Safety and Accident Prevention, Project

TIKIGAQ CORPORATION CORPORATE HEALTH & SAFETY PROGRAM PLAN Corporate Office Location 2121 Abbott Road Anchorage, AK 99507 January 2014 Table of Contents 1.0 Health and Safety Program Policy Statement........................................................................ 1-1 2.0 Health and Safety Program Introduction ............................................................................... 2-1 2.1 General Principles ................................................................................................................. 2-1 2.2 Corporate Health and Safety Program Objective ............................................................. 2-2 2.3 Program Effectiveness .......................................................................................................... 2-2 2 .4 Position Statement on Modified Work Assignments ....................................................... 2-2 2.5 Primary Corporate Health and Safety Program Functions ............................................. 2-3 3.0 Responsibilities........................................................................................................................... 3-1 3.1 Management Responsibilities .............................................................................................. 3-1 3.1.1 President ............................................................................................................................. 3-2 3.1.2 Chief Operating Officer .................................................................................................... 3-2 3.1.3 General or Regional Managers ........................................................................................ 3-2 3.1.4 Human Resource Manager .............................................................................................. 3-2 3.2 Line Supervisor Responsibilities ......................................................................................... 3-2 3.2.1 Project/Facility Managers ................................................................................................ 3-3 3.2.2 Line Supervisors ................................................................................................................ 3-4 3.3 Safety Coordinator Responsibilities .................................................................................... 3-5 3.3.1 Corporate Health and Safety Manager .......................................................................... 3-6 3.3.2 Health and Safety Officer/Health and Safety Program Administrator .................... 3-6 3.3.3 Site Safety and Health Officer (SSHO) ........................................................................... 3-8 3.4 Employee Responsibilities ................................................................................................... 3-9 4.0 Accident/Incident I Reporting and Investigation Procedures ........................................... 4-1 4.1 Introduction ............................................................................................................................ 4-1 4.2 Policy ....................................................................................................................................... 4-1 4.3 Definitions .............................................................................................................................. 4-1 4.4 TIKIGAQ Incident Notification and Reporting Process .................................................. 4-2 4.4.1 Overall Summary of Incident Procedures ..................................................................... 4-5 4.5 Procedures for Accident/Incident Investigation .............................................................. 4-7 4.5.1 Best Management Practices for Accident/Incident Investigation ............................. 4-8 4.6 Incident Report Form (IRF) Instructions ............................................................................ 4-9 4.7 Determination of Root Cause(s) of Accidents and Incidents ........................................ 4-12 4.8 Lessons Learned .................................................................................................................. 4-13 4.9 Distribution of Required Report Forms/Records ........................................................... 4-14 5.0 Risk Management Process ........................................................................................................ 5-1 5.1 Site/faciltiy Specific Health and Safety Plans ................................................................... 5-1 5.2 Activity Hazard Analysis ..................................................................................................... 5-2 5.3 Pre-Task Safety Plans ............................................................................................................ 5-3 5.4 Loss Prevention Observation ............................................................................................... 5-4 5.4.1 Deficiency Tracking System ............................................................................................ 5-4 5.5 Incident (Loss/Near-Loss) Investigations ......................................................................... 5-5 5.5.1.1 Contractor Significant Incident Report ................................................................. 5-6 5.6 Drug-Free Workplace Program ........................................................................................... 5-6 5.7 Subcontractor Qualifications ............................................................................................... 5-7 5.7.1 Site or Facility Subcontractor Safety Performance ....................................................... 5-7 6.0 Training ....................................................................................................................................... 6-1 6.1 Site/Facility Orientation ....................................................................................................... 6-1 6.2 Mandatory Training .............................................................................................................. 6-1 6.3 Medical Surveillance ............................................................................................................. 6-2 7.0 Hazard Communication ........................................................................................................... 7-1 7.1 Introduction ............................................................................................................................ 7-1 7.2 "Employees ―Right To Know‖ ............................................................................................. 7-1 7.3 Availability of Information .................................................................................................. 7-1 7.4 Hazardous Materials ............................................................................................................. 7-2 7.4.1 Definitions .......................................................................................................................... 7-2 7.4.2 Chemical Identification .................................................................................................... 7-3 7.4.2.1 Identification of Flammability ................................................................................ 7-3 7.4.2.2 Identification of Health Hazard ............................................................................. 7-4 7.4.2.3 Identification of Reactivity ...................................................................................... 7-4 7.4.2.4 Identification of Other Hazards ............................................................................. 7-4 7.5 Hazardous Material Acquisition Process ........................................................................... 7-5 7.6 Chemical and Physical Agent Inventories ......................................................................... 7-6 7.7 MSDS and PADS ................................................................................................................... 7-6 7.8 Training ................................................................................................................................... 7-6 7.8.1 Attendance and Records .................................................................................................. 7-7 7.9 Labeling of Containers .......................................................................................................... 7-7 7.10 Primary Containers ............................................................................................................... 7-7 7.10.1 Portable Containers ...................................................................................................... 7-7 7.10.1.1 Immediate Use .......................................................................................................... 7-7 7.10.1.2 Not for Immediate Use ............................................................................................ 7-7 7.11 Responsibilities of Line Supervisors and Safety Coordinators ....................................... 7-8 7.12 Responsibilities of Employees ............................................................................................. 7-8 7.13 Line supervisor or safety coordinator Responsibilities .................................................... 7-9 7.14 General Safety Precautions .................................................................................................. 7-9 7.15 Chemical Disposal ............................................................................................................... 7-10 7.16 Task Evaluation ................................................................................................................... 7-10 7.17 Hazardous Material Master List Form ............................................................................. 7-11 7.18 Chemical Specific Hazards Review Form ........................................................................ 7-12 8.0 Worker Protection Measures (Physical/Chemical) .............................................................. 8-1 8.1 Engineering Controls ............................................................................................................ 8-1 8.2 Administrative Controls ....................................................................................................... 8-1 8.2.1 Employee Exposure Monitoring ..................................................................................... 8-2 8.2.1.1 Perimeter Air Monitoring ........................................................................................ 8-3 8.3 Personal Protective Equipment ........................................................................................... 8-4 8.3.1 Management Responsibilities ......................................................................................... 8-4 8.3.2 Line Supervisor and Safety Coordinator Responsibilities .......................................... 8-4 8.3.3 Employee Responsibilities ............................................................................................... 8-5 8.3.4 Eye and Face Protection ................................................................................................... 8-5 8.3.5 Foot Protection ................................................................................................................... 8-8 8.3.6 Hearing Protection ............................................................................................................ 8-9 8.3.6.1 Danger of Noise Exposure ...................................................................................... 8-9 8.3.6.2 ACGIH Standards .................................................................................................... 8-9 8.3.6.3 Reducing Noise Exposure ....................................................................................... 8-9 8.3.6.4 Engineering Controls ............................................................................................. 8-10 8.3.6.5 Administrative Procedures ................................................................................... 8-10 8.3.6.6 Personnel Protective Devices ................................................................................ 8-10 8.3.6.7 Hearing Protection Devices .................................................................................. 8-10 8.3.7 Head Protection ............................................................................................................... 8-10 8.3.8 Hand Protection .............................................................................................................. 8-11 8.3.9 Protective Equipment for Chemical Exposures .......................................................... 8-11 8.3.10 Respiratory Protection................................................................................................ 8-12 8.4 General Personal Protective Equipment Overview ........................................................ 8-13 8.5 Proper Worker Hygiene & Decontamination Practices ................................................. 8-14 8.5.1 Decontamination Requirements ................................................................................... 8-14 9.0 Respiratory Protection Program .............................................................................................. 9-1 9.1 Purpose ................................................................................................................................... 9-1 9.2 Scope ........................................................................................................................................ 9-1 9.3 Regulatory Compliance ........................................................................................................ 9-1 9.4 Respiratory Protection Program .......................................................................................... 9-1 9.5 Program Administration ...................................................................................................... 9-2 9.5.1 Employer Responsibility .................................................................................................. 9-2 9.5.2 Employee Responsibility .................................................................................................. 9-3 9.6 Respirator Selection ............................................................................................................... 9-3 9.7 Exclusive Employee Use ....................................................................................................... 9-4 9.8 User Training ......................................................................................................................... 9-4 9.9 Fitting ...................................................................................................................................... 9-5 9.9.1 Positive and Negative Pressure Tests ............................................................................ 9-6 9.9.1.1 Positive Pressure Test .............................................................................................. 9-6 9.9.1.2 Negative Pressure Test ............................................................................................ 9-6 9.10 Fit Testing Procedures -- General Requirements .............................................................. 9-6 9.11 Qualitative Fit Test ................................................................................................................ 9-9 9.11.1 Particulate Filter Cartridge Respirators - QLFT via Irritant Smoke Protocol....... 9-9 9.11.1.1 Sensitivity Screening Check .................................................................................... 9-9 9.11.1.2 Irritant Smoke Fit Test Procedure ........................................................................ 9-10 9.11.2 Organic Vapor Cartridge Respirators - Isoamyl Acetate Fit Test Protocol ........ 9-10 9.11.2.1 Odor Threshold Screening .................................................................................... 9-11 9.11.2.2 Isoamyl Acetate Fit Test ........................................................................................ 9-12 9.11.3 Quantitative Fit Test ................................................................................................... 9-13 9.11.3.1 Aerosol Condensation Ambient Nuclei Counter (CNC) quantitative fit testing protocol. ................................................................................................................................... 9-13 9.12 Respirator Inspection and Repair ...................................................................................... 9-14 9.12.1 Record Keeping ........................................................................................................... 9-14 9.12.2 Inspection Considerations ......................................................................................... 9-14 9.12.3 Repair and Filter Replaceme nt .................................................................................. 9-15 9.12.4 Cleaning and Disinfecting. ........................................................................................ 9-15 9.12.5 Storage .......................................................................................................................... 9-16 9.13 Work Area Surveillance ...................................................................................................... 9-16 9.14 Program Surveillance .......................................................................................................... 9-16 9.15 Confined Space Entry ......................................................................................................... 9-16 9.16 Medical Approval ................................................................................................................ 9-17 9.17 Disposable Respirators ....................................................................................................... 9-17 9.18 Specific Limitations ............................................................................................................. 9-17 9.19 Emergency Equipment ....................................................................................................... 9-17 10.0 Confined Space Entry .............................................................................................................. 10-1 10.1 Introduction .......................................................................................................................... 10-1 10.2 Definitions ............................................................................................................................ 10-1 10.3 Responsibilities .................................................................................................................... 10-2 10.3.1 Training ........................................................................................................................ 10-2 10.3.2 Safety Coordinator and Safety Representatives ..................................................... 10-2 10.3.3 Entry Supervisor ......................................................................................................... 10-2 10.3.4 Entrants ........................................................................................................................ 10-3 10.3.5 Attendants .................................................................................................................... 10-3 10.4 Rescue Entry Services ......................................................................................................... 10-4 10.4.1 Retrieval System .......................................................................................................... 10-4 10.5 CSE Ventilation .................................................................................................................... 10-5 10.6 Confined Space Standard Practices .................................................................................. 10-5 11.0 Hazardous Energy Control/LOTO ....................................................................................... 11-1 12.0 Site/Facility Specific hazard Control measures .................................................................. 12-1 12.1 Adverse Weather ................................................................................................................. 12-1 12.1.1 Lightning ...................................................................................................................... 12-1 12.2 Aerial Lifts ............................................................................................................................ 12-2 12.3 Air Compressor Operations ............................................................................................... 12-3 12.4 Asbestos Containing Material ........................................................................................... 12-4 12.4.1 Asbestos General Awareness Information .............................................................. 12-4 12.5 Biological Hazards (Bears) - Northern Operations ......................................................... 12-6 12.5.1 Site or Facility Operations ......................................................................................... 12-7 12.5.2 Performing Site/Facility Activities .......................................................................... 12-7 12.5.3 Bear Encounters .......................................................................................................... 12-8 12.5.4 Personal Protection ..................................................................................................... 12-9 12.5.5 Reporting Bear Encounters ........................................................................................ 12-9 12.5.6 Polar Bears ................................................................................................................. 12-10 12.6 Biological Hazards (various) - Southern Operations ................................................... 12-10 12.6.1 Alligators .................................................................................................................... 12-10 12.6.2 Fire Ants ..................................................................................................................... 12-11 12.6.3 ―Poisonous‖ Plants ................................................................................................... 12-11 12.6.3.1 Exposure ................................................................................................................ 12-12 12.6.3.2 Best Management Practices ................................................................................. 12-13 12.6.4 New Treatment for Exposure to Poisonous Plants .............................................. 12-13 12.6.5 Rabid Animals ........................................................................................................... 12-14 12.6.6 Stinging Insects ......................................................................................................... 12-14 12.6.6.1 Mosquito Bites....................................................................................................... 12-15 12.6.7 Venomous Spiders – Brown Recluse ...................................................................... 12-15 12.6.8 Venomous Spiders – Widow ................................................................................... 12-17 12.6.9 Venomous Snakes ..................................................................................................... 12-18 12.6.10 Ticks ............................................................................................................................ 12-20 12.6.10.1 Hazard Control ................................................................................................. 12-20 12.6.10.2 Tick Identification ............................................................................................ 12-21 12.6.10.3 Illnesses and Signs/Symptoms ...................................................................... 12-21 12.6.10.4 Tick Removal .................................................................................................... 12-21 12.6.10.5 First Aid and Medical Treatment ................................................................... 12-22 12.6.10.6 Analysis for Tick-borne Pathogens................................................................ 12-22 12.7 Biological Hazards - Bloodborne Pathogens ................................................................. 12-23 12.7.1 Universal Precautions against Exposure to Bloodborne Pathogens ................. 12-24 12.8 Blasting Operations ........................................................................................................... 12-25 12.9 Concrete & Masonry Work .............................................................................................. 12-25 12.9.1 General Requirements .............................................................................................. 12-25 12.10 Cranes ............................................................................................................................. 12-26 12.10.1 Critical Lift ................................................................................................................. 12-27 12.11 Demolition ...................................................................................................................... 12-27 12.11.1 Planning ..................................................................................................................... 12-28 12.11.2 Demolition Zone Procedures .................................................................................. 12-29 12.11.3 General Requirements .............................................................................................. 12-29 12.11.4 Protection of the Public ............................................................................................ 12-30 12.11.5 Work Area Protection ............................................................................................... 12-31 12.11.6 Demolition Using Heavy Equipment .................................................................... 12-31 12.11.7 Demolition Using Cranes ........................................................................................ 12-31 12.11.8 Manual Removal of Masonry Walls ....................................................................... 12-32 12.11.9 Manual Removal of Floors ...................................................................................... 12-32 12.11.10 Material Chutes ..................................................................................................... 12-33 12.11.11 Debris Storage and Disposal ............................................................................... 12-33 12.11.12 Demolition Housekeeping .................................................................................. 12-34 12.12 Diving Operations ......................................................................................................... 12-34 12.13 Drilling ............................................................................................................................ 12-34 12.14 Electrical Hazards ......................................................................................................... 12-35 12.15 Excavation Activities .................................................................................................... 12-37 12.16 Fire Prevention .............................................................................................................. 12-42 12.17 Haul Trucks .................................................................................................................... 12-43 12.18 Handling or Sampling of Drummed Waste .............................................................. 12-44 12.18.1 Drum Management .................................................................................................. 12-44 12.18.2 Preliminary Inspection ............................................................................................. 12-45 12.18.2.1 Drums with Potential Shock Sensitive Material .......................................... 12-46 12.18.2.2 Drums with Potential Laboratory Waste ...................................................... 12-46 12.18.2.3 Leaking, Open or Deteriorated Drums ......................................................... 12-46 12.18.3 Handling .................................................................................................................... 12-47 12.18.4 Opening and Sampling ............................................................................................ 12-47 12.18.5 Increased Safety Objectives ..................................................................................... 12-47 12.18.6 Overhaul Original Planning .................................................................................... 12-48 12.19 Heat and Cold Stress .................................................................................................... 12-48 12.19.1 Heat Stress.................................................................................................................. 12-48 12.19.1.1 Monitoring Heat Stress .................................................................................... 12-50 12.19.2 Cold Stress ................................................................................................................. 12-51 12.20 Heavy Equipment ......................................................................................................... 12-52 12.21 Land Clearing Operations – General .......................................................................... 12-53 12.21.1 Land Clearing – Hydraulic Mowing ...................................................................... 12-54 12.21.2 Land Clearing – Chainsaws/Brush Cutters .......................................................... 12-55 12.21.3 Land Clearing – Tree Felling via Chainsaws ........................................................ 12-56 12.21.4 Land Clearing - Chippers ........................................................................................ 12-56 12.22 Mechanical Guarding ................................................................................................... 12-57 12.23 Manual Lifting ............................................................................................................... 12-58 12.23.1 Manual Lifting Assessment and Preparation ....................................................... 12-58 12.23.2 Lifting the Load ......................................................................................................... 12-59 12.23.3 Carrying the Load ..................................................................................................... 12-59 12.23.4 Setting the Load Down ............................................................................................ 12-59 12.23.5 Management Support ............................................................................................... 12-59 12.24 Power and Hand Tools ................................................................................................. 12-60 12.24.1 Training ...................................................................................................................... 12-60 12.24.2 Hand Tools, General ................................................................................................. 12-60 12.24.3 Repair and Storage .................................................................................................... 12-60 12.24.4 Selection ..................................................................................................................... 12-60 12.24.5 Individual Hand Tools, Precautions ...................................................................... 12-60 12.24.5.1 Screwdrivers ..................................................................................................... 12-60 12.24.5.2 Hammers ........................................................................................................... 12-61 12.24.5.3 Chisels ................................................................................................................ 12-61 12.24.5.4 Wrenches ........................................................................................................... 12-61 12.24.5.5 Pliers ................................................................................................................... 12-61 12.24.5.6 Inspections ........................................................................................................ 12-61 12.24.5.7 Repair and Storage ........................................................................................... 12-62 12.24.6 Individual power Tools, Precautions ..................................................................... 12-62 12.24.6.1 Grinders ............................................................................................................. 12-62 12.24.6.2 Saws.................................................................................................................... 12-62 12.24.7 Power Actuated Tools .............................................................................................. 12-62 12.24.7.1 Grounding ......................................................................................................... 12-63 12.24.8 Knife Use .................................................................................................................... 12-63 12.24.8.1 Responsibilities ................................................................................................. 12-63 12.24.8.2 Glove Requirements ........................................................................................ 12-63 12.24.8.3 Standard Control Measures for Knife Use ................................................... 12-63 12.25 Pressure Washing Operations ..................................................................................... 12-64 12.26 Site/Facility Housekeeping – General ....................................................................... 12-65 12.27 Site/facility Control Measures –General ................................................................... 12-66 12.27.1 Site/Facility Sanitation Requirements ................................................................... 12-67 12.27.2 Site Control – HAZWOPER ..................................................................................... 12-68 12.27.2.1 Exclusion Zone ................................................................................................. 12-69 12.27.2.2 Contamination Reduction Zone ..................................................................... 12-69 12.27.2.3 Support Zone .................................................................................................... 12-69 12.27.3 Decontamination & Good Hygiene Practices ....................................................... 12-70 12.27.3.1 Decontamination Requirements .................................................................... 12-70 12.28 Slips, Trips & falls ......................................................................................................... 12-72 12.29 Spill Prevention ............................................................................................................. 12-72 12.29.1 Anticipated Hazardous Materials .......................................................................... 12-73 12.30 Underground utility or objects (location of) ............................................................. 12-74 12.30.1 Unknown or Suspect Objects .................................................................................. 12-76 12.31 Unexploded ordinance/Munitions of Explosive Concern ..................................... 12-76 12.32 Vacuum Truck Operations ........................................................................................... 12-76 12.33 Vehicle Use Policy ......................................................................................................... 12-77 12.33.1.1 Supervisor Responsibilities ............................................................................. 12-77 12.33.1.2 Employee Responsibilities .............................................................................. 12-77 12.33.1.3 Accidents ........................................................................................................... 12-77 12.33.1.4 Exposure to Vehicular Traffic ......................................................................... 12-78 12.34 Visible Lighting ............................................................................................................. 12-79 12.35 Welding and Cutting .................................................................................................... 12-80 12.35.1 Compressed Gas Cylinders ..................................................................................... 12-82 12.36 Working Around Material Handling Equipment .................................................... 12-83 12.36.1 Powered Industrial Trucks ...................................................................................... 12-84 12.36.2 Rigging ....................................................................................................................... 12-85 12.36.2.1 Suspended Loads ............................................................................................. 12-86 12.37 Working Over Water .................................................................................................... 12-86 12.38 Working Surfaces .......................................................................................................... 12-88 12.38.1 Fall Protection ............................................................................................................ 12-88 12.38.2 Surfaces or Activities Requiring Fall Protection or Protection from Falling Objects .............................................................................................................................................. 12-88 12.38.3 Guardrail Systems ..................................................................................................... 12-89 12.38.4 Personal Fall Arrest Systems ................................................................................... 12-89 12.38.5 Protection from Falling Objects .............................................................................. 12-89 12.38.6 General Fall Protection Evaluation ........................................................................ 12-90 12.38.7 Working Surface House Keeping ........................................................................... 12-91 12.38.8 Aisles and Passageways ........................................................................................... 12-91 12.38.9 Floor Loading Protection ......................................................................................... 12-92 12.38.10 Wall Openings and Holes ................................................................................... 12-92 12.38.11 Portable Ladders ................................................................................................... 12-92 12.38.11.1 General Requirements ..................................................................................... 12-92 12.38.11.2 Climbing Ladders............................................................................................. 12-93 12.38.11.3 Replacement Ladders ...................................................................................... 12-93 12.38.11.4 Safety Harnesses ............................................................................................... 12-93 12.38.12 Scaffolding ............................................................................................................. 12-93 13.0 Emergencies .............................................................................................................................. 13-1 13.1 Introduction .......................................................................................................................... 13-1 13.2 Supervisor Responsibilities ................................................................................................ 13-1 13.3 Employee Responsibilities ................................................................................................. 13-1 13.3.1 Pre-Emergency Planning ........................................................................................... 13-1 13.3.1.1 Procedures and Tests ............................................................................................. 13-2 13.3.2 Emergency Equipment ............................................................................................... 13-2 13.3.3 Emergency Medical Treatment ................................................................................. 13-3 14.0 Office Ergonomics .................................................................................................................... 14-1 14.1 S tep 1: Evaluate Your Chair ............................................................................................... 14-1 14.1.1 Specific Information about Chairs – Selection ........................................................ 14-2 14.1.1.1 Seat ............................................................................................................................ 14-2 14.1.1.2 Backrest .................................................................................................................... 14-2 14.1.1.3 Armrest .................................................................................................................... 14-2 14.1.2 Specific Information about Chairs - Adjustments .................................................. 14-3 14.2 Step 2: Evaluate Your Keyboard ........................................................................................ 14-4 14.3 Step 3: Monitor, Document, and Telephone .................................................................... 14-4 14.4 Step 4: Pauses and Breaks ................................................................................................... 14-5 15.0 Health & Safety Program Plan Attachments ....................................................................... 15-1 Attachment 1: TIKIGAQ Return to Work Authorization Attachment 2: Subcontractor Safety Performance Questionnaire A ttachment 3: Incident Report Form R oot Cause Analysis Form Stop Work Order Form Lessons Learned Format Tick Bourne Pathogen Testing Submission Form Attachment 4: Blank Activity Hazard Analysis (A HA ) Forms (2 versions) Attachment 5: Blank Pre-Task Safety (PTSP) Form A ttachment 6: Blank Loss Prevention Observation (LPO) A ttachment 7: Air Monitoring Log A ttachment 8: Equipment Inspection Form Attachment 9: Daily Site/facility Sign-in Log Exclusion Zone Sign-in Log Attachment 10: Acknowledgement Form Acronyms and Abbreviations AHA Activity Hazard Analysis AL Action Level AOR Area of Responsibility APP Accident Prevention Plan BBLPS Behavior Based Loss Prevention System B l s B elow land surface CFR Code of Federal Regulation CHSM Corporate Health and Safety Manager CHSP Corporate Health and Safety Program CIH Certified Industrial Hygienist COCs Constituents of Concern COO Chief Operating Officer CPR C ardio pulmonary resuscitation CRZ C ontamination reduction zone CSE Confined Space Entry CTO Contract Task Order dB D ecibels DEET N, N - diethyl - meta - polyamide DFWP Drug Free Workplace Program DOT Department of Transportation ESC E rosion and sediment contro l EZ E xclusion zone FA F irst aid FC F oot candle GFCI G round fault circuit interrupter GPR G round - penetrating radar H&S Health and Safety HAZWOPER Hazard Waste Operations and Emergency Response HBV Hepatitis B Virus HEPA H igh - efficiency particulat e air HIV Human Immunodeficiency Virus HR H eart rate HRM Human Resource Manager H&S Healt h and Safety HSO Health a nd Safety Officer (same as HSPA) HSPA Health and Safety Program Administrator (same as HSO) HSP Health and Safety Plan IRF Incident R eport Form KA Contracts Administrator LPO Loss Prevention Observation M M eter(s) MSDS Material Safety Data Sheet NIOSH National Institute for Occupational Health NLI Near Loss Investigation OEL Occupational Exposure Limits OSHA Occupational Safety and Health Administration PADs Physical Agent Data Sheets PDF Personal Floatation Device PEL Permissible Exposure Limit POC Point of Contact PPE Personal Protective Equipment PTSP Pre - Task Safety Plan RCRA Resource Conservation and Recovery Act RMS F Rocky Mountain Spotted Fever STARI Southern Tick - Associated Rash Illness SC Safety Coordinator SOP Standard Operating Procedure SSHO Site Safety and Health Officer SWO Stop Work Order SZ Support Zone TCL Target Compound List TSCA Toxic Substances Control Act UL Underwriters Laboratory UV U ltraviolet TIKIGAQ Corporate Health and Safety Program Plan, 11/09 1-1 1.0 HEALTH AND SAFETY PROGRAM POLICY STATEME NT The measurement of a successful health and safety program includes the ability to execute profitably, on time, without violations and safety. Success can only be achieved when all these components are integrated; therefore, health and safety must be part of every operation, at every responsibility level. It is the intent of the TIKIGAQ Corporation and its duly authorized Subsidiaries (herein after referred to as TIKIGAQ), to adhere to established standards concerning the health and safety of our employees and create work environments that are free of recognized hazards that may result in an accident, injury or illness. To do this, we must be vigilant in the identification and elimination of acts and conditions that can produce or lead to accidents, injuries, and illnesses in our workplace. Management, supervisory, and worker personnel are all entrusted with implementing the policies and procedures of the TIKIGAQ health and safety program and prepared site specific health and safety documents. Prevention of accidents, injury, and illness is an achievable objective for all employees, at all responsibility levels, for all program operations. It is a basic re quirement that each manager and supervisor to make the safety of employees, under their tenure, an integral component of his or her regular management practices. Additionally, it is the duty of each employee to accept and follow established safety policies and procedures established by TIKIGAQ.

