CONFIDENTIAL

C-3.0 GLOBAL CONSTRUCTION SAFETY POLICY

C-3.1 Introduction
C-3.2 High Risk Activity (HRA) Management

(a) Working from Heights

(b) Electrical
(c) Energy Isolation
(d) Lifting Operations
(e) Mobile Equipment
(f) Material Handling
(g) Confined Space
(h) Ground Disturbance
(i) Hazardous Materials
(j) Driving
(k) Temperature Extremes
(l) Noise

C-3.3 General EHS Plan Management Standards

(a) Access
(b) Barricades
(c) Blades
(d) Construction Laser
(e) Demolition
(f) Ergonomics
(g) Fire Prevention
(h) Housekeeping
(i) Off-Site Pre-Fabrication, Skidding, and Commissioning Services
j) Portable Tools
(k) Powder Actuated Devices
(l) Sanitation

C-3.4 EHS Plan Administration

(a) Safety Culture

(b) Accountability
(c) Incident/Injury Reporting and Investigation
(d) Job Hazard Analysis
(e) Competent (Appointed) Persons
(f) Emergency Planning
(g) Fatigue Management
(h) First Aid and Medical Care
(i) Permits
(j) Personal Protective Equipment (PPE)
(k) Pre-Task Analysis
(l) Safety Inspections and Audits
(m) Safety Meetings
(n) Safety Orientation
(q) Safety Personnel
(r) Safety Management Reports
(s) Subcontractors
(t) Substance Abuse
(u) Training

2020-0227 Global Construction Safety Policy (1.0)

CONFIDENTIAL

(v) Wellness

C-3.1 Introduction. (a) Owner is committed to promoting a safe jobsite, given that unsafe conditions at
the site can jeopardize the health and safety of Owner’s employees, contractors, customers, and guests. Therefore,
Owner’s contractors and their employees, agents, and Subcontractors are expected to adhere to the minimum
standards that comprise this Global Construction Safety Policy. This policy is part of the Master Construction Contract
with Owner and is a resource for contractors to develop and manage jobsite safety while performing work for Owner.
Defined terms used but not defined in this policy are as defined in the Master Construction Contract.

(b) Contractor will develop and manage for each relevant PSR a Project-specific
environmental, health, and safety plan (a “EHS Plan”) that meets or exceeds the standards stated in this policy and
the United States Occupational Safety and Health Act (https://www.osha.gov/law-regs.html) (OSHA) and OSHA
regulations and otherwise complies with applicable laws and regulations, and takes account of applicable guidance
and approved codes of practice (“ACOPs”). The EHS Plan should also include measurable KPIs for environmental,
health and safety aspects which the Contractor is expected to achieve. Any references to OSHA standards should be
used as benchmarks with an expectation that at least an equivalent standard is achieved in any local jurisdictions.

(c) Contractor’s EHS Plan should account for the entirety of the Work, whether performed at
the Site or elsewhere, including third-party locations where prefabrication, skidding, and/or commissioning services
may be performed. Notwithstanding any rights and authority granted to Owner under the Contract or the relevant
PSR, Contractor will be solely responsible for, and have control over, the means, methods, techniques, sequences and
procedures and for coordinating all portions of the Work under the relevant PSR. Contractor is solely responsible for
initiating, maintaining and supervising all safety precautions and programs in connection with the performance of the
Work. If Owner, this policy, and/or the relevant PSR is deemed to have given specific instructions concerning
construction means, methods, techniques, sequences or procedures, Contractor shall evaluate the jobsite safety of the
same and will be fully and solely responsible for the jobsite safety of such means, methods, techniques, sequences or
procedures. Where construction means, methods, techniques, sequences and procedures are specified, either directly
or indirectly, by reference to industry standards, or otherwise, Contractor shall review the specified procedures and, if
they will not produce intended results, cannot be warranted or otherwise are objectionable to Contractor, Contractor
will propose alternative procedures.

(d) Prior to the start of any field work associated with the relevant PSR, Contractor's home
office and key field supervision personnel will meet with Owner’s project leaders to assure the contents of this section
of the Contract are clearly understood, and to show how Contractor's EHS Plan meets or exceeds these minimum
standards.

(e) Contractor must promptly inform its Owner contact (or a member of Owner management)
when any situation develops that causes Contractor to operate in violation of this policy. While Contractor is
expected to self-monitor and demonstrate its compliance with this policy, Owner may audit Contractor and/or inspect
the Site and off-site locations where the Work is performed to confirm compliance.

(f) Owner may update this policy on one or more occasions and in its sole discretion in
accordance with Section C-1.15 of the Master Construction Contract. All changes will be effective upon notice to
Contractor, unless otherwise agreed in writing. Contractor shall promptly notify Owner if Contractor determines that
changes to a policy or procedure will cause a material change to the Schedule, the Contract Price or other costs for
the Work. Upon Owner’s receipt of Contractor’s notice, the parties will discuss how to mitigate the impact of the
change to enable Contractor to comply.

C-3.2 High Risk Activity (HRA) Management. Contractor’s EHS Plan should include a dedicated section
outlining prevention strategies for certain high risk activities (“HRAs”) that increase the likelihood for serious incidents
and fatalities (“SIFs”). Those HRAs include working from heights, electrical, energy isolation, mobile equipment,
material handling, confined spaces, lifting operations, ground disturbance, hazardous materials, traffic management
on site and driving (including driving offsite in connection with the PSR). Other significant exposures include noise

2020-0227 Global Construction Safety Policy (1.0)

CONFIDENTIAL

and temperature extremes. Contractor may choose to add additional categories that have a high SIF potential after
completing a Project-specific risk assessment.

The following topics should be included, at a minimum, in the dedicated HRA section of the Contractor’s EHS
Plan:

- Three levels of risk assessments (project, activity, task).

- Incorporation of HRAs into project schedule.
- Planning meetings – Level 2 planning meetings, look-aheads, daily coordination meetings
(“SIMOPs”)
- Pre-task planning with workers and daily ‘tool box’ talks
- Permits
- Communications and Lessons Learned Sharing
- Orientation, Training and Competency
- Audits and Inspections
- Reporting
- Metrics and Analysis
- Change Management (impacts related to changes in schedule, costs, design, personnel and scope)
- Use of BIM / VDC for HRA Management

Refer to DCX-SPS-100 High Risk Activity Management Safety Performance Specification for more guidance.

(a) Working from Heights.

