COMPANY SAFETY POLICY

INTRODUCTION

We all need to be familiar with the safety regulations and policies established to protect us in the
workplace. Our desire is that this manual will make that important responsibility easier to fulfill by
providing a summary of the most essential information we need to know concerning the various aspects
of our daily work routine.

This policy provides an overview of basic Winger Companies, herein referred to as Winger, policies and
programs related to safety, health, and accident prevention, as well as procedures to follow during OSHA
inspections and accident investigations. It also sets forth the specific safety and health policies and
regulations governing different areas of our work environment ranging from confined space to welding
safety.

Winger Safety Manuals are available on all nested jobsites and corporate office. The most recent
versions of our safety programs are available on our website: www.Wingercompanies.com , under the
tab “Safety Manual”, password is Safety1234. Winger jobsite forms are found under “Employee Access”.

SAFETY POLICY STATEMENT

Winger is dedicated to providing a healthy and safe place of employment for all our employees and for
the public at large in all of our operations. Our safety rules governing the workplace have been
established in accordance with the safety regulations of our industry.

Safety will take precedence over more expedient, unsafe operations. Every attempt will be made to
provide equipment and create conditions that will make for a safe workplace.

All employees and subcontractors will be subject to read and understand the Winger Safety Handbook
that have been provided to them. Any employee who willfully disregards known safety practices will be
subject to disciplinary action as set forth in this section.

Any employee who has not been trained or believes that their training is inadequate must immediately
notify their supervisor. No employee shall do any work for which training is required, until they have
received the appropriate training and fully understand all applicable safety rules and procedures.

It is the objective of management to provide all employees with a safe and healthful workplace. In order
to achieve this goal, the following guidelines will help to distinguish the respective duties and levels of
responsibility of each employee. All levels of employees shall make safety their top priority in the day to
day operations of this company.

While it will be the responsibility of the superintendent to insure that all programs, policies, and standards
are being adhered to, all employees are required to participate in the enforcement of these standards as
a condition of employment.

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SAFETY COMMITMENT

Safety is Winger’s primary strategic objective and first consideration in every project that we execute.
We share the belief that all incidents are preventable and we are committed to making this belief a
reality in our organization.

There is no job so important that it cannot be done SAFELY.

Working safely requires management leadership, employee and customer involvement, and a rigorous
implementation of our safety program, best work practices, and regulatory requirements. It is important
to understand that we each have an important role in making our work environment a safe place to work.

Project Safety Goals:

Medical Aid / First Aid – Zero Injuries

Recordable Accident Rate – Zero Injuries
Lost Work Day Case Rate – Zero Injuries

The above goals shall be achieved through pre-job planning, employee training in pre-job hazard
awareness and recognition, enforcement of federal, state, local, customer and Winger safety
requirements and positive reinforcement with Winger employees.

The following description of duties should be helpful in identifying the person responsible for various
aspects of the overall safety and health program:

EMPLOYER RESPONSIBILITY FOR SAFETY

The employer has a primary responsibility for the safety and health of its employees. These
responsibilities include, but are not limited to:

1. The establishment of safe work practices and procedures to minimize workplace hazards.
2. Training all employees in good safety and health practices.
3. Provide the necessary personal protective equipment (PPE), tools and equipment and instructions
on their use.
4. Conduct pre-project and pre-task safety planning to prevent the occurrence of workplace injuries
and illnesses.
5. Conduct frequent safety inspections and audits to find and eliminate unsafe working conditions
and practices, to control health hazards, and to comply fully with the safety and health standards
for every job.
6. Report and investigate, promptly and thoroughly, every accident, injury or near miss to find out
what caused it to correct the problem so that it will not happen again.
7. Provide for employee recognition for outstanding safety service or performance.
8. Compliance with all company, federal, state, local and customer safety requirements.

THE COMPANY SAFETY DIRECTOR

1. To develop, administer, and manage all programs and policies in accordance with local, state,
federal, and customer standards.

