvals or more for 3 consecutive days. Should the work activities
exceed this requirement, the First Line Supervisor or Offshore Superintendent must
immediately notify their Facility Manager or Offshore Manager for specific approval
to continue their work activities. After 3 consecutive days a 12 hour shift should be
worked.
Facility Manager / Offshore Manager approval is required if the 2-hour
extension or 3 consecutive days limits are to be exceeded. Should the 2hour extension need to be exceeded to finish a task, prior approval from the
Vice President over the Division shall be required.
All DOT Hazmat Drivers, Truck Drivers shall be limited to the DOT Regulation
for hours of service. Each driver will be responsible for maintaining their
individual trip logs to verify compliance with DOT regulations.

I9.6

The table below outlines the hours of service a DOT Covered Drivers my work/drive:
1. Drivers may drive up to 11 hours in the 14-hour on-duty window after they
come on duty following 10 or more consecutive hours off duty.
2. The 14-hour on-duty window may not be extended with off-duty time for
meal and fuel stops, etc.
3. The prohibition on driving after being on duty 60 hours in 7 consecutive
days, or 70 hours in 8 consecutive days, remains the same, but drivers can
"restart" the 7/8 day period anytime a driver has 34 consecutive hours off
duty.
4. CMV drivers using the sleeper berth provision must take at least 8
consecutive hours in the sleeper berth, plus 2 consecutive hours either in
the sleeper berth, off duty, or any combination of the two.
The table below outlines the hours of service for a passenger carrying vehicles:
Moreno Group LLC and Subsidiaries shall permit or require any driver used to
drive a passenger-carrying commercial motor vehicle, nor shall any such driver
drive a passenger-carrying commercial motor vehicle:
1. More than 10 hours following 8 consecutive hours off duty; or
2. For any period after having been on duty 15 hours following 8 consecutive
hours off duty
Moreno Group LLC and Subsidiaries shall permit or require a driver of a
passenger-carrying commercial motor vehicle to drive, nor shall any driver drive a
passenger-carrying commercial motor vehicle, regardless of the number of motor
carriers using the driver's services, for any period after
1. Having been on duty 60 hours in any 7 consecutive days if the employing
motor carrier does not operate commercial motor vehicles every day of the
week; or
2. Having been on duty 70 hours in any period of 8 consecutive days if the
employing motor carrier operates commercial motor vehicles every day of
the week.
Each individual employee is personally responsible for managing the risks
associated with prolonged working hours and shall discuss any concerns with
their supervisor. The supervisor is responsible for appropriate addressing on
the employees concerns.
Rest Breaks
In an effort to minimize the potential for fatigue, breaks will be provided on a
designated frequency. During the summer months, First Line Supervision will be
responsible for evaluating the need and providing if warranted, additional breaks to
minimize the potential for heat related illnesses and/or fatigue.

I9.7

Return to Work from Doctors Care


Facility Manager / Offshore Managers or designee shall ensure that
personnel returning from a prolonged injury or illness must be able to safely
perform the essential functions of their job.
An employee should not be returned to work if the employee is not released
to full duty without prior approval of Facility Management or Offshore
Manager.
Prescription and Over the Counter Medications
To maximize SH&E in the work environment, and to help minimize employees
working while taking medications which can reasonably be anticipated to affect the
employees ability to perform the essential functions of his or her job, all employees
are required to certify at the beginning of each offshore assignment that they are
taking no prescription or over the counter medications which may affect their ability
to perform the essential functions of their jobs. Employees will be required to certify
their job by completing and submitting the Medical Questionnaire (See Attachment
2) to their First Line Supervisor or other designated supervisory personnel at the
SH&E meeting prior to beginning work assignments for offshore employees and
annually for onshore employees. Onshore employees will certify daily utilizing
Moreno Group LLC and Subsidiaries SH&E Meeting Form (onshore) that there has
not been a change in their fitness or health. If a change has occurred, a new Fitness
to Work Certification shall be completed and evaluated.
Employees who are taking prescription or over the counter medications are required
to notify their Offshore Coordinator or First Line Supervisor prior to accepting an
assignment offshore or prior to starting work onshore if the use of such medication
may affect their ability to perform the essential function of their jobs.
All employees who are routinely called upon to operate vehicles, machinery or
equipment which may cause injury to himself or others, must also notify their
Offshore Coordinator or First Line Supervisor, prior to accepting an assignment
offshore or prior to starting work onshore or prior to the operations of such a vehicle,
machinery or equipment, of any medication the employee is taking which warns
against the use of vehicles or other machinery or equipment.
Upon notification of an employees use of any medication which can reasonably be
anticipated to affect the employees ability to perform the essential functions of his or
her job, whether by the employees submission of the Medical Questionnaire or
through any other means (i.e. Drug Screen, etc.), the employees Offshore
Superintendent, Offshore Coordinator or First Line Supervisor shall advise Human
Resources of the employee taking such prescription or other medication.
The Offshore Superintendent or Offshore Coordinator or First Lines Supervisor shall
provide to the Human Resource Department or designee the following information:
Full Name and Correct Spelling of the prescription and over the counter
medications taken by the employee which can reasonably be anticipated to
affect the employees ability to perform the essential functions of his or her
job.
I9.8

The dosage of each medication


For prescription medications the frequency the medication is to be taken (i.e.
1 tablet a day, etc.)
The Human Resource Department or designee shall contact Moreno Group LLC and
Subsidiaries Company Physician to confirm whether the employee can safely
perform the essential functions of his or her job while taking the prescription or over
the counter medication. The Company Physician will determine whether an
employee is able to perform the essential job functions of his or her job while taking
the prescription or over the counter medication.
If the Company Physician determines the employee is unable to safely perform the
essential functions of his or her job while taking the prescription or over the counter
medication, the Human Resource Department shall verbally notify the employee who
may not return to work while on the prescription or over the counter medication.
Once the employee has finished their prescription medicine, the employee is eligible
to return to work.
Training
Upon hire and at least annually employees will be trained within this procedure and
recognizing signs of fatigue.

I9.9

Attachment 1

I9.10

ARC Industries, Inc. Fitness to Work Evaluations Requirements

Non DOT
Physical

Shipping /Receiving
Coordinator
Mechanic
Service Technician
Electricians
Electricians Helpers
DOT Driver
Service Manager
Store Manger
Carpenter
Housekeeping
Crane/Cherry picker
Operator
Plumbers Helper
Mechanic Helper
Painter/Blasting

X
X
X
X
X
X
X
X
X
X

DOT
Physical

Respirator
Questionn
aire

Pulmonary
Function
Exam

Respirator
Fit Test

PS

PS

PS

PS
PS
PS
PS
PS
PS
PS

PS
PS
PS
PS
PS
PS
PS

PS
PS
PS
PS
PS
PS
PS

X
X
X

PS
PS
PS

PS
PS
PS

PS
PS
PS

PS

PS

PS

Audio
gram

Serum
Aluminum
Blood Test

Chest
X-Ray

OSHA
Blood
Lead
Level

CBC
Blood
Test

SMAC
Blood
Test

Blood
Level
ZPP

PS

PS

Vision
Exam

Non
DOT
Drug
Test

X
X
X
X
X
X
X
X
X
X

X
X

PS
PS
PS
PS
PS
PS
PS

PS
PS
PS
PS
PS
PS
PS

PS
PS
PS
PS
PS
PS
PS

PS
PS
PS
PS
PS

X
X

PS
PS

PS
PS

PS
PS

PS
PS

X
X
X

PS

PS

PS

PS

PS

X
X
X
X
X
X
X

I9.10.a.1

DOT
Drug
Test

PS
X
PS
PS
X

PS

Dynamic Industries, Inc. Fitness to Work Evaluations Requirements


Non DOT
Physical

Administrative
Personnel
Control Panel
Specialist
DOT Driver
Electricians
Electricians
Helpers
Fitter (Curtis Lane)
Fitter (Fourchon)
Fitter (Harvey)
Fitter (Ingleside)
Fitter (Offshore)
Fitter (Topside)
Foreman
Helper (Curtis
Lane)
Helper (Fourchon)
Helper (Harvey)
Helper (Ingleside)
Helper (Topside)
Instrumentation
Fitter
Instrumentation
Technicians
Management
Metering
Specialist
Offshore Crane
Operator
Offshore Rigger
Offshore
Superintendents
I9.10.a.2

DOT
Physical

Respirator
Questionn
aire

Pulmonary
Function
Exam

Respirator
Fit Test

Audio
gram

Serum
Aluminum
Blood Test

Chest
X-Ray

OSHA
Blood
Lead
Level

CBC
Blood
Test

SMAC
Blood
Test

Blood
Level
ZPP

Vision
Exam

Non
DOT
Drug
Test

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

X
PS

PS

PS

PS

PS

PS

PS

PS

PS

X
X
X
X
X
X

PS
PS
PS
PS
PS
PS

PS
PS
PS
PS
PS
PS

PS
PS
PS
PS
PS
PS

PS
PS
PS
PS
PS
PS

PS
PS
PS
PS
PS
PS

PS
PS
PS
PS
PS
PS

PS
PS
PS
PS
PS

X
X
X
X
X
X

PS, X3

PS, X3

PS, X3

X 1,2

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

X
X
X
X

PS
PS
PS
PS

PS
PS
PS
PS

PS
PS
PS
PS

PS
PS

PS
PS

PS
PS

PS
PS

PS

PS

PS

PS

X
X
X
X

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

X3

X3

X3

PS
PS

PS

PS

PS

PS

PS

PS

PS

PS

PS, X3

PS, X3

DOT
Drug
Test

X3

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS, X3

PS

PS
PS,
X3

PS

PS

PS

X3

X3

Dynamic Industries, Inc. Fitness to Work Evaluations Requirements


Non DOT
Physical

Power Generating
Technicians
Sales
Van Driver
Welder (Curtis
Lane)
Welder (Fourchon)
Welder (Harvey)
Welder (Ingleside)
Welder (Offshore)
Welder (Topside)
Onshore Crane or
Cherry Picker
Operator
Onshore or
Offshore Painter /
Sand Blaster
Onshore Rigger
Onshore
Supervisors

DOT
Physical

Respirator
Questionn
aire

Pulmonary
Function
Exam

Respirator
Fit Test

PS

PS

PS

Audio
gram

Serum
Aluminum
Blood Test

Chest
X-Ray

OSHA
Blood
Lead
Level

CBC
Blood
Test

SMAC
Blood
Test

PS

Blood
Level
ZPP

Vision
Exam

PS

X
X

PS

PS

PS

X
X
X
X
X

PS
PS
PS
PS
PS

PS
PS
PS
PS
PS

PS
PS
PS
PS
PS

PS

PS

X
X

Non
DOT
Drug
Test

DOT
Drug
Test

PS

X
X

PS

PS

PS

PS

PS
PS
PS
PS
PS

PS
PS
PS
PS
PS

PS
PS
PS
PS
PS

PS
PS
PS
PS
PS

X
X
X
X
X

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

X1,2

PS

PS

PS

PS

PS

PS

Sub #1 Curtis Lane - All employees, Harvey All employees, Sub #2 Topside East and West - All employees, Sub #3 Environmental
Topside = East, West and Lake Charles Topside Facilities

Division - Foreman and Supervisors, PS = Project Specific

I9.10.a.3

Dynamic Industries, Inc. (Construction Division) Fitness to Work Evaluations Requirements


Non DOT
Physical

DOT
Physical

Respirator
Questionn
aire

Pulmonary
Function
Exam

Respirator
Fit Test *

Audio
gram

Serum
Aluminum
Blood Test

Chest
X-Ray

OSHA
Blood
Lead
Level

CBC
Blood
Test

SMAC
Blood
Test

Blood
Level
ZPP

Non
DOT
Drug
Test

Vision
Exam

X
X
X

Administrative
Sales
Clerical
Carpenter
Plumber
Insulator

DOT
Drug
Test

X
X
X
X
X
X

X
X
X

X
X
X

X
X
X

X
X
X

PS
PS
PS

X
X
X

PS
PS
PS

PS
PS
PS

PS
PS
PS

PS
PS
PS

X
X
X

X
X
X

*All employees who may be required to wear respirators must be initially, and annually fit-tested with the specific respirator(s) that
they may be required to wear. (Pulmonary function tests will be performed in conjunction with all fit-tests)

Dynamic Industries, Inc. (Environmental Division) Fitness to Work Evaluations Requirements


Non DOT
Physical

DOT
Physical

Respiratory
Question

PFT

Fit
Test
**

Audio.

Serum
AL Blood
Test

Chest
X-Ray

Blood
Lead

CBC

SMAC

ZPP

Vision

Drug
Screen

Administrative

Sales

Clerical
Cleaning Techs,
including
Foremen

X
X

PS

PS

PS

DOT
Drug
Test

**All employees who may be required to wear respirators must be initially, and annually fit-tested with the specific respirator(s) that
they may be required to wear. (Pulmonary function tests will be performed in conjunction with all fit-tests)

Dii LLC (Emergency Response, Government Projects, etal) Fitness to Work Evaluations*
Administrative, Sales, and Clerical personnel have the same Fitness to Work requirements as Construction and
Environmental Divisions for their positions. All other employees are subcontractors. These subcontractors will have all of the
appropriate fitness evaluations according to project requirements as designated by S/H & E Dept.
I9.10.a.4

dii Industrial Services, LLC Fitness to Work Evaluations Requirements


Non DOT
Physical

Administrative
Administrative/
McKee
Helper/ other
Helper/ McKee
Carpenter/ other
Carpenter/ McKee
Iron Worker/ other
Iron Worker/ McKee
Operator (crane)/
other
Operator (crane)/
McKee
Electrician/ other
Electrician/ McKee
Instrument Fitter/
other
Instrument Fitter/
Mckee
Millright/ other
Millright/ McKee
Instrument Tech./
other
Instrument Tech/
McKee
Pipefitter/ other
Pipefitter/ McKee
Boilermaker/ other
Boilermaker/ McKee
Welder, Multi Process
Alloy/ other
Welder, Multi Process
Alloy/ McKee

DOT
Physical

Respirator
Questionn
aire

Pulmonary
Function
Exam

Respirator
Fit Test

Audio
gram

Serum
Benzene
Blood
Test

Chest
X-Ray

OSHA
Blood
Lead
Level

CBC
Blood
Test

SMAC
Blood
Test

Blood
Level
ZPP

Vision
Exam

Non
DOT
Drug
Test

DOT
Drug
Test

X
X
PS
X
PS
X
PS
X

PS
X
PS
X
X
X

PS
X
PS
X
X
X

PS
X
PS
X
X
X

PS
X
PS
X
PS
X

PS
X
PS
X
PS
X

PS
X
PS
X
PS
X

PS
X
PS
X
PS
X

PS
X
PS
X
PS
X

PS
X
PS
X
PS
X

PS
X
PS
X
PS
X

PS
X
PS
X
PS
X

X
X
X
X
X
X

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS
X

X
X

X
X

X
X

PS
X

PS
X

PS
X

PS
X

PS
X

PS
X

PS
X

PS
X

X
X

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS
X

X
X

X
X

X
X

PS
X

PS
X

PS
X

PS
X

PS
X

PS
X

PS
X

PS
X

X
X

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS
X
PS
X

X
X
X
X

X
X
X
X

X
X
X
X

PS
X
PS
X

PS
X
PS
X

PS
X
PS
X

PS
X
PS
X

PS
X
PS
X

PS
X
PS
X

PS
X
PS
X

PS
X
PS
X

X
X
X
X

PS

PS

PS

PS

PS

PS

PS

PS

PS

X
I9.10.a.5

dii Industrial Services, LLC Fitness to Work Evaluations Requirements

PS

X
X

X
X

Pulmonary
Function
Exam

Respirator
Fit Test

PS

X
X

Non DOT
Physical

Welder, Multi Process


Alloy, Rig/ other
Welder, Multi Process
Alloy, Rig/ McKee

Audio
gram

Serum
Benzene
Blood
Test

Respirator
Questionn
aire

DOT
Physical

Chest
X-Ray

OSHA
Blood
Lead
Level

CBC
Blood
Test

SMAC
Blood
Test

Blood
Level
ZPP

Vision
Exam

Non
DOT
Drug
Test

PS

PS

PS

PS

PS

PS

PS

X
PS

X
PS

X
PS

X
PS

X
PS

X
PS

X
PS

X
PS

Welder/ other

PS

Welder/ McKee
Welder, Rig/ other
Welder, Rig/ McKee
Mechanical Leadman/
other
Mechanical Leadman/
McKee
Foreman 1/ Other

X
PS
X

PS

PS

PS

PS

PS

PS

PS

PS

X
X
X

PS

PS

PS

PS

PS

PS

PS

PS

PS

X
PS

X
X

X
X

X
X

X
PS

X
PS

X
PS

X
PS

X
PS

X
PS

X
PS

X
PS

X
X

PS

X
X

X
X

X
X

PS
X

PS
X

PS
X

PS
X

PS
X

PS
X

PS
X

PS
X

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

X
X

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

X
PS

X
PS

X
PS

X
PS

X
PS

X
PS

X
PS

X
PS

X
PS

X
PS

X
PS

X
PS

X
X

Foreman 1/ McKee
General Foreman/
other
General Foreman/
McKee
Timekeeper/ other
Timekeeper/ McKee
Safety Supervisor/
other
Safety Supervisor/
McKee
Quality Control/ other
Quality Control/
McKee

I9.10.a.6

DOT
Drug
Test

dii Industrial Services, LLC Fitness to Work Evaluations Requirements


Respirator
Questionn
aire

Pulmonary
Function
Exam

Respirator
Fit Test

Audio
gram

Serum
Benzene
Blood Test

Chest
X-Ray

OSHA
Blood
Lead
Level

CBC
Blood
Test

SMAC
Blood
Test

Blood
Level
ZPP

Vision
Exam

Non
DOT
Drug
Test

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

Non
DOT
Physical

Planner/ Scheduler/
other
Planner/ Scheduler/
McKee
Project Control/
other
Project Control/
McKee
Superintendent/
other
Superintendent/
McKee
Area
Superintendent/
other
Area
Superintendent/
McKee
General
Superintendent/
other
General
Superintendent/
McKee
Project Manager/
other
Project Manager/
McKee

DOT
Physical

DOT
Drug
Test

I9.10.a.7

Industrial Safety Solutions (ISS) Fitness to Work Evaluation Requirements

Non DOT
Physical

Administrative
Personnel

SH&E Field
Personnel

PS = Project Specific

I9.10.a.8

DOT
Physical

Respirator
Questionn
aire

Pulmonary
Function
Exam

Respirator
Fit Test

Audio
gram

Serum
Aluminum
Blood Test

Chest
X-Ray

OSHA
Blood
Lead
Level

CBC
Blood
Test

SMAC
Blood
Test

Blood
Level
ZPP

Vision
Exam

Non
DOT
Drug
Test

DOT
Drug
Test

X
PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

PS

Southern Steel & Supply, LLC. Fitness to Work Evaluations Requirements

Non DOT
Physical

DOT
Physical

Respirator
Questionn
aire

Pulmonary
Function
Exam

Respirator
Fit Test

Audio
gram

Serum
Aluminum
Blood Test

Chest
X-Ray

OSHA
Blood
Lead
Level

CBC
Blood
Test

SMAC
Blood
Test

Blood
Level
ZPP

Vision
Exam

Non
DOT
Drug
Test

Driver

Warehouse Puller
Steel Supply
Puller
Warehouse
Manager
Receiving/Shippin
g Manager

DOT Driver
Processing
employee

X
X

X
X

DOT
Drug
Test

X
X

I9.10.a.9

Attachment 2

I9.11

FIT FOR DUTY CERTIFICATE


1410513
I certify that during my days off from _____________________ to ____________________,
Circle One
1

Was involved in any type of accident?

Yes

No

Suffered an injury to any part of my body

Yes

No

Had surgery performed, either in-patient or out-patient

Yes

No

Explain any Yes answers to the above:


_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
4

Was sick or ill?

Yes

No

Had a high temperature?

Yes

No

Was seen by any doctor?

Yes

No

Went to the emergency room of any hospital?

Yes

No

Was hospitalized overnight for any reason?

Yes

No

Prescribed medication by a doctor?

Yes

No

10

Underwent any type of diagnostic test?

Yes

No

11

Had surgery recommended by a doctor?

Yes

No

12

Went to a dentist?

Yes

No

13

I had an extensive dental procedure performed or recommended by


a dentist ?

Yes

No

If you answered Yes to any questions above (1-13), you must complete and submit
the Medication Questionnaire on the back of this document directly to your
supervisor.
I certify that the above answers are true and correct.
I further certify that I am fully fit to return for my regular hitch and I am physically and
mentally able to safely perform my job.

___________________________________
DATE

________________________________
EMPLOYEE SIGNATURE
________________________________
PRINT EMPLOYEES NAME

I9.11.a.1

Medication Questionnaire
As described in Moreno Group LLC and Subsidiaries
Substance Abuse and
Contraband Policy, prescription and non-prescription medications may interfere with
safe and effective performance of duties or operation of equipment. In order to
maintain a safe workplace, Moreno Group LLC and Subsidiaries would like to ensure
any medication you are taking will not hinder your ability to work safely or perform the
essential function of your job. Therefore, in addition to testing completed as part of
Moreno Group LLC and Subsidiaries anti-drug testing and alcohol misuse prevention
plans, Moreno Group LLC and Subsidiaries periodically inquires about employee use
of prescription and non-prescription medications which can reasonably be anticipated
to affect the employees ability to perform the essential functions of his or her job.
Are you now taking any prescription or non-prescription
medications which you believe may affect your ability to
make decisions, remain alert, reactive, and responsive on
the job, or pose a threat to your safety or that of others
such that you believe the use of such medication can
reasonably be anticipated to affect your ability to perform
the essential functions of your job?
Circle one: Yes or No
IF YOU ANSWERED YES, YOU ARE NOT TO BEGIN WORKING WITHOUT YOUR
SUPERVISORS APPROVAL, AND MUST COMPLETE THE CHART BELOW.

PLEASE PROVIDE THE INFORMATION REQUESTED BELOW FOR EACH


PRESCRIPTION OR NON-PRESCRIPTION MEDICATION YOU BELIEVE MAY
AFFECT YOUR ABILITY TO PERFORM THE ESSENTIAL FUNCTIONS OF YOUR
JOB
Name of Medication

Dosage of
Medication

How often is the


Medicine Taken

I certify that the above is true and correct.


Employees Printed Name

I9.11.a.2

Date

Employees Signature

Moreno Group LLC


and Subsidiaries
SH&E Management
System

Hazard Communication
Program

Page: 1 of 7
Original: 07/01/1998
Revised: 01/01/2008

Hazard Communication Program


Purpose
The purpose of this Hazard Communication Program is to communicate Moreno
Group LLC and Subsidiaries policies and procedures to all employees and/or
visitors. The methods to identify hazards of chemicals in the work environment will
be per 29 CFR 1910.1200.
Scope
The scope to the Hazard Communication Program is to inform the employees of the
chemical products to which they are exposed and the precautions, which must be
observed when using these chemicals. The following outlines how hazards will be
communicated:
A written Hazard Communication Program is available to all employees
and/or their representatives and visitors. The program will be located in the
Companys SH&E Management System Manual.
All chemical products used by the company will be identified and inventoried.
Material Safety Data Sheets (MSDS) will be obtained for all chemicals
purchased. The MSDS shall be available to all employee and/or visitors. The
MSDS will be located in binders in the supervisors office.
Assure appreciate labels are legible on the chemical containers and an
alternative labeling system is used should the containers label not be legible.
Training will be conducted at the time of employees initial assignment,
annually and whenever a new chemical is brought into the work environment.
This will be conducted by the supervisor. The training will include the
following:
Elements of the MSDS, their location and the possible health
and physical hazards associated with the chemical.
Methods of detection of an accidental release of hazardous chemical.
Specific routine/non-routine work procedures associated with the chemical
(i.e. PPE, work practices, personal hygiene).
Location of the Hazard Communication Program
Hazard Communication labeling systems (i.e. manufacturers, alternative).
I10.1

Hazard Assessment of the chemical and inventory requirements.


Responsibilities
The Hazard Communication Coordinator (Safety, Health and Environmental
Manager) as appointed by the Facility / Site Manager is responsible for:
Overseeing the Hazard Communication program and ensuring
effectiveness in providing necessary information to employees.

its

Being knowledgeable of the OSHA Hazard Communication Standard or


similar regulations.
Maintaining the master list of hazardous substances at the Moreno Group
LLC and Subsidiaries facilities / sites and updating them as necessary.
Granting approval for a chemicals usage. All chemicals (those currently
being used in the facility / site and new chemicals coming into the facility /
site) will be evaluated for associated hazards using the following protocol:
The MSDS will be carefully reviewed by the HAZCOM Coordinator and /
or his designated representative.
A review will be conducted of the area that the chemical will be used in to
ensure that engineering controls are in place (i.e., ventilation, etc.).
Based upon the above steps, an evaluation will be conducted to assess
the potential of employee exposure to the project.
Maintaining the MSDSs and updating them as necessary.
Retaining all outdated MSDSs when revisions are received or use of the
substance is discontinued.
The Facility / Site Manager or Designee is responsible for:
Understanding and complying with the requirements of the Hazard
Communication Procedure and appointing a Hazard Communications
Coordinator.
Evaluating the listing of hazardous substances at Moreno Group LLC and
Subsidiaries facilities / sites. Re-evaluating the hazardous substance list
annually or when changes may affect the list.
Determining appropriate personal protective equipment (PPE) to be used
when working with hazardous substances and defining the respiratory
protection requirements, when applicable.

I10.2

Ensuring that personnel are informed of hazardous substances and have


access to the MSDSs.
Monitoring compliance with this procedure.
Ensuring the referencing of MSDSs in Standard Operating Procedures
(SOPs).
Ensuring MSDSs are obtained for any new hazardous substances
brought into any Moreno Group LLC and Subsidiaries facility / site.
The First Line Supervisors are responsible for:
Understanding and complying with this procedure.
Conferring with other personnel as to the hazardous substances used on
a job.
Communicating to personnel reporting to him as to hazardous substances
used on a job. (Reviewing of the material safety Data Sheet.)
Obtaining special PPE when required, including proper respiratory
protection.
Monitoring jobs and work areas for compliance with this procedure.
Initiating the use of additional precautions as specified in permits, MSDSs
or SOPs.
Ensuring personnel new to his area have received the proper training.
The Employee is responsible for:
Following the work practices for chemicals, this includes reviewing and
following the chemicals MSDS information on the proper handling and/or
using the chemical.
Definitions
Alternative Labels - Any written and/or printed label displayed on or affixed to a
container of a hazardous chemical container.
Hazardous Chemical - Any material that is a physical hazard or a health hazard as
defined by OSHA.
Immediate Use - Any chemical which is under the control of and used only by the
person who transfers if from a labeled container. The transferred must be
completed by the end of the work day.
I10.3

Label - Any written and/or printed label displayed on or affixed to a containers of a


hazardous chemical.
Portable Container - Any bottle, box, can, cylinder or any other container that
contains a hazardous chemical and may be carried by an individual
Hazard Assessment
Manufactures and/or Suppliers are responsible for providing MSDS for the
hazardous chemicals purchased by Moreno Group LLC and Subsidiaries
New Chemicals shall not be brought onto Moreno Group LLC and Subsidiaries
Facility without an approved MSDS on record. Individuals requesting new chemicals
must complete the Request for a New Chemical form (Attachment 1).
Purchased Chemicals will not be received unless the appropriate identification and
hazard information accompanies the chemical. The First Line Supervisor shall
review the containers to ensure that the containers meet Moreno Group LLC and
Subsidiaries requirements. The manufacturers label shall be considered adequate
only if the label is legible.
Portable Containers shall be labeled with the name of the hazardous chemical and
appropriate hazard warning. All portable containers containing flammable or
combustible materials shall be stored in the Flammable Liquid Cabinet.
Material Safety Data Sheet
Material Safety Data Sheet shall be maintained on all chemicals used and stored at
Moreno Group LLC and Subsidiaries Facilities. It is the responsibility of the program
administrator to maintain and update the facilities Material Safety Data Sheet.
Material Safety Data Sheet shall be reviewed by the employee prior to handling any
chemical. The Material Safety Data Sheet may be obtained by calling 1-888-3627416 or www.msdsonline.com.
A chemical inventory list shall be maintained in the Safety, Health and
Environmental Department. This inventory shall be utilized to submit annual Tier II
reports.
Non-Routine Tasks
Prior to performing any non-routine task such as:
Confined Space Entry into Tanks, Process vessels or Barges
The Material Safety Data Sheet of the chemicals to which the employee may be
exposed to will be reviewed during the Confined Space Entry Training.

I10.4

Contractor Safety, Health and Environmental (Multi Employer Worksite)


Contractors will be informed during pre-job meetings and SH&E Orientation on how
to gain access to the following information:
MSDS
Procedures/precautionary measures to be followed pertaining to chemicals
outlined by MSDS.
Contractors shall provide MSDSs to the yard foreman prior to bring any
hazardous material into any Moreno Group LLC and Subsidiaries facility
Labels and Signs
All chemical and hazardous materials, drums, and bulk tanks received on site shall
have the proper labels. The label shall have the following:
Identify the chemical name
Identify the hazard class of the chemical (NFPA Diamond)
Manufacture of the chemical
All containers having chemicals shall be labeled. The only exception to this rule is
containers used by one individual, who will immediately use or transfer the chemical
from a fixed container and empties the dispensing container.
Facility piping will be labeled with the contents of the piping.
The original label must not be removed from the container. Alternative labels may
be used to replace the original label when the original becomes not legible.
Training
Employees will receive Hazard Communication training during the New Employee
Orientation / SH&E Training. This training shall include all required elements of 29
CFR 1910.1200. Refresher training will be conducted by the First Line Supervisor
prior to handling a new chemical and a least annually.

I10.5

Attachment 1

I10.6

REQUEST FOR A NEW CHEMICAL

Chemical Name:
Chemical Manufacturer:
Type of Storage:
Is Storage Pressurized:

Yes_______

No______

Maximum Daily Amount In Inventory:


Purchased Amount:
Requested By:

Date:

Approved By:

Date:

Recommendation(s):________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________
_________________________________________________________

I10.6.a.1

Attachment 2

I10.7

Note: If Spanish speaking employees are present at worksite facility


should consider bilingual HazCom Stickers.

I10.7.a.1

Moreno Group LLC


and Subsidiaries
SH&E Management
System

Hearing Conservation

Page: 1 of 5
Original: 01/01/2001
Revised: 10/01/2006

Hearing Conservation
Purpose
The purposes of this program it to set forth the procedures, which have been
established to evaluate and control employee exposure to excessive workplace
noise. It is intended to address the requirements of OSHA 1910.95, Occupational
Noise Exposure.
Scope
The scope of this plan requires Moreno Group LLC and Subsidiaries to administer a
hearing conservation program whenever employee noise exposures equal or exceed
an 8-hour time-weighted average (TWA) sound level of 85 decibels (dB) measured
on the A-weighted scale (slow response) or, equivalently, a dose of fifty percent.
Responsibilities
The Facility / Site Manager / Offshore Manager or Designee is responsible for:
Assuring that noise level surveys are conducted for all typical operations /
equipment.
Notify SH&E Department when changes in the work area may affect the noise
levels.
Posting and maintaining warning signs where hearing protection is required.
Conferring with the supervisors to identify noise hazards and hearing
protection required for a specific job / task.
Audit compliance with the use of proper hearing protection.
Implement and manage this program for covered positions.
Maintaining records of employee audiometric test results per Access to
Medical records requirements.
The First Line Supervisor or Offshore Superintendent is responsible for:
Understanding and implementing
Conservation program.

the

requirements

of

the

Hearing

I11.1

Conferring with SH&E Department as to the noise hazards of a job and


hearing protection required.
Obtaining special hearing protection when required for a specific job.
Monitoring employee usage of required hearing protection.
The Safety, Health and Environmental Department is responsible for:
Coordinating and/or conducting area noise or personal monitoring.
Facilitating employee notification concerning exposure monitoring.
Assisting Human Resource Department in annual audiogram testing for
covered employees.
The Human Resource Department is responsible for:
Coordinating annual audiogram testing for covered employees.
Maintaining employee exposure and monitoring records per Access to
Medical Records requirements.
The Employee is responsible for:
Complying with this procedure and using the required hearing protection.
Employees are expected to cooperate with those conducting noise monitoring
by providing information about the work environment, the equipment in
operation, and specific jobs.
Conferring with immediate supervisor as to noise hazards involved and
hearing protection requirements associated with the job.
Inspecting hearing protection equipment prior to each use and maintaining it
in a good and clean condition.
Requesting information from supervision about any portion of the Hearing
Conservation Program that is not fully understood.
Requirements
Engineering and Administrative Controls
Engineering Controls
Engineering controls shall be implemented to reduce noise levels whenever feasible.
I11.2

Administrative Controls
Administrative controls shall be exercised to reduce noise levels, when practical.
Monitoring
Covered Employees
Employees whose noise exposures equal or exceed 85 dBA for an 8-hour TWA on
the A scale (slow response) or 82.5 dBA for a 12-hour TWA on the A scale (slow
response) are included in the Hearing Conservation Program. Any exception to this
criterion will be made on an individual case basis.
All personnel are included in the Hearing Conservation Program, with the exception
to office personnel and those employees not exposed to 85 dBA for an 8-hour TWA.
Personal Sampling
Personal noise monitoring is to be conducted to determine the noise exposures of
employees who are included in the Hearing Conservation Program.
Results of noise monitoring will be filed in the employees medical record file. A
notification letter shall be distributed to the employee explaining the results to them,
on their personal noise monitoring.
Method of Noise Measurement
Employee exposure measurements are obtained by the use of noise dosimeters and
sound level meters.
Noise dosimeters measure all continuous, intermittent, and impulsive sound levels
from 80 dB to 130 dB, which are integrated into TWAs.
Measurements are obtained on the A-weighted scale using the slow response
mode.
Equipment used to monitor employee noise exposures shall be calibrated before
and after each days use in accordance with the equipment calibration instructions.
Observation
All employees and/or their representatives are entitled to observe any noise
monitoring that is to be conducted.
Audiometric Testing and Evaluation
Audiometric or Hearing Testing
Testing is available on an annual basis to all Moreno Group LLC and Subsidiaries
employees covered by this program.
I11.3

The audiometric test will be compared to the baseline test to determine if a Standard
Threshold Shift (STS) has occurred.
A certified audiologist or technician will perform these tests.
All participating employees will receive written individual test results from the testing
company.
Employees are to be advised to avoid high noise levels, occupational and nonoccupational, for fourteen (14) hours prior to taking an audiogram.
Baseline Audiogram
Moreno Group LLC and Subsidiaries shall offer a baseline audiogram within six (6)
months of employment, or during a pre-placement physical.
Audiogram Evaluation
The testing facility will evaluate all audiogram to determine if an STS has occurred.
The STS is defined as a change in hearing threshold relative to the baseline
audiogram of an average of 10 dB or more at 2000, 3000, and 4000 Hz in either ear.
Occupational age-adjusted noise-induced threshold shifts greater than or equal to an
average of 25 dB at 2000, 3000 and 4000 Hz in either ear shall be recorded as an
occupational illness on the OSHA 300 log. A follow-up audiogram will be performed
to confirm this result.
Employees included in the Moreno Group LLC and Subsidiaries Hearing
Conservation Program who experience an STS will be notified in writing.
A follow-up audiogram within thirty (30) days of the original audiogram.
Follow-up Procedures
All employees will be notified of an STS in writing within 21 days.
The following actions are to be taken (unless a physician determines that the STS is
not work related):
Refer as necessary for clinical evaluations or additional testing.
Inform employees with non-work related ear problems of need for
examination.
Provide employees with hearing protectors (if not already wearing) train in
care and use and require them to be worn.

I11.4

Hearing Protection
Evaluation
Hearing protection provide will be evaluated to ensure the appropriate Noise
Reduction Rating (NRR) is provided.
Availability
Hearing protectors are available through the customer and the Operations Manager.
Requirements
Hearing protectors are required to be worn when the following exist:
Employees are exposed to 85 dBA TWA or greater, as identified by posting of
signs in designated areas.
During tasks that generate noise.
Precautions
Posting of signs stating Caution Hearing Protection is Required in This Area or
Hearing Protection is Required Beyond This Point have been posted in areas with
noise levels of 85 dBA or greater, measured with a sound level meter.
All employees working in the posted areas shall wear approved hearing protectors.
Supervisors are responsible for ensuring that employees adhere to the hearing
protection requirements.

I11.5

Dynamic Industries, Inc.


SH&E Management
System

Heat Stress Management

Page 1 of 5
Original: 05/12/2009
Revised:

Heat Stress Management


Purpose
The purpose of this procedure is to establish procedures throughout all of Dynamic
Industries Inc. facilities to ensure heat stress management and potable drinking
water is adequately provided throughout the workplace as well as electrolyte
availability during excessive heat.
Scope
This procedure applies to all of Dynamic Industries Inc. facilities and worksites. The
goal of this procedure is to ensure all facilities follow uniform procedures in
supplying potable drinking water throughout the workplace as well as electrolytes
during excessive heat.
Responsibilities
The Facility / Site Manager or Designee is responsible for:
Overall coordination and implementation of this procedure.
Auditing compliance with this procedure.
Assigning personnel the responsibility for cleaning and distributing water
containers throughout the facility.
If applicable, developing project specific plans to address when additional
mitigation practices may need to be implemented.

The First Line Supervisor / Superintendent is responsible for:


Ensuring heat stress management is addressed during SH&E meetings and
as a hazard on the JSEA with proper mitigation.
Monitoring employees and new hire employees to ensure employees are
staying hydrated throughout the workday and not showing any signs are
symptoms of any heat related illness.
Ensuring sealed and dated water containers are available in immediate work
areas.

I12.1

Distributing electrolyte supplements when applicable.


Discussing proper hydration methods during morning SH&E meetings.
The Employee is responsible for:
Discussing any concerns relating to this procedure with their immediate
supervisors or Safety, Health and Environmental Department.
The Safety, Health and Environmental Department are responsible for:
Training and coordinating the training of managers, supervisors and hourly
employees on this procedure as well as water container cleaning procedure.
Periodically auditing the facility to ensure compliance with this procedure.
Issuing Heat Stress Safety Alerts (Attachment 1 & 2) and Heat Advisories
during extreme heat conditions.
Training employees on Heat Stress Awareness monthly training topic.

Requirements
Water Container Cleaning Instructions
Dynamic Industries, Inc. will ensure water containers are cleaned utilizing the below
procedure each time before a water container is utilized:
Wash hands with anti-bacterial soap or hand sanitizer and utilize nitrile
gloves prior to cleaning and / or filling water containers.
Before opening the water container, remove the tape around the outside of
the lid and thoroughly clean the outside of the container, lid, handle and
spout area. Utilize a plastic bristle brush marked For Outside Use Only.
Clean and disinfect inside and water container and spout utilizing a 1:50
bleach to water disinfectant. For spray bottles utilize 24oz. water and 3 tsp.
bleach.
For containers that have not been used in over 3 days, new containers or
containers with excessive dirt/grime, the following needs to be performed:
o Thoroughly wash container using soap and water.
o Use a long handled bristle brush marked For Inside Use Only, and
scrub the inside of the container.
o Follow below disinfecting procedure.

