Northeast Data

Northeast Data Safety Manual and Policies

Contents

Employee Safety

QRP Quick Risk Prediction, Every Task - Every Time

General Safe Practices Policy

Head Injury / Hard Hats

Toe and Foot injury Prevention Safety (Safety Shoes)

Hand Injury Prevention Safety

Eye Injury Prevention Safety (Safety Glasses)

Hearing Injury Prevention Safety (Ear Plugs / Ear Muffs)

Work Appearance Injury Prevention Safety (Proper Work Attire)

Prescription Drug Prevention Safety

Fatigue Management Policy

Fit for Duty Policy

Jewelry Prevention Safety Policy

Tool Injury Prevention Safety

Workplace Organization (Housekeeping Safety)

Pedestrian Walkways at customer Sites

Fire Prevention Safety

Hot Work Safety

Safety Emergency Alerts

Fall Protection

Ladder Prevention Safety

Aerial Lifts

Cranes, Forklifts, and other Mobile Equipment

Hazardous Areas and Conditions Safety

Lockout / Tagout / Tryout

Signs and Barricades

Respiratory Hazards

Lifting

Site Specific Requirements

Safety Responsibility

Safety Station

Hazardous Communication Policy "List of MSDS" / "Right to know Station"

Hydrogen Sulfide Policy

Medical Emergencies Policy

Blood Borne Pathogen's Policy

Electrical Safety Policy

Driving Safety Policy

360 Circle of Safety

First Aid Policy

Work Place Emergency Action Policy

Ergonomics Program

Violence in the Workplace

Post-Accident Procedures for Employees and Temporary Workers

Contagious Disease Policy

Covid Mandate Policy

Continuous Improvement

Employee Safety

A. Safety Issues

THERE IS ABSOLUTELY NO JOB OR TASK THAT NORTHEAST DATA MUST PERFORM WHICH IS MORE IMPORTANT THAN THE SAFETY OF AN EMPLOYEE, A CUSTOMER, OR A CITIZEN.

Due to customer safety demands, Northeast Data has adopted a stricter safety program. Due to this, our policy for Progressive discipline on safety only has changed effective 02/01/2005 and forward.

Safety Progressive Discipline:

Our Safety Progressive Discipline program will be broken down into the (4) four classifications listed below:

After violation of each incident, employee will be retrained on the proper procedures and handling of the broken general safe practice guideline. Violation of any (3) Three General Safe Practices in a two (2) week period, or (3) violations of the same General Safety Practice within (1) one year, will result in removal from the job site and will endure immediate termination of employment

After violation of each incident, employee will be retrained on the proper procedures and handling of the broken serious violation guideline. Any two (2) serious violations performed within a one (1) one year period will result in removal from the job site and will endure immediate termination from employment.

Any violation of work or safety rules labeled Zero Tolerance (0) or Life Critical (L) will result in an individual's immediate termination from employment.

All Northeast Data employees are required to abide by all Northeast Data and Customer Safety Policies. As a rule, the greater protection of the two is to be followed at all times.

All employees will be provided with a Northeast Data Statement of Safety Policies and General Safety Policies prior to beginning work. These policies must be read/understood/signed by each employee. Any employee refusing to sign Northeast Data's Safety policy will be terminated from employment. All parts of the manual must be adhered to at all times. Failure to comply with any part or parts of these policies will be grounds for immediate termination.

Employee / Customer Safety is of the utmost importance at Northeast Data. Any/all safety violations will be grounds for immediate termination. No warnings are required, verbal or written.

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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B. QRP - Quick Risk Prediction, Every Task - Every Time

All Northeast Data Employees are required to follow a quick risk prediction exercise with every task. A quick risk prediction is a mental exercise developed to be completed by ALL in order to identify immediate hazards faced in the field just prior to execution of any task.

QRP

QUICK RISK PREDICTION - EVERY TASK - EVERY TIME

Daily Safety Task Assessment

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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C. General Safe Practices Policy

General Safe Practices

This policy is in accordance with OSHA's General Safe Practices regulation. The purpose of this policy is to make all employees aware of the Safe Practices they must know during their employment with Northeast Data to keep their selves / their co-workers and our customers safe. The safety progressive discipline program will be utilized for violations of these rules and regulations. As a reminder of the Classification codes, please review the bottom of each page for a quick reference.

(O) Harassment of any kind will not be tolerated in any form by anyone. Any conduct, which interferes with an individual's work performance or creates an intimidating, hostile or offensive environment can be considered harassment. Any employee who believes that he or she is being harassed should report those incidents to their immediate foreman, or safety manager.

(G) At all customer sites, no Northeast Data employee shall drive any company / or personnel vehicle over 15 MPH. All Northeast Data employees no matter if they are in a company vehicle or personnel vehicle must at all times obey all traffic signs.

(S) Cameras are not permitted at any time to be brought on to any customer sites without prior security clearance.

(S) All safety incidents and property damage must be reported within the same day to the site construction manager.

(O) Northeast Data employees are strictly prohibited to be located / or working on or around a customer's premises while under the influence of alcohol or illegal drugs.

(O) It is prohibited at all times for any Northeast Data employee to run, gamble, horseplay on any customer site.

(O) Firearms, explosive devices, or any weapons at any kind are banned from being brought onto the premises of any customer site including the Northeast Data office location. (including parking lots)

(S) Intentional abuse, misuse, or damage of company owned, or customer owned equipment/tools will result in disciplinary action and the employee will pay for all related damages.

(I) Ensure all tools, equipment, and materials are free from infestation.

(O) The use of ANY type of tobacco / vaping products inside any customer facility will not be tolerated and will result in immediate termination.

(G) Smoking / vaping is only allowed during organized break and lunch periods and only in the designated contractor smoking areas.

(G) Absolutely at no time will a Northeast Data employee bring a butane lighter on to any customer premises.

(S) Only within designated lunch facility, office areas, or smoking areas on customer sites will food, candy, or beverages be allowed.

(S) While on customer sites, all exterior doors need to be closed immediately after use. Insect screens are to be used if doors or vents need to remain open.

(G) The practice of good hygiene should always be followed; all wounds and open sores are to be properly covered.

(I) Planning - All other options must have been considered before you are exposed to a fall hazard.

(I) Use of warning lines and controlled access zones will require approval from the safety manager, construction manager, and project manager.

(I) Customer site regulation signs are installed on pedestrian doors entering protected areas; obey all restrictions

(I) Ventilation (fans) will only be used in customer approved areas

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Head Injury Prevention Safety (Hard Hats)

(G) All Northeast Data Employees, Temporary Hires, and Sub-Contractors are required to wear class A ANSI head protection at all times when on a customer site unless specifically noted by said customer, when engaged in any construction activity, or when populating a posted construction area. Head protection may be removed in posted break and meeting / conference areas.

(I) Northeast Data hard hats must display the following:

Note: All other stickers / designs etc. are not permitted at any time.

(G) Employees not wearing Hard Hats or having hats which are not up to the above standards will be asked to leave the work area and not return until the defects are corrected. Repeated encounters with the same employee will result in use of progressive disciplinary action.

(G) All Hardhats must be work with the bill forward unless utilizing a face shield.

(G) Promptly remove any and all outdated or expired stickers.

(I) You should always check hard hat for signs of fatigue or damage prior to each use. Check suspension regularly for damage, defects, deterioration. Replace hat and suspension as specified by the manufacturers "Useful Service Life Guidelines".

(G) Any special customer request for special identification of the Foreman.

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Knee, Toe, and Foot Injury Prevention Safety (Knee Pads and Safety Shoes)

(G) Knee Pads (or equivalent protection) are mandatory when kneeling on hard surfaces.

(G) To prevent injury to the feet all Northeast Data Employees within the installation group are to wear steel toe safety shoes meeting ANSI anbd ASTM Z41 PT99 I/75 and C/75 standards at all times while on a customer site.

(G) Shoe tops worn to the point of exposure of the steel or composite toe must be replaced.

(G) All steel toe shoes must be a hard sole, well fitting, leather work boot or work shoes in good repair.

(G) High heels, open toed shoes, or sandals are prohibited in all construction areas.

(G) Using a jackhammer, tamper, or roller, will require the use of metatarsal guards.

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Hand Injury Prevention Safety

Proper hand protection (Cut Resistant Gloves Level 6, Puncture 5 or higher) MUST be worn AT ALL TIMES during ALL Installation manual tasks, material handling, and the use of any hand tool.

Note: a Hand tool is a device for doing a particular job that does not use a motor, but is powered solely by the person using it. (i.e. axes, rakes, shovels, hammers, wrenches, etc.)

(G) Other tools (i.e. piston drill, porta-band war, Sawzall, power saw, etc.) require gloves. 4' or larger grinders, require gloves and should be Leather Kevlar Lined type. The only exception to wearing gloves would be working around stationary rotating equipment, or taking field measurements.

The appropriate glove type must be used per the below recommended list:

Glove Type

Use

Leather Kevlar Reinforced work gloves

General use MUST BE minimum Level 6 Cut Resistant, Puncture 5 Type work gloves for routine tasks

Portable Grinders used for Grinding or Cutting

Hot work such as light torch cutting, heating, etc.

Handling materials, power and hand tools

General manual and other tasks as described in this policy

Welding Gloves

Electrode welding, MIG welding, heavy torch cutting

TIG Welding Gloves

TIG welding, Flame torch welding, and sharpening tungsten

Neoprene or latex gloves

Acids, caustics, ketones, alcohols, solvents, soaps, detergents, and misc. chemicals.

Kevlar cotton blended gloves (Cut Resistant Level 6, Puncture 5)

Cutting with a knife or box cutter

High Voltage Gloves (Test at 6 month intervals)

High Voltage Electricity

Latex exam gloves

Providing first aid and blood spill clean-up

Product Protection

Cleaning

As a second barrier under impervious gloves.

Nitrile "Ultra Tech" gloves

Terminating & other intricate work.

Precautions

(G) To eliminate hand injuries, all Northeast Data employees must wear hand protection for most tasks; the exception would be working around rotating equipment, and field measurement.

(G) Northeast Data employees will only use proper tools and only in the service for which it is designed

(G) Northeast Data employees shall keep knives, scissors, etc. in protective sheaths when not in use.

(G) Never place your hands within 6 inches of rotating materials or equipment

(I) Cut Resistant Gloves are NOT CUT PROOF always use extreme caution around all sharp edges.

(I) Glove clips are highly recommended to keep gloves available at all times for employee use.

(I) Never place your hand in between an object being moved and a stationary object or the floor.

(I) Use a pry bar, stick, or other tool to clear any obstruction. Never use your hands!

(I) When using force with wrenches or other tools, pull towards your body, and maintain control to prevent striking yourself or other equipment with your hand or loss of balance.

(G) Never cut toward your hand with a knife.

(I) Whenever possible, use clamps or vises to hold work.

(I) Never attempt to operate tools or equipment with one hand when two hands are needed

(L) Never break the guard plane of unguarded, energized equipment.

(I) Never place your hand on the top rail of an aerial lift while it is in motion.

(I) Use gloves and tool holders to hold punches or chisels for striking with a hammer.

(I) Inspect your work area for sharp unprotected edges, hot surfaces, nails, staples, or other items that could cause hand injury.

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Eye Injury Prevention Safety (Safety Glasses)

(G) All Northeast Data Employees (in the installation group) are to wear OSHA approved Safety Glasses meeting ANSI specifications at all times while on the clock for Northeast Data (except during travel).

(G) Northeast Data employees entering a customer site (such as at P&G Mehoopany, PA) must wear approved safety glasses meeting ANSI specifications upon entering the plant through the gates and shall not remove the safety glasses until the employee has entered an approved area where safety glasses are not required.

(I) All Northeast Data employee's shall asset their work area's to protect against the highest level of each hazard. Protective devices do not provide unlimited protection.

(G) Safety glasses must meet the ANSI Z87.1-2003 standard and include side shields."Street" glasses (prescription), even if they are "impact resistant", are prohibited.

(G) Goggles / Spogles or other snug fitting protection must be worn in high dust environments or when exposed to airborne particulates while performing tasks.

(G) Face Shields are required for tasks that create flying debris or when drilling overhead.

(I) Use caution when removing face shields after grinding operations to prevent debris accumulated atop the shield from falling down onto eyes and face.

(G) When cutting or burning Northeast Data employees will be required to utilize tinted goggles / lenses.

(G) Mirrored or dark lenses are unacceptable indoors. (At all times indoors it is necessary to keep eye contact with other workers in your area. Forklift operators must be able to see your eyes at all times within plant areas.)

(I) If you wear contact lenses, you must notify your Installation Manager / Foreman.

(I) All Northeast Data Employees shall observe special precautions when wearing contact lenses in operating areas.

(I) Always avoid poor visibility by frequent inspection and cleaning of glasses and face shields.

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critial     O = Zero Tolerance  

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Hearing Injury Prevention Safety (Ear Plugs / Ear Muffs)

(I) Northeast Data will provide hearing protection at the start of an employee’s employment where exposure is prevalent and will provide replacement hearing protection when necessary. This may contain single or double hearing protection based on possible exposure.

(I) Hearing protection will comply with OSHA CFR 1910.95 and all requirements below

(G) Hearing protection is required when noise or potential noise levels may exceed 82 db. While working client / customer sites, all Northeast Data employees are required to utilize Single Hearing Protection (Ear Plugs) at a minimum, in all operational, production, converting, and papermaking areas. This applies to walking through the Manufacturing Areas while in the pedestrian aisles or riding through in any vehicle.

(G) Hearing protection is required in the Manufacturing areas at any client / customer site whenever one or more machines is operating adjacent to your work area.

(G) Our customers have addressed which hearing protection is required for specific noise environments. Hearing protection is required in any Service, Utilities, and Manufacturing areas whenever equipment is running.

(G) Noise Sampling / Monitoring is performed by our customers.

(G) An employee must receive a baseline audiogram prior to the first day of employment and annually thereafter.

(G) Northeast Data may require personnel that are subject to exposure to acquire a baseline audiogram to keep on file. This audiogram will be kept on file for the duration of employment.

(G) At times double hearing protection will be required. Northeast Data employees are required to utilize their company provided Earmuffs along with their ear plugs where noise levels exceed 100 db, or in areas posted that double ear protection is required. If you are in an area where there is jack hammering and concrete “saw cutting”; Northeast Data employees will be required to utilize double hearing protection as well as post a warning sign for others in your area.

(I) If in doubt, always obey posted signs, review hearing maps, or consult Safety Personnel.

(I) Training in the use of the appropriate hearing protection will be provided by a Northeast Data, Inc. Manager or Foreman prior to start of employment during orientation, OSHA 10 / 30 training, customer site specific training, and annually.

(I) Employees will be provided an annual training on the hearing conservation program.

(I) Employees who are exposed to noise of 85 db or greater will be included in the hearing conservation program and the audiometric testing program.

(I) Employees should never be in areas greater than 10 db without hearing protection and shall be notified in writing within 21 days of determination of a standard threshold shift. Re-evaluation of hearing protection will be addressed in the event of an STS.

Note: Standard Threshold Shift, or STS, is defined in the occupational noise exposure standard at 29 CFR 1910.95(g)(10)(i) as a change in hearing threshold, relative to the baseline audiogram for that employee, of an average of 10 decibels (db) or more at 2000, 3000, and 4000 hertz (Hz) in one or both ears.

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Work Appearance Injury Prevention Safety (Proper Work Attire)

(G)  All Northeast Data Employees are required to wear the uniform provided to them from the company at all times while on a customer site. You are expected to be in proper work attire to prevent injury

(G) Hooded garments (ex. Coveralls, rain-suits, jackets, etc.) are considered as loose clothing and cannot be worn with hood down when around running, unguarded equipment.

(G)  Ties are not permitted outside pedestrian aisles in operating areas

(G)  Long sleeved shirts must be tightly rolled up above the elbow or securely fastened at the wrist when around running, unguarded equipment.

(G) ll work shirts with at least a 3 1/4 sleeve is required while working on a customer site.