Knowledge of an unsafe act or condition does not make the work safe. When an act or work area condition is identified that is not consistent with the established practices of TIKIGAQ, it is the inherent responsibility of each employee to report such inconsistencies to a line supervisor so the act or condition may be evaluated, corrected, controlled, or engineered to a status that does not pose a significant threat. Where an act or condition in the workplace is determined to be Immediately Dangerous to Life and Health of TIKIGAQ employees, work must stop until the condition has been abated. No employee shall be required to work at a location that would jeopardize their life, health or general safety. Employee cooperation in detecting, controlling, and reporting workplace hazards is a condition of employment. It is critical for TIKIGAQ employees to immediately inform their line supervisor of any situation or work area condition that is beyond their ability to correct or control. Employees will not be disciplined or suffer any retaliation for reporting acts or conditions that are not consistent with the policies and procedures outlined by the TIKIGAQ health and safety program or project specific health and safety documents. Every effort should be made to provide adequate training to employees; however, if an employee is ever in doubt about how to do a job or task safely, it is his or her duty to ask a qualified person for assistance. Fellow employees that need help should be assisted. Employees are expected to assist management in accident prevention activities. Everyone is responsible for executing their assigned duties in a safe and healthy manner. Every incident (including a near- miss) that occurs in the workplace shall be reported to a first-line supervisor, as soon as possible. Under no circumstances, except in the instance of emergency medical care, should an employee leave a work environment without reporting an accident, injury, or illness that occurs in the workplace. When a workplace accident, injury, or illness occurs, everyone is affected. The success and longevity of our program is directly related to maintaining a healthy and safe working environment for everyone. TIKIGAQ Corporate Health and Safety Program Plan, 11/09 1-2 “Success is Created by Positive Individual Contributions ”CUSTOMER SATISFACTION SAFETY EMPLOYEE PROJECT “PERFORMANCE “ TIKIGAQ Corporate Health and Safety Program Plan, 11/09 2-1 2.0 HEALTH AND SAFETY PROGRAM INTRODUCTI ON Every employer should have a written Health and Safety Program. While no "program" on its own can specifically guarantee an accident free work place, it is TIKIGAQ ’s intent to provide a place of employment which is free from recognized hazards that are likely to cause death or serious physical harm or illness to our employees. The TIKIGAQ Corporate Health and Safety Program (CHSP), has been prepared with the purpose of establishing corporate health and safety policies and procedures that can assist employees to recognize, and mitigate potential workplace hazards, conditions and acts that may be of danger to them or their your co-workers. These policies and procedures are not meant to replace Federal, State or other recognized safety standards, but have been developed to promote adherence to applicable Health and Safety standards, by providing the employee with a working, lay-persons guidance to implementing established health and safety requirements that may apply to the employee’s work environment. Additionally, the employee must be aware, that as a routine procedure, TIKIGAQ may prepare and implement site/facility specific Health and Safety Plans (HSPs) and/or Accident Prevention Plans (APPs). These HSPs/APPs routinely address specific site hazards and associated hazard control measures, as well as established policies and procedures that must be implemented on specific executable contracts/site work. Where such HSPs/APPs exist and are presented to the employee for use, it is the responsibility of the employee to abide by and execute the work practices, procedures and hazard control measures which have been established for this purpose.

TIKIGAQ strongly encourages employees to utilize this CHSP document as a general safety guide for periodically reference to promote a safe working environment for yourself and your fellow employees. 2.1 GENERAL PRINCIPLES The information in this CHSP document constitutes the TIKIGAQ injury and illness prevention program. While we cannot anticipate every workplace hazard, the general principals established by our CHSP should guide the execution of your assigned tasks. Every employee shall implement these general principles, as applicable to their daily assigned duties.

• Review the guidelines contained in this CHSP document in conjunction with site or facility specific HSPs/APP’ s and seek consultation or clarification from a line supervisor or designated TIKIGAQ Safety Coordinator (SC) on any information that is presented to the employee for use, for which they are unsure of. • Notify your line supervisor of any identified workplace conditions, acts and situations that are not consistent with the CHSP or other established policies and procedures so that the condition, act or situation can be evaluated and corrected. • Attend all company sponsored training and safety meetings.

• Read notices and warnings posted in the work environment.

• Follow the work place practices established by this CHSP and those that are presented elsewhere in the workplace. TIKIGAQ Corporate Health and Safety Program Plan, 11/09 2-2 • Participate in accident investigations, as requested.

• Accept responsibility for the safety of coworkers.

• Maintain all required documentation. Listen to instructions carefully.

2.2 CORPORATE HEALTH AND SAFETY PROGRAM OBJECTIVE It is the objective of TIKIGAQ to prevent employee accidents, injuries and illnesses, provide a place of employment free of all recognized hazards that will likely cause death or serious physical harm to our employees and to surpass the best performance criteria of others, having similar operations. This objective is facilitated by developing and administering an overall Health and Safety Program which implements its established policies, procedures to serve as vehicles through which program and project/facility level requirements are met and hazard control measures are engaged.

TIKIGAQ’s objective of incurring zero accidents, injuries and illnesses in the workplace can only be achieved if all employees work together to keep ― Safety First‖ . Assigned employee tasks and contract/project work must be conducted in a manner that minimizes the probability of near misses, injury, illness and equipment/property damage.

TIKIGAQ considers safety and health of its employees the highest priority during work at all activate project/facility sites and its business of fices, but only each individual employee’s effort can help achieve our goal of zero accidents, injuries and incidents, on an annually basis.

2.3 PROGRAM EFFECTIVENESS Every effort must be made to provide adequate training to employees. However, if an employee is ever in doubt about how to do a job or task safely, it is his or her duty to ask a line supervisor for help. Employees are expected to assist management in accident prevention activities and immediately report identified acts or conditions, which are not consistent with ou r established protocols or standards applicable to our industry. Fellow employees that need help should be assisted. Everyone is responsible for the housekeeping duties that pertain to their jobs. Every incident (including a near-miss) that occurs on the job, even a slight cut or strain, shall be reported to the line supervisor as soon as possible. Under no circumstances, except emergency trips to the hospital, should an employee leave the work site without reporting a work-place accident, injury or illness.

2.4 POSITION STATEMENT ON MODIFIED WORK ASSIGNMENTS If an employee should become be injured or ill in the course of and arising from his or her assigned duties, TIKIGAQ will attempt to provide modified work. Modified work (―light duty‖, ―restricted‖ or ―temporary reassignment‖) will be made available in order to bring the injured employee back to the work environment, for the benefit of the employee and the company, whenever medically appropriate.

Employees are expected to return to a modified work condition whenever medically capable.

The work assigned to an employee who has experienced a workplace injury or illness will meet the restrictions set forth by the treating and/or attending physician. Examples of modified work include but are not limited to office work, dispatching, project support roles, or light ―shop work‖. Modified work assignments shall only be in accordance with conditions deemed appropriate by the treating and/or attending physician. Supervisors, managers or human TIKIGAQ Corporate Health and Safety Program Plan, 11/09 2-3 resource personal should advise or even require employees to who have experienced a work place injury or illness to seek the medial attention and advice of medical occupational physicians/therapists, as may be allowed by TIKIGAQ policy or appropriate to the situation.

However, in certain workplace injuries or illnesses case it may also be necessary to seek the assistance of medical specialists, who are not necessarily experienced with workplace injury/illness requirements. When an employee returns to work on a Modified Work Assignment basis, they will be required to have the attending or treating physician complete the TIKIGAQ ―Return to Work Authorization‖ form included in Attachment 1 of this CHSP document. 2.5 PRIMARY CORPORATE HEALTH AND SAFETY PROGRAM FUNCTIONS Following are the primary functions of the TIKIGAQ CHSP: Provide lay-persons guidance to implementing established health and safety requirements that may apply to the employee’s work environment. Define the health and safety responsibilities of TIKIGA Q personnel. Administer the medical surveillance program, as applicable to an employee’s assigned duties (i.e. Hazardous Waste Operations, respirator Use, potential exposure to certain chemical products) Where applicable, ensure that any site/facility specific Health and Safety Plan (HSP) or Accident Prevention Plan (APP) documents are prepared for executable contract or site/facility specific work that identify project hazards, present appropriate hazard control measures to mitigate identified hazards, and establish guidelines by which program/project participants shall be expected to operate. Establish a basic understanding for the need of appropriate employee safety training. Provide basic safety procedures and protocols to be implemented by employees in their work environment. Establish means and methods for conducting incident reporting and accident investigations. Provide a basic awareness for employees to continually strive toward achieving adherence to applicable Health and Safety regulatory or contract requirements, as applicable to executable contract work. Establish safety and health consciousness for employees and to consistently strive toward our corporate goal of experiencing Zero workplace injuries, illnesses and accidents. Provide our clients with a responsible, well-trained, oriented work force that can perform assigned tasks in a healthy and safe manner, while also balancing the need to meet overall client objectives and completing projects/assigned work on-time and within budget. TIKIGAQ Corporate Safety Program, 11/09 3 -1 3.0 RESPONSIBI LITIES The following sections describe the roles and responsibilities of management, line supervisors and employees for the purpose of creating a safe working environment for all TIKIGAQ personnel. 3.1 MANAGEMENT RESPONSIBILITIES The effectiveness of the TIKIGAQ CHSP depends on the attitude, approach and commitment projected by our Senior Management team to foster a strong safety culture throughout the organization. It should be a primary focus for all TIKIGAQ management staff to continually strengthen our safety culture by conducting themselves in a manner that facilitates our commitment to providing a safe working environment for our employees. Management teams must endeavor to achieve this objective by:

1. Providing the leadership, commitment, means and methods (i.e. personnel and budget resources) for subordinate employees to remain consistent with the policies and procedures of our CHSP; 2. Enforcing polices established by this CHSP and other established corporate initiatives by guiding and warning, reprimanding or potentially discharging, if necessary, any employee who willfully disregards them; 3. Requiring that TIKIGAQ subcontractors abide to health and safety processes established by site/facility specific requirements with the intent of them experiencing consistency with safety standards established by Federal or State agencies which are applicable to their assigned work. This must include notifying the subcontractor and documenting acts or conditions which are not consistent with industry standards or protocols; 4. Ensuring that that subordinate personnel who are responsible for selecting subcontractors, perform a review of applicable subcontractor safety related data to support the selection of qualified subcontract personnel; 5. Monitoring the activities and performance of subordinate personnel and enacting necessary action to correct workplace conditions or actions that are not consistent with TIKIGAQ’ s CHSP, industry health and safety standards and established workplace harassment or Equal Employee Opportunity (EEO) polices.

6. Requiring that routine daily and/or periodic health and safety overviews are conducted at TIKIGAQ project/facility specific locations through-out all phases of executable work, but especially when the project begins, as new tasks are planned or as new project hazards are identified; 7. Requiring investigations and complete reports on all workplace accidents, injuries and illnesses; 8. Providing the means and methods of executing employee health and safety training in accordance with established Federal, State or Local standards that are applicable to our work; 9. Assuring necessary support and insisting employees work in a manner which is consistent with our CHSP policy and procedures and spirit of TIKIGAQ’s culture . TIKIGAQ Corporate Safety Program, 11/09 3 -2 10.

By continually reviewing prospective employee candidate qualifications and only hiring those individuals which exhibit the proper attitude, professionalism and potential skill to perform in a manner which is consistent with the reasonable expectations of TIKIGAQ.

3.1.1 President The President administers the execution of all corporate objectives on behalf of the TIKIGAQ Corporation, and its duly authorized subsidiaries. The President reviews, promotes and delivers new or modified corporate policies, procedures and objectives, as necessary, for review and approval by the TIKIGAQ Board of Directors. The President reports to the TIKIGAQ Board of Directors on all matters that affect or would potentially affect overall corporate operations and safety objectives.

3.1.2 Chief Operating Officer The Chief Operating Officer (COO) is responsible for overseeing all corporate operations and ensuring that TIKIGAQ’s management teams are executing corporate operations and objectives in a fiscally responsible manner that is safe, efficient and consistent with corporate objectives, policies and procedures, business partner agreements. The COO supports all TIKIGAQ General and Regional Manager operations and promotes the development and delivery of new corporate policies, procedures and objectives to the President for review. The COO reports to the President on all matters that affect or would potentially affect overall corporate operations and safety objectives. 3.1.3 General or Regional Managers The TIKIGAQ Subsidiary General or Regional Manager is the primary operational safety official for each division of TIKIGAQ and has overall responsibility for ensuring that TIKIGAQ employees adhere to the health and safety policies and procedures established by TIKIGAQ. 3.1.4 Human Resource Manager T he TIKIGAQ Human Resource Manager (HRM) supports the implementation of Equal Employee Opportunity (EEO) requirements, proper employee hiring and termination procedures, internal review of conditions that violate corporate policy on sexual harassment and work place violence, management of employee benefit packages and coordination of any worker compensation cases. With this regard, it is imperative that the HRM be notified of any work place accidents, injuries and illnesses or situations that affect these responsibilities.

3.2 LINE SUPERVISOR RESPONSIBILITIES Line supervisors are entrusted with special duties concerning the safety and health of TIKIGAQ employee ’s. Line Supervisors are critical links to the success of the TIKIGAQ injury and illness prevention program. Some of their responsibilities are as follows:

1. Implementing the aspects of the health and safety program, especially pertaining to individual project site(s)/facility requirements; TIKIGAQ Corporate Safety Program, 11/09 3 -3 2.

Recognizing and taking action on health and safety hazards which are or are likely to cause death or serious physical harm to subordinate employees; 3. Conveying hazard information, to which you identify or are advised of, to subordinate employees at the contract project site or facility locations; 4. Investigate or assist with the investigation of accidents, injuries and illness, that occur under their supervision at the contract project site, in accordance with the accident investigation procedures identified by the CHSP; 5. Implementing routine pre-job safety overviews at TIKIGAQ contract project locations as the project begins, as new tasks are planned, as new project hazards are identified or when new project team members are assigned to the project site; 6. Taking prompt action to correct identified acts or conditions that are not consistent with established health and safety requirements that are personally observed by a line supervisor or brought to the attention of a supervisor; 7. Providing adequate pre-project planning to allow for the effective procurement of appropriate equipment, materials, safety related systems or documents to facilitate the execution of project tasks or individual assignments in a healthy, safe and efficient manner; 8. Promoting and ensuring an appropriate project safety culture for subordinate employee’s by positive example; and 9. Stopping or correcting questionable acts or identified conditions, especially those that represent an Imminent Danger or Immediately Dangerous to Life and Health situation.

3.2.1 Project/Facility Managers The TIKIGAQ Project/Facility Manager is responsible for supporting the acquisition of adequate resources (budget and staff) for implementation of required project or facility specific related operations. The Project/Facility Manager has overall management responsibility for identified project or facility specific functions. The Project/Facility Manager may explicitly delegate specific tasks to other staff, but retains ultimate ly responsible for completion of the f ollowing: Development or lead the development of detailed technical documents or performance specifications that will be included subcontractor Statement of Work (SOW)/Request for Quote (RFQ) packages that are prepared by subcontractor procurement specialists. Such documents shall also address applicable health and safety, quality control, drug free workplace and site or facility specific security requirements. Select qualified and competent subcontractors by ensuring that subcontractor pre- qualification questionnaires ( See Attachment 2 ) have been received and reviewed by a subcontractor procurement specialist and Safety Coordinator, as necessary. Note: The Chief Operating Officer (COO), General or Regional Manager, can for valid reason, waive this requirement for low risk subcontractor work (i.e. surveying, consulting, geophysical surveys). Work in non-remote or harsh environment locations, may not be subject to this waiver. Subcontractor operations that are not performed at site/facility specific locations (i.e. off-site) may also be excluded from this requirement. TIKIGAQ Corporate Safety Program, 11/09 3 -4 Ensuring that acceptable certificates of insurance, including TIKIGAQ as named additional insured, are secured as a condition of subcontract award. Including H&S deliverables identified in subcontract agreements, and ensuring that appropriate site-specific safety procedures, training and medical monitoring records are reviewed and accepted prior to the start of subcontractor’s field operations. Prior to the start of Subcontractor work, verify that all Subcontractor deliverables have been received and are in the project file. These deliverables include but are not limited to the following: work plans, certificates of insurance (including TIKIGAQ as named additional insured), bond, applicable Subcontractor licenses, training and medical monitoring records or drug screen confirmation, and site-specific health and safety plans. The Project/Facility Manager shall verify that key project team members have or have access to these deliverables. These functions, by nature, are normally delegated to the Contract Administrator/procurement coordinators but remain the responsibility of the Project Manger to verify appropriate documents are in place prior to the start of subcontractor work. Oversight of subcontractor H&S practices by ensuring qualified supervisory personnel is available at the project or facility. Manage the site/facility operations and interface with third parties in a manner consistent with our contract and subcontract agreements and the applicable standard of reasonable care. Ensure that both the overall program and project/facility specific H&S requ irements and goals are fully are consistently implemented.

3.2.2 Line Supervisors Line Supervisors (i.e. site/facility supervisors, forepersons or project field team leaders) are site or facility specific employees that are entrusted with special duties concerning the safety and health of TIKIGAQ employees under their supervision. They are critical links to the success of the TIKIGAQ injury and illness prevention program and are key comments to achieve assisting with corporate loss prevention goals. Some of the l ine supervisor’s responsibilities are as follows:

 Implementing the aspects of the CHSP program and site/facility specific HSPs/APPs and other health and safety documents;  Recognizing and taking action on safety and health hazards which are causing or are likely to cause death or serious physical harm to subordinate employees;  Verifying that required project/facility postings (federal, state, program specific, wage determinations) are posted in a conspicuous locations that all site/facility personnel have access to.  Conveying hazard information and specific project or facility requirements to subordinate employees;  Investigating or assisting with the investigation of accidents, injuries and illness, that occur under at the contract project sites or sites under control of TIKIGAQ, in accordance with TIKIGAQ Corporate Safety Program, 11/09 3 -5 the accident investigation procedures identified by the program (as deemed appropriate to the incident by corporate officials);  Imp lementing routine pre-job safety overviews at TIKIGAQ contract project locations when site or facility operations begin, new tasks are first initiated , as new project hazards are identified or if new project team members are assigned to the project site;  Taking prompt action to correct identified acts or conditions which are personall y observed by a line supervisor or brought to the attention of a line supervisor by a employee under their tenure;  Providing adequate pre-project planning to allow for the effective procurement of appropriate equipment, materials, safety related systems or documents to facilitate the execution of individual project tasks in a safe and efficient manner;  Promoting and ensuring an appropriate project safety culture for subordinate employee’s by positive example; and  Stopping or correcting questionable acts or identified conditions that are under a supervisor’s responsibility and which are inconsistent with established safety standards, TIKIGAQ ’s policies and procedures and requirements established by site or facility specific HSPs/APPs or industry regulations, where applicable.

3.3 SAFETY COORDINATOR RESPONSIBILITIES A Safety Coordinator also referred to as a Corporate Health and Safety Officer (CHSM), Health and Safety Officer (HSO)/Health and Safety Program Administrator (HSPA) or Site Safety and Health Officer (SSHO) is an individual designated by TIKIGAQ’s management team to perform or assist with the following responsibilities:

1. Assist employees at all levels with understanding and implementing the TIKIGAQ CHSP, project/facility specific or regulatory health and safety requirements ; 2. Assist with implementing employee training and awareness programs at all levels; 3. Investigate or assist with investigation of any accident, injury, illness or dangerous occurrence and recommend means of preventing recurrence; 4. Develop, assist or support the implementation of safety related documents, materials, procedures or research that may be needed by management, line supervisors or other employees that which may be required to help these personnel established health and safety requirements; 5. Promote employees awareness and use of available safety related documents or other applicable information that will facilitate the employee in creating workplace environments that are consistent with the CHSP or other applicable health and safet y requirements; 6. Attend project meetings or briefing s, as requested, to support management functions; 7. Carry out site surveys to ensure that health and safety protocols are being implemented at all levels and are consistent with specific project contract/facility requirements and TIKIGAQ CHSP obligations. Report on project/facility safety performance to management, as needed; TIKIGAQ Corporate Safety Program, 11/09 3 -6 8.

Ensure that all health and safety support materials and equipment are adequate and properly maintained; 9. Assist with or otherwise perform, depending on employee title, the recording and analysis of information on injuries, illness and property damage and review overall safety performance; 3.3.1 Corporate Health and Safety Manager The TIKIGAQ Corporate Health and Safety Manager (CHSM) is responsible for the overall implementation of Corporate Health and Safety program policies, procedures and objectives and his/her responsibilities include the following: 1) Developing health and safety policies, procedures, support documents, new corporate objectives and promoting corporate approval, where necessary.

2) Implements and maintains record keeping requirements associated with employee injury, illness and lost work day cases as related to 29CFR1904.

3) Reviews employee medical surveillance documents/results and assists with recommendations to the Human Resource Manager (HRM) for employee/physician follow-up and/or administrative control procedures where certain employee medical conditions are ―flagged‖ or represent areas of ―concern‖ by the designated TIKIGAQ occupational physician(s).

4) Assi sting management, Health and Safety Officers (HSOs)/Health and Safety Program Administrator(s) (HS PAs), and Site Safety and Health Officer(s) (SSHO) and other em ployees in determining health and safety and trainin g needs for employees based on an employee’s job duties or assignments including supporting the implementation of health and safety training curriculum.

5) Reviewing r egulations to determine applicability for TIKIGAQ ’s health and safety training program and updating existing training goals and requirements to ensure that requirements for employee training meet the in tent of the regulations and commu nicate TIKIGAQ policies an d procedures.

6) Coord inatin g with General or Regional Managers or HSOs/ HSPAs to ensure a nnual training sch edules and goals are met; 7) Assessi ng implementation of the training and medical surveillance program an d developing corrective measures to address identified de ficie ncies; 8) Evaluate, coordinate and assist with the development of adequate employee health and safety trainin g and medical surveillance budgets, where necessary, with General or Regional Managers. 9) To only provide consultation on topics in areas where the individual is qualified by education, experience or demonstrated competency in the specific technical fields involved or to sufficiently research and otherwise seek out technical assistance fro m others, outside sources which allows the CHSM to a to provide valid consultation.

3.3.2 Health and Safety Officer/Health and Safety Program Administrator As TIKIGAQ operations expand, the corporation and its subsidiaries may assign various health and safety professions into key positions for the purposes of administering and or supporting TIKIGAQ Corporate Safety Program, 11/09 3 -7 the implementation of established health and safety requirements for various areas of operation. These authorized health and safety professionals are typically referred to as a Health and Safety Officer ( HSO) or a Health and Safety Program Administrator (HSPA). These safety professionals will assist with the administration of program or project/facility specific health and safety requirements on behalf of TIKIGAQ and their subsidiaries. These health and safety professionals typically support the General or Regional Manager and employees under General and Regional Manager’s ten ure the in their Area of Responsibility (AOR) and CHSM with regard to TIKIGAQ program and project related matters. The HSO/HSPA is responsible for supporting and assisting program staff at all levels to so that employees may engage their assigned duties in a manner which is consistent with established health and safety r equirements. The HSO/HSPA’s responsibilities include the following: Supplementing duties performed by the CHSM, except in the following areas: Record keeping requirements associated with 29CFR1904. Review of employee medical surveillance documents/results. Promoting corporate approval of newly developed policies, procedures and objectives, where necessary. Prepare project specific H&S documents such as site/facility specific HSP/APPs related su pport documentation (i.e. AHAs) and approve for use as necessary, these documents for specific site or facility use within their AOR or in accordance with requested management support. To only provide consultation on topics in areas where individual s are qualified by education or experience, or demonstrated competency in the specific technical fields involved. Where support must be provided on areas where the HSO/HSPA is not technically competent they will seek out technical assistance from other outsid e ven dors or sufficiently research a topic and/or get consultation in a manner which allows the HSO/HSPA to a to provide valid consultation. Support and assist staff with the execution the H&S policies and procedures established by TIKIGAQ for project implementation, including the implementation of Behavior Based Loss Prevention System (BBLPS) and other risk management processes. Support the designated TIKIGAQ SSHO’s oversight of subcontractor (and lower -tier subcontractors) H&S practices and interfaces with third parties, as necessary. Coordinate with General or Regional Managers in their AOR to schedule and sponsor employee training courses and fulfill medical surveillance program requirements, for the employee’s benefit, based on the needs of the employees in their AOR and on an as needed basis, by outside vendors. Identifying and securing outside training vendors, as needed, in their AOR to provide external training not conducted internally or by established contrac t training ven dors. Developing, participating, and delivering, as needed, training material and supporting the logistics of the presentation of in house TIKIGAQ sponsored training sessions. Provides consultation and direction to project staff with regard to H&S program/project specific requirements and worker exposure prevention measures. TIKIGAQ Corporate Safety Program, 11/09 3 -8 Review subcontractor pre-qualification questionnaires that fall outside standard performance criteria that can be comfortably evaluated by the Contracts Administrator (KA) teams. Review subcontractor training records and site-specific safety procedures prior to start of subcontractor’s field operations, when requested. Support the SSHO’s oversight of subcontractor (and lower -tier subcontractors) H&S practices and interfaces with third parties, as necessary. Maintain H&S training certificates that may be generated by company sponsored training requirements. Perform the same duties and responsibilities as the SSHO, when assigned this function. 3.3.3 Site Safety and Health Officer (SSHO) The Site Safety and Health Officer (SSHO) is responsible for facilitating the administration of established health and safety procedures and protocols at the project site(s) level. The SSHSO may be a safety professional, manager, line supervisor or other designated employee with the tr aining, skills, experience, demonstrated qualities and professionalism to act in this capacity.

The SSHO is the primary health and safety representative at the site/facility working level.