I12.2

For containers that are used daily and are not excessively soiled, only the
below disinfecting procedure shall be utilized:
o Spray or wipe the inside of the container and lid using the 1:50 bleach
to water disinfectant.
o Be careful to drench all components of the container including the lid
and spout area.
o Allow the disinfecting solution to sit in the container for 3 minutes prior
to discarding it.
o Do not rinse the container after disinfecting as this can introduce new
contaminates.
o The container is ready for use. It can be immediately filled after
decontamination or the top can be secured and container can be filled
later. If container is to be filled later, repeat the bleach solution
disinfecting steps prior to filling the containers with water.
Filling Water Container Instructions:
o Wash hands with anti-bacterial soap or hand sanitizer and utilize
nitrile gloves.
o Fill container with ice then top off with water.
o If ice machine is used, ensure ice scoop is used.
o Do not handle ice or water with bare hands, ensure nitrile gloves are
utilized.
o All hoses used for cleaning and filling of water coolers should only be
used for this purpose.
o After the container is filled, secure the lid, dry off the container and
place tape around the lid.
o Write the time and date the container was filled on the tape.

Electrolyte Supplements
Electrolyte supplements in addition to water will be provided to employees when
deemed necessary by Dynamic Industries Inc.s Facility Management and Safety,
Health and Environmental Department during extreme heat conditions.
During extreme heat conditions, employees will be provided two (2) individual
packets of Sqwencher or equivalent electrolyte replacement supplements to be
consumed at morning and afternoon break. This will be distributed to each
employee by their respective foremen each morning at the SH&E Meeting. When
utilizing electrolyte supplements, ensure water is still consumed in adequate
quantities.

I12.3

Attachment 1

I12.4

Who Turned Up the Temperature!


Heat Stress Disorders are serious. Workers who have ignored the symptoms have
lost their lives. Humans have an ingenious system for regulating body temperaturea personal, natural air conditioner. We sweat, it evaporates through our skin, and
were cooled off. But this personal air conditioner can fail, and often does if we
overexert when environmental temperatures are high. To help you recognize Heat
Stress Disorders, the following are the symptoms.

Symptoms of Heat Stress Disorders:


Heat Cramps- Symptoms are painful spasms of the muscles. Heat cramps are
caused when workers consume large quantities of water but fail to take enough salt
to replace the salt their body lost through sweating. Tired muscles are most
susceptible to cramping.
Heat Exhaustion- Symptoms are moist, clammy, pale skin; profuse sweating,
extreme weakness or fatigue, dry mouth dizziness fast pulse, rapid breathing, muscle
cramps and nausea.
Heat / Sun Stroke- Symptoms are a very high body temperature (104 degrees F or
higher), lack of sweat, mental confusion, deep breathing and rapid pulse, hot, dry,
red or mottled skin, and dilated pupils. Seek medical help at once for this condition.

Tips for Heat Stress Prevention:


Acclimatization: Adjust yourself to the heat through short exposure periods followed
by longer exposures until your body is accustomed to the heat. It may take 5-7 days
of hot weather exposure before the body undergoes changes that make heat more
bearable. This is especially important for new employees or offshore employees who
have been off of work who may not be acclimated to the heat. It will be important to
closely monitor these employees for the first week until they become acclimated to
the heat.
Drink lots of Water- Replenish the fluid that your body is losing though sweating.
Not only water, but also critical electrolyte such as sodium, potassium and calcium
are lost through sweating, so consider using electrolyte drinks to combat heat related
disorders.
Education- Know the signs and symptoms of heat stress disorders and act quickly.
Use Your Head- Do not ignore possible symptoms of heat stress disorders. If you
feel very hot, dizzy, nauseous or if your muscles cramp, stop and cool off!!

Be Cool. Know what you have to do to Beat the Heat!


I12.4.a.1

Attachment 2

I12.5

HEAT STRESS KNOW THE FACTS


Please use the following information as a guide for working in the heat, proper hydration and the
signs, symptoms and facts of heat stress and heat illness. Please keep in mind that you are the
most important asset that we have as a company and if you feel that heat is impacting the work
that you are performing, please stop your job, take a break in a cool area and properly hydrate
yourself.

Q: How many workers in United States are affected by heat stress every year?
A: 10 million or about 7% of the US workforce
Q: Other than the health effects of the individual, what other problems does heat stress cause?
A: Decrease in productivity,
A: Decrease in alertness,
A: Decrease in morale,
A: Increase in proneness to accidents
Q: What is the prime cause of heat stress?
A: Dehydration
HEAT EXHAUSTION
Symptoms
1. Heavy sweating
2. Intense thirst from dehydration
3. Fatigue, weakness or loss of
coordination
4. Tingling in hands and feet or
headache

First Aid Treatment


1. Loosen or remove clothing and boots
2. Cool the victim as fast as possible

HEAT STROKE
Early Symptoms
1. High body temperature
2. Hot, red or flushed, dry skin
3. Headache or dizziness
4. Confusion or delirium
Advanced Symptoms
1. Seizure or convulsions
2. Loss of consciousness
3. No detectable pulse

I12.5.a.1

Treatment
1. Lower the victims body temperature as fast as possible
2. Dont give liquids to unconscious victims
Other tips for controlling heat stress
Individuals:
Allow your body to become acclimated to your surroundings
Follow scheduled work/rest cycles to avoid overexertion
Drink before youre thirsty
Drink 6-8 ounces of cool water every 15 minutes
1 hour of strenuous activity requires 1 liter of fluid replacement
Avoid alcohol, coffee, tea or soda
Consume a light, cool lunch instead of hot, heavy meals
Leadership:
Ensure everyone is trained on the symptoms of heat stress
Give consideration to inclusion of heat stress as a hazard when developing JSAs and ensure
mitigation steps are followed
Heat Index

Weather Related Fatalities


170

I12.5.a.2

117

100
80
60
40

74
62
44

47

41
18

d
W
in

rm
St
o

Co
ld

te
r
W
in

He
at

ne
ca

Hu
rri

rn
a

nin
ht

To

do

20
0
Lig

Facts Related to Dehydration


Our body is 60% water.
Our brain is 85% water and
has a narrow tolerance of
dehydration to stay at it's
peak.

140
120

Fl
oo

AM I HYDRATED?

10 Year Average

180
160

We lose about 8-10 cups (64-80 oz) of water per day (WITHOUT exercise) through
breathing, perspiration and normal bodily functions.
75% of people are dehydrated.
As little as 2% loss in water content begins to cause the brain to lose alertness and the body
to feel fatigue. In 37% of us, the thirst mechanism is so weak it is often mistaken for hunger.
The number one trigger of day time fatigue and poor performance is not lack of sleep or
stress but dehydration.
Formula
Body Weight + 12 = Daily Requirement (ounces)
2
Example
150 lb person = (150/2)+12 = 75+12 = 87 oz.

THE URINE COLOR CHART


This urine color chart is a simple tool your can use to assess if
you are drinking enough fluids throughout day to stay
hydrated.
If your urine matches the colors numbered 1, 2, or 3 you are
hydrated.
If your urine matches the colors numbered 4 through 8 you
are dehydrated and need to drink for more fluid.
Be Aware! If you are taking single vitamin supplements or a
multivitamin supplement, some of the vitamins in the
supplements can change the color of your urine for a few
hours, making it bright yellow or discolored.
Electrolyte Supplements
Electrolyte supplements in addition to water will be provided
to employees when deemed necessary by Dynamic Industries
Inc.s Facility Management and Safety, Health and
Environmental Department during extreme heat conditions.
During extreme heat conditions, employees will be provided two (2) individual packets of
Sqwincher or equivalent electrolyte replacement supplements to be consumed at morning and
afternoon break. This will be distributed to each employee by their respective foremen each
morning at the SH&E Meeting. When utilizing electrolyte supplements, ensure water is still
consumed in adequate quantities.

I12.5.a.3

Moreno Group LLC


and Subsidiaries
SH&E Management
System

Hexavalent Chromium
Program

Page: 1 of 19
Original: 08/29/2006
Revised:

Hexavalent Chromium Program


Purpose
The purpose of this program is to establish and implement practices and procedures
for protecting the health of Moreno Group LLC and Subsidiaries employees who
may be exposed to airborne hexavalent chromium while on the job. This program
also establishes methods for complying with the OSHA Construction Industry
Chromium (VI) - 1926.1126 and OSHA Standards for General Industry 1910.1027.
Scope
The scope of this program applies to all Moreno Group LLC and Subsidiaries
projects and employees involved with exposure to hexavalent chromium.
This program also applies to all subcontractors, working under the direct control of
Moreno Group LLC and Subsidiaries, involved with projects that have exposure to
hexavalent chromium from work processes and activities. Subcontractors must
provide all manpower, supplies, equipment, training, and medical examination and
testing necessary to comply with this program.
Responsibilities
The Facility Manager / Yard Foreman or designee is responsible for:
Informing the SH&E Department of the any upcoming project that may have
the potential of containing hexavalent chromium exposure.
Inform any subcontractors that may be working on the project that hexavalent
chromium exposure may be possible.
Ensure that subcontractors understand and comply with this policy.
The First Line Supervisor is responsible for
Understanding and complying with this policy / procedure.
Designating employees for the project and ensuring that a list employees is
provided to the SH&E Department to report to the Medical Review Officer to
be placed in a medical surveillance program and receive all necessary
surveillance prior to job commencing, such as Pulmonary Function Testing
and questionnaire, as well as any pulmonary testing deemed necessary.

I13.1

Coordinate with the SH&E Department to see if all designated employees


have received hexavalent chromium training and / or up to date. If training is
needed, coordinate with the SH&E Department date and time for which
training will take place.
Ensuring that barricade and applicable warning signs have been posted prior
to the startup of the project.
Ensuring that all safety measures are being followed throughout the project.
Performing with and without the SH&E Department a pre-job inspection and
continuous monitoring of jobsite to ensure that all safe work practices are
being done.
Coordinating with the SH&E Department at the end of the project or when any
employee is removed from the project that those employees all go to the
Medical Review Officer and receive post job medical testing that is deemed
necessary.
The Safety, Health and Environmental Department is responsible for
Coordinating with First Line Supervisor to determine which projects and
employees will be working with airborne chromium and have potential
exposure.
Perform any training, such as respiratory training and fit testing, as well as
pre-job hexavalent chromium training, for all employees that need this
training.
Coordinating and performing any air monitoring which may be required, as
well as coordinating any medical surveillance needed with the Human
Resources Department.
Regularly audit jobsites, along with First Line Supervisors, to ensure
compliance with this procedure.
Scheduling of third party air monitoring and notifying personnel of monitoring
results.
The Human Resources Department is responsible for
Authorizing all employees to go to the Medical Review Officer and receive
any medical surveillance that is needed for projects with airborne chromium
exposure.
Maintaining all medical records for all employees that will work on the project.
Informing the SH&E Department of any employee that is unsuitable to work
on the project due to medical reasons.
I13.2

Authorizing all employees to return to Medical Review Officer follow-up


medical surveillance once project is complete or if employee has been
removed from project.
The Employee is responsible for
Understanding and complying with this policy/procedure.
Reporting to his immediate supervisor any problem, which may arise, or any
symptoms of chromium exposure.
DEFINITIONS
Action level - Concentration of airborne chromium (VI) of 2.5 micrograms per cubic
meter of air (2.5 g/m3) calculated as an 8-hour time-weighted average (TWA).
Chromium (VI) [hexavalent chromium or Cr(VI)] - Chromium with a valence of
positive six, in any form and in any compound.
8-hour TWA Concentration - 8-hour Time-Weighted Average concentrations for
airborne contaminants - common units for reporting daily airborne hexavalent
chromium exposures. This is the chromium exposure received per day expressed
as a constant exposure for eight (8) hours at a steady state concentration.
Employee exposure - Exposure to airborne chromium that would occur if the
employee were not using a respirator.
Competent Person - One who is capable of identifying existing and predictable
hexavalent chromium hazards in the surroundings or working condition and who has
authorization to take prompt corrective measures to eliminate them.
HEPA filter - High Efficiency Particular Air filter - Filters that remove 99.97% of all
particulate 0.3 microns or greater in diameter.
mg/m - Milligrams per cubic meter of air. Common units for reporting airborne
concentration of chromium.
NIOSH/MSHA - National Institute of Occupational Safety and Health/Mine Safety
and Health Administration - Federal agencies which conduct research on safety and
health issues and test and certify respirators.
PEL - OSHA requires employers of workers who are occupationally exposed to
airborne chromium to institute engineering controls and work practices to reduce and
maintain employee exposure at or below permissible exposure limits (PEL's). The
employer shall ensure that no employee is exposed to an airborne concentration of
chromium in excess of 5 micrograms per cubic meter of air (5 g/m 3), calculated as
an 8-hour time-weighted average (TWA).
Physician or other licensed health care professional [PLHCP] - An individual whose
legally permitted scope of practice (i.e., license, registration, or certification) allows
I13.3

him or her to independently provide or be delegated the responsibility to provide


some or all of the particular health care services required by OSHA 29 CFR
1926.1126 (k).
REQUIREMENTS
RECOGNITION OF HAZARDS
IDENTIFICATION OF CR(VI) AND WORKPLACE HAZARDS OF EXPOSURE
Cr(VI) is a natural metal used in a wide variety of industrial activities, including the
manufacturing of stainless steel, welding, painting and pigment application,
electroplating, surface coating processes, wood preservation, and abrasive blasting
materials (Table 1). OSHA specifically cites those involved with welding and cutting
stainless steels as the group with the highest risk.
Table 1
Cr(VI) in Industry Products
USES

TYPES
OF
HEXAVALENT
CHROMIUM CHEMICALS

Lead chromate (chrome yellow, chrome


green, molybdenum orange), zinc
Pigments for paints, inks,
chromate, barium chromate, calcium
and plastics
chromate, potassium dichromate, sodium
chromate
Anti-corrosion
products Chromic trioxide (chromic acid), zinc
(chrome
plating,
spray chromate, barium chromate, strontium
coatings, additives)
chromate
Cr(VI) is given off when stainless steel is
Stainless steel
cast, welded, or torch cut
Wood preservation
Chromium trioxide

It is important to note that welding filler metals typically have material properties that
closely mirror the base metal compositions. It has been established that the higher
the chromium level in the supplied materials, the more Cr(VI) will be generated in
welding fumes. Studies performed by the Navy Research Center determined that
approximately 90 percent of the fumes generated during welding come from the filler
metal, and the other 10 percent comes from the base metal.
Stainless steel electrodes and filler wires contain metallic chromium and chromium
alloys. Stainless steel filler metals contain little or no chromium oxide, but the high
heat from the welding arc causes the metallic chromium to oxidize and transmits it
into the air as a fume. The high-heat oxidation process caused by the arc produces
Cr(VI) as a byproduct in the fume, which becomes airborne part of the welding
environment.
The type of welding or cutting also influences the generation of metal fumes and
therefore the concentration of Cr(VI). The highest fume exposures--from highest to
lowest--are from arc gouging and plasma arc cutting, then shielded metal arc
I13.4

welding (stick welding), then gas metal arc (MIG)/gas tungsten arc (TIG) welding.
However, when considering Cr(VI) fume levels apart from other metal fumes, the
lowest Cr(VI) exposures are often seen in welding processes that use a flux instead
of a shielding gas.
The next most significant source of Cr(VI) exposure within Moreno Group LLC and
Subsidiaries operations is the generation of dust, fumes or mist from the following
operations:
Abrasive blasting involving grit contaminated with Cr(VI);
Abrasive blasting on base material coated with any chromate or dichromate
paint;
Grinding, drilling, or other similar aggressive activity on any chromate or
dichromate paint;
Welding or torch cutting on any chromate or dichromate paint;
Painting activities that use chromate or dichromate paint; and
Mist or dust generated from using chromium-containing chemicals (e.g.
corrosion inhibitors).
HEALTH EFFECTS
The primary routes of exposure to Cr(VI) are inhalation and skin contact. Cr(VI) is a
carcinogen and is known to cause lung cancer. It is also suspected of causing
leukemia and Hodgkins Disease. Other acute and chronic health effects cited by
OSHA that are associated with Cr(VI) include:
Reproductive disorders;
Stomach, kidney, and bladder diseases;
Asthma;
Nasal septum ulcerations and perforations;
Skin ulceration (chrome holes); and
Allergic and irritant contact dermatitis.
Cr(VI) will irritate the nose, throat, and lungs and repeated or prolonged exposure
can damage the mucous membranes of the nasal passages and result in ulcers. In
severe cases, exposure causes perforation of the nasal septum (the wall separating
the nasal passages).

I13.5

Prolonged skin contact with Cr(VI) can result in dermatitis and skin ulcers. Some
individuals may develop an allergic sensitization to chromium and direct eye contact
with chromic acid or chromate dusts can cause permanent eye damage.
CONTROLLING EXPOSURES AND MANAGING RISKS
EXPOSURE LIMITS
The OSHA standard regulates the permissible exposure limit (PEL) for Cr(VI) to 5
micrograms per cubic meter (g/ m3) of air as an 8-hour time-weighted average
(TWA). Respiratory protection, safe work practices, and engineering controls are
required above 5 g/ m3 TWA and above.
When feasible, use engineering and work practice controls to reduce and maintain
workforce exposure to chromium (VI) at or below the 5 g/ m 3. Wherever feasible
engineering and work practice controls are not sufficient to reduce workforce
exposure to or below the PEL, reduce workforce exposure to the lowest levels
achievable, and supplement them using respiratory protection.
The OSHA standard also sets an action level (AL) of 2.5 g/ m 3 as an 8-hour TWA
exposure. This AL mandates medical assessments if an employee is exposed for 30
days or more in a year (regardless of location). This level also triggers the need to
maintain medical assessment records, provide training, and conduct additional
exposure assessments.
DETECTING AND MEASURING CR(VI) IN THE WORKPLACE
OSHA requires that each employer determine the 8-hour TWA exposure for each
employee exposed to Cr(VI) within their workplace or work operation. Moreno
Group LLC and Subsidiaries will utilize air monitoring to determine the TWA
exposure on Cr(VI) projects.
RISK ASSESSMENT
Each operating facility must conduct an assessment to ascertain if any chromiumcontaining products or materials are being utilized. In addition, facilities should
conduct such an assessment for each maintenance project at the planning stage.
Initial assessments may include a review of Material Safety Data Sheets,
engineering specifications, product labels and manufacturers product information
sheets. If chromium-containing materials are determined to exist (e.g. stainless
steel, chrome steel, carbon steel, chromium containing paints or corrosion inhibitors)
or be periodically used (e.g. chromium containing welding rods or paints) in the
workplace, then additional information shall be gathered to identify:
The types and amounts of materials;
How many people are involved; and
The specific work activities involving chromium.

I13.6

QUANTIFIED SAMPLING
A comprehensive sampling and data collection program is needed to quantify the
risk of Cr(VI) exposure to personnel. Moreno Group LLC and Subsidiaries shall
perform initial monitoring to determine the 8-hour TWA exposure for each employee
on the basis of a sufficient number of personal breathing zone air samples to
accurately characterize full shift exposure on each shift, for each job classification, in
each work area. Representative sampling may be conducted instead of sampling all
employees in order to meet this requirement, as long as the employees sampled are
those expected to have the highest Cr(VI) exposures.
All sampling must be conducted according the analytical specifications of the OSHA
standard (OSHA standard ID 215) and be tested by a laboratory with accreditation
from the American Industrial Hygiene Association (AIHA), the National Voluntary
Laboratory Accreditation Program (NVLAP), and the National Institute of Standards
and Technology (NIST).
Personal exposure monitoring will be conducted by an industrial hygienist or a
specifically trained technician (e.g. occupational health technician) under the
direction of an industrial hygienist using integrated sampling methods. Monitoring
will be conducted as an initial assessment for all tasks identified as having a
potential for Cr(VI) exposure, periodically in accordance with the OSHA standard
when levels are determined to exist above the action level or when
workers/management express any reasonable exposure concern.
An industrial hygienist will report laboratory analytical results to the supervisors,
SH&E coordinators and workers involved in the monitored task.
If initial monitoring indicates that employee exposures are below the action
level, monitoring may be discontinued for those employees whose exposures
are represented by such monitoring.
If monitoring reveals employee exposures to be at or above the action level,
periodic monitoring must be performed for those employees at least every six
months.
If monitoring reveals employee exposures to be above the PEL, periodic
monitoring must be performed for those employees at least every three
months.
If periodic monitoring indicates that employee exposures are below the action
level, and the result is confirmed by the result of another monitoring taken at
least seven days later, monitoring for those employees whose exposures are
represented by such monitoring may be discontinued.
Additional monitoring must be performed when there has been any change in
the production process, raw materials, equipment, personnel, work practices,
or control methods that may result in new or additional exposures to Cr(VI), or
when there is any reason to believe that new or additional exposures have
occurred.
I13.7

As direct reading instruments cannot be used to determine Cr(VI) concentrations in


workers breathing zones, protective measures, such as the use of ventilation
equipment and respiratory protection, shall be utilized until quantified exposure
monitoring has been completed that determines the exposure risk associated with
the tasks and the results have been received from a certified analytical laboratory
and review by an industrial hygienist.
CONTROLLING CR(VI) EXPOSURES
Each Moreno Group LLC and Subsidiaries facility/site is responsible for
implementing control measures appropriate to the Cr(VI) exposure levels determined
to exist during the risk assessment and quantified exposure evaluations. In order to
control Cr(VI) exposure hazards, standard industrial hygiene controls must be
employed that consist of engineering controls, administrative controls, and personal
protective equipment. Engineering controls are preferred because the hazard is
reduced or eliminated. If engineering controls are not effective enough to reduce
exposure to below the PEL, the next choice is administrative controls, then finally
personal protective equipment.
ENGINEERING CONTROLS
The target for engineering control is to reduce Cr(VI) exposure below 0.5 g/m 3,
which is an automatic exemption level to the OSHA Cr(VI) standard, or alternatively,
2.5 g/ m3, which is the action level set by the standard. When feasible, use
engineering and work practice controls to reduce and maintain workforce exposure
to chromium (VI) at or below the 5 g/ m3. Wherever feasible engineering and work
practice controls are not sufficient to reduce workforce exposure to or below the
PEL, reduce workforce exposure to the lowest levels achievable, and supplement
them using respiratory protection. Engineering and work practice controls are not
required to be implemented if the 5 ug/ m 3 PEL is not exceeded 30 or more days per
year. Job rotation of employees is not allowed to reduce employee exposures or to
comply with requirements of the standard. Engineering controls should be
implemented based on:
Chromium composition in materials;
Type of operations performed; and
Technology available.
It is likely specific controls may be unique to specific tasks and facilities because of
the differing exposure sources and exposure potentials.
Substitution: Substitution of chromium-containing materials with non-chromium
materials, or substitution with a material containing less chromium, is the best
possible engineering control.
Ventilation: Ventilation can be used to remove harmful fumes and gases. The
three types of ventilation are natural, General Dilution and Local Exhaust. General
Dilution lowers the concentration in the general area of the operator while Local
Exhaust removes the fumes and gases at their source. Local Exhaust is the most
I13.8

effective method but may not be the most practical, particularly based upon location
of the task being performed or for blasting/painting operations. Local Exhaust can
be provided by a partial enclosure of the source such as a ventilated work bench, or
by smoke suckers positioned as close to the point of welding as possible. Hoods and
ductwork should be constructed of fire-resistant materials.
Some examples of local exhaust ventilation are portable smoke eaters and fume
extraction welding guns. Local exhaust is best when you have:
Limited mobility;
Limited openings;
Interior obstructions;
Few sources (e.g. welders); and
More toxic alloys.
Some examples of dilution ventilation are centrifugal fans, axial fans and
venturi eductors. Dilution ventilation is best when you have:
Mobile work;
Multiple openings;
Few obstructions;
Many sources; and
Less toxic alloys.
ADMINISTRATIVE CONTROLS
Facilities/sites must establish a regulated area wherever an employee's exposure to
airborne concentrations of Cr(VI) is, or can reasonably be expected to be, in excess
of the PEL. Regulated areas must:
Be demarcated from the rest of the workplace in a manner that adequately
establishes and alerts employees of the boundaries of the regulated area;
and
Limit access to regulated areas to personnel authorized and required by work
duties to be present in the regulated area.
Administrative controls include written instructions (e.g. written contract
specifications, JSEAs) and also include posted regulated areas and safe work
practices. If possible, always use work techniques that generate the least amount of
welding fume or other airborne chromium-containing materials.
I13.9

Examples of administrative controls are:


Not welding on painted or coated parts and removing all surface coatings
before welding;
Using the less fume producing process when practical;
Using cold-cutting techniques instead of torch cutting;
Using the minimum amperage necessary to perform the work correctly;
HEPA vacuuming personnel and areas contaminated with dusts and particles
in order to remove external contamination so that it does not get taken
outside of the work area;
Washing face and hands before eating, drinking, smoking, or applying
cosmetics; and
Prohibiting the consumption of food or beverages, chewing of gum/tobacco or
application of cosmetics within regulated areas.
PERSONAL PROTECTIVE EQUIPMENT
Personal protective equipment, including respirators, should always be used along
with, rather than instead of, engineering controls and safe work practices.
Respiratory Protection:
Whenever respirators are used to protect against Cr(VI),
a written respiratory protection program that complies with OSHA requirements
found in 29 CFR 1910.134 and a site-specific respirator program must be
implemented. Following standard protection factor application, respirators shall be
worn for protection against Cr(VI) as follows:
Half facepiece air-purifying respirator with P-100 (HEPA) cartridges for
exposures up to 50 g/m3;
Loose fitting facepiece powered air-purifying respirator (PAPR) with P-100
cartridges for exposures up to 125 g/m3;
Full facepiece air-purifying respirator with P-100 cartridges for exposures up
to 250 g/m3;
Full facepiece powered air-purifying respirator (PAPR) with P-100 cartridges
for exposures up to 500 g/m3; and
Supplied-air respirator for exposure above 500 g/m3.
Skin and Eye Protection: Protective clothing/equipment is required if a potential
skin or eye hazard exists from direct contact with Cr(VI) compounds. Examples of
such tasks include:
I13.10

Spray painting or large blasting operations involving chromium containing


paints;
Welding operations utilizing methods of high fume production on stainless
steel, or other high Cr(VI) producing products, with known levels above the
PEL in confined spaces or within a large operation; or
Handling Cr(VI) containing products, such as corrosion inhibitors (splash or
spill risk).
The Industrial Hygiene coordinator should be consulted for professional support
when the skin or eye exposure hazard is not known.
If reusable protective clothing is required, then clean and dirty change rooms must
be provided that are equipped with separate storage facilities for both protective
clothing/equipment and street clothes, and that prevent cross-contamination. Where
skin contact with Cr(VI) occurs, washing facilities in conformance with 29 CFR
1910.141 shall be provided.
All protective clothing and equipment contaminated with Cr(VI) must be
removed at the end of the work shift or at the completion of tasks involving
Cr(VI) exposure, whichever comes first, and no employee shall remove
Cr(VI)-contaminated protective clothing or equipment from the workplace
except for those employees whose job it is to launder, clean, maintain, or
dispose of such clothing or equipment.
When contaminated protective clothing or equipment is removed for
laundering, cleaning, maintenance, or disposal it shall be stored and
transported in sealed, impermeable bags or other closed, impermeable
containers.
Protective clothing must not be worn inside break areas or lunch
rooms/galleys.
Bags or containers of contaminated protective clothing or equipment that are
removed from change rooms for laundering, cleaning, maintenance, or
disposal must be labeled in accordance with the requirements of the Hazard
Communication regulatory and procedural requirements.
The removal of Cr(VI) from protective clothing and equipment by blowing,
shaking, or any other means that disperses Cr(VI) into the air or onto an
employee's body is prohibited.
MEDICAL SURVEILLANCE
Moreno Group LLC and Subsidiaries must make medical surveillance available at no
cost to the employee, and at a reasonable time and place, for all employees:

I13.11

Who are or may be occupationally exposed to Cr(VI) at or above the action


level for 30 or more days a year;
Experiencing signs or symptoms of the adverse health effects associated with
Cr(VI) exposure; or
Exposed in an emergency.
Medical examinations shall be provided:
By a Physician or other licensed health care professional (PLHCP);
Within 30 days after initial assignment, unless the employee has received a
Cr(VI) related medical examination that meets the requirements of this
paragraph within the last twelve months;
Annually;
Within 30 days after a PLHCP's written medical opinion recommends an
additional examination;
Whenever an employee shows signs or symptoms of the adverse health
effects associated with Cr(VI) exposure;
Within 30 days after exposure during an emergency which results in an
uncontrolled release of Cr(VI); or
At the termination of employment, unless the last examination that satisfied
the requirements of medical surveillance was less than six months prior to the
date of termination.
TRAINING
The workforce must receive training and information as part of Moreno Group LLC
and Subsidiariess Hazard Communication Program initially upon assignment, at a
minimum.
Training shall include:
Cr(VI) exposure risks within the BP facility/site;
Cr(VI) health hazards and routes of exposure;
Protective measures; and
Content of the OSHA Cr(VI) standard including aspects regarding medical
surveillance.

I13.12

RECORDKEEPING
Monitoring records must include the specific information outlined in OSHAs new
Cr(VI) standard as follows:
The date of measurement for each sample taken;
The operation involving exposure to Cr(VI) that is being monitored;
Type of ventilation used
Sampling and analytical methods used and evidence of their accuracy;
Number, duration, and the results of samples taken;
Type of personal protective equipment, such as respirators worn; and
Name, social security number (or unique personal ID number), and job
classification of all employees represented by the monitoring, indicating which
employees were actually monitored.
Medical surveillance records must include the specific information outlined in
OSHAs new Cr(VI) standard as follows:
Name and social security number;
A copy of the PLHCP's written opinions;
A copy of the information provided to the PLHCP as required by paragraph
(k)(4) of 29 CFR 1910.1026 Chromium (VI).
In accordance with 29 CFR 1910.1020 Access to Employee Exposure and Medical
Records, employee exposure records must be maintained for at least 30 years and
medical surveillance records, if applicable, must be maintained for the duration of
employment plus 30 years. In addition, records must be made available to
employees.
ACTION LEVEL LIMIT
The Action Level for airborne chromium is 2.5 micrograms per cubic meter of air (2.5
g/m3) calculated as an 8-hour time-weighted average (TWA).
Whenever workers airborne total chromium exposures exceed due to monitoring,
the Action Level, the following will be implemented for the work project:
Periodic monitoring at least every six months.

I13.13

PERMISSIBLE EXPOSURE LIMIT


The Permissible Exposure Limit (PEL) for airborne chromium exposure is five (5)
g/m3 as an 8-hour TWA concentration. This is the maximum 8-hour average
concentration of airborne chromium that an employee may be exposed to during
each work day.
Whenever workers airborne total chromium exposures exceed or are expected to
exceed the PEL, the following will be implemented for the work project:
Periodic monitoring at least every three months.
Competent person
Employee information and training
Employee medical surveillance
Airborne respirable chromium and exposure monitoring
Record keeping
PPE / Housekeeping
No employee will be exposed to airborne chromium above the PEL without proper
protection.
The following methods will be used, as feasible and effective, for maintaining
airborne chromium exposures below the PEL:
Engineering controls, such as general area ventilation for containments, local
exhaust ventilation for spot removal, vacuum blasting or vacuum equipped
power tools. When ventilation for containments is used, manometers and/or
velometers, will be used to evaluate the mechanical performance of the
ventilation system
Warning signs
Hygiene facilities and practices
Protective work clothing and equipment
Respiratory protection
Housekeeping
During the period that respirators are worn, the protection factor of the
specific respirator may be used to determine employees exposure to airborne
chromium and to achieve compliance with the PEL.
I13.14

HEALTH EFFECTS
The primary routes of exposure to hexavalent chromium are inhalation and skin
contact. Hexavalent chromium is a carcinogen and is know to cause lung cancer. It
is also suspected of causing leukemia and Hodgkins disease. Other acute and
chronic health effects cited by OSHA that are associated with hexavalent chromium
include:
Reproductive disorders
Stomach, kidney and bladder diseases
Asthma
Nasal septum ulcerations and perforations
Skin ulceration (chrome holes) and
Allergic and irritant dermatitis
Hexavalent chromium will irritate the nose, throat and lungs and repeated or
prolonged exposure can damage the mucous membranes of the nasal passages
and result in ulcers. In severe cases, exposure causes perforation of the nasal
septum (the wall separating the nasal passages).
Prolonged skin contact with hexavalent chromium can result in dermatitis and skin
ulcers. Some individuals may develop an allergic sensitization to chromium and
direct eye contact with chromic acid or chromate dusts can cause permanent eye
damage.
COMPETENT PERSON
All work activities where employee airborne chromium exposures may exceed the
PEL will include a competent person in both the planning and performing stages of
projects involving chromium exposure.
The competent person will be a person with training and experience in conduction
jobs involving airborne chromium exposure. The competent person will have the
capability of identifying hazards and the authority to take immediate action to
eliminate them.
The competent person will be at the work site at all times while airborne chromium
exposure activities are in progress. They may have other job duties, but must be
able to monitor work continuously for hazards or deficiencies, and the authority to
take immediate corrective action.
EMPLOYEE INFORMATION AND TRAINING
All employees who work on projects where airborne chromium and exposures are
known to or expected to be at or above the PEL will be provided information and
I13.15

training on the hazards of airborne chromium and measures for controlling these
hazards and protecting health.
Employees will receive initial comprehensive airborne chromium training before
performing work that may involve airborne chromium exposure. This training will be
repeated annually as a refresher course.
The content of airborne chromium training will include:
The specific nature of activities or operations that may result in airborne
chromium exposure above the Action Level
The health effects and risks of airborne chromium exposure
OSHA standards and guidelines for airborne chromium exposure
Engineering controls, including containments and ventilation systems
Work practices for controlling airborne chromium and exposure, including
information, warning signs, housekeeping, protective clothing and proper
hygiene facilities and practices
Respiratory protection for controlling airborne chromium exposure, including
fit testing
Methods for monitoring airborne chromium concentrations and exposures
The medical surveillance program including medical removal
When conducting airborne chromium exposure activities on a multi-employer work
site, Moreno Group LLC and Subsidiaries will notify other employers of the nature of
the chromium exposure system in effect, and the potential need to take measures to
protect their employees. Notification to other employers will contain the following:
NOTICE - MORENO GROUP LLC AND SUBSIDIARIES IS PERFORMING
ACTIVITIES AT THIS JOB SITE THAT MAY CREATE AIRBORNE CHROMIUM
EXPOSURE. ALL CONTRACTORS AT THIS JOB SITE SHALL REMAIN CLEAR
OF ANY CHROMIUM EXPOSURE AREA.
ACCESS INTO CHROMIUM
EXPOSURE AREA IS CONTROLLED BY THE MORENO GROUP LLC AND
SUBSIDIARIES JOB FOREMAN. ONLY TRAINED, QUALIFIED WORKERS ARE
PERMITTED TO ENTER CHROMIUM EXPOSURE AREAS AND MUST WEAR
RESPIRATORS AND/OR PROTECTIVE CLOTHING.
WELDING OPERATIONS
Welders at Moreno Group LLC and Subsidiaries are exposed to hexavalent
chromium-CR(VI) through the following means:
Stainless steels or other chromium-containing alloys represent the source of
hexavalent chromium in welding operations.
I13.16

Most welding operations join metals by heating the base and/or filler metal to
temperatures at or above the melting point and vaporization temperature of
the weld joint material.
A portion of the metal vapor, including chromium vapor originating from the
base metal, consumable electrode, surface coating, or surface contaminants
instantaneously reacts with atmospheric oxygen and condenses into solid
particles (known as fume) to form metal oxides, such as iron oxide, and
chromium oxides.
o Metallic chromium when vaporized may react with oxygen to form both
trivalent chromium and hexavalent chromium oxide-containing fume.
Hotwork done on galvanized material, such as cutting on grating or handrails
that have been coated with galvanize.
WARNING SIGNS
Warning signs will be posted in the work area around activities where airborne
chromium exposures may exceed the PEL. The work area can be demarcated by
ropes, tape, walls, or containments.
Signs will be posted at every accessible side of the work area. These signs will be
easily visible from a distance so that employee can read the sign and take
necessary protective measures before entering the work area. Signs will read as
follows: WARNING, CHROMIUM WORK AREA.
The competent person will control access of persons into work area.
All persons entering work areas will wear protective clothing and respirators.
Eating, drinking, smoking, and chewing are prohibited in work areas and any area
where airborne chromium exposure may exceed the PEL.
CONTAINMENTS
Where required by federal, state, or local regulation, the project sponsor, or the
project owner, containments will be constructed and used as specified.
The purpose of containments is to restrict or prevent the spread of airborne
chromium or debris to surrounding areas or the environment. While the proper use
of containments can help protect the public and the environment, they generally
cause a significant increase in airborne chromium concentrations in the work area.
Containments may increase the potential for higher employee chromium exposures.
Therefore, the use of well designed exhaust ventilation and the use of more
protective respirators may be necessary to properly protect workers.

I13.17

Containments may include any of the following:


Rigid or flexible barriers or sheets surrounding the work area
Complete unventilated enclosures built around the work area
Complete enclosures maintained under negative pressure by exhaust
ventilation with exhaust air filtration
Containments may also require the construction and use of platforms or scaffolding.
These may be stationary or movable, ground supported or suspended.
PERSONAL HYGIENE PRACTICES
All employees whose airborne chromium exposures may exceed the Permissible
Exposure Limit will, at a minimum wash, their hands and face before breaks, at
lunch and at the end of each work shift.
An adequate number of clean lavatory and hand washing facilities will be provided.
These will comply with the OSHA Standard, 29 CFR 1926.51, Sanitation.
EXPOSURE MONITORING
For work projects when exposure is at or above PEL, personal air samples will be
collected to determine airborne chromium exposures to employees performing tasks
involving chromium exposure. Full shift (at least 7 hours) air samples will be
collected for each job classification in each work area. The air samples will be taken
for the shift with the highest expected exposure level. Moreno Group LLC and
Subsidiaries will implement employee protective measures until results of the
employee exposure assessment are received. The competent person will be
responsible to ensure that exposure monitoring is performed.
Where initial monitoring indicates that chromium exposures are below the PEL, and
where work activities and conditions will remain the same as at the time of initial
sampling, additional monitoring need not be repeated for that work project.
Historical data on past exposure monitoring shall be used and a written record of the
air monitoring data will be kept at the job site.
Where initial monitoring indicates that airborne chromium exposures are below the
PEL, additional representative exposure monitoring will be conducted at least once
every six (6) months for that work project. Where initial monitoring indicates that
chromium exposures are above the PEL, additional representative exposure
monitoring will be conducted at least once every three (3) months. Representative
monitoring should be conducted during the beginning of each different phase of the
project or when changes occur to determine range or exposures for chromium
removal and clean-up activities.
All air samples will be collected and analyzed according to NIOSH 7082 Method or
equivalent. All samples will be analyzed by laboratories accredited under the
Laboratory Accreditation Program of the American Industrial Hygiene Association for
metals analysis.
I13.18

All exposed employees will be notified in writing of the monitoring results within five
(5) days after receiving these results.
Initial exposure monitoring may not be required when previously collected data has
conclusively determined that current job condition exposure levels will be less than
the PEL.
HOUSEKEEPING
Accumulations of chromium and chromium-containing dust and debris generated by
work activities will be removed and cleaned daily.
All persons doing the clean-up will be trained in performing chromium activities,
respirator qualified, and participate in the medical surveillance program. Respirators
and protective clothing will be worn by all persons doing the cleanup unless
exposure monitoring proves otherwise.
Wherever feasible, HEPA-filtered vacuum cleaners will be used for housekeeping.
All chromium and chromium-containing dust and debris will be collected into sealed
containers. The waste will be tested to determine whether it will be disposed as
hazardous or non-hazardous waste.
RECORDKEEPING
All records relating to training, medical examinations, blood chromium monitoring,
exposure monitoring, and project specific requirements will be maintained by
Moreno Group LLC and Subsidiaries, for the employees length of employment plus
30 years.
OTHER RELEVANT INFORMATION
The compliance program will be kept available at the work site for examination by an
affected employee or authorized person/agency.
The compliance program will be revised and updated at least annually.