(G)  Northeast Data employees are required to wear full-length pants

(G) Tank tops, shorts, cut off pants, tennis shoes, and loose clothing are strictly prohibited at customer sites.

(G)  All clothing worn must be in good repair. (i.e. torn clothing, exposure of body parts, and torn out knees in garments are prohibited.)

(G)  Any employee with Hair longer than 3" from the body must be contained above a hat or behind the collar.

(G) Facial hair 3" in length or more must be contained by hair nets, braids, or other methods.

High Visibility Clothing / Garments (High-Vis)

Northeast Data issued orange / green fluorescent shirt or vest is Mandatory in the following situations and areas:

(I) Working in any / all construction areas

(I) Working in congested work areas

(G)  Personnel working within 15 feet of railroad tracks or exposed to vehicular traffic along all outside roadways, and parking lots.

(G)  Personnel walking in any area without a designated / established walkway when exposed to vehicular traffic of any type.

(G) Operating a tricycle on customer site.

(G) High-VIS must be worn in the following areas at Procter and Gamble in Mehoopany, PA

(G) Building 52 Stock Prep - the entire department

(G) FPH, Logistics, Warehousing, Parent Roll Storage

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Prescription Drugs Prevention Safety

(S) All Northeast Data employees shall inform their site foreman prior to using prescribed drugs on the job and shall only be allowed to use those same authorized drugs under the following conditions:

Medical Marijuana is still considered illegal by Federal Laws. Northeast Data will follow the federal laws governing this topic and will not tolerate a positive drug test result received due to Medical Marijuana use regardless of state law.

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Fatigue Management Policy

Purpose

The purpose of this policy is to establish the requirements for managing fatigue. It is intended that this policy will reduce the risk of fatigue-related injuries and incidents in the workplace.

Scope

This policy applies to all staff – especially those whose work involves travel and extended hours of employment and/or on-call arrangements.

Definitions

Employee Assistance: The Employee Assistance Program (EAP) provides confidential counselling and support to staff and their families on a range of issues, such as alcohol and drug related problems, emotional stress, and relationship difficulties. It should not be used for counselling relating to an injury that is subject of a workers’ compensation claim or as post-incident counselling following a traumatic incident in the workplace. Refer to the EAP policy for further details.

Extended Hours: Hours that are an extension of a standard workday / work week, as a result of overtime, on-call arrangements, out of town travel, or secondary employment.

Fatigue: A mental or physical exhaustion that prevents a person from functioning normally. In the work environment this can mean that a person is also unable to function safely. It has many causes, but is usually related to inadequate restorative sleep

Resorative Sleep: The process by which the body overcomes fatigue. It involves cycles of deep sleep that allow a person to recuperate and wake up refreshed.

Out of Town Travel: Work performed during 10-day trips away from the main office or main work site.

Sleep Cycles: Sleep cycles are determined by the body’s natural biological rhythms (also known as circadian rhythms or the ‘body clock’), which are repeated every 24 hours. As well as regulating sleep cycles, biological rhythms also regulate body temperature, digestion, and hormone levels.

Policy Statement

Northeast Data, Inc. is committed to providing and maintaining safe systems of work for all its workers, including those whose work involves out-of-town travel, extended hours, or on-call arrangements.

Northeast Data’s operations are sometimes undertaken outside ordinary work hours. Activities such as out of town work often involve extended hours. These working arrangements may contribute to fatigue if not managed appropriately.

Fatigue can be caused by both work and non-work related factors. Non-work factors include family responsibilities, social activities, health issues – such as sleep disorders – study commitments. Work factors include out-of-town travel and extended work hours.

Responsibilities

Managers and workers of Northeast Data, Inc. have a responsibility to ensure that fatigue does not impact the safety, health and well-being of themselves and others.

Managers and foremen are responsible for:

Workers are responsible for:

Work Hours and Rotations

To help control fatigue, out of town employees will work 10 days out of town and return to recuperate rest for 4-days on a rotation basis before starting a new out of town job. No employee should work over a maximum of 10-hour day on an out-of-town trip. Managers are expected to rotate staff accordingly, so employees are able to recuperate from previous trips. Drive time per day shall be made in rotation staffing.

Ergonomic Friendly Equipment Usage

Employees and Managers are encouraged to use mechanical assistances, counterbalance systems, adjustable height tables, and workstations, powered equipment and ergonomic approved tools to reduce work effort and muscle exertions and fatigue.

Analyzing Work Tasks

Managers and foremen are required to analyze all work tasks prior to the start of the job to determine if additional equipment is needed to complete the task to ensure employees are not putting their self into extra exertion in order to complete the work and allowing time for recovery when work tasks are completed.

Rest Breaks

Managers shall encourage staff to take the necessary rest breaks in the morning and afternoon along with lunch breaks to allow employees to recuperate and rest after various work activities to improve the mental well-being and performance.

Prescription Drugs / Over the Counter Prescriptions

Employees working at heights or in positions that require alertness on production floors or for tasks are required to speak to their manager and or foremen if they are utilizing over the counter or prescription drugs especially in circumstances where these prescriptions may cause dizziness.

Fatigue Management Training

Managers and employees will submit to fatigue management training on a per needed basis to learn how to deal with fatigue caused by various factors, such as work, activity, rest, or stress.

Breach of Policy

Breaches of this policy and/or any of its associated procedures may result in disciplinary action being initiated in accordance with Northeast Data’s Discipline Policy.

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Fit for Duty Policy

Purpose

The purpose of this policy is to ensure that employees are fit for duty to perform the work they are assigned to.

When to apply this policy

Managers and foremen are required to apply this policy to employees when they believe the employee is not able to perform their essential job duties or poses a direct threat to workers and others because of a medical condition. Concerns about an employee’s performance or conduct when there is no information suggesting that the issue arises from a medical condition will continue to be addressed through relevant performance and conduct policies.

Definition

Fit for Duty: An employee is fit for duty when they are able to perform their essential job functions, with or without reasonable accommodation, in a manner that does not pose a direct threat to themselves or another employee. An employee’s essential job functions are the fundamental duties of the position or the primary reasons the position exists. For all jobs at Northeast Data, regular predictable attendance, ability to work without disruption to the workplace, and ability to comply with applicable conduct standards are essential job functions. A direct threat is a significant risk of substantial harm that cannot be eliminated or reduced by reasonable accommodation.

Drugs and Alcohol

Northeast Data, Inc. is a zero-tolerance company and will not tolerate any use of non-prescribed drugs or alcohol during work hours. Employees under the influence of illegal Drugs or Alcohol are not fit for duty and should be subjected to the Northeast Data Drugs and Alcohol policy on file.

Employee Job Functions

Employees are required to come to work fit to complete their work assignments, meaning they should not be under the influence of drugs or alcohol. If an employee is under medical or physical impairment, it is required that they are cleared for duty by a physician before they are allowed to return to work. Job functions should not be requested for an employee to complete unless the employee is physically capable of completing the job task.

Prescription Drugs / Over the Counter Prescriptions

Employees working at heights or in positions that require alertness on production floors or for tasks are required to speak to their manager and or foremen if they are utilizing over the counter prescription drugs especially in circumstances where these prescriptions may cause dizziness.

Monitoring Employees

Employees are required to work in a certain professional manner daily. Managers and Foremen are required to monitor the employee’s activities and behaviors.

Fatigue

It is necessary to notify your manager immediately if you feel fatigued and cannot perform your duties safely.

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Jewelry Prevention Safety Policy

(G)  Jewelry is not allowed to be worn around operating equipment, or on the operating floor, because of the potential of getting entangled in machinery. This jewelry restriction includes non-metallic jewelry. Unless restricted by module quality standards, there are exceptions for:

The following items are strictly prohibited while working in operating or construction areas at any customer site:

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Tool Injury Prevention Safety

(I) The maintaining of quality tools is highly encouraged. All Northeast Data employees are required to take care of all company tools.

(G) Proper selection of tools is critical (always use the right tool designed for the task)

(I) Employees shall not share or borrow tools among other contractors.

(I) All Northeast Data employees are required to place all tools located in their personnel tool boxes on an inventory list if they plan on taking their tool box inside a customer site and the inventory list must be approved to bring the items on site by the customer. This approved inventory list must be updated continually.

(I) All approved inventory lists must be signed by the customer's security department. This includes updated versions of the paperwork. (A copy of the approved paperwork needs to be faxed to the office for departmental files)

(I) Always inspect all tools thoroughly for defects or damage before every use.

(I) Any chisel or other impact tools with mushroomed heads should not be used.

(I) Understand and completely follow the manufacturer's directions for safe use of tools.

(S) Never modify tools, disable or remove or defeat safety devices or guards for any reason.

(S) Damaged tools or equipment must be tagged - "DEFECTIVE Do Not Use" and removed from service immediately.

(S) Northeast Data employees are not to use tools or equipment that are tagged and / or locked out.

(G) Northeast Data employee will only be allowed to use knifes approved for your area/task. When not in use, all knives must be stored with the blade sheathed or covered to prevent accidental (blade) contact.

(G) All Northeast Data employees must wear cut resistant gloves while cutting.

(S) Northeast Data employees will only use electrical tools and extension cords with a ground fault circuit interrupter.

(S) All Northeast Data employees will use appropriate Personal Fall Arrest Protection when working at heights over 4 (four) feet.

(G) Magnetic base drills, at a minimum, require a tether to prevent falling.

(S) All grinders used in cutting operations must be approved, reviewed, and signed off on. Cutting guards must be used with cutting disks on all grinders.

(G) Operational speed (RPM) and condition of all grinding, cutting discs, rotary files, cut-off and de-burring tools must be matched to the tool speed produced.

(G) Tungsten electrode sharpeners are strongly recommended for this task.

(I) Do not use any tool handle for pounding or bumping

(I) Do not use screwdrivers as a pry bar or chisel

(I) Do not use pliers as wrenches

(I) Protective insulation on electrical pliers should be free of cracks to avoid shocks

(I) Use the smallest wrench that will fit across the flats of a nut. Avoid the use of an adjustable wrench. If pushing in close quarters, use the base of palm and hold hand open

(I) Do not hammer on wrenches

(I) When chiseling, hold the chisel with thumb and first finder about an inch from upper end of the chisel

(I) Clamp small pieces rigidly in vise-clip toward the solid or stationary jaw of the vise

(I) Always center punch locations of holes to avoid wandering drills

(I) Use a tight-fitting handle on a file

(I) Apply only enough pressure to keep a file cutting. Do not use a file as a pry bar.

(I) Clean and inspect tools daily.

(I) Never use a pipe wrench for any task other than on a pipe or shaft.

(I) You must have proper clearance (1/8") maximum between the tool rest and the grinding wheel on a pedestal or bench type grinder. The upper guard must be no more than (1/4") away from the wheel.

(G) On portable grinders, you must have guards in place.

(I) Do not grind plastic, painted objects, or any material that will load up a wheel or disc.

(I) When grinding, you must wear a face shield together with goggles or safety glasses.

(I) After grinding, clean forehead and brim of hard hat before removal of glasses or goggles to prevent material from falling into your eyes.

Procter and Gamble - Mehoopany, PA Owned Tools or Equipment

Electrical Safety, Power Tools / Cords

(I) All 120V electrical power tools and cords must utilize a Ground Fault Circuit Interrupter

(I) Testing of ground fault devices is required before every use.

(G) Never plug in any live 240/480 volt devices.

(I) Cords, leads, and hoses must be routed over or around walkways and work areas

(G) If a cord or welding lead is routed on the ground it must be secured.>

(G) All power tools must be unplugged when repairing, changing blades / bits / disks, or when not in use.

(I) Laser tools must be approved by customer prior to being brought on site

(I) Defective tools must be removed from service immediately and tagged out of service.

(I) All non-double insulated power tools and cords shall be checked for positive ground.

(I) All double insulated power tools shall be checked for proper insulation before being used for the first time and every three months thereafter

(G) Cord and plug connections for magnetic drills must me marked "Mage Drill Do Not Disconnect"

(L) Any activity near any overhead energized power lines is strictly prohibited

(I) The following is a list of plug adaptations for electrical power connections:

Voltage

Manufacturer

Cat #

Description

120 Volt

Hubbell

7567C

2 wire w/ ground

220 Volt

Hubbell

99656C

2 wire w/ ground

480 Volt

Crouse Hinds

APJ10487

3 wire w/ ground

(S) Portable tools and equipment on a customer site not protected with GCFI must be inspected quarterly and color coded with a wire tie or sticker based on customer specifications.

Procter and Gamble - Mehoopany, PA Mandatory Requirements:

(S) Quarterly safety wire tie or sticker color code will indicate that the piece of equipment has been tested for that time period:

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Workplace Organization (Housekeeping Safety)

(I) All Northeast Data employees are responsible for following good housekeeping and general safe practices in all work / office areas on and off customer sites. These responsibilities include but are not limited to:

(I) Keep extension cords and electrical cords out of the way

(I) Follow manufacture's procedures when clearing a jam in the copying machine

(I) Keep lid down when operating copying machine.

(I) Keep hands away from the paper shredder when turned on. Ensure machine is off when clearing jams.

(I) Unplug copying machine if a jam cannot be cleared.

(I) Do not unplug any office machine by the cord; grab the plug itself.

Work Area:

(I) Keep desk file drawers closed.

(I) Remove staples with staple remover

(I) Keep wastebaskets away from electrical outlets.

(I) Keep door closed on upright cabinets.

(I) Sit squarely on chair, not on the edge. Do not recline.

(I) Use letter openers properly, ripping in the direction away from your body.

(I) Keep desk, file, and work areas neat.

(I) Do not open more than one file cabinet drawer at a time.

Shop / Construction / Site areas:

(I) Work areas include storage areas, tool sheds, lay down areas, and equipment yards.

(G) Materials need to be stored neatly.

(G) Lift platforms must always be neat and clean.

(S) Immediately clean up potential trip or slip hazards. When immediate clean-up is not possible, Northeast Data employees shall rope off area and clean up as soon as possible.

(G) All Northeast Data employees shall ensure all tools / equipment / job materials / etc. are stored in their proper place.

(I) All general construction areas (pre-work areas, staging/storage areas, and work areas) are to be maintained at an acceptable level of organization as defined by:

(G) All designated staging/storage areas are to be roped off with yellow safety ribbon indicating the boundaries of the area. Each staging area is to be identified with a sign including the contact name and contact phone extension. On customer sites, this will be the customer designated project contact:

(I) Company / Personnel owned items must be kept within their designated area; they should not be scattered throughout customer sites.

(I) All large tools and moveable equipment but be labeled with the owner's name on it.

(I) On all customer sites and at all office locations, garbage cans that have been filled by employees' waste must be emptied into an appropriate garbage container. Large waste items on customer sites must be removed daily.

(I) Upon completion of projects, Northeast Data employees must remove all tools and equipment from the customer sites in a timely manner.

(I) Do not use metal flashlights, metal rulers, or uninsulated metal tools on or near electrical equipment.

(G) Only qualified and authorized persons may use welding equipment, shop machine tools, and equipment.

(I) Remove all sharp edges on any work being completed prior to calling a job complete.

(I) Do not leave tool bits or drill bits in equipment unattended

(I) Any spills or liquid on floors, benches, etc. must be cleaned up immediately.

(G) All machinery must be locked out during adjustments and repairs.

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Pedestrian Walkways at Customer Sites

(I) Northeast Data employees are required to be aware of their surroundings.

(G) Northeast Data employees are required to follow customer designated pedestrian walkways when moving through customer sites. If your work shall block a designated walkway, you must provide for a clear, designated walkway and have it approved by the customer.

(G) Northeast Data employees will use pedestrian doors and walkways whenever possible.

(G) Northeast Data employees while on customer sites are not to block exit/entrance points and must get prior approval by the customer if they can't prevent blocking these points

(S) Cell phone usage is prohibited when walking in pedestrian walkways. Any time a cell phone is in use, you must STOP to make / take calls, text messaging, bluetooth, web search, etc. Use of a cell phones is prohibited unless you are stationary.