(1) Aerial Lifts and Boom Trucks. Contractor will comply with OSHA 1926.453 for aerial lifts (such as articulating
boom trucks) and with 1926.452 for powered mobile scaffolds (such as scissor lifts and mobile elevated
working platforms) when operating and inspecting such equipment. In addition, the following minimum
standards apply:

 The manufacturer’s posted capacity of the lift will not be exceeded by the combination of
personnel, tools and material in the lift.
 Any equipment equipped with outriggers will have the outriggers fully extended and set before the
bucket/cage is raised.
 Personnel utilizing aerial lifts, boom trucks, MEWPs, or similar equipment will tie off utilizing
appropriate fall restraint equipment. Tie-offs while performing work inside scissor and aerial lifts
will be used for restraint and not arrest. Traversing a scissor lift while in the elevated position should
be avoided.
 Personnel climbing out of or onto the platform to/from an elevated work location when using an
aerial lift, scissor lift, or boom truck in the elevated position shall be prohibited unless Contractor
can demonstrate alternative means are not feasible. In such cases, Contractor shall utilize
additional fall protection equipment such that the person maintains 100% fall protection tie-off as
soon as their feet leave the platform of the lift. The additional fall protection equipment shall be
anchored to a structure exterior to the lift that meets the OSHA requirement for a fall protection
anchor. In some cases, a double lanyard system will have to be utilized to maintain 100% fall
protection during the transition. A detailed method statement with corresponding risk assessment
will be developed and approved by Contractor’s project and safety managers. Contractor will
ensure all other means of access (including scaffolding and approved lift extensions) have been
reviewed and eliminated for feasibility. Contractor’s decision on means of access will not be made
solely on cost.
 Rigging and lifting from the platform or boom is not permitted.
 Each aerial work platform shall be inspected, maintained, repaired, and kept in proper working
condition in accordance with the manufacturer's manuals. A Competent Person shall perform an
inspection each day prior to use.

2020-0227 Global Construction Safety Policy (1.0)

CONFIDENTIAL

 Each aerial work platform shall be equipped with a fire extinguisher when there is a potential for fire
or while working in proximity to electrical.
 Contractor shall maintain a list of personnel on site, including subcontractors, who have been
properly trained and are authorized to operate aerial lifts and boom trucks.

(2) Fall Prevention. Fall arrest equipment, work positioning equipment, or travel restricting equipment will be
used by employees when exposed to a fall of 6 feet (1.8m) or more, such as at floor and roof openings,
upper floor and roof edges, elevator shafts, and stairwells. Fall arresting systems will consist of a full body
harness with two shock absorbing lanyards, self-locking snap hooks, and adequate anchorage points. 100%
tie-off, with at least one lanyard connected to an anchorage point at all times is required when exposed to a
fall of 6 feet (1.8m) or more.

(A) Before starting any work with a fall exposure, Contractor will have a written fall protection plan. The
written fall protection plan will be written by a Competent Person, address the specific issues on the
project, and include a rescue plan which includes steps in addition to calling local emergency
services. Contractor will provide for each employee who might be expected to perform elevated
work the proper training with written records thereof as described in OSHA 1926.503. Owner may
review these records upon request.

(B) Contractor will ensure that fall protection equipment is inspected prior to each use and not used for
any other purpose other than worker fall protection. The use of controlled decking zones is
prohibited. 100% tie off is required at all times when workers are exposed to a fall hazard of 6 feet
(1.8m) or greater. Warning lines may be used to warn personnel of fall hazards of 6 feet (1.8m) or
greater.

(C) Safety netting and the use of Safety Monitors are not permitted as the sole means of fall protection.

(3) Hole Covers. Any opening in a floor or roof with a minimum dimension of 2 inches (5.1cm) in any direction,
and not otherwise protected by handrail or other guarding system must be mechanically covered by a
temporary hole cover in accordance with OSHA 1926.502(i).

(4) Ladders. Contractor will use reasonable efforts to avoid the use of ladders and promote the ladders last
policy by actively seek out safer alternatives for elevated work tasks. Where step ladders must be used they
will be of the platform design or equivalent. Contractor will maintain a task-specific permit system to assure
the ladders last policy is executed and to assess alternatives when platform ladders cannot be used.
Contractor’s permit system will enlist a means of controlling the use of ladders when not in use.

(A) The use of straight and extension ladders is limited to use for access only and only after alternate
means are proven infeasible. All straight and extension ladders will be equipped with non-slip feet.
All such ladders will be either tied off at the top and bottom (where possible) or held when in use.
No more than one person will use a single ladder at any given time. All ladders will be inspected by
the user before each use. Any ladder found to be defective during any inspection will be removed
from the site or disposed of. Any evidence of oil, grease, or other slippery substance on any ladder
must be immediately remedied. No conductive ladders or job-made ladders will be used.

(B) When a worker working from or using a ladder is exposed to a fall of more than 6 feet (1.8m), a
safety harness must be worn with at least one lanyard attached to a suitable anchorage point. If
there is no anchorage point available, a different means of access to the work is required, such as a
scaffold or aerial lift. Personal fall arrest is required when using straight or fixed ladders for access
to a different level (such as when climbing a scaffold) unless there are other conditions that increase
the fall exposures (such as muddy terrain or awkward transitions). Stepladders must be fully
extended and locked when in use.

2020-0227 Global Construction Safety Policy (1.0)

CONFIDENTIAL

(C) Workers will not carry tools, materials or other items in their hands while climbing a ladder. Any
material or tools needed that cannot be carried on a belt must be hoisted by rope or passed to the
person by an assistant.

(5) Scaffolding. Contractor must comply with OSHA 1926 Subpart L for the erection, use, inspection and
maintenance of all scaffolds. Scaffolds will be erected, moved, dismantled, or altered only by trained
personnel under the supervision of a Competent Person. The Competent Person will inspect all scaffolds for
structural integrity and deficiencies prior to each shift's use. The inspection will be documented in writing on
a tag hung from the scaffold. The tag will indicate whether the scaffold is approved for use. Scaffolding that
is incomplete or otherwise not suitable for use will have a red tag displayed on the scaffold indicating that it
is out of service. Multi level scaffolds shall incorporate a stair design, in lieu of, an external straight ladder for
access to various levels unless it can be demonstrated to be infeasible. In such cases, a fall arrest system will
be designed and utilized for personnel using the access ladder.

(6) Steel Erection. Steel erection will be primarily accomplished from aerial lifts. Climbing of columns is
prohibited. Steel erection personnel will maintain 100% tie-off at all times in areas that have fall exposures
of 6 feet (1.8m) or greater. Traversing horizontal beams is permitted so long as proper tie-off is maintained
using such devices as rolling beam clamps. Safety netting is not permitted as the sole means of fall
protection.

(7) Dropped Object Prevention Plan. Contractor must develop a plan that outlines protection measures that
prevent struck-by incidents to personnel below any elevated work. The plan must include both prevention
and protection control measures. Use of prevention strategies (e.g. tool tethering, protection screens, etc.)
shall be prioritized over protection measures (e.g. use of a controlled access zone and/or spotter.)

Refer to DCX-SPS-105 Working from Heights for additional requirements.

(b) Electrical.

(1) Ground Fault / Residual Leakage Current Protection. Contractor will provide ground fault circuit interrupter
(GFCI/RCD) protection for all cord sets, receptacles and electrical tools and equipment connected by cord
and plug which are used or available for use by employees. All GFCI/RCD receptacles will be placed at the
source end of the electrical service and tested prior to each use. Contractor must maintain a documented
inspection program that is completed by a competent person.

(2) Energization or Re-energization. When initially energizing electrical equipment or systems, or re-energizing
systems that have been modified, Contractor must have a written plan in place that addresses the integrity
of the equipment/system being energized and the protection of personnel involved.