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 2. Advises all levels of management on the matters pertaining to safety, to include the
establishment of a “chain of command” for the handling of all concerns and/or communications
relative to safety.
3. To prepare and distribute monthly reports on safety performance, and weekly tool box safety
meeting subjects.
4. To provide technical guidance to field level personnel concerning matters of safety standards.
5. Interface with project managers and engineers, and insure that all safety training which is
required is accomplished.
6. To conduct site inspections on a regular basis to insure compliance to all applicable standards.
7. To insure that field level personnel have adequate safety equipment and supplies to insure
compliance.
8. To pursue continuing education in the field of occupational safety and health as is necessary to
maintain timely knowledge of the subject matter.
9. Keep Winger’s policy and work procedures in compliance with current OSHA rules and regulations
and advises the owner, project manager, superintendents, and foreman of any all changes in
these OSHA rules and regulations.
10. Meets regularly with the superintendents and foremen to review safety procedures on the job
and, in general, checks on the superintendent’s and supervisors’ compliance with the Winger’s
Safety and Health Program.
11. Files complete and concise accident reports using the OSHA Form 300 or equivalent.
12. Displays OSHA Form 300A from February 1 to April 30 annually.

PROJECT MANAGERS / SUPERINTENDENTS

1. Reads and reviews the Construction Safety Standards and is knowledgeable with federal, state,
local and customer requirements.
2. To implement, administer, and enforce the company safety and health programs and policies and
to train all employees that are assigned to their control in said programs/policies in cooperation
with the company safety director.
3. Ensures all employees attend all scheduled safety trainings and toolbox talks.
4. To coordinate high risk activity schedules with the company safety director for preplanning
efforts in order to control or eliminate the hazards of the activity.
5. To review project safety needs so that appropriate funding is arranged for these items.
6. Ensures that all subcontractors complete a Winger Subcontractor Prequalification form and is
approved by the Winger President and Safety Director. Ensures that the sub or trade contractor’s
work meets or exceeds all federal, state, local and customer requirements.
7. Requires that all sub or trade contractors and their prime subcontractors comply with all safety
regulations. To monitor safety performance and adherence. Reports any unsafe conditions
existing on sub or trade contractor areas of the work to their supervisor and/or safety director.
8. Is safety oriented when visiting the jobsite. Completes a Weekly Jobsite Inspection form and
reports all unsafe acts and conditions to the Safety Director and foreman, as well as those
affecting the sub or trade contractor’s personnel.

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 9. Pair new employee(s) with experienced employee(s) on jobs. New employees will have a yellow
sticker on their hardhat with the word NEW and the date of hire. This will enable current
seasoned employees to visually see a new employee is on their jobsite and coach them in proper
safety behaviors. The sticker may be removed after six (6) months.
10. To document all items relative to safety performance or job site conditions in a daily job log and
to bring all unsafe issues up to the Safety Director.
11. Instructs the foremen that safe practices are to be followed and safe conditions maintained
throughout the jobsite.
12. Informs the foremen that they are not to require or permit their workers to take chances but
rather are to instruct their workers in proper and safe procedures.
13. Ensures that all necessary personal protective equipment, job safety materials, and first-aid
equipment are readily available.
14. Files complete and concise accident reports using First Report of Injury and Winger Incident
Report. Reviews all accidents with employee, foreman and safety director and ensures that
corrective action is taken immediately.
15. Maintains a copy of Construction Safety Standards (Code of Federal Regulations, Part 1926) close
at hand for ready reference.

FOREMAN RESPONSIBILITY FOR SAFETY

The supervisor/foreman MUST accept the day-to-day responsibility for assuring the safety and health of
those employees working under his or her supervision. These responsibilities include:

1. Implements COMPANY’s on-site safety and health program.

2. Is familiar with the basic requirements of the federal, state, local, company and customer’s
requirements pertaining to safety and job procedures.
3. Plan safety into EACH day’s work activities.
4. Ensures that the employees commit no unsafe acts and that no unsafe conditions exist in the
work areas.
5. If at any time an imminent danger exists, the job must be stopped immediately. All hazards
must be reduced or eliminated before proceeding.
6. Explain job scope. STOP and re-assess when the job scope changes. Instructs all employees on
safety procedures and job safety requirements. Follows up and insists on compliance.
7. Assure that all employees fully understand what to do in the event of an emergency.
8. Provide each employee with the time, material, equipment, and training necessary to implement
the work plan safely.
9. Ensures that all necessary personal protective equipment, job safety materials, and first-aid
equipment are readily available. Ensures that necessary protective equipment is used as required.
16. Pair new employee(s) with experienced employee(s) on jobs. New employees will have a yellow
sticker on their hardhat with the word NEW and the date of hire. This will enable current
seasoned employees to visually see a new employee is on their jobsite and coach them in proper
safety behaviors. The sticker may be removed after six (6) months.
10. Be positive, receptive and act on an employee’s safety and health concerns.
11. Encourage employee participation in the identification and correction of safety and health issues.
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 12. Requires that all sub or trade contractors and their prime subcontractors to comply with all safety
regulations. Reports any unsafe conditions existing on sub or trade contractor areas of the work
to their supervisor and/or safety director.
13. Administer disciplinary action if necessary, but do so in a manner that exhibits an example of a
good leader. Immediately report disciplinary action needed to Project Manager or Site
Superintendent for documentation.
14. Report all near misses and unsafe conditions, injuries and illnesses, vehicle accidents, fires,
chemical and environmental spills and property damage immediately, no matter how minor, to
their supervisor and safety director so that appropriate responses may be taken and treatment
promptly rendered.
15. Investigates and reviews all accidents with employee, supervisor and safety director.
Implements corrective action is taken immediately after cause of accident has been determined.
16. Monitors all Tool Box Safety Talks.
17. Performs Weekly Jobsite Inspections and corrects any deficiencies immediately.