I13.19

Moreno Group LLC


and Subsidiaries
SH&E Management
System

Hydrogen Sulfide H2S

Page: 1 of 8
Original: 10/01/06
Revised:

Hydrogen Sulfide H2S


Purpose
The purpose of this program is to establish and implement practices and procedures
for protecting the health of Moreno Group LLC and Subsidiaries employees who
may be exposed to hydrogen sulfide (H2S). Hydrogen sulfide (H2S) is an extremely
toxic gas responsible for numerous deaths in the oil industry. Many of these deaths
are caused by a lack of awareness, improper or shortcutting procedures, lack of
respiratory protection, and/or poor rescue techniques.
Scope
The scope of this program applies to all Moreno Group LLC and Subsidiaries
projects and employees involved with projects which may contain H2S. H2S can be
found in drilling operations, recycled drilling mud, water from sour crude wells,
blowouts, tank gauging, tanks at the producing, pipeline and refining operations, field
maintenance activities, tank batteries and wells.

Responsibilities
The Facility Manager/Offshore Manager/Yard Foreman or Designee
responsible for:

is

Understanding and complying with this policy/ procedure.


Informing the SH&E Department of any upcoming project at an H2S facility.
Designating employees for the project and ensuring that those employees all
go the Human Resources Department to get an authorization to go the
approved Medical Facility and receive Respiratory Protection evaluation and
pulmonary function testing.
Coordinate with the SH&E Department to see if all designated employees
have received proper H2S training and or up to date. If training is needed
coordinate with the Safety Department date and time for which training will
take place.
The First Line Supervisor / Offshore Superintendent is responsible for
Understanding and complying with this policy/ procedure.

I14.1

Ensuring proper respiratory protection is readily available and location of


emergency respiratory equipment.
Ensure client locations site specific plan meets or exceeds this plan.
The Safety, Health and Environmental Department is responsible for
Coordinating

H2S

training

and

respiratory

training

and

fit

testing.

Identifying respiratory protection equipment which will be utilized on the


project.
The Human Resources Department is responsible for
Authorizing all employees to go to the Medical Facility and receive proper
evaluation.
Maintaining all medical records for all employees that will work on the project.
The Employee is responsible for
Understanding and complying with this policy/procedure.
Reporting any incident to his immediate supervisor.
H2S Toxiity
H2S is an acute toxin; that is, its only known toxic properties are caused by shortterm exposures to the gas. There are no known health effects associated with longterm exposure to hydrogen sulfide gas, particularly at concentrations at or below the
point where short-term symptoms (for example, eye or respiratory irritation) are
observed.
The acute toxicity of H2S can not be overemphasized. H2S paralyses the nerve
center responsible for breathing. One breath of a high concentration (> 1000 ppm)
can result in immediate unconsciousness and death by suffocation.
H2S does not last long nor accumulate in the body. Therefore, if the victim is
promptly removed from exposure, there is a good chance that he/she can be
successfully resuscitated. Any aftereffects would be dependent on the amount of
time the person was without oxygen, not on the amount of H2S inhaled.
Written Hydrogen Sulfide Policy
Each facility/location with hydrogen sulfide (H2S) should have a written H2S program
or procedures governing activities that may expose personnel to H 2S. Moreno
Group LLC and Subsidiaries will follow the facilities Hydrogen Sulfide Policy unless
this policy is most stringent. This program should meet or exceed the provisions
outlined in the sections of this standard.
I14.2

Training Requirements and Hazard Communication


All personnel who may be required to work in a known or suspected H 2S
environment should receive initial training and bi-annual refresher training in the
following areas:
hazards and characteristics of H2S gases;
toxicity and properties of H2S;
the proper use of H2S detection devices, including personal detection
devices;
H2S alarms, employee response to alarms, and contingency plans;
use and limitations of respiratory protective equipment for H 2S and SO2
(sulfur dioxide);
symptoms of exposure, first-aid and emergency medical procedures;
emergency rescue, stand-by and "buddy system" requirements;
site-specific H2S procedures, contingency plans, rules, labeling and posting.
All such training should be documented with attendance and course outline.
All sub-contractor personnel should be advised of the presence of H 2S, the
facility's/location's H2S program, rules and procedures, and other special
precautions.
Contractors should document and provide suitable verification of such training for
their employees upon request.
Respiratory Protection Equipment
For the purpose of this standard, the term "respiratory protective equipment" (RPE)
shall imply only positive pressure NIOSH approved self-contained breathing
apparatus (SCBA) or positive pressure airline units with an emergency egress bottle;
no other types of respiratory protective equipment shall be used in H 2S
environments, except:
NlOSH/MSHA-approved compressed air escape units may be used for
escape from an emergency release of H2S.
NOTE: Air-purifying respirators, including canister units, shall not be used for
H2S, even for escape (because of the poor warning properties of H 2S, i.e.,
olfactory fatigue).
The Standard for Respiratory Protection and Medical Surveillance shall be followed
for RPE and personnel required to wear such equipment.
I14.3

Instrumentation and Atmospheric Testing


The odor of H2S shall not be used as an indicator of the presence or absence
of H2S under any circumstances.
The detection of the typical "rotten egg" odor indicates the presence of H2S, but the
odor threshold is very low (<0.02 ppm); and
Above 30 ppm and well below lethal concentrations, H 2S produces olfactory fatigue
(lack of smell). At high concentrations (> 200 ppm), olfactory fatigue occurs almost
instantaneously. Therefore, the lack of odor is not indicative of the absence of
H2S.
Real-time measurement of H2S concentration in the breathing zone or tank/vessel
vapor space can be made with the following types of instruments.
Fixed detector,
instrumentation:

portable/gas

test

meter),

and

personal

electronic

Direct-read" digital meter for determining actual concentration with alarm set
points; or
"Alarm only" type (no indication of concentration). This type should only be
used for personnel warning and should not be used as a screening device
because there is no indication of concentration.
Both fixed and personal H2S detection instruments should have a distinctive
audible and visual alarm signal consistent throughout the facility/location
Color-metric indicating tubes These are generally less susceptible to
interferences (such as from other sulfur compounds and hydrocarbons) and
can read higher ranges than most electronic instrumentation. If electronic
instrumentation indicates the presence of H2S where none is suspect, colormetric tubes can be used as a confirmatory source. See the Standard Toxic
Gas Testing for additional information on this equipment.
Lead-acetate paper (commonly a go/no-go type of indicator): generally has
been replaced by other instrumentation. Not recommended, particularly for
personal monitoring.
Calibration - All instrumentation should be calibrated according to the manufacturer's
instructions at least monthly, at the time of servicing or repair, and at the time
of battery replacement. See the Standard, Calibration of Portable Toxic
Gas/Oxygen Meters. A calibration log and maintenance record should be
maintained.
Recommended alarm points for H2S instrumentation are 10 ppm for the low alarm
point and 20 ppm for the high alarm.*
I14.4

Employee(s) must be instructed to evacuate the area immediately, even if the low
alarm is the only one to sound.
Ambient H2S levels should be made in the employee's breathing zone; except that
For tank gauging/sampling purposes, the H2S concentration should be measured at
the level of the thief or gauging hatch, not the breathing zone of the employee. (see
9.c)
Safe Work Practices
Written H2S procedures should identify jobs and work conditions where H 2S may be
of concern and describe appropriate work practices. These procedures should
include at least the following as applicable.
Respiratory protection:
Shall be worn until the concentration of H2S has been established.
Shall be worn for any known or expected environment that equals/exceeds 10
ppm in the employee's breathing zone.
Buddy system and requirements of the standby person:
A standby with respiratory protection is required whenever the H 2S
concentration in the breathing zone could exceed 300 ppm (See 9.c
regarding open hatch tank gauging).
Trained in CPR/First-Aid and appropriate rescue techniques or how to initiate
a rescue response.
Trained on and proficient in the use of SCBA.
Have a two-way radio to request back up assistance if an emergency
develops.
Standby shall be located upwind with a clear view of his/her "buddy."
Ground level is preferable; if the standby must climb to keep his/her "buddy"
in view; the standby should don the SCBA, except the facepiece. If the
standby must actually use the RPE because of potential exposure another
standby located in a "safe" area would be required.
Requirements for gauging/sampling tank which contain a product producing
hydrogen sulfide (H2S) in the tank vapor space are as follows:
For H2S concentration < 10 ppm above the gauging hatch and < 300 ppm
at the gauging hatch, no respiratory protection is required; a standby person
is not necessary (Figure 1).
I14.5

For H2S concentration > 10 ppm above the gauging hatch and < 300 ppm
at the gauging hatch, SCBA or supplied air is required; a standby person is
not necessary (Figure 2).
For H2S concentration > 300 ppm at the gauging hatch, SCBA or supplied
air with escape bottle and a standby person is required (Figure 3).
For the purpose of this discussion, at the hatch means on a plane level with
the top of the hatch.
Alarm investigation
All alarms should be investigated as an actual gas release with proper
respiratory equipment and standby personnel.
Employees with personal monitors should be instructed to evacuate the area
immediately even if the low alarm is the only one to sound.
General Work and Hazardous Work Permit
Efforts shall be made to reduce H2S levels to below 10 ppm before
implementing H2S/RPE procedures.
If RPE is required because of H2S levels, appropriate management
authorization of the work should be required on the work permit. Second level
management review is recommended for IDLH (> 300 ppm) work.
No tank, valve, line, flange, relief vent, pig access, etc. which may create an
H2S concentration of 10 ppm or greater in the employee's breathing zone
shall be opened without proper RPE (G.1). The H 2S concentration in the
process stream should be considered when determining the potential for
exposure.
H2S procedures should always be employed if gas stream concentrations
exceed 300 ppm (volume) or 5 ppm (weight) in liquid streams regardless of
anticipated breathing zone levels.
Personal H2S instruments
Should be used by personnel not using RPE where there is a possibility that
the breathing zone concentration may exceed 10 ppm, unless fixed
monitoring is effectively employed at the facility/location. These areas should
be described in the written H2S program.
Some areas may include:
a. Catwalks and inside of firewalls of sour tanks
b. Sour crude tank batteries, well sites, and gas handling facilities
I14.6

c. Sour water stripper areas, amine units, sulfur plants


d. Tail gas (Beavon-Stretford) open reaction/regeneration tanks
e. Sour gas Compressors
If personal H2S monitors are issued to warn employees of H2S (as opposed to
using a gas test meter with readout to test for H2S concentration), the
facility/location should consider "alarm-only" monitors. Since there is no readout, employees will not have the tendency to further investigate the source
without proper precautions or RPE.
Fixed-point H2S monitors:
Some considerations for applicability include, but are not limited to: Indoor,
enclosed, or semi-enclosed process areas, compressor houses, etc.;
Near equipment with potential for failure, such as sour water pump seals;
Where required by regulation.
Signs and Postings
When the breathing zone concentration is 10-300 ppm, the following sign should be
posted at employee access points.
DANGER
HYDROGEN SULFIDE
POSITIVE PRESSURE RESPIRATORY PROTECTION REQUIRED
When the breathing zone concentration could exceed 300 ppm:
DANGER
HYDROGEN SULFIDE
POSITIVE PRESSURE RESPIRATORY PROTECTION AND
STANDBY PERSON REQUIRED
If posting at the base of a tank, add the words "WHEN TANK OPENED" after the
word "REQUIRED."
Tank battery access roads (particularly public access) should be posted with a sign:
DANGER
POISON GAS
Signs already in place conveying the same meaning need not be replaced.
Windsocks should be installed in easily visible locations where breathing zone
concentrations (including tank hatch concentrations) may exceed 100 ppm.

I14.7

Emergency Procedures
The facility/location should have an Emergency Action Plan and procedures which
address H2S, including, at minimum:
Evacuation:
Evacuate personnel in a direction upwind or crosswind from the source to a
designated safe refuge;
Several selected areas of safe refuge for variable wind conditions;
Consider appropriate ventilation system scrubbers, air intake alarms,
automatic shutdown of air handlers, and RPE systems to protect those
personnel who can not evacuate the area, such as control room personnel.
Alarm Investigation
All alarms should be treated as an actual gas release.
Respiratory protection shall be worn when investigating alarms, and actual or
potential releases.
First Aid and Rescue
DO NOT INITIATE ANY RESCUE WITHOUT WEARING SCBA.
DO NOT ATEMPT ANY RESCUE IF YOU ARE NOT AUTHORIZED AND
TRAINED
A single standby person should not initiate rescue until radio contact has
been made and it is known that help is on the way.
After donning SCBA and calling for help, remove the victim from the area of
exposure.
First-Aid and medical treatment instructions: After removing the victim to a
safe location, clear the airway, begin mouth to mouth resuscitation. The
victim will die from lack of oxygen unless resuscitation is promptly and
successfully administered.
Administer oxygen if available and trained or qualified to do so.
Seek immediate medical attention.

I14.8

Moreno Group LLC


and Subsidiaries
SH&E Management
System

Lead Protection

Page: 1 of 15
Original: 01/01/2001
Revised: 01/01/2004

Lead Protection
Purpose
The purpose of this program is to establish and implement practices and procedures
for protecting the health of Moreno Group LLC and Subsidiaries employees who
may be exposed to lead on the job. This program also establishes methods for
complying with the OSHA Construction Industry Lead Standard, 29 CFR 1926.62.
Scope
The scope of this program applies to all Moreno Group LLC and Subsidiaries
projects and employees involved with lead paint removal projects and activities.
This program also applies to all subcontractors, working under the direct control of
Moreno Group LLC and Subsidiaries, involved with lead-based paint removal
projects and activities. Subcontractors must provide all manpower, supplies,
equipment, training, and medical examination and testing necessary to comply with
this program.
Responsibilities
The Facility Manager/Offshore Manager/Yard Foreman or Designee is
responsible for:
Informing the SH&E Department of any upcoming project that may have the
potential of containing lead
Inform any subcontractors that may be working on the project that the project
contains lead.
Ensure that subcontractors understand and comply with this policy as well as
the Lead Employee Project Specific Protection Plan.
The First Line Supervisor / Offshore Superintendent is responsible for
Understanding and complying with this policy/ procedure as well as the Lead
Employee Project Specific Lead Protection Program.
Designating employees for the project and ensuring that those employees all
go to the Human Resources Department to get an authorization to go to the
Medical Review Officer and receive initial blood lead levels prior to performing
any work on the project

I15.1

Coordinate with the SH&E Department to see if all designated employees


have received lead training and or up to date. If training is needed coordinate
with the Safety Department date and time for which training will take place.
Ensuring that barricade and applicable warning signs have been posted prior
to the startup of the project.
Ensuring that all safety measures are being followed throughout the project.
Performing with the safety department the Lead Job Checklist and performing
this checklist throughout the project.
Coordinating with the Human Resources Department at the end of the project
or when any employee is removed from the project that those employees all
go to the Medical Review Officer and receive blood lead levels.
The Safety, Health and Environmental Department is responsible for
Coordinating paint samples to have analyzed to determine if project contains
lead.
Informing Facility Manager/Offshore Manager/Yard Foreman or designee of
the outcome of the sample analysis.
Perform any lead training, any respiratory training and fit testing for all
employees that need this training
Coordinating and performing any air monitoring which may be required.
Developing Lead Employee Project Specific Protection Plan.
The Human Resources Department is responsible for
Authorizing all employees to go to the Medical Review Officer and receive an
initial blood lead level as well as a respiratory analysis if one is needed.
Maintaining all medical records for all employees that will work on the project.
Informing the safety department of any employee that is unsuitable to work on
the project due to high lead levels or medical conditions that do not allow
employee to wear a respirator.
Authorizing all employees to return to Medical Review Officer for blood lead
levels once project is complete or if employee has been removed from
project.

I15.2

The Employee is responsible for


Understanding and complying with this policy/procedure as well as the Lead
Employee Project Specific Protection Plan.
Reporting to his immediate supervisor any problem, which may arise, or any
symptoms of lead exposure.
Definitions
Lead - The word lead when used in this program means elemental lead, all
inorganic lead compounds. Lead is a heavy metal at room temperature and
pressure and is a basic chemical element. It can combine with various other
substances to form lead compounds.
Lead-based Paint - Although there is no federal guideline or definition for lead-based
paint, it is generally accepted to be dry paint that contains 0.06% (600 ppm) or
greater lead by weight. A more restrictive limit for lead based paint may be defined
for specific projects by the project sponsor, the project owner, or federal, state or
local regulation.
g/m - Micrograms per cubic meter of air. Common units for reporting airborne
concentration of lead.
8-hour TWA Concentration - 8-hour Time-Weighted Average concentrations for
airborne contaminants - common units for reporting daily airborne lead exposures.
This is the lead exposure received per day expressed as a constant exposure for
eight (8) hours at a steady state concentration.
g/100g - Micrograms per 100 grams of whole blood. Common units for reporting
concentrations of lead in blood samples. Also reported as g/dl (micrograms per
deciliter) of whole blood.
NIOSH/MSHA - National Institute of Occupational Safety and Health/Mine Safety
and Health Administration - Federal agencies which conduct research on safety and
health issues and test and certify respirators.
HEPA filter - High Efficiency Particular Air filter - Filters that remove 99.97% of all
particulate 0.3 microns or greater in diameter.
Competent Person - One who is capable of identifying existing and predictable lead
hazards in the surroundings or working condition and who has authorization to take
prompt corrective measures to eliminate them.
Action Level
The Action Level means employee exposure, without regard to the use of
respirators, to an airborne concentration of lead of thirty (30) g/m , calculated as an
8-hour TWA.
I15.3

Whenever workers airborne lead exposures exceed or are expected to exceed the
Action Level, the following will be implemented for the work project:
Competent person
Employee information and training
Employee medical surveillance
Airborne lead exposure monitoring
Record keeping
The Action Level may be exceeded where lead-containing coating or paint are
present and the following activities are performed: abrasive blasting, cleanup of
expendable abrasives, containment movement and removal, spray painting with lead
paint, manual scraping, manual sanding, power tool cleaning with and without dust
collection systems and heat gun applications. Some non-painting related activities
include: manual demolition of structures, welding, cutting, torch burning, rivet
busting, installation, removal, or demolition of lead containing materials, lead burning
and lead contamination/emergency cleanup operations.
Permissible Exposure Limit
The Permissible Exposure Limit (PEL) for airborne lead exposure is fifty (50) g/m ,
as an 8-hour TWA concentration.
This is the maximum 8-hour average
concentration of lead that an employee may be exposed to during each work day.
No employee will be exposed to airborne lead above the PEL without proper
protection.
The following methods will be used, as feasible and effective, for maintaining
airborne lead exposures below the PEL:
Engineering controls, such as general area ventilation for containments, local
exhaust ventilation for spot removal, vacuum blasting or vacuum equipped
power tools. When ventilation for containments is used, manometers and/or
velometers, will be used to evaluate the mechanical performance of the
ventilation system
Warning signs
Hygiene facilities and practices
Protective work clothing and equipment
Respiratory protection
Housekeeping
I15.4

During the period that respirators are worn, the protection factor of the specific
respirator may be used to determine employees exposure to airborne lead and to
achieve compliance with the PEL. The protection factors listed in the respirator
selection table of Moreno Group LLC and Subsidiaries Respiratory Protection
Program. For example:
Measured airborne lead concentrations at the workers breathing zone: 300
g/m ,8-hour TWA
Half-mask, air-purifying, negative pressure respirator with HEPA filters worn
all day: protection factor of 10
Employees daily lead exposure: 30 g/m
Competent Person
All work activities where employee airborne lead exposures may exceed the Action
Level will include a competent person in both the planning and performing stages of
projects involving lead exposure.
The competent person will be a person with training and experience in conducting
jobs involving lead exposure. The competent person will have the capability of
identifying hazards and the authority to take immediate action to eliminate them.
The competent person will be at the work site at all times while lead exposure
activities are in progress. They may have other job duties, but must be able to
monitor work continuously for hazards or deficiencies, and the authority to take
immediate corrective action.
Employee Information and Training
All employees who work on projects where airborne lead exposures are known to or
expected to be at or above the Action Level will be provided information and training
on the hazards of lead and measures for controlling these hazards and protecting
health.
Employees will receive initial comprehensive lead training before performing work
that may involve airborne lead exposure. This training will be repeated annually as a
refresher course.
The content of lead training will include:
The specific nature of activities or operations that may result in airborne lead
exposure above the Action Level
The health effects and risks of lead exposure
OSHA standards and guidelines for lead exposure
Engineering controls, including containments and ventilation systems
I15.5

Work practices for controlling lead exposure, including information, warning


signs, housekeeping, protective clothing and proper hygiene facilities and
practices
Respiratory protection for controlling lead exposure, including fit testing
Methods for monitoring airborne lead concentrations and exposures
The medical surveillance program including medical removal
Precautions for female employees who are pregnant.
Instructions to employees that chelating agents should not be used to remove
lead from their bodies
When conducting lead exposure activities on a multi-employer work site, Moreno
Group LLC and Subsidiaries will notify other employers of the nature of the lead
exposure system in effect, and the potential need to take measures to protect their
employees. Notification to other employers will contain the following: NOTICE MORENO GROUP LLC AND SUBSIDIARIES IS PERFORMING ACTIVITIES AT
THIS JOB SITE THAT MAY CREATE AIRBORNE LEAD DUST.
ALL
CONTRACTORS AT THIS JOB SITE SHALL REMAIN CLEAR OF ANY LEAD
EXPOSURE AREA. ACCESS INTO LEAD EXPOSURE AREA IS CONTROLLED
BY THE MORENO GROUP LLC AND SUBSIDIARIES JOB FOREMAN. ONLY
TRAINED, QUALIFIED WORKERS ARE PERMITTED TO ENTER LEAD
EXPOSURE AREAS AND MUST WEAR RESPIRATORS AND PROTECTIVE
CLOTHING.
Medical Surveillance
All employees who may be exposed to lead above the Action Level or who may be
required to wear a respirator will be provided initial and periodic medical
examinations.
All employees who may be exposed to lead above the Action Level will be provided
with initial and periodic biological monitoring in the form of blood sampling and
analysis of lead and zinc protoporphyrin.
All employees who are temporarily removed from lead exposure due to elevated
blood lead levels or at the recommendation of a physician may be reassigned other
job duties at the site that do not involve exposure to lead above the Action Level.
The specific components, requirements, and frequencies of medical examination,
blood lead test, and medical removal protection benefits are provided in Moreno
Group LLC and Subsidiaries Medical Surveillance / Examination Program for Lead
Exposure and Respirator Use (see Attachment 1)

I15.6

Warning Signs
Warning signs will be posted in the work area around activities where lead
exposures may exceed the Permissible Exposure Limit. The work area can be
demarcated by ropes, tape, walls, or containments.
Signs will be posted at every accessible side of the work area. These signs will be
easily visible from a distance so that employee can read the sign and take
necessary protective measures before entering the work area. Signs will read as
follows: WARNING, LEAD WORK AREA, POISON, NO SMOKING OR EATING.
The competent person will control access of persons into work area.
All persons entering work areas will wear protective clothing and respirators.
Eating, drinking, smoking, and chewing is prohibited in work areas and any area
where lead exposure may exceed the Permissible Exposure Limit.
Containments
Where required by federal, state, or local regulation, the project sponsor, or the
project owner, containments will be constructed and used as specified.
The purpose of containments is to restrict or prevent the spread of lead-containing
dust or debris to surrounding areas or the environment. While the proper use of
containments can help protect the public and the environment, they generally cause
a significant increase in airborne lead concentrations in the work area.
Containments may increase the potential for higher employee lead exposures.
Therefore, the use of well designed exhaust ventilation and the use of more
protective respirators may be necessary to properly protect workers.
Containments may include any of the following:
Rigid or flexible barriers or sheets surrounding the work area
Complete unventilated enclosures built around the work area
Complete enclosures maintained under negative pressure by exhaust
ventilation with exhaust air filtration
Containments may also require the construction and use of platforms or scaffolding.
These may be stationary or movable, ground supported or suspended.
Personal Hygiene Facilities and Practices
Clean change areas will be provided for all projects where employee airborne lead
exposures may exceed the Permissible Exposure Limit. These clean change areas
will be equipped with storage facilities for street clothing and a separate area for the
removal and storage of lead-contaminated clothing and equipment. This change
area will be designed and used so that contamination of street clothing does not
I15.7

occur. Airborne lead exposures in the change area will be maintained below the
Action Level.
Shower facilities will be provided for all projects where feasible when employee lead
exposures exceed the Permissible Exposure Limit. Shower facilities will comply with
the OSHA Standard, 29 CFR 1926.51, Sanitation. All employee whose airborne
lead exposures may exceed the Permissible Exposure Limit will shower or at a
minimum wash their hands and face at the end of each work shift. Employees
required to shower will not leave the workplace wearing any clothing worn while
performing lead exposure activities.
Clean lunch areas will be provided for all projects where employee airborne lead
exposures may exceed the Permissible Exposure Limit. Employee will remove or
clean their protective clothing and wash their hands and face before eating, drinking
or smoking. Airborne lead exposures in the lunch area will be maintained below the
Action Level.
An adequate number of clean lavatory and hand washing facilities will be provided.
These will comply with the OSHA Standard, 29 CFR 1926.51, Sanitation.
Where required by federal, state, or local regulation; the project sponsor; or the
project owner; decontamination units will be constructed and used as specified.
These generally are maintained under negative pressure and contain clean change
rooms, showers and dirty equipment rooms.
Protective Clothing and Equipment
Protective clothing and equipment will be worn by all employees whose airborne
lead exposures may exceed the Permissible Exposure Limit. Protective clothing and
equipment will be provided at no cost to the employee.
Protective clothing will include washable or disposable full body coveralls. Other
protective equipment will include faceshields, hats, gloves, shoes or disposable shoe
covers, eye protection, and hearing protection as appropriate.
Disposable protective clothing will be used for no more than one (1) work day. They
will be disposed of as lead-contaminated waste.
Reusable coverall will be collected at the end of each work day in closed containers.
Contaminated clothing will be cleaned by authorized laundries according to all
applicable federal, state, or local regulations pertaining to lead-contaminated laundry
and water discharge. All containers of lead-contaminated laundry will be labeled as
follows: CAUTION: CLOTHING CONTAMINATED WITH LEAD. DO NOT
REMOVE DUST BY BLOWING OR SHAKING.
DISPOSE OF LEAD
CONTAMINATED WASH WATER IN ACCORDANCE WITH APPLICABLE LOCAL,
STATE OR FEDERAL REGULATIONS.
Reusable protective clothing (coveralls) will be laundered at least weekly, and clean
coveralls provided daily to employees whose exposure levels without regard to a
respirator are over 200 g/m3 of lead as an 8-hour TWA.
I15.8

Protective clothing and equipment will be removed in the contaminated section of


the change area and will not be worn into any clean areas not contaminated with
lead.
Protective clothing and equipment will be worn by all employees performing the
following activities where lead-containing coatings or paint are present unless
exposure monitoring proves otherwise: When abrasive blasting, cleanup of
expendable abrasives, abrasive blasting enclosure construction, movement and
removal, power tool cleaning with and without dust collection systems, manual
scraping, manual sanding, manual demolition of structures, heat gun applications,
welding,
cutting,
torch
burning,
chemical
stripping
and
lead
contamination/emergency clean-up activities.
Respiratory Protection
Respiratory protection will be used in combination with engineering controls and
work practices to maintain employee airborne lead exposures below the Permissible
Exposure Limit.
Respirators will be worn by all employees, other contractors, inspectors, or
observers who may be exposed to airborne lead at or above the Permissible
Exposure Limit.
The selection, use, maintenance, and inspection of respirators will be according to
Moreno Group LLC and Subsidiaries Respiratory Protection Program. Qualifications
for respirator users are also contained in this program. Select respirators from the
types listed below in Table 1. Any respirator chosen must be approved by the Mine
Safety and Health Administration (MSMA) or the National Institute for Occupational
Safety and Health (NIOSH).
Table 1 Respiratory Protection for Lead Aerosols
Airborne Concentration of Lead or
Condition of Use
Not in excess of 500 ug/m3

Not in excess of 1,250 ug/m3

Not in excess of 2,500 ug/m3

Respirator Required
mask air purifying respirator with
HEPA filters2,3
mask supplied air respirator operated
in demand (negative pressure mode.)
Loose fitting hood or helmet powered
air-purifying respirator with HEPA
filters.3
Hood or helmet supplied air respirator
operated in continuous flow mode that
is type CE abrasive blasting respirators
operated in continuous flow mode.
Full facepiece air purifying respirator
with HEPA3
Tight fitting powered air-purifying
respirator with HEPA
I15.9

Airborne Concentration of Lead or


Condition of Use
Not in excess of 50,000 ug/m3

Full facepiece supplied air respirator


operated in demand mode.
mask or full facepiece supplied air
respirator operated in a continuous-flow
mode.
Full facepiece self-contained breathing
apparatus (SCBA) operated in demand
mode.
Respirator Required

mask supplied air respirator operated


in pressure demand or other positivepressure mode.
3
Not in excess of 100,000 ug/m
Full facepiece supplied air respirator
operated in pressure demand or other
positive pressure mode, that is, type CE
abrasive blasting respirators operated in
a positive-pressure mode.
Greater than 100,000 ug/m3 , known Full facepiece SCBA operated in
concentration, or fire fighting
pressure demand or other positive
pressure mode.
1
Respirators specified for higher concentrations can be used at lower concentrations
of lead.
2
Full facepiece is required if the lead aerosols cause eye or skin irritation at the use
concentration.
3
A high efficiency particulate filter (HEPA) means a filter that is 99.97 percent
efficient against particles of 0.3 microns size or larger.
Exposure Monitoring
For each work project, personal air samples will be collected to determine airborne
lead exposures to employees performing tasks involving lead exposure. Full shift (at
least 7 hours) air samples will be collected for each job classification in each work
area. The air samples will be taken for the shift with the highest expected exposure
level. Moreno Group LLC and Subsidiaries will implement employee protective
measures until results of the employee exposure assessment are received. The
competent person will be responsible to ensure that exposure monitoring is
performed.
Where initial monitoring indicates that lead exposures are below the Action Level,
and where work activities and conditions will remain the same as at the time of initial
sampling, additional monitoring need not be repeated for that work project. A written
record of the air monitoring data will be kept at the job site.
Where initial monitoring indicates that lead exposures are at or above the Action
Level but at or below the PEL, additional representative exposure monitoring will be
conducted at least once every six (6) months for that work project. Where initial
monitoring indicates that lead exposures are above the PEL, additional
representative exposure monitoring will be conducted at least once every three (3)
I15.10

months. Representative monitoring should be conducted during the beginning of


each different phase of the project or when changes occur, such as an increase in
the number of blasters in the area, to determine range or exposures for lead removal
and clean-up activities.
All air samples will be collected and analyzed according to NIOSH 7082 Method or
equivalent. All samples will be analyzed by laboratories accredited under the
Laboratory Accreditation Program of the American Industrial Hygiene Association for
metals analysis.
All exposed employees will be notified in writing of the monitoring results within five
(5) days after receiving these results.
Initial exposure monitoring may not be required when previously collected data has
conclusively determined that current job condition exposure levels will be less than
the Action Level.
Housekeeping
Accumulations of lead-containing dust and debris generated by work activities will be
removed and cleaned daily.
All persons doing the clean-up will be trained in performing lead activities, respirator
qualified, and participate in the medical surveillance program. Respirators and
protective clothing will be worn by all persons doing the cleanup unless exposure
monitoring proves otherwise.
Wherever feasible, HEPA-filtered vacuum cleaners will be used for housekeeping.
All lead-containing dust and debris will be collected into sealed containers. The
waste will be tested to determine whether it will be disposed as hazardous or nonhazardous waste.
Employees will not be permitted to remove lead-containing dust from protective
clothing or equipment by blowing, shaking, or by any other means which disperses
lead in the air.
Project Specific Requirements
The specific worker lead protection requirements for each lead-removal project will
be determined by Moreno Group LLC and Subsidiaries, the project sponsor, and the
project owner. The job specific requirements will be placed in Attachment 2 - Lead
Paint Removal Project Specific Requirements. Enough detail will be provided as to
accurately outline the job specific requirements. This attachment will be posted at
the job site and maintained with the work records of the project.
Recordkeeping
All records relating to training, medical examinations, blood lead monitoring,
exposure monitoring, and project specific requirements will be maintained by
I15.11

Moreno Group LLC and Subsidiaries, for the employees length of employment plus
30 years.
Other Relevant Information
The compliance program will be kept available at the work site for examination by an
affected employee or authorized person/agency.
The compliance program will be revised and updated at least annually.

I15.12

Attachment 1

I15.13

Medical Surveillance/Examination Program For


Lead Exposure And Respirator Use
Purpose
To establish and implement a program that meets, in substance, the medical
surveillance requirements of the OSHA Construction Industry Lead Standard, 29
CFR 1926.62 and by the OSHA Respiratory Protection Standard, 29 CFR 1926.103.
Scope
This program applies to all Moreno Group LLC and Subsidiaries, employees who
may be exposed to lead in the course of their work and who are required to wear
respirators.
This program also applies to all subcontractors working under the direct control of
Moreno Group LLC and Subsidiaries Subcontractors must provide all manpower,
medical examination and testing, and other resources necessary to comply with this
program.
This program combines the medical surveillance and examination requirements of
the OSHA Construction Industry Lead Standard and the Respiratory Protection
Standard into one unified program.
Requirements
All medical examination will be conducted by or under the supervision of a licensed
physician.
All medical examination will be provided at no cost to the employee and at a
reasonable time and place.
Moreno Group LLC and Subsidiaries will provide the following information to the
examining physician:
A copy of the OSHA Construction Lead Standard, 29 CFR 1926.62, including
all Appendices.
A description of the employees duties as they relate to lead exposure.
The employees representative or anticipated exposure level to lead and any
other toxic substance they may be exposed to at work.
A description of any protective clothing and respirators to be used.
Information from previous examination(s) performed for lead exposure
or respirator use, including past blood lead results, including all prior
written medical opinions concerning the employee, that may be in the
possession or control of Moreno Group LLC and Subsidiaries
I15.13.a.1

Medical examinations provided by other employers or groups may be accepted by


Moreno Group LLC and Subsidiaries provided the following conditions are met:
The employee agrees to release all medical record of these examinations and
tests to Moreno Group LLC and Subsidiaries or their medical examination
provider.
All medical examinations and tests specified in this program were performed.
The physicians medical opinion is reviewed by Moreno Group LLC and
Subsidiaries medical provider or an additional medical opinion is provided.
Records of medical examinations and tests are confidential medical records.
Access to these records by employees, their designated representatives, or other
parties will be according to 29 CFR 1926.63, Access to Employee Exposure and
Medical Records.
Medical Surveillance
All medical surveillance will be performed by or under the supervision of a licensed
physician.
Initial medical surveillance consisting of blood sampling and analysis for lead and
zinc protoporphyrin (ZPP) will be provided to all employees exposed at any time (1
day) above the action level. For each employee who may be exposed at or above
the action level for more than thirty (30) days in any consecutive 12 months,
biological monitoring for blood lead and ZPP will be provided at least every two (2)
months for the first six (6) months and every six (6) months thereafter.
Respirator Requirements. Respirators will be provided whenever an employees
exposure to lead exceeds the Permissible Exposure Level, in work situations in
which engineering controls and work practices are not sufficient to reduce exposures
to or below the PEL, and whenever an employee requests a respirator.
Respirators will be selected from those approved for protection against lead dust,
fume, and by the Mine Safety and Health Administration and the National Institute
for Occupational Safety and Health.
Respirators or combinations of respirators that will provide adequate protection to
the employee will be chosen by the competent
person based on OSHA
Construction Industry Lead Standard 29 CFR 1926.62 Table 1: Respiratory
Protection for Lead Aerosols.
Each employee will be required to wear a half-mask, negative pressure respirator
will be qualitatively fit tested every six (6) months on the specific respirator that will
be used. Fit test procedures specified in the OSHA Construction Industry Lead
Standard, 29 CFR 1926.62, Appendix D will be followed. Full facepiece negative
pressure respirator will be quantitatively fit tested in accordance with Appendix D of
the standard.
I15.13.a.2

Medical Exam - Requirements for respirator users will include examinations and
tests as deemed necessary by the examining physician to ensure the ability to wear
and utilize respiratory protection. These tests will be provided annually to
employees assigned to wear a respirator.
Medical Examination for Lead Exposure
Frequency of Medial Examinations - Medical examinations will be provided at least
annually for each employee for whom a blood sampling test conducted at anytime
during the preceding twelve (12) months indicated a blood lead level at or above
forty (40) g/dl; as soon as possible, upon notification by an employee either that the
employee has developed signs or symptoms commonly associated with lead
intoxication; that the employee desires medical advice concerning the effect of
current or past exposure to lead on the employees ability to procreate a healthy
child, the employee is pregnant, or that the employee has demonstrated difficulty in
breathing during a respirator fit test or during use; and as medically appropriate for
each employee either removed from exposure to lead due to a risk of sustaining
material impairment to health, or otherwise limited pursuant to a final medical
determination.
Content of Medical Examinations - Medical examination will include, as a minimum:
A detailed work and medical history, with particular attention to past lead
exposure (occupation and non-occupational), personal habits (smoking,
hygiene), reproductive history and plans, and past problems involving the
cardiovascular, nervous or digestive systems, liver, kidneys, blood, or lungs.
A thorough physical examination with particular attention to the teeth, gums,
heart, lungs, digestive system, liver, kidneys, blood, and nervous system.
Pulmonary function test of forced vital capacity and forced expiratory volume.
Tests for blood pressure and resting heart rate.
Blood sample and analysis for blood lead level, hemoglobin and hematocrit
determinations, red cell indices, peripheral smear morphology, zinc
protoporphyrin, blood urea nitrogen, and serum creatinine.
Routine urinalysis with microscopic examination.
Other examinations or tests deemed necessary by the examining physician
Physicians Written Opinion - Medical Examinations
For each examination, Moreno Group LLC and Subsidiaries will obtain a written
opinion from the examining physician that contains the following:

I15.13.a.3

Whether the employee has a detected medical condition that places them at
an increased risk or health effects from exposure to lead
Any special protective measures to be provided to the employee or limitations
to be placed on the employees exposure to lead
Whether the employee is medically qualified to wear a respirator and any
limitations of use, especially concerning negative pressure respirators
A statement that the employee has been informed by the physician of the
results of the medical examination, blood tests, urine tests, and of any
medical conditions that may result from lead exposure
Moreno Group LLC and Subsidiaries will provide a copy of the examination and test
results and the physicians written opinion to the employee immediately after its
receipt.
Medical records of examinations and tests will be retained by Moreno Group LLC
and Subsidiaries for the employees length of employment plus 30 years.
Blood Lead Monitoring
Along with the initial and annual medical examinations have been addressed,
Moreno Group LLC and Subsidiaries will provide periodic blood sampling and
analysis for lead and zinc protoporphyrin levels to each employee exposed to lead
above the Action Level.
Blood lead analysis will be performed by laboratories licensed by the US Center for
Disease Control (CDC) or which has received a satisfactory grade in blood lead
proficiency testing from the CDC in the prior twelve (12) months.
Periodic blood lead monitoring will be provided every two (2) months for the first six
(6) months and every six (6) months thereafter to exposed employees during leadpaint removal projects, or more often if required.
Employees with blood lead levels above 40 g/dl but below 50 g/dl will continue to
be provided blood lead tests every two (2) months, until two (2) consecutive blood
lead levels are below 40 g/dl.
Employees who are identified with a blood lead level at or above fifty (50) g/dl will
be provided with a blood lead test within two (2) weeks. If the blood lead level
remains at or above fifty (50) g/dl, blood lead testing will be provided once a month,
until two (2) consecutive blood lead levels are less that forty (40) g/dl.
Employee will be informed in writing of their blood test results within five (5) working
days after receiving results. Employees will also be informed in writing that they
must be temporarily removed from lead exposure jobs and may be reassigned to
other duties at the site not involving lead exposure if their blood lead levels are at or
above fifty (50) g/dl. Anytime an employees blood lead level exceeds fifty (50)
g/dl, another blood lead test will be taken within two (2) weeks from the receipt date
I15.13.a.4

of the initial results. If both test results exceed fifty (50) g/dl the employee will be
temporarily removed and successive blood lead level tests will be made on a
monthly basis during the employees removal.
Medical Removal Program
Employees with blood lead levels at or greater that fifty (50) g/dl and as described
in Blood Level Monitoring will be temporarily removed from any work where airborne
lead exposure may exceed the Action Level. Workers will be removed from lead
exposures until two (2) consecutive blood lead samples show results below forty
(40) g/dl.
Employees determined, by a physician, to be at increased risk of health impairment
from exposure to lead will also be temporarily removed from any work where
airborne lead exposure may exceed the Action Level. Moreno Group LLC and
Subsidiaries will implement and act consistent with the physicians recommendations
for any special protective measures or lead exposure limitations for the employees.
Any employee temporarily removed from lead exposure activities due to elevated
blood lead levels or a physicians recommendations will be provided blood lead test
every four (4) weeks until two (2) consecutive tests indicate that blood lead levels
are at or below forty (40) g/dl.
Employees temporarily removed from lead exposure activities may be assigned to
other duties on-site that do not involve lead exposure above the Action Level.
Employees temporarily removed from lead exposure activities may return to their
normal lead exposure duties after two (2) consecutive blood lead tests indicate that
blood lead levels are at or below forty (40) g/dl.