(G) When walking through customer sites, Northeast Data employees will:

(S) Customer designated walkways are clearly marked. Should your work block a pedestrian aisle way for any period of time, a well-defined SAFE temporary walkway must be provided by the person causing the detour. This must be clearly communicated to all pedestrians traveling in the affected area either verbally or the proper signage placed in the area. If a door to the outside or an evacuation route is to be blocked, it must be approved first, and include clear SAFE direction to the next available EXIT door.

(S) Temporary walkways must meet the following specifications:

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Fire Prevention Safety

(I) Know the emergency fire signals and the location of the nearest red alarm pull boxes.

(I) If you discover a fire, pull the alarm to notify other workers in the area so they can evacuate the area.

(I) Remain in the general area to show the responding fire personnel the location of the fire.

(I) If you accidentally set off an alarm, remain there to let responders know there is not an emergency.

(I) If the alarm system should fail to function when an alarm box is pulled or when fire water flows, shout "FIRE" to those in hearing range and call emergency personnel. Give your location, the nature of the fire or emergency, and your name.

(I) Always know your location to be able to respond to alarm situations.

(I) If the fire is in the vicinity, disconnect power to equipment immediately, stop all hot work, and evacuate the area immediately.

(I) Advise and assist first responders with a safe route of access if applicable.

(S) All Northeast Data employees will only smoke in designated areas outside the Northeast Data Office and only where permitted at customer sites.

(S) Northeast Data employees will use proper precautions around open flames

(S) Combustible materials shall always be stored away from heat sources.

(I) Combustible trash, rags, and waste are to be kept only in red metal containers with tight tops or approves self-closing safety cans with the lid held open with a fusible link and are to be disposed of when full or at the end of each shift.

(I) All high-pressured gas cylinders must be immediately removed from a fire area

(S) All managers and employees may not at any time use a Butane lighter on any customer site. Butane lighters are extremely dangerous and may explode

(S) Combustible materials may not be stored inside any building unprotected by sprinklers.

(S) Company / Customer owned fire extinguishers must not be removed from their sealed location except for use.

Flammable / Combustible Liquids - Storage and Handling:

(G) Storage of flammable liquids (in 5-gallon or smaller metal safety cans) equipped with metal fire baffles must be only in pre-approved locations and conditions.

(I) The following color codes must be observed for storage containers:

(I) Use non-flammable solvents for swabbing, dipping, soaking, and other cleaning operations

(I) Contents of each safety container must be plainly stenciled on the outside of the can

(I) Do not store under trailers or in unprotected areas

Fire Extinguisher Inspection and Mobile Equipment:

(I) Fire extinguishers #5 Dry Chemical Types are required on all mobile equipment. I.e. forklift, boom lift, platform lift, welding machines, etc. They must be inspected prior to each use. If the seal is broken, damaged, or missing, cease use of machinery and replace immediately.

(I) Discharged extinguishers must be removed from service until they can be refilled. All extinguishers should be inspected on an annual basis and tagged with date and inspector.

Extinguisher Type

OK to use on:

Cautions

Water (Class A)

Paper, wood, cloth, ordinary combustibles

Never use on electrical gear (shock hazard), not effective on gas or oil.

Dry Chemical

Paper, wood, ordinary combustibles, flammable liquids, electrical fires

Causes damage or clean-up, problems in electrical gear. Chemicals can "cake" in extinguishers, may have to be bumped to operate.

Carbon Dioxide

Electrical fires, flammable liquids

May cause hazard to people in confined area by displacing oxygen

Metal Fires (Class D)

Metal fires

Metal fires in Metallic Sodium, Magnesium

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Hot Work Permits and Procedures

(S) Customer designated Hot Work Permits are used to ensure that proper safety precautions are taken before, during, and after procedures that have high risk of starting fires. Each customer has authorizers for approval of permits.

(I) Hot Work Permits are specifically required for any ignition source (i.e. arc welding, gas welding, flame heating, electric heat guns over 300 degrees, industrial heat guns are 500-1000 degrees, (bending parts, soldering pipes, grinding with portable electric or pneumatic grinders)

(S) Everyone is responsible for fire safety in their area, no matter who performs the work.

(I) Permits are made in duplicate by the supervisor of the work to be done. The original copy is issued to the person doing the work, who must keep it in the area of the work until completion of the work, then turn in the permit to their supervisor at the end of their shift.

(I) Expiration of Hot Work Permit is based on customer specifications.

(S) Supervisors are responsible for:

Types of Fire Watch and Training

(S) The "Hot Work Bottle" water can is used to pre-wet areas where latent dust may be trapped. It must be filled with water, pressurized, be identified as such with decal, fully operational with a working pressure gauge and safety pin in place.

(S) Two full extinguishers are required prior to start.

(S) A #5 or Dry Chemical extinguisher shall be at the welding machine location during operation.

Welding, Cutting, Burning, and Heating:

(G) An approved signed hot work permit is required before starting any Hot Work

(G) All welding and cutting operations shall be shielded by non-combustible for flameproof screens to protect employees and other persons in the vicinity from direct arc rays.

(S) All tarps placed in any Hot Work area shall be fire resistant type only with tags affixed.

(G) When electrode holders are to be left unattended, the electrodes shall be removed, and the holder shall be placed or protected so that they cannot make electrical contact with employees or conducting objects. Extended periods of inactivity require shut off of the welder.

(G) Fuel gas ad oxygen cylinders must be separated if not used within a 24-hour period.

(G) Welding lead cam lock connectors shall be fully booted and insulated at all connection points

(G) Tig Torch electrical connections shall be fully insulated at the connection point.

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

 

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Safety Emergency Alerts

(S) All Northeast Data employees will immediately communicate any fire or potential emergency by using word of mouth or the fire alarm system

(S) No Northeast Data employee shall attempt to fight a fire alone

(S) All Northeast Data employees shall follow appropriate evacuation procedures.

(S) All Northeast Data Employees shall follow the Medical Emergency Policy set forth by Northeast Data

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Fall Protection

(S) All fall protection / prevention shall comply with current ANSI and OSHA regulations.

(I) Employees shall be trained, familiar with all current fall protection techniques and methods appropriate for the elevation which they are working at.

(G) Tie off to a structure able to hold 5,000 lbs. of force or the potential load created by a fall.

(L) Full body harness equipped with only SRL / PRL retractable lanyards, with double locking snap hooks are required when exposed to a fall 4 feet or more.

(G) Two SRL lanyards shall be utilized anytime a worker must unhool and move to another location. One lanyard shall stay connected to the harness and tie-off point at all times. The other shall be connected to the new tie-off point before disconnecting and moving the first.

(S) Employees working off ladders, any type of scaffold, leading edge work, or working over a hazardous process at any level shall wear appropriate fall protection equipment, if theya re exposed to a fall of 4 feet or greater.

(S) Ascending and descendng any ladders requires 3 point contact at all times

(S) All floor perimeters and wall openings will be protected with temporaty guard rails and toe boards until permanent items are in place or flagged at least 6 feet from the edge.

(S) All floor or platform penetrations or holes must be covered or guarded

(S) Hole covers must be cleated or secured to prevent movement, be substantial enough to support the potential weight load, and marked "Danger", "Hole Cover" with indelible High Visibility paint.

WARNING:Fall protection is a Life Critical, 0 Tolereance System. Improper use, incorrect use, incorrect equipment can also be considered a violation with similar consequences

Exception permit for donning ANY Straight Shock absorbing Lanyard, Straight Lanyard with shock pack in a single or double leg configuration:

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Ladder Prevention Safety

This policy is in accordance with OSHA's Ladder Safety Practices regulation. The purpose of this policy is to protect personnel from injury caused by the improper use of ladders.

(I) Northeast Data employees will only use approved and inspected ladders at all times.

(S) All Northeast Data employees will use appropriate Personal Fall Arrest Protection when working at heights of 4 (four) feet or more. All Northeast Data employees must have a plan and anchor-man until they are tied off when working at any type of elevation height.

(I) All Northeast Data employees will use only OSHA/ANSI approved industrial ladders.

(G) Do not use finished product, raw material, or equipment for climbing on or as a walking working surface for any reason.

(G) A break in elevation of 19 inches or more requires the use of a ladder or stairway when no ramp, runway, or sloped embankment is present.

(I) Ladder injuries fall into three categories: using ladders in an unsafe manner, using ladders in an unsafe condition, and over-extending our reach rather than repositioning the ladder.

(G) Metal ladders are not to be used around electrical equipment. All metal ladders must be marked, "NOT FOR USE AROUND ELECTRICAL EQUIPMENT" Aluminum ladders are not to be used at any time.

(I) Northeast Data company owned ladders will be marked with the company name, address, and phone number.

(G) All ladders must be inspected monthly and before each use. An inspection tag shall be attached to each ladder. Ladders not current in inspection shall not be used until inspected by a competent person.

(S) Ladders must not be used if rungs, steps, or runner are either missing, cracked, or broken, or if ropes are frayed or worn on extension ladders. Defective ladders must be immediately removed from service and tagged "DEFECTIVE - DO NOT USE". Faulty ladders will be repaired or replaced.

(I) All ladders must be kept clean, dry, unpainted, bear all warning labels, be kept in good repair, and stored properly when not in use.

(I) Always place all ladder feet on a firm surface. Prior to ascending the ladder, make sure it is secure and has safe footing. The ladder shoes, your shoes and the ladder rungs must be free from mud or grease before climbing.

(I) Ladders will not be placed in front of doors opening toward the ladder unless the door is blocked and the proper barricade and signage has been established.

(I) Ladders will not be placed against windowpanes or sashes.

(I) Never lean away from a ladder; move it to a better location.

(I) Get help, if needed, to carry or stand erect an extension or step ladder.

(G) Always face a ladder (fixed vertical, extension ladder, or step ladder) when ascending or descending and maintain a three-point contact unless a fall protection system is in use first.

(S) Don't stand on top rungs. Stay below the third rung from the top of straight ladders, and on or below the third step from the top of a stepladder. Safety harnesses are required when it is necessary to use the second top step of a stepladder over 4 feet.

(I) Keep your weight centered between side rails to avoid falling off the side of the ladder.

(G) Maintain a firm grip use both hands in climbing. This means to maintain three (3) points of contact at all times. Do not carry materials up or down a ladder. If necessary, use an assistant and pull up extra material with a rope.

(S) Ladders will not be spliced together to make a longer ladder.

(G) Ladders will not be used as scaffolding, platforms, or runways

(I) Never store ladders in areas where they can be exposed to chemicals or harmful environmental conditions.

(G) All ladders must be secured. The ladder must be held at the base (footed) until it is tied in place. If it is not possible to tie a ladder, it must be (footed) by another person while in use.

(I) Northeast Data employees will determine and utilize the appropriate ladder for each job.

(G) Top halves of extension ladders must not be used as straight ladders.

(I) Never walk under a ladder.

(S) Personnel working off ladders, any type of scaffold, leading edge work, or working over a hazardous process at any level shall wear appropriate fall protection equipment and be tied off at all times.

(I) Ladders are to be taken down and returned to their places of storage after the job is completed.

(I) Place a ladder so that the horizontal distance form the base to the vertical place of the support is approximately one-fourth (1/4) of the ladder's length.

(G) No ladder will be used to support more than one person at a time unless designated by manufacturer.

Step Ladder Prevention Safety

(I) Stepladders will not be used for heights in excess of 20 feet.

(G) Stepladders must be locked fully open before use.

(I) When carrying a stepladder, it must be fully closed

(G) Never climb the back supports of a stepladder.

(G) Never use the shelf on a stepladder for a step.

Extension Ladder Prevention Safety

(I) Extension ladders are designed for use with the top section (extension) OVER the bottom portion. Don't invert them.

(I) The ideal angle for a ladder is achieved when the horizontal distance from the base of the wall (or support point at top) is about 1/4; of the vertical height to the top support point.

(I) Place ladders only against solid backing - never on glass or loose stacks of materials.

(G) Extension ladders must extend at least three (3) feet above the point of landing.

(G) Fall protection must be used anytime an employee is more than 4 feet off the ground.

(G) All extension ladders must be equipped with safety shoes.

Scaffold Use and Scaffold Building

(I) Scaffold building and use will comply with current OSHA regulations.

(S) All scaffolds must have a complete scaffold tag affixed indicating conditions of the scaffold construction, restrictions, and requirements completed and signed by the competent scaffold builder.

(S) All scaffolds shall be built and used in a safe manner. Building of scaffolds shall be completed under the direction of a competent, trained person for scaffold building.

(S) All persons who work off supported scaffolds shall be properly trained.

(S) Barricades, safety nets, and tool tethers must always be used to protect others from falling objects.

(G) Scaffold boards must be constructed of LVL (Laminated Veneer Lumber). Runways must be clear of debris, trip hazards and must be secured with tie wire, or cleats as necessary to prevent movement.

(G) Handrails, mid-rails, toe-boards, a full solid platform, and a ladder for access and exit with safety chains or spring gate are required on all scaffolding.

(S) During scaffold construction intermediate working platforms must be installed at no more than 10-foot intervals to provide a working surface for builders.

(S) Fall protection must be used while building scaffolds.

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Personal Manlift Safety

(O) Only trained, qualified, licensed, and authorized personnel will operate Northeast Data owned or rented liftequipment.

All personnel authorized to operate Northeast Data owned or rented lift equipment, including temporary workers hired through a staffing agency and subcontractors, must be aerial and scissor lift certified through an authorized operator proficiency certification training course to operate an aerial lift for Northeast Data, Inc. Lift certifications obtained through an online training course will not be accepted.

(S) All persons on or around a manlift or in an area where overhead work is being performed are required to wearthe following safety equipment:

(O) Operators of lift equipment must ensure the weight on the lift is limited to the weight specified on the machine.(Gross weight: weight of the operators and their tools and equipment.) Operators shall never attach overhangingloads or increase the work platform size.

(O) Lift equipment shall never be operated within ten feet of power lines as these machines are not electricallyinsulated. Operators are required to plan their route prior to taking action. They shall check their route forobstructions and electrical conductors.

(S) Always distribute the load evenly over the area work platform.

(S) Operator must keep body and limbs inside the lift while in motion.

(O) Do not lean over the guard railings, or controls to perform work.

(O) Do not stand, sit, or climb on the guardrail.

(G) Operators will not place hands on the toprail of the lift while in operation as this is a pinch point.

(O) Operators will not use ladders or scaffolding on the work platform to obtain greater heights.

(O) Operators will not recharge batteries near sparks or open flames. Batteries being charged emit highly explosive hydrogen gas.

(O) It is against company policy for operators of any lifts to drive on uneven, sloping, or soft terrain, unless the lift is designed for that type of terrain.

(O) Report any damage to or cause by lifts immediately to designated safety personnel

(O) Northeast Data personnel are never allowed to over-ride any Hydraulic, mechanical, or electrical safety devices any lifts owed or rented by Northeast Data.

(O) Northeast Data personnel shall never operate a lift if they feel dizzy, unsteady or are under the influence of any over the counter or prescription drug.

(O) Northeast Data personnel shall always make sure all safety chains are attached on the lift they are utilizing. If the lift does not have a safety chain, then the operator shall be sure to secure the safety gate or mid Rail bar.

(O) Upon your first date of employment, Northeast Data provides employees who may come in contact with a lift a full body harness and lanyard. At all times while in operation of a lift, employees are expected to wear their company issued full body harness and lanyard with the lanyard attached to a secure point. Any Northeast Data employee who was not issued a full body harness or lanyard may not at anytime utilize another employee’s gear.

(O) While on any customer site and in operation of a lift, all employees are expected to use caution when approaching an intersection and obey site policies for operation of an aerial lift at all times.

(O) Orange safety cones, flashers, and caution tape (yellow/red) will be used to form a minimum perimeter 5 feet beyond the overhead work area.

(O) A ground man will be used at all times for traffic control as well as pedestrian protection.

(O) A ground man must be used at all times while moving a lift in the elevated or non-elevated position as a spotter and travel safety person.

(O) Prior to utilizing any lift, Northeast Data employees are required to perform a thorough inspection of the lift for damage such as cracks, hydraulic leaks, damaged controls, loose wires, connections, or tire damage. In the compartment of the lift a safety checklist can be located. This safety checklist will show what areas are required by Northeast Data to be checked prior to utilizing the lift.