The responsibility for the implementation health and safety is delegated and shared by Project/Facility Manager s, site/facility line supervisor and subcontractors' supervisor, but the SSHO supports these individuals in the implementation of site or facility specific health and safety requirements. At a minimum, the SSHO must perform, or otherwise supervise the performance of, the following: Verifying the site/facility specific Health and Safety Plan (HSP)/Accident Prevention Plan (APP) remains current and amended when project activities or conditions change; Verify TIKIGAQ Site personnel and subcontractor personnel read, or have been briefed on the contents of site/facility specific HSP/APP , and sign ―Employee Acknowledgement Form‖ prior to commencing field activities; Verify TIKIGAQ Site personnel and subcontractor personnel have completed any required specialty training (e.g., fall protection, confined space entry) and medical surveillance requirements prior to starting work; Verify adherence with the requirements of the site/facility specific HSP/APP and applicable the subcontractor’s health and safety plan(s). Act as the project ―Hazard Communication Coordinator‖. Act as the project ―Emergency Coordinator‖, when designated by the site/facility line supervisor or foreperson, and perform any responsibilities outlined in the site/facility specific HSP/APP or as maybe required to properly coordinate the on-site response of emergencies, as they arise. Verify that required work phase meetings are conducted at least daily, or more frequently as project tasks or hazards change, and the contents of such meetings are documented for th e project record in accordance with the elements of the Behavior Based Loss Prevention System (BBLPS) and verify that other components of the Risk Management Process (RMP) are being implemented, as intended. TIKIGAQ Corporate Safety Program, 11/09 3 -9 Verify that specific H&S forms and permits, found in are being used as required. Verifying Site-specific safety procedures are available or have been executed prior to start of subcontractor’s field operations. Interface with third parties in a manner consistent with our contract/ subcontract agreements, on an as needed basis. Coordinate with the site/facility line supervisor, Project/Facility Manager, HSO/HSPA, as necessary, regarding subcontractor operational performance or third-party interfaces. Assist with the overall implementation of project/facility-specific and program H&S goals. To only provide consultation on topics in areas where the individual is qualified by education or experience, or demonstrated competency in the specific technical fields. Where support must be provided on areas where the SSHO is not technically competent they will seek out technical assistance from other outside vendors or research a topic and/or get consultation in a manner which allows the SSHO to a to provide valid consultation. The SSHO is responsible for coordinating with the TIKIGAQ site/facility line supervisor and Project/Facility Manager. In general, the Project/Facility Manager will contact the client in the event accidents, injuries or property damage occurs on the project Site. The Project/Facility Manager, General or Regional manager, HSO/HSPA(s) and CHSM may also be contacted by the SSHO, when appropriate to the situation.

3.4 EMPLOYEE RESPONSIBILITIES Every Employee , regardless of job title, shares the responsibility for health and safety and must report any co -worker acts or site/facility work conditions that are not consistent with this CHSP, site/facility specific HSP/APPs or other health and safety requirements that have been expressed to the employee, without fear of reprisal. It is imperative that employees observe the following minimum requirements in order to achieve a safe and healthy workplace:

2.4.1 Safety Rules for All Employees Each employee this is taking any prescription or over the counter medications that could alter the manner in which they could be treated in an emergency or effect their job performance/safety or other employees in the work environments (i.e. via heavy equipment operations) shall notify their line supervisor prior to beginning work. Each employee must familiarize themselves and abide by the contents this CHSP and any project/facility specific HSP/APP and will implement and follow health and safety requirements, communicated to them in the workplace. All employees will wear the necessary Personal Protective Equipment (PPE) required by this CHSP, site/facility specific HSP/APP, delivered in training or established dress code policy, as applicable. Suitable clothing and footwear shall be worn at all times.

Personnel at pro ject or facility sites shall wear shirts with a minimum 6‖ long sleeve (i.e.

no tank tops or ¼‖ sleeve shirts) and shall not bear any language that could be considered offensive. Hard toe footwear, providing sufficient ankle support (i.e. with lacing), and preferable constructed from leather, shall be worn. For demolition, welding or cutting operations boots must be made of leather and should have steel shank TIKIGAQ Corporate Safety Program, 11/09 3 -10 protection. For ground personnel involved in demolition operations performing cutting tasks, metatarsal projection should be provided. Employees shall follow good personal hygiene practices and wash thoroughly after handling hazardous substances, and follow special instructions or procedures which may be outlined in site/facility specific HSP/APPs. The employee will notify their immediate line supervisor of any potential workplace condition or act that is not consistent with the TIKIGAQ health and safety policies and procedures or industry standards and which could result in an accident, injury, illness, or destruction of property. The employee will report all workplace accidents, injury, illnesses or property damage to their line supervisor regardless of the severity so that arrangements can be made for medical or first aid treatment or other actions needed to respond to the identified situation. This includes all near misses (accidents without injury, illness or property damage). If an employee is injured or becomes ill as a result of work related operations, action shall be promptly taken to see that the employee receives appropriate medical treatment. At no time should an employee who becomes injured or ill in the work place leave the work place without notifying their line supervisor, EXCEPT in the case where emergency medical attention is required. Managers, supervisors and safety coordinators shall actively promote a safe and healthful work place environment by implementing TIKIGAQ ’s CHSP policies and insisting that employees under their supervision follow established health and safety requirements set forth by TIKIGAQ or industry standards. Housekeeping must be practiced at all times in the work area. Actively clean up waste materials and eliminate any perceived hazards in the work environment. In appropriate site/facility housekeeping measures can be considered as a basis for OSHA citations. All employees will participate in scheduled safety meetings. All employees shall observe and follow the conditions of the TIKIGAQ Drug Free Work Place (DFWP) Program. Anyone under the influence of alcohol or drugs, including prescription drugs which might impair motor skills, job performance and judgment or potentially impact the safe execution of assigned tasks, shall not be allowed to work environment and subject to disciplinary actions in accordance with TIKIGAQ policy. There will be no consumption of alcohol or any type on the job, including lunch periods. TIKIGAQ reserves the right to implement drug and alcohol testing for reasonable suspicion or probable cause, where there has been a workplace accident or injury or were property damage occurs in excess of $1,000.00 (US currency). No one shall be permitted to work while the employee's ability or alertness is so impaired by fatigue, illness, or other causes that it might expose the employee or others to injury. ― Horseplay ‖ , scuffling, and other acts that tend to have an adverse influence on the well-being of the employee or their co-workers is prohibited. TIKIGAQ Corporate Safety Program, 11/09 3 -11 To the extent possible, employees must work in a well planned and supervised manner to avoid accidents, injuries, illness or property damage. Employees must ensure that that all guards and other protective devices on equipment or tools that they are operating are in proper condition. Any item that is identified as being deficient shall be reported to their line supervisor so that it can be removed from service, replaced or repaired to the manufacturer’s specified condition . Employees shall not handle or tamper with any electrical equipment or machinery in a manner not within the scope of their duties and training, experience or licensure. When lifting heavy objects, use the large muscles of the leg instead of the smaller muscles of the back. (i.e. ―lift with your legs, not your back‖). Do not throw things, especially materials and hand tools. Dispose of all waste properly and carefully. Report spills of hazard materials to a line supervisor. Employees shall not enter any confined spaces such manholes, underground vaults, chambers, tanks, silos, or other similar places that contains or has a potential to contain a hazardous atmosphere (chemical hazard or oxygen deficient or enrich environments), contains a material that has the potential for engulfing an entrant, 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 other recognized serious safety or health hazard, unless the employee has received the proper training, is authorized to do so and has been determined that it is safe to enter. Employees shall not enter into an excavation unless the excavation authorized by a competent person, the excavation is protected from cave-ins by adequate protective systems designed in accordance with applicable standards (i.e. Design of Sloping and Benching Systems and Design of Support Systems, Shield Systems and other Protective Systems) EXCEPT when excavations are made entirely in stable rock, or excavations are less than 5 feet (1.52m) in depth AND examination of the excavation and surrounding area by a competent person has performed and the competent personnel determines there is no indication of cave-in or other recognized hazard. An employee may only be designated as designated personnel for excavation operations by an officer of TIKIGAQ or its subsidiaries. Workers will avoid the use of extension ladders for carrying loads to elevated positions. No employee shall erect or work on scaffold systems unless they have been deemed competent by TIKIGAQ to do so, have had proper training and experience to do so and only after the scaffold system has been inspected daily (or more frequently as required) by a designated personnel. Any damage to scaffolds or other supporting structures shall be immediately reported to the scaffold competent person for re-inspection and repair, 9where necessary) before the system is reused. TIKIGAQ Corporate Safety Program, 11/09 3 -12 Understand that violations of published safety policies and procedures may be cause for disciplinary actions up to and including dismissal. TIKIGAQ Corporate Safety Program, 11/09 4 -1 4.0 ACCIDENT/INCIDENT NOTIFICATI ON AND INVESTIGATION PROCEDURES 4.1 I NTRODUCTION The information presented below defines the TIKIGAQ Corporation Accident/Incident Investigation and Reporting Procedures for all authorized TIKIGAQ work place environments .

The intent of this section is to establish a uniform method of reporting accidents and injuries involving TIKIGAQ employees, as well as incidents involving property damage.

4.2 POLICY All occupational illness or accidents resulting in employee injury or illness or damage to pr operty or equipment must be reported immediately, regardless of its severity. However, in accident/incident scenarios that requires immediate emergency medical treatment; it is imperative that prompt medical attention be secured for the employee first and then execute the TIKIGAQ Incident Reporting Process identified in section 5.5 of this CHSP. Prompt, accurate reporting combined with effective investigations and implementation of identified corrective actions is essential to preventing accident recurrence.

Line supervisors of employees involved in accidents must ensure that the employee's medical needs are met, that the accident is investigated, that corrective actions are initiated, and that the required incident notification and investigation reports are completed.

4.3 DEFINITIONS The following definitions are related to incident reporting.

First Aid —First aid is any one-time treatment, and any follow-up visit for the purpose of observation, of minor scratches, cuts, burns, splinters, or care otherwise defined by 29CFR1904.7(b)(5)(ii), which do not ordinarily require medical care, even though provided by a physician or registered professional personnel.

Loss Incident (INCIDENT) — A loss incident is an unplanned event that results in an injury or illness, equipment or property damage, spill, leak, motor vehicle accident and/or regulatory violation where a resource or monetary loss occurs. Lost Workdays —The number of days (consecutive or not) after, but not including, the day of injury or illness during which the employee would have worked but could not do so; that is, could not perform all or part of his/her normal assignment during all or any part of the workday or shift; because of the occupational injury or illness.

Medical Treatment —Medical treatment includes the management and care of a patient to combat disease or disorder and as defined by 29CFR1904.7(b)(5)(i). Medical treatment may also be considered care even when it’s provided by someone other than a physician or other licensed health care professional.

Multi-employer work site (MEWS) —A multi-employer work site, is defined as a location in which many employers occupy the same site. For purposes of issuing OSHA citations for a violation of a work place standard on a MEWS, OSHA considers the prime or genera l contractor to be the ―controlling employer‖ and is the employer who is responsible, by contract or through actual practice, for health and safety (H&S) conditions on the worksite or has the TIKIGAQ Corporate Safety Program, 11/09 4 -2 authority for ensuring that hazardous conditions are corrected.

On a MEWS, the ―exposing employer‖ is the employer whose employees are exposed to the hazard, while the ―creating employer‖ is the employer who actually creates the hazard. A ―correcting employer‖ is the employer who has the responsibility for actually correcting the hazard.

Near-Loss Incident — A near-loss incident is an unplanned event that could have resulted in a loss incident. Near- loss incidents may also be referred to as ―near misses‖. O ccupational Injury is any occurrence which results from a work accident or from an exposure involving a single incident in the work environment, i.e., cuts, fractures, sprains, strains, concussions, burns, etc. NOTE: Conditions resulting from animal bites or from onetime exposure to chemicals are considered to be injuries.

Occupational Illness of an employee is any abnormal condition or disorder, other than one resulting from an occupational injury, caused by exposure to environmental factors associated with employment. It includes acute and chronic illnesses or diseases which may be caused by inhalation, absorption, ingestion, or direct contact. Operating Envelope — An ―operating envelope‖ around a crane is any area which includes the operator and the crane, riggers, rigging gear between the hook and the load, the load and the crane’s supporting structure (ground, rail, etc.). Qualified Person —An individual who, by possession of a recognized degree, certificate, or professional standing, or extensive knowledge, training, and experience, has successfully demonstrated his or her ability to solve or resolve problems related to the subject matter, the work or the project.

Serious Accidents —Any work-related incident, which results in, a fatality, in-patient hospitalization of three or more employees, or property damage in excess of $200,000.

Significant Accident —Any accident which involves falls of 1.2 m (4 feet) or more, electrical accidents, confined space accidents, diving accidents, equipment accidents, crane accident or fire accidents, which, result in property damage of $10,000 or more, but less than $200,000; or when fire department or emergency medical treatment (EMT) assistance is required.

Work Environment is comprised of the physical location, equipment, materials processed or used, and the kinds of operations performed by an employee in the performance of his work, whether on or off the employer's premises.

4.4 TIKIGAQ I NCIDENT NOTIFICATION AND REPORTING PROCESS In the event that an accident, injury, illness or property damage (i.e. INCIDENT) occurs at a project or facility site, the TIKIGAQ line supervisor will immediately notify the Project/Facility Manager of any incidents that occur at the site/facility that the line supervisor has responsibility for. In the event the site/facility line supervisor is injured, the SSHO or any other employee shall notify the Project/Facility Manager. However, in all site or facility incidents, providing necessary employee medical attention and securing the job site (to the extent possible) are always first priorities. 1.

Employees shall promptly report ALL occupational illnesses, injuries, near misses, and damage to property and/or equipment (or INCIDENTS) to their immediate supervisor REGARDLESS OF HOW MI NOR . TIKIGAQ Corporate Safety Program, 11/09 4 -3 2.

Under no circumstances, except in the instance of emergency medical care, should an employee leave the work site without reporting an injury, illness or other incident that occurs in the work place.

3. It is the responsibility of the site or facility line supervisor to ensure that the TIKIGAQ Project/Facility Manager, Corporate Health and Safety Manager (CHSM) and General or Regional Manager are notified of any workplace incident as soon as possible after the incident occurs. This process may be initially completed via verbal notification, followed by written notification by using the IRF forms included in Attachment 3 of this CHSP following the procedures identified in sections 4.6 of this CHSP, as applicable to the incident. In incidents where ―medical treatment‖ has or must be provided to a TIKIGAQ employee, it is extremely important the verbal notification be made to the TIKIGAQ management team as soon as possible. In non-life threatening or ―minor injury‖ cases, the employee, CHSM or regional HSO/HSPA may be able consult with the physician or person providing treatment, to determine if simple ―first aid‖ treatment measures are appropriate versus ―medical treatment‖ options. However, in doing so, the HSO/HSPA must not in any way , interfere with the medical treatment process of the employee. The CHSM (or designee specifically authorized by the CHSM) will handle all OSHA reporting requirements of occupational injuries or illnesses. 4.

For all work place injuries, illnesses and property damage incidents, TIKIGAQ management, SSHO, line supervisor or the designated HSO/HSPA will conduct an in cident investigation to establish the root cause(s) of the Incident, in accordance with the procedures identified in section 4 .5 ―Procedures for Accident/Incident Investigation‖. 5. For ALL incidents (employee injury, illness, near loss events, environmental spills or releases or property damage), an Incident Report Form (IRF) ( Attachment 3) and shall be filled out as soon as possible after the incident occurs, but no later than 24 hours from the time of the incident. The IRF shall be completed using the procedures section 4.6 of this CHSP. 6. The required IRF document ( Attachment 3) will be completed by the site or facility line supervisor, SSHO or other qualified designee within 24 hours of the incident and delivered to the Project/Facility Manager. The PM will forward the IRF documents to the CHSM, and the General and Regional Manager, or COO, as necessary, for joint review by the designated TIKIGAQ management team. The determination of an incident’s status will be evaluated in accordance with the requirements of 29CFR1904.

7. Upon completion of an incident investigation and IRF, a Root Cause Analysis (RCA) shall be performed using the instructions identified in Attachment 3 and submitted with the final IRF form.

8. All information contained on the IRF or RCA documents should be factual as to how the incident occurred, or as the incident was observed. See section 4.5, of this CHSP ―Procedures for Accident/Incident Investigation‖ and section 4.5.1 ―Best Management Practices for Accident/Incident Investigation‖ for appropriate procedures for performing an incident investigation. .

9. Upon review of investigation results, the CHSM, or designee, and the TIKIGAQ management team shall jointly review appropriate response measures or corrective TIKIGAQ Corporate Safety Program, 11/09 4 -4 actions that may need to be implemented, based on the information generated from a review of the incident. Designated Client representatives shall be notified of any site or facility specific incident in accordance with the conditions of the prime contract.

10. Final versions of all completed I RF’s, and , RCA forms or other client required incident reporting forms will be completed by the site or facility line supervisor or SSHO and submitted to the project management team for review and submitted to the client (as necessary), the project records and the TIKIGAQ Human Resource Manager once they have been finalized. Where it is alleged that TIKIGAQ facilities or equipment involved were defective, TIKIGAQ site/facility line supervisors, SSHO or regional HSO/HSPA may conduct an independent investigation for its own evaluation, as directed by the CHSM and General/Regional Manager.

Investigation notes, forms, photos, witness statements and area map if applicable are to be submitted to TIKIGAQ's CHSM for review.

In addition to TIKIGAQ incident reporting processes, it is important for the site/facility manager to understand any client contract, site or facility specific incident reporting processes to flow these incident reporting processes down to the site or facility line supervisor for implementation. For instance, with certain government or Department of Defense (DOD) funded work; completion of a Contractor Significant Incident Report (CSIR) form may also be required for significant or serious accidents (i.e. OSHA recordable accidents and property damage in excess of $2,000.00). Typically, these documents are completed by the site or facility line supervisor, SSHO or Project/Facility Manager and forwarded to the TIKIGAQ upper management team. Upon completion of any client, contract, site or facility specific required incident report documents, they will be reviewed by the TIKIGAQ management team (i.e.

Project/Facility Manager, general or regional manager and COO, as necessary). Once review is complete by the management team, they can be forwarded to the Client POCs as required by the prime contract conditions. To meet client reporting criteria an expedited review process by management may be required.

Figure 1, below identifies a graphical flowchart of the TIKIGAQ Incident Reporting Process. TIKIGAQ Corporate Safety Program, 11/09 4 -5 FIGURE 1 4.4.1 Overall Summary of Incident Procedures Table 1, below, identifies a step by step process for completing the TIKIGAQ Incident Action Procedures. TIKIGAQ Incident Notification & Reporting Process TIKIGAQ COO TIKIGAQ or TIKIIGAQ subsidiary General or Regional Manager TIKIGAQ Corporate Health & Safety Manager TIKIGAQ or TIKIGAQ Subsidiary Responsible Project or Facility Manager TIKIGAQ or TIKIGAQ subsidiary Site or Facility Line Supervisor Accident, Injury, Illness or Property Damage or near miss incident involving a TIKIGAQ or TIKIGAQ subsidiary subcontractor Client (as applicable by the terms of the General Contract) Accident, Injury, Illness or Property Damage or near miss incident involving TIKIGAQ or TIKIGAQ Subsidiary personnel TIKIGAQ President TIKIGAQ Human Resource Manager TIKIGAQ Board of Directors TIKIGAQ or TIKIIGAQ subsidiary Site or Facility SSHO TIKIGAQ Corporate Safety Program, 11/09 4 -6 Table 1 - Incident Response Procedures Nature of the Incident Action to be Taken Respon sibility All accidents, injury, illness or property damage or ―near miss‖ incidents. 1. If the employee is conscious, make prompt notification of the incident t o the employee’s immediate line supervisor. Coworker 2. Obtain immediate medical treatment o r first aid, as necessary . Where applicable, secure the site and equipment to the extent possible. Providing medical treatment is the priority. Line Supervisor/ SSHO/ Co - worker 3. Determi ne if outside medical treatment is required; if not, proceed to 6. Line Supervisor /SSHO/Co - worker 4. Make arrangements for transportation and treatment at a medical facility. Supervisor 5. Make verbal notification to the TIKIGAQ Project/Facility Manager, General/Regional Manager, and CHSM office within One hour of inc ident.

See Figure 1, section 4.4 for the proper TIKIGAQ Incident Notification and Reporting Process . If incident results in a fatality, hospitalization or loss of consciousness notification shall be IMMEDIATE , upon coordinating medical services and securin g the site with Emergency/security personnel . Line Supervisor 5a. Only the CHSM or TIKIGAQ COO shall c all OSHA (state or federal as a ppropriate) within 8 hours of a hospitalization of three (3) or more employees or death of an employee. (NOTE: Reporti ng requirements differ from federal OSHA and the various state OSHA programs.) TIKIGAQ Corporate Health & Safety Manager Only or COO 6. Where applicable to incident, secure Worker Compensation forms from Human Resource Manager (HRM). Complete form, revie w for accuracy and return to HRM within 24 hours. Employee/Line Supervisor with assistance from PM, SSHO, other safety Coordinator (SC) as necessary 7. Refer ALL accident/injury, medical, media inquiries to General/Regional Manager, CHSM and HRM. PM, l ine supervisor, SSHO, other SC, Employees 8. Review worker's compensation forms and send to insurance company. HRM 9. Investigate the incident. If defective equipment, part, or tool was involved, "Red Tag" and/or remove from service. T ake immediate co rrective action where identified/possible and after consultation with PM and CHSM . Line Supervisor (SSHO, other Safety Coordinator or Senior Management) 10. Complete IRF, as applicable to incident, with applicable pictures, statement s , interviews, wit ness statements etc. Forward all information to CHS, PM and General Manager/Regional Manager for review. Line Supervisor (other Safety Coordinator or Senior Management) 11. Review IRF, as applicable to incident, make recommendations and develop correct ive actions. TIKIGAQ management supports implementation corrective action(s). CHSM, TIKIGAQ Management, site or facility management team 13 . Coordinate and implement modified operation procedures and / or developed corrective actions, as soon as possible. Line Supervisor 14. Keep in contact with employee s who have experienced a workplace injury/illness on a regular basis and update Management on employee status. CHSM/ HRM w/support from Line Supervisor 15. Monitor status of Worker Compensation issues and claims, where applicable HRM 16. Return employee back to work as soon as possible including temporary reassignment of employee duties, as applicable to the case. CHSM, HRM, General/Regional Manager, PM 17. Notify PM and when employee is deemed, in writing by a licensed physician/therapist, to be ―fit‖ to resume employees normal assigned duties (Attachment 1 – ―Return to Work Authorization‖) Employee, HRM/CHSM 18. Update OSHA 300 log, as necessary. CHSM TIKIGAQ Corporate Safety Program, 11/09 4 -7 4.5 PROCEDURES FOR ACCIDENT /INCIDENT INVESTIGATIO N 1. The primary purpose of an accident/incident investigation is to determine the contributing factors and the root cause of the accident so that future reoccurrence can be avoided. An accident investigation should not be conducted with the purpose of identifying ―fault‖ on individuals. 2. All accidents, injuries, property damage will be reported on the prescribed IRF documents.

3. Accident/injury investigations will be conducted by line supervisors or the SSHO, HSO/HSPA, as may be designated by the CHSM and/or the General or Regional Manager. In certain situations, incident investigations may be required to be completed by members of the upper management team. 4. If an accident results in equipment damage and no injuries, the responsible supervisor shall, with the aid of the employee involved, complete an IRF accident investigation form. This form will be completed within 24 hours and forwarded to CHSM, via the PM, for review. A joint management review of the incident information will occur. 5. Care must be taken to preserve evidence at the accident site which may aid in determining the cause of the accident. Only move items and materials which must be moved to aid in rescue or medical treatment operations. 5A. If an incident results in an immediate fatality, no one except for on-scene security or medical authorities may disturb the victim or disturb evidence (victim, materials, equipment, site conditions) associated with the incident. Photo evidence maybe retrieved for investigatory purposes only and only as deemed necessary (jointly determined the COO, CHSM and General/Regional Manager) and as allowed for by security or medical personnel responding to, coordinating or controlling the incident scene. All photographs, copies or digital images of a fatality incident retrieved by TIKIGAQ personnel shall only be turned over to the COO, CHSM and General/Regional Manager as soon as feasibly possible and shall not be distributed in any other manner, except as per the express direction by the TIKIGAQ COO, CHSM and General/Regional Manager. In the execution of this condition these individuals shall work with the HRM to ensure the security of such evidence. Failure to do so may result in disciplinary actions, including but not limited to termination. For a fatality incident at remote project sites, direct consultation with the CHSM COO, CHSM and General/Regional Manager and area/regional security forces will be required to ensure proper procedures are adhered to. 6. The site or facility line supervisor or SSHO on the scene will record names of the witnesses and conduct interviews.

7. The supervisor will immediately, if possible, photograph the accident scene and all related equipment, except as may be disallowed by on-site security or medical personnel responding to, coordinating or controlling the incident scene. 8. The supervisor will make a sketch and take measurements of the accident scene and related equipment.

9. The supervisor will ensure timely (within 24 hours) delivery of the completed accident investigation documents to the safety coordinator.

TIKIGAQ Corporate Safety Program, 11/09 4 -8 4.5.1 Best Management Practices for Accident/Incident Investigation The p urpose of an inciden t inv estigation is to understand how the in cident happened, analyze the root causes, and prevent recurrence by impleme nting corrective actions. To conduct an effe ctive investigation, all in formation must be as detailed and comprehensive as possible. The investigation must be based on facts that clearly identify the sequence o f events and the factors that contributed to the i ncident. The investigation team should not be involved with any punitive actions r esult ing fr om the investigation. Fairness and impartiality are essential. The following provides general Best Management Practice guidance in 1. An unbiased approach is necessary to obtain objective findings.

2. Visit the accident scene as soon as possible while the facts are fresh and before witnesses forget important details.

3. If possible, interview the injured worker at the scene of the accident and "talk" through re-enactment.

4. Conduct all interviews as privately as possible. Interview witnesses individually and separately. Talk with anyone who has knowledge of the accident/incident, even if he/she did not actually witness it. Only retrieve witness statement from individuals who actually observed the accident/incident. Document witness interviews.

5. Document details graphically. Use the IRF as well as sketches, diagrams, and photographs as needed. Take measurements where appropriate.

6. Focus on the causes and hazards leading to the accident/incident. Develop an analysis of what happened, how it happened and how it could have been prevented. Determine what caused the accident/incident itself, not just the injury.

7. Include a Corrective Action plan in every investigation. Describe how you will prevent such accidents in the future. Completion of the Root Cause Analysis may assist in the formulation of such plans. 8. Save any evidence if a third party or defective product contributed to the accident/incident. It should be critical to the recovery of claims costs. TIKIGAQ Corporate Safety Program, 11/09 4 -9 4.6 INCIDENT REPORT FORM (IRF) I NSTRUCTIONS The Incident Report Form (IRF) is used for workplace injuries and illnesses that occur to TIKIGAQ employees. If the information, line or listing in the IRF is Not Applicable to the condition of the incident, write Not Applicable (NA). If incident information associated with a specific, line or listing in the IRF is Not Available, write Not Available. The following instructions are intended to aid in the completion of the IRF. Type of Incident Secti on Select at least one of the incident types provided on the form. More than on e incident type may be selected. Th e ―Other‖ option may be used for in cident types not provided on the form (e.g., fires, explosio ns, bomb threats, workplace violence). General Information Section Preparer’s name and Employee # – Enter the name an employee number of the person completing the IRF.