I15.13.a.5

Attachment 2

I15.14

Moreno Group LLC and Subsidiaries Lead Paint Removal


Project Specific Requirements
PROJECT
LOCATION
DATES
ON-SITE COMPETENT PERSON
DESCRIPTION OF EACH ACTIVITY EMITTING LEAD

EQUIPMENT USED

WORKER TRAINING REQUIRED


MEDICAL SURVEILLANCE REQUIRED
MECHANICAL VENTILATION EFFECTIVENESS

LEAD WORK AREA LOCATIONS


WARNING SIGNS NEEDED
HYGIENE FACILITIES
EXPOSURE ASSESSMENT CONDUCTED
EXPOSURE ASSESSMENT RESULTS
ADEQUATE RESPIRATORY PROTECTION
RESPIRATORY FIT TEST REQUIRED
RESPIRATORY FIT TEST PERFORMED
PROTECTIVE CLOTHING
HEPA VACUUMS NEEDED
I15.14.a.1

EMPLOYEE JOB RESPONSIBILITIES

OPERATING PROCEDURES FOR WORKER DECONTAMINATION, DISPOSAL OF


PROTECTIVE CLOTHING, CLEANING EQUIPMENT, ETC...

JOB ROTATION SCHEDULE

EMPLOYEE NAME(S)

JOB DURATION AND EXPOSURE LEVELS

OTHER LEAD REDUCTION ADMINISTRATIVE CONTROLS

I15.14.a.2

ALL CONTRACTORS ON SITE INFORMED OF POTENTIAL LEAD EXPOSURE


A DESCRIPTION OF THE SPECIFIC MEANS THAT WILL BE EMPLOYED TO
ACHIEVE OSHA COMPLIANCE. IF ENGINEERING CONTROLS ARE REQUIRED,
LIST THE ENGINEERING PLANS AND STUDIES USED TO DETERMINE THE
METHODS SELECTED FOR CONTROLLING EXPOSURE(S) TO LEAD

LIST THE TECHNOLOGY CONSIDERED IN MEETING THE PEL

SCHEDULE FOR IMPLEMENTATION OF THE COMPLIANCE PROGRAM

CONSTRUCTION CONTRACTS/PURCHASE ORDERS

I15.14.a.3

Moreno Group LLC


and Subsidiaries
SH&E Management
System

NORM Program

Page 1 of 42
Original: 03/01/2006
Revised: 09/08/2009

NORM Program
Purpose
The purpose of this program is to establish and implement practices and procedures
for protecting the health of Moreno Group LLC and Subsidiaries employees who
may be exposed to harmful levels of Naturally Occurring Radioactive Material
(ionizing radiation) encountered on the job. This program also establishes methods
complying with the OSHA construction industry radiation standard, 29 CFR
1910.1096 and LAC 33:XV.
Scope
The scope of this program applies to Moreno Group LLC and Subsidiaries
Environmental Divisions projects and employees involved with the maintenance,
cleaning, decontamination, land remediation, transportation, and handling of NORM
and TENORM contaminated material including but not limited to equipment,
tubulars, tanks, vessels and facilities. Also any land classified as NORM and
TENORM contaminated according to this program.
Responsibilities
The Facility Manager/Offshore Manager or Designee is responsible for:
Informing the SH&E Department and corporate RSO of any upcoming project
that may have the potential or has been clarified to contain NORM material or
action level NORM readings.
Purchase any radiological supplies as necessary and in accordance with
Moreno Group LLC and Subsidiaries purchasing procedure.
Inform any subcontractors that may be working on the project that the project
contains NORM and at what levels.
Ensure that subcontractors understand and comply with this policy as well as
the NORM employee project specific protection plan.
The Corporate Radiation Safety Officer (RSO) is responsible for:
The Corporate Radiation Safety Officer shall have overall responsibility and
charge of radiological conditions during activities performed under this
license. The corporate RSO may designate other RSOs to act in his absence
at the Moreno Group LLC and Subsidiaries NORM temporary jobsites. These
individuals, while acting in the capacity of an RSO, will be called NORM
I16.1

Supervisors (NS). RSOs will coordinate activities with Work Supervisors,


employees, and contract personnel to ensure that all work can be
accomplished in a safe and radiologically sound manner.
RSO/NS
responsibilities are as follows:
The RSO will have familiarity with the Louisiana radiation Protection
Regulations, company requirements and procedures, general training in basic
radionuclide handling techniques and safety practices, and on-the-job
experience actually handling comparable materials. The position requires a
minimum of 40 hours of instruction in radiation safety and health physics that
is recognized by the state of Louisiana and 3 months of hands-on practical
NORM supervisory field experience, or 6 months of experience handling
Hazardous Materials.
The RSO/NS will maintain control of NORM operations to ensure proper
radiological health and safety procedures are in effect. The RSO/NS, as well
as anyone in the work area, shall have the specific authority to stop
operations at any time an unsafe or environmentally hazardous condition
exists.
He may purchase radiological supplies as necessary and in
accordance with Moreno Group LLC and Subsidiaries purchasing
procedures. And, he may promulgate changes to Moreno Group LLC and
Subsidiaries NORM Policies and Procedures as necessary to maintain
radiological safety controls.
Preparation of a Radiation Work Permit (RWP) outlining radiological
conditions and precautions to be taken during work activities. The RWP shall
be maintained available for review by all employees and contractors. The
RSO/NS will ensure that all employees sign the RWP prior to the start of work
acknowledging their understanding of and responsibility to comply with the
requirements of the RWP.
The RSO/NS is responsible for all employees being properly informed and
trained regarding radiological safety issues. At a minimum, employees shall
receive a 4 hours of training that meets the applicable regulations. Topics
shall include, but are not limited to: radiation safety and work procedures for
employees and contractors; health physics precautions; contamination
control; and, other radiological conditions outlined in this license and the
Louisiana Radiation Regulations (LRR).
Ensure that equipment used, areas where NORM is handled and stored, and
operations involving NORM are operated and maintained in a safe working
condition and in compliance with the license, LRR, and other applicable rules,
regulations, and orders.
Conduct baseline, release, dose rate and radiological surveys of equipment,
lands, jobsite, and personnel. Ensure proper decontamination of lands,
equipment, and personnel who become contaminated with NORM.
Ensure that only those individuals properly trained in the safe handling of
NORM shall have access to controlled areas and that all applicable areas are
I16.2

properly posted in accordance with this license and LAC 33:XV. He will also
ensure that individuals frequenting Restricted Areas are provided personal
dosimetry and adequate personal protective equipment to prevent NORM
contamination.
The RSO/NS is responsible for proper documentation of all safety meetings,
training, surveys, and control.
In the event of an emergency such as fire, accident, or uncontrolled NORM
release, the RSO/NS shall have authority to respond so as to minimize injury
to personnel or the environment. The corporate RSO shall be contacted
immediately.
Ensure that the requirements of this license, LAC 33:XV, 29 CFR, 10CFR,
and other pertinent rules, regulations, and orders are properly met and
implemented.
The Safety, Health and Environmental Department is responsible for:
Review the implementation of all safety requirements and procedures of all
personnel working in the area.
Review personnel training and knowledge of their duties and responsibilities.
Review the availability of necessary safety, personal protective and
environmental equipment and ensure that it is functioning and in good status.
Periodically inspect employee and contractors work habits to ensure that they
are working in a safety conscious manner.
Periodically inspect all equipment, plastic protective sheeting, storage areas,
containers, and other jobsite materials to ensure that they are properly
maintained in accordance with the applicable provisions of this license and
that NORM or other contaminants do not contaminate equipment, personnel,
or the equipment.
The First Line Supervisor / Offshore Superintendent is responsible for:
Qualifications are to include instructions in radiation safety practices
appropriate for operating procedures, knowledge of radiation regulations, and
on-the-job experience handling comparable materials. This individual will
have a minimum of 16 hours of instruction in radiation safety or 8 hours of
instruction in radiation safety and 40 hours of Hazardous Material safety
instruction. In addition, this individual will have a minimum of 3 months of
experience performing NORM decontamination procedures or 6 months of
experience handling Hazardous Materials. At a minimum, annual refresher
training will be required.

I16.3

Supervise all working personnel and all work activities taking place at the
jobsite.
Conduct safety meeting, at a minimum of the beginning of each job or when
additional (or new) personnel become necessary to perform work activities, to
inform employees and contractors of safety concerns and procedures prior to
the start of work.
Perform pre-job and daily/continual inspections of work site, equipment and
personnel work habits to ensure compliance with work plans, safety
standards and procedures, license specifications, and the LRR are being
followed. The inspections shall be documented on the Moreno Group LLC
and Subsidiaries NORM pre-job checklist and NORM daily checklist. (see
Attachments 1 & 2)
Shut down operational activities in the event of any emergency which could
result in injury to personnel or the environment.
All accidents and near misses are to be reported to the RSO and SH&E
Department.
Assist in preparing the daily RWP and associated paperwork required by this
license for the job and supply the RWP and associated paperwork to the
RSO.
The Personnel Working in Restricted/ Radioactive Areas are responsible for:
Facilities and areas where NORM contaminated equipment or waste is being stored,
utilized, or worked with shall be considered Radioactive Material Areas. A jobsite or
facility may be posted as a Radioactive Material Areas. A jobsite or facility may be
posted as a Radioactive Material Area and contain within it one or more Restricted
Areas. A Restricted Area is any area where access is controlled by the licensee for
purposes of protection of individuals against undue risks from exposure to radiation
and radioactive materials. The immediate area in which NORM activities are taking
place shall be considered Restricted Areas. Only individuals who have been
properly trained and/or informed regarding the risks associated with NORM and
proper handling of sources of radiation shall be allowed to work in Restricted Areas.
Individuals who perform the decontamination activities will have a minimum of
8 hours of instruction in radiation safety. In addition, these individuals will
have a minimum of 8 hours of on-the-job training in performing NORM
decontamination procedures. At a minimum, annual refresher training will be
required.
Visitor and short term contractors (contractors working less than one full day)
entering a Restricted Area will be briefed on the radiological health hazards
contained in the area, and made aware of precautions to be taken to minimize
their exposure. The guidelines used for this briefing shall be those contained
in LAC 33:XV.1012.
I16.4

Moreno Group LLC and Subsidiaries may employ contract labor for use in
operations involving NORM. These personnel, while not directly employed by
Moreno Group LLC and Subsidiaries, will be treated as employees for
purposes of training, worker protection, and qualifications.
All personnel working in a Restricted Area will be required to read and sign
the RWP prepared by the RSO/NS prior to commencing operations. The
RWP will describe authorized activities, personal protective equipment
required, and expected radiological and safety concerns. The RWP shall be
available for review at all times.
All personnel working in the Radioactive Materials/Restricted Areas shall
retain, at all times, Stop Work Authority. All employees will have not only
the right, but also the responsibility to immediately stop any operation or
evolution which may be dangerous to safety, health, equipment, and/or the
environment.
All personnel entering Restricted Areas will be required, as a minimum, to
perform a hand and foot frisk immediately upon exiting the Restricted Area.
A whole body frisk will be performed before leaving the work site and when
protective clothing was worn in the Restricted Area. Any reading above
background when performing a personal frisk shall be removed and the
person refrisked.
All accidents or injury, no matter how minor, will be reported to the designated
Work Supervisor, RSO/NS, and/or SH&E Department
All personnel working in Restricted Areas at temporary jobsites will hold Daily
SH&E Meeting. Meetings will include, but not limited to, a review of all
personnel concerns and the scheduled operations for the week (or day, as
appropriate), including any radiological hazards and concerns.
Requirements
HEALTH PHYSICS PROGRAM
BASIC PRACTICES AND GUIDELINES
Safety is of highest concern to Moreno Group LLC and Subsidiaries at all times, all
personnel will follow safe work procedures to protect themselves and their fellow
employees from direct contact with NORM and to prevent the release of NORM
contamination into the environment. All employees and contractors shall use, to the
extent practicable, procedures and engineering controls based upon sound radiation
protection principles to achieve occupational doses and public doses that are as low
as reasonable achievable (ALARA).

I16.5

PERSONNEL MONITORING
External Exposure
All personnel working in a Restricted Area shall be provided with personal
dosimetry devices to monitor the individuals received radiation dose.
Dosimeters will consist of either a film badge or thermoluminescent
dosimeter.
-

Each dosimeter will be assigned to a specific person and will be


worn only by that person. It will bear the name of the individual
and/or a number corresponding to the individual assigned. When
the employee reports to work, they will attach their assigned
dosimetry to their outermost clothing above the waist (typically at
the neck or collar) and wear it throughout the work shift. Utmost
care will be taken to prevent dosimeter loss or damage. At the end
of the shift, the employee will leave his dosimeter in a location with
low background radiation readings as designated by the RSO/NS.

Dosimeters will be read at 3 month intervals by Landauer, or other


approved suppliers.

Taking into account that oilfield NORM does not normally exhibit
high radiation exposure levels, the annual occupational dose limit to
individual adults working under this license shall be that which is
the most limiting of: the total effective dose equivalent being equal
to 0.05 Sv (5 rem); or, the sum of the deep dose equivalent and the
committed dose equivalent to any individual organ or tissue other
than the lens of the eye being equal to 0.5 Sv (50 rem). In any
other circumstances, those limits as specified in LAC 33:XV.410
shall be utilized. Moreno Group LLC and Subsidiaries shall reduce
the dose that an individual may be allowed to receive in the current
year by the amount of occupational dose received while employed
by any other person(s)

A control dosimeter will be kept at a low background area at all


times and be read at the same frequency as those dosimeters worn
by employees.

Records of readings of the dosimeters will be maintained


indefinitely at the facility housing the corporate RSO for his review.
In addition, each individuals records shall be maintained at their
employment facility. Pursuant to LAC 33:XV.1013, results of the
monitoring will be reported to each individual once results are
received. This may be done at scheduled safety meetings with the
individual initiating the report acknowledging his receipt.

Visitors and short term contractors (working less than 12 hours) entering a
Restricted Area will not be assigned dosimetry. These individuals will be
briefed, as described in LAC 33:XV.1012, on the radiological health hazards
I16.6

contained in the area and made aware of precautions to be taken to prevent


exposure to NORM.
Internal Exposure
No eating, drinking, smoking, or chewing will be allowed in Restricted Areas.
Open wounds, sores, or cuts shall be reported to the RSO/NS and covered
with bandages and/or protective clothing prior to working in the Restricted
Areas.
Significant intakes by ingestion or inhalation are presumed to occur only as a
result of accidents, poor procedure, inadvertence, or similar situations.
Intakes will be evaluated and accounted for by techniques appropriate for the
occurrence as determined by the RSO/NS. Techniques measuring the intake
of radioactive material into the body may include bioassays (the
measurement of radioactivity excreted from the body), whole body counts (the
measurement of radioactivity in the body), or a combination thereof (per LAC
33:XV.413) as necessary for timely detection and assessment of individual
intakes.
Baseline bioassays will not be required for workers involved in NORM activities due
to the large amount of NORM material which must be inhaled or ingested prior to
being detectable using modern bioassay techniques. Documentation of the
circumstance and results of the bioassay shall be maintained by Moreno Group LLC
and Subsidiaries for a minimum of five years. This documentation shall be made
available to LDEQ/RPD upon request.
Air Sampling
Every practicable effort shall be made to prevent or effectively reduce
airborne NORM through proper equipment layout, design, and use of
engineering controls (i.e., wetting down NORM, ventilation systems, etc.) to
an extent where respirator usage is not necessary.
When it is not practicable to apply process or other engineering controls to
control the concentrations of radioactive material in air to values below those
that define an airborne radioactivity area, Moreno Group LLC and
Subsidiaries shall, consistent with maintaining the total effective dose
equivalent ALARA, increase monitoring and limit intakes by one or more of
the following means:
-

control of access;
limitation of exposure times;
use of respiratory protection equipment; or,
other controls.

Air sampling shall be conducted of the Restricted Area breathing zone of all
workers wearing respiratory protection at the direction of the RSO/NS and
boundaries of airborne-causing evolutions to ensure that no airborne
I16.7

radionuclides are being released to the environment outside of the Restricted


Area.
A low-volume air sampler equipped with a two inch filter holder and having a
volumetric flow rate of at least 50 liters per minute shall be used to sample for
airborne particulates. The air sampler shall be calibrated at least once every
12 months and at each servicing.
The air will be drawn through a filter paper patch for a minimum of 20 minutes
at a flow rate of 2 cfm to achieve proper volume. Longer run times to obtain
larger volumes will be allowed at the direction of the RSO/NS. Should any
employee believe the instrument not be working properly, he should contact
the RSO/NS immediately.
Once air sampling is complete, the filter should be removed from the air
sampler using tweezers to prevent cross-contamination and placed into a
plastic bag for analysis. The bag should be labeled as a minimum with the
date the sample was taken, the start and stop times of the sample, air flow
rate, the sample location, and the printed initials of the person taking the
sample.
A chain of custody form will be completed to accompany the sample to an
approved lab for analysis. LDEQ/RPD approved field analysis may be used
for analysis of air samples. The results of all air samples will be documented
and retained for a minimum of five years at Moreno Group LLC and
Subsidiaries
Moreno Group LLC and Subsidiaries shall monitor, to determine compliance
with LAC 33:XV.413, the occupational intake of radioactive material by and
assess the committed effective dose equivalent (CEDE) to adults likely to
receive, in one year, an intake in excess of 10 percent of the applicable ALI in
Table I, Columns 1 and 2, of Appendix B.
PERSONAL PROTECTION
Protective Clothing
A minimum of coveralls, gloves, and shoe coverings or water resistant boots
shall be worn by all personnel who may come into contact with NORM
contaminated items when entering a Restricted Area. Direct skin contact with
NORM scale, sludge, solids, waters or materials will be avoided to the extent
possible. Any coveralls, gloves, or shoe coverings that become torn will be
immediately replaced.
Eye protection, such as safety glasses equipped with side shields and a
respirator with a HEPA filter, should also be worn while working in Restricted
Areas.
Upon exiting an area of known or suspected NORM contamination, the
worker will immediately proceed to a designated personal survey station in a
I16.8

low background area to perform a contamination frisk. Receptacles for used


contaminated clothing will be made available at the exit area.
Respiratory Protection Procedures
This procedure delineates precautions and procedures for the use of respiratory
protection equipment.
Included in this procedure are items concerning
responsibilities, selection, fit testing, issuing, use, and maintenance of respirators.
This procedure also addresses medical and bioassay evaluations.
Responsibilities
-

It is the responsibility of the RSO to ensure that all aspects of this


procedure are implemented and that all necessary materials to
implement this procedure are available. The RSO will ensure that
all potential wearers of respirators are properly trained and
knowledgeable in the use of respirators; that respirators are
properly selected, issued, and used; and that respirator
maintenance is accomplished as provided by this procedure.

All personnel wearing respirators are responsible to ensure that


they are trained and knowledgeable in the use and maintenance of
respirators. They should also ensure that they maintain themselves
qualified to wear and knowledgeable in the requirements to wear
respirators.

It is the responsibility of all personnel to conduct themselves and


their work assignments in a fashion so as to minimize, to the
greatest extent possible, the need for respiratory protection by
minimizing the amount of radioactive material disturbed into the air.

Materials
The materials necessary to implement this procedure vary. The following list
serves as a guideline of items that may be kept on hand.
*
*
*
*
*
*
*

NIOSH/MSHA Approved Respirators


HEPA Respirator Filters
Irritant Smoke Tubes
Alcohol Wipes
Face shields
Respirator Qualification Sheet
HEPA Ventilation Unit

*
*
*
*
*
*

Iodine Cleaning Solution


Respirator Repair Kit
Air Sampler
Air Sampler Filters
Ziploc Bags (for A/S filters)
Air Sample Data Log

Operating With Respirators


-

Philosophy
1) State and federal regulations state that respirators will be
prescribed only when it is likely that a potential for the
I16.9

inhalation of ingestion of radioactive material exists at levels


above those prescribed in LAC 33:XV, Chapter 4, Appendix
B, or in oxygen deficient or toxic contaminant confined space
entries. Respirators will not be a contamination control
method nor will they be used as a substitute for engineering
or process controls.
2) To the greatest extent practical, Moreno Group LLC and
Subsidiaries will incorporate process or engineering controls
to limit the concentrations of radioactive materials in the air
to levels below those specified in LAC 33:XV, Chapter 4,
Appendix B. These controls will also be used to assist in
confined space entries. These controls will include, but are
not limited to, system venting, system flushing, and the use
of containments and HEPA ventilation systems.
3) Contaminated equipment or areas may be wiped down or
decontaminated to limit the potential for airborne radioactive
or toxic contaminants and the subsequent need for
respirators.
4) Good work practices will be incorporated so as to limit the
potential for airborne radioactive or toxic contaminants and
the subsequent need for respirators.
- Respirator Selection
1) When it becomes necessary for an employee or contractor
entering a Restricted Area likely to contain airborne
contamination, that person shall wear a properly fitted
NIOSH/MSHA approved respirator equipped with cartridges
capable of removing airborne radionuclides. The RSO/NS
will determine when respirators are justified for any
maintenance activity and shall use the following
considerations:
(a) the nature of the maintenance activity,
(b) the levels of contamination,
(c) the duration of the task,
(d) the use and effectiveness
engineering controls,

of

process

and

(e) the potential for decontamination, and


(f) any other hazards present such as hydrogen sulfide,
ammoniums, or oxygen deficiency.
I16.10

2) The RSO/NS will select the appropriate respirator to ensure


that the average concentration of radioactive material
inhaled during respirator use does not exceed the
concentrations specified in LAC 33:XV, Chapter 4, Appendix
B. For confined space entries, respirators will be selected
for oxygen deficient atmospheres and to limit toxic
contaminant exposure to levels below the PEL.
3) Half-face, full face negative pressure, supplied air, and selfcontained air respirators may be used, depending on the
type and levels of contaminants encountered. For most
activities, the half-face respirator will provide sufficient
protection. However, for environments which are oxygen
deficient or contaminated with ammoniums, hydrocarbons,
or hydrogen sulfide, the RSO may determine that the selfcontained breathing respirator is warranted.
4) Respirators will only be used when necessary to limit the
potential ingestion or inhalation of radioactive materials or
toxic contaminants, or in oxygen deficient atmospheres.
When it is necessary or warranted to use respirators, it is
important to select a respirator that adequately protects the
worker, but will not unnecessarily burden him. Negative
pressure, full-face respirators and SCBAs, in particular,
increase worker fatigue and limits the time the worker may
work safely.
5) If the RSO/NS determines that respirators are warranted
based on the Hazards/Exposures, the RSO/NS will specify
the type of respirator and for what work activity it is to be
worn on the RWP and/or on the confined space entry permit.
- Fit Test
1) To ensure a given respirator provides the worker with
prescribed protection, qualitative fit tests will be performed
by every potential respirator wearer with any and every
respirator type that might be worn (i.e., half-face, full-face
negative pressure, SCBA, etc.).
2) Qualitative fit tests will be performed initially and with
refresher training.
3) Qualitative fit tests are performed by donning the respirator,
performing a negative pressure face seal test, and the
testing the face seal area with irritant or aroma smoke. By
covering the face seal area with the smoke and breathing
naturally, the respirator wearer immediately recognizes
whether the respirator fits properly.
I16.11

4) Qualitative fit test dates should be recorded and the


Respirator Qualification Sheet.
- Issuing Respirators
1) Prior to issuing a respirator to anyone, the RSO/NS, or his
designee, will determine that the individual is qualified to
wear that type of respirator.
2) As a minimum, the following items will be verified for each
wearer:
(a) physical examination,
(b) qualitative fit test,
(c) training,
(d) type and size of respirator, if appropriate.
3) Respirator qualifications need only be verified once during a
given job at a temporary jobsite as long as any individuals
qualifications will not expire during the job. Records of the
respirator qualifications shall be maintained by Moreno
Group LLC and Subsidiaries for a period not less than 5
years.
- Using Respirators
1) Inspection
(a) Each individual issued a respirator will be required to
visually inspect the respirator prior to its use to ensure
that it is in good operating condition.
(b) The inspection should include the tightness of the
connections and the condition of the harness, the
coverings, filter(s), canister(s), and the cartridge(s).
(c) Each wearer should also ensure that the filter,
cartridge, or canister being used is applicable for
radioactive particulates or radionuclides. The filter,
cartridge, or canister should be specified as 99.97%
efficient for protection against radioactive particulates
or radionuclides or for use with organic vapors and
mists.

I16.12

2) Seal Tests
(a) The wearer of a respirator shall ensure proper
protection by checking the seal of the facepiece prior
to each use by performing a negative pressure seal
test.
(b) The negative pressure seal test is performed by
covering the respirators canister or filter inlets with
the palms of the hands. The wearer then inhales
gently and holds his breath for at least 10 seconds. If
the facepiece collapses slightly and no inward
leakage of air into the respirator is detected, the fit is
considered satisfactory.
(c) No one is authorized to use any respirator without first
performing a satisfactory face seal test.
3) Relief From Use
(a) Each and every respirator user may leave the area at
any time for relief from respirator use in the event of
equipment malfunction, physical or psychological
distress, procedural or communication failure,
significant deterioration of operating conditions, or any
other condition that might require relief.
(b) Relief from use will be included as part of the pre-job
brief.
- Air Monitoring
Air monitoring will be conducted as needed.
- Medical Evaluations
1) Physicals
(a) Employees will be evaluated by competent medical
personnel to ensure that they are physically and
mentally able to perform work while wearing
respiratory protection equipment.
(b) These evaluations will be performed initially and at
least annually thereafter.
(c) Records of these physicals shall be maintained at
Moreno Group LLC and Subsidiaries for not less than
5 years.
I16.13

- Respirator Maintenance
1) Respirators will be inspected prior to each use, when
cleaned and both during and after the days work. Any
respirator not in working condition will be removed from use
and repaired or replaced.
2) Respirators will be cleaned after each use with alcohol or
other suitable swabs. At the end of the work shift, the
respirators will be washed in soapy water and let to dry.
3) Respirators will be maintained in bags or some other
protective enclosure to ensure that they do not become
contaminated. They shall be stored in a clean, dry area,
preferably out of direct sunlight.
ALARA PROGRAM
Philosophy
Moreno Group LLC and Subsidiaries will maintain all exposure to personnel and the
environment ALARA (as low as reasonable achievable). This will be accomplished
by minimizing personnel time spent in the vicinity of radioactive sources and by
maximizing distance from radioactive sources. ALARA practices will also include
necessary surveys, safety/radiological meetings, and other measures to track,
control, and dispose of NORM appropriately and in accordance with the radiation
protection philosophy of this license and existing regulations.
Program Structure and Responsibilities
The ALARA program consists of all Moreno Group LLC and Subsidiaries personnel:
workers (both employee and Contractor), supervisors and management.

I16.14

Moreno Group LLC and Subsidiaries Management has the responsibility


to generate and maintain company commitment to ALARA principles and
practices. Management must ensure that area audits are performed at a
frequency and depth to evaluate the success of this program and to
facilitate necessary changes ensuring that all exposures to personnel and
the environment are ALARA. Management shall also provide direction to
the RSO/NS in the development and implementation of this program.

RSO/NSs have the direct responsibility of developing, implementing, and


evaluating ALARA procedures. They shall take direction from Moreno
Group LLC and Subsidiaries management and provide continuous
surveillance of any areas that apply to the program and address the
conditions that exist. The RSO/NS has the authority to enforce any
regulations and administrative policies that affect any aspect of the
program.

All Moreno Group LLC and Subsidiaries personnel shall adhere to the
rules and procedures established by the RSO/NS. The worker must
report any unsafe work practices and/or equipment malfunctions that
could result in any increase of radiological hazard to the RSO/NS or his
designee. The worker may also make suggestions as to improve the
ALARA program.

Administrative Procedures
-

Frequent inspections and audits of operational practices shall provide


Moreno Group LLC and Subsidiaries management with necessary
information to conduct an appropriate ALARA program. These inspections
shall be made at intervals not to exceed 12 months. Documentation of the
finding shall be maintained and will provide future references to make
comparisons during the development of an effective program.

The following shall serve as a guideline for documentation of inspections


and audits:
a) employee exposure records
b) bioassay results
c) logs of inspections made of the program
d) documented training program activities
e) pre-job briefs
f) survey and sampling data
g) facility changes and reviews
h) discussions of the findings during the inspections and audits
-

NORM training shall include reference to this program and the concepts
this program is based on.

Written Procedures
Standard procedures shall be written for all practices involving the handling,
processing, and temporary storage of NORM. These procedures should contain
proper radiation work practices to minimize exposure during all NORM activities.
Operating Procedures
The ALARA program shall be maintained while performing NORM activities at the
Moreno Group LLC and Subsidiaries temporary jobsites. It is the responsibility of
each individual to adhere to procedures for safe radiological work practices.
I16.15

During operations, the RSO/NS is responsible for implementing the


ALARA program.

Pre-job briefings shall be conducted prior to commencing work activities to


inform workers of existing radiological conditions and ALARA work
practices.

Surveys shall be performed in accordance with this license to identify any


changes in radiological conditions.

Minimization of potential hazards can be accomplished through the use of


engineering controls such as ventilation systems, HEPA units, wetting of
materials to reduce airborne contamination, etc..

Protective equipment shall be worn as required to prevent any


unnecessary exposure to radioactive materials. It is the duty of the
RSO/NS to assign the proper personal protective equipment for tasks
associated with the NORM activities taking place.

Access to areas containing NORM should be controlled in such a way as


to prevent any unnecessary exposures to personnel or the environment.

Workers shall be made aware of any changes in the program and


procedures pertinent to maintaining safe radiological work practices and
be reminded of the basics: minimize time and maximize distance from
radioactive sources.

Equipment Design and Facility Use


-

The jobsite layout, types, and placement of equipment to be used during


NORM activities should be considered prior to commencing work. It
should be established in such a manner as to minimize exposure to
personnel while at the same time reducing the risk of exposure to
unauthorized
persons
and
the
environment.

Packages containing NORM should be stored in the designated areas and


posted in accordance with this license and LAC 33:XV to prevent
unnecessary exposures to personnel.

ACCIDENTS
In the event of an accident, fire, release, or spill, the RSO/NS will be immediately
notified. First priority will always be given to injured personnel. Radiological
concerns will be addressed only after conditions involving personnel, fires,
uncontrolled releases, or spills have been stabilized. In the event of a spill, the
person discovering it shall immediately implement the Spill Contingency Plan in
Section 11.0 of this license.

I16.16

RADIATION TRAINING REQUIREMENTS


All persons entering a Restricted Area will be trained in accordance with LAC
33:XV.1012.
This training shall consist of a minimum of 8 hours classroom instruction,
practical factors, and an examination. This course of instruction will be
provided by individuals recognized by LDEQ/RPD as having sufficient
knowledge and skills to provide such training.
Visitors and short term contractors shall be briefed.
A minimum of eight hours refresher training shall be conducted annually.
Employees shall also receive respiratory protection training as per DII
Respiratory Protection program.
Other personnel not working directly with NORM, will receive NORM awareness
level training during New Hire Orientation / SH&E Training. This training shall
consist of the hazards related to NORM exposure and protection methods.
REPORTING
RESPONSIBILITY
The corporate RSO or his designee is responsible for making reports to the
Louisiana Department of Environmental Quality / Radiation Protection Division
(pursuant to LAC 33:XV. Chapter 4, Subchapter J) should any of the following
become necessary:
Reports of Stolen, Lost, or Missing Sources of Radiation
- Telephone Reports
a) Immediately after its occurrence becomes known to Moreno Group
LLC and Subsidiaries, stolen, lost, or missing radioactive material in
an aggregate quantity equal to or greater than 1,000 times the
quantity specified in Chapter 4, Appendix C under such
circumstances that it appears to Moreno Group LLC and
Subsidiaries that an exposure could result to individuals in
unrestricted areas; or
b) Within 30 days after its occurrence becomes known to Moreno
Group LLC and Subsidiaries, stolen, lost, or missing radioactive
material in an aggregate quantity greater than 10 times the quantity
specified in Chapter 4, Appendix C that is still missing.
- Written Reports
I16.17

Should Moreno Group LLC and Subsidiaries be required to make a report as


mentioned above, a written report to LDEQ/RPD shall be made within 30 days after
making the telephone report setting forth the following information:
a) A description of the NORM involved, including the kind, quantity,
and chemical & physical form;
b) A description of the circumstances under which the loss or theft
occurred;
c) A statement of disposition, or probable disposition, of the NORM
involved;
d) Exposure of individuals to radiation, circumstances under which the
exposures occurred, and the possible total effective dose
equivalent to persons in unrestricted areas;
e) Actions that have been taken, or will be taken, to recover the
NORM; and
f) Procedures or measures that have been, or will be, adopted to
ensure against a recurrence of the loss or theft of NORM.

Subsequent to filing the written report, Moreno Group LLC and


Subsidiaries shall also report additional substantive information on the
loss or theft within 30 days after learning of such information.

Moreno Group LLC and Subsidiaries shall prepare any report filed to
LDEQ/RPD so that names of individuals who may have received exposure
to radiation are stated in a separate and detachable portion of the report.

Notification of Incidents
-

Given that oilfield NORM should not reach elevated levels of exposure,
should it occur, Moreno Group LLC and Subsidiaries will follow the
procedures listed in LAC 33:XV.486 and 487.

Notifications of Spills (See Section 11.2 of this license)


Notifications and Reports to Individuals

I16.18

Requirements for notification and reports to individuals of exposure to


radiation or radioactive material are specified in this license and LAC
33:XV.1013.

Should Moreno Group LLC and Subsidiaries be required to report to


LDEQ/RPD pursuant to LAC 33:XV.487, Moreno Group LLC and
Subsidiaries will also notify the individual at a time no later than the

transmittal to division and shall comply with the provisions of LAC


33:XV.1013.A.
Quarterly Work Activity Report
-

This report shall be submitted to LDEQ/RPD within 30 days of the end of


each calendar quarter. Should additional time become necessary for
preparation and submittal of this report, a written request for extension will
be forwarded to LDEQ/RPD.

It will include waste generating activities from the Moreno Group LLC and
Subsidiaries temporary jobsites within LDEQ/RPD jurisdiction.

The report shall list the customer (or generator) name, jobsite location,
dates of job, amount of waste generated, and the date the waste was
transferred.

Financial Security Requirements


-

Pursuant to LAC 33:XV.1420, Moreno Group LLC and Subsidiaries shall


post with the division financial security to ensure protection of the public
health and safety and the environment in the event of abandonment,
default, or other inability or unwillingness of Moreno Group LLC and
Subsidiaries to meet the requirements of the state and federal rules and
regulations. This financial security shall:

a) name the division as beneficiary with a bond issued by a fidelity or surety


company authorized to do business in Louisiana. The amount of the bond
shall be equal to or greater than the amount of the security required. It
shall be available in Louisiana and subject to judicial process and
execution in the event required for the purposes set forth in LAC 33:XV,
Chapter 14 and be continuous for the term of the license; and
b) be in an amount based upon a division-approved cost estimates plan for
decontamination, decommissioning, restoration, and reclamation of
buildings, equipment, and the site to levels that would allow unrestricted
use.
- No later than 90 days after Moreno Group LLC and Subsidiaries notifies
LDEQ/RPD that decontamination and decommissioning have been
completed, the division shall determine if these have been conducted in
accordance with appropriate rules and regulations. If the division finds that
the requirements have been met, the secretary or his designee shall direct
the return or release of Moreno Group LLC and Subsidiaries security in full
plus any accumulated interest within 14 days. If the division finds that
these requirements have not been met, the division will notify Moreno
Group LLC and Subsidiaries of the steps necessary for compliance.

I16.19

RADIATION AND CONTAMINATION SURVEYS


Radiation surveys shall be conducted to determine exposure rates, area postings,
presence or absence of loose surface, fixed and airborne contamination and for
establishing baseline and release criteria.
ACTION LEVELS FOR DEFINING RADIATION AREAS
Definitions
A Radiation Area is an area accessible to individuals in which there exists radiation
at such levels that a major portion of the body could receive in any one hour a dose
in excess of 5 millirems (0.05 millisievert), or in any five consecutive days, a dose in
excess of 100 millirems (1 millisievert).
A High Radiation Area is an area accessible to individuals in which there exist
radiation at such levels that a major portion of the body could receive in any one
hour a dose in excess of 100 millirems (1 millisievert).
An Airborne Radioactivity Area is an area in which airborne radioactive materials
exists in concentrations:
-

in excess of the derived air concentrations (DACs) specified in LAC


33:XV Chapter 4, Appendix B, Table 1; or

to such a degree that an individual present in the area without


respiratory protective equipment could exceed, during the hours an
individual is present in a week, an intake of 0.6% of the annual limit
on intake (ALI) or 12 DAC hours.

A Radioactive Material Area is an area where NORM contaminated equipment or


waste is stored, utilized, or treated. A facility or area may be posted as a
Radioactive Material Area and contain within it one or more work areas controlled as
Restricted Areas.
A Restricted Area is an area, excess to which is limited by the license for the
purpose of protecting individuals against undue risks from exposure to sources of
radiation.
Radiation surveys shall be conducted at each jobsite to ensure that the
exposure rates are less than 2,000 uR/hr at the boundary of any Restricted
Area and that exposure rates at the perimeter are such that a member of the
general public will not receive a dose greater than 100 mrem in one calendar
year. An action level of 600 uR/hr will be used for exposure rates at the
perimeter of temporary jobsites. If this exposure rate is encountered
anywhere on the perimeter, work activities will stop and the RSO will be
immediately notified. Work activities shall not recommence until the radiation
levels at the perimeter have been lowered.

I16.20

The Restricted Area boundary surveys shall be conducted before, during, and
after all work activities involving NORM operations. A minimum of one
radiation and contamination boundary survey shall be conducted each day at
temporary jobsites. Additional surveys shall be conducted as warranted by
the work activities and as directed by the RSO.
Survey results shall be documented on a jobsite sketch or map and reported
to the RSO. Records of surveys shall be maintained for a period of not less
than 5 years at Moreno Group LLC and Subsidiaries
EQUIPMENT CONTAMINATION SURVEYS
Wipe Tests
-

Random wipe tests shall be taken of contaminated equipment at the


Moreno Group LLC and Subsidiaries temporary jobsites to ascertain the
presence or absence of loose surface contamination upon receipt of the
material and to verify decontamination to acceptable levels.