(O) Operators of safety lifts must verify that a 5 lb dry chemical fire extinguisher is securely mounted to the lift. If there is damage to the extinguisher of if the extinguisher has a broken seal, the extinguisher must be discarded and replaced prior to the lift being utilized.

(O) Operators are expected to evaluate the ground they are on with the lift and verify it is level and firm prior to lifting the lift basket.

(O) Good housekeeping is expected from all employees, all lifts will be kept clean at all times. Lifts shall be free of debris, parts, and tools when in use as well as cleaned after each use.

Excavations

(S) Flagging, warning signs, red barricades are required around all open trenches and excavations at least 6 feet from the edge of the excavation wall.

(I) If underground utilities are damaged during the case of the excavation process, work must stop immediately until the area has been reviewed by engineering / site owners and management.

(S) Northeast Data employees will complete any necessary customer required permit documentation prior to the start of excavation work.

(S) All excavations must be benched, sloped, shored, or employ the use of an approved trench box.

(S) All excavations 4’ or more will be monitored and follow confined space procedures.

(S) No personnel will enter an excavation until management, foreman, or other competent designated supervisor has inspected it and deemed the area safe for entry.

(S) Entering an excavation confined space requires a full body harness and retrieval rope to be attached

(S) A stairway or ladder must be provided within 25 feet of any personnel inside all excavations.

(S) Spoil piles shall be placed at least 2 feet from the edge of the trench.

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Cranes, Forklifts, and Other Mobile Equipment

(I) All vehicles listed in this policy are considered Mobile Vehicles and require special awareness, operational training, special requirements, and safety equipment.

Cranes / Equipment / Rigging

(L) Only NCCO Certified operators or equivalent will operate cranes

(I) Customer required inspection reports must be completed prior to operation

(G) Only trained signal persons will direct any crane operations where the operator is out of sight of the load being transported

(G) Rigging for hoisting of materials or equipment must be supervised and approved by a competent trained rigging person

(S) Critical Lifts 70% of crane capacity or the use of two cranes together on a lift require a written and approved critical lift plan to be completed prior to lift.

(S) Never move a rigged load over any person or occupied buildings.

(G) At no time will the operator leave the controls when a load is suspended

(O) Man baskets require a written critical lift plan and are to be weight tested prior to use daily

(O) Riding material being hoisted is strictly prohibited

(G) Hoists, forklifts, cranes, cables, slings, and other lifting equipment and rigging must be inspected quarterly and labeled according to customer specifications

(I) Slings and cables in poor condition shall be tagged and removed from the job site immediately.

(G) Taglines shall be used on all suspended loads to stabilize the load

(S) Riding on any equipment where seatbelts are not provided is prohibited

(I) Examine contents of any crates or containers prior to opening as the load may have shifted and shipping braces dislodged during transport.

Autonomous Vehicles

(S) Do not enter Autonomous Vehicle travel paths.

(S) Wait for the vehicle to complete its drop or pick when it is within 15 feet of a hazardous area. Once the vehicle has left the 15-foor perimeter, you may proceed crossing.

(I) Autonomous Vehicle travel paths will be designated using orange painted lines to meet ANSI requirements.

(O) Travel paths are not to be entered by unauthorized personnel.

(G) Items shall not be stored in travel paths.

(G) Any work / maintenance being performed in Autonomous Vehicle paths require communication to be made with individuals in and around the operating area.

(G) Anytime work / maintenance is being performed in Autonomous Vehicle paths, cones must be placed in the center of the travel path at least 15 ft away.

(S) Anytime a Pick-up / Drop zone is locked out, a cone must be places in the path to prevent unexpected drops.

(G) All Booms / Mark Lifts / EZ-Go's will have static straps attached to prevent Autonomous Vehicle strikes.

Forklifts / Tricycles / Vehicles

(S) Never approach any powered vehicle while it is operational. Maintain 6' safe distance until the vehicle is off and disables.

(S) All vehicles must stop completely at all intersections designated with a posted stop sign.

(L) All vehicles must slow down, beep horn, and proceed with caution at all intersections.

(G) Fuel operated forklifts and cranes must be personally escorted by a fire watch wearing Hi-Viz vest with a # 10 fire extinguisher.

(G) Forklift, aerial lift, and personnel cart operators shall have a current operator's license and will obey all manufacturer and OSHA operator requirements.

(G) Any forklift using extensions greater than 48" shall travel in reverse.

(G) Seatbelts shall be worn in all vehicles at all times

(I) All motorized vehicles on the site shall have a working #5 extinguisher in an accessible location

(I) Never leave a forklift unattended while motor is running or in designated walkways

(I) Return lifts to battery charging station and place on charger after each use.

(I) Tricycles must have the following:

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Hazardous Areas and Conditions Safety

Hazardous Materials:

(S) Hazardous materials are to be approved by the customer prior to being used on site.

(I) Assume any spill or leak is hazardous unless you know otherwise.

(S) Line breaking and hazardous system permits are required prior to breaking into any existing piping. Customer will perform all first line breaks

(I) Northeast Data will assist any customer or employee needing SDS information on process chemicals of concern.

(I) Only trained employees will work on any Chlorine systems.

(I) Unique site cleanup will be completed with the direction of customer specifications.

Chemical Handling:

(S) New chemicals must clear Northeast Data and the customers chemical approval system.

(I) Use the correct PPE for chemicals as dictated by specific safe practices and MSDS

(I) Become familiar with the SDS before working with any chemical, gasses, fumes, and vapors

(I) Use correct PPE and safe practices / procedure when working with solvents, lubricants, detergents, and fuel.

(I) Report all chemical incidents regardless of severity.

(I) All protective equipment must be maintained in clean, safe, and usable condition.

(I) A formal inspection program must be in place to ensure protective equipment is available when needed.

(I) Emergency showers and eye wash stations are mandatory in chemical areas. If these areas fail, immediately postpone work and notify Northeast Data and all others who may be affected.

Spills and Leaks:

(I) Report all spills or leaks immediately

(G) Do not pour any material down drains or sewer systems without prior approval.

(S) Absolutely nothing may be placed in any storm drain except storm water.

Confined Space Entry:

(I) Site confined space safe practice and all OSHA regulations will be strictly followed for all entries on site.

(O) A permit is required before working in a vessel, pit, duct, or other closed or semi-closed space not intended for continuous human occupancy. Never enter a confined space until this has been issued.

(G) Do not enter dumpsters.

(S) All entrants and attendants must be properly trained for the situation and potential hazards of the space. Entrants and attendants shall always install their own personal lock on all systems locked out for the entry permit.

(L) All directions and requirements on the entry permit must be followed completely. Any changes must be approved.

(G) A class III full body harness shall be worn by entrants.

(G) A rated approved rescue rope shall be provided for retrieval of entrants from the space.

(S) ELSA 10min air packs shall be provided for entrants to the space.

Work on External Roof Surfaces:

(S) No work upon external roof surfaces shall be completed without the consent of Northeast Data and the customer safety department.

(G) A written roof work risk prediction shall be completed and posted each day of work after notification is made to the system owner by being signed by the system owner, or his / her designee

(S) Between November and April each year a special "Winter roof risk prediction" will be completed and approved by site safety, Northeast Data, and the roof system owner.

Work hours and Consecutive Days Worked:

(I) No one has permission to remain on-site after fourteen hours in a twenty-four-hour period.

(I) After 5 consecutive 12 hour shifts (60 hours), a full work day (24 hours) will be taken off.

(I) After 8 consecutive workdays of 8 hours duration, a full work day (24 hours) will be taken off.

(I) Employees will work no more than 60 hours in any work week.

Compressed Gas:

Handling Cylinders:

(I) Serious accidents may result from the misuse, abuse, or mishandling of compressed gas cylinders. Persons assigned to the handling of cylinders under pressure must be trained. High-pressure gas bottles will create the "rocket effect" causing them to thrust themselves violently about, injuring people. With many gasses there is a great potential for a fire and explosion, in addition to the risk of personal exposure and harmful effects to the contents.

(G) Do not lift compressed gas cylinders with an electromagnet

(G) Slings must not be used to hoist cylinders individually

(G) You may not use cylinders for rollers, supports, or any purpose other than to contain gas

(G) Flammable gas must be kept at least 25 feet from all buildings, structures, and oxidizers (Oxygen).

(S) Propane cylinders must be kept outside of buildings when not in use (stored or unattended)

(G) Cylinders transported via fork truck, crane, derrick, truck, etc. must be securely fastened in approved cradle, rack, or cart secured with only chain or steel cable, and only moved in a vertical position with safety caps in place.

Using Cylinders:

(I) All Oxy-acetylene burning outfits require safety back flow preventers install prior to use.

(I) Do no tamper with valves, regulators, or safety features on cylinders.

(I) Only use cylinders in an upright position at all times and secure them against being accidentally knocked over.

(I) Fuel and compressed gas cylinders are prohibited on all roof surfaces.

(I) Do not use a cylinder of compressed gas without a pressure-reducing regulator attached to the cylinder valve.

(I) Close all valves when not in use

(I) Never use petroleum-based lubricants.

(I) Gas cylinders in which leaks occur must be taken out of use immediately and handled as follows:

(I) A real hazard is created if sparks, molten metal, electric current, excessive heat (in excess of 125° F.), or flames come in contact with the cylinder or attachments.

(G) Do not weld on or over gas cylinders, battery operated equipment, or flammable storage areas.

(G) Use of compressed air for blow down requires the use of safety goggles. Safety glasses are not considered safety goggles. Wear appropriate eye and respiratory protection for these tasks.

(G) Never use compressed air to blow off clothing or skin.

Forces in Motion:

Hazardous Energy Release produced by gravity and un-expected part in motion can produce a serious injury.

What can we do to prevent this?

Procter and Gamble Mehoopany:

High Awareness Areas:

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Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Lockout / Tagout / Tryout

           Security locks:                                                               System and Process Locks:                                                    ID Tags

                                                                

(S) Ensure verification by the customer has occurred prior to placing locks or beginning any work.

(O) Do not work on equipment, machinery, electrical equipment, or process piping systems with out de-energizing, block and bleed, blanking, or locking and tagging the disconnect or valve.

(S) Foreman and supervisors are responsible for ensuring lockout of the individual has occurred before allowing any crew members to begin work Each affected person will apply a lockout no supervisor / foreperson lockout.

(I) Northeast Data will supply solid green locks. This lock shall bear the Northeast Data name, contact number, and the name of the person applying the lock.

(I) Always apply lockouts to Osborne devices and never directly to the locked device

(G) The customer will apply the first lock and a "Do not operate" tag. Employee will then apply their locks to the Osborne / Lock box after the customer lock is applied.

(S) Do not operate any customer site disconnect valve unless you are qualified, and operation is done under the direct supervision of the customer.

(O) Lockout devices may not be removed by anyone other than the owner, without following the lockout removal procedure, and filling out the customer designated lockout removal form.

(S) All work on or around any general population area requires a lockout.

(L) Foreman or supervisor is required to review the work area to ensure all personnel are clear and the machine guarding is replaced prior to removing a lock.

Energized Work

(S) Customer issued Hazardous Energy Work permit is required before any work can be done on or around energized circuits.

(I) At least two members of personnel wearing proper protective equipment shall be present whenever work is performed on an energized system of 50 volts or more.

(I) At least one person shall be in eyesight and know the disconnect procedures for any enclosure containing 480 volts or the 480 volts shall be disconnected and locked out at the next lockout level.

(I) Always verify if any equipment needs to be locked out prior to starting any work.

Procter and Gamble - Mehoopany, PA Lock Requirements:

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Signs and Barricades

Barricades and signs shall be erected to warn others sufficiently of the hazards associated with the construction activity, detours, or pre-work

(I) All information on barricade signs must be filled out completely

(I) Signs and chain must be obtained from the job site contact or Northeast Data supervisor if applicable

(I) Avoid attaching any customer equipment to barrels or stanchions.

(I) The two types of barrier systems that will be used are:

(G) Red barricades must have a red sign indicating Northeast Data's name and phone number and a roster of persons authorized to enter the area located at the single-entry point.

(O) Crossing or moving a red barricaded area without owner authorization is strictly prohibited

(G) Red barricades must be promptly removed by the owner or designee when the hazard has ended

(G) Use only red plastic chain with all red barricade systems

(G) Yellow barricades must have a yellow sign indicating Northeast Data's name and phone number

(G) PPE is required for safe entry and must be clearly indicated on the posted yellow sign

(G) Use only yellow chain with all yellow barricade systems

(I) A red danger area may exist inside a yellow barricade area if a hazard is identified.

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Respiratory Hazards

(G) Avoid all areas when Machine Blow Downs are in progress. If entering, you will need protection

(G) Avoid areas where AGM is present and could become airborne. Never broom clean, use CVC System.

(S) Silica Dust is not just dust, avoid creating by wet cutting only. If not, you must wear proper respiratory gear to protect from inhalation. Wear protective suits to avoid contamination of clothing.

(G) Never clean your clothing off with compressed air. Use Hepa Vacuum to control airborne dust.

(S) Whenever using Paints, Solvents, Adhesives or other products which produce Flammable, Toxic, or irritating fumes steps MUST be taken to prevent migration into other areas via ventilation systems.

(S) Hexavalent Chromium (CrVI) compounds, often called hexavalent chromium, exists in several forms. Industrial uses of hexavalent chromium compounds include chromate pigments in dyes (concrete coloring pigments), paints, inks, and plastics; chromates added as anticorrosive agents to paints, primers, and other surface coatings.

Hexavalent chromium can also be formed when performing "hot work" such as welding on stainless steel, welding with rods that have a high chrome content (15% - 30%) or melting chromium metal. In these situations, the chromium is not originally hexavalent, but the high temperatures involved in the process results in oxidation that converts the chromium to a hexavalent state.

There are several ways to reduce exposure to hexavalent chromium. Recommended controls vary from operation to operation. The preferred approach is to use engineering controls such as ventilation or equipment and process modification. If these controls are not sufficient, other controls may be implemented, including the use of respirators, eye protection, showering, and changing into street clothes before leaving the work site.

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Lifting

(G) All Northeast Data employees shall lift with their legs and not their back.

(I) Employees shall not twist while lifting at any time and will utilize employee rotation techniques when working in cramped, awkward spaces.

(S) Use only approved and currently inspected rigging and hoisting apparatuses.

(S) Only qualified Northeast Data employees shall use lifting devices.

(I) Northeast Data employees will not lift objects weighting over 60 pounds unless lifting with another employee to ensure safe lifting.

(I) When handling an object that is awkward and assistance is needed, always:

SAFE LIFTING

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Site Specific Requirements

All Procter and Gamble Facilities

Safety Orientation

Procter and Gamble – Mehoopany, PA

Mandatory Weekly Safety Meetings **Installation Teams**

Safety and Contractor Coordination Meetings

Behavior Observation Participation

Site Intervention and Action Plans

Safety Task Assessments

(I) The purpose is to outline the Major Steps f the work. It will help to identify required permits, hazards, either known or potential, mitigation steps and any PPE necessary for safe execution. It also identifies Safety Systems, prevention & protection measures selected and location of some essential emergency systems that may be needed. STA forms are available from the site orientation classroom, construction manager, and all field safety boards. All STA forms must be returned to Site Safety when work is completed.

(G) Foreman and Leadership are responsible to assure the STA form has been completed daily by all contractor and subcontractor employees prior to starting any work

(G) The STA checklist will be reviewed as a team with all employees working on that job with the foreman leading the discussion and assuring identified items are understood. All employees and supervisor will sign off acknowledging their understanding of the STA.

(G) The STA will be posted daily at the work site,

xField Person Leadership Training (STAR) **Installation Manager and Foreman**

Mandatory1 hour monthly sessions to assist contractors with development of strong field leadership skills, through knowledge of site standards, safe practices, and systems. Each month 4-5 safety topics will be offered that are repeated each Thursday to assure that all have the opportunity to attend one monthly session. Handouts are provided.