Date of In cide nt— Provide the date the incident occurred. If the exact date is unknown, provide an approximate date. En ter date in th e ―mm/dd/yyyy‖ format. Time of Incident —Provide the time th e inci dent occurred. If the exact time is unkno wn, provide an approximate time, and identify it as such. Enter time in military time or th e ― hh:m m, am or pm‖ format. Type of A ctiv ity —Select the activity being performed that r esulted in the incident. If activity is not listed, select ―other ‖ and provide a brief description. Only u se ―other‖ if no other option is appropriate.

Location of Incident —Select the location where the in cident occurred from the list. If ―Company Premises‖ is selected, provide the TIKIGAQ office location. If ―Field‖ is selected, provide the project number, projec t/site name, an d clien t name. If ―In Tr a nsi t‖ is selected, provide traveling from and traveling to. Di scuss ―at home‖ selections with CHSM as only specific at home incidents may require notification and recording. Geographic Lo cation of Inci dent— Select th e TIKIGAQ region where the incident occurred from the pick li st. Subcon tra ct or Involved —If a TIKIGAQ subcontractor was involved in th e inci dent, provide th e su bcon tra ctor ’s company name, telephone number and Point of Contact (POC). Describe the Incident —Provide a brief but detailed description of th e events that led to (caused) the incident. Be as specific as po ssible.

Injure d Employee Da ta Sect ion (Complete for Injury/Il lness Inciden ts only) Injured Employee General Information —If a TIKIGAQ employee was injured, identify the employee’s name and number. If a TIKIGAQ subcontractor’s employee was injur ed , identify name of the injured subcontractor employee and the subcontractor’s name. Injury T ype —Select th e injury type from the list. If injury type is not listed, select ―Ot her‖ a nd provide a brief description. U se ―Other‖ only if no other option is appropriate. If more than TIKIGAQ Corporate Safety Program, 11/09 4 -10 on e injury type, select ―Multi ple‖ and provide a brief descriptio n . Part of B ody Injured— Select the body part injured from the pick list. If the body part inj ured is not listed, sele ct ―Other‖ and provide a brief de scr iption. Use ―O ther‖ only if no other option is appropriate. If more than one body part wa s inj ured, se lect ―Mu ltiple‖ and provide a brief description. Personnel completing the IRF may use the terminology such as ―private‖ as may be appropriate and a verbal identification of injuries to a private area of the employee maybe provided to the CHSM/HRM upon receipt of the IRF. Discretion must be used for injuries of this type to protect the privacy of the injured employee. Nature of Injury —Selec t nature of i njury from the list. If nature of injury is not listed, select ―O ther ‖ a nd provide a brief description. Use ―Other‖ on ly if no other option is appropriate. If more than one nature of injury, select ―Mul tiple‖ a nd provide a brief description.

Init ial D iagno sis /T rea tment Date —Provi de the in itial date wh en the inj ury/illne ss was diagnosed or treated. Enter date in th e ―mm/dd/yyyy‖ format. Type of Treatm e nt— Select treatment from th e list. If treatment is n ot listed, select ―Ot her‖ an d provide a brief description. U se ―Other‖ on ly if no other option is appropriate. If more than one treatmen t, select ―Multi ple‖ a nd provide a brief description.

R equired Days Off —Pro vide th e number of days the doctor required the employee to be away from work. Do not coun t days in which th e emp loyee chooses to stay away from work without the doctor ’s inst ruction. Do not coun t initial day of inj ury or onset of illness. Do not count days on which th e employee would n ot have worked even if the employee had been able to work (e.g., holidays, vacation s, weekends). This number may n eed to be updated if the doctor changes in itial instru ctions. Restricted Days of Work Activity —Provide the number of days the doctor restricted the employee ’s work activity. Restricted days include: (1) days employee was assi gned to another job on a temporary basis, (2) days employee worked at a permanent job l ess th an full time, and (3) days employee worked at hi s/her permanent j ob but c ould not perform all th e duties normally conducted. Do not coun t initial day of i njury or onset of illness. Do not coun t days on which employee would n ot have worked even if the employee had been able to work (e.g., holidays, vacation s, weekends). This number may need to be updated if th e doctor changes initial in stru ctions.

Equipment Malf unction— Select ―Yes‖ if equipment malfunction caused or led to th e in cident.

R ou ti ne Task —Select ―Yes‖ if inciden t occurred during a routine task.

Descri be How the Incident May Have Prevented —Based on information at hand, provide a brief description o f how th is incident could have been avoided or prevented.

Physician Info rmation—Pro vide name, address, an d telep hone number of ph ysi cian the employee went to for medical treatment, first aid or diagnosis.

Hospital Info rmation— Provid e name, address, and telephone number of the hospital the employee went to for medical treatment, first aid or diagnosis.

Emergency R oom Information —P rovide name, address, and telephone number of the em erge ncy room went to for medical treatment, first aid or diagnosis. TIKIGAQ Corporate Safety Program, 11/09 4 -11 Propert y Damage Section (Complete fo r Propert y Damage incidents only) Property Damaged —Provide a brief but detailed description of the pr operty, in cluding al l ve hicles, e quipment, structures, etc. that was damaged as a result of the incident. Property Ow ner— Ind icate if the pr operty i s own ed by TIKIGAQ or, if not, wh o own s th e damaged property.

Damage Descr iption —Provide a brief description of the physical damage on each damaged item.

Es tima ted Amount —Pro vide the estimated dollar value of damage or cost to repair.

Spill or Re lea se (Complete for Spil l/Release incidents only) Subs tance —Pro vide the type of substanc e spilled or released to th e environ ment.

E st ima ted Quantity —P rovide th e estimated quantity of the substance sp illed/released.

Fa cility —Pro vide the name, address, and telephone number of the facility where th e inci dent occurred.

Movement Off Property —If a substance that was spilled/released moved off the property where the work was being performed, indicate yes and identify discharge point, final disposition point, if known and any sensitive receptors (wetlands, ocean, river, agricultural area etc.) that may have been impacted as a result of the spill/release. Spill/Release From —Select from the list the type of contain er the substance was in prior to the sp ill/release. If th e container type is not listed, selec t ―Other‖ and p rovide a brief description.

U se ―O ther‖ only if no other option is appropriate.

Spill/Release To —Select from the pick list where the substa nce e nded up after th e spill/release. If ar ea is not listed, sele ct ―Other‖ a nd provide a brief de scription. Use ―Ot her‖ only if no ot her option is appropriate.

Environmen tal/Permit Issu e Sect ion (Complete for Environmen tal/Pe rmit Issue in ciden ts only) Describe Env ironmental or Pe rmi t Issue —Whe n a federal, state, or local law or r egula tion may have be en violated, describe th e requiremen t and how it was violated.

Permit Type— Select the type of permit that was exceeded from the pick list. If the permit type is not listed, sele ct ―Other‖ and provide a brief descriptio n. Use ―O ther‖ only if no other option is appropriate.

Permitted Level or Cr iteria— Provide the level or criteria exceeded (e.g., 5.0 ppm lead or sur face water quality criteria).

Permit Name and Number —Pro vide name an d number of permit e xceeded (e.g., NPDES No.

ST1234).

Subs tance and Esti mat ed Quantity —Provide substanc e name and estimate th e quantity of th e exceedance.

D ur a tion of Pe rmit Exceedance— Provide an estimate of h ow long th e exceedance lasted. TIKIGAQ Corporate Safety Program, 11/09 4 -12 Verbal Notifi cat ion Sec tion TIKIGAQ Personnel Notified —P rovide names, dates, an d times of all TIKIGAQ per sonnel notif ied regarding the accident or incident. C lie nt No tified— Indicate if the Project/Facility Manager or other member of the TIKIGAQ management team (Regional Manager, General Manager or Chief Operating Officer or President) has n otified the cl ient as maybe required by the terms and conditions of the general or prime contract. Witnesses Se ction Witness infor mation —Provide name, address, and telephon e number of an y witne sses to th e inci dent.

Witness Observations — Secure written Witness Statements for individuals who saw the accident/injury occur. Upon completion of the written witness statement, have witness print name, provide signature and date the statement was taken. Witness observations may not be coerced in any way. If the witness is not willing to provide a written detail of the incident, the person completing the IRF may document discussions with the witness in this section and note that the information was taken as a witness interview. Additional notes, sheets of paper maybe attached as required to properly document the interview, as necessary. Comments Sec tion A ddi tion a l Co mments/Changes —Provide any addi tional information provided by Witness 1 or Witness 2 that was not covered that will help clarify the reasons for the in cident.

4.7 DETERMINATION OF ROOT CAUSE (S ) OF ACCIDENTS AND INCIDENTS Information and observations gathered at a loss or near loss incident investigation scene are analyzed to determine the ―root cause‖ and any related ―contributing factors‖ of the accident/incident. The TIKIGAQ personnel who are performing accident/incident investigations personnel shall use the Root Cause Analysis (RCA) Form and Flow Chart to assist with the identification the root cause(s) and contributing factor(s) of an incident. See Attachment 3 of this CHSP for these forms and descriptions that should aid in the completion of the RCA form.

Any loss or near incident may have one or more ―root causes‖ and ―contributing factors‖. The ―root cause‖ is the primary or immediate cause of the incident, while a ―contributing factor‖ is a condition or event that contributes to the incident happening, but is not the primary cause of the incident. Root causes and contributing factors that relate to the person involved in the incident, his or her peers, or the supervisor should be referred to as ―personal factors‖. Causes that pertain to the system within which the incident occurred should be referred to as ―job factors‖. Personal Factors Lack of skill of knowledge Correct way takes more time and/or requires more effort Short-cutting standard procedures is positively reinforced or tolerated TIKIGAQ Corporate Safety Program, 11/09 4 -13 Person thinks that there is no personal benefit to always doing the job according to standards Job Factors Lack of or inadequate operational procedures or work standards. Inadequate communication of expectations regarding procedures or standards Inadequate tools or equipment Other The root cause(s) and contributing factor(s) could be any one or a combination of these seven possibilities or some other ―uncontrollable factor‖. In the vast majority of losses, the root cause is very much related to one or more of these seven factors. Uncontrollable factors should be used rarely and only after a thorough revie w eliminates ―all‖ seven other factors.

4.8 LESSONS LEARNED A ―Lessons Learned‖ program is a method of consolidating all the information, observations, findings and developed/implemented corrective actions associated with the incident into one final document. A Lessons Learned is prepared as a written hard copy or electronic document and is circulated to TIKIGAQ personnel as a loss prevention tool for Project/Facility Managers, site or facility line supervisors and SSHO’s to incorporate into existing and future field operations to prevent recurrenc e of similar incidents. Lessons Learned documents are fabricated in a manner that eliminates identification of specific project names, personnel or subcontractors. A Lessons Learned Program Outline is included in Attachment3 of this CHSP.

However, use of subcontractor information involved in significant or serious accidents will be evaluated by the CHSM and TIKIGAQ management. Prepared Lessons Learned are developed by the jointly prepared by the project team (PM, line Supervisor, SSHO) and submitted to the CHSM, (HSO/HSPA if designated), General or Regional Manager for review and comment. Once finalized, the Lessons Learned maybe circulated to TIKIGAQ personnel. It is the intent of a Lessons Learned program to share accumulated information and corrective action procedures implemented as a result of the accident/incident investigation process with designated site personnel during site safety meetings, briefings or orientation events. It is also shared manually or electronically with management, supervisor and H&S staff. Sharing such information with management, supervisor, H&S and worker personnel is done in an effort to promote worker hazard awareness and reduce accident, injury, illness and property damage liabilities.

Supervisor personnel shall document via daily safety briefings/meetings that corrective procedures developed as a result an accident/incident that occurred on a site for which they are responsible for has been integrated into site operations. Additionally, this acknowledge shall be forwarded via email to the PM and CHSM. The incident shall remain open until corrective site actions have been acknowledged in this manner. However, Worker Compensation claims and cases which have been established by the HRM on behalf of employees who have suffered a workplace injury or illness may remain ―open‖ after completion of such acknowledgement. TIKIGAQ Corporate Safety Program, 11/09 4 -14 4.9 DISTRIBUTION OF REQUIRED REPORT FORMS /RECORDS TIKIGAQ Incident Report Form, Loss/Near Loss Incident Report Form (as applicable) and Root Cause Analysis Form Distribution: Original - Employee file via HRM Copy – TIKIGAQ CHSM file Copy – Project and/or Regional Office H&S file Copy – Regional or General Manager, COO, President as may be requested by these individuals TIKIGAQ Contractor Significant Incident Report (as applicable to DOD contracts) Distribution: Original – Client and only as required by prime contract documents Copy – TIKIGAQ CHSM/HRM file Copy – Project and/or Regional Office H&S file Copy – Regional or General Manager, COO as may be requested by these individuals TIKIGAQ Lessons Learned Program Distribution:

Original – TIKIGAQ CHSM/HRM file Copy – Project and/or Regional Office H&S file Copy – Applicable management, supervisor and H&S staf f Copy – Implemented at project site as part of a daily H&S briefing/meeting with site workers Worker’s Compensation Forms (Secured from TIKIGAQ HRM) State Workers Compensation Commission Accident Report (1 st Report of Accident) Distribution: Original – State Workers Compensation Board/Agency Copy – TIKIGAQ Workers Compensation Carrier Copy - Employee file and/or Corporate file via HRM Copy – Employee or employee ’s beneficiary in the event of a fatality (in some instances employee may receive two copies) Note: Additional and separate Workers Compensations (WC) Claim forms will be provided by the HRM to be completed by the affected employee as required by individual state WC claim requirements and processes. TIKIGAQ Corporate Safety Program, 11/09 4 -15 Log and Summary of Occupational Injuries and Illness (OSHA 300 log via CHSM only) The CHSM will maintain the OSHA 300 Log based on occupational injuries and illnesses reported in accordance with the • The OSHA #300, depicting total injuries and illnesses for the previous calendar year, will be posted in facilities from February 1st through April 30th. TIKIGAQ Corporate Safety Program, 11/09 5-1 5.0 RISK MANAGEMENT PROC ESS TIKIGAQ utilizes a Behavior Based Loss Prevention System (BBLPS) to support the implementation of our Risk Management Process (RMP). The implementation of a BBLPS in all our executable contract work assists employees with identifying, analyzing and controlling certain risks (liabilities) that may be encountered during assigned contract work. The use of a BBLPS is a successful, industry tested, loss-prevention management approach that focuses on the use of behavior-based tools and management techniques to eliminate undesirable behaviors, acts or conditions that could lead to losses.

The following BBLPS components are routinely executed as an integral component of our RMP and include the use of, but are not limited to the following:

Preparation of site/facility specific Health & Safety Plans (SSHSP)/Accident Prevention Plans (APP) Activity Hazard Analyses (AHA) Pre-Task Safety Plans (PTSP) Routine Inspections (LPO, Deficiency Tracking) Incident (Losses/Near Losses) Investigation Drug Free Workplace Program (DFWP) Subcontractor Qualifications The Project/Facility Manager and site/facility line supervisor are responsible for ensuring that the required components of the BBLPS and other risk management processes are implemented for each executed contract. These individuals routinely assign or request other team members or management staff to support the execution of this risk management process, but the Project/Facility Manager and the site line supervisor remains accountable for its imp lementation.

5.1 SITE /FACILTIY SPECIFIC HEALTH AND SAFETY PLANS TIKIGAQ prepares a site/facility specific Health and Safety Plan (HSP)/Accident Prevention Plan (APP) for each executable contract. The primary function of this document is to identify health and the safety concerns or hazards that may be associated with major contract definable features of work or general site conditions and provides project team members with hazard awareness and control information that, if implemented correctly, should support the mitigation of project related injuries, illnesses or property damage. Additionally, these documents detail roles and responsibilities of key project and management team personnel, exposure monitoring and Personnel Protective Equipment (PPE) requirements, decontamination procedures and emergency planning measures and overall health and safety program policies and procedures to be implemented on each individual awarded contract or task order. Where hazardous site conditions or actions are identified by the project team that are not consistent with established Health and Safety policies, procedures or processes or information identified in the site/facility specific HSP/APP and cannot be controlled or abated by designated project site personnel, then these conditions or actions are promptly be brought to the attention of the TIKIGAQ management team for immediate evaluation and corrective action. TIKIGAQ Corporate Safety Program, 11/09 5-2 In the event that it is determined that a site/facility specific HSP/APP does not adequately address experienced site conditions or anticipated operations, the site/facility specific HSP/APP will be re-evaluated and amended as necessary to address any unanticipated encountered project conditions or newly defined project tasks. In the event that recorded air monitoring data indicates that designated site workers are or may be exposed to site contaminants concentrations in excess of established Occupational Exposure Limits (OELs), work shall cease until such engineering or administrative control measures and/or PPE are implemented to reduce potential worker exposures to acceptable levels.

5.2 ACTIVITY HAZARD ANALYSIS One of the key elements in executing our risk management process, and subsequently reducing project risk, is via the development and use of an Activity Hazard Analysis (AHA) for each major phase, or Definable Feature of Work (DOFW) or safety sensitive operation. An AHA defines the activity being performed, the hazards posed, and control measures required to perform the work. In addition, tools, equipment and materials, as well as inspection processes and employee training or medical surveillance requirements needed to complete the assigned work are also identified in the AHA. Workers shall review or be briefed on the AHA contents before initiating the assigned task or phase of work. Employee input is also solicited before, during, and after the performance of task or work phase to further identify the hazards posed and control measures required that were not initially identified.

AHAs are prepared for identified definable features of work or safety sensitive operations performed by TIKIGAQ or their subcontractors that would be engaged in during the course of the project. These AHAs are typically prepared or reviewed by the designated TIKIGAQ health and safety professional or other qualified line supervisor or manager. In many of our contract conditions, TIKIGAQ prepares and submits AHAs for each identified with the site/facility specific HSP/APP for review by a Government Designated Authority (GDA), as a contract deliverable, prior to the start of work.

TIKIGAQ subcontractors, regardless of tier, are required to develop and provide AHAs specific to their scope of work or they may choose to review and acknowledge TIKIGAQ prepared AHAs where the work is jointly executed by TIKIGAQ and Subcontract personnel and where the Subcontractor determines that TIKIGAQ prepared AHA is applicable and acceptable for the work and their employees. Otherwise each subcontractor shall develop their own AHA applicable to their assigned work. Subcontractors, under certain contract conditions, may also be required to submit their prepared AHAs for GDA review.

When additions or changes in anticipated TIKIGAQ or subcontractor field activities occur or when additional/different hazard encountered that require additional/different hazard control measures are identified, these situations would require either a new AHA to be prepared or modification to an existing AHA. After the review of each AHA, acknowledgement shall be made by the TIKIGAQ or Subcontractor employee with the addition of the individual’s printed name, signature and date that the material was delivered to them or reviewed by them on the last page of the AHA form.

The AHA that is applicable to the current site operation(s), task or work phase shall be posted in a conspicuous place (i.e. project construction trailer, weather proof bulletin board) that all site or facility personnel have access to. When the most current AHA is not in use and not TIKIGAQ Corporate Safety Program, 11/09 5-3 required to be posted, these completed AHAs shall be kept on-site in a neat and organized manner for review by management or the client, as deemed necessary. The Project/Facility Manager or site line supervisor may establish a process by which completed AHAs are scanned and emailed for inclusion in the electronic project record, where email communication capability is available. Regardless, at the end of contract operations all completed AHA hardcopies shall be forwarded to the Project/Facility Manager at the regional off ice for inclusion in the final project record.

Blank AHA forms are available in Attachment 4 of the CHSP but may be executed in a variety of formats. However, AHAs developed for TIKIGAQ operations, must contain the minimum components identified above.

5.3 PRE -TASK SAFETY PLANS Daily safety meetings are held with all designated project site personnel in attendance in order to review the potential hazards that may be associated with daily work assignments. The purpose of these daily meetings is to set-forth various hazard control measures or policies and procedures which must be implemented by project staff to facilitate the reduction or elimination of work place incidents that could be associated with the scheduled work. The topics developed and delivered during each production day are documented on a Pre-Task Safety Planner (PTSP). The PTSPs are held between the site line supervisor and their work crews and are designed to focus on eliminating identified hazards associated with daily assigned work.

Daily safety topics typically include task specific or site hazards and associated hazard control measures, health and safety processes, or ―hazardous conditions‖ discovered and corrected/controlled during a previous work event that may still be applicable to the current daily production goals. Additionally, names of personnel, types of tools and equipment that will be used to perform the assigned daily task(s) are listed, along with the hazards posed and required H&S procedures that have been identified in the task specific AHA or site/facility specific HSP/APP are incorporated into each PTSP. This preparation and delivery of the PTSP may be delegated to the Site Safety and Health Officer (SSHO) by the site line supervisor, in order to facilitate site operations. At the start of each day’s activities, the line supervisor or SSHO completes a PTSP. Ideally input from the work crew should be solicited and integrated into the development and delivery of the PTSP. The end result of the implementation of daily PTSPs is to promote enhanced worker participa- tion in the recognition and control of hazardous site conditions or undesirable site acts, while reinforcing the task-specific required H&S procedures with the crew each day. In the event that more than one type of project task is scheduled in any one daily production event, then multiple PTSPs may need to be completed and implemented.

After the delivery of each PTSP, all personnel in attendance of the daily safety meeting shall acknowledge the delivered material with the addition of their printed name, signature and date that the material was delivered to them on the last page of the form. These completed PTSPs shall be kept on-site in a neat and organized manner for review by management or the client, as deemed necessary. The Project/Facility Manager and the site line supervisor may establish a process by which these completed PTSPs are scanned and emailed for inclusion in the electronic project file, where email communication capability is available. Regardless, at the end of the project or facility operations all completed PTSPs hardcopies shall be forwarded to the TIKIGAQ Corporate Safety Program, 11/09 5-4 Project/Facility Manager at the corporate or regional office for inclusion in the final project r ecord. Blank PTSP forms are available in Attachment 5 of the CHSP but may be executed in a variety of formats.

5.4 LOSS PREVENTION OBSERVATION Loss Prevention Observations (LPOs) are a tool to be used by management, site line supervisors and SSHO to determine whether workplace behaviors, acts and conditions are consistent or not consistent with established health and safety procedures, site/facility specific HSPs/APPs requirements or other established safety standards An LPO may also be completed by individual work crew members to initiate a necessary corrective action, to identify a work crew members positive performance or contribution or undesirable act that would endanger the employee or other co-workers. Completion of the LPO provides a mechanism for management to reinforce positive actions for work practices performed correctly, while also identifying and eliminating work procedures, site conditions or behaviors that could result in eventual losses. LPOs can be completed by any employee involved with or observing site operations, but is typically prepared by the site line supervisor, SSHO or Project/Facility Manager. The LPO is implemented as a comparison of the actual execution of work process observed against established work procedures identified in the site/facility specif ic HSP/APP, AHAs, established health and safety policies and procedures or regulatory standards. Completed LPOs should be forwarded to the project management team for review on a weekly basis, where email capability is available, for inclusion in the active project file. In cases were severe or critical deficiencies are observed, the Project/Facility Manager, site line supervisor or SSHO has duty to notify the Project/Facility Manager and the General Manger of the condition for further review and development of corrective action requirements. Completed LPOs shall be kept on-site in a neat and organized manner for review by management or the client, as deemed necessary. At the end of the project or facility operations all completed LPO hardcopies shall be forwarded to the Project/Facility Manager at the corporate or regional office for inclusion in the final project record.

There should be at least one LPO completed each week of completed active site or facility tasks/operations using form in Attachment 6. 5.4.1 Deficiency Tracking System On certain government contracts (i.e. EPA, NAVFAC, AFCEE, USACOE) where adherence to the US Army Corps of Engineers, EM 385-1-1, ―Safety and Health Requirements Manual ‖ is required, in addition to Occupational Safety & Health Administration (OSHA) regulations, then the site or facility line supervisor shall also be required to keep and maintain a ― deficiency tracking system ‖ or log. The deficiency tracking system is utilized to identify and monitor the status of safety and healt h ― deficiencies ‖ observed at the project or facility location, in chronological order. The deficiency tracking system should provide the following information: (1) Date deficiency identified; (2) Description of deficiency; (3) Name of person responsible for correcting deficiency; (4) Projected resolution date; TIKIGAQ Corporate Safety Program, 11/09 5-5 (5) Date actually resolved.

The deficiency tracking system or log shall be posted on a project bulletin board, or other conspicuous place commonly accessed by project or facility personnel and must be ―updated‖ daily. An example of a deficiency tracking system log is included in Attachment 5. At project or facility sites where the use of a Deficiency Tracking System is required, it shall supplement the LPO process. At the end of the project or when facility operations are completed hard copies of the deficiency tracking system data or logs, shall be forwarded to the corporate or regional office for inclusion in the final record.

5.5 INCIDENT (LOSS /NEAR -LOSS ) I NVESTIGATIONS Employees shall promptly repor t ALL occupational illnesses, injuries, near misses, and damage to property and/or equipment to their immediate supervisor regardless of how minor. When accidents, incidents or ―near -misses‖ occur at TIKIGAQ work environments, then an Incident Investigation is performed. Incidents are also usually referred to Loss or Near Incidents (L/NLI) depending upon the event that result that is produced by any Incident event.

Investigations must be performed if the following work place situations occur: All personal injuries/illnesses (regardless of the severity) ― Near-miss‖ incidents Equipment/property damage Spills, leaks, regulatory violations Motor vehicle accidents Weight Handling Equipment (WHE) Incidents The causes of loss and near-loss incidents can be similar, so by identifying and correcting the causes of near-loss incidents and correcting the causes of work pace incidents can prevent future losses. The Project/Facility Manager, site line supervisor or the SSHO, as appropriate to the incident situation, will perform an incident investigation as soon as practical after the occurrence of any incident. Investigation processes should occur on the day of the incident, wherever possible, using dedicated incident investigation forms. The following is the incident and loss/near-loss investigation process: Gather all relevant facts, focusing on fact-finding ( not fault-finding), while answering the necessary ―who, what, when, where, and how‖ questions. Draw conclusions, putting facts together into a probable scenario. Determine incident root cause(s), which are basic causes on why an unsafe act/ condition existed. Develop and implement solutions, matching all identified root causes with solutions. Communicate incident as a lesson learned to all project personnel.

File foll ow-up on implemented corrective action to confirm solution is appropriate.

All incidents, property damage in excess of $1,000, or near-loss incidents that could have resulted in serious consequences will be investigated and documented by completing the required forms identified below which and are located in Attachment 3 of this CHSP. TIKIGAQ Corporate Safety Program, 11/09 5-6 Incident Report Form Root Cause Analysis Form A completed preliminary Incident Report Form (IRF) and Root Cause Analysis (RCA) Form incident investigation forms will be submitted to the Project/Facility Manager, General Manager/Regional Manager and HSO/HSPA within 24 hours of incident occurrence. Final incident report documents will be submitted after completing a comprehensive investigation of the incident, if deemed necessary, to the upper management officers, the CHSM and the HRM.