The wipe shall be of a porous material approximately 1 in diameter and


shall be wiped across an accessible area of the equipment equivalent to
approximately 100 square centimeters.

Only those persons who have received, at a minimum, proper training for
NORM surveying will be allowed to conduct wipe testing of equipment, etc.
A Ludlum Model 2 survey meter outfitted with a Ludlum Model 44-9 probe (or
equivalent instrumentation) shall be used to measure the wipes. Other
information on instrumentation can be found in Section 9.0 of this license.
After the wipe has been taken, it will be brought to an area of low background
(equal to or less than 50 cpm) and counted with the instrumentation listed
above. Taking into account the instrument efficiency, add the background
reading to the action level of 100 cpm to get a true action level. Items with
loose surface contamination exceeding this true action level will be handled
as NORM contaminated and appropriate action taken. If the item has been
verified free of loose surface contamination, the item shall be taken to an area
of low background and surveyed for fixed contamination over 100% of all
accessible surfaces. Any item found to have fixed contamination exceeding
levels for unrestricted use, or as directed by the customer, shall not be
released for such use. Should the item contain levels exceeding those
specified in LAC 33:XV.1404, it shall be handled and controlled as NORM
contaminated.

PERSONNEL CONTAMINATION SURVEYS


A Ludlum Model 2 survey meter outfitted with a Ludlum 44-9 probe (or
equivalent instrumentation) shall be utilized to perform contamination surveys.
See Section 9.0 for further information.
I16.21

Only those persons who received, at a minimum, proper training for NORM
surveying shall be allowed to perform personal frisks.
Personal Frisking Procedures
-

All personnel entering Restricted Areas will be required, as a minimum, to


perform a hand and foot frisk immediately upon exiting the Restricted
Area. A whole body frisk will be performed before leaving the work site
and when protective clothing was worn in the Restricted Area.

The probe shall be held within of the body and moved at a rate of 2 3
inches per second. Any sustained readings above background shall be
cause to slow or stop the probe over the affected area for adequate
measurement. Should the reading persist, the contamination in that area
shall be removed and the person refrisked.

Any contamination found on personnel shall be immediately reported to


the RSO/NS. The RSO/NS will identify where the individual became
contaminated and what work activities he was involved in. Personal
protective measures and work activities shall be reviewed to prevent a
recurrence of the incident. The RSO/NS shall complete an Incident
Report Form for each contaminated individual. As a minimum, the report
shall document:
a) the full name of the individual,
b) the date and time the incident occurred,
c) location(s) on the body and level(s) to which the individual was
contaminated,
d) approximate length of time the individual was contaminated,
e) work location where the
circumstances involved,

contamination

occurred

and

the

f) methods of decontamination and level to which the individual was


decontaminated,
g) corrective actions which can be taken to prevent recurrence.

I16.22

After completion of the Incident Report Form, the RSO/NS shall review the
form with the individual. The individual will counter-sign the form
indicating the information contained on the form is true and correct to the
best of his knowledge.

Personnel shall not be allowed to leave the temporary jobsite with


accessible loose surface contamination. An exception will only be made
in event of a life threatening injury to a person requiring immediate

medical attention. Whenever possible, the RSO/NS will arrange for


decontamination of the person prior to leaving the Restricted Area.
SAMPLING
SOIL SAMPLING
Temporary Jobsites
Procedures
-

Soil and sediment samples shall be taken at a depth up to 15 cm


retrieving approximately one liter of soil to be analyzed.

Appropriate sampling tools (i.e., shovel, trowel, auger, coring device, etc.)
shall be utilized to retrieve representative samples at the appropriate
depths. Tools will be wiped and cleaned between samples to prevent
possible cross contamination.

Each sample shall be placed into a suitable container (i.e., Ziploc bag,
plastic wide-mouth container, etc.) and labeled including customer name,
date, project number, sample number, sample location, contents, and any
other appropriate markings for shipping protocol.

A chain of custody will be completed with a minimum of one copy retained


for project files and one copy to accompany the sample shipment to the
laboratory.

All soil and sediment samples shall be analyzed by a laboratory


recognized or licensed by the LDEQ/RPD to perform analysis of
radioactive materials and which utilizes National Institute of Standards and
Testing (NIST) traceable sources. The reporting units shall be in
picocuries per gram.

WATER SAMPLING
Wash water
-

A decontamination area will be established at temporary jobsites and


provisions will be made to collect all wash water so as to prevent the
spread of NORM contaminated fluids or materials to uncontrolled areas.
The wash water collected will be filtered to remove particulates and
recycled for further wash down activities. Settling tanks may also be used
to remove solids from the water. Decontamination activities will stop if any
water leaks are noted and shall not recommence until the leak has been
corrected. The wash water collected shall be considered NORM waste
until a laboratory analysis proves otherwise.

Any surface (or ground) water that may accumulate in a low or remediated
area of known NORM contamination shall be pumped into appropriate
I16.23

containers. The water will be filtered to remove particulates and recycled for
further wash down activities. It will also be considered NORM waste until a
laboratory analysis proves otherwise.
Sampling procedures
-

A sample measuring approximately one (1) gallon will be collected into an


appropriate container and marked.

A chain of custody shall be completed and handled.

Laboratory analysis shall be in picocuries per milliliter.

Under no circumstances will washwater be released for unrestricted


discharge. Once analysis of the water proves it to be below 60 pCi/L,
approval from the Louisiana Office of Conservation will be solicited for proper
disposal at a state-approval injection well.
AIR SAMPLING
Air sampling for radioactive materials shall be performed in accordance with Section
3.2.C of this license.
ENVIRONMENTAL RESPONSIBILITIES
BASELINE AND RELEASE SURVEYS OF TEMPORARY JOBSITES
Prior to commencement of any NORM work activities at a temporary jobsite, a
baseline radiological survey of the area shall be conducted in accordance with LAC
33:XV Chapter 14 and the guidelines contained in the current Implementation
Manual for Management of NORM in Louisiana. The survey shall include, but is not
limited to, the following:
Baseline Dose Rate Survey
-

Instrumentation utilized per manufacture requirements.

A dose rate survey shall be performed in an area immediately adjacent to


the proposed work site to determine background levels of exposure.

A dose rate survey shall be performed on the lands, equipment, and well
head found on the work site.
a) The survey will be documented on gridded survey maps or plats.
The maps shall be constructed so that grid locations can be easily
identified and referenced. All notes and other information not
recorded directly on the map should be referenced to grid locations.
Maps should be of sufficient size and scale to contain all survey
information, sample locations, and all significant objects.

I16.24

b) In no case will grid spacing be greater than 10 meters. In areas of


known contamination, the grid spacing shall not exceed 3 meters.
Each grid line should be surveyed from outside point to outside
point. Readings should be recorded at no more than 10 meters or
3 meter intervals, as appropriate.
c) Survey instrument readings shall be taken within 1 cm of the
ground surface or any object surveyed. The response of the survey
instrument shall be continuously monitored while performing the
survey.
d) Any areas surveyed reading twice background levels of
radioactivity or greater when performing the initial baseline dose
rate survey shall be noted on the grid map as a potential sampling
location and a 100 square meter delineation constructed.
e) Upon completion of the land survey, all areas of identified
contamination should be demarcated to prevent workers from
walking through the contamination, thereby reducing the potential
of contaminating themselves and spreading contamination. The
surveyor will then perform a whole body frisk to verify the absence
of contamination on his body.
-

A copy of the baseline dose rate survey shall be retained on the temporary
jobsite for the duration of the project for review by the RSO/NS, other
employees & contractors, and the LDEQ.

Baseline Soil Sampling


- A minimum of three (3) soil samples shall be taken within the first 15 cm in
the following locations:
f) in an area adjacent to the work site to determine area background
levels,
g) within the worksite, at or outside of the Restricted Area boundary,
and
h) at the point of work activities within the Restricted Area.
- Additional soil samples may be taken of the areas delineated as potential
sampling locations on the grid map.
- Sample locations shall be marked on the grid map.
- Sampling procedures shall be in accordance with the license and the
implementation manual mentioned in the preceding page.
- A copy of the baseline survey report indicating soil sample locations and
soil sample analysis results shall be kept on the temporary jobsite for
review by the RSO/NS, other employees & contractors, and the LDEQ.
Upon completion of work activities involving NORM at the temporary jobsite, a
similar dose rate survey shall be made with soil samples retaken in the initial
baseline locations for comparison. Any increase in dose rates or activity as
I16.25

compared to the initial baseline survey shall be documented on a survey map


and reported to the RSO/NS. Those areas noted with dose rates above those
identified in the baseline survey shall be sampled or decontaminated as
necessary.
Records of the baseline and release surveys of temporary jobsites shall be
retained at Moreno Group LLC and Subsidiaries for a period of not less than 5
years; or, until copies have been turned over to LDEQ for site closure.
RELEASE FOR UNRESTRICTED USE
Pursuant to LAC 33:XV.1417, facilities, equipment and land exceeding the level of
contamination provided in LAC 33:XV.1404 and are subject to the provisions of
Chapter 14, they shall not be released for unrestricted use until they have been
decontaminated in accordance with this license and LRR.
For equipment contaminated in excess of limits specified, decontamination
must be performed to reduce exposure levels below 50 microroentgens per
hour including background and ensure that it is free of loose surface
contamination (or to current regulatory limits).
For areas or soil contaminated in excess of those specified limits,
decontamination shall be to five picocuries per gram above background of
radium-226 or radium-228. However, prior to land being released for
unrestricted use, the closure procedures contained in LAC 33:XV.1417.B,C,D,
& E must be met.
PREVENTING THE SPREAD OF CONTAMINATION
All personnel involved with NORM work activities shall make a conscious effort to
avoid conditions leading to the uncontrolled release of NORM which may
contaminate personnel, equipment, and the environment. All unsafe working
conditions and defective equipment shall be reported to the RSO/NS, SH&E Officer,
or Work Supervisor immediately.
Although it is difficult to anticipate all potential scenarios and proceduralize the steps
to take, Moreno Group LLC and Subsidiaries will take necessary actions to ensure
that no contaminated, or potentially contaminated, equipment or materials come in
direct contact with unprotected skin or uncovered ground or soil. Moreno Group LLC
and Subsidiaries will also take actions necessary to ensure that NORM particulates
are not allowed to become inhaled or ingested. The following steps shall be
followed to provide adequate protection against the spread of NORM contamination
for workers, the public, and the environment.
A baseline radiological survey will be performed of all temporary jobsites.
Refer to the license and LRR for further information on these surveys.
Daily visual inspections of equipment shall be made by the RSO/NS, SH&E
Officer, or another designated representative to ensure that hoses, pipes,
I16.26

valves, flanges, pumps, and containers are not leaking NORM or other
contaminants to the environment.
Per existing regulations and conditions of this license, only properly briefed
and/or trained individuals shall be allowed to work with NORM.
A boundary shall be established around the jobsite and posted with
appropriate signs as specified in LAC 33:XV.450, 451 & 452 and Section 5.2
of this license. The signs shall bear the conventional radiation colors
(magenta, purple, or black on a yellow background) and the three blade trifoil design. As a minimum, the sign shall bear the words Caution
Radioactive Materials.
Additional postings such as Radiation Area,
Airborne Radioactivity Area, Restricted Area, etc. may be required
depending upon other activities taking place.
The area posted and controlled as a Restricted Area shall be kept as small as
possible. However, the area will be large enough to allow for all work and transit of
personnel and equipment to be performed in a safe manner.
No eating, drinking, smoking, or chewing will be allowed within the Restricted
Area or Radioactivity Area. Open wounds, sores or cuts shall be reported to
the RSO/NS and covered with bandages and/or protective clothing prior to
working in the Restricted Area or Radioactivity Area.
The provisions of the RWP shall be carried out which delineates, among other
things, personal protection requirements as specified in the Health Physics
section of this license.
Depending on the site conditions and layout, plastic sheeting, rubber or
plastic mats, drip pans, cement or plastic lined slabs, or other non-permeable
material shall be used to minimize the potential spread of contamination.
A point of entry and egress from the Restricted Area shall be designated and
established based on several conditions, not the least of which concerns
personal and environmental safety. As stipulated in the license, all personnel
exiting controlled areas will perform a personal frisk to ensure that
contamination is not being removed from the controlled area and that the
individual is not contaminated.
All containers and equipment used in NORM work activities will be wiped or
smeared for loose surface contamination per the license. They will not be
released for unrestricted use should those levels reach or exceed twice
background.
Prior to being released for unrestricted use, facilities, equipment, or sites shall
be decontaminated in accordance with this license and current LRR.
As directed by the RSO/NS, radiation & contamination surveys shall be
performed or controlled areas at temporary jobsites.
They shall be
I16.27

documented & maintained for review by employees, contractors, and LDEQ


at Moreno Group LLC and Subsidiaries for a period of not less than five (5)
years.
During NORM activities which may cause NORM materials to become
airborne, air samples will be taken of the workers breathing zone and at the
Restricted Area boundary per Section 3.2.C of this license.
When NORM activities are to be continued the next day, the work area shall
be placed in a controlled condition to prevent the release or escape of NORM
contaminants.
All containers shall be surveyed and labeled according to the clients
procedures and current radiation regulations. At a minimum, they shall be
marked with the generators name, contents, date sealed, identification
number, and the maximum dose rate.
Wash or process water will be filtered and recycled to minimize the
generation of contaminated fluids. All remaining waste water will be sampled
and analyzed by a laboratory which utilizes NIST traceable standards for
radioactivity and disposed of as per existing regulations and policies.
All other waste materials generated from NORM activities will be surveyed,
decontaminated or disposed of in accordance with existing state and federal
regulations and policies.
Upon completion of NORM activities at a temporary jobsite, a release survey
shall be performed in accordance with the license.
Records of all NORM activities will be properly documented and maintained
at Moreno Group LLC and Subsidiaries for a period of not less than 5 years.
RECEIPT, TEMPORARY STORAGE AND TRANSFER
OF NORM AND NORM CONTAMINATED MATERIALS
NORM contaminated equipment, and waste generated from NORM activities, shall
be temporarily stored and handled pursuant to the following procedures.
MATERIAL RECEIPT
NORM material received at temporary jobsite shall be handled as follows:
The person designated to register receipt of NORM materials shall ensure
that all documentation (i.e., prior written confirmation of the acceptability,
manifests, etc.) has been received and/or shipped with the NORM material.
He will also ensure that the paperwork adequately reflects the material being
received.

I16.28

All items received shall be randomly surveyed for radiation levels and loose
surface contamination. Items having loose surface contamination shall be
controlled and worker protection measures placed in effect (i.e., protective
clothing, sealing exposed openings with plastic or other suitable materials
preventing the spread of contamination) until such time that the items have
been moved into a decontamination area and/or decontaminated. In addition,
trucks, boats, or other vehicles transporting the NORM shall be surveyed for
loose surface contamination and shall not be released for unrestricted use
until verified free of contamination.
Records shall be kept of NORM contaminated equipment and materials
received and shall include, but not be limited to:
-

the name, address, phone, and general license number of the generator;

the amount (or estimate) of drums, containers, tubulars, etc., included in


the shipment;

the maximum dose rate obtained from the random survey of the external
surface of the material the NORM is contained in;

the presence of any loose surface contamination on the external surface


of the material;

the date of the survey; and,

the name of the person performing the survey.

Upon completion of the radiation and contamination surveys, the received


items shall be moved to a designated temporary storage location to await
further action.
TEMPORARY STORAGE AREAS
Temporary storage areas shall be posted with conspicuous signs reading, as
a minimum, Caution-Radioactive Materials.
Additional postings may
become necessary depending on exposure levels.
Access will be controlled by erecting rope or tape barriers, as a minimum,
around the storage area when NORM materials or equipment is being stored.
No person will be allowed entrance into the storage area until that individual
has been briefed and/or appropriately trained in the precautions and potential
hazards of NORM.
Visual inspections shall be made of the temporary storage areas.
temporary jobsites, they shall be performed daily

On

During the inspection, the designated individual shall look for leaking or deteriorating
containers, labels, and the condition of materials preventing the spread of
I16.29

contamination. The RSO/NS shall be informed of any container holding NORM


waste that is found not to be in good or safe condition (i.e., severe rusting, leaks,
apparent structural defects, etc.) The NORM from the defective container shall be
transferred to a container free from material defects and the area decontaminated as
soon as possible.
Records of the inspections shall be maintained per LAC 33:XV.1414.G for inspection
by the RSO/NS and LDEQ at the jobsite for the duration of the project and/or at
Moreno Group LLC and Subsidiaries job for a period of not less than 5 years.
An inventory of all containers stored in the temporary storage area(s) shall be
maintained. The inventory shall contain, as a minimum, unique identification
numbers, origin of the item (i.e., owner or generator name), date transferred
to storage (or date sealed of the item is a waste container), item exposure
rate, date removed form storage, and place transferred to.
Moreno Group LLC and Subsidiaries Does not intend to store NORM waste at
their Facilities.
CONTAINERS
NORM and NORM waste shall be kept in containers that are in good or safe
condition. The container shall meet DOT approval and be made of, or lined
with, materials that will not react with, or be incompatible with, the NORM
waste to be stored so that the ability of the container to contain the waste is
not impaired or compromised.
A container of NORM waste shall not be opened, handled, or stored in a
manner that may rupture it or cause it to leak. It shall be closed and sealed
during storage, except when necessary to add or remove waste.
All containers of NORM waste shall be stacked in a fashion that each
container identification label can be read from the access aisle or area.
Containers having higher exposure rates shall be arranged so as to minimize
boundary exposure rates.
All containers of NORM waste shall bear a durable, clearly visible label
bearing the radiation symbol and the words Caution Radioactive Material.
Other markings shall include, but not be limited to, name of the generator,
date sealed, unique identification number, contents, and exposure levels to
permit individuals handling or using the containers, or working in the vicinity of
the containers, to take precautions to avoid or minimize exposures.
Prior to removal or disposal of empty uncontaminated containers to
unrestricted areas, removal or defacing of the radioactive material label and
markings shall be performed or otherwise clearly indicated that the container
no longer contains radioactive materials.
TRANSFER FOR DISPOSAL AND MANIFESTS
I16.30

All NORM waste generated by activities performed by Moreno Group LLC


and Subsidiaries Remains the property of the generator and is shipped to
either his authorized temporary storage location or disposal facility.
Waste transfers shall be accompanied by a shipment manifest that contains
the name, address, and phone number of the generator, transporter, and
designated facility for receipt of the material. Transfer, manifest, and
documentation requirements shall be conducted in accordance with LAC
33:XV.1412 & 1418, Chapter 15, and as appropriate, DOT regulations and
policies.
INSTRUMENTATION
Radiation and contamination survey instruments should conform to specifications in
LAC 33:XV.1406 and the following guidelines.
EXPOSURE INSTRUMENTATION
Instrumentation utilized to measure gamma radiation exposure rates from land and
equipment shall be capable of measuring from 1 to 5000 microreontgens per hour.
This may be accomplished with a Ludlum Model 3 survey meter equipped with a
Ludlum Model 44-2 sodium iodide detector (or equivalent instrumentation). At least
one exposure rate instrument shall be available at each temporary jobsite.
CONTAMINATION INSTRUMENTATION
Instrumentation utilized to detect both alpha and beta particle contamination on
personnel and equipment shall be capable of measuring from 1 to 500,000 counts
per minute (cpm). A Ludlum Model 2 survey meter equipped with a Ludlum Model
44-9 GM Pancake probe (or equivalent instrumentation) may be used. At least one
contamination survey instrument shall be available at each temporary jobsites.
CALIBRATION
The following companies offer survey instrument calibration that may be used by
Moreno Group LLC and Subsidiaries:
Amersham Corporation
Suntrac Services, Inc.
Ludlum Measurements, Inc.
Total Safety

Baton Rouge, LA.


Webster, TX.
Sweetwater, TX.
Broussard, LA.

(504) 751-5893
(713) 280-9982
(915) 235-5494
(800) 824-4250

Each survey instrument shall be calibrated: at intervals not to exceed one year; any
time the instrument is found to respond inconsistently to a known source; when it
shows any indication of physical damage; after each instrument servicing; at
energies and radiation levels appropriate for use; and, so that accuracy within plus
or minus 20 percent of the true radiation level can be demonstrated on each scale.

I16.31

PRE-OPERATIONAL TESTING OF SURVEY INSTRUMENTS


Four different pre-and post-operational checks will be performed on survey
instruments. They may also be conducted any time the user believes and
instrument may not be operating properly. These checks include:
A physical integrity check,
A battery check (to also be performed during each use)
Source response check (with a button source, lantern mantle, or NORM
sample)
Check the calibration sticker to ensure proper calibration requirements
have been met.
CARE AND USE
Radiation and contamination survey instruments are very fragile. Therefore,
extreme care will be taken during storage and while being handled. When surveying
personnel, equipment, or land for unrestricted release, the instruments shall only be
used by individuals trained in accordance with this license and current LRR.
DECONTAMINATION
PERSONNEL DECONTAMINATION
All personnel exiting a Restricted Area are required to have a personal frisk
performed as outline in the license. When sustained readings above background
are encountered requiring decontamination, the method used should be chosen on
the basis of not only the effectiveness of removing the contamination, but also the
effect it will have on the individual.
NORM contamination on the skin is best removed by gently washing the
affected area with a mild, high lather soap and tepid water. A waterless
washing gel may also be used and wiped from the skin with rags being
careful not to push the contamination further into the skin. Upon completion
of the initial washing process, the affected area shall be re-surveyed. If
necessary, a second washing will be performed and the area again
resurveyed. If contamination is still present after two washings, the RSO/NS
will be contacted for further guidance.
If clothing (or rags) is found to be contaminated, it shall be washed and
surveyed until it is free of contamination. If it cannot be decontaminated, it
shall be disposed of as NORM waste.
All wash water shall be collected and handled in accordance the license.

I16.32

If necessary, and Incident Report Form shall be completed in accordance with


the license.
EQUIPMENT DECONTAMINATION
A decontamination area will be established at the temporary jobsites.
The area will be of a size to adequately contain essential working personnel,
the equipment being decontaminated, the decontamination equipment, and all
wash water. Proper postings and boundaries shall be utilized in accordance
with this license and LRR.
Decontamination shall be accomplished by the simplest and most
radiologically-sound method. Wipedown and washing with low pressure
water is preferable to high pressure hydro-lancing. Prior to beginning
decontamination, consideration will be given to the potential for spreading
NORM throughout the decontamination area during the decontamination
process.
All wash water shall be collected and handled in accordance with Section
6.2.A. of this license.
After decontaminating the item(s), a contamination survey shall be performed
in accordance with the license.
LAND DECONTAMINATION
In the unlikely event land should become contaminated, the procedures for land
remediation outlined in the license shall be followed. Other pertinent sections of this
license and LRR shall also be followed.
SPILL CONTINGENCY PLAN
This spill contingency plan consists of procedures to follow in the event of a spill of
NORM materials. Its purpose is to provide coordinated response to spills or
accidental discharges of NORM waste. The RSO/NS is responsible for ensuring
that all personnel are familiar with this plan. The RSO/NS is also responsible for
ensuring that the spill is stopped and for any subsequent cleanup and
decontamination efforts.
BASIC SPILL PROCEDURES
This spill contingency plan will follow the basic S.W.I.M.S. procedures as outlined
below. All of the steps in the procedures shall be carried out concurrently with each
other.
Stop the spill. The primary effort of personnel upon noticing the spill will be to
stop the spill. This may be accomplished by simple operations such as
closing a container, shutting a valve, stopping a pump, or tightening a flange
or gasket.
I16.33

Warn others. It is the responsibility of the person noticing the spill to warn
others in the vicinity of the spill of the danger and ensure that the RSO/NS is
notified of the occurrence as soon as possible.
Isolate the area. It is the responsibility of the personnel combating the spill to
contain the spill and isolate the area of occurrence to prevent possible
inadvertent personnel contamination.
Minimize the spill spread and personnel exposure. Every effort shall be made
by the personnel combating the spill to contain the spill to as small an area as
possible. Additionally, the personnel will take steps to minimize their
exposure. Exposure to NORM contaminants can be prevented through use
of appropriate protective clothing. Other measures may be taken as noted in
the license and/or as directed by the RSO/NS.
Secure operations. All operations which could possible result in the spread of
the spill, or which could cause the spilled effluents to become airborne, shall
be immediately stopped.
NOTIFICATION REQUIREMENTS
The RSO/NS on duty will be responsible for determining which spills and
incidents need to be reported to the corporate RSO. The corporate RSO
shall
then determine if the spill or incident needs to be reported to LDEQ/RPD in
accordance with LRR. These spill or incidents shall be reported to:
STATE OF LOUISIANA
Department of Environmental Quality
Office of Air Quality and Radiation Protection
Radiation Protection Division
P.O. Box 4313
Baton Rouge, LA. 770821-4313
(225) 765-0160
Additionally, the RSO/NS shall determine if it is necessary to contact one or
more of the members of Moreno Group LLC and Subsidiaries Radiation
Safety Committee. The following names are listed in order of priority for
contact.
Corporate Radiation Safety Officer ........ Alan Tasar
Work:
337-364-7170
Cell
337-577-4994
Environmental Manager ......................... Anthony Sagrera II
Work
337-364-7170
Cell
337-298-8615
I16.34

Upon detection of a spill or incident requiring notification, the corporate RSO,


or his designee, will give verbal notification to LDEQ/RPD. At a minimum, the
report shall include:
-

The name of the person reporting the spill / incident and a telephone
number where he may be reached.

The location of the spill / incident.

Time and date the spill / incident began and ended, or the estimated time
of continuation of discharge of the material

Best estimate of the amount of NORM contaminated material lost in the


spill, including the method of calculating the spill volume.

The potential for personnel exposure to the NORM contaminants.

Within seven (7) days following a verbal report, a written report shall be
submitted to LDEQ/RPD. The written report shall include:
-

The name of the person filing the written report.

Time and date of the verbal notification and name of the person who made
the verbal notification.

Date and time that the spill / incident occurred.

Details of the circumstances and events that caused the spill / incident.

Best estimate of the amount of NORM contaminated material lost,


including the method for calculation the spill volume.

Description of the remedial action taken to recover any NORM


contaminated material and to restore any contaminated material to its
original state.

Procedures or measures which have or will be adopted to prevent a


recurrence of the spill / incident.

The results of any personnel NORM contamination(s) and their exposure.

SPILL CLEANUP
In the unlikely event that a spill might migrate or occur over unprotected land, the
contaminated soil shall be removed in accordance with the license and shall be
returned to the client as part of the decontamination project for temporary storage or
disposal. Cleanup will continue until the area is cleaned to background (or baseline)
levels.
OPERATING PROCEDURES
Moreno Group LLC and Subsidiaries shall follow all applicable state and federal
rules and regulations in addition to the policies and procedures contained in this
I16.35

document. Following are additional general operational procedures to those already


outlined in this license that will be taken when performing NORM activities at the
temporary jobsites.
TUBULAR (PIPE) AND MISCELLANEOUS EQUIPMENT CLEANING
Tubular and miscellaneous equipment cleaning will take place over an
impermeable surface such as a concrete slab, drip pans, etc. to contain
NORM contamination and prevent the spread of the contamination.
A high pressure water lance, flex auger, fixed auger, heating, and/or a dry air
tool system may be utilized to clean the tubulars. Other methods may be
employed as long as the requirements of this license are met.
-

The water lance will utilize a multi-port tip affixed to it allowing


circumferential spraying inside the tubular. The waste and wash water
generated will be collected and contained as mentioned above. All wash
and spray fluids will be recycled and filtered to minimize waste.

The air tool scrapes the internal surface of the tubular using centrifugal
force to remove the scale. The NORM particles are sent to a collection
chamber from where the air is filtered prior to release into the atmosphere.

Heat may be applied to the tubular surface to remove the moisture from
the NORM scale effectively causing it to flake off. Small hand tools may
also aid the removal of fixed NORM contamination.

Radiological controls (PPE, postings, minimizing exposure, etc.) shall be


incorporated and followed as delineated in the RWP and/or as directed by the
RSO/NS.
TANK AND VESSEL CLEANING
Areas around tanks or vessels requiring cleaning will be protected as
necessary with suitable impermeable protective materials (concrete slab
when available, drip pans, etc.).
NORM contaminated tanks or vessels will be cleaned using vacuum trucks,
hydrolances, hand tools, portable vacuum systems, or other appropriate
means as long as the requirements of this license are met. To clean process
vessels while in production, a remote hydraulic hydro-injection and suction
device may be used. Attachment, and detachment, of hoses, fittings, or
valves should not result in spillage of NORM materials to unprotected areas.
Tanks or vessels evaluated as confined spaces shall be treated as such in
accordance with 29CFR1910.146 and the attached Moreno Group LLC and
Subsidiaries policy. Radiological controls, postings and worker protection
procedures will be incorporated as outlined in this license and delineated in
the RWP and/or as directed by the RSO/NS.
I16.36

LAND AND SOIL REMEDATION


Prior to commencing remediation (decontamination) of NORM contaminated
land and soil, a thorough radiological assessment of the area will be
performed as specified in the license and LRR. This assessment will
establish background levels of radiation exposure in the adjacent area and
identify those areas needing to be remediated.
NORM contaminated land and soil will be remediated using equipment such
as backhoes, graders, front end loaders, hand tools, or similar equipment and
placed into containers appropriate to the situation.
Radiological controls, postings, and other worker protection procedures will
be instituted into the remediation activities as outlined in this license and as
delineated in the RWP and/or as directed by the RSO/NS.
At job completion, a release survey shall be performed of the remediated area
as described in Section 7.1 of this license and the Divisions current
Implementation Manual for Management of NORM in Louisiana. Once
contaminated, areas may not be released for unrestricted use prior to closeout authorization by the LDEQ/RPD as prescribed in LAC 33:XV.1417.
ENCAPSULATION OF NORM
Encapsulation of NORM into pipe or tubulars provides the generator a means
with which to dispose of his NORM waste into a plugged and abandoned well
location. This encapsulation activity shall be performed in an area protected
with suitable impermeable protective materials (concrete slab, drip pans,
etc.).
The pipe or tubular used shall be constructed of steel, PVC, or other suitable
materials. After placing a plate (or end cap) on one end of the pipe for
containment, the NORM waste will be place into it. If the waste is a dry
product, water may be added to minimize the potential for airborne particles
and/or to maximize flow into the capsule. Once the pipe is filled, the opposite
end will be closed in a similar fashion.
Radiological controls, postings, and other worker protection procedures will
be incorporated as outlined in this license and as delineated in the RWP,
and/or as directed by the RSO/NS.
The filled capsule shall be marked, labeled, and handled as outlined in this
license similar to other containers of NORM waste.
VOLUME REDUCTION
NORM waste will be placed through a volume reduction device using various
mesh screens, possibly in combination with a shaker system, to separate the
waste or foreign debris into respective particle sizes. Materials may be
transferred utilizing a variety of methods depending on the material handling
I16.37

characteristics of the NORM.


Water, mud, surfactants, emulsifiers,
stabilizers, and other chemicals may be added to facilitate handling and
treatment. Water used in the process will be recycled and filtered.
Radiological controls, postings, and other worker protection procedures will
be incorporated as outlined in this license and as delineated in the RWP,
and/or as directed by the RSO/NS.
NORM TREATMENT / SLURRING FOR DOWNHOLE DISPOSAL
Treatment of slurring of NORM waste may be accomplished by utilizing a
mixing tank and injection unit. The unit may consist of a shaker, chopper
pump, auger tank, inclined auger, generator, triplex pump, centrifuge, water
tank, settling tank, and decontamination enclosure.
NORM waste will be placed into the shaker and small particles will pass
through a mesh screen. Larger particles will be funneled through a chopper
pump to grind the material and drop it into a tank. Material that cannot be
grinned are removed and decontaminated by hand. The waste that fell into
the tank will be mixed with water and a bentonite or polymer to have the
NORM waste remain suspended until disposal. This material will be
circulated through the auger tank until being pumped into the well prepared
for NORM disposal or into a cutting box for temporary storage.
Prior to injecting NORM into a plug and abandon well location, the generator
will submit the proper form (UIC-30) to the Department of Natural Resources,
Office of Conservation, Injection and Mining Division in Baton Rouge for
approval.
Once written authorization is received, a copy of the completed UIC-30 form shall
be submitted to LDEQ/RPD along with form RPD-34.
Plugging and abandon procedures utilized by the generator will be in
accordance with the guidelines set forth by the Injection and Mining Division.
Radiological controls, postings, and other worker protection procedures will
be incorporated as outlined in this license and delineated in the RWP and/or
as directed by the RSO/NS.
NORM HANDLING
All NORM handling will be in accordance with this license and LRR. NORM
contaminated equipment and waste containers may be handled by forklift, crane,
manually, or other similar means with extreme care being taken not to damage the
integrity of the material containing the NORM preventing the potential spread of
contamination.
RECORDS
Master copies of all records associated with Moreno Group LLC and
Subsidiaries NORM work activities at the temporary jobsites shall be kept at
I16.38

Moreno Group LLC and Subsidiaries These records shall be kept legible and
shall include, but not be limited to, the following:
-

Those that will be maintained for a period of not less than five (5) years.
a) Training records of all personnel; briefs & instructions given to
visitors & short term contractors.
b) Inventory and manifests reflecting all material processed at the
temporary jobsites. This shall include the generator of origin, date
shipment was received, the number of drums or packages
received, and the maximum dose rate readings and smearable
contamination reading on each drum or package.
c) Instrumentation calibration records.
d) Radiation and contamination surveys conducted by Moreno Group
LLC and Subsidiaries at the temporary jobsites. This includes
decontamination, spill/cleanup operations and environmental
monitoring, such as air and soil laboratory results.

Those that must be kept indefinitely either by Moreno Group LLC and
Subsidiaries or, at termination of this license, by making provisions with
LDEQ/RPD for transfer to the division.
e) Personnel monitoring data.
f) Results of surveys used to evaluate the release of NORM effluents
into the environment.
g) Records of disposal of radioactive material.

The following documents, or copies, shall be maintained on-site at all


temporary jobsite for the duration of the job:
-

Moreno Group LLC and Subsidiaries NORM license procedures

NORM regulations (LAC 33:XV, specifically Chapters 4, 10, and 14)

On-site personnels current NORM training, monitoring, and respiratory


qualification records

Temporary job-site authorization

Survey instrumentation calibration records

Survey records including baseline & release radiation and contamination


surveys associated with the job.
I16.39

I16.40

NORM manifest(s) associated with the job

Inventory of NORM material located at the job site

Form DRC-3

Attachment 1

I16.41

NORM
Pre-Job Checklist
Job Name:

Job #:
Date:
__________________________
Job Description:
__________________________ Job Locations:
Customer Representative:(Print)
#
Task/Item
1
2
3

Initials

Verify planned activities and isotopes are authorized IAW License Number
Submit RPD - 35. Temporary Jobsite Notification to LDEQ
Gather required records
RPD - 35. Temporary Jobsite
Notification to LDEQ

Instrument calibration records;

dii LLC radioactive material license,


LA

Louisiana regulations LAC 33:XV,


Chapters 1,3,4,10,14,15, & 25

dii LLC NORM Procedures

Any current dii LLC Notice of


Violation

Personnel Training Certificates


Records of worker physicals and fit
tests:

Form DRC-3, "Notice to Employees"


The pre-job Norm survey for the
specific job:

Respirator Policy Statement


4
5

Ensure required records are current (training, calibration certificates, physicals, etc

Assimilate blank paperwork for job documentation


Radiation Work Permits (RWP
Waste Inventory/ Tracking Sheets
Radiation and Contamination Survey
NORM Manifests
Air Sample Log
Personal Frisk Sheet
Instrument Pre-operational Checks
UIC - 28s - NOW Waste Manifest
Assimilate radiological instrumentations, equipment, and supplies
Ludlum Model 3 w/44-2 Probe

Ludlum Model 3 w/44-9 Probe

Air sampler with sample head and


tygon tubing

Air sampler filters

Work area barrier rope or tape


Work area postings (signs)

Ziploc bags for air sample storage


Protective Clothing

Respirator Wipes
Radioactive Material Labels

Pens and Markers


Rags for decontamination

Sample storage bottles/bags

Irritant smoke test (if applicable)

Perform pre-job survey of jobsite

Obtain or perform a waste inventory of client's waste

Person Completing Report (Print)__________________ Signature:___________________________

I16.41.a.1

Attachment 2

I16.42

NORM
Daily Checklist
Job Name:
Job Description:
#
1
2
3
4
5

Job #:
Date:
__________________________
__________________________ Job Locations:
Task/Item

Daily Storage Area Boundary Survey

Air sample when likely to exceed


10% of DAC from appendix B
Periodic radiation and/or loose
contamination survey of work area(s)

Breathing Zone Air Sample for each


occasion of respirator use

Periodic work area air samples

Daily Work Area(s) Boundary Survey

Daily Boundary Air Sample

6
7
8
9
10
11
12
13
14
15
16

Initials

Conduct safety meeting and complete Radiation Work Permit


Issue Dosimetry Badges
Perform NORM instrument(s) pre-operational checks
Inspect and verify worksite, storage area, and posting
Perform Surveying and Monitoring

Periodic radiation and/or loose


contamination survey of work area(s)

Equipment/material loose surface


Equipment decon and loose
contamination survey(s) prior to
contamination survey prior to
removal from work area
releasing for unrestricted use
Monitor worker frisking and decontamination procedures
Monitor use of respirators appropriately
Evaluate public awareness and exposure issues
Evaluate job for potential spread of contamination
Survey, label and transfer waste containers to storage, Document on waste sheet
Properly transfer and document waste shipments (Manifest, UIC-28s) Update Wastetracking sheet
Ensure air samples properly logged and storage bags labeled
Ensure all equipment / Material removed from work area(s) has been properly surveyed
and the surveys logged
At end of day secure work and storage area(s)
At end of day collect dosimetry
At end of day, verify documentation complete for the day
Radiation/Contamination Survey Log
Air Sample Log
Instrument Pre & Post-Operational
Checks

Waste Tracking Sheet


Safety Meeting and RWP
Work Design Diagram

Person Completing Report (Print)__________________ Signature:___________________________

I16.42.a.1

Moreno Group LLC


and Subsidiaries
SH&E Management
System

Respiratory Protection

Page: 1 of 21
Original: 01/01/2001
Revised: 06/01/2008

Respiratory Protection
Purpose
The purpose of Moreno Group LLC and Subsidiaries respiratory protection program
is to establish and set guidelines for the selection of respiratory equipment,
situations for its use, and training in the use of the respirator selected.
Scope
It is the policy of Moreno Group LLC and Subsidiaries to maintain and implement a
Respiratory Protection Program that will ensure employee respiratory protection for
routine, and non routine activities when feasible engineering controls or work
practices are not adequate or available to control exposure to airborne
contaminants.
Whenever possible, effective engineering controls shall be used to control employee
exposure. Effective engineering controls include enclosure or confinement of the
operation, general and local ventilation, and substitution of less toxic materials.
When not feasible, or while instituting controls, appropriate respiratory protection
should be use as described in this program.
Administration
Moreno Group LLC and Subsidiaries Management will have the primary
responsibility for administering and updating the Respiratory Protection Program.
The following portions of the program may be delegated to the Safety, Health and
Environmental Department; program evaluation, employee training, fit testing,
procedures for selecting a respirator and use, and respirator hazard determination.
The following portion shall be administered by the supervisor; respirator use in
surveillance areas, respirator purchasing and inventory and respirator
maintenance(i.e. cleaning, storage, inspection and repair).
Responsibilities
The Facility / Site Manager or Designee is responsible for:
Evaluating the respiratory hazards at their facility / site and the protective
equipment required.
Obtaining the assistance of an outside consultant whenever necessary to
satisfy the requirements of this Procedure.