EMPLOYEE RESPONSIBILITY FOR SAFETY

Each employee is expected to cooperate with all aspects of the safety and health program including
compliance with all rules and regulations and for continuously practicing safety while performing their
duties.

Employees are expected to:

1. It is the employee’s primary responsibility for their own safety and that of their coworkers and to
caution fellow employees and other persons in the workplace when they perform unsafe acts.
2. Be familiar with the safety requirements that pertain to their jobs and follow all prescribed safety
regulations, rules, practices, instructions and signs.
3. Read the OSHA Poster at the jobsite. Comply with all applicable OSHA standards. Exercise rights
under the Act in a responsible manner.
4. All employees, whether it is a Winger or a Winger sub-contractor employee, have the right to
stop work, work of their co-workers or customers, and refuse unsafe work conditions any time
they feel that the situation is unsafe. All unsafe work conditions must be immediately reported to
their supervisor.
5. Wear or use all required Personal Protective Equipment (PPE) while working at their job site.
6. Before proceeding with a job, all employees SHALL assure themselves they can perform the work
safely. If they are assigned work they are not qualified to perform or are not comfortable
performing, they SHALL inform their supervisor immediately.
7. Employees who leave their normal work environment and enter another work environment SHALL
know, understand, and follow the safety rules of that work group.
8. Report all near misses and unsafe conditions, injuries and illnesses, vehicle accidents, fires,
chemical spills and property damage immediately, no matter how minor, to their supervisor and
safety director so that appropriate responses may be taken and treatment promptly rendered.
9. Actively participate in safety training, meetings, incident investigations, safety inspections, safety
audits, industrial hygiene monitoring, medical surveillance, pre-task planning and other safety
related matters or programs as requested.

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 10. Many of our customer’s locations are tobacco free facilities. That means that NO SMOKING or
CHEWING TOBACCO PRODUCTS are allowed to be used onsite.
11. Know that disciplinary action may result from violation of the safety rules. Violations of any safety
rules or policies set forth herein may result in discipline and/or discharge. A flagrant violation,
which puts you or your fellow workers in a dangerous situation, may result in immediate
discharge.
IF YOU HAVE ANY QUESTIONS, ASK YOUR FOREMAN or SAFETY TEAM!

DISCIPLINE PROCEDURE

Winger adopts the following progressive disciplinary policy. The policy is intended to ensure compliance
by all Winger employees with Winger Program for Safety and Health Manual and with safe and healthful
work practices.

Violations of any safety rules may result in discipline and/or termination of employment. These actions
may include the following:

FIRST OFFENSE: Verbal and written notices.

SECOND OFFENSE: Suspension: Verbal, written and 3 days off without pay.

THIRD OFFENSE: Dismissal.

A flagrant violation, which puts yourself or fellow workers in a dangerous situation, may result in
immediate discharge, avoiding steps one and two.

I __________________________ hereby acknowledge that I have read, or have been read to, the
Winger’s General Safety and Work Rules. I agree to follow these rules while working for Winger.