A final IRF and RCA document will be submitted after completing a comprehensive investigation of the incident, in accordance with the procedures identified in section 4.5 of this CHSP.

5.5.1.1 Contractor Significant Incident Report For project accidents and incidents that occur on Department of the Navy (DON) project sites involving an OSHA recordable accident, property damage in excess of $2000.00, Weight Handling Equipment (WHE) accident, or near miss/high visibility mishaps, resultant initial, follow-up or final accident/incident investigation information must be detailed on a Contractor Significant Incident Report (CSIR). The CSIR must be completed and submitted to the GDA within the required GDA time-frames.

Other Contractor incident forms may apply for other types of government or publicly funded contract work. It shall be the responsibility of the project or facility manager to determine with our client representatives if client specific reporting requirements apply to TIKIGAQ work. If required, incident reporting procedures and timeframes must be executed to meet client and contract conditions. 5.6 DRUG -FREE WORKPLACE PROGRAM In an effort to provide a safe and healthy workplace for all program participants, TIKIGAQ promotes and implements a Drug Free Workplace Program (DFWP). TIKIGAQ personnel must participate in and adhere to the requirements of the DFWP, as a condition precedent to employment. In addition, personnel that are involved in HAZWOPER and Construction, or other safety sensitive operations, at a minimum may be drug tested at least, annually. Employees may also be tested for pre -employment conditions, reasonable suspicion, and probable cause or following accidents.

TIKIGAQ does not tolerate the use of alcohol, illegal drugs, controlled substances, or even prescription drugs that could impair an employees work performance or behavior while on a project/facility site or while performing work related activities. Our corporation has established policy that its employees will not be involved in any manner with the unlawful manufacture, distribution, dispensation, possession, sale, or use of illegal drugs in the workplace. The use or possession of alcohol in the workplace is prohibited. Reporting to assign ed work under the influence of alcohol is also prohibited. Any violation of these DFWP requirements may result in disciplinary actions, up to and including termination. For many of TIKIGAQ ’s awarded contracts, the requirement to provide a DFWP must be ―flowed- down‖ to designated on -site subcontractor’s. Some subcontractors could potentially be exempt from this requirement for low risk or short duration site/facility work, (less than two TIKIGAQ Corporate Safety Program, 11/09 5-7 (2) weeks) so long as they are escorted and observed by a project team member that is enrolled in the DFWP program.

5.7 SUBCONTRACTOR QUALIFICATIONS Prior to awarding Subcontract work, subcontractor qualifications are evaluated. Subcontractor evaluation is not only based on the overall bid response to designated work defined by prepared Subcontract Statement of Work (SOW)/Request for Quote (RFQ) packages, but is also based on their overall experience and past and present corporate safety performance record. When reviewing a potential Subcontractor’s and safety performance record, the following key items are evaluated. Acceptable certificates of insurance, including coverage limits Experience Modification Rate (EMR) trends OSHA recordable incident and lost work day data Key health and safety program components (health and safety plans, inspection and work phase meeting processes, DFWP etc.) Employee training and medical surveillance (as applicable) program details Self performance of work By evaluating Subcontractor safety performance data, work history, in addition to proposed subcontracted cost, TIKIGAQ endeavors to select the most qualified Subcontractor to complete the designated Subcontract work, thus theoretically reducing risk to TIKIGAQ and the contract ― stakeholders‖ (i.e. business partners and clients) . 5.7.1 Site or Facility Subcontractor Safety Performance Subcontractor safety performance and adherence to established drug and alcohol testing r equirements must be reviewed prior to being issued a contract for site work. TIKIGAQ subcontractors must be contractually required to adhere to health & safety that are required by specific contract conditions, outlined in site/facility specific documents or other policies and procedures to which they have been made aware.

All subcontractor employees are subject to the same training and medical surveillance requirements as TIKIGAQ personnel performing the same functions. All activities involving potential exposure to hazardous waste materials will require medical and training certification as mandated by 29 CFR 1910.120/29CFR1926.65 or other regulatory specific training and/or medical surveillance requirements that may be needed to perform their assigned subcontractor work (i.e. asbestos or lead paint abatement). All subcontractor personnel will be required to sign in/sign-out of the site/facility daily ( see Attachment 4) and either conduct or attend a daily safety meeting which identifies scheduled daily operations, site specific hazard awareness, or other pertinent issues associated with the scheduled work.

Subcontractors should submi t and Activity Hazard Analysis (AHA) for their work activities to the project/facility manager SSHO or other designated Safety Coordinator for review and comment. The subcontractor reports directly to the TIKIGAQ Project/Facility Manager. Once field operations are initiated, the TIKIGAQ Project/Facility Manager may designate su bcontractor reporting requirements to the site/facility line supervisor. TIKIGAQ Corporate Safety Program, 11/09 5-8 All incidents involving subcontractor employees will be reported to the TIKIGAQ site/facility line superviso r and a copy of the subcontractor’s injury / illness report will be submitted to the Project/Facility Manager and CHSM, as soon as possible, but no later than 24 hours.

S ubcontractors to acknowledge and adhere to all requirements of site/facility specific health and Safety documents and/or their own health and safety documents, especially where specifically applicable to the subcontractor’s specialized work or where subcontractor’s work is not addressed by the TIKIGAQ health and safety documents. Suppliers delivering materials to a site/facility or providing equipment and equipment maintenance will comply with all rules and regulations specified by the owner. Supplier personnel will not be permitted into contaminated areas unless training and medical surveillance is in accordance with 29 CFR 1910.120/29 CFR1926.65. Contractors will not ride on tractors, forklifts, or similar vehicles unless specific seats are provided. They will follow Facility hot work rules if hot work is required for vehicle or equipment maintenance. Trucks will be loaded and unloaded in a safe and effective manner and materials will be stored safely in designated locations only. Associated packaging will be properly disposed and litter will not be permitted to be scattered or blown from truck beds. Operators of mobile equipment onsite must observe all traffic rules such as speed limits and pedestrian rights- of-way.

TIKIGAQ should continuously endeavor to observe subcontractors’ safety performance. This goal should be reasonable, and include observing for hazards or practices and procedures that are not consistent with established Health and Safety (H&S) requirements that are both readily observable and occur in common work areas. When apparent conditions, actions, or practices ar e observed that are not consistent with the TIKIGAQ Health and Safety Program, regulatory requirements or contract requirements, the subcontractor safety representative or line supervisor must be notified and a corrective action must be required. The subcontractor is responsible for determining and implementing necessary controls and corrective actions.

When identified conditions or practices/actions that are not consistent with TIKIGAQ policies and procedures, regulatory requirements or contract conditions are repeated or persist, notify the subcontractor safety representative and stop affected work until adequate corrective measures are implemented. See Stop Work Order (SWO) Form in Attachment 3 of this HSP.

When an apparent imminent danger exists, immediately remove all affected TIKIGAQ employees and subcontractors, notify subcontractor safety representative or line supervisor, and stop affected work until adequate corrective measures are implemented (see SWO form).

The ability for TIKIGAQ personnel to perform this SWO action must be routinely contained in TIKIGAQ-subcontractor contract conditions. TIKIGAQ Corporate Safety Program, 11/09 6-1 6.0 TRAINING TIKIGAQ engages in environmental remediation, construction, and other services, and endeavors to comply with the numerous health and safety training requirements mandated by governmental agencies, clients, and internal policies. Personnel will be provided sufficient training to execute their jobs in a safe and healthy manner.

Line supervisors and managers with support by the CHSM, HSO/HSPA, are responsible to determine the training requirements of a task and ensure employees have the necessary training to complete the task safely. The CHSM and/or the HSO/HSPA personnel will assist with the delivery of identified required training.

Designated employer personnel and electronic databases facilitate the maintenance of training records and applicable experience documentation. When an employee is identified as lacking sufficient training or experience to perform an assigned task, every effort will be made to provide the necessary training or to provide a trained and experienced alternate until the employee has achieved the required criteria.

Employee training records are available at corporate offices, electronically, and should be maintained on project sites for review by client representatives, should they wish to review it. 6.1 SITE /FACILITY ORIENTATION All site/facility personnel, including TIKIGAQ subcontractors, must review or be provided a detailed briefing on the contents of dedicated site/facility specific safety d and sign the Employee Acknowledgement Form. Manager and Supervisors receive and more extensive program indoctrination, commensurate with their assigned responsibilities.

6.2 MANDATORY TRAINING All TIKIGAQ personnel engaged in activities are regulated by 29CFR1910.120/29CFR1926.65 an must enter a ―regulated‖ work area, exclusion zone (EZ) or are performing designated Hazardous Waste and/or Emergency Response Operations, or other tasks that may require specific training including, but may not be limited to the following: TIKIGAQ Corporate Safety Program, 11/09 6-2 Mangers , Line Supervisor or SSHO (Hazwoper): 40 or 24 hour training course in accordance with 29 CFR 1910.120(e)(3)/29 CFR 1926.65(e)(3) (as applicable to assigned duties) Annual 8 hour refresher training course in accordance with 29 CFR 1910.120(e)(8)/ 29 CFR 1926.65(e)(8). Management and Supervisor training course in accordance with 29 CFR 1910.120(e)(4)/29 CFR 1910.65(e)(4) 10-hour Construction Safety Training course (or equivalent) for construction related projects. First Aid and CPR ( 2 minimum per project site) Relevant Competent Person Courses (excavation, confined space, scaffold, fall protection, etc.), as applicable to the Manager, Supervisor or SSHO’s assigned duties. Project Specific training as may be required by project specific tasks (i.e. Lead awareness, fall protection, excavation and trenching etc.) Site Workers (Hazwoper): 40 or 24 hour training course in accordance with 29 CFR 1910.120(e)(3)/29 CFR 1926.65(e)(3) (as applicable as applicable to assigned duties) Annual 8 hour refresher training course in accordance with 29 CFR 1910.120(e)(8)/ 29 CFR 1926.65(e)(8). Site, facility or duty specific training as may be required by project specific tasks (i.e. Lead awareness, fall protection, respiratory protection, dangerous goods etc.) Mangers , Line Supervisor or SSHO (Construction): 10-hour Construction Safety Training course (or equivalent) for construction related projects. First Aid and CPR ( 2 minimum per project site) Relevant Competent Person Courses (excavation, confined space, scaffold, fall protection, etc.), as applicable to the Manager, Supervisor or SSHO’s assigned duties. Project Specific training as may be required by project specific tasks (i.e. Lead awareness, fall protection, excavation and trenching etc.) 6.3 MEDICAL SURVEILLANCE All employees who perform work at hazardous waste Sites or perform emergency response in accordance with 29CFR1910.120(a)(1)(i)-(v)/29CFR1926.65(a)(1)(i)-(v) will be subject to the TIKIGAQ medical surveillance program requirements. This program conforms to the requirements established by 29 CFR 1910.120(f)/1926.65 (f), medical surveillance. In addition, those individuals who must utilize respiratory protection devices, for whatever reason, shall also be evaluated in accordance with 1910.134(e).

In addition, it may be required to perform certain employee medical surveillance requirements under the specific requirements of 29CFR1910.1001 through 29CFR1910.1052 or TIKIGAQ Corporate Safety Program, 11/09 6-3 29CFR1926.1101 through 29CFR1926.1152, depending on the employees assigned duties site/facility specific conditions the employee may be exposed to during their assigned duties.

Pregnant or potentially pregnant personnel should discuss this matter with their medical care provider and direct supervisor or the human resources manager before performing any hazardous or potentially hazardous duties. TIKIGAQ Corporate Safety Program, 11/09 7-1 7.0 HAZARD COMMUNICATION 7.1 INTRODUCTION On May 25, 1986 the Occupational Safety and Health Administration (OSHA) placed in effect the requirements of a new standard called Hazard Communication (29 CFR 1910.1200). This standard establishes requirements to ensure that chemical hazards in the workplace are identified and that this information, along with information on protective measures, is transmitted to all affected employees. This section describes how TIKIGAQ employees are informed of the potential chemical hazards in their work environment so they can avoid harmful exposures and safeguard their health. Components of this program include:

• labeling; • securing and reviewing material safety data sheet (MSDS) or physical agent data (PADS); and • training. Common Hazard Communication Acronyms The following terms are commonly used acronyms that are associated with hazard communication. CPAI Chemical and Physical Agent Inventories CSM Corporate Safety Manual (TIKIGAQ) HCP Hazard Communication Program IDLH Immediate ly Dangerous to Life and Health MSDS Material Safety Data Sheet PADS Physical Agent Data Sheet PEL Permissible Exposure Limit PPE Personal Protective Equipment R PE Respiratory Protective Equipment TLV Threshold Limit Value 7.2 "EMPLOYEES “RIGHT TO KNOW ” Employees have the right to be aware of and trained to recognize the hazards of the chemicals and physical agents present in the work place. 7.3 AVAILABILITY OF INFORMATION The hazards of all chemicals produced in or imported to the workplace are evaluated, and that information concerning their hazards must be transmitted to employees. This transmittal of information is to be accomplished by means of container labeling and other forms of warning, material safety data sheets and employee training.

TIKIGAQ site or facility line supervisor or designated site or facility safety coordinators shall secure and maintain copies of any material safety data sheets (MSDS) or Physical Agent Data Sheets (PADS) other pertinent information, associated chemicals materials, TIKIGAQ Corporate Safety Program, 11/09 7-2 products or hazardous materials brought onto or stored at the project site or facility. This includes those materials that are being installed as a final contract product or materials used to execute site or facility operations. Such chemical hazard information shall be readily accessible during each work shift for employees when they are in their work area(s).

7.4 HAZARDOUS MATERIALS Some materials that are brought onto the project site or facility for normal use or are incorporated into the finished contract products must be carefully handled because of their toxicity, flammability, reactivity nature or other special hazards that may be associated with the material. Chemical or physical hazards associated with these materials must be understood, recognized, and controlled in the workplace such that worker exposure to these chemicals or physical hazards associated with them does not produce adverse affects.

7.4.1 Definitions Hazardous Material: Any substance or compound that has the capability of producing adverse effects on the health and safety of individuals. Toxicity: The ability of a substance to produce an unwanted effect when the chemical has reached a sufficient concentration at a certain site in the body. Hazard: The probability that the above concentration in the body will occur. Acute Effects: Short-term high concentrations and immediate results of some kind: illness, irritation, or death. Chronic Effects: Characterized by symptoms or disease of long exposure duration to low levels of contaminants. Mutagen: Chemical that affects the genetic system of the exposed people in such a way that it may cause cancer or an undesirable mutation to occur in some later generatio n. Teratogen: Chemical that may produce malformations of the fetus without inducing damage to the mother or killing the fetus. Flash Point: The lowest temperature at which a liquid gives off enough vapor to form an ignitable mixture with air and produce a flame when a source of ignition is present. Flammable Liquid: Any liquid having a flash point below 37.8 C (100 F). Combustible Liquid: Liquids having a flash point at or above 37.8 C (100 F). Vapor Specific Gravity: < 1 = Lighter than air; rises > 1 = Heavier than air; sinks 1 = Air's Specific Gravity Specific Gravity: < 1 = Floats > 1 = Sinks 1 = Water's Specific Gravity TIKIGAQ Corporate Safety Program, 11/09 7-3 7.4.2 Chemical Identification Most important factor in working with chemical substances or hazardous materials is to be able to readily and easily identify any hazards associated with the substance. One of the most widely recognized systems for the rapid identification chemicals and their associated hazards is the system developed by the National Fire Protection Association (NFPA). The NFPA regulates the identification of stationary Storage Tanks and smaller Containers at facilities . NFPA uses numbers and a color-coded diamond shaped label (NFPA 704 Diamond) to identify Flammability, Reactivity, and Health Hazards or other special characteristics associated with a particular chemical material or hazardous substance. A graphical representation of the NFPA 704 Diamond is identified below.

7.4.2.1 Identification of Flammability Color Code: Red 4 Materials which will rapidly or completely vaporize at atmospheric pressure and normal ambient temperature, or which are readily dispersed in air and which will burn readily.

3 Liquids and solids that can be ignited under almost all ambient temperature conditions.

2 Mat erials that must be moderately heated or exposed to relatively high ambient temperatures before ignition can occur.

1 Materials that must be preheated before ignition can occur. TIKIGAQ Corporate Safety Program, 11/09 7-4 0 Materials that will not burn.

7.4.2.2 Identification of Health Hazard Color Code: Blue 4 Materials which on very short exposure could cause death or major residual injury even if prompt medical treatment is given.

3 Materials which on short exposure could cause serious temporary or residual injury even if prompt medical treatment is gi ven.

2 Materials which on intense or continued exposure could cause temporary incapacitation or possible residual injury unless prompt medical treatment is given.

1 Materials which on exposure would cause irritation but only minor residual injury even if no treatment is given.

0 Materials, which on exposure under fire conditions, would offer no hazard beyond that of ordinary combustible material.

7.4.2.3 Identification of Reactivity Color Code: Yellow 4 Materials which in themselves are readily capable of detonation or of explosive decomposition or reaction at normal temperatures and pressures.

3 Materials which in themselves are capable of detonation or explosive reaction but require a strong initiating source or which must be heated under confinement before initiation or which react explosively with water.

2 Materials which in themselves are normally unstable and readily undergo violent chemical change but do not detonate.

1 Materials which in themselves are normally stable, but which can become unstable at elevated temperatures and pressures or which may react with water with some release of energy but not violently.

0 Materials which in themselves are normally stable, even under fire exposure conditions, and which are not reactive with water.

7.4.2.4 Identification of Other Hazards Color Code: White OXY = Oxidizer Acid = Acid ALK = Alkali COR = Corrosive W = Use no water Ra = Radiation Hazard TIKIGAQ Corporate Safety Program, 11/09 7-5 SA = Simply Asphyxiant 7.5 HAZARDOUS MATERIAL ACQUISITION PROCE SS This procedure shall be used when ordering any material that is or has the potential to be classified as a hazardous material. 1. Check to see if the material is already on site or at the facility. A copy of a Hazardous Material (HM) ― Master List‖ should be located in the area/location designated for Hazardous Material Storage Area. This list should reflect the current amount of materials stored in a designated Hazardous Material Storage Area. 2. If the material is not already in stock, check the HM Master List or with the site or facility line supervisor to see if the material has been approved for purchase or not already ordered. If the material is on the Master List, check for any special precautions.

3. If the material is not on the Master List and is scheduled for procurement, an MSDS, must be secured from the manufacturer at or before the time the material arrives in the workplace. If assistance is needed in obtaining a MSDS, contact your site or facility line supervisor or designated safety coordinator for assistance. 4. If the material is considered to be a ―hazardous material‖ , acquisition of a suitable substitute should be considered, wherever possible. If a substitute is not available, then one the necessary amount to complete assigned tasks should be procured and for a short term basis, only. 5.

Any special handling and worker protections conditions must be identified, acknowledged and implemented during the use of the material. 6. Storage of all hazardous materials shall be kept at a minimum wherever possible.

When any hazardous material is brought on to a site or facility, the quantity of the material and proper storage procedures must be confirmed with the site or facility line supervisor. Improper storage will not be allowed. Items must be labeled as they come in for accurate and instant identification in case of an emergency. In order to control inventory, each material stocked in the Hazardous Material Storage Area should assigned one of four possible numbers by the site or facility line supervisor. These four inventory control numbers appear on the Hazardous Material Master List and are defined as follows:

1. A specific amount of material shall be on hand at all times. (i.e., 10 gallons of latex paint, a can of ―Goof -Off‖ , or case of Liquid Gold Furniture Polish) 2. Reorder as needed. These are materials with a long shelf life and a low hazard rating. (NOTE: According to the HMIS 0-1 is considered low hazard rating and 2-4 is considered a high hazard rating.) Do not reorder these materials until the next job is pending. Excess of these materials may be kept, but they are not required stock items. i.e., repeatedly used oil based paints or WD-40. 3. Reorder only the specific amount needed. These are materials with a high hazard rating and no low rated substitute material. The amount on hand is only for the job TIKIGAQ Corporate Safety Program, 11/09 7-6 in progress. All excess materials shall not remain in stock and will be turned into the site or facility line supervisor for disposal. Aerosol cans with a high hazard rating, and Naphtha 225 fall into this category.

4. For deletion. These items are being deleted and shall not be reordered. 7.6 CHEMICAL AND PHYSICAL AGENT INVENTORIES 1. Chemical and physical agent inventories are lists of chemicals stored in the workplace. In each work area, there shall be a CPAI specific to that area.

2. All new chemicals shall be added to the list immediately when brought into the work area.

3. In each work area, a list of physical agents to which exposures are reasonable foreseeable or may be above the current TLV shall be compiled into the CPAI.

7.7 MSDS AND PADS 1. MSDS's and PADS's present the basic health and physical hazards along with general precautions, effects of over exposure, treatment, and other pertinent information. 2. The MSDS's/PADS's will be available prior to the use of a chemical or exposure to a ny physical agents.

3. The MSDS/PADs will be available to all employees in a conspicuous location at the site or facility location.

7.8 TRAINING All new employees shall be trained on the TIKIGAQ Hazard Communication Program. The training shall consist of the points listed below.

1. Orientation of TIKIGAQ Hazard Communication Program.

2. Information regarding areas where hazardous chemical or physical agents are present including methods and observations to detect the presence or release of hazardous chemicals or physical agents.

3. General measures employees can take to protect themselves, such as emergency procedures, work practices, and personal protective equipment.

4. General information on labeling, material requisition (outlined above), and location of MSDS and PADS.

5. Instruction on how to access MSDS/PADS.

6. Instruction on all emergency procedures and work practices.

All employees shall be trained on any new hazard that may arise in the workplace. The training shall consist of the points listed below. 1. Operations in the work area where the new chemical is present.

2. The physical and health hazards of the new chemicals or physical agents. TIKIGAQ Corporate Safety Program, 11/09 7-7 3.

Methods and observations that may be used to detect the presence or release of the new chemical or physical agent in the work area such as monitoring, visual appearance, or odor.

4. Protective measures to be taken, such as the use of engineering controls, appropriate work practices, emergency procedures, PPE, and labeling of secondary containers.

7.8.1 Attendance and Records Attendance at the training sessions will be mandatory and records will be kept on attendees and topics discussed. 7.9 LABELING OF CONTAINERS Labeling is a major source of information for advising employees of the safety and health hazards of chemicals. All primary and secondary labels shall as a minimum:

1. Identify the hazardous chemical; 2. Provide appropriate hazard warnings; and 3. Be legible, in English, and prominently displayed on the containers, or readily available throughout each work shift.

7.10 PRIMARY CONTAINERS • In addition to the requirements of the above, "Chemical Information," incoming containers shall have the name and address of the manufacturer, importer, or other responsible party.

• Any failure to have this information at the time of receipt shall be immediately reported to the site or facility line supervisor.

• Labels on incoming containers shall not be removed or defaced.

7.10.1 Portable Containers 7.10.1.1 Immediate Use Portable containers of chemicals need not be labeled when the chemical is transferred from labeled containers and which are intended for immediate use of the employee who performs the transfer during the work shift.

7.10.1.2 Not for Immediate Use Containers of chemicals transferred from labeled containers and not intended for immediate use by the employee performing the transfer shall be labeled accordingly. Information contained on the primary container will be transferred to the label affixed to the new container.

Instructions for the secondary container label are given in the following points.

1. Chemical or Trade Name: Use information as shown on the original label. (MANDATORY) 2. Manufacturer: Use same as on primary container or a responsible party where further information may be obtained. (MANDATORY) TIKIGAQ Corporate Safety Program, 11/09 7-8 3.

MSDS#: Write the number to identify the MSDS for this product identify where the MSDS can be found. Examples are "primary container" (some paint cans come this way), or Chemical Inventory Book, MSDS file in lab.

4. Danger, Caution, Warning: Check the most appropriate "Hazard Alert" word. these are often found on the label and or on the MSDS. (Non mandatory) 5. Hazards: This is not an exhaustive list of hazards. Check items as appropriate based on available information.

The blank under Inhalation is for other effects besides irritation that result from exposure of the lung. Examples are Narcosis, stupor, or CNS depression. (MANDATORY as appropriate).

6. Other Hazards: This space is for hazards not found above; examples include pyrophoric, carcinogen, reproductive hazard, causes olfactory fatigue, no odor, poison, shock sensitive, or forms explosive peroxide. (MANDATORY as appropriate) 7. Target Organs: If label or MSDS provides this information, list organ(s) effected by exposure to chemical. (MANDATORY if available) 8. Precautions: This space is non mandatory but of great value. Try to provide the most specific information relative to the chemical's use at the workplace (e.g., "Use Edmost Solvex gloves" is better than "Avoid skin contact" or "stored in Flammable Storage Building" rather than store away from heat and sparks").

7.11 RESPONSIBILITIES OF LINE SUPERVISORS AND SAFETY COORDINATORS 1. Identify hazards for respective work areas. 2. Ensure hazards are properly labeled. 3. Obtain/maintain copies of material safety data sheets, as required, of each hazardous material used in the work area and make them accessible to employees during each work shift. 4. Have the written Hazard Communication Program available to all employees. 5. Provide hazard-specific training for employees. 6. Identify hazardous materials in the hazard review section of the TIKIGAQ purchase requisition form. 7. Establish safe procedures.

8. Ensure that the protective equipment needed to work with the chemicals is available.

9. Instruct workers on possible hazards, safety precautions that must be observed, possible consequences of an accident, and procedures to follow if an accident does occur.

10. Enforce the proper use of protective equipment and established safety practices. 7.12 RESPONSIBILITIES OF EMPLOYEES TIKIGAQ Corporate Safety Program, 11/09 7-9 1.

Attend safety training meetings. 2. Perform operations in a safe manner. 3. Notify management immediately of any safety hazards or injuries. 4. Understand the properties of the chemicals and follow all precautions that apply to each specific task. 5. Choose a course of action that provides the most protection for yourself and to others in the area. 6. Report to your supervisor any unsafe condition seen in the area that would not permit you to work safely. 7.13 LINE SUPERVISOR OR SAFETY COORDINATOR RESPONSIBILITIES 1. Maintain a copy of the Hazard Communication Program. 2. Maintain a central file of material safety data sheets and physical agent data sheets. 3. Provide employee training programs. 4. Assist supervisors in developing hazard-specific training programs. 5. Oversee the Hazard Communication Standard written policy and implementation plans. 6. Alert on-site subcontractors to hazardous materials in work areas. 7. Alert on-site subcontractors that they must provide to their employees information on hazardous materials they bring to the work site. 8. Assist employees and supervisors to work safely by providing information on the hazardous properties of materials. 9. Recommend methods for controlling the hazards of specific operations. 10. Monitor the work environment for potential worker exposures to chemical materials. 7.14 GENERAL SAFETY PRECAUTIONS The following general safety precautions should be observed when working with chemicals. 1. Keep the work area clean and orderly. 2. Use the necessary safety equipment. 3. Carefully label every container with the identity of its contents and appropriate hazard warnings. 4. Store incompatible chemicals in separate areas. 5. Substitute less toxic materials whenever possible. 6. Limit the volume of volatile or flammable material to the minimum needed for short operation periods. 7. Provide means of containing the material if equipment or containers should break or spill their contents. 8. Obtain and read the Material Safety Data Sheets. TIKIGAQ Corporate Safety Program, 11/09 7-10 7.15 CHEMICAL DISPOSAL Contact a licensed hazardous material transporter and disposal facility for proper transportation and disposal of spent or waste chemical materials. Spent or waste chemicals and materials shall be transported and disposed of utilizing appropriate transportation and disposal documentation in accordance with Federal and State statues regarding the same. 7.16 TASK EVALUATION Each task that requires the use of chemicals must be evaluated to determine the potential chemical and physical hazards associated with the work. This hazard evaluation may be written or if the hazard is not significant, it may be a verbal or researched based evaluation. If it is in written form it must include the chemical or combination of chemicals that will be used in the work, as well as other materials that will be used near the work. If a malfunction during the operation has the potential to cause a serious accident, injury, illness or property damage, an Activity Hazard Analysis (AHA) must be prepared, implemented and followed. Operations must be planned to minimize the generation of hazardous wastes or materials. Additionally, unused chemicals should be recycled, to every extent possible. TIKIGAQ Corporate Safety Program, 11/09 7-11 7.17 HAZARDOUS MATERIAL MASTER LIST FORM Hazardous Material Master List This form must be completed prior to performing activities that expose personnel to hazardous chemicals products. Upon completion of this f orm, the line supervisor or SSHO will verify that training is provided on the hazards associated with these chemicals and the control measures to be used to prevent exposure to TIKIGAQ and subcontractor personnel.

Labeling and MSDS systems will also be exp lained. Project Name : Task Order: MSDSs will be maintained at the following location(s): Hazardous Chemical Products Inventory Chemical Quantity Location MSDS Available Container Labels Identity # Hazard TIKIGAQ Corporate Safety Program, 11/09 7-12 7.18 CHEMICAL SPECIFIC HAZARDS REVIEW FORM Project/Facility Name: Location:

Individual Performing Review: Title:

Chemical Reviewed Date:

The site or facility line supervisor or SSHO will use the product MSDS/PADs to provide the following information concerning the products listed above.

Participants Attending Hazardous Material Review:

NAME SIGNATURE NAME SIGNATUR E Physical/Health Hazards of Materials/Products:

Control Measures for Products Materials/Products:

Head: Face: Hands: Body: Respiratory; Spill/Release: First Aid: Fire: Methods or Observations Used to Detect a Release:

Training participants will have the opportunity to ask questions concerning these products and, upon completion of this training, will understand the product hazards and appropriate control measures available for their protection.

Copies of MSDSs, chemical inventories, and the written hazard communication program will be made available for employee review in the facility/project hazard communication file. TIKIGAQ Corporate Safety Program, 11/09 8-1 8.0 WORKER PROTECTION MEASURES (PHYSICAL/CHEMICAL) Protection of workers to overexposure of identified site site/facility physical or chemical hazards is a critical component in creating a healthy and safe working environment for our employees. This can be achieved by implementing the ―Hierarchy of Controls‖ for one or more of following Worker Protection Measures at all our project site or facility locations.

1) Engineering Controls 2) Administrative Controls 3) Use of Personal Protective Equipment (PPE) In addition to the above worker protection measures, in many work place conditions where chemical exposures (i.e. lead) or severe physical (i.e. heat, noise) worker exposure it is Best Management Practice (BMP) and even required by Federal and State law in many applications to institute various employee/workplace ―exposure assessments‖ via the use of ambient air or environmental monitoring equipment . These worker protection measures are always complemented by executing proper Hygiene and Decontamination Procedures , and are critical component in eliminating accidental or incidental exposure to chemical or mineral hazards that may be present in the work place. 8.1 ENGINEERING CONTROLS Generally, the most effective and preferred strategy is to "engineer the hazard out" by using control methods that physically change a machine or work environment. Engineering a hazard out of a work environment, it is the best and least intrusive means of providing worker protection. Methods to some examples of Engineering Controls eliminate or reduce hazards may include: Using certain equipment or processes/procedures to remove the hazard, or by substituting processes, equipment, materials, or other factors to lessen a perceived hazard; Isolating workers from a hazard by enclosing personnel in enclosed equipment cabs or other structures not susceptible to the hazardous conditions; Removing or redirecting the hazard such as with local and exhaust ventilation and taking advantage of natural ventilation conditions (i.e. wind speed and direction); Using standard dust suppression techniques 8.2 ADMINISTRATIVE CONTROLS Administrative controls in general are considered the "next best" strategy, if engineering control methods are insufficient. If the hazard cannot be ―engineered‖ to a less hazardous con dition, it may have to be administratively controlled.

Administrative Controls may be used to eliminate or reduce employee exposure to hazards to certain identified hazards include but are not limited to the following: TIKIGAQ Corporate Safety Program, 11/09 8-2 Developing new policies, procedures, and practices to reduce frequency/duration of exposure Revising work schedules to reduce the frequency/duration of exposure (i.e. Heat Stress) Alarms, signs, and warnings Always utilizing the ―Buddy System‖ for assigned work Worker training Monitoring potential worker exposure to hazardous materials (Air/Exposure monitoring) 8.2.1 Employee Exposure Monitoring It is company policy to conduct employee exposure monitoring utilizing appropriate air monitoring devices and procedures to verify that our employees are not exposed to hazardous materials, chemical vapors gases or mists, particulates or hazardous wastes in excess of Occupational Exposure Limits (OELS) set forth by the Occupational Safety and Health Administration (OSHA). This is achieved by the use of various available air monitoring devices and with sound industrial hygiene practices such that TIKIGAQ can provide a safe and healthful workplace for all of our employees, contracted personnel, and visitors.

Prior to commencement of site activities, an evaluation of the potential hazards associated with the work site will be undertaken. The evaluation will consist of summarizing available data concerning the site by reviewing current information in project files and from other sources. Typically available site information should be reviewed by a qualified Safety Coordinator, but can also be performed by a qualified site/facility line supervisor or project manager. Summarized or maximum concentration data is then incorporated into site/facility specific HSPs/APPs and are used as driver mechanisms for the implementation of site/facility air monitoring procedures and establishment of response action levels (ALs) to be followed during potential hazard producing operations.

If the site/facility information available is insufficient to adequately describe on-site conditions, an initial site characterization will be conducted to elicit any evidence of radiation hazards, explosion hazards, oxygen deficiency, toxic chemical vapors, or other conditions that may adversely affect the health and safety of site personnel. The objective of site characterization is to determine, on a preliminary basis, the presence of potentially hazardous conditions. Sufficient data should be obtained during the initial entry to map or screen the site/facility for various levels of organic vapors. These gross measurements are used on a preliminary basis to:

– Determine levels of personnel protection, – Establish site work zones, and – Select candidate areas for more thorough qualitative and quantitative studies.

When site/facility specific chemical constituents are present and known, air sampling sh ould be undertaken using techniques such as a Photo-Ionization Detector (PID) or Flame- TIKIGAQ Corporate Safety Program, 11/09 8-3 Ionization Detector, direct-reading colorimetric indicator devices, particulate monitors, other direct reading electronic instrumentation, or field sampling with laboratory analysis.

When the presence of certain types of organic vapors or gases are unknown, instruments such as a portable gas chromatograph or other similarly capable devices might be needed to determine potential worker exposures.

All air monitoring data collected as a result of site/facility operations must be recorded and included in the final site/facility project file.

See Attachment 7 of this CHSP for an example of a typical blank air monitoring log used for this purpose.

Personal air monitoring methods shall be preformed to further identify and specific types and quantities of airborne hazardous substances present in a worker Breathing Zone (BZ) in order to further determine or to verify that level of employee dermal and respiratory protection for site/facility personnel. Personal monitoring shall focus on the potentially highest exposed employees in each job classification. Sampling shall be representative for that job classification. OSHA/NIOSH sampling procedures shall be followed for personal air sampling events/processes. The following devices may be utilized by TIKIGAQ during employee personal air monitoring events.

 Personal sampling pumps – Draws air through a filter or cartridge which is sent to a lab for analysis  Canisters or Tedlar bags – Air is drawn into canister or bag by use of a pump or vacuum pressure  Sorbent Tubes – Sample is drawn through tube by use of a pump then tube is sent to lab for analysis  Color detector tubes (such as Drager) – Direct reading  Dosimeters or passive badges – Worn for a set time then sent to a lab for analysis In many DOD or public agency contract situations, specific employee exposure monitoring procedures or plans may be required to be developed and incorporated within the site/facility specific HSP/APP.

8.2.1.1 Perimeter Air Monitoring Where there are potential chemical, hazardous material, particulate, vapor or gas exposures to untrained or unprotected personnel in buildings or positions that are proximal to, adjac ent to TIKIGAQ operations it maybe be prudent or required to perform ―perimeter‖ air monitoring to verify or determine concentrations at these locations. Perimeter air monitoring is typically completed as ― fixed-location‖ air monitoring samples to determine various exposure concentrations at both upwind and downwind positions from the site/facility operations, based on wind speed, direction and position(s) of the perimeter feature to be monitored. At a minimum, one upwind (or background), two downwind, and two crosswind sampling locations should be monitored via OSHA or NIOSH standard methods for sample analysis to be performed. Where appropriate, direct reading air monitoring devices, may also be used in this process as well. In many DOD or public TIKIGAQ Corporate Safety Program, 11/09 8-4 agency contract situations, specific employee exposure monitoring procedures or plans may be required to be developed and incorporated within the site/facility specific HSP/APP.

8.3 PERSONAL PROTECTIVE EQUIPMENT The use of various types of Personal Protective Equipment (PPE) by TIKIGAQ employees may be advisable or required to facilitate a negative employee’s exposure to chemical or physical hazards that have been identified or may be present on project or facility sites or encountered during the execution of assigned work. Designated TIKIGAQ site/facility line supervisor or safety coordinator personnel must routinely a ssess the workplace operations/conditions and review requirements of established site/facility specific HSPs/APPS to determine if hazards are present, or are likely to be present, which necessitate the use of specific personal protective equipment. When the use of PPE is required, selected PPE for eyes, face, head, and extremities, protective clothing, respiratory devices, and protective shields and barriers, shall be provided, used, and maintained in a sanitary and reliable condition. PPE use may be deemed necessary to safeguard employees against exposures from chemical, physical, radiological or biological hazards which may be encountered in the workplace in a manner capable of causing injury or impairment in the function of any part of the body through absorption, inhalation or physical contact.

The implementation of PPE to protect employees against recognized chemical and physical hazards in the workplace should be considered as a last resort for hazard control and worker protection measures and only after the evaluation of other engineering or administrative hazard controls measures have been determined to be potentially ineffective, impractical or unfeasible. However, in many cases for active site and facility operations, the utilization of some types of PPE such as hard hats, safety glasses, hard toe work boots and ear plugs/muffs, chainsaw chaps and face shields considered a ―standard‖ prerequisite by TIKIGAQ employees before engaging in assigned tasks. In all cases were Hazardous Waste Operations and Emergency Response (HAZWOPER) or Construction related operations are ongoing, this will be the case. 8.3.1 Management Responsibilities Management is responsible for providing the resources, funding, and training resources necessary to enable TIKIGAQ employees to comply with the program PPE requirements.

8.3.2 Line Supervisor and Safety Coordinator Responsibilities 1. Review and asses activities and locations which may require the use of specialized PPE.

2. Ensure that PPE is worn by employees under supervisor oversight 3. Train employees in the proper use of PPE with assistance from the safety coordinator.

4. Where an employee has already been trained in the proper use, maintenance, stowage or disposal of required PPE but does not demonstration the understanding or skill required to adequately or safely use necessary PPE, the supervisor or designated safety coordinator shall retrain the employee. TIKIGAQ Corporate Safety Program, 11/09 8-5 5.

Periodically inspect PPE to ensure proper distribution, usage, maint ena nce, stowage or disposal as may be applicable.

6. Administer PPE components of the Safety Program and approve temporary deviations, which are authorized by designated safety coordinators.

8.3.3 Employee Responsibilities 1. Employees shall be responsible for PPE maintenance and are accountable for the care and use of assigned PPE.

2. Employees shall inform their supervisor whenever a need arises to use PPE for which the employee has not received training or when a condition exists where adequate PPE is not available.

3. Employee shall be required to attend training in the proper use, stowage, maintenance or disposal of PPE as it may be determined by TIKIGAQ. 8.3.4 Eye and Face Protection Eye injuries are the most common type of accident; however, they are the easiest to preven t. TIKIGAQ requires that each employee may be potentially exposed to eye from flying particles/debris, molten metal, liquid chemicals, specific acids or caustic liquids, chemical gases or vapors, or potentially injurious light radiation will utilize eye protection. This protection shall be provided at not burden to the employee. The use of eye protection will be used, but not limited to, the following situations to reduce or eliminate potential eye exposure hazards. 1. Eye protection devices in accordance with the most recent American National Standard Institute (ANSI) for eye protection (ANSI Z87.1) will be worn by bystanders or support personnel who are in close proximity to ongoing work which requires the use of goggles or face shields.

2. ANSI rated safety eyewear will be worn during all phases of HAZWOPER and construction related work, except where full face respiratory protection is worn.

3. Safety glasses will be worn when working on energized electrical circuits of 120 V/AC to ground or less.

4. Where there is a danger of flying particles or corrosive materials, employees must wear protective eyewear and/or face shields provided by TIKIGAQ. 5. Employees are required to wear safety glasses at all times in areas where there is a risk of eye injuries such as punctures, contusions or burns. 6. Employees who need corrective lenses are required to wear only safety eye wear that meets the ANSI Z87.1 standard when working in areas where there is a risk of eye injury. 7.

Employees shall use protective eyewear with filter lenses that have a shade number appropriate for the work being performed for protection from Radiant Energy (light) .

The following is a listing of appropriate shade numbers for various operations. TIKIGAQ Corporate Safety Program, 11/09 8-6 Filter Lenses for Protection Against Radiant Energy ____________________________________________________________________ Minimum(*) Operations Electrode Size 1/32 in. Arc Current Protective Shade _____________________________________________________________________ Shielded metal arc welding Less than 3 ......... Less than 60 ... 7 3- 5 ................. 60 -160 ......... 8 5- 8 ................. 160 -250 ........ 10 More than 8 ......... 250 -550 ........ 11 _____________________________________________________________________ Gas metal arc welding and flux cored arc welding less than 60 ... 7 60 -160 ......... 10 160 -250 ........ 10 250 -500 ........ 10 _____________________________________________________________________ Gas Tungsten arc welding less than 50 ... 8 50 -150 ......... 8 150 -500 ........ 10 _____________________________________________________________________ Air carbon (Light) ............. less than 500 .. 10 Arc cutting (Heavy) ............. 500 -1000 ....... 11 _____________________________________________________________________ Plasma arc welding less than 20 ... 6 20 -100 ......... 8 100 -400 ........ 10 400 -800 ........ 11 _____________________________________________________________________ Plasma arc (light)(**) ......... less than 300 .. 8 cutting (medium)(**) ........ 300 -400 ........ 9 (heavy)(**) ......... 400 -800 ........ 10 _____________________________________________________________________ Torch brazing ................ 3 Torch soldering ................ 2 Carbon arc welding ................ 14 _____________________________________________________________________ TIKIGAQ Corporate Safety Program, 11/09 8-7 Filter Lenses for Protection Against Radiant Energy _____________________________________________________________________ Minimum(*) Operations Plate thickness -inches Plate thickness -mm Protective Shade _____________________________________________________________________ Gas Welding:

Light Under 1/8 ............ Under 3.2 ......... 4 Medium 1/8 to 1/2 ........... 3.2 to 12.7 ....... 5 Heavy Over 1/2 ............. Over 12.7 ......... 6 _____________________________________________________________________ Oxygen cutting:

Light Under 1 .............. Under 25 .......... 3 Medium 1 to 6 ............... 25 to 150 ......... 4 Heavy Over 6 ............... Over 150 .......... 5 ______________________________________________________________________ Footnote(*) As a rule of thumb, start with a shade that is too dark to see the weld zone. Then go to a lighter shade which gives sufficient view of the weld zone without going below the minimum. In oxy- fuel gas welding or cutting where the torch produces a high yello w light, it is desirable to use a filter lens that absorbs the yellow or sodium line in the visible light of the (spectrum) operation. Footnote(**) These values apply where the actual arc is clearly seen. Experience has shown that lighter filters may be used when the arc is hidden by the work piece.

8. Where it is identified that employees are exposed to physical or chemical hazards (exclusive of Radiant Energy) to the face and eyes, the following table shall be used as a guide in the selection of proper face and eye protection for the hazards and operations noted. Protection Type 1. GOGGLES, Flexible Fitting - Regular Ventilation 2. GOGGLES, Flexible Fitting - Hooded Ventilation 3. GOGGLES, Cushioned Fitting - Rigid Body 4. SPECTACLES, Metal Frame, with Side shields (1) 5. SPECTACLES, Plastic Frame - with Side shields (1) 6. SPECTACLES, Metal -Plastic Frame - with Side shields (1) 7. WELDING GOGGLES, Eyecup Type - Tinted Lenses (2) 7A. CHIPPING GOGGLES, Eyecup Type - Clear Safety Lenses 8. WELDING GOGGLES, Coversepc Type - Tinted Lenses (2) 8A. CHIPPING GOGGLES, Coverspec Type - Clear Safety Lenses 9. WELDING GOGGLES, Coverspec Type - Tinted Plate Lens (2) 10. FACE SHIELD (Available with Plastic or Mesh Window) 11. WELDING HELMETS (2) Footnote(1) Non- side shield spectacles are available for limited hazard use requiring only frontal protection. Footnote(2) See Table E -2, in paragraph (b) of this section, Filter Lens Shade Numbers for Protection Against Radiant Energy. TIKIGAQ Corporate Safety Program, 11/09 8-8 Applications ________________________________________________________________________\ _ | | | | Recommended protectors: Operation | Hazards | Bold type numbers signify | | preferred protection _________________ _|________________________|___________________________\ _ | | Acetylene- Burning, | Sparks, harmful rays, | 7, 8, 9. Acetylene- Cutting,| molten metal, flying | Acetylene- Welding | particles............ | ___________________|________________________|___________________________\ _ | | Chemical Handling | Splash, acid burns, | 2, 10 (For sever exposure | fumes................ | add 10 over 2). ___________________|________________________|___________________________\ _ | | Chipping...........| Flying particles.......| 1, 3, 4, 5, 6, 7A, 8A. ___________________|________________________|___________________________\ _ | | Electric (arc) | Sparks, intense rays, | 9, 11,(11 in combination welding...........| molten metal..........| with 4, 5, 6, in tinted | | lenses advisable) ___________________|________________________|___________________________\ _ | | Furnace operations.| Glare, heat, molten | 7, 8, 9 (For severe | metal.................| exposure add 10). ___________________|________________________|___________________________\ _ | | Grinding- Light.....| Flying particles.......| 1, 3, 4, 5, 6, 10. ___________________|________________________|___________________________\ _ | | Grinding- Heavy.....| Flying particles.......| 1, 3, 7A, 8A (For severe | | exposure add 10) ___________________|________________________|____________________________ | | Laboratory.........| Chemical splash, | 2 (10 when in combination | glass breakage........| with 4, 5, 6). ___________________|________________________|____________________________ | | Machining..........| Flying particles.......| 1, 3, 4, 5, 6, 10. ___________________|________________________|___________________________\ _ | | Molten metal’s. .....| Heat, glare, sparks, | 7, 8, (10 in combination | splash................| with 4, 5, 6, in tinted | | lenses) ___________________|________________________|____________________________ | | Spot welding.......| Flying particles, | 1, 3, 4, 5, 6, 10 | sparks................| ___________________|________________________|____________________________ 8.3.5 Foot Protection This section will ensure that all TIKIGAQ employees will have the proper foot protection for the prevention of foot injuries.

TIKIGAQ Corporate Safety Program, 11/09 8-9 1. All employees shall wear sanctioned (ANSI Z41 ) hard toe (steel or composite), sturdy work boots that provides sufficient ankle support (lace-up). Boots should preferably be of leather construction. 8.3.6 Hearing Protection Unprotected exposure to excessive noise levels may lead to gradual and permanent hearing loss. The greater the intensity of a noise and the longer a person is exposed to the noise, the greater the chance of hearing loss. A hearing loss can be permanent or temporary. After certain noise exposures, a person may experience a temporary threshold shift (hearing loss) that results in the inability to hear certain sounds. The ability to hear may return however, repeated or intense noise exposure can prevent this recovery, resulting in permanent hearing loss. This section contains information on the effects, evaluation, and control of noise. For assistance in evaluating a potential noise exposure, contact the designated safety coordinator. 8.3.6.1 Danger of Noise Exposure • Employee exposures to high levels of noise may cause hearing loss. This loss can be temporary or permanent. • Noise which has a low but steady decibel ( dB) level may induce hearing loss if the exposure is chronic. (i.e. exposed 8 hrs a day for a long period of time.) • Temporary hearing loss or auditory fatigue occurs after a few minutes exposure to an intense noise but is recoverable following a period of time away from the noise. • If the noise exposure is repeated, there may be only a partial hearing recovery and the loss becomes permanent. • Typically, significant hearing losses occur first in the frequency range of 3,000 to 6,000 hertz (Hz). Losses in this frequency range are not critical to speech perception, and the individual usually is completely unaware of this initial symptom. With longer exposures, the hearing loss spreads to lower frequencies, which will affect speech perception. 8.3.6.2 ACGIH Standards TIKIGAQ has adopted the noise exposure limits established by the American Conference of Governmental Industrial Hygienists (ACGIH) as a standard for occupational noise exposure. • Exposure to continuous noise above 85 dBA is not permitted without ear protection. • Personnel must not be exposed to impact noises exceeding 140 dBA. Impact noises occur at intervals of greater than one per second. (i.e. the noise made by a metal shear) • Since individual susceptibility varies, some people will be harmed by noise well below the 85 dB level; others can tolerate much higher levels with no damage whatsoever. 8.3.6.3 Reducing Noise Exposure Noise exposure can be reduced by using engineering controls, administrative procedures, or personal protective devices. TIKIGAQ Corporate Safety Program, 11/09 8-10 8.3.6.4 Engineering Controls Reduction of noise production at the source Proper design of new machines.

• Modification of present machines. • Proper repair and upkeep of equipment. • Use of appropriate mufflers. • Use of vibration dampers on machines. Reduction of noise transmission • Increase distance between noise and personnel exposed. • Construction of barriers between noise source and personnel. • Sound treatment of ceilings and walls. 8.3.6.5 Administrative Procedures • Job schedule changes • Personnel rotation 8.3.6.6 Personnel Protective Devices Ear plugs Earmuffs 8.3.6.7 Hearing Protection Devices Federal and state occupational safety and health regulations require that whenever employees are exposed to excessive noise levels, feasible engineering or administrative controls must be used to reduce these levels. When these control measures cannot be completely accomplished and/or while such controls are being initiated, personnel must be protected from the effects of excessive noise levels. Such protection can, in most cases, be provided by wearing suitable protective hearing devices. Single use type ear plugs must be discarded after use to prevent ear infections. Protection greater than that provided by a single device can be obtained by wearing ear plugs under an earmuff. While the reduction provided by wearing both devices simultaneously is considerably less than the sum of the individual attenuation, it is still greater than when either device is worn separately. • Approved hearing protective equipment will be available to every employee working in areas where continuous noise levels exceed 85 dB. • To be effective, ear protectors must be properly fitted and employees will be instructed in their use and care. 8.3.7 Head Protection Personnel must wear hard hats which comply with ANSI Standard #Z89.1. TIKIGAQ Corporate Safety Program, 11/09 8-11 1.

Hard hats must be worn in work environments areas where there is a potential for injury to the head from falling objects and at all times while at construction sites or when performing construction related work. 2. At TIKIGAQ, hardhats are required in designated areas, or when deemed appropriate to protect an employee from head injury.

3. When wearing a hardhat, wear it in the manner which is determined to be correct by the manufacturer. Keep it squarely on your head with the inside band properly adjusted. Seek assistance from your supervisor or designated safety coordinator if you are having trouble adjusting the hardhat. 8.3.8 Hand Protection TIKIGAQ may require employees to use appropriate hand protection when employees' hands are exposed to hazards such as those from skin absorption of harmful substances; severe cuts or lacerations; severe abrasions; punctures; chemical burns; thermal burns; and harmful temperature extremes. Superviso r’s or designated safety coordinators should base the selection of the appropriate hand protection on an evaluation of the performance characteristics of the hand protection relative to the task(s) to be performed, conditions present, duration of use, and the hazards and potential hazards identified. Appropriate hand protection shall be worn by all TIKIGAQ employees where the potential for hand injuries exist.

At a minimum, TIKIGAQ employees will wear hand protection for the following exposures conditions:

1. Using harmful corrosive substances and processes or other significant chemical exposures 2. Where there is a high probability of hand injuries of an abrasive, puncture, cutting, pinching or crushing potential; 3. Performing regular assembly or disassembly of heavy system components; 4. Using hand-held earth compactors, snow blowers or other vibratory equipment; 5. Any cold weather operations;(i.e., snow shoveling) 6. Normal maintenance shop activities; 7. Abnormal ly wet conditions (rubber gloves); Handling scrap materials or other demolition debris.

8. When performing any type of cutting or welding activities 9. Other during other identified activities and or in works areas as identified by supervisors or designated safety coordinators.

8.3.9 Protective Equipment for Chemical Exposures When full body protection is required for employees to eliminate exposure to chemicals, hazardous waste, hazardous materials or particulates, fumes, mists or vapors, then this protection shall be in accordance with the requirements of 29 CFR 1910.120, Appendix B for both fully-encapsulating and non-encapsulating clothing (i.e. levels A, B and C). TIKIGAQ Corporate Safety Program, 11/09 8-12 8.3.10 Respiratory Protection Harmful air-borne contaminants have properties capable of producing adverse health effects. These contaminants can be in the form of particles (i.e. dust), fumes, gases/vapors, and/or mists/sprays. Engineering and/or administrative controls which are feasible and effective shall be instituted to control the exposure to personnel. Only when such controls are not feasible, effective or prior to their implementation shall respiratory protective equipment be utilized. 1. All respiratory equipment purchased and used at TIKIGAQ will carry a NIOSH approval.