I17.1

Assuring use of engineering controls where feasible. Such controls may


include:
Change of the work process
Substitution of less hazardous substances for harmful materials
Isolation or enclosure of the work process or employees
Local exhaust or general dilution ventilation
Providing to employees proper respiratory protection training equipment and
medical evaluations to employees covered under this program.
The First Line Supervisor / Offshore Superintendent is responsible for:
Understanding the requirements of the Respiratory Protection Procedure.
Ensuring all personnel required to wear a respirator as part of their job have
had a medical evaluation and are physically capable of wearing a respirator.
Ensuring personnel required to wear a respirator have been fit tested and
properly trained. Also ensuring documentation of fit testing and training.
Conferring with the area personnel as to the respiratory hazards and
protection required.
Conferring with the personnel reporting to him / her as to the respiratory
hazards of a job and the respiratory protection required.
Obtaining special respiratory protection when required for a specific job.
Monitoring the job and work area for compliance with required respiratory
protection usage.
Initiating the use of additional respiratory protection as specified in any work
permits such as confined space entry.
Ensuring special-use respirators are cleaned, sanitized and inspected after
each use.
Using respiratory equipment as outlined in safe operating procedures (SOPs)
or Job Safety and Environmental Analyses (JSEAs).

I17.2

The Safety, Health and Environmental Department is responsible for:


Assuming overall responsibility for the respiratory protection program and
serving as the Respiratory Program Administrator.
Assisting area supervision with initial and ongoing monitoring of areas where
respiratory protection may be necessary in order to ensure the adequacy of
respiratory protection.
Specifying the appropriate styles of respirators based upon the hazards
determined from a hazard assessment.
Re-evaluating the hazards when changes in work areas may affect the
respiratory protection required.
Re-evaluating respiratory protection requirements on an annual basis.
Posting and maintaining warning signs where respiratory protection is
required.
Conferring with supervisors / to identify respiratory hazards and what
protection is required for a job.
Providing initial and annual training and fit testing to all users of respiratory
protection.
Maintaining records of respirator inspections, respiratory protection training, fit
testing, and medical determinations of fitness to wear respiratory protection.
Providing maintenance or access to maintenance for respirators.
Approving all purchases of respiratory equipment.
Remaining knowledgeable of new respiratory protection products or
standards.
The Engineering Personnel are responsible for:
Understanding and complying with this procedure.
Recommending less hazardous chemicals or substances be used rather than
more hazardous ones whenever it is practical to do so.
The Employee is responsible for:
Complying with this procedure and using the required respiratory protection.
Being clean shaven in the facial areas where the respiratory facepiece makes
a seal with the wearer.
I17.3

Conferring with his / her Supervisor / designee as to the respiratory hazards


involved and the protection requirements associated with the job.
Inspecting the respiratory protection equipment prior to each use and
maintaining it in a good and clean condition.
Performing a positive-pressure or negative-pressure fit check each time a
respirator is worn.
Advising supervision of any suggestions to improve the respiratory protection
program or the use or selection of protective equipment.
Advising supervision when experiencing any respiratory conditions that may
be related to occupational exposure of contaminants or hazardous
atmospheres.
Requesting information from supervision about any portion of the respiratory
protection program that is not fully understood.
Having respiratory protection when it is required and using protection
whenever there is the possibility of exposure to contaminants or hazardous
atmospheres.
Changing cartridges and canisters as specified by supervision.
Definitions
Air-purifying respirator means a respirator with an air-purifying filter, cartridge, or
canister that removes specific air contaminants by passing ambient air through the
air-purifying element.
Atmosphere-supplying respirator means a respirator that supplies the respirator user
with breathing air from a source independent of the ambient atmosphere, and
includes supplied-air respirators (SARs).
Canister or cartridge means a container with a filter, sorbent, or catalyst, or
combination of these items, which removes specific contaminants from the air
passed through the container.
Emergency situation means any occurrence such as, but not limited to, equipment
failure, rupture of containers, or failure of control equipment that may or does result
in an uncontrolled significant release of an airborne contaminant.
Employee exposure means exposure to a concentration of an airborne contaminant
that would occur if the employee were not using respiratory protection.
Filter or air purifying element means a component used in respirators to remove
solid or liquid aerosols from the inspired air.
I17.4

Filtering facepiece (dust mask) means a negative pressure particulate respirator with
a filter as an integral part of the facepiece or with the entire facepiece composed of
the filtering medium.
Fit factor means a quantitative estimate of the fit of a particular respirator to a
specific individual and typically estimates the ratio of the concentration of a
substance in ambient air to its concentration inside the respirator when worn.
Fit test means the use of a protocol to qualitatively or quantitatively evaluate the fit of
a respirator on an individual. (See also Qualitative fit test QLFT and Quantitative fit
test QNFT.)
Helmet means a rigid respiratory inlet covering that also provides head protection
against impact and penetration.
High efficiency particulate air (HEPA) filter means a filter that is at least 99.97%
efficient in removing monodisperse particles of 0.3 micrometers in diameter. The
equivalent NIOSH 42 CFR 84 particulate filters are the N100, R100, and P100 filters.
Hood means a respiratory inlet covering that completely covers the head and neck
and may also cover portions of the shoulders and torso.
Immediately dangerous to life or health (IDLH) means an atmosphere that poses an
immediate threat to life, would cause irreversible adverse health effects, or would
impair an individual's ability to escape from a dangerous atmosphere.
Loose-fitting facepiece means a respiratory inlet covering that is designed to form a
partial seal with the face.
Negative pressure respirator (tight fitting) means a respirator in which the air
pressure inside the facepiece is negative during inhalation with respect to the
ambient air pressure outside the respirator.
Oxygen deficient atmosphere means an atmosphere with oxygen content below
19.5% by volume.
Physician or other licensed health care professional (PLHCP) means an individual
whose legally permitted scope of practice (i.e., license, registration, or certification)
allows him or her to independently provide, or be delegated the responsibility to
provide, some or all of the health care services required by this program.
Positive pressure respirator means a respirator in which the pressure inside the
respiratory inlet covering exceeds the ambient air pressure outside the respirator.
Powered air-purifying respirator (PAPR) means an air-purifying respirator that uses a
blower to force the ambient air through air-purifying elements to the inlet covering.
Qualitative fit test (QLFT) means a pass/fail fit test to assess the adequacy of
respirator fit that relies on the individual's response to the test agent.
I17.5

Quantitative fit test (QNFT) means an assessment of the adequacy of respirator fit
by numerically measuring the amount of leakage into the respirator.
Respiratory inlet covering means that portion of a respirator that forms the protective
barrier between the user's respiratory tract and an air-purifying device or breathing
air source, or both. It may be a facepiece, helmet, hood, suit, or a mouthpiece
respirator with nose clamp.
Service life means the period of time that a respirator, filter or sorbent or other
respiratory equipment provides adequate protection to the wearer.
Supplied-air respirator (SAR) or airline respirator means an atmosphere-supplying
respirator for which the source of breathing air is not designed to be carried by the
user.
Tight-fitting facepiece means a respiratory inlet covering that forms a complete seal
with the face.
User seal check means an action conducted by the respirator user to determine if
the respirator is properly seated to the face.
Requirements
Respirator Selection Procedures
Respirators used in the work place are selected based on:
A reasonable estimate of employee exposure to respiratory hazards and
Relevant work place and user factors.
Where the employee exposure cannot be identified or reasonably estimated, the
atmosphere shall be considered IDLH.
Respirators selected shall be NIOSH certified and used within the conditions
of the NIOSH certification.
The number of respirator models and sizes offered by Moreno Group LLC
and Subsidiaries will be sufficient to correctly fit any user.
Respiratory Hazard Evaluation
The employee respiratory hazard evaluation and identification of relevant workplace
and user factors may be found in the Attachments. The evaluation shall be updated
when new hazards or exposures are identified or job descriptions or job tasks
change.
The table within Attachment 1 was developed from the evaluation and lists respirator
and cartridge selection based on the evaluation. After any update of the hazard
I17.6

evaluation the following table will be updated and the Respiratory Protection
program will be amended.
The following table lists the respirators by job description and task. With each job
and respirator listed is the associated contaminant for which the respirator is
authorized and the cartridges required change schedule (maximum use time limit).
Respirator Use In Non-IDLH Atmospheres
Compliance with all OSHA statutory and regulatory requirements, under routine and
reasonably foreseeable emergency situations shall be provided.
Moreno Group LLC and Subsidiaries requirements include Lead, 29 CFR
1910.1025 and Air Contaminants, 29 CFR 1910.1000.
The respirator shall be appropriate for the chemical state and physical form of
the contaminant.
Respirator Change Schedule
The change schedule is weeks equivalent replacement of the cartridge unless
required earlier by contaminant breakthrough suspicion or potential equipment
performance deterioration. Weeks equivalent means 40 hours of continuous use.
When the painting workload is heavier than normal and the respirator change
schedule based on weeks equivalent is suspect, the cartridge replacement cycle
will be reduced an appropriate amount.
When equipment inspection reveals the performance of the respirator is diminished,
such as, but not limited to head band elastic loss, valves not sealing, the respirator
will be replaced.
Change Schedule Basis
The change schedule is based on a combination of manufactures
recommendations, employee historical evidence of breakthrough-suspicion and preand post-use inspection observations.
Cartridges shall be selected from:
NIOSH certified HEPA,
Filter certified for particulates by NIOSH under 42 CFR part 84, or
Any filter certified by NIOSH for particulates.

I17.7

Respirator Use In IDLH Atmospheres


IDLH Atmosphere Routine Work
Moreno Group LLC and Subsidiaries employees shall not enter IDLH atmospheres
for routine work.
IDLH Atmosphere Non-routine Work
Moreno Group LLC and Subsidiaries employees shall not enter IDLH atmospheres
for non-routine work.

Oxygen Deficient Atmospheres


Oxygen-deficient atmospheres, that is atmospheres with less than 19.5 percent
oxygen, shall be considered IDLH. Oxygen deficient atmospheres that cannot be
maintained within the range of 16.0 percent to 19.5 percent oxygen (at altitudes less
than 3,000 feet) cannot be entered under any circumstances.
Medical Evaluation Procedures
The medical evaluation is completed to determine the employees ability to use a
respirator. Respirator use may be limited by the physiological burden placed on the
employee due to the respirator worn, the job and work place conditions in which the
respirator is used, and the medical status of the employee.
Medical Evaluation
A medical evaluation is required before an employee is fit tested or required
to wear a respirator in the work place.
The medical evaluations for Moreno Group LLC and Subsidiaries will be at
designated Occupational Health Clinics.
The initial medical evaluation may be administered as a questionnaire.
Medical Questionnaire
The medical evaluation consists of a medical questionnaire. An initial medical
examination that obtains the same information as the questionnaire is also
acceptable.
Follow-up Medical Examination
A follow-up medical examination is required for any employee who gives
positive response to any question among questions 1 through 8 in Section 2,
Part A on the medical questionnaire.

I17.8

A follow-up medical examination is required for any employee whose initial


medical examination indicates the need for a follow-up examination.
The follow-up medical examination consists of any medical tests,
consultations, or diagnostic procedures that the PLHCP deems necessary to
make an employee fitness to use respiratory protection determination.
Medical Questionnaire and Examination Administration
Administer the questionnaire and examinations confidentially during the
employees normal working hours or at a time and place convenient to the
employee.
Administer the questionnaire content in a manner that ensures the employee
understands.
The employee shall have the opportunity to discuss the questionnaire and
examination results with the PLHCP.
Supplemental Information for the PLHCP
Information Submittal
Provide the following information to the PLHCP before the PLHCP makes a
recommendation concerning individual respirator use. When information remains
the same, it needs to be submitted only once. Provide:
The type and weight of the respirator
The duration and frequency of routine respirator use and emergency
respirator use.
Expected physical work effort.
Additional protective clothing and equipment to be worn, and
Expected temperature and humidity extremes.
A copy of the respiratory protection program.
Changing PLHCPs
When a PLHCP is changed the information shall be provided to the new
PLHCP directly from Moreno Group LLC and Subsidiaries or transferred from
the former PLHCP to the new PLHCP.
Employees do not have to be reevaluated when PLHCPs are changed.

I17.9

Medical Determination
Moreno Group LLC and Subsidiaries shall do the following to determine an
employees ability to use a respirator.
Obtain the PLHCPs written recommendation regarding the employees ability
to use the respirator. Include only the following in the recommendation.
Any respirator use limitations due to medical condition or work place
conditions including the employees fitness to wear the respirator.
The need for follow-up medical evaluations if required, and
A PLHCPs statement the employee was provided with a copy of the
PLHCPs written recommendations.
For negative pressure respirator use, a negative finding by the PLHCP or
other qualified person means Moreno Group LLC and Subsidiaries will:
Examine the reason for the negative finding with the help of the PLHCP or
other qualified person.
Investigate alternative respiratory protection.
Provide alternative respiratory protection as required to ensure the employee
is provided with adequate respiratory protection.
Additional Medical Evaluation
An additional medical evaluation will be provided to employees under the following
conditions:
The employee reports medical signs or symptoms that are related to the
ability to use a respirator,
A PLHCP, Superintendent, Foreman, or the program
determines that an employee needs to be reevaluated,

administrator

Program information, including fit testing observations and program


evaluation that indicates a need for employee reevaluation, or
Changes to work place conditions, that is, physical work effort, protective
clothing, temperature, that result in a substantial increase in the physiological
burden on the employee.

I17.10

Fit Testing Procedures


Employees using a tight-fitting facepiece respirator must pass a qualitative fit test
(QLFT) or a quantitative fit test (QNFT). The employee must be fit tested with the
same make, model, style, and size of respirator that will be used by the employee.
The fit QLFT and QNFT protocols and procedures available for Moreno Group LLC
and Subsidiaries use are stated in the OSHA Respiratory Protection Regulation 29
CFR 1910.134.
Fit Testing Schedule
Before an employee may use any negative or positive pressure tight-fitting
respirator the employee must be fit tested.
Fit testing shall be conducted whenever a different respirator facepiece (size,
style, model, or make) is used and then annually.
Changes in the employees physical condition that could affect respirator fit
shall require re-fit testing. Some examples include obvious changes in body
weight, facial scarring, and dental changes.
Fit Testing Considerations
Respirators may need to be modified before fit testing. Remove any
modifications to the respirator so it is restored to NOISH-approved
configuration before using the facepiece in the workplace
The test shall not be conducted if there is any hair growth between the skin
and the facepiece sealing surface, such as stubble beard growth, beard,
mustache or sideburns which cross the respirator sealing surface. Any type of
apparel, which interferes with a satisfactory fit, shall be altered or removed.
Qualitative Testing (OLFT)
Qualitative fit tests shall be used to fit test only negative pressure air-purifying
respirators that are used for a fit factor of 100 or less.
Qualitative fit tests shall be conducted using the employees actual respirator.
Convert the facepiece into a negative pressure respirator if it is not already a
negative pressure respirator. Use appropriate filters for negative pressure
respirators or an identical surrogate for the atmosphere supplying or PAPR
facepiece and convert to a negative pressure respirator.
Quantitative Testing (ONFT)
Quantitative fit tests are passed only when a tight-fitting facepiece fit factor of
100 or more has been achieved for half-facepieces and 500 or more has
been achieved for full facepieces.

I17.11

Quantitative fit testing shall require sampling inside the facepiece midway
between the nose and the mouth of the employee. Modification of the
employees respirator with a temporary sampling adapter or surrogate
respirator modification to accept a permanent sampling probe is required.
Respirator Use Procedures
Procedures include proper use for routine and reasonably foreseeable emergency
situations. The following procedures establish proper use of respirators. Procedural
requirements include:
Prohibiting facepiece seal leakage,
Preventing removal of respirators in hazardous environments,
Ensuring continued effective respirator operation throughout the work shift,
And
Preventing use of respirators in IDLH atmosphere without approval of the
administrator and prior development of specific written procedures.
Facepiece Seal Protection
Conditions That Will Prevent Employees Wearing Tight -Fitting Facepiece
Respirators
When facial hair comes between the sealing surface of the facepiece,
When facial hair interferes with valve function, and
When any condition interferes with the face-to-facepiece seal or valve
function.
Ensure Tight Fitting Respirator Seals To The Employees Face
Ensure corrective glasses or goggles or other personal protective equipment
is worn in a manner that does not interfere with the seal of the facepiece to
the face.
Ensure the employee performs a user seal check each time the respirator is
put on. Use the following procedure. The user seal check is not a substitute
for qualitative or quantitative fit testing.

I17.12

Facepiece Positive and/or Negative Pressure Checks


Positive Pressure Check.
Close off the exhalation valve and exhale gently into the facepiece. The face
fit is considered satisfactory if a slight positive pressure can be built up inside
the facepiece without any evidence of outward leakage of air at the seal. For
most respirators this method of leak testing requires the wearer to first
remove the exhalation valve cover before closing off the exhalation valve and
then carefully replacing it after the test.
Negative Pressure Check.
Close off the inlet opening of the cartridges by covering with the palm of the
hand(s) or by replacing the filter seal(s), inhale gently so that the facepiece
collapses slightly, and hold the breath for ten seconds. The design of the inlet
opening of some cartridges cannot be effectively covered with the palm of the
hand. In this case, perform the test by covering the inlet opening of the
cartridge with a material so that no air may pass the inlet opening. If the
facepiece remains in its slightly collapsed condition and no inward leakage of
air is detected, the tightness of the respirator is considered satisfactory.
Manufacturer's Recommended User Seal Check Procedures
The respirator manufacturer's recommended procedures for performing a
user seal check may be used instead of the positive and/or negative pressure
check procedures provided that the employer demonstrates that the
manufacturer's procedures are equally effective.
Ensure Continuing Respirator Effectiveness
The First Line Supervisor or Superintendent shall provide appropriate
surveillance of the work area conditions and degree of employee exposure or
stress. When there is a change in work area conditions or degree of
employee exposure or stress that may affect respirator effectiveness,
respirator use shall be reevaluated. To reevaluate respirator use, contact the
Program Administrator.
The employee shall leave the respirator use area for the following reasons:
To wash faces and respirator facepieces as necessary to prevent eye or
skin irritation from respirator use, or
If vapor or gas breakthrough, changes in breathing resistance , or
facepiece leakage is detected, or
To replace respirators, the filter, or the cartridge.

I17.13

If vapor or gas breakthrough, changes in breathing resistance or leakage


of the facepiece are detected, Moreno Group LLC and Subsidiaries will
replace or repair the respirator before allowing the employee to return to
the work area.
IDLH Atmosphere Non-routine Work
Moreno Group LLC and Subsidiaries employees shall not enter IDLH atmospheres
for non-routine work.
Respirator Maintenance
Procedures include schedules for cleaning, disinfecting, storing, inspecting,
repairing, discarding, and otherwise maintaining respirators.
Cleaning and Disinfecting
Moreno Group LLC and Subsidiaries shall provide employees with respirators
that are clean, sanitary, and in good working order.
Employees shall keep, respirators clean, sanitary, and in good working order.
Respirators issued to more than one employee shall be cleaned and
disinfected following use by the employee who used the respirator. The
respirator shall be cleaned and disinfected before the respirator is provided
for the next employee.
Respirators issued for exclusive use shall be cleaned and disinfected after
each use or more often to maintain the respirator in sanitary condition.
Respirators used in fit testing and training shall be cleaned and disinfected
after each use.
Use the procedures described in OSHA 29 CFR 1910.134 Appendix B-2 to
clean and disinfect respirators. The procedures are general in nature, and
the employee, as an alternative may use the cleaning recommendations
provided by the manufacturer of the respirators. The alternative procedures
must also ensure that the respirator is properly cleaned and disinfected in a
manner that prevents damage to the respirator and does not cause harm to
the user.
Test the respirator to ensure that all components work properly after the
respirator is cleaned and reassembled.

I17.14

Storage
Employees shall store respirators as follows:
Respirators shall be protected from damage, contamination, dust, sunlight,
extreme temperatures, excessive moisture, and damaging chemicals, and
they shall be packed in a container to prevent deformation of the facepiece
and exhalation valve.
Emergency respirators shall not be routinely used by Moreno Group LLC and
Subsidiaries employees. In the event that the administrator deems they are
necessary for non-routine work, the program administrator shall provide a
procedure for respirator use consistent with the OSHA Respiratory Protection
Regulation, 29 CFR 1910.134.
Inspection
Respirators shall be inspected by the employee as follows:
Respirators shall be inspected before each use and during cleaning.
Respirator inspections shall include the following:
Check for function, tightness of connections, and the condition of the
various parts including, but not limited to, the facepiece, head straps,
valves, connecting tube, and cartridges, and filters.
Check plastic and rubber parts for pliability and signs of deterioration.
Repairs
Respirators that fail inspection or are otherwise defective shall be removed
from service and discarded, repaired, or adjusted.
Respirator repair shall be performed by Program Administrator authorized
persons.
Authorized persons include Safety Department Safety Managers or
coordinators or persons working directly under the manager or
coordinators direction.
Repairs shall be made according to the manufacturers recommendations
and specification for the type and extent of repairs to be performed. At no
time shall respirator parts for one make or type respirator be used on a
respirator of another make or type.

I17.15

Breathing Air Quality and Use


Procedures are included to ensure adequate air quality, quantity, and flow of
breathing air for atmosphere-supplying respirators.
Air Quality
Moreno Group LLC and Subsidiaries will provide employees using supplied-air
respirators with breathing gases of high purity.
Employees will not use self-contained breathing apparatus for routine work.
In the event that the program administrator deems SCBA is necessary for
non-routine work, the program administrator shall provide a procedure for
respirator use consistent with the OSHA Respiratory Protection Regulation,
29 CFR 1910.134.
Compressed or liquid oxygen shall not be used for respiration.
Compressed breathing air shall meet at least the following requirements for
Grade D breathing air. The requirements are described in ANSI/Compressed
Gas Association Commodity Specification for Air, G-7.1-1989.
Oxygen content (volume/volume) of 19.5 percent to 23.5 percent;
Hydrocarbon (condensed) content of 5 milligrams per cubic meter of air or
less;
Carbon monoxide (CO) content of 10 ppm or less;
Carbon dioxide (CO2) content of 1,000 ppm or less; and
Lack of noticeable odor.
Supplied Air Cylinders
When SAR requirements are met by supplying air from compressed air
cylinders, the cylinders shall be tested and maintained as prescribed in the
Shipping Container Specification Regulations of the Department of
Transportation (49 CFR part 173 and part 174); the air shall have a certificate
of analysis from the supplier that the breathing air meets the requirements for
Grade D breathing air and the moisture content in the cylinder does not
exceed a dew point of 50 degrees Fahrenheit at 1 atmosphere pressure.
Supplied Air Compressors
Breathing air compressors shall be constructed and situated so as to:
Prevent entry of contaminated air into the air-supply system;
I17.16

Minimize moisture content so that the dew point at 1 atmosphere pressure is


10 degrees Fahrenheit below the ambient temperature;
Have suitable in-line air-purifying sorbent beds and filters to further ensure
breathing air quality. Sorbent beds and filters shall be maintained and
replaced or refurbished periodically following the manufacturers instructions.
Maintain at the compressor a tag containing the most recent change date and
the signature of the superintendent or foreman who performed the change.
For non-oil lubricated compressors, ensure the carbon monoxide level in the
breathing air does not exceed 10 ppm.
For oil lubricated compressors ensure a high-temperature or carbon
monoxide alarm (or both) monitor carbon monoxide levels. If only hightemperature alarms are used, the air supply shall be monitored at intervals
sufficient to prevent carbon monoxide in the breathing air from exceeding 10
ppm.
Ensure breathing air couplings are incompatible with outlets for nonrespirable worksite air or other gas systems. No asphyxiating substance shall
be introduced into breathing air lines.
Ensure breathing gas containers are marked in accordance with the NOSIH
respirator certification standard, 42 CFR part 84
Filters and Cartridges
Filters and cartridges used in the workplace shall be labeled and color-coded
with the NIOSH approved label. Ensure the label is not removed and remains
legible.
Training Procedures
Training provisions provide effective training to employees who are required to use
respirators. The training shall be comprehensive, understandable, and should
include the following: Hazards, proper use, provision, information, evaluation, and
recordkeeping.
Training on Respirator Hazards
Provisions include hazards to which employees are potentially exposed
during routine situations.
Training on Proper Respirator Use
Ensure employees can demonstrate knowledge of at least the following:
Why the respirator is necessary, how improper fit, usage, or maintenance can
reduce the protective effect of the respirator;
I17.17

The limitations and capabilities of the respirator;


How to inspect, put on and remove, use, and check the seals of the
respirator;
Procedures for respirator maintenance and storage;
Recognition of medical signs and symptoms that may limit or prevent
respirator effective use;
General requirements of the Respiratory Protection standard, 29 CFR
1910.134.
Training Provision
Provide training prior to requiring the employee to use a respirator in the
workplace.
When a new employee can demonstrate receipt of training within the last 12
months that addresses the elements specified above, the employee is not
required to repeat the training, provided that the employee can demonstrate
knowledge of the elements by examination. The new employee must have
repeat training within 12 months from the date of the previous training.
Retraining shall be administered annually, or earlier, when the following
conditions occur:
Changes in the workplace or the type of respirator render the previous
training obsolete;
Inadequacies in the employees knowledge or use of the respirator
indicate that the employee has not retained the knowledge;
Any other situation arises in which retraining appears necessary to ensure
safe respirator use.
Information for Employees Using Respirators When Not Required Under the
Standard
Respirators are an effective method of protection against designated hazards
when properly selected and worn. Respirator use is encouraged, even when
exposures are below the exposure limit, to provide an additional level of
comfort and protection for workers. However, if a respirator is used improperly
or not kept clean, the respirator itself can become a hazard to the worker.
Sometimes, workers may wear respirators to avoid exposures to hazards,
even if the amount of hazardous substance does not exceed the limits set by
OSHA standards.

I17.18

If a respirator is provided by Moreno Group LLC and Subsidiaries for


voluntary use, of if the respirator is employee provided, certain precautions
are required to be sure that the respirator itself does not present a hazard.
The following is required:
Read and heed all instructions provided by the manufacturer on use,
maintenance, cleaning and care, and warnings regarding the respirators
limitations.
Choose respirators certified for use to protect against the contaminant of
concern. NIOSH, the National Institute for Occupational Safety and Health
certifies respirators. A label or statement of certification should appear on
the respirator or respirator packaging. The label or statement of
certification will tell you what the respirator is designed for and how much
it will protect you.
Do not wear the respirator into atmospheres containing contaminants for
which the respirator is not designed to protect against. For example, a
respirator designed to filter dust particles will not protect against gases,
vapors, or very small solid particles of fumes or smoke.
Keep track of the respirator so that one employees respirator is not
mistakenly used by someone else.
Program Evaluation Procedures
Program evaluation shall be conducted to ensure that the written program is properly
implemented and employees are using respirators properly.
Provisions of the written program shall be evaluated to ensure they have
been implemented and are effective.
Employees shall be regularly consulted to assess the employees views on
program effectiveness and to identify any problems. Problems identified shall
be corrected. Factors to be assessed at least include:
Respirator fit (including respirator use without interfering with workplace
performance)
Appropriate selection for the hazards to which the employee is exposed.
Proper respirator use.
Proper respirator maintenance.

I17.19

Record Keeping
Records must be maintained for medical evaluations, fit testing, and the respirator
program. The records shall be available to facilitate employee involvement in the
program, assist in auditing adequacy of the program and provide a record for
compliance determinations by OSHA.
Medical Records
Ensure records are retained and made available in accordance with 29 CFR
1910.1020.
Fit Testing
Ensure records of qualitative and quantitative fit tests administered to
employees are retained including:
Name or identification of employee tested.
Type of fit test performed
Specific make, model, style, and size of respirator tested,
Date of test, and
Pass/fail result for QLFTs or the fit factor and strip chart recording or other
recording of the test results of QNFTs.
Fit test records shall be retained for respirator users until the next fit test is
administered.
Note: Moreno Group LLC and Subsidiaries Inc. reserves the right to change this
policy at their discretion.
Written Respiratory Protection Program
A written copy of the current program shall be retained by the Program
Administrator. Current copies shall be distributed as needed to First Line
Supervisors and Offshore Superintendents and foremen who have respirator users.

I17.20

Attachment 1

I17.21

Moreno Group LLC and Subsidiaries Respirator Requirements

Job Description

Onshore Painter

Onshore Painter

Blaster

Job Task

Respirator and Cartridge

Contaminant

Maximum Change
Schedule

3M 5301 (L) oranic vapor


with 5P71 prefilter

expoxies, VOC based paints, Urethanes 900


paints,Solvents

8 hour or
breakthrough

-3M

3M 5301 (L) oranic vapor


with 5P71 prefilter

expoxies, VOC based paints, Urethanes 900


paints,Solvents

8 hour or
breakthrough

Blasting

Supplied Air Blasthood

Silica,Quartz,Cristobalite,Trydimite,Respirable
dust

8 hour or
breakthrough

Paint

Mixing/Cleaning

I17.21.a.1

The following table lists the respirators by job description and task. With each job and respirator listed is the associated contaminant for which the
respirator is authorized and the cartridges required change schedule (maximum use time limit). Respirator Selection Table for all Moreno Group LLC and
Subsidiaries Locations (onshore and offshore)
Job
Description

Onshore
Painter

Offshore
Painter

Job
Task

Paint

Paint

Respirator and Cartridge


Supplied Air Blasthood Primary
3M 5101 (S) organic vapor with 5P71 prefilter (only
with Project Manager or Designee approval)
3M 5201(M) organic vapor with 5P71 prefilter (only
with supervisors approval)
3M 5301 (L) organic vapor with 5P71 prefilter (only
with supervisors approval)
Supplied Air Blasthood Primary
3M 5101 (S) organic vapor with 5P71 prefilter (only
with Project Manager or Designee approval)
3M 5201(M) organic vapor with 5P71 prefilter (only
with Project Manager or Designee approval)
3M 5301 (L) organic vapor with 5P71 prefilter (only
with Project Manager or Designee approval)

Onshore
Painter

Mixing/Cleaning-3M

3M 5101 (S) organic vapor with 5P71 prefilter


3M 5201(M) organic vapor with 5P71 prefilter
3M 5301 (L) organic vapor with 5P71 prefilter

Offshore
Painter

Mixing/Cleaning-3M

3M 5101 (S) organic vapor with 5P71 prefilter


3M 5201(M) organic vapor with 5P71 prefilter
3M 5301 (L) organic vapor with 5P71 prefilter

Helper
Welder
Helper

Welding help
Welding
Welding help

3M 6000 with 2097 filter


3M 6000 with 2097 filter
3M 6000 with 2097 filter

Blaster

Blasting

Supplied Air Blasthood

Welder

Welding in Confined
Space

Contaminant

Maximum Change
Schedule

Inorganic Zinc

8 hour or breakthrough

Epoxies (incl. coal tar)

8 hour or breakthrough

VOC based paints


Urethanes
Solvents

8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough

Inorganic Zinc

8 hour or breakthrough

Epoxies (incl. coal tar)

8 hour or breakthrough

VOC based paints


Urethanes
Solvents
Inorganic Zinc
Epoxies (incl. coal tar)
VOC based paints
Urethanes
Solvents
Inorganic Zinc
Epoxies (incl. coal tar)
VOC based paints
Urethanes
Solvents
Zinc
Galvenize/Lead
Galvenize/Lead
Silica, Quartz, Cristobalite,
Trydimite, Respirable dust

8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough
8 hour or breakthrough

Organics, Fumes

8 hour or breakthrough

Hexavalent Chromium

8 hour or breakthrough

N/A

3M 6101 (s) with 2097 filter


3M 6201 (m) with 2097 filter
3M 6301 (l) with 2097 filter
3M 6101 (s) with P-100 filter
Welder

I17.21.a.2

Welding on Stainless
Steel or Exotic Metals

3M 6201 (m) with P-100 filter


3M 6301 (l) with P-100 filter - also refer to Hexavalent
Chromium Program.

Moreno Group LLC and Subsidiaries Industrial Service, LLC


Job
Description
Laborer/Helper

Job Task
Assist with first flange
break

Assist with environmental clean


up

Helper
Boilermaker

Respirator and Cartridge


3M 6000 organic vapor cartridge
Full Face Scott AV 2000 organic vapor cartridge

Supplied air Respirator

Welding help

3M 6000 with 2097 filter

First flange break


Hot Bolt work

3M 6000 organic vapor cartridge


Full Face Scott AV 2000 organic vapor cartridge

Supplied air Respirator

Contaminant
Benzene > 1ppm - <25ppm
Benzene >25ppm - <50ppm
HF Acid >3ppm - < 6ppm
H2S >5ppm- < 15ppm
Benzene >50ppm
HF Acid >6ppm
H2S >15ppm
Unknown concentration of any
of the above contaminants
Zinc
Galvanize/Lead
Benzene > 1ppm - <25ppm
Benzene >25ppm - <50ppm
HF Acid >3ppm - < 6ppm
H2S >5ppm <15ppm
Benzene >50ppm
HF Acid >6ppm
H2S >15ppm
Inorganic Zinc
Epoxies (incl. coal tar)
VOC based paints
Urethanes
Solvents
Galvanize/Lead
Organics, Fumes

Painter

Mixing/Cleaning-3M

3M 6000 organic vapor with prefilter

Welder
Welder

Welding
Welding in Confined Space

3M 6000 with 2097 filter


3M 6101 with 2097 filter

Welder

Welding on Stainless Steel or


Exotic Metals

3M 6101 with P-100 filter - also refer to Hexavalent


Chromium Program.

Hexavalent Chromium

Pipe Fitter

Welding help

3M 6000 with 2097 filter

Pipe Fitter

Welding help on Stainless Steel or 3M 6101 with P-100 filter - also refer to Hexavalent
Exotic Metals
Chromium Program.
Blasting
Supplied Air Blasthood

Zinc
Galvanize/Lead
Hexavalent Chromium

Blaster

Instrument Technician Breaking into Instrument Lines


Millwright

Supplied Air

Work on process

3M 6000 organic vapor cartridge

pumps

Full Face Scott AV 2000 organic vapor cartridge

Supplied air Respirator

Silica, Quartz, Cristobalite,


Trydimite, Respirable dust
Hydrogen/Nitrogen
Other unknown gases
Benzene > 1ppm - <25ppm
Benzene >25ppm - <50ppm
HF Acid >3ppm - < 6ppm
H2S >5ppm- < 15ppm
Benzene >50ppm
HF Acid >6ppm
H2S >15ppm
Unknown concentration of any of
the above contaminants

Maximum Change
Schedule
8 hour or breakthrough
8 hour or breakthrough

N/A

8 Hours or breakthrough
8 Hours or breakthrough
8 Hours or breakthrough

N/A
8 Hours or breakthrough
8 Hours or breakthrough
8 Hours or breakthrough
8 Hours or breakthrough
8 Hours or breakthrough
8 Hours or breakthrough
8 Hours or breakthrough
8 hours or breakthrough
8 Hours or breakthrough
8 hours or breakthrough
N/A
N/A
8 hour or breakthrough
8 hour or breakthrough
N/A

I17.21.a.3

Respirator Selection Table for Moreno Group LLC and Subsidiaries


8 hour or breakthrough

Insulator

Asbestos Abatement

North, 550030 / HEPA Cartridge 7581, P100

Airborne Asbestos Fiber

Carpenter

Spray Painting

North, 550030 / 75001, OV

Organic Vapor

8 hour or breakthrough

All Trades

Mold Abatement
Tank Cleaning
* (Confined Space)
Tank Cleaning
(From Outside)

North, 550030 / HEPA Cartridge 7581, P100

Mold, Mold Spore

8 hour or breakthrough

Scott Full Face SAR (Or Equivalent)

Environment

NA

Scott Full Face Neg. Pressure / 642-OV-T100


(Cartridge will vary depending on contaminant)

Material being removed

8 hour or breakthrough

Rescue

Scott Pac Full Face SAR (Or Equivalent)

Environment

NA

Cleaning Tech
Cleaning Tech
Cleaning Tech

* We stay on air in all


environments where
there may be
unknown
contaminants, or high
end CO, or low end
O2. We never enter
IDLH atmospheres

I17.21.a.4

Assigned Protection Factors (APFs) Employers must use the assigned protection factors
listed in Table 1 to select a respirator that meets or exceeds the required level of employee
protection. When using a combination respirator (e.g., airline respirators with an air-purifying
filter), employers must ensure that the assigned protection factor is appropriate to the mode
of operation in which the respirator is being used.
Table 1. -- Assigned Protection Factors5
Type of respirator1, 2
Quarter
Half
Full
Helmet/
Loosemask
mask
facepiece
hood
fitting
facepiece
3
1. Air-Purifying Respirator
5
10
50 .............. ..............
2. Powered Air-Purifying
..............
50
1,000 425/1,000
25
Respirator (PAPR)
3. Supplied-Air Respirator
(SAR) or Airline Respirator
Demand mode
..............
10
50 ..............
..............
Continuous flow mode
..............
50
1,000 425/1,000
25
Pressure-demand or
..............
50
1,000 ..............
..............
other positive-pressure
mode
4. Self-Contained Breathing
Apparatus (SCBA)
Demand mode
..............
10
50
50
..............
Pressure-demand or
.............. ..............
10,000
10,000
..............
other positive-pressure
mode (e.g., open/closed
circuit)
Notes:
1
Employers may select respirators assigned for use in higher workplace concentrations of a
hazardous substance for use at lower concentrations of that substance, or when required
respirator use is independent of concentration.
2
The assigned protection factors in Table 1 are only effective when the employer
implements a continuing, effective respirator program as required by this section (29 CFR
1910.134), including training, fit testing, maintenance, and use requirements.
3
This APF category includes filtering facepieces, and half masks with elastomeric
facepieces.
4
The employer must have evidence provided by the respirator manufacturer that testing of
these respirators demonstrates performance at a level of protection of 1,000 or greater to
receive an APF of 1,000. This level of performance can best be demonstrated by
performing a WPF or SWPF study or equivalent testing. Absent such testing, all other
PAPRs and SARs with helmets/hoods are to be treated as loose-fitting facepiece
respirators, and receive an APF of 25.
5
These APFs do not apply to respirators used solely for escape. For escape respirators
used in association with specific substances covered by 29 CFR 1910 subpart Z,
employers must refer to the appropriate substance-specific standards in that subpart.
Escape respirators for other IDLH atmospheres are specified by 29 CFR 1910.134 (d)(2)

I17.21.a.5

Moreno Group LLC and


Subsidiaries SH&E
Management System

Air Tugger / Winch Operations

Page:
Original: 01/01/2010
Revised:

Air Tugger / Winch Operations


Purpose
The purpose of this policy is to establish and set guidelines for the safe use of material
handling equipment related to Air Tugger Operations
Scope
This procedure applies to all Moreno Group, LLC and Subsidiaries employees,
non-permanent employees and sub-contract employees who operate, use, inspect,
maintain or work around air tugger operations.
Responsibilities
The Facility Manager / Yard Manager / Offshore Manager or Designee is
responsible for:
Continually communicated to First Line Supervision the employees right to use
STOP WORK AUTHORITY.
Assuring compliance with this procedure.
Evaluating air tugger needs for the facility / site, preparing detailed purchase /
rental specifications and providing sufficient equipment to support the needs of
Moreno Group, LLC and Subsidiaries.
Assuring the equipment is operated and maintained in a safe manner and in
accordance with equipment manufacturers recommendations.
Assuring that equipment operators are properly trained and qualified to operate
specific equipment.
Ensuring that no modifications or additions are made to equipment without the
manufacturers written approval.
Ensuring that all work group investigations, significant incidents, property
damage reports, and general information regarding mobile / motorized equipment
is communicated to applicable employees.
Informing all Contractors of this procedure during the project meeting and ensure
the Contractor follows the requirements of this procedure.
Ensuring air tugger / winch operations procedure is reviewed and approved for all
vertical and multi-tugger lifts
Approving of the spooling of air tugger / winches offshore.
J1.1

The First Line Supervisor / Offshore Superintendent is responsible for:


Understanding and enforcing the provisions of this procedure.
STOP WORK anytime any employees are in question of the lift, lift operation,
lifting equipment, lifting accessories or work activities around lift operation.
Identify the hazardous area (Red Zone) around operating equipment, and notify
all affected personnel of this area.
Conferring with personnel reporting to them as to the hazards of specific jobs and
the air tugger to be used.
Assuring that equipment is inspected, operated and maintained in accordance
with this procedure and the manufacturers recommendations.
Assuring recommended power supply input for best performance.
Assuring that only trained, authorized and physically fit personnel operate and
maintain equipment.
Assisting in the evaluation of operator competency.
Ensuring no one places their hands on the cable while the air tugger is
connected to the power source.
Assuring a detailed Job Safety and Environmental Analysis (JSEA) is developed
and followed for the air tugger operations.
Sending approved air tugger operations procedure and JSEA to Operations
Manager for approval prior to starting operation
The Equipment Operator is responsible for:
Use STOP WORK AUTHORITY anytime the operator is questioning the lift or
lift operation, lifting equipment, lifting accessories or work activities around lift
operation.
Complying with this procedure and operating equipment safely.
Remaining alert and not operating equipment if mentally or physically impaired.
Consulting with the supervisor if taking either over-the-counter or prescription
medication.
Conferring with supervision as to hazards involved or associated with the job.
Surveying the work areas for hazards and erecting barricades.
Operating only equipment for which they have been trained.