Staffing Requirements

Trigger

10-25 Employees

>25 Employees

> 50 Employees

>100 Employees

Normal Work Conditions

Site Construction

Safety Department

50% of a Qualified Safety Manager on Site

Full Time Qualified Safety Manager on Site

One additional full time assistant safety person for each additional 50 employees

Contractor Rated “At Risk”

50% of a Qualified Safety Manager on Site

Full Time Qualified Safety Manager on Site

Full Time Qualified Safety Manager on Site

One additional full time assistant safety person for each additional 50 employees

“High” Critical Work

50% of a Qualified Safety Manager on Site

Full Time Qualified Safety Manager on Site

Full Time Qualified Safety Manager on Site

One additional full time assistant safety person for each additional 50 employees

“High” Risk Rated Work

50% of a Qualified Safety Manager on Site

Full Time Qualified Safety Manager on Site

Full Time Qualified Safety Manager on Site

One additional full time assistant safety person for each additional 50 employees

Construction Experience Level “Low”

50% of a Qualified Safety Manager on Site

Full Time Qualified Safety Manager on Site

Full Time Qualified Safety Manager on Site

One additional full time assistant safety person for each additional 50 employees

Note: < 10 Employees – Site Construction Safety Dept. responsible for safety Assisted by a designated company safety representative.

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Safety Responsibility

(G) All Northeast Data employees shall correct / report all unsafe acts and conditions.

(G) Immediately reporting and caring for any injury you incur or treat

(O) All Northeast Data employees shall not report to work under the influence of alcohol, drugs or medications.

(G) All Northeast Data employees shall ask questions when he/she doesn't understand the proper procedures / etc.

(S) When cutting metal Northeast Data employees will use pre-designated areas so as not to cause a fire hazard.

(G) Employees will, at all times, be aware of their working environment and report all unsafe practices to their Foreman / Manager.

(G) Seatbelts must be worn at all times by all passengers, when traveling in any Northeast Data owned vehicle.

Statement of Safety Policies

To assure safe and healthful working conditions for working men and women; by authorizing enforcement of the standards Northeast Data makes every provision under Safety a must and strictly follows all OSHA and customer required rules and regulations.

The safety and health of every employee at Northeast Data is of the utmost importance. All work related injuries and illnesses must be prevented. In order to insure a safe work environment for our workers and our associates, the following policies have been adopted:

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Safety Station Policy

Purpose

To ensure the safety and well-being of employees by providing essential safety information and equipment in company vehicles.

Policy

  1. Safety Station Requirements

  2. Location and Accessibility

  3. Maintenance and Inspection

  4. Usage Guidelines

  5. Training

  6. Compliance

Effective Date

Review and Amendments

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Hazardous Communication Policy

This policy complies with OSHA’s Hazard Communication Standard (HCS) 1910.1200. Its purpose is to ensure that the hazards of all chemicals produced or imported are evaluated, and that information concerning these hazards is communicated to employees.

Labeling System

Right to Know Station

Hazard Communication Training

Known Chemicals Used on Field

Method of Information

Hazardous Exposure

Off-Site Employees

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Hydrogen Sulfide Policy

Purpose

The purpose of this policy is to protect workers from harmful exposure.

Northeast Data does not utilize Hydrogen Sulfide in any of our work tasks. However, an employee may come in a hazardous situation at customer sites where this gas could be present.

Requirements

Employees that may have a potential of working at customer site where Hydrogen Sulfide is present will be required:

Air Testing and Alarms

All air testing for hydrogen sulfide will be done only by qualified personnel at the customer site. Our customer will monitor the H2S using the more stringent operating exposure limit (OEL) and an alarm will sound if the exposure limit exceed 10 PPM or 20 PPM . To reduce exposure, the customer will use SCBA equipment when air concentrations go above 10 PPM.

Definition of Hydrogen Sulfide

H2S is a colorless, flammable, extremely hazardous gas with a rotten egg smell.

H2S Gas is found in oil and natural gas deposits, and some mineral rock. H2S gas may also form when organic materials such as manure, or vegetable matter breaks down without oxygen. (Example: Break down of sewage in a septic tank)

In Event of a Hazard

If an unexpected hydrogen sulfide (H2S) release is evident, the air will be tested from outside before employees are allowed re-entry.

Continuous testing will be completed during work operations.

Only permitted entry will be allowed if the customer requires.

If you hear the Alarm

Immediately put your appropriate personal protection equipment on. If you are not already wearing your gas mask but have one available and nearby, put it on. Put your straps down tight and breathe as you were trained. After yours is on, help anyone who is struggling. Your mask will help keep you safe while you clear the area. Requirements for having the mask vary from location to location depending on the environment. Evacuate the area following the customer site training and evacuation routes and report to your manager / site foremen

Evacuation Process

Follow customer evacuation training and routes.

Prolonged Exposure

Prolonged exposure has been reported to cause low blood pressure, headache, nausea, loss of appetite, weight loss, ataxia, eye-membrane inflammation, and chronic cough. Neurologic symptoms, including psychological disorders, have been associated with chronic exposure.

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

Medical Emergencies Policy

This policy is in accordance with OSHA’s Medical Emergencies regulation CPL 2-2.53. The purpose of this policy is to provide employees with information pertinent to Medical Emergencies that they may come in contact with while working on the field and in the office. This policy defines the responsibilities for handing different forms of medical emergencies.

For the purpose of this policy, the following definitions shall apply:

Minor Injury - Injury, which requires 1st Aid treatment, such as small lacerations, and abrasions (cuts and scrapes).

Serious Injury - An injury, which could require Doctor's care, surgery, or hospitalization, such as: unconsciousness, amputation, back injury, or severe lacerations.

Minor Injury:

Serious Injury:

Activate the Emergency Response System by dialing 911. If you are not near a phone, pull the nearest building fire alarm box and when the first person responds, have them dial 911.

Family Notification:

Special Procedure for "Unusual Behavior" Problems:

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Blood Borne Pathogen's Policy

This policy is in accordance with OSHA’s Blood Borne Pathogens regulation 1900.1030. The purpose of this policy is to provide employees with potential for blood borne pathogens exposure with the means to avoid exposure to potentially infectious materials.

For the purpose of this policy, the following definitions shall apply:

Safe Practices

All Northeast Data employees will utilize Universal Precautions in all situations where there may be potential exposure to blood and/or body fluids. All Northeast Data employees shall consider all body fluids to be potentially infectious materials.

When being presented with an emergency that would involve you in a potential infectious situation, Northeast Data requires all employees to first examine the situation and proceed to place appropriate PPE on prior to addressing the situation.

Exposure Control Plan

Northeast Data is committed to providing a safe and healthy work environment for our entire staff. In pursuit of this goal, the following exposure control plan (ECP) is provided to eliminate or minimize occupational exposure to bloodborne pathogens in accordance with OSHA standard 29 CFR 1910.1030, “Occupational Exposure to Bloodborne Pathogens.”

The ECP is a key document to assist our organization in implementing and ensuring compliance with the standard, thereby protecting our employees. This ECP includes:

Implementation methods for these elements of the standard are discussed in the subsequent pages of this ECP.

Employees covered by the bloodborne pathogens standard receive an explanation of the ECP during their initial training session. It will also be reviewed in their annual refresher training. All employees can review this plan at any time during their work shifts by contacting the operations department or going onto the Employee Portal and reviewing the electronic handbook. The operations department is responsible for reviewing and updating the ECP annually or more frequently if necessary, to reflect any new or modified tasks and procedures that affect occupational exposure and to reflect new or revised employee positions with occupational exposure.

Program Administration

The operations department is responsible for implementation of the ECP. The operations department will maintain, review, and update the ECP at least annually, and whenever necessary to include new or modified tasks and procedure. Contact Phone Number 1-866-435-3816.

Those employees who are determined to have occupational exposure to blood or other potentially infectious materials (OPIM) must comply with the procedures and work practices outlined in this ECP.

The operations department will provide and maintain all necessary personal protective equipment (PPE), engineering controls (e.g., sharps containers), labels, and red bags as required by the standard. The operations department will ensure that adequate supplies of the aforementioned equipment are available in the appropriate sizes. Contact 1-866-435-3816.

The operations department will be responsible for ensuring that all medical actions required by the standard are performed and that appropriate employee health and OSHA records are maintained. Contact 1-866-435-3816.

The operations department will be responsible for training, documentation of training, and making the written ECP available to employees, OSHA, and NIOSH representatives. Contact 1- 866-435-3816.

Employee Exposure Determination

Potential exposure may be encountered in the installation department at certain customer sites during installation or demolition work.

Note: Part-time, temporary, contract and per diem employees are covered by the bloodborne pathogens standard. The ECP should describe how the standard will be met for these employees.

Methods of Implementation and Control

UNIVERSAL PRECAUTIONS

All employees will utilize universal precautions.

Engineering Controls and Work Practices

Engineering controls and work practice controls will be used to prevent or minimize exposure to bloodborne pathogens.

This facility identifies the need for changes in engineering controls and work practices through OSHA records, employee interviews, etc.

We evaluate new procedures and new products regularly by reviewing literature, supplier info, products used. The operations department is responsible for ensuring that these recommendations are implemented.

Personal Protective Equipment (PPE)

PPE is provided to our employees at no cost to them. Training in the use of the appropriate PPE for specific tasks or procedures is provided by the operations department.

The types of PPE available to employees are

PPE is located at each site at the team lead office as well as in the office in the kitchen area and on Installation Lifts.

Additional PPE may be obtained through the operations department. Employees can call 1-866-435-318 to acquire additional PPE.

Precautions

All employees using PPE must observe the following precautions:

Housekeeping

Northeast Data employee’s who may come in contact with potentially infectious materials must wear disposable latex gloves in all exposure situations involving cuts, open wounds, any bleeding, where the injured may require direct assistance or first aid. Any Northeast Data employee whom shall give CPR to the injured will continue to wear safety glasses with side shields during the potential exposure incident.

Any Northeast Data employee not qualified to render first aid shall find someone who is qualified to render Basic first aid to assist in the situation.

While working in the Northeast Data Office, place all contaminated first aid materials (paper towels, gauze pads, bandages, used gloves, etc.) in specially marked “bio-hazard” red bags contained in the first aid Northeast Data emergency kits. Return the sealed red bag to the Northeast Data Operation Manager for appropriate disposal.

All needed personal protective equipment (red bags, disposal latex gloves, CPR mouthpieces, rubber gloves for clean-up) are to be maintained in all Northeast Data Emergency kits and are to be replaced by the Northeast Data Operation Manager upon notification from the Northeast Data Foreman.

After any incident, the following clean-up procedures must be followed:

If any Northeast Data employee is involved in an exposure incident, the following procedure must be followed:

Regulated waste is placed in containers which are closeable. Contaminated hazards should be bagged and properly sealed in a red Bio-Hazard bag and discarded with the Health Services Department onsite.

Any treatment area, equipment or tools must be properly cleaned and disinfected before work can continue.

Employees are to ensure that contaminated materials or pathogens did not come in contact with hands, skin, eyes or mouth. Hands, face, arms, and safety glasses are to be washed thoroughly with soap and running water or at a minimum they are to use antiseptic hand cleansers or towelettes to remove any hazards.

Exposure / Hepatitis B Vaccine

Employees which are exposed will be provided information on medical attention that the company will provide to them as a result of their exposure. In the event where exposure or potentially infectious material occurs, the Hepatitis B Vaccine will be provided by Northeast Data. Any / All exposed employees will be provided the Hepatitis B Vaccine at no cost to the employee. Any and all exposure to bloodborne pathogens will be kept on record and remain accessible for the duration of employment of personnel plus 30-years.

All employee records will be kept confidential at will not be disclosed or reported to any person without the written consent of the employee.

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Electrical Awareness

Purpose

Electricity is a serious workplace hazard, capable of causing both employee injury (shocks, electrocution, fires and explosions) as well as serious property damage. By providing maintenance personnel with proper training in safe electrical work practices, Northeast Data hopes to reduce the risk of such incidents.

Responsibilities

Northeast Data’s management is responsible for providing employee safety training, conducting electrical safety inspections, correcting all electrical safety hazards, and ensuring that all new electrical equipment and components comply with codes and regulations.

Employees are responsible for the immediate reporting of electrical safety hazards, for not working on electrical equipment without proper training and authorization, and for inspecting equipment prior to using it.

Qualified High Voltage Workers must have all necessary Licensure / Training / Certifications necessary to complete their work, based on the type of work being performed.

Qualified Low Voltage workers will be sent to BICSI and Manufacturer specific training for low voltage installation training / certification.

Definitions

Qualified Low Voltage workers: An employee who is trained and authorized to perform work on electrical equipment and components.

Unqualified worker: An employee who has not been trained or authorized to perform electrical work.\

Hazard Control

The following control methods will be used to prevent occurrence of electricity-related incidents:

Engineering Controls

Administrative Controls

Work Practice Controls

Electrical Equipment Inspections

Inspect all low voltage electrical equipment for hazards that could cause employee injury or death. Consider the following factors when determining the safety of the equipment:

Personal Protective Equipment

Northeast Data will provide personal protective equipment for use by employees working in areas where they could be exposed to electrical hazards.

Employees are required to observe the following procedures for PPE use:

Employee Training

Qualified Employees

Training for those employees qualified to perform electrical work will consist of:

Unqualified Employees

Employees not qualified or authorized to perform work on High/Low voltage electrical equipment and components will be trained in general electrical safety precautions for the purpose of hazard awareness.

The following electrical safety rules also apply to unqualified employees:

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Driving Safety

Company vehicles will only be used for Northeast Data business and will be assigned to key personnel. At no time is a company vehicle to be used for personal reasons or taken home by an employee without the direct consent of the owner of Northeast Data. Key personnel that sign off on company vehicles will be held fully responsible for all vehicle usage / registration / inspections / maintenance / cleanliness / stock / tools and equipment / vehicle logs / parking violations / traffic violations / accidents. Anyone found in violation will be subject to the Progressive Discipline Policy.

Aim Of This Policy

To reduce vehicle incident and at-fault work related road collision costs and injuries over three years by promoting a safe driving culture within the organization.

Objectives Of The Policy

  1. To make drivers aware of the main risks they face or create when driving for work
  2. To make sure that employees who drive vehicles in the course of their work demonstrate safe, efficient driving skills and other good road safety habits at all times.
  3. To maintain all company vehicles in a safe, clean and roadworthy condition to ensure the maximum safety of the drivers, occupants and other road users, and reduce the impacts of company vehicles on the environment – this also applies to personal vehicles used for work purposes.

Code Of Conduct

The code of conduct for Northeast Data states: “While operating a motor vehicle for work purposes, employees must comply with traffic legislation, be conscious of road safety and demonstrate safe driving and other good road safety habits.”

The following actions in company vehicles will be viewed as serious breaches of conduct

Alcohol Consumption / Transportation / DUI-DWI

Northeast Data is a ZERO Tolerance company. Northeast Data’s company policy, maintains that no alcohol will be transported or consumed when riding in any company owned vehicle. Any employee who has been convicted of DUI/DWI is found under the influence while driving a company owned vehicle will be subject to immediate termination from employment. Northeast Data reserves the right to disregard any and all warning procedures used in the employee termination process in all DUI/DWI violations. Any Employee convicted of DUI/DWI while operating a company owned vehicle is required to notify your manager immediately after such conviction. “Conviction” means a finding of guilt or acceptance of a guilty plea, including a plea of nolo contendere, or imposition of a sentence, or both, by a judicial body.

Responsibilities As An Employee

Drivers of company vehicles

Every driver of a company vehicle must:

Employees Driving Company Vehicles

Northeast Data employees need to have an unexpired copy of their Driver’s license in the office at all times. Regardless if the employee is driving company provided vehicles (rented or owned). The Northeast Data office will request for a copy to be provided to the office if an expired license is on record.

Suspended Drivers Licenses

Any Northeast Data employee who has a suspended driver’s license will not at any time drive any company vehicle. Any employee caught driving the company vehicles without a current driver’s license will be terminated from employment immediately.

Any Northeast Data employee who had a suspended driver’s license that has recently become active, must provide proof that their license has been moved to active status from the state of issue. This letter must be sent to the Northeast Data office. Northeast Data will then need approval of the driver’s status from our insurance carrier before the employee can be allowed to drive any company vehicle. Notification will be sent to the employee at the time of the decision.

Traffic Violations

You are expected to notify the office immediately if the validity of your driver’s license is changed.

Any/all Citation Attached Traffic Violations must be reported immediately to the violator’s manager. All Managers must report all such violations to the owner immediately. Any employee failing to do so will be subject to immediate termination. No warnings will be given, verbal or written. Citation Attached Traffic Violations will be considered a Safety Violation. The employee will be held 100% responsible for any and all costs associated with the citation. The following will be mandatory for all Citation Attached Traffic Violations: (No Verbal Warnings will be given.) Northeast Data reserves the right to disregard any warning procedures if the Citation has endangered the wellbeing of fellow employees / customers / or citizens

  1. 1st Offense - Written Warning # 1 - 1-month suspension of driving privileges.
  2. 2nd Offense – Immediate termination of employment.

Employee's must:

In addition, it is required that all drivers:

Vehicle Maintenance

It is the sole responsibility of the Individual who has been issued a Company Vehicle to oversee its proper maintenance and repair. This maintenance will be done at the Company’s Expense but off the clock outside regular working hours (except for extended repair work.)

Oil changes are to be done on 3000-mile intervals.

Company vehicle appearance is required to be kept up at all times. Trucks should be washed at least once per week. The interior of each truck must be kept free of garbage and debris at all times. Each truck should be waxed at least twice per year.

Company vehicles will be kept clean and organized at all times. Any employee who uses the company vehicle is responsible for cleaning it at the end of each day.

Company vehicles must always be returned to office with at least a three-quarter tank of fuel.

Ensuring all vehicles are well maintained and that the equipment promotes driver, operator and passenger safety by:

Materials / Equipment Inventory

Material inventory levels must be maintained at all times. It is the responsibility of the Individual issued the vehicle to maintain these levels. Tools and equipment signed out to the truck is also the responsibility of the individual who was issued the truck and equipment. Any tools damaged (by abuse) or lost will be the responsibility of the individual who was issued this Company owned equipment. All equipment “Loaned” to another truck will be the responsibility of the individual who loaned the equipment or materials. When tools and ladders are removed from the vehicle to a site, they should be returned to the vehicle at the end of each workday. In the event that a truck is called out on emergency service, it should not have to return to a site to pick up ladders or tools. All materials must be secured for transport.

Smoking

It is the policy of Northeast Data to provide a safe working environment for employees. It is recognized that smoke from cigarettes, pipes and/or cigars is hazardous to health. Therefore, it is the goal of Northeast Data to offer a smoke free environment to the greatest extent possible. To achieve this goal, Northeast Data will limit smoking as set forth in this policy. This company policy maintains that there will be absolutely no smoking in any company vehicles.

E-Cigarettes

"E-Cigarettes" will be treated the same as tobacco cigarettes. Northeast Data restricts smoking to only designated areas. Employee with E-Cigarettes may use this product only in designated smoking areas.

It is the responsibility of all managers, and employees to enforce the company’s Non-Smoking Policy. Anyone smoking in a nonsmoking area should be directed to a smoking-permitted area. Disputes over the interpretation of the policy, or complaints about individuals violating the policy and/or guidelines, should be brought to the attention of a manager using the normal channels for making complaints. Managers should follow existing policies and procedures to deal with complaints received or infractions of this policy.

Drivers Utilizing Their Own Car For Work Purposes

If an employee is driving their own vehicle for work, the same policies apply.

In addition:

the employee must seek the employer’s agreement before using their vehicle for work

Responsibilities As An Employer

The employer will take all steps to ensure company vehicles are as safe as possible and will not require employees to drive under conditions that are unsafe or likely to create an unsafe environment, physical distress or fatigue.

The employer will do this by:

Vehicle Selection And Procurement

Giving priority to safety features when selecting new vehicles, including:

Data On Collisions And Incidents

Collecting and collating statistics on incidents, collisions and their causes, including:

Driver Training

Identifying driver training needs and arranging appropriate training or refresher training, including providing:

Safe Driver Behavior

Encouraging safe driving behavior by:

Fuel Efficiency

Encouraging better fuel efficiency by:

Accident Procedure

What to do in the event of an incident in a company vehicle

Immediately stop your vehicle at the scene or as close to it as possible, making sure you are not obstructing traffic.

  1. Apply the handbrake and switch off the engine.
  2. Switch on the vehicle’s hazard warning lights.
  3. Ensure your own safety first, put on your hi-vis vest before exiting the vehicle.
  4. Ensure any passengers put their hi-vis vest on before getting out.
  5. If the vehicle is on fire – get out immediately if it is safe to do so.
  6. Help any injured people and call for assistance if needed.
  7. Try to get the following information:

  8. Give your name and address and company details.

If you damage another vehicle that is unattended, leave a note on the vehicle with your contact details.

Contact the police:

Only move the vehicle if:

In the event an accident occurs while traveling in a Company Vehicle / Rental Vehicle / or Personal Vehicle for business purposes the following must be performed:

DO NOT ADMIT GUILT EVEN IF YOU BELIEVE IT IS YOUR FAULT!

Citation Attached Accidents will follow the same disciplinary actions as Traffic Violations. Any Northeast Data employee who does not follow the above guidelines for Accidents will be subject to the Progressive Discipline Policy.

The individual, who signed off on the company issued vehicle, must report accidents that occur within 24 hours of the accident. An **Estimate of cost to repair damages must be attached to a company accident report. A local auto body repair shop, approved by the insurance company, will produce this estimate. All reports and estimate collection is the responsibility of the Individual who was issued the truck unless that individual became incapacitated by the accident. In this situation the responsibility is transferred to the employee’s manager.

Important / Undrivable Vehicles

If the vehicle cannot be driven arrangements must be made for its removal. All valuables should be secured

Follow-Up With Manager

If there is an injury or major damage, report the crash to your manager as soon as you can

Breakdowns

In the event of a breakdown do not try to repair the vehicle.

Policy Measuring

The success of this policy will be measured by the increase or decrease in:

Policy Review

This policy will be reviewed after its first year and every year thereafter.

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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360 Circle of Safety

Effective Date of Policy – 09/23/2024

A 360° Walk Around Circle for Safety should always be performed just prior to moving the vehicle. It only takes 30-seconds, but is worth your time in order to prevent a tragedy.

Purpose

The 360 Circle of Safety is a procedure that involves walking all the way around a vehicle before departing to ensure the area is safe. It helps drivers check for hazards such as other vehicles, pedestrians, or obstacles.

Procedure

Inspecing the area

Make sure you perform a visual check of the area you are about to back into. If you are not sure if it’s safe get out and check for hazards

Get the big picture.

Get Out And Look and search for hazards all around your vehicle prior to moving the vehicle.

Be aware of your clearances

Make sure you are aware of any obstructions behind, to the sides, above and below your vehicle. This is especially important if you drive a larger vehicle such as a van or truck.

Be Alert - Avoid Distraction

Before backing – turn off your radio, turn down your heater / ac and lower your window. Turn your company cell phone to silent and do not text or be on an active call as this can distract you.

Use your Mirrors Continuously

Check all mirrors before moving and re-check them continuously as you back or park your vehicle.

Keep your eyes moving.

Don’t stare in any one direction while driving; use your peripheral vision and continuously scan the entire area.

Maneuver Slowly

The slower you maneuver your vehicle the more time you have to react to hazards.

Back from the Drivers Side

You have less visibility when you back from the passenger side.

Use a Guide:

There’s nothing like an extra set of eyes to assist you. Pick someone reliable to be sure to agree on hand signals before backing. Utilization of a spotter in congested areas is recommended.

Back into your parking place upon arrival

It is safer than backing into traffic when you depart

Avoid Backing

Whenever possible position your vehicle so you can avoid a backing maneuver. Always have an identified escape plan for you and your vehicle.

Make sure they see you.

Help other drivers be aware of your presence by using the tools at your disposal, including the vehicle’s turn signals, brake lights, headlights and horn. All Company Vehicles have a back up alarm and this alarm will go off every time the employee is in reverse.

Parking methods in preferred order:

Safety is the utmost importance at Northeast Data. All employees are required to complete a 360 Circle prior to moving a company vehicle. Violations will be ground for immediate termination. Northeast Data has zero tolerance for an employee to have a lack of safety that will result in a Life Critical incident and can lead up to the company progressive discipline policy up to employment termination.

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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First Aid Policy

It is the policy of Northeast Data, Inc. to have a safe work environment for employees, visitors, and those that are conducting business in our office. Emphasis is placed on the prevention of accidents and injuries, when accidents do occur. Prompt and knowledgeable treatment of injured employees will, in many cases, prevent minor injuries from becoming major ones. Northeast Data will select and train key personnel in CPR, AED, BASIC First Aid and Preventing and Handling Blood-Borne Pathogens Exposure. These trained people will respond to medical problems or medical emergencies.

All Northeast Data Personnel shall minimally complete and be certified to OSHA 10 Hour Course and all Installation Team Upper Management / Supervisors / Foremen / Crew Leaders shall complete and be certified to OSHA 30 Hour Course.

The Following First Aid Rules Should be Established:

Objectives

Personnel will be trained in CPR, Basic First Aid, AED use, and Blood-Borne Pathogens Exposure.

First Aid Class Outlines

ASHI - Basic First Aid Course - (~ 3 Hours every 2 years)

https://emergencycare.hsi.com/first-aid-training - full class curriculum.

ASHI - CPR and AED Course - (~ 3 Hours every 2 years) –

https://emergencycare.hsi.com/cpr-aed-certification - full class curriculum.

ASHI - Bloodborne Pathogens Course - (~ 1 Hour every 1 year) –

https://emergencycare.hsi.com/blood-borne-pathogens - full class curriculum

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Work Place Emergency Action Policy

Northeast Data's Workplace Emergency Action Policy

This policy is in accordance with OSHA's Emergency Action Regulation 1910.038. The purpose of this policy is to ensure employee safety from fire and other emergencies they may come in contact with while working on the job.

This Emergency Action Plan is to be followed at all times. Northeast Data Foremen are to ensure the policy is followed correctly and all employees are accounted for at all times.

Types of Emergency situations:

  1. Chemical Spill - A release of significant amounts of gaseous materials to the air.
  2. Other Emergencies - A fire, flood, weather disaster, or any incident, which may require an employee to clear their work area unexpectedly.

Requirements - Chemical Emergency Response.

Most chemicals represent no threat beyond the area immediate to their use.

Responsibilities

This plan will be maintained and executed by the Northeast Data Foreman

Other emergencies

  1. Detection / Notification - Any Northeast Data employee who detects a problem will immediately notify personnel in the area where the problem exists.
  2. Evacuation - When presented with an evacuation, all Northeast Data employees shall exit the building using the closest fire exit.

Fire Fighting Policy

This policy is in accordance with OSHA's Fire protection regulations 1910.155, 1910.156, and 1910.157. The purpose of this policy is to ensure that employees are aware of the system used by Northeast Data for communicating a fire and procedures to combat fires.

Fire Alarms:

All Northeast Data employee's will be expected to identify fire alarm safety. Below is the actions that shall take place when a fire alarm is activated at the plant.

  1. The fire alarm will be activated when the odor or visible signs of smoke, sparks, smoldering dust or flames are present
  2. Alarms may be sounded in the following manner:
  3. If the alarm system fails to function, Northeast Data employees are required to shout "Fire" to those in hearing distance and call 911 immediately.
  4. When you detect or suspect a fire, you will activate the alarm before doing anything else. Unless the fire is so small you can extinguish it quickly and safely, the delay caused by attempting to fight it yourself, before sounding the alarm may permit the fire to get out of control.

Fire Equipment / Procedure

  1. Fire doors must always be in operating condition, in good repair, and not blocked by stored materials or wedged or tied open. A fusible link must be used if necessary to keep a fire door open.
  2. Windows, doors, and smoke vents near sprinkler lines must be closed and in good repair during freezing weather.
  3. Sprinkler piping must never be used to support electrical wiring, other pipe or pipes, and an electrical ground.
  4. Use of operation of the following must not be impaired in any way.
  5. The operator of any Northeast Data Vehicle must inspect the Fire extinguisher located on / in the vehicle. If the seal is broke, or if the inspection sticker is 12 months old, replace the extinguisher. It is the Northeast Data foreman's responsibility to notify the office when extinguishers are to be replaced on the Man lifts.
  6. Return unused extinguishers to their proper location.
  7. Do not use extinguishers / fire hoses for any purpose other than fire fighting. For wash down, use proper hoses or other appropriate means.

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Ergonomics Program

OSHA Ergonomics Program Standards - Reporting

Northeast Data employees will need to follow all of OSHA's Ergonomic Program Standards. The purpose of these standards is to reduce the number of musculoskeletal disorders (MSDs) caused by exposure to risk factors in the workplace.

Musculoskeletal disorders are defined as a disorder of the muscles, nerves, tendons, ligaments, joints, cartilage, blood vessels, or spinal discs. The MSDs disorders that OSHA requires all employee's to report on apply only to the following areas of the body that have been associated with exposure to risk factors: neck, shoulder, elbow, forearm, wrist, hand, abdomen, (hernia only), back, knee, ankle, and foot. MSDs may include muscle strains and tears, ligament sprains, joint and tendon inflammation, pinched nerves, and spinal disc degeneration. MSDs include such medical conditions as: low back pain, tension neck syndrome, carpal tunnel syndrome, rotator cuff syndrome, DeQuervain's syndrome, trigger finger, tarsal tunnel syndrome, sciatica, epicondylitis, tendonitis, Raynaud's phenomenon, hand-arm vibration syndrome (HAVS), carpet layer's knee, and herniated spinal disc. Injuries arising from slips, trips, falls, motor vehicle accidents, or similar accidents are not considered MSDs for the purposes of this standard.

All MSD hazards must be reported to the office within 24 hours of the incident. A MSD hazard means the presence of risk factors in the job that occur at a magnitude, duration, or frequency that is reasonably likely to cause MSDs that result in work restrictions or medical treatment beyond first aid.

Any MSD incident, that is work-related, and requires medical treatment beyond first aid, or MSD signs or symptoms that last for 7 or more consecutive days need to be reported to the office within 24 hours of the incident. The importance of reporting the incident immediately is so the proper paperwork can be processed and medical treatment can begin within the allotment of time provided by the MSDs standard.

Some MSD signs are objective physical findings that an employee may be developing an MSD. Examples of MSD signs are:

MSD symptoms are physical indications that an employee may be developing a MSD. For purposes of this standard, MSD symptoms do not include discomfort. Examples of MSD symptoms are:

Due to the above, the MSD standard requires all employee's to wear Personal Protective Equipment (PPE). This equipment is to be worn by all Northeast Data employee's to provide a protective barrier between the employee and any MSD hazards to prevent any risk factors that may occur. The Personal Protective Equipment is to be followed as per Northeast Data's and OSHA's required guidelines under the following sections of this policy and procedures handbook. These sections include General Safe Practices / Personal Manlift Safety and Ladder Safety.

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Violence in the Workplace

Workplace Violence

Northeast Data is committed to providing a safe, healthful workplace that is free from violence or threats of violence. For purposes of this policy, workplace violence is any violent or potentially violent behavior that arises from or occurs in the workplace that affects employees / mangers / etc.

Individuals who engage in violent or prohibited behavior (see below) may be removed from the premises, and may be subject to dismissal or other disciplinary action, arrest and/or criminal prosecution. This policy applies to all work locations including offices, work sites, vehicles, and field locations.

Northeast Data takes reports of threatening or violent workplace incidents seriously. Employees, supervisors and managers are expected to follow the Workplace Violence Report / Response Procedure to report actual or alleged incidents of violence in the workplace.