2. The substance(s) creating the hazard must be identified in order to determine acceptable methods or equipment to be used for protection. The following criteria must be evaluated:

a. The nature of hazards and significant properties of the substances; b. The severity and effects of exposure at various concentrations; c. Possible engineering controls or limiting exposure duration; d. Replacement of substance with less toxic compounds; and e. Necessary emergency measures to protect individuals, should administrative controls or protection be inadequate or fail.

3. Employees with physical disabilities such as lung disease, heart disease, or other problems which could make use of a respirator harmful or unsafe, will not be assigned jobs requiring their use.

4. The safety coordinator or office appointed safety representative will assist supervision in ensuring proper precautions/safeguards are taken. S/he is available to assist by recommending ventilation requirements, protective equipment selections, employee training requirements, and other technical safeguards.

5. No respirator is capable of preventing all airborne contaminants from entering the wearer's breathing zone. Respirators help protect against certain airborne contaminants by reducing airborne contaminant concentrations in the breathing zone to below the recommended exposure level. 6 All employees who must wear any tight fitting respirator must be clean shaven. No facial hair (i.e., beards) or other interference is allowed between the face and the seal edge of the respirator or allowed to interfere with valve function.

7 All employees required to use respirators shall receive training on the proper use, care, and limitations of RPE. (Respiratory Protection Equipment) 8 Personnel required to wear respiratory protection will be evaluated to determine their ability, both physiologically and psychologically, to wear the required devices under foreseeable circumstances.

9 Respirator fit testing (conducted by an approved tester) shall be quantitative. For explicit details associated with the TIKIGAQ Respiratory Protection Program, please see section 8.0 of this CHSP. TIKIGAQ Corporate Safety Program, 11/09 8-13 8.4 GENERAL PERSONAL PROTECTIVE EQUIPMENT OVERVIEW As always verify with the site/facility line Supervisor or designated Safety Coordinator for proper selection and use of PPE to mitigate potential employee exposure to recognized project specific hazards or exposures. PPE WHEN NEEDED Eye and Face Protection • When in close proximity to work requiring goggles or face shields. • During carpentry, land clearing, demolition or other construction related activities where eye and face hazards exist. • Whe n working on energized electrical circuits of 120 VAC to ground or less. • When there is a danger of flying particles or corrosive materials. • When there is a risk of eye injuries such as punctures, contusions, burns and exposure to ultraviolet radiation or lasers. • Potential exposure to Bloodborne Pathogens • Potential risk to identified chemical and physical hazards Foot Protection • At all times when working and appropriate for job conditions (hard toe, sturdy footwear with ankle support and preferab ly leather in construction or footwear providing the above plus chemical/liquid resistance , when required) Hearing Protection • When exposed or potentially exposed to noise above 85 dB or potentially damaging noise hazards Head Protection • In areas sub ject to falling objects. • When on construction sites. • In other designated head protection areas. Respiratory Protection • When there is potential exposure to high levels of a chemical, particulate, dust, mist , vapor or fume in excess of established exp osure limits. Hand Protection • When using or exposed to harmful chemical agents or corrosive materials • When exposed to sharp or pointed objects, edges or tools • In cold weather operations. • Normal heavy equipment maintenance or shop activities. • Wh en using energized power and hand tools • When handling chemical or waste materials. (i.e., chemicals, scrap material, demolit i on) • Abnormal ly wet conditions. • Potential exposure to Bloodborne Pathogens TIKIGAQ Corporate Safety Program, 11/09 8-14 8.5 PROPER WORKER HYGIENE & D ECONTAMINATION PRACTIC ES Wherever hazardous waste, hazardous materials or chemical products are handled or workers are just working in dusty/dirty environments it is extremely important for workers to utilize proper personal hygiene procedures to ensure that workers are not directly or indirectly ingesting, inhaling or have dermal contact with such materials. Proper worker hygiene and decontamination procedures (when required) are important to eliminate any inadvertent exposure to hazardous waste, hazardous materials, chemical products general nuisance dust/dirt and it is important for site personnel to exercise to the following procedures: 1) Eating, drinking, smoking and other tobacco use shall only be conducted in designated and unrestricted areas and not in any areas where there is any exposure to hazardous material/waste, flammable/combustible liquids, and gases.

2) Wash hands and face, if applicable, before eating, drinking, smoking or otherwise using tobacco.

3) Shower as soon as feasible after completing field activitie s.

The SSHO must establish and monitor the decontamination procedures and their effectiveness. Decontamination procedures found to be ineffective will be modified by the SSHO. The SSHO must ensure that procedures are established for disposing of materials generated on the site.

8.5.1 Decontamination Requirements Where Level D modified, Level C, Level B or Level A PPE is required for worker protection (usually during TIKIGAQ HAZWOPER operations or hazardous materials handling), it is essential for workers to maintain the good personal hygiene practices. Proper and specific decontamination procedures will be required where these types of PPE are required, to ensure negative worker exposure to any identified contaminants, or hazardous waste, or hazardous materials. These procedures are identified and illustrated below. Personnel Sample Equipment Heavy Equipment  Boot wash/rinse  Glove wash/rinse  Outer - glove removal  Body - suit removal  Inner - glove removal  Respirator removal  Hand wash/rinse  Face wash/rinse  Shower ASAP  Col lect, properly containerize, label and dispose of all spent of PPE  Collect, properly containerize, label and dispose of all spent decontamination fluid contain for offsite disposal  W ash/rinse equipment  Solvent - rinse equipment  Contain solvent waste for off site disposal  Collect, properly containerize, label and dispose of all spent of decontamination fluid and residual solids for offsite disposal  Power wash  Steam clean  Collect, properly containerize, label and dispose of all spent of decontamination fluid or residual solids TIKIGAQ Corporate Safety Program, 11/09 8-15 Workers/equipment shall be fully decontaminated prior to leaving designated restricted access zones. Only disposable worker protective clothing will be utilized, and as such the use of on-site showers is not anticipated. Workers will be instructed to shower at off-site lodging facilities, which are in close proximity to the project site, immediately after the end of the scheduled work shifts. If Level Modified D, Level C, B or A PPE is ever required during the execution of the site/facility work, disposable protective coveralls shall have hoods and boot coverings to minimize potential dermal contact or contact with designated work clothes. Use of dedicated clothing washing or laundering facilities should not be needed so long as workers strictly adhere to required PPE use and decontamination requirements and disposable type gloves, coveralls and boots are utilized, to the extent possible. Hand washing facilities must be provided at the site and used prior to entering designated ―support zones‖. Any utilized respiratory protection equipment shall be fully cleaned, decontaminated and properly stored in accordance with the respiratory protection program. Respiratory protection devices may also require intermediate decontamination prior to resuming work after scheduled breaks. Prior to the end of a scheduled work shift, all generated potentially lead impacted PPE shall be containerized to minimize the potential for the spread of contamination and all hand tools used in the daily events will be decontaminated/containerized and stored to promote good housekeeping practices.

No eating, drinking, or smoking is permitted in contaminated areas and in exclusion or decontamination zones. The line supervisor and SSHO should establish areas for eating, drinking, and smoking. Contact lenses are not permitted in exclusion or contaminant reduction zones. In all cases, whether Level D modified, Level C, Level B or Level A PPE is required, it is essential for workers to maintain good positive personal hygiene practices an d follow proper decontamination procedures for all activities.

Figure 7-6 is a flow chart of a typical Personnel Decontamination Line. TIKIGAQ Corporate Safety Program, 11/09 8-16 Exclusion Zone Boundary W ind Direction Equipment drop onto clean surface PPE to be re - used PPE to be disposed Dispose of PPE as specified in the HSP Change out respirator cartridges or air tank. If removed, replace outer boots and gloves. Dispose of PPE as specified in Section 7.1 of the HSP Remove outer gloves and boots or boot covers Remove coveralls (e.g., Tyvek ) and inner gloves If worn, remove APR, SAR or SCBA. Dispose of ca rtridges and Decon respirator as specified in the HSP W ash face and hands. Shower as soon as possible. Outer glove, boot and coverall (e.g., Tyvek ) wash Outer glove, boot and coverall rinse Remove outer boots, gloves, and coveralls Remove inner gloves and coveralls Return to exclusion zone Figure 7 - 6 Personnel Decontamination Line Sample preparation Sample decontamination and packing Notes: 1 . This figure can be used as a guide to establish a decontamination line when used PPE will either be disposed of or re - used, and can be applied to any level of protection. 2. The stations illustrated below may be removed when not applicable (e.g., no respirator station if not wearing Level C or B). 3. The SHSO may modify the decontamination sequ ence based on site - specific conditions. Sample Table TIKIGAQ Corporate Safety Program, 11/09 9-1 9.0 RESPIRATORY PROTECTION PROGRAM 9.1 PURPOSE The TIKIGAQ Corporation Respiratory Protection Program has been established to coordinate the use and maintenance of respiratory protective equipment as determined necessary to 1) reduce employee exposure to toxic chemical agents, asbestos, lead based paint, and other identified hazardous work environments; and 2) ensure employees are trained in, and familiar with, respirator use, fit, maintenance, cleaning, and associated limitations and applications. 9.2 S COPE This Respiratory Protection Program is provided as a regulatory guide for employees of TIKIGAQ to prevent occupational diseases caused by breathing contaminated air. To minimize employee exposure to potentially hazardous chemical substances, the primary objective shall always be to achieve the needed control, whenever feasible, through engineering methods (such as exhaust ventilation) or administrative control. It is recognized, however, that for certain operations, the use of engineering controls may not be feasible or practical. Under these circumstances or during an interim period while engineering controls are being developed or installed, the use of personal protective respiratory equipment may be necessary. A sound and effective program is essential, therefore, to ensure that the personnel using such equipment are adequately protected. 9.3 R EGULATORY COMPLIANCE Th is Program encompasses the regulations of 29 CFR 1910.134, as well as additional measures deemed necessary by TIKIGAQ, to execute assigned tasks safely and effectively. TIKIGAQ updates this Program as the Code of Federal Regulations (CFRs) are amended and at least annually. 9.4 R ESPIRATORY PROTECTION PROGRAM Where an identified or perceived respiratory hazard may exist, the primary measure for controlling occupational exposure caused by breathing air contaminated with harmful dusts, fogs, fumes, mists, gases, smokes, sprays, or vapors, shall be by preventing atmospheric contamination of the workers breathing zone. This shall be accomplished, as far as feasible, by instituting accepted engineering control measures (for example, enclosure or confinement of the operation, general and local ventilation, and substitution of less toxic materials) or by implementing administrative control processes which achieve the same level of protection against occupational exposure. When effective engineering or administrative controls are being implemented, are determined and documented as being infeasible, or are determined to be ineffective, appropriate respiratory protection may be required or advisable. Under these circumstances, it is essential that the correct type of equipment is used, that it is clean and in good working order, that a good fit is ensured, and that the user is adequately trained in the use, care, and limitations of the protective device. The Respiratory Protection Program described below sets forth accepted practices governing selection TIKIGAQ Corporate Safety Program, 11/09 9-2 and use of respirators, and provides information for training and guidance on fitting, care, and maintenance of the respiratory equipment. 9.5 P ROGRAM ADMINISTRATION Management shall designate a Safety & Health Representative to be responsible for the implementation of the TIKIGAQ Respiratory Protection Program within their division area(s). All Health and Safety Representatives are charged with the following responsibilities: 1. Supervision of respirator selection procedure. 2. Establishment and implementation of periodic training sessions for respirator users. 3. Establishment and implementation of a program for cleaning, inspection, and maintenance of respiratory equipment. 4. Designation of proper storage areas of respiratory equipment. 5. Establishment of issuance and accounting procedures for users of respiratory equipment. 6. Assurance that the necessary medical approval has been received for each user of respiratory equipment. 7. Inspections and evaluations of all aspects of the Respiratory Protection Program to ensure continued functioning and effectiveness. The Corporate Health and Safety Manager (CHSM) shall serve as the Respirator Program Manager and shall review and insure that all divisional managers are performing their assigned tasks. For additional help on any questions or problems concerning the proper selection and use of respirators, consult the corporate Health and Safety Manager. 9.5.1 Employer Responsibility The employer is responsible for the following: 1. Respirators shall be provided by the employer when they are necessary to protect the health of the employee. 2. The employer shall provide the respirator that is applicable and suitable for the intended purpose. 3. The employer shall be responsible for the establishment and maintenance of a respiratory protection program. 4. The employer shall train the employee in the proper use and care of their assigned respirator. 5. The employer shall provide fit testing to ensure proper fitting respirators for each employee assigned a respirator. 6. The employee shall provide medical evaluations of employees to determine if the employee is able to wear a respirator without endangering the employee’s health. TIKIGAQ Corporate Safety Program, 11/09 9-3 9.5.2 Employee Responsibility All employees are responsible for the following: 1. The employee shall use the respiratory protection in accordance with instructions and training received. 2. The employee shall be responsible for cleaning, and inspecting of his/her respirator, in accordance with instruction and training received. If the respirator is damaged or not functioning properly return your respirator to your supervisor so he/she can replace it with a functional one of the same make, model and size. 3. The employee shall report any problem, malfunction, or improper fit of the respirator to his supervisor. It is the employee’s responsibility to inform their Supervisor or Health and Safety Representative of any situation affecting the fit of your respirator.

4. Employees required to wear any respirator shall have facial hair clean shaven at all points of contact for the respirator used. This is to insure that a quality seal is achieved between the respirator and the face. 9.6 R ESPIRATOR SELECTION The CHSM, Certified Industrial Hygienist (CIH), HSO/HSPA is responsible for selecting the appropriate respirator for your specific task. Selection criteria are determined to meet employee exposure requirements established by OSHA, except in cases where TIKIGAQ has adopted more stringent respiratory protection requirement to adhere with current best practice and/or more stringent State requirements. Contact your Superintendent or designated Safety Coordinator if any doubt exists concerning the correct respirator for the assigned task. At present, TIKIGAQ may utilize the following respiratory protective devices as part of its executable work:  Particulate Masks  ½ Face  Full Face APR  Self Contained Breathing Apparatus (SCBA)  Supplied Air Respirator, pressure demand The following respirator selection requirements are provided for your protection; adherence to them may save your life: 1. No respirators shall be purchased or used unless the intended application has been approved by the CHSM or CIH. 2. Only NIOSH-approved respirators shall be used. 3. Respirators shall be selected on the basis of the potential hazard to which the worker is exposed. The following factors must be considered in making this selection: a . The identity of the substance(s) present in the work environment for which protection is needed. b. The physical state of the contaminant (gas, vapor, dust, mist, asbestos fiber, etc., or a combination) c. The permissible exposure limit or toxicity of the substance. TIKIGAQ Corporate Safety Program, 11/09 9-4 d. Exposure measurements showing the concentrations likely to be encountered. e. The protection factor listed for the respirator type. f. The possibility of skin absorption or severe eye irritation. g. The possibility of oxygen deficiency. h. Any limitations or restrictions applicable to the types of respirators being considered that could make them unsafe in the environment involved. 4. At no time will a respirator be selected that offers less protection than is required for the particular condition(s) under which it is to be used. However, a respirator type offering a greater protection factor than needed may be selected. 5. Measurements to determine or predict the potential exposure concentrations shall be made by or in consultation with the project IH, CIH, CHSM or other qualified and authorized Health and Safety professional. 6. No respirator shall be used for any purpose unless the Respirator Selection Checklist for that application has been completed and the employee has been fit tested for the specific respirator. 9.7 E XCLUSIVE EMPLOYEE USE TIKIGAQ will make every attempt to ensure that employees are assigned an individual respirator for exclusive use. An exception to this exclusive-use policy may be permitted for equipment used in emergency or rescue purposes. In some cases where it could be necessary for a respirator to be used by more than one worker, it must be thoroughly cleaned and disinfected after each use. 9.8 U SER TRAINING Any worker required to wear a respirator at any time shall receive training in donning and doffing, cleaning and storage, maintenance and inspection, fit testing, proper usage, and limitations of the respirators used at TIKIGAQ. Training at this facility shall be conducted by the Safety & Health Engineer or qualified training professional. For those projects outside of Anchorage, user training shall be conducted by the CHSM, HSO, Health and Safety Representative, other qualified individual or vendor, under the supervision of the CHSM. All employees have an opportunity to wear the respirator in a safe, uncontaminated atmosphere prior to usage on the job. A test will be performed to ensure the selected respirator fits adequately. Please see Section 9.9, fitting, for more information on fit testing. Employees will sign a form indicating you have been trained and fit tested in your respirator. On this form, list the make, model, and size of respirator(s), and the Fit Factor that gave you an adequate fit and in which you were trained. This will be part of your permanent company record. Employees will receive annual retraining. If th e anniversary of an employee’s annual training is past due, the employee must receive retraining prior to utilizing respiratory protection. You must be trained on any new respirator obtained by TIKIGAQ prior to using it on the job. The Safety Coordinator or Line site/facility line supervisor will TIKIGAQ Corporate Safety Program, 11/09 9-5 inform you when retraining is needed; if you have any questions regarding retraining, see the Health and Safety Manager, or authorized designate. At a minimum, the following items shall be covered in the training session(s): 1. The nature of the respiratory hazard. For example, what specific chemical substances are present; what areas, operations, or conditions may result if the respirators are not used. A Material Safety Data Sheet (MSDS) may be useful for the latter. 2. An explanation of why engineering controls are not immediately possible and a discussion of what efforts are being made to eliminate the need for respirators. 3. An explanation of why the respirator type is the proper one and what factors effect selection. 4. A discussion and demonstration on how to use the respirator; for example, how to put it on, tighten the straps, test for proper fit, etc. 5. Instruction on the proper techniques and importance of cleaning, disinfecting, inspection, maintenance, and storage of the respirator. 6. A discussion of the capabilities and limitations of respirator; for example, in what environment or under what circumstances (such as oxygen deficiency) the respirator does not offer adequate protection. (These limitations are generally listed on the container in which the respirator is shipped, or in the user’s manual.) 9.9 FITTING Employees using a tight-fitting face piece respirator must fit tested prior to initial use of the respirator, whenever a different respirator face piece (size, style, model or make) is used, and at least annually thereafter. An additional fit test must be performed whenever the employee reports, employer, supervisor, program administrator, Physician or other Licensed Health Care Professional (PLHCP), makes visual observations of changes in the employee's physical condition that could affect respirator fit. Such conditions include, but are not limited to, facial scarring, dental changes, cosmetic surgery, or an obvious change in body weight. Fit tests will be repeated at least annually or sooner if there is any doubt as to a respirator’s fit. Both Qualitative Fit Test (QLFT) and Quantitative fit test (QNFT) respiratory fit test procedures are utilized for TIKIGAQ respiratory fit testing procedures. A QLFT means a pass/fail fit test to assess the adequacy of respirator fit that relies on the individual's response to a test agent. QLFT may only be used to fit test negative pressure air- purifying respirators that must achieve a fit factor of 100 or less. A Quantitative fit test QNFT means an assessment of the adequacy of respirator fit by numerically measuring the amount of leakage into the respirator. The fit test shall be administered using an OSHA-accepted QLFT or QNFT protocol. If the fit factor, as determined through an OSHA-accepted QNFT protocol, is equal to or greater than 100 for tight-fitting half face pieces, or equal to or greater than 500 for tight-fitting full face pieces, the QNFT has been passed with that respirator. However, where a manufacturer of a respirator designates a fit factor greater than that identified herein, and then the more stringent fit factor shall be achieved. TIKIGAQ Corporate Safety Program, 11/09 9-6 Fit tests shall not be conducted if there is any hair growth between the skin and the face piece 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. If a satisfactory fit is not achieved by any o f the test procedures described herein, another size or model respirator must be selected and the appropriate test repeated. 9.9.1 Positive and Negative Pressure Tests Either a positive or negative pressure test for tightness of fit must be applied each time a respirator is put on. It is a regulatory requirement and TIKIGAQ policy that you perform a ―positive and negative fit check‖ each time you don your respirator and includes periodic breaks. If your respirator fails one of these checks, and you cannot correct it by adjusting the straps, inform your immediate supervisor and/or designated Health & Safety Representative at once, to evaluate the situation and develop and corrective action approach.

All workers required to wear a respirator shall be assured of having a proper fit. This will be achieved with: 1. Conducting an initial and annual QLFT or QNFT fit test as required by the respirator manufacturer, regulatory agencies (i.e. OSHA) and/or TIKIGAQ requirements. 2. Conducting a positive and negative pressure fit test each time the respirator is put on. The process for performing a positive and negative pressure test is as identified below.

9.9.1.1 Positive Pressure Test 1. Close off the exhalation valve with the palm of your hand. 2. Exhale gently into face piece. 3. Check for air leakage. The face fit is considered satisfactory if slight positive pressure can be built up inside the face piece without any evidence of outward leakage. 4. If leakage is detected, reposition face piece or readjust straps and repeat the test. 9.9.1.2 Negative Pressure Test 1. Close off the inlet of the canister, cartridge(s), or filter(s) by covering with your palm(s). 2. Inhale gently so that the face piece collapses slightly. 3. Hold your breath for 10 seconds. If the face piece remains collapsed and no inward leakage is detected, the fit is considered satisfactory. 9.10 FIT TESTING PROCEDURES -- GENERAL REQUIREMENTS The following general fit testing procedures shall be followed when determining the overall fit of a selected respiratory protection device. The requirements in this appendix apply to all OSHA-accepted QLFT and QNFT methods. TIKIGAQ Corporate Safety Program, 11/09 9-7 (1) The test subject shall be allowed to pick the most acceptable respirator from a sufficient number of respirator models and sizes so that the respirator is acceptable to, and correctly fits, the user. (2) Prior to the selection process, the test subject shall be shown how to put on a respirator, how it should be positioned on the face, how to set strap tension and how to determine an acceptable fit. A mirror shall be available to assist the subject in evaluating the fit and positioning of the respirator. This instruction may not constitute the subject's formal training on respirator use, because it is only a review. (3) The test subject shall be informed that he/she is being asked to select the respirator that provides the most acceptable fit. Each respirator represents a different size and shape, and if fitted and used properly, will provide adequate protection. (4) The test subject shall be instructed to hold each chosen face piece up to the face and eliminate those that obviously do not give an acceptable fit. (5) The more acceptable face pieces are noted in case the one selected proves unacceptable; the most comfortable mask is donned and worn at least five minutes to assess comfort. Assistance in assessing comfort can be given by discussing the points in the following item (6), below. If the test subject is not familiar with using a particular respirator, the test subject shall be directed to don the mask several times and to adjust the straps each time to become adept at setting proper tension on the straps. (6) Assessment of comfort shall include a review of the following points with the test subject and allowing the test subject adequate time to determine the comfort of the respirator: (a) Position of the mask on the nose (b) Room for eye protection (c) Room to talk (d) Position of mask on face and cheeks (7) The following criteria shall be used to help determine the adequacy of the respirator fit: (a) Chin properly placed; (b) Adequate strap tension, not overly tightened; (c) Fit across Nose Bridge; (d) Respirator of proper size to span distance from nose to chin; (e) Tendency of respirator to slip; (f) Self-observation in mirror to evaluate fit and respirator position.

(8) The test subject shall conduct a user seal check, either the negative and positive pressure seal checks described herein, those which maybe recommended by the respirator manufacturer which provides equivalent or superior protection to the procedures herein or 29CFR1910.134, Appendix B-1, whichever is more stringent. Before conducting the negative and positive pressure checks, the subject shall be told to seat the mask on the face by moving the head from side- to-side and up and down slowly while taking in a few slow deep breaths. Another face piece shall be selected and retested if the test subject fails the user seal check tests. TIKIGAQ Corporate Safety Program, 11/09 9-8 (9) The test shall not be conducted if there is any hair growth between the skin and the face piece 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. (10) If a test subject exhibits difficulty in breathing during the tests, she or he shall be referred to a physician or other licensed health care professional, as appropriate, to determine whether the test subject can wear a respirator while performing her or his duties. (11) If the employee finds the fit of the respirator unacceptable, the test subject shall be given the opportunity to select a different respirator and to be retested. (12) Exercise regimen. Prior to the commencement of the fit test, the test subject shall be given a description of the fit test and the test subject's responsibilities during the test procedure. The description of the process shall include a description of the test exercises that the subject will be performing. The respirator to be tested shall be worn for at least 5 minutes before the start of the fit test. (13) The fit test shall be performed while the test subject is wearing any applicable safety equipment that may be worn during actual respirator use which could interfere with respirator fit. (14) Test Exercises Personnel conducting Fit Test procedures must ensure that employees perform the test exercises in the appropriate test environment in the following manner: 1. Normal breathing. In a normal standing position, without talking, the subject shall breathe normally. 2. Deep breathing. In a normal standing position, the subject shall breathe slowly and deeply, taking caution so as not to hyperventilate. 3. Turning head side to side. Standing in place, the subject shall slowly turn his/her head from side to side between the extreme positions on each side. The head shall be held at each extreme momentarily so the subject can inhale at each side. 4. Moving head up and down. Standing in place, the subject shall slowly move his/her head up and down. The subject shall be instructed to inhale in the up position (i.e., when looking toward the ceiling). 5. Talking. The subject shall talk out loud slowly and loud enough so as to be heard clearly by the test conductor. The subject can read from a prepared text such as the ― Rainbow Passage‖, count backward from 100, or recite a memorized poem or song. 6. Grimace. The test subject shall grimace by smiling or frowning. (This applies only to QNFT testing; it is not performed for QLFT).

7. Bending over. The test subject shall bend at the waist as if he/she were to touch his/her toes. Jogging in place shall be substituted for this exercise in those test environments such as shroud type QNFT or QLFT units that do not permit bending over at the waist. TIKIGAQ Corporate Safety Program, 11/09 9-9 8. Normal breathing. Same as exercise (1).

Each test exercise shall be performed for one minute except for the grimace exercise which shall be performed for 15 seconds. The test subject shall be questioned by the test conductor regarding the comfort of the respirator upon completion of the protocol. If it has become unacceptable, another model of respirator shall be tried. The respirator shall not be adjusted once the fit test exercises begin. Any adjustment voids the test, and the fit test must be repeated.