(3) Temporary Power and Lighting. Contractor will provide all temporary power necessary for office trailers,
welding machines, mall tools, etc. Except for welding machines, temporary power distribution will be limited
to 120 volts. Contractor will ensure sufficient levels of illumination exist inside buildings and outside with
emphasis placed on hazardous tasks and walking paths. Temporary lighting stringers will be hard usage
cord construction with lamp covers. Outdoor temporary lighting will be protected by ground fault current
interrupters (GFCI's/RCDs). Temporary power must be protected by hard barricades to prevent damage from
vehicle traffic.

Refer to DCX-SPS-102 Electrical for additional requirements.

(c) Energy Isolation. Contractor will prepare a written energy isolation plan in accordance
with DCX-SPS-101 Energy Isolation, and notify Owner whenever Contractor deems it necessary to work on equipment
or systems that are energized or pressurized, or may become energized or pressurized during such work. The plan
must state that every worker is protected by his/her own lock. In the case of complex lockouts with multiple lockout
points, a lockout box may be used and managed by the supervisor, where a single key may be placed in a lockbox.

2020-0227 Global Construction Safety Policy (1.0)

CONFIDENTIAL

The workers then place their individual locks on the lockbox. Contractor will periodically audit lockouts in progress to
assure the integrity of the lock and tag process. Contractor will forward to Owner the findings of such audits. Workers
are not permitted to work on any electrically energized component.

Refer to DCX-SPS-101 Energy Isolation for additional requirements.

(d) Lifting Operations

(1) Cranes. Crane operator qualification (per ANSI B-30.5) must be certified by the National Commission for the
Certification of Crane Operators (NCCCO certification) or international equivalent and furnished to Owner
prior to any crane work. This includes any crane work to be done by subcontractors.

(A) A lift plan and HRA planning meeting are required for all lifts. The lift plan and associated planning
meeting can cover multiple lifts within the same operation. The lift plan must clearly outline the
scope of work to be completed. Contractor will review changes to the plan to ensure no adverse
risks emerge and go unmitigated.

(B) A critical lift plan and permit are required if the lift operation could cause significant work delay or
property damage, exceed 75% of crane's rated capacity, require more than one piece of equipment,
lifts over sensitive equipment, hoist personnel, or cause the crane boom or load to come within 15
feet (4.6m) of energized overhead lines. Contractor shall provide Owner with a copy of the permit
before any critical lift commences.

(C) Contractor will not lift a suspended load over personnel, occupied buildings, processes, or electrical
conductors.

(2) Rigging and Hoisting. Contractor will ensure that only competent employees are used for rigging tasks and
maintain documentation of qualifications at the site.

(A) Rigging from the bucket or booms of mobile equipment (including backhoes, front-end loaders,
etc.) to pick and/or carry loads is prohibited unless a properly installed and tested lifting eye or lug
has been attached to the bucket or boom by the manufacturer. Lifting capacities and configurations
will be in accordance with the manufacturer's operating manual. All operators must be trained by
the manufacturer or vendor regarding the specific use of equipment. Rigging from the tines of fork
trucks is prohibited.

(B) All lifts using rigging are required to have a lift plan, regardless of whether mobile equipment or
cranes are used to perform the lift.

(C) All hoisting shall use a qualified signal person to coordinate actions with the operator of hoisting
equipment. The signal person must be in constant communication with the operator; able to track
the load at all times, and, if using hand signals only, must be in full view of the operator.
Contractor’s lift plan must address communication protocols and positive acknowledgement by
operators of signals from the signal person when radio communications are used. All loads shall
have a tag line(s) attached for control. Controlling loads by hand is not permitted. Workers must
always stay clear of the potential impact area should a load fall. Cranes, hoists and heavy
equipment will be kept at least 15 feet (4.6m) from all overhead power lines. Where voltage exceeds
200 KVA, distance shall be increased as follows:

KVA Feet
201 – 300 19
301 – 400 22
401 – 500 25
501 – 700 32

2020-0227 Global Construction Safety Policy (1.0)

CONFIDENTIAL

701 – 1000 42
Over 1000 50

(D) Contractor will establish an exclusion zone to protect personnel in the swing radius and the full
length of the boom. No workers are allowed under a suspended load.

Refer to DCX-SPS-106 Lifting Operations for additional requirements.

(e) Mobile Equipment. No worker will operate mobile equipment unless he/she has been
trained and demonstrated his/her competency. Documentation of this training must be retained at the project site
and available for audits upon request. Contractor must accompany all equipment with the manufacturer's operating
instructions. Contractor shall ensure all mobile equipment is in safe working order. A daily inspection, at the
beginning of the shift, will be made by the operator of such equipment, and findings will be documented in an
appropriate inspection log. The log will be kept with the equipment and be available to Owner upon request. All
mobile construction equipment will be equipped with audible backup alarms or, in the absence of such, a qualified
flag person will be used whenever the vehicle or piece of equipment is being operated or backing up in a congested
area. Tractors, backhoes, and end-loaders will be equipped with rollover protection and seat belts. Seat belts will be
used whenever the equipment is in operation. Equipment attachments must be engineered and approved by
manufacturer of the equipment prior to use.

(1) Contractor will not allow the use of cell phones or tablets by operators or workers in proximity to mobile
equipment in use.

(2) Contractor will designate a location for routine maintenance and repair of equipment. Contractor will use
barricades when it is not feasible to relocate equipment to the designated area. A pre-task plan should be
developed with all maintenance and/or repair workers.

(3) Contractor will enforce a policy against leaving mobile equipment engines running while the cab is
unoccupied. Mobile equipment left unattended shall be left in a state to prohibit any unintended movement
by ensuring that all attachments are lowered and all locks, levels, or brakes are set to prevent any
unintentional movement.

Refer to DCX-SPS-107 Mobile Equipment for additional requirements.

(f) Material Handling.

(1) Site Logistics Safety Plan. Part of Contractor’s EHS Plan must address logistical risks associated with material
handling and storage, mobile equipment movement, lifting operations, personnel and vehicle movement,
designated parking areas, location of overhead power lines, major delivery routes, emergency vehicle access,
and emergency shelters or assembly locations. Contractor will establish personnel walkways and provide a
hard barricade separating mobile equipment and vehicles from common pedestrian pathways.

(2) Manual Material Handling. Where manual material handling is performed, Contractor will enforce a forty-
pound maximum manual lift limit per worker in order to encourage personnel to utilize material handling
equipment such as dollies, forklifts, pallet jacks, rolling carts, etc. In an operating facility or other enclosed
spaces, no single person shall transport material (pipe, conduit, wood, etc.) that is longer than 10 ft (3m).

(3) Material Handling Plans. A Material Handling Plan is required when equipment or materials are being
offloaded and/or transported throughout a building or Site. The plan shall, at a minimum include:

a. Assignment of a primary, qualified, move manager responsible for the task.

b. A review of equipment specifications and visual markings of loads to indicate weight, center of gravity,
recommended material handling equipment to be used to move materials/equipment.
c. Means to secure loads to material handling equipment.

2020-0227 Global Construction Safety Policy (1.0)

CONFIDENTIAL

d. Competencies of workers assigned to perform material handling tasks.

e. A review of the planned route to ensure possible hazards to personnel are identified.
f. Schedule of concurrent activities to eliminate conflicting or overlapping tasks.
g. Emergency procedures.

Refer to DCX-SPS-110 Material Handling for additional requirements.

(g) Confined Space. "Confined space" means any area large enough for a worker to enter
and perform tasks, yet has limited means of access and egress, and is not intended for continuous worker occupancy.
All confined spaces are considered "Permit Required Confined Space." Contractor will comply with the requirements
of OSHA 1926 Subpart AA, Permit Required Confined Spaces, for work activities inside confined spaces. Contractor
will notify the Owner Project Manager or designee 24 hours in advance of any planned confined space work, and a
copy of the closed out permit will be forwarded to Owner’s Project Manager or designee at the completion of the
work. The permit will be posted at the work location and protected from weather that could cause damage to the
permit for the duration of the task. Contractor will notify Owner’s Project Manager or designee of any unexpected
hazards encountered during entry operations.

Refer to DCX-SPS-108 Confined Space for additional requirements.

(h) Ground Disturbance. All excavations must meet the requirements of OSHA 1926,
Subpart P. Contractor is not permitted to handle any known or suspected contaminated soil except to the extent
permitted under the relevant PSR.

 All spoils, debris and equipment are to stay a minimum of 2 feet (0.6m) from the edge of
excavations,
 All excavations/trenches 4 feet (1.2m) or more in depth must be properly shored, benched or
sloped as determined by soil type and the competent person.
 All excavations/trenches 4 feet (1.2m) or more in depth must be properly barricaded with rigid
barricades a minimum of 2 feet (0.6m) from edge, or warning barricades a minimum of 6 feet (1.8m)
from the edge.
 All excavations/trenches require proper means of access and egress such that no worker is ever
more than 25 feet (7.6m) from an exit point. Designated egress points shall be designed to reduce
the likelihood of a slip, trip, or fall incident in all weather conditions.

(1) Inspection of excavations, the adjacent areas, and protective systems will be made by a Competent Person
on a daily basis, or when environmental conditions change, for evidence of any situation that could result in
cave-ins, failure of protective systems, hazardous atmospheres, or other unusual conditions. All excavations
require a permit. If it becomes necessary for workers to enter any excavation, regardless of depth, the
atmosphere in the excavation must be taken into consideration and be evaluated by safety personnel or the
competent person prior to anyone entering the excavation.

(2) Contractor is responsible to locate utilities and any underground services prior to digging. Contractor will
use multiple means to locate services including contacting local utilities to identify existing underground
services. Any such services must be exposed by hand digging before using mechanical excavators.
Additional means may include, but are not limited to, hydro-excavation, ground penetrating radar, drawing
and BIM reviews. The requirement for utility locates extends to at least 50 feet (15.25m) outside of the
project perimeter/footprint or when the task falls within the Work.

(3) Contractor is responsible to locate utilities and services prior to performing any core drilling activities. All
activities shall be coordinated with site project management to ensure site protocols are adhered to, prevent
a utility strike, or interrupt services. All coring activities require a ground disturbance permit.

2020-0227 Global Construction Safety Policy (1.0)

CONFIDENTIAL

(4) Blasting. A detailed justification for blasting activities shall be presented to the client to validate why
traditional methods are not suitable. Only licensed contractors and operatives shall be engaged in blasting
activities along with all specific local legislative permissions and permits and in compliance with OSHA
1926.900 (Subpart U Blasting and the Use of Explosives)

Contractor will ensure a qualified and experienced Blaster in Charge (BIC), who has overall responsibility
for all aspects of the blasting operations, is assigned. No explosive materials shall be stored on site
overnight. A detailed blasting plan shall be developed for all blasting works by suitably qualified persons.
Blasting plans and procedures must incorporate all reasonable measures necessary to eliminate negative
impacts on persons, property, and the environment.

The blasting plan shall include at a minimum, but not limited to:

 explosive material security and storage facilities,

 explosive material quantity minimization,
 explosive type and associated hazard controls,
 blast energy levels, blast radii,
 affected persons safe zones,
 exclusion zone security,
 warning signs and audible safety signals pre and post blast,
 flying debris control measures,
 vibration and noise monitoring,
 pre-blasting dilapidation report of potentially affected structures,
 post blast inspection procedures and communication,
 emergency and failed blast procedures, and explosive material disposal.

Refer to DCX-SPS-103 Ground Disturbance for additional requirements.

(i) Hazardous Materials.

(1) Hazard Communication/Safety Data Sheets (SDS). Contractor and all Subcontractors will submit for Owner's
review and acceptance Safety Data Sheets (SDS) for all chemicals which will be used at the Site. Contractor is
responsible for complying with Federal Hazard Communication Standard (OSHA 29 CFR 1910.1200), and all
applicable state and local hazard communication requirements, which includes:

 Developing and implementing a written hazard communication program for the site and providing
copies to Owner upon request
 Maintaining a list of all hazardous materials present in the workplace and posting it in a place
accessible to all employees. Safety Data Sheets must be on file for each material.
 Training its employees in handling and protection from all hazardous materials
 Providing Owner the quantity of each hazardous material brought on site
 Labeling of chemicals with appropriate name, hazard, and warnings
 Providing copies of the list of hazardous materials and the safety data sheets to state and local
officials as required

Contractor will take effective and responsible steps to contain, control, and clean up all spills. Contractor will
immediately notify Owner of any chemical spill, including fuels and lubricants, and will notify appropriate
regulatory agencies of any spill exceeding regulatory thresholds. All drums, containers, chemicals, and wastes
generated by the contractor are the property and responsibility of Contractor. Chemical wastes will be
secured daily and removed from the property at the conclusion of the Work. Contractor is responsible for

2020-0227 Global Construction Safety Policy (1.0)

CONFIDENTIAL

disposing of waste in accordance with all regulatory guidelines. Contractor will not discharge any
construction materials or chemicals, including service water, into local waterways or drains.

(2) Health Hazard Evaluation (HHE). Contractor shall complete and include as part of the EHS Plan a summary
of the HHE. The summary of the HHE should identify all major health hazard issues including the following:

 Monitoring requirements
 Equipment required for monitoring
 Analysis of any monitoring results
 Reporting and distribution of results

(3) Liquid Storage. Only approved containers and portable tanks will be used for storage and handling of
flammable and combustible liquids. Approved safety cans shall be used for the handling of flammable
liquids in quantities of 5 gallons (0.67ft3) or less. All containers must be properly capped when not in use.
Flammable or combustible liquids shall not be stored in areas used for exits, stairways, or normally used for
the safe passage of people. All aerosols should be stored in a closed metal cabinet, separated from other
flammable liquids.

(4) Respiratory Equipment. During spray painting operations where a hazardous warning is posted on the paint
can label and controls are inadequate to prevent harmful exposure, Contractor will provide and require its
employees to use respirators approved for spray painting operations, and will comply with OSHA Standard
1910.134. Similar protection is required for the use or handling of any airborne agent identified as an
inhalation hazard in the SDS.

Refer to DCX-SPS-109 Hazardous Materials for additional requirements.

(j) Driving.

(1) Vehicles. Contractor will post speed limit signs at appropriate locations at the Site. Speed limits must be
approved in advance by Owner. Riding on equipment or in the back of pickup trucks is not permitted. Use
of seat belts is required. Vehicles must not be left unattended unless the engine is turned off, transmission is
in park or low gear, and the parking brake is set to prevent unintentional movement. Contractor will
maintain a reverse parking policy in all designated parking areas. Contractor will maintain a vehicle policy
that controls unnecessary vehicle traffic inside the construction area and precludes the use of cellular phones
while driving on the Site.

(2) Off-Road Vehicles (ORVs). Off-road vehicles (“ORVs”) must be made readily visible and equipped with
seatbelts, headlights, a horn, and back up alarm. Contractor will assure that workers using ORVs receive
adequate training for operation on the project construction site. ORVs include ATVs, utility vehicles, golf
carts, and mini-trucks.

(3) Public Protection Plan. Contractor will develop a written plan outlining the means and methods that will be
taken to protect the general public while on or in the immediate vicinity of the Site. The EHS Plan will
address appropriate roadway signage and be coordinated with local transportation authorities. Vehicles
exiting the Site will utilize a truck wheel wash (or equivalent) to prevent mud and construction debris from
being exported to the public streets adjacent to the project. All dump trucks exiting the Site will cover loads
of loose dirt or gravel.

(4) Onsite Traffic Management Plan. In addition to paragraph C-3.2(e)(2) above, Contractor will develop a
written plan outlining the means and methods that will be taken to protect employees, contractors, sub-
contractors and visitors from the risks of vehicle movements across the site. This will consider an
appropriate means of vehicle / pedestrian segregation which, for example, could include temporary barriers
or the use of proximity alert technology.

2020-0227 Global Construction Safety Policy (1.0)

CONFIDENTIAL

Refer to DCX-SPS-104 Driving and Off-Road Vehicles for additional requirements.

(k) Temperature Extremes. Contractor shall develop written programs to address the
hazards associated with heat and cold stress. Programs must include the following elements at a minimum:
 Temperature, humidity, and respective index measurements throughout the Site at high risk locations.
 Worker education on the symptoms and prevention of heat and cold stress related illnesses.
 Cool down and warm up shelters located throughout the Site.
 Signage and visual indicators of corresponding risk levels to inform workers.
 Work/rest cycles based on type of work and temperature extreme measurements.
 Availability of drinking water.
 Emergency procedures.

Refer to DCX-SPS-111 Temperature Extremes for additional requirements.

(l) Noise. Refer to DCX-SPS-112 Noise for requirements.

C-3.3 General EHS Plan Management Standards. (a) Access. Contractor will fence and control access to
the Site. Only those persons and vehicles with proper authorization will be allowed to enter the site. Proper PPE is
required for all people entering construction zones, and signage will be prominently displayed at all access points
stating PPE requirements. Signage will also indicate that no weapons, alcohol, or illegal drugs will be permitted on the
site. Cameras may be allowed with written permission from Owner. People entering the Site should be classified as
permanent, phased-support, short-term, transient, or a visitor. Contractor shall address how the hazards associated
with the classification and scope of these people will be proactively managed to ensure risks are mitigated.

(b) Barricade. Contractor will furnish, erect, maintain, and dismantle safety barricades
required for their work, and coordinate all barricades belonging to any subcontractors. Each barricade will be tagged
to identify owner, purpose, date erected, and date to be dismantled. Red barricade tape shall indicate "Danger – Do
Not Enter", and no one will be permitted to enter without verbal permission from the barricade owner at the moment
of entry. Yellow barricade tape will be used as a warning to alert personnel to unusual work or conditions inside the
barricade, and entry is permitted once the entrant has read the “Caution” tag indicating the purpose of the barricade.
All barricades using tape as an exclusion zone must be positively maintained. Where conditions exist where tape is
difficult to maintain, such as weather or frequency of access, Contractor will provide a more rigid barricade or
additional mitigation. Red tape barricades are required:

 Around all work areas requiring respiratory protection

 Around swing radius areas for lifting of materials or equipment using mobile equipment or cranes
 To define areas of overhead work
 Around excavations or floor/roof openings greater than 4ft (1.2m) in depth, if at least 6 feet (1.8m)
from the edge
 Around any area where energized electrical components are exposed

Where rigid barricades are required, they must be capable of withstanding lateral forces (downward and outward) of
200 pounds (90.7kg) or greater. They will consist of a top rail and a mid-rail meeting the OSHA definition of "standard
railing" (OSHA Section 1926.502(b). Protective rigid barricades are required around the following:

 Excavations, if less than 6 feet (1.8m) from the edge

 Around floor and roof openings, unless secure hole covers are in place
At upper floor and roof edges, unless there is a warning barricade at least 6 feet (1.8m) from the
edge.

(c) Blades. Contractor will establish a blade safety program that controls the use of blades
without automatic safety guard protection and that actively educates workers and promotes the use of leading
industry cutting tools. Non self-retracting box cutters are prohibited.

2020-0227 Global Construction Safety Policy (1.0)

CONFIDENTIAL

(d) Construction Laser. Only qualified and trained workers will install, adjust, and/or operate
laser equipment. Each operator must carry evidence of his/her qualification at all times. Contractor shall ensure that
all personnel exposed to direct or reflected laser light greater than 0.005 watts (5 milliwatts) shall be provided
antilaser eye protection devices as specified in 1926.54 (E). Area in which lasers are used shall be posted with standard
laser warning placards. Beam shutter caps shall be utilized, or the laser turned off, when laser transmission is not
actually required. When the laser is left unattended for a substantial period of time such as during lunch hour,
overnight, or at change of shifts, the laser should be turned off. The laser beam must not be directed at employees.
When it is raining or snowing, or when there is dust or fog in the air, the operation of laser systems will be prohibited;
in any event, employees should be kept out of range of the area of source and target during such weather conditions.

(e) Demolition. Before permitting workers to start any demolition of existing structures,
Contractor must develop a demolition plan and assure that a Competent Person has conducted an engineering
survey of the exact scope of work and the method to safely execute it. The engineering survey must be documented
in writing and provided to Owner at least 5 working days prior to initiation of demolition activities. The survey must
include details on methods of removal, integrity of the structure (including surrounding structures that may be
affected), energy isolation, risk assessment, and provisions to safeguard all personnel from the hazards associated
with demolition activities.

(f) Ergonomics. Contractor shall implement an industrial ergonomic program that includes
(but not limited to):
 Morning and periodic stretching (“stretch and flex”)
 Ergonomic evaluations of planned work
 Prevention strategies
 Use of tools and equipment that reduce repetitive motion, awkward body position,
and compression injuries.

(g) Fire Prevention.

(1) Burning, Welding, Cutting, Grinding, and Heat Treating. Any work that produces a spark or flame capable of
initiating a fire or explosion will be considered “Hot Work” and will be done according to OSHA 1926
Subpart F- Fire Protection and Prevention. One ABC non-expired portable fire extinguisher will be kept at
each location where the work is to be performed, and one non-expired portable fire extinguisher will be
attached to or readily accessible for all portable welding machines and burning carts.

(A) Hot work performed in or on an enclosed building or in proximity to fuel storage areas will require
a hot work permit issued by Contractor. An ABC fire extinguisher (rated no less than 10B) should be
available within 20ft (6.1m) and a designated fire watch must be present during the hot work
activity. Prior to commencing with the activity, the fire watch will ensure that all combustibles have
either been cleared from the area or have been protection from sparks. For two hours after the hot
work activity is complete, the fire watch will monitor the area to ensure no smoldering, smoke, or
other indications of fire are present.

(B) Compressed gas cylinders shall be properly secured at all times and brought into buildings only as
needed and removed as soon as work is completed daily or as tanks are emptied. Unless individual
cylinders are equipped with regulating devices, they will have the safety cap secured in place.
Cylinders should have a three-part identification tag attached to all cylinders. Oxygen and fuel gas
cylinders, when not in use, must be stored 20 feet (6.1m) apart or separated by a 5ft (1.5m) fire
resistant barrier. All oxy-fuel burning or welding units will be equipped with one combination
check valve flashback arrester installed between the regulator and the hoses, and a second arrestor
between the hoses and torch.

(C) Contractor must develop an independent method statement with corresponding risk assessment
for all roofing operations, including the use of tar kettles. Tar kettles must remain on the ground
level and always attended. Tar kettles will not be lifted or transported while a fire potential exists.

2020-0227 Global Construction Safety Policy (1.0)

CONFIDENTIAL

(2) Fire Extinguishers. Contractor shall furnish a sufficient number of non-expired fire extinguishers to protect its
work area. Extinguishers will be the correct size and type and located, maintained, and inspected according
to NFPA 10. Contractor must provide separate extinguishers for hot work tasks and not rely only on those
provided for the facility. Workers will be trained on the use of fire extinguishers.

(3) Smoking. Smoking and the use of smokeless tobacco, including the use of e-cigarettes, is not permitted
inside any buildings, temporary trailers, or near flammable liquid storage areas and is allowed only in
designated areas clearly marked with an approved cigarette butt container capable of self-extinguishing.

(h) Housekeeping. During the course of construction, all debris must be kept cleared from the
work area, passageways, stairs, and in/around buildings or other structures. Contractor shall provide adequate waste
receptacles, continuous cleanup of its work areas, and remove daily all scrap and waste materials that accumulate
from its operations. All cables, cords, leads, and hoses in a building shall be strung by nonconductive means at least 7
feet (2.1m) overhead, kept to the perimeter of the building, or otherwise protected to prevent tripping hazards.
Contractor will be responsible for removing snow and ice from its work, office, storage areas, and other construction
facilities in its use, and walkways between these areas. When weather conditions are favorable for the presence of
snow or ice, walkway traction shall be enhanced with salt or sand. Impalement protection should be provided for both
horizontal and vertical exposures. Protection should be provided on rebar where there are hazards associated with
laceration and related injuries in addition to impalement.

(i) Off-Site Pre-Fabrication, Skidding, and Commissioning Services. A portion of Contractor’s

EHS Plan should address work that will be performed at off-site locations for the purposes of pre-fabrication,
skidding, modular construction, and commissioning services, etc. The EHS Plan should clearly set expectations that
align with Owner’s culture and vision for safety and include focus around HRAs. Contractor will provide oversight and
perform periodic safety inspections at all off-site locations.

(j) Portable Tools. All portable electrical tools and portable lifting equipment (chain falls,
come-alongs) on site will be inspected by Contractor prior to use and on a quarterly basis. All tools remaining on site
after shift end shall be secured/locked up.

(k) Powder Actuated Devices. Powder actuated devices are not permitted at the Site without
written permission from Owner.

(l) Sanitation. Contractor will provide a designated lunch area away from the main
construction area. Lunch area shall be kept clean and protected from weather exposures. Personnel shall be
furnished with seating, tables, and a sanitary area to prepare and store lunches. Contractor shall ensure some form of
access to food is provided on site for workers to opt to purchase (e.g., food truck). If contractor is offering food for
workers in a camp or dormitory housing arrangement where the provided food is the only option for workers to eat,
then contractor shall accommodate religious dietary preferences. Contractor shall provide hand washing stations and
trash receptacles for the collection of rubbish. Contractor must provide ready access to clean toilet facilities at all
times. Mobile restroom facilities, inclusive of handwashing and hot water must be provided within 45 days of site
mobilization. Individual portable toilet rentals with handwashing stations may be used prior to 45 days. Contractor
must assure potable water is provided to all personnel. Water coolers used to dispense potable water shall be
maintained clean and sealed with tape to maintain sanitation. Paper drinking cups must be provided. Worker
dormitories, if provided, must provide sanitary toilet facilities, sanitary showers, potable water, sanitary food
preparation/storage areas, clean eating facilities. Dormitory sleeping area and other worker accommodations must be
maintained in a clean and safe manner and supplier is responsible for assuring regular cleaning accounts for work
force schedules and volume of personnel.

C-3.4 Administration. (a) Safety Culture. Contractor shall develop a documented strategy as part of their
site specific EHS Plan that promotes the owner’s vision for fostering a positive safety culture and inclusive
environment. Elements of the plan must address means for encouraging safe behaviors, intervention for unsafe
conditions or behaviors, recognition programs, safety campaigns, mental health wellness, and worker welfare. The

2020-0227 Global Construction Safety Policy (1.0)

CONFIDENTIAL

strategy shall also recognize cultural differences and backgrounds, taking into account language, culture of origin,
migrant workforce, and religious beliefs.

(b) Accountability. Contractor shall assure direct line supervision is held accountable for safety
performance of their personnel. The role of Contractor’s safety professional is to support and provide
technical guidance to the line.

(c) Incident/Injury Reporting and Investigation. Contractor shall immediately notify Owner by
phone of any injury to personnel or any potentially serious on-site incidents, which may include unsafe conditions,
near misses, property damage, or environmental incidents. Contractor shall submit a preliminary written report to
Owner within 12 hours of the incident. Contractor will follow requirements outlined in SAFE-001, EHS Serious Incident
Management Standard. Contractor shall notify Owner within 8hrs of any OSHA Recordable injury and shall investigate
within 3 working days of the incident. Contractor shall submit a formal written report, including root cause(s) and
corrective action, within 7 working days of the incident. Any corrective action not completed within the 7- day period
shall require a follow-up report within 30 days of the incident indicating all corrections have been implemented.

(d) Job Hazard Analysis (JHA). None of Contractor’s workers will perform tasks he/she is not
fully trained to perform. Contractor will analyze every non-routine task prior to initiation of the work and assess the
related hazards to develop protective measures. The analysis must be written and thoroughly discussed with
personnel assigned to conduct the work before the task begins. As work on the task continues on subsequent days,
appropriate parts of the JHA will be reviewed as part of the daily pre-task analysis. Contractor may use its own form
for the analysis. The following work categories will always be considered for inclusion in a JHA. This list is not all
inclusive, but is intended to provide examples of the type of tasks needing hazard analysis:

 Biological hazards
 Chemical exposure
 Confined space entry
 Crane operations
 Electrical hazards.
 Elevated work 6 feet (1.8m) or more
 Excavations over 4 feet (1.2m) deep
 Energy Isolation
 Excessive noise
 Fire or explosion potential
 Ground disturbance
 Hot work
 Maintenance and repair
 Manual lifting of heavy or awkward objects
 Material handling
 Material Storage on site in excessive quantities and inappropriate locations
 Rigging and transportation of equipment and materials
 Oxygen deficiency.
 Temperature extremes.
 Vehicle / pedestrian segregation.

(e) Competent (Appointed) Persons. Contractor will provide and ensure all Subcontractors
provide a "Competent Person", as defined by OSHA, for all work requiring such competency by OSHA standards and
for every HRA. The Competent Person for each component of the Work will be identified in the Contractor's EHS
Plan and updated throughout the course of the Project.

(f) Emergency Planning. Contractor’s EHS Plan must include a Project-specific emergency
action plan for emergencies such as extreme weather, medical, power failures, major fires, civil unrest, etc. The EHS
Plan shall include, as a minimum, a means of notifying and accounting for all personnel on site, assembly points, and
a list of phone numbers for key site leaders and Owner, and a communication plan. The phone list must be updated

2020-0227 Global Construction Safety Policy (1.0)

CONFIDENTIAL

any time new vendors or Subcontractors arrive on site. The emergency plan must be reviewed by site personnel upon
arrival at the project site, every three months, and after any emergency event. Table top drills will be conducted at
least every six months. As part of the emergency planning, Contractor must also develop and maintain a Project-
specific crisis management plan which outlines details in the event of major catastrophes or fatalities.

(g) Fatigue Management. A fatigue management plan will be developed to protect workers
from the effects of working excessive hours (no more than 10 hours in a single day (8hours for night/third shift) and
60 hours in a week unless authorized by the Owner. The plan should consider factors such as environmental
conditions, level of risk associated with job task, fit for duty of workers, acclimation of workers to the site, potential
emergency response situations, and commute times.

(h) First Aid and Medical Care. Contractor is responsible for ensuring that first-aid and medical
treatment is administered for workers in the event of injury. Contractor must keep at least one person qualified in
administering first aid treatment and CPR on site during all working hours. The qualified person must also be trained
in Blood-borne Pathogens and familiar with Contractor's exposure control plan. Every work location must have a first-
aid kit and a written emergency plan for handling injuries. The plan will include, at a minimum, the name, telephone
number, address, and driving directions for the medical facility designated to handle emergencies for that work
location. Contractor will maintain an injury log for the duration of the work showing all OSHA recordable, lost time,
and first-aid injuries. The log will be available to Owner on request. Contractor will develop a case management plan
which will include an assessment for the need of onsite medical care staff and clinic, a copy of which plan will be
submitted to Owner prior to the commencement of the Work.

(i) Permits. Contractor's EHA Plan shall include procedures requiring written safety permits
for the following work:

 Hot work (burning and welding)

 Confined space
 Ground disturbance
 Critical lifts
 Energized electrical work
 Elevated work
 Ladders
 Energy Isolation

None of the above work will commence without a properly filled out permit, authorized by Contractor's job
supervisor. The supervisor must review with the appropriate personnel and/or crew the details of every permit to
ensure safe completion of the work. All permits must be on file in Contractor's safety office and made available to
Owner upon request.

(j) Personal Protective Equipment. Workers must wear the following minimum PPE while in
construction zones:

 Hard hats (conforming to ANSI Z89.1)

 High visibility reflective vests, shirt or jacket (meeting or exceeding ANSI Class II, Class III for
roadways),
 Task-specific gloves (except when the use of gloves will not allow the required level of dexterity
such as when operating mobile equipment or peeling tape; or when gloves might increase the risk
of personal injury (e.g. during the operation of rotating equipment).
 Hard-toe work boots (footwear must cover the ankle and conform to ASTM F-2412, “Standard Test
Methods for Foot Protection”, and ASTM F-2413, “Standard Specification for Performance
Requirements for Protective Footwear)
 Safety glasses, including all components i.e., frames, lenses, and side shields (ref. ANSI Z87.1),
 Long pants (no sweatpants or pants with holes or frays), and

2020-0227 Global Construction Safety Policy (1.0)

CONFIDENTIAL

 Shirts with at least 4 inch (10.1cm) sleeves

Welders must wear ANSI recommended welder's helmets. Hearing protection will be required where noise levels
exceed 85 dBA. If Contractor's Work causes noise levels which exceed 85 dBA, Contractor must post warning
barricades at the limits of the high noise zone. If the 85 dBA threshold is inconsistent with local regulations, the more
stringent guideline shall apply. Face shields shall be worn when chipping, grinding, and drilling in addition to safety
glasses. Welders and those using cutting torches shall wear ANSI recommended goggles. Contractors performing
work that may be exposed to an electrical flash shall wear appropriate Flame Retardant Clothing and follow guidelines
in latest version of NFPA 70E. All PPE shall be furnished by Contractor at no cost to Owner.

(k) Pre-Task Analysis. A pre-task analysis shall be completed for each task prior to starting the
task, and prepared with involved employees. The analysis will describe the step-by-step approach to performing the
work safely and will include - but not be limited to - proper PPE, safe body positions, proper use of correct tools and
mobile equipment, identification of potential hazards, any necessary barricading, coordination with other crafts in the
area, emergencies, and any permits required for the work. Employees will sign the analysis indicating they have
received and understood the information. Pre-task plans shall be re-written any time the task changes, even multiple
times during the same day. Contractor shall maintain completed analyses in a file for the duration of the work and
make them available to Owner’s Project Manager or designee on request.

(l) Safety Inspections and Audits.

(1) Contractor will conduct regular safety inspections and program audits of the Work. All work areas must be
inspected at least weekly by a Contractor team consisting of one safety resource, one manager, and at least
one supervisor or worker. The purpose of the inspection is to reinforce good safety behavior, provide
coaching for any at risk behavior, and identify any negative trends needing management attention. Owner
shall be made aware of inspection and audit schedules so a representative may participate if available.

(2) Audit findings, both positive and negative, should be documented and corrective action noted where
necessary. Findings shall be ranked according to risk with corresponding timelines for correction. Interim
abatement should be established for those items not immediately corrected. High risk deficiencies shall be
corrected immediately. Contractor shall provide to Owner on a weekly basis copies of all completed
inspection and audit reports and record results in a designated project database.

(3) Contractor will develop and conduct High Risk Activity (HRA) program audits. The audit will, at a minimum,
review the existence and execution of regulatory required written programs, training and competency,
forecasting and planning of HRAs, risk assessments, administration of permits, and the field execution.
Contractor will record results in a designated project database.