Prohibited Behavior

Northeast Data does not tolerate behavior, whether direct or through the use of Northeast Data's facilities, property or resources that:

Violent or threatening behavior can include physical acts, oral or written statements, harassing telephone calls, gestures and expressions or behaviors such as stalking.

Northeast Data's Workplace Violence Report/Response Procedure

Direct Threats of Harm to Persons or Property

Direct threats of harm to persons or property require immediate response as follows:

Call 911

Reporting Requirements

All employees of Northeast Data must cooperate to maintain a safe work environment. Individuals should report to their supervisor any incidents of violent, threatening, harassing, or intimidating behavior in the workplace, whether or not those involved are Northeast Data employees.

Employees who report incidents of workplace violence may request to do so confidentially. Such requests will be honored to the degree legally allowable. Employees who are concerned about confidentiality should discuss their concerns with their unit's General Manager.

Each unit is responsible for reporting incidents of violent or threatening behavior involving all Northeast Data employees and appointees as follows:

  1. Supervisors and managers who receive reports of violent or threatening behavior must notify the General Manager; and
  2. Telephone the unit's Operations Manager. Do not leave a voice mail message.

If a report must be made after normal business hours, use the procedure for reporting direct threats of harm.

The General Manager will involve the appropriate resources and assist supervisors and managers in their response to allegations of violent or threatening conduct. If allegations of violent behavior are made against employees, the General Manager will notify the Sole Proprietor immediately.

Supervisors must also report alleged violent workplace behavior on an "Incident/Accident/Quality Improvement Report" form. For details on incident reporting, including where to obtain and submit the proper form, see Environmental Health and Safety's "Reporting Work Related Incidents, Injuries or Illnesses" section of this handbook.

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Post-Accident Procedures for Employees and Temporary Workers

Types of Accidents

Accidents fall into two categories, serious and non-serious. Non-serious accidents do not cause lost workdays. Examples of these include paper cuts, minor scratches or abrasions, or system failures that have minor consequences, such as a low-pressure hose that ruptures and sprays cool water. Serious accidents include both those which did involve lost workdays and those which might have. This second type of serious accident is called a "near miss." Examples of near misses with serious injury potential include:

All serious accidents, those involving lost workdays or near misses, should be investigated with the same thoroughness.

Immediate Actions

Immediately following an accident, the closest available manager or employee to the injured worker must initiate site emergency notification protocols.

All ongoing work in that area must cease immediately and scene secured. Lockout tagout procedures must be followed, bloodborne pathogens procedure followed if necessary. Basic medical attention should be administered to the injured worker as applicable. See Emergency Response / First Aid Management System Policy. Northeast Data Management and Customer Site (customer representative / contact overseeing project) host must be notified of the accident immediately. If a Temporary Worker, the appropriate staffing agency representative for said temporary worker must also be notified.

The injured worker must:

Northeast Data Human Resources and Management will keep in contact with the injured worker throughout their treatment at the medical facility. During this time period the following will be recorded for OSHA reporting requirements:

Accident Investigation Procedures

The Northeast Data, Inc. representatives participating in any Accident Investigation are expected to be thorough and maintain objectivity throughout the investigation. Its purpose is to find the cause of the accident, not to assign blame for its occurrence.

During the Accident Investigation process, the following must be completed:

Reporting Injuries and Fatalities to OSHA

xThe following guidance applies to sites located in states governed by the federal OSHA program. If your site is located in a state with a state-run OSHA plan, check to see if other reporting requirements apply. (Link to more details on state-run OSHA plans.)

Northeast Data, Inc. will report to OSHA any work-related fatality within 8 hours and any work-related in-patient hospitalization, amputation, or loss of an eye within 24 hours. (Link to OSHA standard 29 CFR 1904.39.) This will be reported by one of three ways:

*If Northeast Data, Inc. is unable to get through by telephone to an individual at the nearest OSHA office, we will not leave a message. Instead, one of the other two reporting methods will be used.

When reporting injuries to OSHA, Northeast Data, Inc. Human Resources and management will prepare a Reporting Injuries and Fatalities Narrative of event prior to calling to ensure comments will be clear, accurate, and avoid speculation. Once Reporting is completed, a copy of the Reporting Injuries and Fatalities Narrative will be provided to the temporary worker staffing agency representative if applicable.

Be prepared to report to OSHA: Additional considerations:
1. Whether you are calling to report a work-related fatality, in-patient hospitalization, amputation, or loss of an eye

Inpatient hospitalization: a formal admission to the in-patient service of a hospital or clinic for care or treatment (you do not have to report an in-patient hospitalization that involves only observation or diagnostic testing).

Amputations: a part, such as a limb or appendage that has been severed, cut off, amputated (either completely or partially), fingertip amputations with or without bone loss, medical amputations resulting from irreparable damage, and amputations of body parts that have since been reattached. Amputations do not include avulsions, enucleations, degloving’s, scalping’s, severed ears, or broken or chipped teeth.

Timing: You must only report a fatality to OSHA if the fatality occurs within thirty (30)days of the work-related incident. For an in-patient hospitalization, amputation, or loss of an eye, you must only report the event to OSHA if it occurs within twenty-four (24) hours of the work-related incident. If a hospitalization from an incident occurs after the 24-hour reporting window, the incident does not need to be reported to OSHA. The incident must still be recorded on the OSHA 300 Log.

2. Your name, title, email address, and a phone number where you can be reached.

A site manager (typically HS&E leader) should report and serve as the contact person.

Specify whether you are the contact person for the site; if not, provide the details for the individual OSHA should contact for follow-up communications.

3. Name, industry, address, and phone number of employer

Include the specific site’s name and information.

4. The number of employees affected.
5. The name, date of birth, date of hire, home address, and home phone number of each affected employee.

If asked, include how long the employee has served in current role.

6. Description of initial injury or injuries and medical status if known

Be specific with this description (i.e. right or left hand, which finger, etc.) and include whether the employee was hospitalized.

7. Whether the injured worker is an employee or was working as a temporary worker.

In almost all cases, the contractor vendor is responsible to report any injuries of their employees to OSHA, even if temporary

8. Number of people that work at the affected employee’s workplace

Include breakdown by full/part time employees and employee/contractor.

9. Whether there is an employee representative or union at the workplace (if so, provide name, address, and phone number)

Only for employees who are in a Union or have other representation.

10. Date and time the incident occurred
11. Specific location at site where the incident occurred

Include name of location and full address if incident occurred at a location other than the address identified for the employer above. Also, the specific location within the site where the injury occurred such as building number, floor and room (or machine number, packing line, etc.).

12. The affected employee’s job title, a description of the work the employee performs, and the tasks that are required in performing that work

Provide a general description of the work performed and associated tasks.

13. A description of the incident, including:

14. what the employee was doing just before the injury occurred

15. what the employee was doing at time of injury

16. any tools/equipment/material the employee was using

17. the object or substance that directly caused the harm to the affected employee

If the cause of the incident is still being investigated, mention it; avoid speculation.

18. Hospital the affected employee was taken to, if applicable
19. Whether the hazard that directly caused the harm to the affected employee still exists in the workplace.

Explain to OSHA what is being done to investigate and eliminate any hazard identified and what is being done to ensure worker safety in the meantime. i.e. shutting down the process until it is verified that all equipment and safeguards are operating as designed.

20. Description of corrective actions and other steps taken to eliminate the hazard
21. Responsive only: Whether a similar incident has happened in the workplace before, or almost happened.

OSHA may ask for this information, but it typically does not make sense to volunteer it. If asked, disclose documented incidents and near misses. If knowledge is limited, state as such.

In addition to the above information, make sure to keep an internal record of the following:

1. Name of person who contacted OSHA
2. Title
3. Method of reporting (if by phone, include number called)
4. Date and time of OSHA notification (if by phone, duration of call)
5. If reporting by phone, OSHA representative spoken to and report number given by representative
6. Report electronically – Save the confirmation page received from the agency for the report. Report number is immediately provided by OSHA following electronic submission.

Example narrative for an initial OSHA report:

Hello. My name is . I am the (Job title) from Northeast Data, Inc. and I wish to report a (fatality, amputation, in-patient hospitalization, loss of an eye). The (site) is a (facility type) located at __________. There are (number) employees that work at the site.

On (date and time), an employee was (task) in (location within the facility). Provide known details including how the person was given first aid:

  1. A description of the incident, including:
  2. what the employee was doing just before the injury occurred
  3. what the employee was doing at time of injury
  4. any tools/equipment/material the employee was using

Inform OSHA of what hospital they were sent to.

The site is currently investigating all potential causes of this incident and will implement any necessary corrective actions. However, we do not believe there is a present risk of harm to our employees (or we shut down the operation to ensure there are no current risks to our employees)

The injured employee’s name is (name) and he works as a ____________ at the __________ site. He was born on (date of birth) and was hired on (hire date). His home address is (Home Address). His home phone number is (phone number).

The employee representative for _______ site is _______________. Her address is ____________ and her phone number is_________________. (ONLY IF UNION SITE)

Again, my name is and I will be your contact for further discussion. My phone number where you can reach me is . I am also available by emailing . Thank you.

Next Steps:

OSHA will evaluate the reported information and determine whether to conduct an inspection, initiate a Rapid Response Investigation (RRI), or take no action.

Note: If a Rapid Response Onsite Investigation with an OSHA representative is required during the course of their Investigation, the customer site representative will complete the necessary scheduling.

OSHA considers an inspection required for:

An inspection may occur where:

In most other cases, OSHA will initiate a RRI. Northeast Data, Inc. will receive a letter from OSHA stating that a RRI is required and Northeast Data, Inc. will conduct an investigation and report findings and corrective actions to OSHA within 5 business days.

Preparing for an inspection: See resources below.

OSHA reporting: It is Northeast Data, Inc.’s responsibility to report incidents to OSHA involving their employees.

Additional Resources:

Links to OSHA Web Sites

Emergency Response / First Aid Management System

Any Northeast Data employee not qualified to render first aid shall find someone who is qualified to render first aid to assist in the situation.

All Northeast Data employees will utilize Universal Precautions in all situations where there may be potential exposure to blood and/or body fluids. All Northeast Data employees shall consider all body fluids to be potentially infectious materials.

When being presented with an emergency that would involve you in a potential infectious situation, Northeast Data requires all employees to first examine the situation and proceed to place appropriate PPE on prior to addressing the situation.

  1. Northeast Data employees who may come in contact with potentially infectious materials must wear disposable latex gloves in all exposure situations involving cuts, open wounds, any bleeding, where the injured may require direct assistance or first aid. Any Northeast Data employee providing CPR to an injured person will continue to wear safety glasses with side shields during the potential exposure incident.
  2. Any Northeast Data employee not qualified to render first aid shall find someone who is qualified to render first aid to assist in the situation.
  3. While working in the Northeast Data Office, place all contaminated first aid materials (paper towels, gauze pads, bandages, used gloves, etc.) in specially marked “bio-hazard” red bags contained in the first aid Northeast Data emergency kits. Dispose of the sealed red bag appropriately.
  4. All needed personal protective equipment (red bags, disposal latex gloves, CPR mouthpieces, and rubber gloves for clean-up) are to be maintained in all Northeast Data Emergency kits and are to be replaced by the Human Resources Department upon notification from the Northeast Data Installation Manager.
  5. After any incident, the following clean-up procedures must be followed:
    1. After gloves are removed, hands must be washed with non-abrasive soap as soon as possible.
    2. All contaminated work area surfaces must be decontaminated as soon as feasible. Clean area with soap and water, rinse, then clean with water / household bleach (9:1) solution; soak 10 minutes, then dry area. Wear rubber gloves while cleaning.
  6. If any Northeast Data employee is involved in an exposure incident, the following procedure must be followed:
    1. The hands or surfaces invaded must be washed and cleansed with a non-abrasive soap immediately. Eyes, when exposed, must be flushed as soon as possible.
    2. The exposed employee’s manager / foreman is to be contacted immediately and notified of the incident. (Foreman will then advise the Human Resources Department of the incident).
    3. Identification of the source of the exposure must be obtained by the Northeast Data manager / foreman and documented on the Northeast Data Incident / Accident Form. When the source is unknown this must also be documented.
    4. All Northeast Data employees involved in an exposure incident must review work practices and appropriate use of personal protective equipment in an effort to limit the risk of recurrent exposure.
    5. The HS&E manager / foreman shall ensure that the incident is investigated by means of assessing the work areas and noting the hazards associated with the incident and provide all information to the attention of the Human Resources Department.
    6. The Northeast Data Installation Manager will then notify the appropriate customer personnel of the incident that occurred.

F1

Northeast Data’s Report Of Occupational Injury or Disease

***Note: If hospitalization has occurred the form must be completed in full. If this is a minor injury requiring no medical attention, please only complete page 1***

Employee Name: ______________________________________ Date of Incident: ___________________________________

Employee’s Occupation: _______________________________ Supervisor’s Name: _________________________________

Explain Occurrence: _____________________________________________________________________________________

_______________________________________________________________________________________________________

_______________________________________________________________________________________________________

What Body Part Was Affected? ____________________________________________________________________________

Did Injury or Illness Occur on Employer’s Premises? ☐Yes ☐ No

If no, please give information of where the incident happened. ________________________________________________

_______________________________________________________________________________________________________

How did the injury or illness or abnormal health condition occur? Describe the sequence of events and include any objects or substances directly responsible.

_______________________________________________________________________________________________________

_______________________________________________________________________________________________________

_______________________________________________________________________________________________________

Did incident require Medical Treatment? (if yes, proceed to following pages) ☐Yes ☐ No

I acknowledge that this report was submitted for record keeping requirements and that the incident described above required no medical treatment or loss of work time.

Employee Name: ______________________________________ Date: ________________________________________

Manager's Name: ______________________________________ Date: ________________________________________

 

 

Employee Name: ____________________________

Employee SS #: ____________________________

Date of Injury: _________________________________

Employee’s Phone #: ____________________________

 

 

Employee Address:__________________________________________________________________

                              City_____________________________ State: ___________ Zip: _____________

                              County:_____________________________________________________________

Employee:

MaleFemale                 ☐ MarriedSingle                 Number of Dependents: ________________________________

Employee’s Date of Birth: ______________________ Employee’s Occupation: ____________________________________

Employment Status:

Full Time                 ☐ Seasonal                 ☐ Part Time                 ☐ Volunteer                 ☐ Other

Employer Name:__________________________________________________________________

Address:                  ________________________________________________________________

                           City_____________________________ State: ___________ Zip: _____________

                           County:_____________________________________________________________

Employer's Phone Number: ______________________________________________________________________________

County: _______________________________________________________________________________________________

Did the employee receive full pay for the day of the injury:   ☐ Yes ☐ No

What time did the employee begin work:                                 ☐ AM ☐ PM

What time did the incident occur:                                             ☐ AM ☐ PM

Last day the employee worked: ______________________ Date Disability Began: _________________________________

Date Employer Notified: ____________________________ Date Returned from Work: _____________________________

Explain Occurrence: _____________________________________________________________________________________

_______________________________________________________________________________________________________

_______________________________________________________________________________________________________

What Body Part Was Affected? ___________________________ Side of body Effected: _____________________________

Cause of Injury? ________________________________________________________________________________________

_______________________________________________________________________________________________________

Did Injury or Illness Occur on Employer’s Premises?   ☐ Yes ☐ No

If no, please give information of where the incident happened. __________________________________________________

_______________________________________________________________________________________________________

_______________________________________________________________________________________________________

Did this incident happen out of state?   ☐ Yes ☐ No       If yes, Please provide state abbreviation _____________________

Were safe guards or safety equipment provided?   ☐ Yes ☐ No

Were safe guards or safety equipment used?   ☐ Yes ☐ No

Please list all equipment / materials / or chemicals the employee was using when the accident or Illness exposure occurred.

_______________________________________________________________________________________________________

_______________________________________________________________________________________________________

_______________________________________________________________________________________________________

How did the injury or illness or abnormal health condition occur? Describe the sequence of events and include any objects or substances directly responsible.