__________________________________ ______________________
Employee Name Date

GENERAL SAFETY WORK RULES

Your health and safety is a primary concern to Winger. These rules have been designed with your safety
in mind. It is essential that you read and understand these general rules so that we can achieve an
accident free work place.
1. Use common sense. These general safety rules are a guide to safe work practices. Report
unsafe conditions immediately. You are not required to work under unsafe conditions.
2. Behave in a respectful professional manner at all times. Horseplay will not be tolerated.
3. Working while intoxicated or under the influence of controlled substances is strictly prohibited.
4. All accidents and injuries MUST be reported to your foreman and supervisor immediately.
5. All safety rules, procedures, and practices set forth by Winger and our customers will be
followed. All applicable permits must be filled out by the Permit Coordinator and obtained from

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 the customer before work begins; i.e. Safe Work Permits, Confined Space, Lockouts walked, Line
Breaks, Electrical, etc.
6. Coordinate and cooperate with all other employees in the workplace to try to eliminate on-the-
job injuries and illnesses.
7. Keep the public, customers, and all other personnel in the workplace aware of potential hazards
in order to eliminate on-the-job injuries and illnesses.
8. Be a leader in the effort to provide a safe and healthful workplace by setting a proper example
and by encouraging others to develop and maintain a strong, positive attitude toward compliance
with all applicable safety standards.
9. Assist less experienced employees in their efforts to comply with applicable safety practices and
standards.
10. Apply the principles of accident prevention in your daily work and use proper safety devices and
protective equipment as required.
11. Proper care will be given to all tools and precautions taken to protect them from loss, damage,
and theft.
12. Vehicles and machinery will not be abused or misused.
13. Work clothes will not be torn, tattered, or in need of repair. Clothing in this condition is a
potential safety hazard and promotes a poor company image.
14. Company provided Personal Protective Equipment (PPE) MUST be worn for the job being
performed. This includes, but is not limited to the following items: safety glasses/goggles, hard
hats, hearing protection, work gloves, face shields, fall protection harnesses, respirators, welding
jackets, sleeves, and hoods, etc. See Winger Personal Protective Equipment Safety Program for
specific instructions.
15. Good housekeeping will be maintained at all times. DO NOT leave materials in aisles, walkways,
stairways, roads or other points of egress. Do not store combustible items under stairways.
16. Keep your work area clean. Remove scrap material and trash on a daily basis or more often if
necessary.
17. Pile and stack material safely. Use proper blocking / stacking practices and NEVER exceed a safe
height.
18. Only authorized and trained personnel may operate machinery or mobile equipment (i.e.,
forklifts, rough-terrain forklifts, aerial lifts, etc.)
19. All posted safety signs, placards, and postings shall be obeyed and shall not be removed except
by management’s authorization.
20. Additional safety rules in the Winger’s Employee Safety Handbook and the Winger’s Safety
Manual should be read and understood.
21. Violation of these safety rules may be cause for immediate dismissal of any
employee.

TRAINING

Employees will be instructed in the recognition and avoidance of unsafe conditions and the regulations
applicable to his work environment to control or eliminate any hazards or other exposure to illness or
injury.

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New employees will be asked to provide evidence of completion of any safety training received from the
union, other contractors, and outside training sources. The status of employee training will be
maintained electronically and in the employee’s personnel file and updated as additional training is
provided.

New employees will receive a written copy of the “Winger Employee Safety Handbook” and will be asked
to sign a receipt acknowledging they have received a copy of our safety policies and read them.

New employees will have a yellow sticker on their hardhat with the word NEW and the date of hire. This
will enable current seasoned employees to visually see a new employee is on their jobsite and coach
them in proper safety behaviors. The sticker may be removed after six (6) months.
Orientation training in essential safety topics will be provided at the time of hire.

Extensive training in OSHA, Hazard Communication, Scaffold User, Fall Protection, Confined Space,
Lockout/Tagout, Aerial Lifts, Rough-Terrain Forklifts, Excavations, Ladders, First Aid & CPR, plus other
safety topics will be provided.

All employees will receive weekly safety training reinforcement through the use of Tool Box Safety Talks
and monthly safety training meetings.

Daily monitoring and weekly jobsite inspections of safety conditions will be used to remind employees of
potential safety hazards.

When a new phase of the job operation begins or when new hazardous materials are brought on the site,
employees will be made aware of any new or additional conditions that may prove to be dangerous.
Specific safety procedures will be reviewed and are to be followed in order to maintain a safe work
environment.

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SOURCE CREDITS:

U.S. Department of Labor, Occupational Safety and Health Administration (OSHA) www.osha.gov
Mechanical Contractors Association of America, www.mcaa.org

DOCUMENT CONTROL:

Revised July 13, 2007

Revised December 16, 2011
Revised September 28, 2012
Revised April 1, 2013
Revised November 15, 2013
Revised February 25, 2014
Reviewed April 8, 2015
Revised June 20, 2016
Revised July 22, 2016
Revised October 19, 2016
Revised September 13, 2017

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