9.11 Q UALITATIVE FIT TEST For QLFTs either isoamyl acetate (banana oil) or irritant smoke (stannic chloride) will be conducted on all half-face, negative pressure respirators in accordance with established protocols (such as in the OSHA benzene standard). TIKIGAQ utilizes irritant smoke for HEPA filter equipped respirators. For individuals who show no affect to irritant smoke isoamyl acetate will be utilized in conjunction with HEPA/OV filters. In some instances, you may receive a quantitative fit test. 9.11.1 Particulate Filter Cartridge Respirators - QLFT via Irritant Smoke Protocol This qualitative fit test uses a person's response to the irritating chemicals released in the "smoke" produced by a stannic chloride ventilation smoke tube to detect leakage into the respirator. The general requirements and precautions are as follows:

(1) The respirator to be tested shall be equipped with high efficiency particulate air (HEPA) or P100 series filter(s). (2) Only stannic chloride smoke tubes shall be used for this protocol. (3) No form of test enclosure or hood for the test subject shall be used. (4) The smoke can be irritating to the eyes, lungs, and nasal passages. The test conductor shall take precautions to minimize the test subject's exposure to irritant smoke.

Se nsitivity varies, and certain individuals may respond to a greater degree to irritant smoke. Care shall be taken when performing the sensitivity screening checks that determine whether the test subject can detect irritant smoke to use only the minimum amount of smoke necessary to elicit a response from the test subject. (5) The fit test shall be performed in an area with adequate ventilation to prevent exposure of the person conducting the fit test or the build-up of irritant smoke in the general atmospher e.

9.11.1.1 Sensitivity Screening Check The person to be tested must demonstrate his or her ability to detect a weak concentration of the irritant smoke. (1) The test operator shall break both ends of a ventilation smoke tube containing stannic chloride, and attach one end of the smoke tube to a low flow air pump set to deliver 200 milliliters per minute, or an aspirator squeeze bulb. The test operator shall cover the other end of the smoke tube with a short piece of tubing to prevent potential injury from the jagged end of the smoke tube. TIKIGAQ Corporate Safety Program, 11/09 9-10 (2) The test operator shall advise the test subject that the smoke can be irritating to the eyes, lungs, and nasal passages and instruct the subject to keep his/her eyes closed while the test is performed. (3) The test subject shall be allowed to smell a weak concentration of the irritant smoke before the respirator is donned to become familiar with its irritating properties and to determine if he/she can detect the irritating properties of the smoke. The test operator shall carefully direct a small amount of the irritant smoke in the test subject's direction to determine that he/she can detect it.

9.11.1.2 Irritant Smoke Fit Test Procedure (1) The person being fit tested shall don the respirator without assistance, and perform the required user seal check(s). (2) The test subject shall be instructed to keep his/her eyes closed. (3) The test operator shall direct the stream of irritant smoke from the smoke tube toward the face seal area of the test subject, using the low flow pump or the squeeze bulb. The test operator shall begin at least 12 inches from the face piece and move the smoke stream around the whole perimeter of the mask. The operator shall gradually make two more passes around the perimeter of the mask, moving to within six inches of the respirator. (4) If the person being tested has not had an involuntary response and/or detected the irritant smoke, proceed with the test exercises. (5) The exercises identified in section 4.6, herein, shall be performed by the test subjec t while the respirator seal is being continually challenged by the smoke, directed around the perimeter of the respirator at a distance of six inches. (6) If the person being fit tested reports detecting the irritant smoke at any time, the test is failed. The person being retested must repeat the entire sensitivity check and fit test procedure. (7) Each test subject passing the irritant smoke test without evidence of a response (involuntary cough, irritation) shall be given a second sensitivity screening check, with the smoke from the same smoke tube used during the fit test, once the respirator has been removed, to determine whether he/she still reacts to the smoke. Failure to evoke a response shall void the fit test. (8) If a response is produced during this second sensitivity check, then the fit test is passed.

9.11.2 Organic Vapor Cartridge Respirators - Isoamyl Acetate Fit Test Protocol This protocol is not appropriate to use for the fit testing of particulate respirators. If used to fit test particulate respirators, the respirator must be equipped with an organic vapor filter. Persons administering QLFT must able to prepare test solutions, calibrate equipment and perform tests properly, recognize invalid tests, and ensure that test equipment is in proper working order. QLFT equipment must be kept clean and well maintained so as to operate within the parameters for which it was designed. TIKIGAQ Corporate Safety Program, 11/09 9-11 9.11.2.1 Odor Threshold Screening Odor threshold screening, performed without wearing a respirator, is intended to determine if the individual tested can detect the odor of isoamyl acetate at low levels. (1) Three 1 liter glass jars with metal lids are required. (2) Odor-free water (e.g., distilled or spring water) at approximately 25 deg. C (77 deg.

F) shall be used for the solutions. (3) Where utilized, the isoamyl acetate (IAA) (also known at isopentyl acetate) stock solution is prepared by adding 1 ml of pure IAA to 800 ml of odor-free water in a 1 liter jar, closing the lid and shaking for 30 seconds. A new solution shall be prepared at least weekly. Pre-manufactured/packaged IAA ampoules may be substituted provided it has been demonstrated that the alternative IAA source will generate an IAA test atmosphere with a concentration equivalent to that generated by mix ratios identified above.

(4) The screening test shall be conducted in a room separate from the room used for actual fit testing. The two rooms shall be well-ventilated to prevent the odor of IAA from becoming evident in the general room air where testing takes place. (5) The odor test solution is prepared in a second jar by placing 0.4 ml of the stock solution into 500 ml of odor-free water using a clean dropper or pipette. The solution shall be shaken for 30 seconds and allowed to stand for two to three minutes so that the IAA concentration above the liquid may reach equilibrium. This solution shall be used for only one day. (6) A test blank shall be prepared in a third jar by adding 500 cc of odor-free water. (7) The odor test and test blank jar lids shall be labeled (e.g., 1 and 2) for jar identification. Labels shall be placed on the lids so that they can be peeled off periodically and switched to maintain the integrity of the test. (8) The following instruction shall be typed on a card and placed on the table in front of the two test jars (i.e., 1 and 2): "The purpose of this test is to determine if you can smell banana oil at a low concentration. The two bottles in front of you contain water. One of these bottles also contains a small amount of banana oil. Be sure the covers are on tight, and then shake each bottle for two seconds. Unscrew the lid of each bottle, one at a time, and sniff at the mouth of the bottle. Indicate to the test conductor which bottle contains banana oil." (9) The mixtures used in the IAA odor detection test shall be prepared in an area separate from where the test is performed, in order to prevent olfactory fatigue in the subject. (10) If the test subject is unable to correctly identify the jar containing the odor test solution, the IAA qualitative fit test shall not be performed. (11) If the test subject correctly identifies the jar containing the odor test solution, the test subject may proceed to respirator selection and fit testing. TIKIGAQ Corporate Safety Program, 11/09 9-12 9.11.2.2 Isoamyl Acetate Fit Test (1) The fit test chamber shall be a clear 55-gallon drum liner suspended inverted over a 2 -foot diameter frame so that the top of the chamber is about 6 inches above the test subject's head. If no drum liner is available, a similar chamber shall be constructed using plastic sheeting. The inside top center of the chamber shall have a small hook attached. (2) Each respirator used for the fitting and fit testing shall be equipped with organic vapor cartridges or offer protection against organic vapors. (3) After selecting, donning, and properly adjusting a respirator, the test subject shall wear it to the fit testing room. This room shall be separate from the room used for odor threshold screening and respirator selection, and shall be well-ventilated, as by an exhaust fan or lab hood, to prevent general room contamination. (4) A copy of the test exercises and any prepared text from which the subject is to read shall be taped to the inside of the test chamber. (5) Upon entering the test chamber, the test subject shall be given a 6-inch by 5-inch piece of paper towel, or other porous, absorbent, single-ply material, folded in half and wetted with 0.75 ml of pure IAA. The test subject shall hang the wet towel on the hook at the top of the chamber. An IAA test swab or ampoule may be substituted for the IAA wetted paper towel provided it has been demonstrated that the alternative IAA source will generate an IAA test atmosphere with a concentration equivalent to that generated by the paper towel method. (6) Allow two minutes for the IAA test concentration to stabilize before starting the fit test exercises. This would be an appropriate time to talk with the test subject; to explain the fit test, the importance of his/her cooperation, and the purpose for the test exercises; or to demonstrate some of the exercises. (7) If at any time during the test, the subject detects the banana-like odor of IAA, the test is failed. The subject shall quickly exit from the test chamber and leave the test area to avoid olfactory fatigue. (8) If the test is failed, the subject shall return to the selection room and remove the respirator. The test subject shall repeat the odor sensitivity test, select and put on another respirator, return to the test area and again begin the fit test procedure described in (b) (1) through (7) above. The process continues until a respirator that fits well has been found. Should the odor sensitivity test be failed, the subject shall wait at least 5 minutes before retesting. Odor sensitivity will usually have returned by this time. (9) If the subject passes the test, the efficiency of the test procedure shall be demonstrated by having the subject break the respirator face seal and take a breath before exiting the chamber. (10) When the test subject leaves the chamber, the subject shall remove the saturated towel and return it to the person conducting the test, so that there is no significant IAA TIKIGAQ Corporate Safety Program, 11/09 9-13 concentration buildup in the chamber during subsequent tests. The used towels shall be kept in a self-sealing plastic bag to keep the test area from being contaminated.

9.11.3 Quantitative Fit Test This test is required for any employee who is required to enter an Immediately Dangerous to Life or Health (IDLH) or where an overall respirator fit factor greater than 100 is required. In this instance specialized equipment must be purchased or rented.

from outside vendors. When utilizing these methods, closely follow manufacturer’s instructions, training materials and instrument calibration processes.

9.11.3.1 Aerosol Condensation Ambient Nuclei Counter (CNC) quantitative fit testing protocol. The ambient aerosol condensation nuclei counter (CNC) quantitative fit testing (Portacount TM ) protocol quantitatively fit tests respirators with the use of a probe. The probed respirator is only used for quantitative fit tests. A probed respirator has a special sampling device, installed on the respirator that allows the probe to sample the air from inside the mask. A probed respirator is required for each make, style, model, and size that the employer uses and can be obtained from the respirator manufacturer or distributor. The CNC instrument manufacturer, TSI Inc., also provides probe attachments (TSI sampling adapters) that permit fit testing in an employee's own respirator. A minimum fit factor pass level of at least 100 is necessary for a half-mask respirator and a minimum fit factor pass level of at least 500 is required for a full face piece negative pressure respirator. The entire screening and testing procedure shall be explained to the test subject prior to the conduct of the screening test. 9.11.3.1.1 Portacount Fit Test Requirements (1) Check the respirator to make sure the sampling probe and line are properly attached to the face piece and that the respirator is fitted with a particulate filter capable of preventing significant penetration by the ambient particles used for the fit test (e.g., NIOSH 42 CFR 84 series 100, series 99, or series 95 particulate filter) per manufacturer's instruction. (2) Instruct the person to be tested to don the respirator for five minutes before the fit test starts. This purges the ambient particles trapped inside the respirator and permits the wearer to make certain the respirator is comfortable. This individual shall already have been trained on how to wear the respirator properly. (3) Check the following conditions for the adequacy of the respirator fit: Chin properly placed; Adequate strap tension, not overly tightened; Fit across nose bridge; Respirator of proper size to span distance from nose to chin; Tendency of the respirator to slip; Self- observation in a mirror to evaluate fit and respirator position. (4) Have the person wearing the respirator do a user seal check. If leakage is detected, determine the cause. If leakage is from a poorly fitting face piece, try another size of the same model respirator, or another model of respirator.

TIKIGAQ Corporate Safety Program, 11/09 9-14 (5) Follow the manufacturer's instructions for operating the Portacount and proceed with the test. (6) The test subject shall be instructed to perform the exercises in section 4.6, item 14 above.

(7) After the test exercises, the test subject shall be questioned by the test conductor regarding the comfort of the respirator upon completion of the protocol. If it has become unacceptable, another model of respirator shall be tried.

9.11.3.1.2 Portacount Test Instrument (1) The Portacount will automatically stop and calculate the overall fit factor for the entire set of exercises. The overall fit factor is what counts. The Pass or Fail message will indicate whether or not the test was successful. If the test was a Pass, the fit test is over. (2) Since the pass or fail criterion of the Portacount is user programmable, the test operator shall ensure that the pass or fail criterion meet the requirements for minimum respirator performance in this Appendix. (3) A record of the test needs to be kept on file, assuming the fit test was successful. The record must contain the test subject's name; overall fit factor; make, model, style, size of respirator used and date tested.

9.12 RESPIRATOR INSPECTION AN D REPAIR All respirators shall be inspected routinely before and after each use and during cleaning. Equipment designed for emergency use shall be inspected after each use, during cleaning, and at least monthly. Self-contained breathing apparatus shall be inspected monthly by the designated Health and Safety Representative. 9.12.1 Record Keeping A record shall be kept of inspection dates and findings for all respirators maintained for emergency use. 9.12.2 Inspection Considerations Each respirator user shall be thoroughly trained in the proper inspection procedure to ensure that the equipment is in good condition. Inspection shall include the following: 1. Head straps check for breaks or tears, loss of elasticity, and missing or malfunctioning buckles. 2. Face piece check for dirt, cracks, tears, holes distortion, or any other signs of deterioration. 3. Valve check for dust, dirt, or detergent residue on the valves or valve seat; cracks, tears, or distortion in the valve material; or missing or defective valve covers. TIKIGAQ Corporate Safety Program, 11/09 9-15 4. Filter elements check for correct filter(s), missing or woven gaskets, worn threads, cracks or dents in filter housing, service life indicator or end of service date. 5. Any other checks as appropriate. 9.12.3 Repair and Filter Replacement Damaged respirators shall be brought to the immediate attention of your Superintendent. Trained personnel shall do repair with parts designated for the respirator. If immediate repairs cannot be made and a respirator is needed, a temporary replacement with the same model and size shall be issued. The authorized Health and Safety designate will ensure that an adequate supply of filters is available for each make and model of respirator. Inform the Safety & Health Engineer if the supply is running low; never attempt to intermix brands. The respirator supplies will be kept in the site supply trailer, or job box. Your Superintendent can provide additional filters as necessary during the shift. Filters are to be placed into a suitable disposal container for the type of material being disturbed and for which they were being utilized. Filters to be utilized for the next days shift shall be sealed using duct tape over the inlet of the filter. The tap will be removed the next shift immediately after donning the respirator and entering the work area. Some filters must be changed at least every 8 hours (i.e.: benzene exposure). If breathing resistance is noticed, change the HEPA filter. If odor, taste, or irritation is experienced, this indicates the chemical filter is spent and must be changed immediately. The expected filter life for organic vapor cartridges is three work shifts; however TIKIGAQ policy is to replace these filters daily. 9.12.4 Cleaning and Disinfecting. Employees will clean their respirators after every shift. Use mild soap, followed by clean water rinse to remove all soap residues, then air dry. Another method is to use chlorine disinfectant (2 tablespoons of chlorine bleach per gallon of water; soak for 10 minutes, then rinse and air dry). After cleaning, place respirator in a clean plastic bag or plastic container and store in a safe and sanitary locations. Never place a heavy object on top of your respirator. This can cause deformation. Cleaning procedures shall also include the following: 1. Remove any filters, cartridges, headbands, and disassemble the major respirator parts. 2. Wash all respirator parts (except cartridges and elastic headbands) in a cleaner- disinfectant solution at about 120° F. Use a hand brush to remove dirt. 3. Inspect all parts; if broken notify your supervisor so they can replace defective parts. 4. Reassemble the respirator and insert new or unexposed filters or cartridges. Be sure the seal is tight. TIKIGAQ Corporate Safety Program, 11/09 9-16 9.12.5 Storage You will store your respiratory equipment so as to protect it from dust, sunlight, heat, extreme cold, excessive moisture, and damaging chemicals. In addition, respirators must be: 1. Stored in a convenient, clean, and sanitary location where they are protected against damage or distortion by overcrowding, or by contact with heavy gear, such as tools or a tool box. 2. Placed in clean plastic bags. 3. Stored in a single layer with the face piece and exhalation valve in a near normal position to prevent the rubber plastic parts from taking a permanent distorted set. 4. Stored in a readily accessible, non-contaminated cabinet or case if used for emergencies.

9.13 WORK AREA SURVEILLANCE Periodic air sampling (or continuous as required) shall be conducted to determine the continued necessity of respiratory protection and to ensure that the proper respirators are being used when in accordance with the Respiratory Protection Program and State and Federal requirements. Employees may be required to wear personal air sampling equipment for this purpose. 9.14 P ROGRAM SURVEILLANC E The Safety & Health Engineer ensures that the company Respiratory Protection Program adequately protects workers. To accomplish this, periodic surveillance of work practices of employees is required. The Safety & Health Engineer will require periodic feedback from the respirator users on the following points: • Comfort • Ability to breathe without objectionable effort • Adequate visibility under all conditions • Ability to perform all tasks without undue interference • Confidence in the face piece fit • Written quiz to determine program effectiveness All TIKIGAQ Health and Safety Representatives and supervisors are responsible for verifying workers follow the program provisions. Frequent random inspections shall be conducted by the Program Manager and or the Competent Person to ensure that the proper respirators have been selected, that employees are in fact wearing the respiratory protection when and where necessary, that they are fitted properly, and that the equipment is cleaned, stored, and maintained.

Inspection dates and general conditions observed are recorded and kept on file. 9.15 CONFINED SPACE ENTRY Because of the hazards associated with confined space entry, no TIKIGAQ employee may enter a confined space unless the space has been evaluated as specified in the TIKIGAQ Confined Space Program. In all cases, air testing and ventilation will be required. Some respirators do not provide oxygen, therefore, entry into a confined space TIKIGAQ Corporate Safety Program, 11/09 9-17 deficient in oxygen while wearing that type of respirator may prove a fatal mistake. As required by the company program, a completed confined space entry permit must be posted at the entrance to the space prior to access by an employee. Read and follow its provisions. Additional training will be provided prior to entry into any confined space. 9.16 MEDICAL APPROVAL All company employees who may need to wear a respirator on the job will be given a medical evaluation prior to such use. A licensed physician, knowledgeable in occupational medicine, will conduct the evaluation and provide written authorization for respirator use. The authorization will be included in your company permanent record. The medical evaluation will be repeated annually. Employees shall work with the CHSM or authorized Health and Safety Officer to determine where this requirement is applicable to the employee’s assigned duties. 9.17 82BDISPOSABLE RESPIRATORS The use of disposable respirators still requires adherence to all applicable sections of this respiratory protection program, including fit testing. TIKIGAQ does not authorize the use of these types of respirators. 9.18 83BSPECIFIC LIMITATIONS OSHA regulations and company policy forbid workers who use respirators to have facial hair in the way of the respirator seal. Even heavy stubble may interfere with pr oper respirator fit and must be shaved. There will be no exceptions. Current OSHA regulations forbid the user to wear contact lenses under a full-face respirator. If corrective lenses are required for you to see, and then inform your Safety & Health Engineer so that lens holders may be provided that fit inside the respirator. 9.19 84BEMERGENCY EQUIPMENT Conditions or accidents may occur that could pose immediate danger to life and health (IDLH). Possible emergency use of respiratory protective equipment should be anticipated, and employees that may encounter dangerous atmospheres will be trained and prepared to use the equipment. IDLH may occur during confined space entry or during other hazardous materials remediation procedures; therefore, TIKIGAQ provides employees who will be working in potential IDLH conditions with supplied air system and a 5-minute emergency escape bottle, or a self-contained breathing apparatus (SCBA). Employees requiring emergency escape bottles shall inspect them prior to their use, and bottles will be inspected by a certified professional every 3 years. Periodic training sessions shall be held for those individuals most likely to use the equipment in an emergency. Training shall include demonstration and practice in donning and doffing, testing for fit, discussion of the capabilities and limitations of the equipment, and so on. The equipment manufacturer’s instructions should be closely followed. If the atmosphere involved is IDLH, stand by persons must also be present with the suitable rescue equipment. TIKIGAQ Corporate Safety Program, 11/09 9-18 It is TIKIGAQ policy that no employee shall enter a known IDLH atmosphere. In the event that employees are required to enter a known IDLH atmosphere a Quantitative fit test shall be performed for the respirator provided prior to entry into the work area. No respirator supplied by TIKIGAQ shall be used to fight a fire. In the event of a fire in your work area, immediately evacuate the area and notify the fire department. TIKIGAQ Corporate Safety Program, 11/09 9-1 Employee Acknowledgement Respiratory Protection Program Em ployees listed below have been provided with a copy of this Respiratory Protection Program, have read and agree to abide by its provisions. Project Name: Project #: EMPLOYEE NAME (Please print) EMPLOYEE SIGNATURE COMPANY DATE TIKIGAQ Corporate Safety Program, 11/09 10-1 10.0 9B CONFINED SPACE ENTRY 10.1 85BINTRODUCTION Work in Confined Spaces are not common work areas for TIKIGAQ; operations but may be performed from time to time. Whenever Confined Space Entry (CSE) operations are conducted by TIKIGAQ the procedures identified below shall be implemented. In addition, when subcontractors perform CSE operations, the Subcontractor’s CSE procedures shall be evaluated as well. The following section is a general guideline to follow when working in and around a confined space situations. 10.2 86BDEFINITIONS Confined Space is any space that is large enough to bodily enter and perform assigned work; and has limited or restricted means for entry or exit; and is not designed for continuous employee occupancy; and may or could contain a potential hazard.

Cold Work Permit Space is 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 physical harm and after evaluation is found to have little (no) potential for generation of hazards or has the hazards eliminated by engineering controls.

Acceptable Entry Conditions for Cold Work Permit Space means that the minimum atmospheric conditions are: oxygen 19.5% to 20.9%; LEL 0% and no hazardous vapors can be detected by calibrated direct reading instruments. There are no physical hazards that could cause serious injuries and illnesses.

Entry means the action by which a person passes through an opening into a permit-required confined space. Entry includes ensuing work activities in that space and is considered to have occurred as soon as any part of the entrant's body breaks the plane of any opening into the sp ace.

Entry Permit means the written or printed document that is provided by the employer to allow and control entry into a permit space.

Attendant means an individual stationed outside a permit space who monitors the authorized entrants and who performs all attendant's duties assigned in the employer's permit space program. A designated attendant may not have any other responsibilities which would distract the attendant from the duties assigned in the permit space program.

Authorized Entrant is any person who is authorized by the entry supervisor to enter a permit space and has his/her name listed on the confined space entry permit.

Entry Supervisor is 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.

Permit-Required Confined Space means a confined space that has one or more of the following characteristics:

1. contains or has a potential to contain a hazardous atmosphere; 2. contains a material that has the potential for engulfing an entrant; TIKIGAQ Corporate Safety Program, 11/09 10-2 3. 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 4. contains any other recognized serious safety or health hazard.

10.3 87BRESPONSIBILITIES TIKIGAQ will inform employees or subcontractors of all hazards associated with "work" and set minimum requirements to be addressed in the site/facility work plan and HSP/APP and coordinate entry operations with the contractor(s) when both TIKIGAQ and contractor personnel are working in or near the permit spaces. The contractor shall be debriefed at the conclusion of the entry operations regarding the permit space program and any hazards confronted or created in permit spaces during entry operations.\ 10.3.1 175BTraining The Entry Supervisor, Attendant and Entrant(s) must be CSE trained in accordance with the requirements of 29CFR1910.146. Designated CSE personnel shall be qualified to perform the assigned duties by proper training and/or previous experience. In addition, designated CSE personnel shall be trained in accordance with other standards, as necessary to perform the assigned duties (i.e. 29CFR1910.120 etc.) 10.3.2 176BSafety Coordinator and Safety Representatives 1. Provide assistance to management and supervisory personnel to assure compliance with this section.

2. Review and endorse initial safety plans and procedures for entry into confined space entry work permit and cold work permit spaces. If the safety plan, or procedure specifies the use of any atmosphere supplying respirator, the safety coordinator of TIKIGAQ.

3. Conduct hazard evaluations of all permit-required confined spaces prior to entry.

10.3.3 177B Entry Supervisor Entry supervisor shall be trained on the duties of the entry supervisor, entrants, attendants and rescue personnel, the requirements of this safety code, first aid and CPR and designated as being competent in Confined Space Entry Procedures. The Entry Supervisor shall: 1. Know the hazards of the confined space; 2. Know the signs and symptoms of an over exposure to the hazard; 3. Verify that Rescue Entry Team Requirements have been evaluated, have been put in place and are available to support the operation in needed. 4. Know the consequences of an exposure to the hazard; 5. Verify that all required tests have been performed; 6. Inspect PPE for appropriate hazard; 7. Verify rescue service plan; TIKIGAQ Corporate Safety Program, 11/09 10-3 8.

Verify communication with the entrant and alarm system; 9. Verify that the MSDS/PADS are on site; 10. Verify that all required postings are on site; 11. Ensure that the permit is complete; 12. Remove all unauthorized individuals; 13. Sign the permit to start work; 14. Stop work and void the permit if conditions change; and 15. Ensure all plans are followed.

10.3.4 178BEntrants All entrants shall be trained on the duties of the entrant, and on the duties of the attendant and rescue persons, if they are required to perform these duties.

The Entrant shall:

1. Know hazards of the confined space; 2. Know the signs and symptoms of an over exposure to the hazard; 3. Know the consequences of an exposure to the hazard; 4. Maintain communication with the attendant; 5. Sound the alarm if needed; 6. Report any potential or real atmospheric or physical hazards; and 7. Know how to exit quickly and safely.

10.3.5 179BAttendants The Attendants shall be trained on the duties of the attendant, and on the duties of the entrant and rescue persons, if they are required to perform these duties.

The Attendant shall:

1) Conduct hazard evaluations of all permit-required confined spaces prior to entry.

2) Conduct gas tests and assist in writing associated work permits.

3) Assist the entry supervisors in evaluating confined space hazards and endorse deviations from this code when required by special circumstances.

4) Conduct initial atmospheric evaluations (air monitoring tests) prior to allowing entry into any confined space by any personnel.

5) Keep record of all entrants; 6) Maintain communication with entrants; 7) Watch for hazards inside and outside of the confined space; 8) Recognize behavioral effects of hazards; 9) Keep unauthorized persons out of the space and area; 10) Sound emergency alarm; 11) Perform non-entry rescue; and TIKIGAQ Corporate Safety Program, 11/09 10-4 12) Perform no other duties that may take him/her away from their duty as a confined space Attendant.

10.4 88BRESCUE ENTRY SERVICES An employer who designates rescue and emergency services must:

• Evaluate a prospective rescuer's ability to respond to a rescue in a timely manner, considering the hazard(s) identified; • Evaluate a prospective rescue service's ability, in terms of proficiency with rescue- related tasks and equipment, to function appropriately while rescuing entrants from the particular permit space or types of permit spaces identified; • Select a rescue team or service from those evaluated that:

1) Has the capability to reach the victim(s) within a time frame that is appropriate for the permit space hazard(s) identified; 2) Is equipped for and proficient in performing the needed rescue services; 3) Inform each rescue team or service of the hazards they may confront when called on to perform rescue at the site; and 4) Provide the rescue team or service selected with access to all permit spaces from which rescue may be necessary so that the rescue service can develop