J1.2

Reading and being familiar with the manual for the equipment being operated
and operating the equipment as intended by the manufacturer.
Never operating equipment that is unsafe and in need of repair.
Performing and documenting the pre-use / shift inspection.
Check brake operation, by lifting load a short distance and releasing control.
Be aware of shut-off valve or electrical disconnect location and proper operation.
Confirm that winch inspections and lubrication checks have been completed
Ensuring no one places their hands on the cable while the air tugger is
connected to the power source.
Notifying supervision of any significant incidents, property damage or near
misses with regards to mobile / motorized equipment.
Participating in the task JSEA and ensuring the lift team follows the JSEA as
written. If any changes occur during the lift, ensuring the operation is stopped
and the JSEA is revisited.
The Signal Person is responsible for:
Providing clear signals and being able to recognize hazards and signal the
operator to avoid them (see Attachment 1).
Use STOP WORK AUTHORITY anytime the signal person is questioning the lift
or lift operation, lifting equipment, lifting accessories or work activities around lift
operation.
Participating in the task JSEA and ensuring the lift team follows the JSEA as
written. If any changes occur during the lift, ensuring the operation is stopped
and the JSEA is revisited.
The Personnel Working around Equipment is responsible for:
Use STOP WORK AUTHORITY anytime any employee is questioning the lift or
lift operation or work activities around lift operation.
Knowing of the hazards of working around equipment.
Keeping a safe distance from operating equipment.
Staying out of designated Red Zone.
Obeying all signs, and barricades.

J1.3

Ensuring no one places their hands on the cable while the air tugger is
connected to the power source.
Never getting on or off moving equipment.
Remaining alert and responding as necessary when an equipment warning
device is heard.
Never walking or working below a raised load on equipment.
Participating in the task JSEA and ensuring the lift team follows the JSEA as
written. If any changes occur during the lift, ensuring the operation is stopped
and the JSEA is revisited.
Definitions
Qualified Operator - A person who has received and successfully completed an
appropriate air tugger / winch operators training, authorized by the Moreno Group, LLC
and Subsidiaries to operate the equipment and meets the following physical
qualifications:
Have vision of at least 20/30 Snellen in one eye and 20/50 in the other with or
without glasses, and have no depth perception problems.
Be able to distinguish red, green and yellow, regardless of position of colors, if
color differentiation is required to crane operation.
Have hearing, with or without a hearing aid, adequate for the specific operation.
Have sufficient strength, endurance, agility, coordination and speed of reaction to
meet the demands of equipment operations
Evidence of physical limitations or emotional instability that could render the
operator a hazard to himself or other or which in the opinion of the examiner
could interfere with the operators safe performance, may be cause for
disqualification.
Evidence that an operator is subject to seizures or loss of physical control shall
be reason for disqualification.
Operators should have good depth perception, field of vision, reaction time,
manual dexterity, coordination and should not be prone to dizziness or similar
undesirable characteristics.
Qualified Inspector - A person who has received and successfully completed the
appropriate air tugger / winch maintenance and is designated by the employer.
Qualified Rigger A rigger is anyone who attaches or detaches lifting equipment to
loads or lifting equipment and/or anyone who directs or signals a lift operation. This
person shall have the training and experience and who has successfully completed API
RP 2d rigger training program.
J1.4

Pre-use Inspection - An inspection that is performed daily by the qualified operator.


This type of inspection shall be conducted prior to beginning each new shift.
Designated Personnel - Only designated personnel shall be permitted to operate an air
tugger covered by this policy.
Red Zone- Designated area around air tugger operations that must be clear of all nonessential personal before operation begins.
Requirements
Air Tugger / Winch Installation
Installation personnel should be trained and knowledgeable in air tugger / winch
installation. During the installation of an air tugger, never weld on any part of the
winch. All supporting structure, mounting hardware and load attaching hardware must
be in accordance with all applicable standards, codes and regulations. When moving
the winch, ensure proper rigging is used and the lift is not made over personnel.
Prior to the installation of the air tugger on location, the installation team shall perform a
site assessment as part of the Job Safety and Environmental Analysis (JSEA) process.
This site assessment shall be performed where the air tugger will be mounted and the
entire path that the load will be taking. The path shall be evaluated to ensure all
obstacles are removed prior to the installation of the tugger. If an obstacle is unable to
moved, a different plan shall be developed. In addition to the path being evaluated, the
assessment shall ensure that the mounting surface will be large enough for air tugger /
winch and the operator. Refer to air tugger / winch the Manufactures Product
Information Manuals for specific information on mounting surface requirements,
attaching hardware and power supply requirements. This assessment shall include the
evaluation of the operators ability to reach all controls comfortably and observe loads
during operation.
The installation team shall check that sufficient space is available to operate winch
control, manual brake or other components and to make inspections or adjustments
when necessary. No welding shall be performed on the winch portion of the air tugger
since this process can change the physical properties of some of the parts, which can
affect strength or durability. In addition to the possibility of changing the physical
properties, the excessive heat can be generated which can affect and/or damage
internal parts such as seals and bearings.
Once the appropriate location has been determined by the installation team, the area
shall be hard barricaded prior to any deck penetrations are made to access the main
deck beams.
The air tugger / winch shall be welded directly to the deck beams with the use of plate
clips (dogs). Both the installation procedure and number of plate clips need to be
evaluated and approved by the Facilitys Registered Structural Engineer.
Note: The only exception to this rule will be for 1 ton air tuggers / winch. The tie down
of this piece of equipment can be performed by use of certified Alloy Grade 80 rigging
chain.
J1.5

Installation of Air Tugger / Winch for Onshore Operations


Installation of an air tugger / winch within an onshore facility, the ability to weld the air
tugger / winch to the structure may not be an option. If during the installation the air
tugger / winch is unable to be welded to the facility, it maybe tied down by use of
certified Alloy Grade 80 rigging chains.
Note: The preferred method of tie down will be appropriately welding down the air
tugger / winch onto the facility.
Warning Labels and Tags
Installation personnel shall not remove or obscure any warning label(s) or tag(s). These
individuals shall ensure warning label(s) or tag(s) are visible to the personnel in the
area. If warning label(s) or tag(s) are damaged, illegible or become lost, contact the
rental company for replacements.
Data Plate
Ensure that data (name) plate is attached and readable. Replacement data (name)
plates are available when complete winch serial number is provided to the manufacture.
Power Supply
To ensure the best performance with any power supplied (electrical, hydraulically or
pneumatic) to the winch; it must meet the manufactures specifications for the air tugger
/ winch. The recommended power supply for an air tugger / winch can be located in the
Manufactures Product Information Manual.
Should a power supply of less than recommended be used, this will result in reduced
winch performance and may cause some items such as brakes, overload valves or limit
switches to function incorrectly. Exceeding the power supply can cause winch to exceed
rated performance in addition, brakes, overload sensors, limit switches/valves may not
function correctly.
In those cases where electrical power is used to as a power source to the operations, a
licensed electrician shall install, properly ground and commission the electrical power
source to these operations.
Electric winches can also be affected by contamination. To reduce this possibility, the
motor and controls should be kept clean and ensure phase, cycle and voltage of motor
magnetic reversing starter and controls all match the electrical service being used.
.
Air and hydraulic powered winches require filtration before the control valve. The
Manufactures Product Information Manuals should be referred to for specific filtration
level, type and location. Without filtration, contaminates can enter the system and cause
components to malfunction.

J1.6

In those cases where multiply air tuggers / winches are to be used simultaneously, the
manufactures specifications shall be applied to each individual air tugger / winch
involved in the operations.
All connections must be tight and installation made with hoses, cables and/or fittings
that are new or in good condition and rated for the power supplied. Pneumatic
connections shall be secured using both a safety pin and the appropriately sized whip
checks.
Shut off Valve
On all pneumatic powered air tuggers / winches the installation personnel shall ensure
an accessible emergency shut off valve has been installed in the air supply line. The
valve position shall be installed within easy range of the operator and positioned so that
activation can occur quickly or any person in the area of the air tugger / winch can also
activate the valve. In addition to an emergency shut off valve, this valve will provide the
operator a positive way of stopping the air tugger / winch operations in the event of an
emergency or prior to performing any adjusting, servicing, maintenance or maneuvering
of wire rope on the winch drum. Any time the air tugger is left unattended the air tugger
shall be shut down and depressurized. All personnel involved in and/or around the air
tugger operations shall be instructed and shown where this valve is located.
Air Tugger / Winch Controls
The location of controls and their features varies between air tuggers / winches. This is
dependent on application requirements for each individual air tugger / winch. The
operator shall be familiar with location of controls and their features. Operators should
be aware that controls are not always included with electric and hydraulic powered
winches. Due to the differences in each air tugger / winch, users and operators should
not assume that all winches operate the same. Although, there are many similarities,
every air tugger / winch should be reviewed to identify their individual characteristics.
Each air tugger / winch has specific characteristics that the operator must understand
and be familiar with.
For instance Ingersoll Rands winches are operated by applying power to a motor,
which is connected through a drive train to the drum. The direction of the drum rotation
and speed is managed by the controls. Various controls are available with the winches
and are dependent on power source, location to winch and degree of control required.
For air winches, full flow control valves are normally used which are connected directly
to the winch motor. These have a lever, which is actuated forward and back for direction
control. The degree of lever movement controls drum speed.
Safety features for these operations; levers should not be able to engage without going
through another action first, such as pulling up a safety pin or resisting a safety spring.
Pendant controls are typically used on electric winches but are also available on
pneumatic and hydraulic winches. This type of control sends a signal back to a valve or
control panel mounted to the winch. This control allows the operator to be some
distance from the winch. Pendant controls have levers or buttons which control forward
and reverse drum rotation. The use of pendant controls require additional safety
J1.7

considerations, as the operator may not be at the winch to observe drum rotation or wire
rope spooling. Operators must maintain visual contact with the load, drum and wire
rope at all times.
Exhaust
The installation location shall be evaluated for ventilation to ensure exhaust from these
operations does not affect other operations and eliminates personnel from standing in or
around exhaust streams. A muffler should be used to reduce noise level to acceptable
limits. Pipe away the exhaust where possible to prevent oil mist creating a slippery
environment.
On pneumatic powered winches, careful consideration must be given to the exhaust.
Noise. Using piping or tubing to move exhaust away from operator can reduce
this. The addition of a muffler is also recommended to reduce noise level.
Misting. Clean and remove any build-up of oily residue in area.
Natural/Sour Gas For air powered winches that use natural/sour gas as the
power source, pipe away exhaust from winch. Exhaust system shall provide safe
removal or recirculation of gas and meet all applicable federal, state, and local
safety regulations Note: This application is discouraged and must have
Moreno Group LLC and Subsidiaries Managements Approval at the Vice
President level prior to the use of this type of power supply.
Unauthorized Modifications to Air Tugger / Winch
During the installation or during the operations of any air tugger / winch, no
unauthorized modification shall be allowed without the manufactures written approval
prior to the modification being performed.
Air Tugger / Winch Guards and Barricading of Operations
All guards shall be installed to prevent personnel from accidentally contacting any
exposed moving parts associated with the winch drum. Personnel shall ensure the
guards do not interfere with the air tugger / winch wire rope spooling or control
operations. Guarding moving parts of an air tugger / winch from accidental contact with
personnel shall be a prime consideration for the installation and maintaining of guards
on the air tugger / winch. Guards shall be capable of supporting, without permanent
distortion, the weight of a 200 lb person. In addition, guards shall not cause an operator
to work in a non-stable or ergonomically incorrect position.
The travel area through which the air tugger / winch wire rope travels shall be
barricaded with Red Danger Tape to prevent non essential personnel from entering the
area without permission.
Approval Prior to Start of Operations
Upon completion of the installation of the air tugger to its fixed location, a photo shall be
taken and sent to the Facilitys Register Structural Engineer or Designee for approval of
tie down method and location. In those cases that a photo is unable to be taken, a
detailed drawing shall be made and provided to the Facilitys Register Structural
J1.8

Engineer or Designee. The First Line Supervisor will be responsible for providing the
Facilitys Register Structural Engineer or Designee the following information:
In those cases where a picture can be taken the following additional information shall be
provided:
Picture
Weight of load to be lifted
Size and thickness of clips
Amount and locations of clips
Size and locations for welds (especially on the back portion of the air tugger /
winch)
Tie-in details of snatch blocks
In those cases where a picture can not be taken the following shall be provided:
A Sketch showing tugger placement, snatch block placement
Weight of load to be lifted
Size and thickness of clips
Amount and locations of clips
Size and locations for welds (especially on the back portion of the air tugger /
winch)
Tie-in details of snatch blocks
Snatch Block or Sheave Installation
To prevent the improper spooling of the wire rope on the winch drum, a snatch block or
sheave shall be placed 6 to 8 feet in front of the air tugger. In those cases where the air
tugger / winch is being used to perform a vertical lift, the snatch block shall be placed
above air tugger / winch prior to the line being ran through the deck or grading
penetration.
To help prevent individuals from placing their hands on the air tugger / winch line, Red
Danger Barricade tape shall be placed on the snatch block or sheave as streamers to
help remind individuals not to place their hands on the wire rope.
The snatch block is used to help prevent the improper spooling of the drum rope.
Note: There are two (2) exceptions to this rule they are as follows:
Air tugger / winch operations that requires a straight pull in a horizontal direction.
During these operations a snatch block or sheave is not required.
Air tugger / winch operations that will be performing a downward lift and does not
have an appropriate anchor point for a snatch block or sheave above the deck
opening. In this case the First Line Supervisor must ensure the deck opening is
properly sized and runs the full length of the drum.
Ensuring the proper selection and installation of wire rope and sheaves is important to
maintain the safety of these operations. Sheaves and sheave mounting must be
designed and selected in accordance with all applicable standards, codes and
J1.9

regulations. Improper installation of wire rope or sheave can cause uneven spooling and
wire rope damage that could cause a load to drop.
The First Line Supervisor shall ensure wire rope and the rigging accessories are
correctly rated for the application. The following shall be considered when determining
the rating: weight of the load, weight of the rigging and rigging accessories.
Example of Sheave Sizes Wire Rope Diameter Min. Sheave Diameter inch mm inch mm

Wire Rope Diameter

Minimum Sheave Diameter

Inch.

mm.

Inch.

mm.

3/8

5/8

7/8
1

6
9
13
16
18
22
26

4-1/2
6-3/4
9
11-1/4
13-1/2
15-3/4
18

108
162
234
288
324
396
468

When using a sheave check minimum D/d ratio for application.


D = Sheave Pitch Diameter
d = Wire Rope Diameter
Typically for hoisting applications an 18:1 ratio is required. Periodically check sheaves for wear in
accordance with sheave manufacturer recommendation.

Maneuvering of Air Tugger / Winch Wire Rope


To help maneuver the wire rope back into the proper sequence, either a certified grating
hook should be place at the air tugger / winch or a come-a-long or Cadillac shall be
placed on the winch. Should the wire rope begin to improperly spool, a certified grating
hook, the come-a-long or Cadillac shall be used to pull the wire rope back into the
proper sequence.
Deck or Grating Penetrations
All deck or grating penetrations performed for below deck lifts / pulls shall be made in
such a way that promotes proper spooling of the air tugger / winch and protects against
the wire rope rubbing or snagging on the edges of the penetration. To help protect the
wire rope from rubbing or snagging on the edges of the penetration, the installation
team shall place softening material to eliminate potential damage to the wire rope by its
contact with the edge of the penetration.
All deck penetrations shall be appropriately barricaded per our open hole procedures
which should include the appropriate fall protections systems if warranted.
Pneumatic Operated Air Tuggers / Winches Operated in Potentially Explosive
Atmospheres
Due to the potential for rubbing and friction, which may cause sparks or elevated
temperatures that could be a source of ignition in an explosive atmosphere, the First
J1.10

Line Supervisor shall ensure the air tugger / winch operations receives a hot work
permit. The hot work permit shall be obtained from the facility owner for the air tugger /
winch operations. The First Line Supervisor is responsible for incorporating all permit
requirements into the air tugger / winch operations.
Pre Use Inspection / Pre Lift Testing
Prior to every shift and prior to the initial start up of any air tugger operations a pre use
inspection of the winch, wire rope and rigging shall be performed. Any deficiencies shall
be noted on the pre use inspection form, the First Line Supervisor Notified and the
deficiencies corrected prior to the air tugger operations beginning. The pre use
inspection shall be documented on the Air Tugger Operations Pre Use Inspection Form.
(see attachment 1)
The intent of an air tugger / winch operations pre use inspection is to ensure all winch
components and attachments are functioning properly and/or properly adjusted. During
this pre use inspection the operator shall perform an operational test by running the air
tugger / winch slowly in each direction with no load and check the operation of each
attachment or option prior to application use.
For loads exceeding eighty percent (80%) of the air tugger capacity, a pre lift test shall
be performed and documented on the Air Tugger / Winch Pre Use Inspection Form.
This test shall consist of the following:
The test load shall not be less than 110% of the rated load nor more than 125%
of the rated load, unless otherwise recommended by the manufacture.
The test load shall be hoisted a vertical distance to assure that the load is
supported by the air tugger(s) / winch(es) and held by the hoist brake(s).
The test load shall be lowered, stopped, and held with the brake(s).
Note: If a lift is to be used with a multiple number of air tuggers / winches, the test shall
be performed with all air tuggers / winches in operations at once. This pre lift test will
help ensure winch anchors and supporting structure are secure and in good condition.
In addition the following shall be observed and checked.
Ensuring air tugger / winch anchors and supporting structures are secure and in good
condition:
Fasteners - Check retainer rings, split pins, cap screws, nuts and other fasteners
on winch, including mounting bolts. Replace if missing or damaged and tighten if
loose.
Foundation or supporting structure - Check for distortion, wear, rigidity and
continued ability to support winch and rated load. Ensure winch is firmly mounted
and that fasteners are in good condition and tight.
Ensuring air tugger / winch supply cables and hoses are in good condition and
connections are tight:
J1.11

Failure of electric cables or their disconnection while power is supplied can result
in electrocution.
Failure of air or hydraulic hoses or their disconnection while pressurized can
result in hazardous situations including the whipping of hoses. To prevent this
potential hoses shall be connected with safety pins installed in crow feet
connects with the appropriately sized whip checks are installed
Keep clear of whipping hoses. Shut off the compressed air or hydraulic pressure
before approaching the whipping hose.
Notify supervisory or maintenance personnel of any malfunction or damage.
Trained and authorized personnel must determine if repairs are required prior to
operating the winch.
Winch should never be operated with damaged wire rope, controls or guards.
Operating an Air Tugger / Winch
The following operating instructions have been adapted in part from American National
(Safety) Standard ASME B30.7 and are intended to avoid unsafe operating practices
which might lead to injury or property damage. The four most important aspects of
winch operation are:
Follow all safety instructions when operating winch.
Allow only people trained in safety and operation of this winch to operate this
equipment. See Training section of this procedure.
Subject each winch to a regular inspection and maintenance program.
Be aware of winch capacity and weight of load at all times. Ensure load does not
exceed winch, wire rope and rigging ratings.
CAUTION

Note: If a problem is detected, immediately STOP operation and notify supervisor. DO


NOT continue operation until problem is corrected.
During all air tugger / winch operations, the operator must be aware of load and its path.
Load must have a free unobstructed path from pick up to set down. This awareness is
to ensure that load does not contact any hazards. Some of the hazards to watch for and
avoid are:
Guide wires, other load lines, strung hoses.
Personnel in the working or walking in the path of the lift or under the load as it
moves. To prevent this condition the travel area of the air tugger / winch rope
shall be barricade. Personnel shall NEVER be under or in the path of a moving
load.

J1.12

Air tugger / winch operations shall be shut down when winds exceed 25 miles per
hour. No loads shall be lift suspended for any period of time.
If during the lift a load must be held suspended, the following shall be followed:
o Operator shall not leave the controls
o If the load must remain suspended for a considerable time a pawl or other
equivalent means, rather the brake alone shall be used to hold the load.
Erratic control valve operation (can cause a sudden jerk on load which could
create an overload condition).
Removing all obstacle such as buildings, support members, another load, etc
from the path to prevent the load from banging or hanging up on the obstacle.
Should the obstacle be unable to be moved, a different plan and site evaluation
shall be performed.
When multi-parting the load line, the two sheaves come together (also called
Two-Blocking).
During onshore operations, power lines, telephone lines and electrical cables.
During pulling (dragging) operations:
Watch for obstructions that could cause load to hang up, causing sudden
uncontrolled load shift.
Direct foot and vehicle traffic to ensure they maintain a safe distance from the
load path and load line.
Additional Operating Procedures
When a DO NOT OPERATE sign is placed on the winch, or controls, do not operate
the winch until the sign has been removed by designated personnel.
Ensuring proper communication is established with the signal person. When the
operation does not allow for the operator to maintain visual contact on the lift at all times
(i.e. Blind lift), the JSEA shall identify who is responsible for signaling the operator and
identifies the method of communications between signal person(s) and operator.
Keep hands, clothing, jewelry, etc. away from wire rope, drum and other moving parts.
Ensuring the operator operates the air tugger / winch with smooth control movements to
prevent jerking or sudden movements of the load.
Ensure the load is not pulled into support structure or winch of the air tugger
Ensure wire rope hook end is not attached or connected (stowed) to an unmovable
point prior to lift operation.
Immediately stop operation if load does not respond to air tugger / winch control.
J1.13

Ensure brake(s) hold prior to making complete lift by lifting load a short distance and
releasing control.
Ensuring the operator is able to maintain visual contact with the load, drum or wire rope
at all times. During a blind lift, the operator shall ensure an adequate number of signal
persons are identified, appropriately spaced / located, provided appropriate means to
communicate effectively with each other and with the operator. This shall be
documented on the task JSEA.
Ensure all personnel involved in the air tugger / winch operations keep hands and
clothing clear of gaps or spaces on winches, off of wire rope and away from sheaves or
snatch blocks.
Operating in Cold Weather
When operating an air tugger / winch in Cold weather, these operations can present
additional hazards. At very cold temperatures metal can become brittle and the use of
this piece of equipment requires extreme care to ensure that load movements are
smooth and even. The lubricating fluids do not flow as readily during cold temperatures
and every effort to warm all fluids and components before operation needs to occur for
the best performance. The warming of fluids can be accomplished by running the winch
slowly in both directions with no load to initially lubricate components.
In addition to the equipment concerns, operators maybe wearing increased clothing.
Their feel of controls, field of vision and hearing could be impaired due to the increased
clothing. To help minimize these effects the First Line Supervisor shall ensure that
additional personnel and / or signal person are used to maintain a safe operation.
Whenever temperature are below freezing, 32 F (0 C), extreme caution must be
exercised to ensure that no part of product, supporting structure or rigging is shock
loaded or impacted as brittle fracture of steel may result.
Completion of Air Tugger / Winch Operations
At the completion of air tugger / winch operation or when in a non-operational mode the
following actions shall occur:
Remove load from load line. Never maintain a load suspended in the air.
Spool load wire rope back onto winch drum and secure. For load lines over
sheaves or snatch blocks, the wire rope shall be secured in a position that will
avoid a safety hazard in the area.
Turn off/shut off or disconnect power supply.
Secure winch against unauthorized and unwarranted use.

J1.14

Air Tugger / Winch Brake


Brakes are of two basic types, band brake and disc brake. Disc brakes are internal and
connected to the drive train. They are automatically engaged, locking the drive train to
the winch frame, thereby stopping drum rotation when the control is released or placed
in the neutral position.
External band brakes wrap around the drum. When applied, the brake band tightens on
the drum and a stop on the band brake contacts the frame of the winch to stop drum
rotation. This tightening can be done two ways. Manually by a lever or wheel which the
operator controls or automatically. On automatic band brakes when the control is placed
in the neutral position the band brake tightens, locking the drum.
Winches with a manual band brake require the operator to operate both winch control
and band brake control simultaneously during operations. It is recommended that
owners/users practice operation of brake and winch control with lighter loads until
proficient with both functions.
When lowering loads near the winches rated load at very slow speeds, monitor the
temperature of the brake bands and/or brake housing. This load/speed combination
may result in automatic brakes dragging, which could cause heat build up. Indications
that the heat build up on the brake is excessive are:
Housing surface temperatures in access of 120 C
Visible indications of hot paint, such as blisters or scorching
The smell of hot oil or burning paint
Stop all operations any time a hot brake is detected.
When operating a winch with a manual drum brake, ensure the brake is fully released
when load is in motion. Use the control throttle to control the speed of the winch. Do not
drag the brake to control the winch speed. If the winch has only a manual drum brake
(no automatic brakes), set the brake to stop winch motion.
Operators must pay careful attention to brake operation at all times. At any indication of
loss of braking ability operator must immediately cease operation, shut off power to the
winch and inform their supervisor. Some indications of brake problems are:
Brake bands or housings becoming very hot during operation. This is an
indication of excessive slippage
Abnormal sounds, such as grinding, coming from brake parts during activation
of the brake. This is an indication of worn bands
Brake(s) do not hold load when winch control is in neutral
During operation it is necessary for the operators hand to be close to the drum when
using a manual band brake. To minimize the possibility of contact:
J1.15

Maintain a firm grip on brake lever handle and winch throttle control lever.
Ensure footing is clean, dry and firm.
Maintain a good comfortable posture, do not lean.
Ensure any loose clothing is tucked in or out of the way of the drum.
Ensure the band brake is correctly adjusted which will allow the operator to stop
drum rotation when the brake is fully engaged.
Use Winch Drum Guards which are available and recommended by the
manufacturer for all air tugger / winch installations
Disengaging Clutch
Clutches are used to disengage the drum from the drive train, which allows wire rope to
free spool from the drum. When the drum is in the free spool mode, use of the band
brake to control wire rope payout is required to prevent the loosening of wraps on the
drum. After wire rope is out and connected to load, the operator should engage the
drum and slowly apply tension to wire rope.
On winches with a clutch free spool option, wire rope should spool from drum with
minimal effort. When pulling wire rope from drum in the free spool mode, do not strain
or lose balance and always look where youre going to avoid tripping.
Note: To prevent load control loss, do not disengage the clutch when there is a load on
the air tugger / winch.
Spooling and Handling of Wire Rope
The most important part of wire rope spooling is attaching wire rope to the drum.
Different methods are used to fasten the wire rope to the drum. The individuals spooling
the wire rope shall refer to the Manufactures Product Information Manuals for the
specific method. Note: Failure to match wire rope diameter with the correct wire rope
anchor hardware can cause wire rope to release from drum and drop the load.
Prior to the staring the spooling operations the individual performing this installation
shall ensure all non-essential individuals are kept away from this operations. This shall
be accomplished by barricading the area with Red Barricade Tape around this
operation. Note: Spooling of an air tugger / winch shall not occur offshore unless
determined as an emergency situation by the Offshore Operations Manager.
The individuals spooling the wire rope shall ensure the anchor pocket guard is installed
when provided with the winch. This individual shall check to ensure the wire rope length
is sufficient for the task meaning the length for the entire range of movement specified
for the application, with no less than three (3) full wraps of rope on the drum at all times,
does not exceed the top layer diameter and is approved for the application. At no time
shall anyone be allowed to add additional wire rope to the established length to extend
the length of the air tugger / winch wire rope. All ends of the air tugger / winch wire rope
will be required to have a manufactured eye.
J1.16

Only factory approved hardware shall be used to attach wire rope to drum. When
initially spooling wire rope onto the winch drum make certain that it bends in the same
direction. The proper method of spooling an air tugger / winch is to re-reel from the top
of one reel to the top of another, or from the bottom of one reel to the bottom of another.
It is also necessary to apply a tensioning load to the wire rope to achieve good spooling.

A. Correct; B. Over wound; C. Winch Drum; D. Wire Rope Spooling; E. Spool;


F. Under wound; G. Incorrect.
Note: Always use gloves, or suitable hand protection when handling wire rope.
When installing new wire rope it is important that all wraps of the first layer are tight on
the drum and adjoining the previous wrap. Open or wavy winding will result in wire rope
damage when multiple layers are used. Adjacent turns should be tight against each
other. If gaps occur between wraps, STOP air tugger / winch and tap wire rope with a
composite or wooden mallet, so that the strands are snug but not interlocked. Do not
restart drum rotation until everyone is clear. The succeeding layers of wire rope should
wind across the preceding layer of wire rope without gaping or bunching. Ensure that
the correct length of wire rope is fitted. This is particularly important as it may be
necessary to fit specific lengths of wire rope for particular applications and wire rope
reeving combinations. The installer shall watch for the following conditions:
Too short of a wire rope could result in the wire rope completely paying out and
the wire rope anchorage on the drum having to carry the full load.

J1.17

Too long a wire rope could exceed the drums spooling capacity, causing the wire
rope to ride over the drum flange resulting in the load dropping, severe damage,
wire rope crushing or complete winch failure.
It is good practice to check the wire rope length whenever the structure is changed, wire
rope is changed or reeving altered. To be certain that wire rope spools evenly on drum
use a spooling device to keep tension on wire rope, approximately 10% of the working
load is recommended. Maintain a fleet angle between the lead sheave and winch of no
more then 1-1/2. A 2 fleet angle is allowable with grooved drums. Exceeding the
specified fleet angle can cause excessive friction, leading to heat build up or sparks.
The lead sheave must be on a center line with the drum, and for every inch (25 mm) of
drum length, be at least 1.6 ft (0.5 m) from the drum. See the diagram below:

A. Sheave; B. Fleet Angle; C. Drum Flange.


The entire length of wire rope should be wound on the drum tightly and correctly as this
will facilitate good winding during operation. Poor or incorrect spooling can:
Shorten wire rope life cause erratic winch operation.
Cause wire rope to drop.
Cause wire rope to bunch.
Be less than distance to flange dimension.

J1.18

A. Sheave Flange and Wire Rope Wear; B. Wire Rope Wear; C. Wire Rope Wound too
tightly compressed; D. Uneven Spooling Bunched Wire Rope; E. or; F. When the Fleet
Angle is too small the Result is Poor Winding.
The spooling area shall be clean and free of debris and care shall be taken to ensure
that the wire rope is clean and properly lubricated as it is spooled onto drum. The Wire
rope shall not be allowed to drag or touch the ground during spooling. Prior to the
spooling of the wire rope, an inspection shall be performed of the wire rope and
carefully as the wire rope is being spooled onto drum. The individual installing the wire
rope shall watch for broken or loose strands or other signs of damage or unserviceable
wire rope.
Note: Use of wire rope sizes other than recommended will greatly decrease the life of
the wire rope.
CAUTION
J1.19

Upon completion of spooling and prior to final installation, the individual spooling the
wire rope shall secure the rope to drum. The securing of the wire rope will prevent wire
rope from loosening on the drum.
Grooved drums are designed with the correct groove pitch and depth for one diameter
of wire rope. To determine the proper wire rope size the individual spooling the air
tugger / winch shall refer to the Manufactures Product Information Manuals. Should the
wire rope size and grooved drum do not match, the individual spooling the air tugger /
winch shall notify his First Line Supervisor immediately so either the drum or wire rope
can be replace with the correct size. Remember the use of the wrong diameter wire
rope on a grooved drum will cause improper spooling of the first layer and it will also
cause excessive wear, damage, erratic operation and shortened life of the wire rope.
Winches without grooved drums are designed for a range of wire rope sizes. The
individual spooling the air tugger / winch shall refer to the Manufactures Product
Information Manuals for the specific range. The use of a wire rope with a larger
diameter than specified will result in decreased life of the wire rope and can cause
damage to the internal wire rope strands, which cannot be seen with a visual inspection.
The diagram below illustrates the correct manner to spool wire rope onto the air tugger /
winch drum.

A. Correct Spooling; B. Distance to Flange; C. Even, Tight Wraps on Drum.


Remember when spooling is complete the wire rope should:
Be tight on each layer.
Have single even layers.
Not be bunched.
Not exceed distance to flange dimension (as specified in the Manufactures
Product Information Manuals).

J1.20

Preventive Maintenance Program


A preventive maintenance program shall be implemented on the air tugger / winch per
the manufacturer's recommendations. Rental companies are expected to maintain
records of the preventive maintenance inspections and must be kept for the life of the
equipment.
Personnel Lifting
Personnel lifting shall not occur within air tuggers / winch that are not personnel or man.
Note: All personnel lifts performed by air tuggers / winches shall be personnel or man
rated and meet the requirements outline within the Moreno Group, LLC and
Subsidiaries SH&E Management System, Crane Policy under Suspended Personnel
Man Baskets / Platforms.
Training of Operators
Each Air Tugger / Winch operations shall be performed by a Qualified Operator that
meets the definition of a Qualified Operator both physically and training.
To designate an employee as a Qualified Operator, the individual must possess a
current API RP 2d Rigging Certification prior to attending the Moreno Group LLC and
Subsidiaries Air Tugger / Winch Operator Training course. The Air Tugger / Winch
Operators Training shall consist of the following:
Classroom and a Hand-on performance evaluation
Moreno Group LLC and Subsidiaries Air Tugger / Winch Operations Safe Work
Practices.
Proper methods and documentation involved in the pre use inspection of an Air
Tugger / Winch
Air Tugger / Winch Operator Training shall be performed at a minimum every 4 years.

J1.21

Attachment 1

J1.22

Air Tugger / Winch Pre-Use Checklist


Date:

Customer:

Supervisor:

Job Location:

Operator:

Job #:

Application:

Pull or Dragging

Lifting / Weight Bearing (Lift Preparation section MUST be completed)

Air Tugger secured in appropriate manner and approved by facility rep.?


Certification of Tugger & Cable Current (within 1 year)?

YES

YES

NO

NO

(Certification Certificates should be verified before operations begin)


Capacity of Tugger:

LBS

KG

Metric Tons

Wire Rope
Diameter:

inch

mm

Tagged Capacity

Is the wire rope spliced in any place?

YES

NO

(If yes, remove from service)

Is manufactured thimble & eye in place?

YES

NO

(If no, remove from service)

Power Supply & Controls:


Combined Compressor CFM Output:
Volume Bottles Added?

CFM

YES

Is the tugger spool side loaded?

NO
YES

NO

(If yes, then repositioning required)

(Angle from spool opening to snatchblock greater than 15 degrees)


Safety Devices:
Control Arm Return to locked position when not in use?
Snatch Blocks Properly Rigged

Safety Cage intact?

Location of Snatch Blocks:

Certified Grating Hook / Come-A-Long / Cadillac to keep Wire Rope properly aligned
Shut off Valve at air tugger
Barricades installed around tugger operation area

Snatch blocks flagged to denote pinch point

Brakes & Auxiliary Holding Devices:


Manual Band

Gear Brake

Communication Method:
Lift Preparations:
Function Test Complete?