(4) In addition to team audits, Contractor shall employ its own safe behavior observation system where all
supervisory personnel are required to conduct individually-documented safety observations on a regular
basis. The findings of these observations shall be collected in an Owner-designated database to identify
trends needing attention. Any such trends will be addressed with specific remedial actions. Contractor shall
establish trending associated with HRA observations.

(5) Owner may in its sole discretion conduct one or more audits to assess Contractor’s compliance with this
policy.

(m) Safety Meetings. Prior to beginning each shift, all Contractor personnel and subcontractors
shall participate in a safety meeting to discuss safety requirements of the job(s) to be performed that day. Daily
meeting material and attendance shall be documented and furnished to Owner’s Project Manager on request.
Contractor shall hold a weekly safety meeting for all employees assigned to the site. This meeting should be used to
provide safety feedback and to expand the workers’ safety awareness, using prepared safety topics. Meeting
attendance shall be documented and furnished to Owner upon request.

2020-0227 Global Construction Safety Policy (1.0)

CONFIDENTIAL

(1) Following any recordable injury or serious incident, Contractor shall hold a site-wide stand down -preferably
the same day - to communicate what happened and reinforce the need for constant safety vigilance.

(2) Contractor's Site manager (the “Site Manager”) shall hold a weekly supervisory safety meeting to show
leadership for the safety program, and to discuss safety incidents, rule changes, educational material, and
continuous improvement. Meeting attendees will include Site Manager's direct reports, any subcontractor
superintendents and safety personnel on site, and Owner.

(3) Contractor shall initiate and participate in a Project-specific safety committee. The committee shall be
comprised of representatives and agents of Owner, Contractor and project labor representatives selected by
the workers, as applicable.

(n) Safety Orientation. Contractor is responsible to ensure each new hire is aware that safety is
a top priority for the Project. Contractor will prepare a formal safety orientation to be delivered to each employee
before he/she starts his/her first day of work. At a minimum, the orientation will cover Contractor's EHS Plan. All
Subcontractors should receive the same orientation. Orientations must be communicated in a manner which is
understood by all workers, regardless of the nationality. A written outline of the orientation will be made available to
Owner before commencement of the Work. Contractor will keep records of all employees who receive the orientation.

(o) Safety Personnel. Contractor must provide a sufficient number of full-time dedicated and
competent safety professionals to ensure proper administration of Contractor’s EHS Plan. Contractor’s project safety
manager must attend the monthly Global Safety Network call facilitated by Owner’s Construction and Design Safety
Manager. Contractor’s most senior safety manager will participate in quarterly progress calls, in person meetings, and
job walks or when performance warrants more frequent interaction and visits to the Site.

(p) Safety Management Reports. Contractor shall submit a monthly written report to Owner
providing agreed feedback on the safety process. Workhours will be entered into a designated project database no
later than the 5th of every month. An example management safety report is attached to this Exhibit C-3.0 as
Attachment A.

(q) Subcontractors. Contractor is responsible to ensure that all Subcontractors comply with
Contractor's EHS Plan. Owner may request on one or more occasions that Contractor provide certain safety-relevant
information about each prospective subcontractor, in accordance with Section 5.2(b) of the Contract. Owner may
require that Contractor register with a designated third-party due diligence service to pre-qualify prospective
subcontractors. Contractor will evaluate every company performing work on the Site monthly and score their safety
performance in a designated project database.

(r) Substance Abuse. Contractor's EHS Plan will include drug testing for pre-employment and
drug and alcohol testing for cause and post incident as a minimum. Contractor shall ensure that such procedures, as
well as maintenance, use, and disclosure of information gathered from test results, comply with the Americans with
Disabilities Act and any other applicable laws and regulations. Contractor shall not assign any worker to the Project
who does not pass the pre-employment drug test.

(s) Training. Contractor shall ensure that all regulatory training is carried out before workers
commence work and that workers are competent in risks associated with their environment and assigned tasks.
Contractor is responsible for maintaining written proof of employee qualifications and training and will make records
available to Owner as requested.

(t) Wellness. Contractor shall consider the wider impact of health and wellness on its
employees and sub-contractors and how it will raise awareness and standards and, for example, develop a Project-
specific wellness program after completing an assessment to identify risks for the geographical location and
demographic worker population.

2020-0227 Global Construction Safety Policy (1.0)

CONFIDENTIAL

ATTACHMENT A
MANAGEMENT SAFETY REPORT TEMPLATE

I. Monthly Lagging Indicator Data*

Contractor to provide lagging indicator data indicated below for each contractor and for the site as a whole.
Data should reflect monthly totals as well as year to date (YTD).

Total Head Count

Total Hours Worked
#First Aid Cases
#Medical Treatment Cases
#Lost Workday Case Total
#Cases Involving High Risk Activities (HRA)
Recordable Rate

Contractor 1 (General Contractor)

Contractor 2
Contractor 3
Contractor 4
Site total
* Cutoff is last Sunday of month

II. Incidents
Brief summary of any incidents during the month. Incidents include all recordable injuries, near misses with serious
potential, environmental damage, fires, motor vehicle incidents, and property damage.

Date
Contractor
Classification (as indicated above)
Severity Classification (Minor, Major, Serious (SIF or potential-SIF))
Brief description of Incident
Outcome of incident

III. Orientations
# of personnel receiving orientation during the month

IV. Performance Management

Outstanding Safety Performers

# of personnel receiving recognition
Names of Outstanding Performers

Disciplinary Actions
# of personnel removed for cause and cause for removal

V. Audit and Inspection results

# inspections conducted during month
Date of Audit
HRA audits completed

VII. Corrective action status

Corrective action status associated with any Major, Potentially-Serious/Serious incident.

VIII. High Risk Activity (HRA) Permits

2020-0227 Global Construction Safety Policy (1.0)

CONFIDENTIAL

# of daily permits issued during the month by type

IX. Stand downs

Brief summary of any stand downs held during the month

XII. Continuous improvement / Initiatives

Progress against improvement goals, and any new goals for the following month

XIII. Leading indicators

Attach jobsite trend charts for:
 Safe act index (from weekly audits)
 SOR observations, % safe actions, and closure of actions
 Delinquent corrective actions (# of outstanding corrections past their due date - see VII.)
 Housekeeping indicator (from weekly audits - excellent, acceptable, needs work, poor)
 Worst Potential Severity Rate (#SIF potential incidents x 200,000/total workhours)

2020-0227 Global Construction Safety Policy (1.0)

CONFIDENTIAL

EHS PLAN CERTIFICATION

Date: (date of original) Revision Date: (date of latest revision)

Sign in the space provided below to certify that the Project-specific EHS Plan complies with Owner’s Global
Construction Safety Policy. Copies of the completed EHS Plan and this form will be distributed to Contractor and
Owner.

Contractor Site Manager Signature Date

Contractor Safety Adviser Signature Date

Construction Manager Signature Date

2020-0227 Global Construction Safety Policy (1.0)