_______________________________________________________________________________________________________

_______________________________________________________________________________________________________

_______________________________________________________________________________________________________

If fatal, give date of death: _______________________________________________________________________________

Initial Treatment: (Please check one)

       ☐ Minor By Employee  ☐ Employee Physician  ☐ Clinic / Hospital

       ☐ Emergency Care       ☐ Panel Physician          ☐ Hospitalized more than 24 hours

Physician / Health Care Provider:

Physician's' Name:__________________________________________________________________

Address:                  ________________________________________________________________

                           City_____________________________ State: ___________ Zip: _____________

                           County:_____________________________________________________________

Hospital Name:__________________________________________________________________

Address:                  ________________________________________________________________

                           City_____________________________ State: ___________ Zip: _____________

                           County:_____________________________________________________________

Policy Period From: ______________________________ Policy Period To: ___________________________________

Policy / Self Insured Number: _____________________________________________________________________________

Witness Name: __________________________________ Witness Phone Number: _______________________________

Person who completed this form:

Name: __________________________________________

Title: ___________________________________________

Phone: __________________________________________

Date form prepared: ______________________________

The said employee has read / reviewed and agree to the Northeast Data Occupational Report.

Employee Name: ______________________________________ Date: ________________________________________

Manager's Name: ______________________________________ Date: ________________________________________

 

 

F2

Accident Investigation Report

Employee Name: _______________________________________________________________________________________

Site Location: _________________________________________________________________________________________

Date of Incident: ________________________________     Time of Incident: _____________________________________

Investigation Report Completed by: _______________________________________________________________________

Supervisor Onsite that day: _______________________________________________________________________________

_______________________________________________________________________________________________________

Description of Incident: __________________________________________________________________________________

_______________________________________________________________________________________________________

_______________________________________________________________________________________________________

_______________________________________________________________________________________________________

Description of Injury: ____________________________________________________________________________________

_______________________________________________________________________________________________________

_______________________________________________________________________________________________________

_______________________________________________________________________________________________________

Who provided basic medical Attention on site: _______________________________________________________________

_______________________________________________________________________________________________________

_______________________________________________________________________________________________________

_______________________________________________________________________________________________________

Did a Hospital or Physician provide medical care: ____________________________________________________________

_______________________________________________________________________________________________________

Investigation findings: ___________________________________________________________________________________

_______________________________________________________________________________________________________

_______________________________________________________________________________________________________

_______________________________________________________________________________________________________

Could anything have been done to prevent injury: ___________________________________________________________

_______________________________________________________________________________________________________

_______________________________________________________________________________________________________

_______________________________________________________________________________________________________

Do you have a history of similar incidents happening in the past: _______________________________________________

_______________________________________________________________________________________________________

 

 

I, __________________ certify that the information provided is complete and correct to the best of my knowledge.

 

 

Signature: ____________________________________________ Date: ____________________

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Contagious Disease Policy

This company seeks to maintain a healthy workplace by appropriately protecting the health and well-being of all employees.

This company is also committed to compliance with all applicable federal and state laws.

An employee is required to report any exposure to a contagious disease that might pose a direct threat to health or safety in the workplace. An employee who fails to do so is subject to discipline, up to and including discharge.

The company may remove or reassign an infected or contagious employee if a secondary infection would pose a higher than usual risk to the employee, co-workers, or others.

The company may require the employee to take a medical leave of absence, to undergo a fitness-for-duty examination, to provide a fitness-for-duty certificate from a physician, or to state the risk of exposure in the workplace with regard to his or her contagious illness.

Supervisors will instruct employees about any special precautions necessary in individual work areas.

An employee concerned about being infected with a contagious disease while in the workplace should convey this concern to his or her supervisor. An employee who refuses to work with or perform services for a person known or suspected to have a contagious disease that does not present a current direct threat in the workplace is subject to discipline, up to and including discharge.

Classification Quick Reference

I = Informational     G = General Safe Practices     S = Serious Violations     L = Life Critical     O = Zero Tolerance  

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Mandatory Covid-19 Vaccination Policy

Purpose

Consistent with its duty to provide and maintain a workplace that is free of recognized hazards, Northeast Data has adopted a Mandatory Covid-19 Vaccination Policy for employees. This policy is intended to safeguard the health and well-being of employees and their families from Covid-19 infectious conditions that can be reduced through an effective mandatory employee vaccination program. This policy complies with all state and local laws and is based upon guidance provided by the Center of Disease Control and Prevention (CDC) and public health and licensing authorities, as well as the Occupational Safety and Health Administration ETS.

Scope

This policy applies to all Northeast Data employees, and individuals receiving offers of employment. This policy applies only to the requirement of completion of the Covid-19 vaccine and doesn’t supersede or otherwise limit any current or future requirements by Northeast Data for proof of an employee’s receipt of other vaccines or compliance in health safety requirements. Compliance under this policy may require recurrent vaccinations or boosters on an annual or recurrent basis consistent with the U.S. Food and Drug Administration labeling, CDC recommendations, and the ETS required by the Occupational Safety and Health Administration.

Policy Statement

Under the Occupational Health and Safety Act and through the Internal Responsibility System, all workplace parties have a duty to keep the workplace safe, this includes taking every reasonable precaution in the circumstances to protect the work force. (OSHA, Section 25(2)(h)).

Northeast Data, Inc is adopting this policy as a condition of employment to minimize and prevent absenteeism due to the vaccine preventable diseases as well as to reduce the risk of transmission to co-workers and clients.

Deadline for Completion

The deadline for an employee’s completion of the Covid-19 vaccine is January 4, 2022. On or before this date, all employees must either; (a) accurately and truthfully enter the date of the completed vaccination into the Northeast Data Portal. (i.e., receipt of second dose in a 2-dose series vaccine such as Pfizer or Moderna, or receipt of a single-dose vaccine, such as Johnson & Johnson) or (b) obtain an approved exemption (with specification of any reasonable accommodation if applicable and available.)

Exemptions can only be authorized to an employee via in writing by Northeast Data. For purpose of compliance with this policy, an employee is considered to have completed the Covid-19 vaccination two weeks after the receipt of either a single-dose or 2-shot vaccine series to enable antibodies to develop. The process for seeking an accommodation is explained below. Individuals receiving offers of employment will be required to comply with this policy prior to the commencement of employment.

Employees who do not fulfill one of these two requirements will be placed on unpaid leave for up to forty-five (45) calendar days. During this time, employees who either submit information through the Northeast Data Portal of a completed vaccination or receive an approved exemption will be authorized to return to duty subject to operational needs. If at the end of the unpaid leave period an employee has not completed vaccination, his/her continuing employment status will be determined by Human Resources, and the employee may be subject to separation at Northeast Data’s discretion.

All Employees on or off contract that are on customer sites who do not fulfill one of the two requirements will be subjected to a witnessed weekly Antigens or PCR test at the employees’ expense. Please see below on how this testing will be expected to be administered. Home tests and Rapid tests will not be allowed as an acceptable Covid Testing Confirmation at this time. All tests must be completed by an acceptable Medical Professional, Such as a Pharmacist, TeleMed, and/or Physician.

**Note: Northeast Data will take on the responsibility of Covid Test Reimbursement for any of the below reasons:

  1. During the first 30-days of this policy.
  2. When an employee can demonstrate they are pursuing covid vaccination and can show scheduled and successful vaccination appointments. Between a 30-day period (Reimbursement will only be for the time between vaccination 1 and vaccination 2)

Any employees refusing to comply with the requirements under this policy will be subject to disciplinary action, up to and including termination from employment.

Individuals receiving offers of employment are required to timely comply with this policy prior to the commencement of employment by providing either proof of a completed vaccination or receipt of Human Resources vaccine exemption approval. Individuals receiving offers of employment from Northeast Data who do not timely comply with this policy will have their offer of employment rescinded.

To establish that an employee has been fully vaccinated, employees are required to enter vaccine information accurately and truthfully in the Northeast Data Portal. Any falsification of vaccine information will subject an employee to protentional disciplinary action up to and including termination of employment.

All current and future employees are required to receive the COVID-19 vaccine and any related boosters.

Request for Vaccine Exemption and Accommodation

To assist any employee who has either; (a) an underlying medical condition or disability that contraindicates administration of the Covid-19 vaccine, (b) pregnancy or pregnancy-related condition, or (c) an objection based upon a sincerely held religious belief, practice, or observance, Northeast Data will provide exemption from the vaccination requirement and engage in an interactive process to determine if a reasonable accommodation can be provided so long as it does not create an undue hardship for Northeast Data and/or does not pose a direct threat to the health and safety of others in the workplace and/or to the employee.

To request and exemption from the vaccination requirement for one of the above reasons, employees are required to submit a completed Request for Exemption from Mandatory COVID-19 Vaccination & Reasonable Accommodation Form to Human Resources.

Employees who submit their request with supporting documentation before January 04, 2022 should receive a determination from Human Resources. Employees are encouraged to submit their requests as soon as possible. Employees may request an exemption to seek workplace accommodation without fear of retaliation.

After receipt of an employee’s request for exemption, Human Resources will review the documentation submitted. If you work on a contract or at a customer site, Northeast Data will review the exemption to ensure it doesn’t conflict with the customer or contract.

If the exemption is approved, engagement in the interactive process with Northeast Data and the employee will be performed to clarify the nature of the request, determine exemption eligibility, and identify potential reasonable accommodations if applicable (with assistance from his/her supervisor.)

Accommodations will be granted where they do not create and undue hardship for Northeast Data and/or do not pose a direct threat to the health or safety of others in the workplace and/or to the employee.

Proof of Vaccination

Northeast Data, Inc. requires proof of vaccination from all current and future employees. Proof is the documentation of completed vaccination series approved by the CDC.

All employees’ COVID-19 immunization information will be protected with appropriate safeguards and will only be used or disclosed for the purposes outlined in this policy.

Employees must disclose their vaccination status to Northeast Data by January 14th, 2022. Staff must receive one dose of COVID-19 vaccine by January 04, 2022, and their second dose of COVID-19 vaccine by January 30, 2022.

Submittal of your Covid-19 Shot records must be uploaded to the Northeast Data Portal, prior to January 04, 2022 utilizing the below online form.

To complete Your Self Certification of Vaccination StatusClick Here>>

Submitting a medical exemption request

Employees in need of an exemption from receiving the COVID-19 vaccine based upon the existence of either (1) an underlying medical condition or disability that contraindicates administration of the vaccine or (2) pregnancy or pregnancy-related medical condition or (3) a sincerely held religious belief practice, or observance must submit a completed request for Exemption from Mandatory COVID-19 Vaccination & Reasonable Accommodate Form to Human Resources to begin an interactive accommodation process prior to the vaccination deadline. By utilizing the below online form. Note All forms must be notarized before turning into the office.

Please complete this form first Click Here>> as you will need to print this off and upload it on the below form with your supporting data

Upload and finish of submittal - Click Here>>

Please note: You must submit a signed copy of the medical exemption and upload all required documents. This letter must specify and prove your why you should be exempt due to medical reasons. Ensure your request includes your full name / current address / today’s date / and an inked signature.

You must also provide a copy of your physicians note along with any supporting data.

All supporting documentation should be uploaded and provided to outline your exemption. Northeast Data reserves the right to request additional supporting documentation.

Submitting a religious exemption request

Employees submitting a religious exemption will be required to engage in the interactive process with Northeast Data for handling the imminent accommodation requests by employees who cannot receive the vaccine. There are two legally recognized exceptions from mandatory vaccines for employees; disability-related reasons and sincerely held religious beliefs.

A sincerely held religious belief is a belief that can be either theistic, or a moral and/or ethical belief as to what is right and wrong.

The vaccine mandate requires an employer to reasonably accommodate an employee’s religious beliefs or practices, unless doing so would cause an undue burden to Northeast Data. Employee can submit their religious exemption requests below.

Click Here>>

Please note: You must submit a written formal letter in addition to the form in the link above requesting a religious exemption. This letter must specify and prove your seriously held religious beliefs that getting the vaccine would not only conflict with but how they conflict with your beliefs. Ensure your request includes your full name / current address / today’s date / and an inked signature.

Documentation may be requested for the review process to further assess the employees sincerely held religious belief. Examples of the types of documents that we might request are:

  1. Statements and explanations from the employee that discuss the nature and tenets of his/her asserted beliefs and information about when, where, and how they follow the practice or belief.
  2. Written religious materials describing the religious belief or practice.
  3. Written statements or other documents from third parties, such as religious leaders, practitioners, or others with whom the employee has discussed his or her beliefs, or who have observed the employee’s past adherence.

The assessment of each employee’s request for exemption will be reviewed on a case-by-case basis.

Northeast Data will review your request against the OSHA ETA standards, customer ETA standards prior to approving or denying a request.

A sample determination form can be found below. Once the office submits an approval or denial, a copy of the form will be also emailed to the employee.

Click Here>>

Special exceptions for exemption request

Special exceptions have been made for the following however, an employee must still fill out the medical exemption form above

  1. Employees that have been infected with COVID-19 and are still having symptoms
  2. Employees in a quarantine period and are unable to start the vaccination process due to a waiting period
  3. Employees that have been treated with monoclonal antibodies or convalescent plasma

These situations may have a 90-day wait before receiving the vaccination.

Personal and/or philosophical objections to the COVID-19 vaccine will not be accepted for granting an exemption from receiving the COVID-19 vaccine or any related boosters.

Submitting Weekly Test Results

All employees regardless of the work they perform, are required to receive the COVID-19 vaccine and any related boosters.

Employees who are unvaccinated for COVID-19 (i.e. those who submitted a completed exemption form or whose vaccine status information is incomplete) will be required to participate in a COVID-19 testing protocol.

Weekly testing submittals can be posted at the link below

Click Here>>

An employee will receive an email from the Infection Control Officer and staff if a weekly test is not submitted. Any employees refusing to comply with the requirements under this policy will be subject to disciplinary action, up to and including termination from employment.

How to replace a missing vaccination card.

It is important to note that the Department of Health as well as the Center for Disease Control and Prevention vaccination cards are official proofs of vaccination. If you have lost / misplaced or if your vaccination card was stolen, you may acquire a copy from

  1. Your State Department of Health;
  2. Requesting a replacement card from the provider that you received your vaccine from; or
  3. Communication with the Center for Disease Control and Prevention.

Covid Positive and Contact Logging

As required by the New OSHA ETS Mandate, Northeast Data will report Covid Positive Personnel on the required Covid-19 Log and Osha 300’s as well as customer requested sites. These logs will only contain the below information

  1. Employee Name
  2. Job Title
  3. The site address they were at when they were positive for covid
  4. The last Date on site
  5. The date of the positive test
  6. The date of the onset of symptoms

Additionally, Northeast Data will keep a copy of the Positive Test result on file for audit purposes.

Sample of Log can be found byClicking Here>>

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Continuous Improvement

Safety Expectation focus for future improvement:

Northeast Data, Inc. is working towards achieving Group HS&E Ideals for: Reduction in injuries and maintaining a low rate of injuries by:

  1. Strong overall company commitment to safety
  2. Increased safety management
  3. Ensuring safety operations and a safe workplace
  4. Continued focus on safety in the workplace
  5. Delivery for required Health, Safety, and Environmental (HS&E) training for all workers
  6. Continued monitoring and measuring of worker’s safety and participation in the HS&E Safety program
  7. Intensive training schedule for emergency management delivered throughout the company

Identification of further Safety Expectation continual improvement through:

  1. Completion of planned internal and external HS&E Audits
  2. Investigation of accidents and incidents and identification of lessons learned
  3. On-going tracking and monitoring of HS&E performance, discussed at local and national levels on a regular basis.
  4. On-going tracking and monitoring of updated Customer Site safety standards
    1. Updated Customer Site Safety Standard notifications will be reviewed by Human Resources and Northeast Data, Inc. Management
    2. Northeast Data, Inc. safety policies and procedures will be reviewed and modified to meet compliance expectations
    3. Any and all policy and procedure modifications will be tracked and noted in the Safety Modifications Tracking System
    4. Notification of any and all policy and procedure modifications will be issued to all Northeast Data, Inc. workers via Northeast Data, Inc. worker notification procedures with additional intensive training provided if applicable.

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