YES

NO

(NOTE: Proof Test required if load is greater than 80% of air

tugger capacity)
For Function Test to be valid, all tuggers involved must be operated simultaneously & all brakes tested.
Tugger Air Demands Total:
Total Weight of Load:

Combined Tugger Capacity:

lbs

lbs

FOR MULTIPLE TUGGER/VERTICAL LIFTS, THIS CHECKLIST AND JSEA + JOB PLAN MUST BE FAXED
TO MANAGER FOR APPROVAL AND SIGNOFF
Manager Approval:

Supervisor on Site:

Platform Rep agreeing to task:


J1.23

Moreno Group LLC


and Subsidiaries SH&E
Management System

Barricading Procedure

Page 1 of 3
Original: 01/01/2004
Revised: 01/01/2008

Barricading Procedure
Purpose
To provide minimum safe work practices for the set-up and maintenance of
barricades that restrict entry and/or provide warning for areas that involve hazardous
activities, unsafe conditions, or unusual circumstances.
Scope
The scope of this procedure is to address the various situations, which require the
use of barricades and the types of barricades, which should be utilized.
Responsibilities
The Facility Manager or Offshore Manager or Designee is responsible for:
Provide resources to fully implement this procedure.
The First Line Supervisor / Offshore Superintendent is responsible for:
Understanding and complying with the requirements of this procedure.
Ensuring that employees comply with the requirements of this procedure.
Evaluating work areas and ensuring that situations, which require barricades,
have been barricaded as per this procedure.
Authorizing employees to enter barricaded area to perform assigned work.
Authorizing employees to remove barricade once hazard has been
eliminated.
The Safety, Health and Environmental Department is responsible for:
Evaluating Program to ensure compliance
The Employee is responsible for:
Understanding and complying with the requirements of this procedure.
Communicating to supervisors any suggestions or concerns related to this
procedure
Stopping unauthorized employees from entering inside a barricaded area..
J2.1

Definitions
Caution Yellow for situations, which may cause minor incident. Signs will be
posted on the barricade to identify the specific hazards and requirements, which
shall be taken inside the barricaded area. Employees shall exercise caution prior to
entering inside a yellow barricade.
Danger Red for hazards which are immediately or potentially life threatening or
can cause serious injury. Only authorized employees shall enter into areas, which
have been barricaded with Danger Red. Signs will be posted on the barricade to
identify the specific hazards and requirements, which shall be taken inside the
barricaded area.
Magenta or Purple or Black on a Yellow background Signage that identifies areas
where there is potential for radiation exposure. Only designated personnel are
allowed inside radiation areas. Moreno Group LLC and Subsidiaries personnel shall
not enter a radiation area at any time unless the crew is not performing any X-raying
and when authorized by the X-ray crew to enter the regulated area.
Protective Barricade - Provides a physical barrier withstanding 200 pounds of
pushing force to protect personnel from hazards such as floor openings or
excavations. Protective barricades shall consist of a toprail, midrail and toeboards.
Anytime wire rope is used, it shall have a diameter of at least 3/8 inch and barricade
should be covered with high visibility orange mesh fencing. If fencing is not
available, red danger flagging needs to be placed at 6 feet intervals on toprail of
barricade to ensure visibility.
Warning Barricade - Erected to call attention to specific hazards, but provides no
physical protection from the hazard.
Requirements
Moreno Group LLC and Subsidiaries will require the use of barricades wherever
necessary for the physical protection of people or property.
The following is a list of activities, which require the use of protective barricades:
Open holes or missing handrails that pose the threat of a fall to a lower level.
Excavations / Trenches
The following is a list of activities, which require the use of Danger Red Color
Coded warning barricades:
Areas underneath construction activities where there is potential for falling
objects.
Areas with temporary wiring operating at more than 600 volts.
Work areas for electrical equipment with exposed, energized parts.
J2.2

Confined Space work areas


Accident / Incident scenes which have not been investigated, or potentially
infectious material may be present.
Work Areas which pose a health risk (i.e. Lead, Asbestos, etc.)
The following is a list of activities, which require the use of Caution Yellow Color
Coded warning barricades:
Material Storage Areas
Slip / Trip and Same Level Fall Hazards
Areas in which x-raying is being performed may be barricade with Caution or Danger
Tape with a sign that contains the standard radiation symbol with the use of colors
magenta or purple or black on yellow backgrounds. When approved by the Facility
Management cones and required signage may be utilized to barricade the regulated
area.
Barricades must completely enclose areas of a more hazardous nature.
Barricades should be erected approximately 42 inches from the ground or floor.
Barricades protecting work areas below overhead work shall be built to a 1' to 1'
ratio (meaning if working 10' above work area, barricade shall be at least 10' radius
of work area below).
All personnel who work inside the barricade are responsible to see that the barricade
is maintained and that housekeeping within the barricade is maintained.
Warning signs shall be placed on barricades to notify personnel of purpose of
barricade, and precautions to be taken prior to entering barricade.
Barricades shall not be removed until hazard is completely removed and only with
supervisors permission.
Barricade material can include plastic barricade tape, woven tape, rope, plastic
chain, or any other material that provides the proper color-coding and will withstand
the environment in which it is placed.
Procedures for Entering a Barricaded Area
Danger Barricaded areas are to be entered only with specific permission from your
immediate supervisor.
Barricades should be entered only after all of the
requirements identified on the barricade sign have been followed.
Caution Barricaded areas are only to be entered after carefully reading the warning
sign and ensuring that protective measures are being taken as per the warning sign.
J2.3

Moreno Group LLC and


Subsidiaries SH&E
Management System

Confined Space Entry

Page 1 of 20
Original: 01/01/2001
Revised: 3/16/2010

Confined Space Entry


Purpose
To establish methods to identify confined spaces, classify them according to their
risks and to establish guidelines necessary for the safe preparation, entry, and
restoration of a confined space entry.
Scope
The scope of this program establishes recommended procedures for classifying;
preparing and entering of confined spaces. This program applies to any confined
space that meets the following definition:
That has limited openings for entry and/or exit;
That could contain known or potential hazards;
That is not intended for continuous occupation;
Or that has insufficient natural ventilation.
Note: This program shall be followed when our customer (owner of the facility) does
not have a Confined Space Entry Program or when a confined space entry is
conducted at our facility. Although, Moreno Group LLC and Subsidiaries
employees shall not enter confined spaces, which has an Immediately
Dangerous to Life and Health (IDLH) condition.
Examples of confined spaces include:
Spaces normally entered through a manhole, such as tank cars, process
vessels, bins, furnaces, boilers, storage vessels, mixers, etc.
Open topped spaces more than four (4) feet deep not subject to good
ventilation, such as pits, trenches, vessels, vaults, sumps, wells, etc.
Other types of spaces, such as large diameter pipes, septic tanks, sewers,
etc.
Responsibilities
The Facility / Site Manager / Offshore Manager is responsible for overall program
administration.

J3.1

The First Line Supervisor / Offshore Superintendent in charge of the space and
/ or work is responsible for:
Implementing the program in their areas and monitoring compliance.
Assuring that entrants, attendants, gas testing and rescue personnel have
completed the appropriate training.
Obtaining and / or issuing the necessary permits and serve as the Entry
Supervisor.
Verifying that equipment preparation and isolation methods have been
completed (including the placement of tags and / or locks as required) and are
sufficient to protect personnel and equipment.
Perform Confined Space Pre-entry Checklist and Hazard Assessment. (See
Attachment 1)
Performing, or having a qualified gas tester perform, the pre-entry and followup atmospheric monitoring for oxygen, flammable and toxic atmospheres.
Complete Confined Space Entry Permit. (See Attachment 2)
Instructing personnel on the proper methods and safeguards required to
perform the job safely.
Develop Rescue Plan for Entry. (See Attachment 1)
Compliance with pre-set conditions on the permit.
Alerting all affected personnel to changes in area conditions which could
adversely affect personnel or equipment involved.
Leaving the jobsite in a safe, clean condition.
Informing the appropriate personnel when the work has been completed, by
returning and / or signing "off" on the permits (including the removal of any
tags and / or locks used to isolate the equipment).
The Safety, Health and Environmental Department is responsible for:
Maintaining a master list or description of permit and non-permit required
confined spaces at the facility / site.
Assisting Moreno Group LLC and Subsidiaries managers and
supervisors/superintendents with the confined space hazard analysis and the
development of entry and emergency procedures.
Procurement, maintenance and calibration of gas testing equipment.
J3.2

Coordinating Confined Space Entry and Gas Testing training.


Assisting with atmospheric monitoring as needed.
Reviewing and endorsing the Confined Space Entry Permit before personnel
enter the space.
The Personnel entering a Confined Space are responsible for:
Understanding and following the Confined Space Entry Procedure.
Knowing the requirements and precautions specified on the Confined Space
Entry Permit.
Knowing the potential hazards related to the confined space involved.
Being able to recognize the signs and symptoms of over-exposure to potential
hazards.
Understanding the consequences of over-exposure to potential hazards.
Maintaining contact with the Attendant (Hole-Watch).
Evacuating the confined space when conditions change, become unsafe or
when instructed to do so by the Attendant.
Using the personal protective equipment required for the job as specified on
the Confined Space Entry Permit.
The Attendant (Hole Watch) for Confined Space Entry is responsible for:
Understanding and following the Confined Space Entry Procedure.
Maintaining an accurate count of all persons in the confined space (see
Attachment 3) utilizing the back of the Confined Space Entry permit.
Knowing the requirements and precautions specified on the Confined Space
Entry Permit.
Knowing the potential hazards related to the confined space and potential
hazards from activities outside the Confined Space, which could affect the
confined space.
Maintaining contact with personnel working in the confined space.
Being able to recognize the signs and symptoms of over-exposure to potential
hazards.
Ordering evacuation of the confined space when:
J3. 3

A condition develops which is not allowed by the entry permit.


Personnel show behavior-indicating over-exposure to hazardous materials.
A situation outside the space develops which could endanger personnel in
the confined space.
The Attendant must leave his / her workstation.
Keeping unauthorized persons away from the confined space.
Summoning rescue services in emergency situations.
NOTE:

The Attendant may leave his / her workstation only long enough to
summon rescue or emergency services.

Assisting rescue personnel to the extent possible based on training to do so.


The Attendant is not to enter the confined space to attempt rescue except as a
trained member of a rescue team.
Definitions
Confined Space means a space that:
is large enough and so configured that an employee can bodily enter and
perform assigned work; and
has limited or restricted means for entry or exit; and
is not designed for continuous employee occupancy.
Non-Permit Confined Space means a confined space that does not contain or with
respect to atmospheric hazards, have the potential to contain any hazard capable of
causing death or serious harm. This type of confined space shall require a written
permit to certify the confined space is able to be entered.
Permit-Required Confined Space means a confined space that has one or more of
the following conditions or characteristics:
Contains or has the potential to contain a hazardous atmosphere or
Contains a material that has the potential for engulfing an entrant or
Has an internal configuration such that an entrant could be trapped or
asphyxiated by inwardly converging walls or by a floor, which slopes
downward and tapers to a smaller cross-section or
Contains any recognized serious safety or health hazard.

J3.4

Note: A Permit-Required Confined Space may be reclassified as a Non-Permit


Confined Space by removing the hazard.
Acceptable Entry Conditions means the conditions that must exist in a permit space
to allow entry and to ensure that employees involved with a permit-required confined
space entry can safely enter into and work within the space.
Attendant means an individual stationed outside the permit space who monitors the
authorized entrants and who performs all attendants duties assigned by the Confined
Space Entry Program.
Authorized Entrant means an employee who is authorized by the employer to enter a
permit space.
Blanking or Blinding means the absolute closure of a pipe, line or duct by fastening of
a solid plate that completely covers the bore and is capable of withstanding the
maximum pressure of the pipe, line or duct with no leakage beyond the plate.
Attempts should be made to blind at the closest point to the confined space.
Double Block and Bleed means the closure of a line or pipe by closing and locking or
tagging two (2) in-line valves and by opening and locking or tagging a drain or vent
valve in the line between the two closed valves.
Entry means the action by which a person passes through an opening into a permitrequired confined space. Entry occurs as soon as any part of the entrants body
breaks the plane of an opening into the space.
Entry Permit means the written or printed document that is provided by the employer
to allow and control entry into a permit space. Acceptable entry conditions are
properly noted on the document.
Entry Supervisor means the person responsible for determining if acceptable entry
conditions are present at a permit space where entry is planned, for authorizing entry
and overseeing entry operations, and for terminating entry as required.
Hazardous Atmosphere means an atmosphere that may expose employees to the
risk of death, incapacitation, impairment of the ability to self-rescue, injury, or acute
illness from one or more of the following causes:
Atmosphere oxygen concentration below 19.5 percent or above 23.5 percent.
Flammable gas, vapor, or mist in excess of 10 percent of the lower explosive
limits (LEL).
Airborne combustible dusts at a concentration that meets or exceeds its lower
explosion limits (LEL).
Any other atmospheric condition that is Immediately Dangerous to Life and
Health (IDLH).

J3. 5

Atmospheric concentration of any substance for which exposure could result in


excess of that substances permissible exposure limit.
Hot Work Permit means the employers written authorization to perform operations
capable of providing a source of ignition.
Immediately Dangerous to Life or Health (IDLH) means any condition that poses an
immediate or delayed threat to life or that would cause irreversible advance health
effects or that would interfere with an individuals ability to escape unaided from a
permit space.
Inerting means the displacement of the atmosphere in a permit space by a
noncombustible gas to such an extent that the resulting atmosphere is
noncombustible. Note that this procedure produces an IDLH oxygen deficient
atmosphere.
Isolation means the process by which a permit space is removed from service and
completely protected against the release of energy or material into the space.
Oxygen Deficient Atmosphere means an atmosphere containing less than 19.5
percent oxygen by volume.
Oxygen Enriched Atmosphere means an atmosphere containing more than 23.5
percent oxygen by volume.
Permit System means the employers written procedure for preparing and issuing
permits for entry and for returning the permit space to service following termination of
entry.
Prohibited condition means any condition in a permit space that is not allowed by the
permit during the period when entry is authorized.
Rescue service means the persons designated to rescue employees from permit
space.
Retrieval system means the equipment (including a retrieval line, chest or full-body
harness, wristlets, if appropriate, and a lifting device or anchor) used for non-entry
rescue of persons from permit spaces.
Testing means the process by which the hazards that may confront entrants of a
permit space are identified and evaluated. Testing includes specifying the tests that
are to be performed in the permit space.
Confined Space Duties
Duties of Authorized Entrant
The authorized entrant shall be trained and understand the following duties:
Know the hazards that may be faced during entry, including information on the mode,
signs or symptoms, and consequences of the exposure.
J3.6

Properly use atmosphere testing equipment, ventilation equipment, personal


protective equipment, communication equipment, lighting equipment and rescue or
emergency equipment.
Communicate with the attendant as necessary to enable the attendant to monitor
entrant status and to enable the attendant to alert entrants of the need to evacuate
the space.
Alert the attendant whenever:
The entrant recognizes any warning sign or symptom of exposure to a
dangerous situation, or
The entrant detects a prohibited condition; and
Exit from the permit space as quickly as possible whenever:
An order to evacuate is given by the attendant or the entry supervisor,
The entrant recognizes any warning sign or symptom of exposure to a
dangerous situation,
The entrant detects a prohibited condition, or
An evacuation alarm is activated
Duties of Authorized Attendant
The authorized attendant shall be trained and understand the following duties:
Knows the hazards that may be faced during entry, including information on the
mode, signs or symptoms and consequences of the entrants.
Is aware of possible behavioral effects of hazard exposure in authorized entrants.
Continuously maintains an accurate count of authorized entrants in the permit space
on the back of the Confined Space Permit. No one shall enter the confined space
without reading, and understand the conditions and requirements on the confined
space permit.
Remains outside the permit space during entry operations until relieved by another
trained attendant. Each attendant shall sign the back of the confined space permit
prior to going on or off duty.
Entry attendant will be responsible for periodically or continuously monitoring the
confined spaces atmosphere
Communicates with authorized entrants as necessary to monitor entrant status and to
alert entrants of the need to evacuate the space.

J3. 7

Monitors activities inside and outside the space to determine if it is safe for entrants
to remain in the space and orders the authorized entrants to evacuate the permit
space immediately under any of the following conditions:
Attendant detects a prohibited condition
Attendant detects the behavioral effects of hazard exposure in an authorized
entrant.
Attendant detects a situation outside the space that could endanger the
authorized entrant.
Attendant cannot effectively and safely perform all the duties required.
Summon rescue and other emergency services as soon as the attendant determines
that authorized entrants may need assistance to escape from permit space.
Take the following actions when unauthorized persons approach or enter a permit
space while entry is underway:
Warn the unauthorized persons that they must stay away from the permit space.
Advise the unauthorized persons that they must exit immediately if they have
entered the permit space
Inform the authorized entrants and the entry supervisor if unauthorized
persons have entered the permitted space.
Perform non-entry rescues as specified within entry SH&E Meeting.
Preventing any unauthorized personnel from attempting a rescue.
Perform no duties that might interfere with the attendants primary duty to monitor and
protect the authorized entrants.
Maintains any Material Safety Data Sheets (MSDS) of chemicals present or
potentially present within confined space.
Duties of Entry Supervisors
The entry supervisor shall be trained and understand the following duties:
Knows the hazards that may be faced during entry, including information on the
mode, signs or symptoms, and consequences of the exposure;
Conducts a Pre-Entry Hazard Assessment of the space to be entered;
Verifies, by checking that the appropriate entries have been made on the permit, that
all tests specified by the permit have been conducted and that all procedures and

J3.8

equipment specified by the permit are in place before endorsing the permit and
allowing entry to begin;
Terminates the entry and cancels the confined space permit if the following happens:
The entry operations covered by the entry permit have been completed; or
A condition that is not allowed under the entry permit arises in or near the
permit space.
Verifies that rescue services are available and that the means for summoning them
are operable;
Removes unauthorized individuals who enter or who attempt to enter the permit
space during entry operations; and
Determines, whenever responsibility for a permit space entry operation is transferred
and at intervals dictated by the hazards and operations performed within the space
that entry operations remain consistent with terms of the entry permit and that
acceptable entry conditions are maintained.
Requirements
A master list of confined spaces at the each location shall be maintained at each
Moreno Group LLC and Subsidiaries facility. Confined Spaces have either been
classified as Permit Required or Non-Permit Required Spaces. All supervisors
should be familiar with this list and consult it to see if a permit is required before
allowing anyone to enter any confined space.
Additions or deletions from the facilitys list of Confined Spaces must be approved by
the Facility / Site Manager and the Safety, Health and Environmental Manager.
Supervision should be alert to the possibility that a confined space may exist or may
be introduced to the facility / site at a later date and that should be added to the list.
Warning signs must be posted at the entrance of confined spaces that may not be
recognized as a confined space.
Anytime multi employers are involved within a confined space a meeting shall occur
to coordinate the entry operation and to determine which permit system will be
followed.
Permit System
Trained Supervision, Safety, Health & Environmental Department or Yard Forman
may only perform atmosphere testing and issuing of Confined Space Entry Permits
(see Pre-Entry Checklist and Hazard Assessment, Attachment 1 and Attachment 2).
The supervisor of personnel performing work inside the space is the recipient of the
permit.

J3. 9

The permitting system shall allow the entry supervisor to evaluate the confined space
to ensure it has been properly prepared for entry. The space shall be blinded at each
inlet and outlet and/ or disconnected, lockout and tagout, cleaned (i.e. purging,
inerting, flushing, steaming, etc.) and properly ventilated.
Note: A double block and bleed shall not be substitute for blinding or disconnecting of
inlets or outlets of the space. Although, double block and bleeds can be used in
conjunction with blinding and disconnecting of inlets or outlets.
The entry supervisor shall barricade the immediate area around the confined space
to protect the space from unauthorized personnel, vehicles, etc. This will help protect
entrants from external hazards being created after the permit has been issued. A
Danger Permit Required Confined Space, Do Not Enter sign shall be placed on
the barricade.
All atmosphere testing and monitoring equipment used in, or to monitor atmospheres
in, confined spaces shall be UL Listed or FM Approved as Intrinsically Safe or
Approved for Use in Hazardous (electrically classified) Locations. Atmosphere
testing and monitoring equipment must have a field calibration check before the initial
use each day. In addition, functional operation checks must be performed before and
after each use. All calibration checks must be recorded and maintained by the
Safety, Health and Environmental Department. Personnel who perform gas testing or
atmospheric monitoring must be trained. Entry attendant will be responsible for
periodically or continuously monitoring the confined spaces atmosphere
Note: All ventilations systems shall be turned off during atmosphere testing.
All permit required and non-permit required confined spaces must have the
atmosphere tested before they are entered. Entry is not allowed into a confined
space with a "hazardous atmosphere".
Permissible exposures to abnormal atmospheres in Confined Spaces for purposes of
entry into confined spaces - a normal working atmosphere will be defined as one
which contains an oxygen concentration of 19.5% minimum and maximum
concentration of 23.5% and is free of harmful amounts of flammable gases, dusts,
and toxic materials (Less than 10% of the LFL and below the PEL or TLV). Anything
other than this will be considered an abnormal or alien atmosphere. Where normal
atmospheres cannot be achieved, personnel will not be permitted to enter.
Entry personnel must be given the opportunity to witness all calibrations of
atmospheric testing equipment and atmospheric monitoring of the space. When entry
personnel feel conditions within the confined space has changed, they can request
additional monitoring to be performed.
Continuous monitoring of the Confined Space atmosphere shall be performed at all
times during the entry. The Entry Supervisor shall recheck the atmosphere of the
confined space after all breaks.
Before any employee is permitted to enter a Permit Required Confined Space, a
Confined Space Entry Permit must be completed by the Entry Supervisor.
J3.10

The Entry Supervisor will communicate the following to all employees involved with
the confined space:
The conditions of the permit and hazards present within space.
The Material Safety Data Sheets (MSDS) of any chemicals present or
potentially present.
Communication procedures to be used between the authorized entrants and
attendants shall be established during this meeting.
Required Personal Protective Equipment, within confined space.
Additional equipment to be used during entry, rescue equipment, alarm
systems, testing equipment, etc.
Duration of permit.
All employees involved in the confined space must read and sign the permit prior to
the posting of the permit at the entrance to the space.
A trained Attendant must be assigned and stationed at the entrance of all permit
required confined space entry jobs. The authorized attendant shall ensure each
authorized entrants name and time entering and exiting the space is placed on the
back of the permit.
Anytime an authorized attendant will be monitoring more than one space, they shall
have radio communication with the entrants and the spaces shall not be more than
10 feet a part from one another. The attendant may not perform any other duties
other than those of an authorized attendant.
A Confined Space Entry Permit is valid for one (1) shift. A new entry permit must be
filled out, and posted at the main access way and reissued every shift or 12 hours.
The permit is void and must be reissued whenever one of the following occurs:
A condition develops which was not covered by the permit.
Unauthorized entry of the Confined Space.
Facility Evacuation Alarm.
An incident within the confined space or outside the confined space that has
affected the confined space.
The confined space permit shall not be removed until all personnel have signed off
the permit. The Entry Supervisor shall identify any problems encountered during the
entry on the permit and forward the permit to the Safety, Health and Environmental
Department for retention. Some examples of problems encountered during any entry
may include:
J3. 11

The unauthorized entry of a confined space.


A hazard not covered by the Confined Space Permit
An incident within the Confined Space or that affected the Confined Space.
The Safety, Health and Environmental Department will review all cancelled permits
for any problems that had been encountered during the entry. The Confined Space
Program shall be revised to address any problems that occurred during the entry. All
cancelled permits will be retained for 1 year and at a minimum shall be reviewed
annually.
Personal Protective Equipment / Non Entry Rescue
Suitable personal protective equipment must be worn when entering a confined
space. Although the equipment can vary depending on the assigned work, it may
include:
Self contained respiratory equipment
Acid or caustic resistant apparel i.e. slicker suits
Suitable hand protection
Eye and face protection
Head protection
Hearing protection
Foot protection
Safety harness
Personal protective equipment such as hard hats, safety glasses, face shields, and
steel toed boots etc., shall meet the applicable ANSI or other recognized industry
standards for the application.
Respiratory protection equipment shall have NIOSH Approval for the application.
Fall Protection & Rescue Retrieval equipment shall meet the applicable ANSI
Standards for the application.
A full body harness with lifelines attached may be required for those who enter the
confined space. If a lifeline is not required for those entering and if entry is from
above or through a manway, a lifeline must be immediately available to the standby
employee.
Each authorized entrant using a full body harness must have a retrieval line attached
at the center of the entrants back near shoulder level, or above the entrants head.
J3.12

Wristlets may be used in lieu of the full body harness, for horizontal entry, if the use
of a full body harness is infeasible or creates a greater hazard and that the use of
wristlets is the safest and most effective alternative.
The other end of the retrieval line must be attached to a mechanical device or fixed
point outside the permit space in such a manner that rescue can begin as soon as
the rescuer becomes aware that rescue is necessary. A mechanical device must be
available to retrieve personnel from vertical type permit spaces more than five (5) feet
deep.
Ventilation
General ventilation should be by exhausting from the confined space and discharging
to the outside.
Ventilation equipment should be placed at the top or bottom of the confined space
based on the risk/nuisance factors to be encountered. For example, if the risk factors
are represented by lighter than air gases such as hydrogen (H2) or natural gas
(methane), the air mover must be near the top of the confined space where these
gases will rise. In all other circumstances, the air mover should be at the bottom of
the confined space.
The inlet for ventilation air must be at a position upwind from the air mover to avoid
short circulating which defeats the purpose of ventilation, and away from diesel
engines, etc., such as welding machines.
A positive means of ventilating the vessel or space must be established and operated
the entire time work is in progress. The accepted practice and the recommended
level for general ventilation is one complete air change every three (3) minutes. In
some cases natural may be sufficient. In other cases it may be necessary to use
fans or air movers. The ventilation system must be arranged so that only clean, fresh
air is drawn into the vessel. Ventilation systems should be bonded to the space or
vessel.
If air operated horns are used to ventilate a space they must exhaust outside the
space, not inside. Air horns may only be operated by clean fresh air. Nitrogen,
oxygen or other gases are hazardous and may not be used.
Whenever welding, cutting, burning or brazing is performed in a confined space, local
exhaust ventilation may be necessary to "capture" contaminants or fumes at the
source (the point of operation) and remove them from the atmosphere within the
confined space. The exhaust air mover must be outside the Confined Space and a
flexible hose/duct connected to it and extending to the point of operation. Hot Work
Permits are required before performing these operations in Confined Spaces. Note:
The LEL during Hot Work shall be and remain at Zero during this type operation.
Specific Requirements
Compressed gas bottles (acetylene, oxygen, argon, nitrogen, air, etc.) must not be
brought into a confined space. Anytime work is suspended, welding leads and
hoses must be removed from the confined space. This is to prevent leakage into the
J3. 13

space, which would compromise the atmosphere, and to reduce the risk of an
explosive release into a small area where its effects would be greatly concentrated.
When painting, welding, burning, applying coatings, or doing anything, which might
generate gases, vapors or fumes, adequate ventilation and respiratory protection
must be used. It should also be noted that coatings may cause a fire hazard.
Pneumatic tools should be used whenever possible to reduce the hazard of electrical
shock and ignition sources. Pneumatic tools may only be operated with air. The use
of nitrogen, oxygen, or other gas is prohibited.
Portable electric tools, lights and equipment operated in areas where there is a
potential for flammable or combustible atmospheres to be present or accumulate
shall be of industrial grade, in good condition and UL listed or FM approved as
Intrinsically Safe or Approved for use in Hazardous (electrically classified) locations.
Portable electric tools, lights and equipment used in Confined Spaces shall be of
industrial grade, in good condition, operated at a maximum of 110 volts AC and
connected to a ground fault circuit interrupter, or be operated at no more than 12
volts DC.
When performing hot-work inside of vessels which contained a flammable or
combustible product, the following steps must be taken with written verification in
addition to all other confined space requirements to ensure vessel is safe for hotwork:
Ensure vessel is properly isolated, locked out and blinded with skillets.
Vessel needs to be cleaned of all hydrocarbons.
Once all hydrocarbons have been removed from the vessel, the vessel needs
to be closed off in preparation for steam cleaning.
A valve should be cracked open to drain liquids produced during the steam
cleaning process.
Steam cleaning equipment needs to be setup and grounded. The purpose of
steaming the vessel is to get the vessel hot enough so the pores of the metal
open up and the potential gases in the metal is released.
The vessel needs to be brought to an inside temperature of 120deg F.
Depending on the size of the vessel, this could take several hours. A
temperature stick or thermal gun will be utilized to verify the internal
temperature has reached 120deg F. The vessel must continue to steam for 2
hours at a temperature of 120deg F.
After steam cleaning has been completed, the equipment needs to be turned
off and removed from the vessel.
The vessel should be opened up and ventilated, then verify LEL with a
portable gas meter by a Confined Space Competent Person.
J3.14

Rescue Services
Emergency notification, response and rescue plans must be made in advance. The
Rescue Plan will be documented on the Pre-Entry Checklist and Hazard Assessment
(See Attachment 1). If special equipment is needed such as, scoop stretches, safety
harnesses, retrieval lines, life lines, self contained breathing equipment, etc., it should
be made ready for immediate use. All rescue equipment shall be inspected by a
competent person prior to each entry. This will be documented on the Pre-Entry
Checklist and Hazard Assessment. If there is a reasonable chance that life
threatening incidents (asphyxiation or severe bleeding) may occur, an onsite rescue
team may be needed.
If the facility / site plans to use an offsite rescue team, facility / site management must
evaluate the capabilities of the response group to assure their response times are
appropriate for the hazards. Agreement with offsite rescue teams should be
documented and updated at least annually.
The rescue team shall be given the opportunity to evaluate the entry site, practice
rescue and decline as appropriate.
The rescue team shall have at least one person with a current First Aid / CPR
certification.
The members of the rescue team shall be provided all training and personal
protective equipment at no cost to them to safely perform a rescue.
Non-Permit Required Confined Spaces
To be classified as a "Non-Permit Required Confined Space" the Confined Space
must not have conditions which are, or could reasonably become, "Immediately
Dangerous to Life or Health" (IDLH). Examples of "Non-Permit Required Spaces"
might include, but not necessarily be limited to:
Pits less than four (4) feet in depth
Heating, ventilating or air conditioning (HVAC) plenums designed to be
entered for servicing
Manholes or large diameter pipe that have very low or no potential for a
hazardous atmosphere to develop.
Non-Permit Required Confined Space work should be conducted as work in regular
work areas. However, personnel should consider if:
There have been changes in the Confined Space since it was determined to
be a "Non-Permit Required Confined Space".
The work planned could cause Confined Space to become "Immediately
Dangerous to Life or Health" (IDLH).

J3. 15

Other work being performed in the area of the "Non-Permit Required Confined
Space" could cause it to become "Immediately Dangerous to Life or Health"
(IDLH).
If any of the above apply, the Non-Permit Required Confined Space should be
treated as a Permit Required Confined Space. If there is any question about the
classification, stop and check with your supervisor.
Pipe Fabrication and Confined Space Classification
The fabrication of pipe or other equipment may create a permit required space at
some point in the fabrication process. If, during the fabrication of equipment, the
confined space becomes difficult to enter or exit or could be subject to a hazardous
environment, the Facility Manager, a Safety, Health, Environmental Department
Representative, Yard Foreman, and the First Line Supervisor will decide if special
precautions and / or a permit is required. If all individuals involved cannot agree, the
space must be classified as Permit Required.
Training
Confined Space Entry training will be performed so that all employees acquire the
understanding, knowledge, and skills necessary for the safe performance of their
assigned duties within the confined space entry process.
Training shall be performed to each affected employee on the following intervals:
Before the employee is first assigned duties under this program;
Before there is a change in assigned duties;
Whenever there is a change in permit space operations that presents a hazard
about which an employee has not previously been trained;
Whenever there is reason to believe either there have been a deviation from
the permit space entry procedures or that there are inadequacies in the
employee's knowledge or use of these procedures.
Training of affected employees shall establish the employee proficiency in their duties
within this program and shall introduce new or revised procedures as necessary.
The employee training shall be certified that the training has been accomplished by
providing the following information within the employees training records:
Employees Name
Signature or initials of the Trainer
Dates of training

J3.16

Certifications shall be available for inspection by employees and their authorized


representatives upon their requests.

J3. 17

Attachment 1

J3.18

Date:

Job Name:

Job Number:

Confined Space Pre-Entry Checklist & Hazard Assessment


The following checklist is to be used to evaluate any confined space prior to an entry attempt. This
checklist will be turned in with all other applicable forms including but not limited to Confined Space
Permit, JSA, Tool Box Safety Forms or Site Safety and Health forms as required. These forms shall
be retained for three (3) years.
Do not enter any confined space until you have determined that acceptable entry conditions exist and
a Moreno Group LLC and Subsidiaries confined space entry permit has been completed. A permit
will be accomplished whether it is a stand-alone permit or a parallel permit with the
customers.
Pre-Job Conference
Yes

No

N/A
Is the entry necessary?
Has the customer informed Moreno Group LLC and Subsidiaries of the
hazards applicable to the Confined Space?
Is there a potential for any of the following conditions to be present?
Oxygen Deficient / Enrichment

Toxic Atmosphere

Flammable or Explosive Atmospheres

Engulfment

Corrosive Atmospheres

Electrical

Reactive (oxygen or water)

Mechanical

Temperature Extremes
Have Material Safety Data Sheets been obtained from the customer?
Has the area been surveyed for external hazards? (i.e., drifting vapors,
nearby hot work, traffic and vehicular movement, potential ignition sources,
etc.)
Have you reviewed with the customer hazards specific to Moreno Group LLC
and Subsidiaries equipment processes?
Lock Out / Tag Out, Binding and Blanking
Yes

No

N/A
Has the space been isolated from all other systems?
Has all electrical equipment been locked out?
Have disconnects been used where possible?
Has mechanical equipment space been blocked, chocked and/or
disengaged?
Have all the lines in the space that are under pressure been blanked or bled?
Has the space been washed, cleaned or rinsed before entry is made?
J3.18.a.1
1

What are the physical characteristics of any remaining contents in the space?
Solids
Gases

Liquids
Vapors

Semi-Solids
Other

Dusts

Sludges

Was the space steamed? If so, was it allowed to cool?

Yes

No

Are there other extreme temperature hazards present? Specify:

Atmospheric Testing
Yes

No

N/A
Is the person conducting the testing trained in the proper use of the testing
equipment?
Are the instruments being used for testing properly calibrated? (manufacturer

or field)
Has the Atmosphere in the Confined Space been tested?
Specify person by name:
Position:
Was the oxygen content at least 19.5% and less than 23.5%?
Were there toxins, flammables, oxygen displacing gases / vapors present?
Will the atmosphere in the space be monitored while work is ongoing?
Specify intervals:
Continuously
Periodically
Note: Atmospheric changes can occur due to the work procedures or the product stored.
The atmosphere may be safe on initial entry, but can change very quickly.
Ventilation:
Yes

No

N/A
Has the space been ventilated prior to entry?
Will ventilation be continuous during entry?
Mechanical
Natural Draft
Is the air intake for the ventilation system located in an area that is free of
combustible dusts, vapors / gases and toxic substances?
If the atmosphere was found unacceptable and then ventilated, was it re-tested
and found acceptable prior to entry?

Personal Protective Clothing / Equipment


Yes

No

N/A
Is specialized clothing required? If so, specify
Level of Protection
A
B
Other

Are special tools required? If so, specify, (i.e., spark proof, explosion proof,
etc.)

J3.18.a.2

Respiratory Protection Requirements


Yes

No

N/A
Is respiratory protection required?
Specify: Manufacturer:

Air Purifying

Supplied Air

SCBA

Cartridge Type:

Can entrants / rescuers get through the opening with an SCBA on? (If you
dont know, find out prior to beginning the job)
Training
Yes

No

N/A
Have all participants been trained / fit tested in the proper use of the respirator
required for entry?
st

Has at least one person on the team been trained and certified in 1 Aid and
CPR?
Have all participants been trained in Confined Space Procedures?
Entry Supervisor / Competent Person
Entrant
Attendant
Attendant / Rescue
Yes

No

N/A
Will there be an attendant on the outside in constant visual or auditory
communications with the entry team on the inside?
Will the attendant be able to hear and see the entrants at all times?
Has the attendant been trained in Emergency Procedures?
Has an Emergency Rescue Action Plan been completed?
Are safety lines and harnesses in place to assist in removing a person?
Are rescue procedures available to be followed in the event of an emergency?
Are all participants familiar with emergency rescue procedures?
Do all participants know who to notify, and how, in the event of an emergency?

Rescue Equipment Inspection


The following checklist shall be conducted by a competent person responsible for emergency retrieval
of personnel onsite prior to use of the equipment on a daily basis while it is on the worksite. This
checklist satisfies the daily inspection and monthly inspection procedures set forth by the
manufacturers recommendations.
Yes

No

N/A
Inspect all screws, bolts, nuts to ensure they are tight and not bent or broken.
Inspect all covers, housings, and guards to ensure free of cracks, dents, or other
damage.
J3.18.a.3

Yes

No

N/A
Inspect crank handle to ensure that it locks positively onto the shaft and be free of
cracks, bends, or any other visible damage.
Inspect connecting hook to ensure there is no damage, breaks, distortion, or have
any sharp edges, burrs,
cracks, worn parts, or corrosion.
Insure the connecting hook works properly. Hook gate must move freely and lock
upon closing. Hook must swivel freely.
Inspect wire rope assembly starting at the hook by bending along the length of the
cable by inspecting closely for cracks, breaks, corrosion, or frayed strands.
Inspect all identification and warning labels ensuring they are legible and securely
attached.
Inspect each system component (support structure, backup fall arrest system, body
support, and connectors.
Inspect the winch locking mechanism, drum, and drum sprocket for damage. The
locking mechanism should move smoothly in and out of the drum sprocket.
Check operation of the winch in high speed and low speed positions. Must crank
up and back down freely.
Inspect the ratchet brake with brake engaged. The drum should be prevented from
releasing cable. The spring must be in place and not damaged.
Inspect for oil in the gearbox by removing plug on top and tilting unit so oil can be
seen through the hole. Then inspect for leaks. Replace with SAE 80 or 90 gear oil if
needed.
Check operation of the handle over the speed brake.

Confined Space Emergency Rescue / Action Plan


The following checklist can be used to establish a rescue plan for each confined space. Modify this
plan as necessary to fit the specific situation. Once completed, the checklist becomes part of the
permanent record and may not be destroyed for three (3) years.
General Information
What are the Confined Space Atmospheric hazards?
What is or was in the Space that makes it hazardous?
Emergency Communications
Identify the method to be used to notify site workers of an emergency situation and evacuation of the
work site (portable air horn, radios, hand signal, etc)

J3.18.a.4

The following standard hand signals will be used in the event audible communications are lost.
Hand Gripping Throat

Out of air / Cant breathe

Grip Partners Wrist or


Both Hands Around Waist

Leave area immediately

Thumbs Up

Im OK, I understand

Thumbs Down

No. Negative

Emergency Procedures (Modify as Necessary)


The Entry Supervisor and/or Project Manager shall be notified of any on-site emergencies and are
responsible for ensuring that the appropriate procedures are followed. In addition, the Customer
Representative and a Moreno Group LLC and Subsidiaries Safety person will be notified of all
accidents, incidents, near misses and/or illnesses that occur at the Customer facility.
Change of Conditions or Unsafe Situation Discovered
The Entry Supervisor and/or Attendant shall:
Order authorized entrants out of the Confined Space
Provide assistance as necessary for removing personnel from the Confined Space (No Entry)
Remove and cancel the Entry Permit
Post the Do Not Enter tag at the entryway
Standby until acceptable entry conditions are re-established and a new permit issued
Notify a Moreno Group LLC and Subsidiaries Safety person

J3.18.a.5

Attachment 2

J3.19

J3.19.a.1

Attachment 3

J3.20

MORENO GROUP LLC AND SUBSIDIARIES

J3.20.a.1

J3.20.a.2

Moreno Group LLC and


Subsidiaries SH&E
Management System

Crane Policy

Page: 1 of 36
Original: 01/01/2001
Revised: 09/01/2009

Crane Policy
Purpose
The purpose of this policy is to establish and set guidelines for the safe use of material
handling equipment related to crane operations per 29 CFR 1910.179, 29 CFR 1910.180
and API RP 2d.
Scope
This procedure applies to all Dynamic employees, non-permanent employees
and sub-contract employees who operate, use, inspect, maintain or work around
cranes.
Responsibilities
The Facility Manager / Yard Manager / Offshore Manager or Designee is
responsible for:
Continually communicated to First Line Supervision the employees right to use
STOP WORK AUTHORITY.
Assuring compliance with this procedure.
Evaluating mobile equipment needs for the facility / site, preparing detailed purchase
/ rental specifications and providing sufficient equipment to support the needs of
Dynamic Industries.
Assuring the equipment is operated and maintained in a safe manner and in
accordance with equipment manufacturers recommendations.
Assuring that equipment operators are properly trained and qualified to operate
specific machines.
Ensuring that no modifications or additions are made to equipment without the
manufacturers written approval.
Ensuring that all work group investigations, significant incidents, property damage
reports, and general information regarding mobile / motorized equipment is
communicated to applicable employees.
Informing all Contractors of this procedure during the project meeting and ensure the
Contractor follows the requirements of this procedure.

J4.1

The First Line Supervisor / Offshore Superintendent is responsible for:


Understanding and enforcing the provisions of this procedure.
STOP WORK anytime any employee is in questioning the lift or lift operation or work
activities around lift operation.
Identify the hazardous area (Red Zone) around operating equipment, and notify all
affected personnel of this area.
Conferring with personnel reporting to them as to the hazards of specific jobs and
the crane to be used.
Assuring that equipment is inspected, operated and maintained in accordance with
this procedure and the manufacturers recommendations.
Assuring that only trained, authorized and physically fit personnel operate and
maintain equipment.
Assisting in the evaluation of operator competency.
The Equipment Operator is responsible for:
Use STOP WORK AUTHORITY anytime the operator is questioning the lift or lift
operation or work activities around lift operation.
Complying with this procedure and operating equipment safely.
Remaining alert and not operating equipment if mentally or physically impaired.
Consulting with the supervisor if taking either over-the-counter or prescription
medication.
Conferring with supervision as to hazards involved or associated with the job.
Surveying the work areas for hazards and erecting barricades as necessary.
Obeying all traffic rules including speed limits, signals and warning signs.
Operating only equipment for which they have been trained.
Reading and being familiar with the manual for the equipment being operated and
operating the equipment as intended by the manufacturer.
Never operating equipment that is unsafe and in need of repair.
Performing and documenting the pre-use / shift inspection.

J4.2

Notifying supervision of any significant incidents, property damage or near misses


with regards to mobile / motorized equipment.
The Signal Person is responsible for: