Stan Greer Millworks Company / Employee Health & Safety Policy Program Manual
I: RESPONSIBILITY FOR SAFETY
All employees of Stan Greer Millworks are responsible for ensuring compliance with the company safety program.
The Safety Manager will be responsible for creating and updating the program.
Supervisors and Manger’s shall be responsible for safety training, investigations, and communication.
Employees are responsible for following safety regulations, reporting unsafe acts or conditions, reporting all accidents and near misses, maintaining safe work areas and cooperating with the intent of the safety program. Specific duties of each group in the safety program include, but are not limited to:
A: ALL EMPLOYEES:
1) Report any unsafe working condition to immediate supervisors.
2) Keep individual work areas clean and safe.
3) Report ALL accidents immediately to immediate supervisor.
4) Follow all safety rules.
5) When in doubt ask your Supervisor.
6) Maintain a positive attitude toward safety and cooperate fully to ensure a safe and healthy workplace for all employees.
B: SUPERVISORS & MANAGERS
1) Actively support and participate in the company safety program.
2) Responsible for ensuring safety of all employees under their management.
3) Responsible for training employees in safe working practices and safety regulations.
4) Remove all unsafe working conditions immediately upon discovery and ensure situation is resolved appropriately. Consult with Safety Manager for help and or ideas if needed.
5) Investigate any reported accident immediately and complete the approved company accident report within one working day. Provide reports to the safety and HR managers.
6) Considers the employee’s accident record and attitude toward safety when evaluating that employee.
7) Enforce all safety rules with a positive attitude and stress the importance of a safe working environment to all.
C: SAFETY MANAGER
1) Determine all OSHA standards that are applicable to the company and to each department.
2) Create informative material to cover those topics that is tailored to Stan Greer Millworks needs that can be distributed for review on an annual basis to each affected department.
3) Provide easy access for the managers to training material.
4) Keep the information for training and annual review streamlined and concise.
5) Keep SDS sheets up to date and easily accessible.
6) Directly train forklift drivers at all locations in all departments for both the initial training and the 3 year refresher training.
7) Review accident reports and make suggestion to department managers on ways to reduce injuries or accidents.
8) Evaluate safety procedures and activities to assure compliance with the safety policy.
9) Work with HR Manager to maintain updated compliance posters at each facility.
10) Maintain a small supply of PPE items for distribution as determined by collaboration with the HR & Payroll Manager, that may include disposable safety glasses and hardhats, (some of which may be available by payroll deduction.)
11) Do an annual safety inspections and audit to ensure safe working conditions. Check for all DOT compliance, Fire Code compliance, and OSHA compliance.
D: MANAGEMENT
1) Evaluate procedures, supervisors, and managers to ensure compliance with the company safety program.
2) Approve expenditures to ensure a safe working environment and correction of any potential safety hazard.
3) Ensure adequate training programs are in place for all levels of employees.
II: SAFETY POLICY
A: The safety, health and well being of all employees is a major concern of Stan Greer Millworks. Therefore, accident prevention is of primary importance. Safety will always take precedence over production demands and shortcuts should always be avoided.
B: The management of the company will take all practical steps to provide a safe and healthy workplace. In its efforts to provide a safe work place, Management has established the safety procedures outlined in the following pages. It is the responsibility of all personnel to comply with these procedures. It is expected that every employee will work together to achieve the common goal of accident prevention.
III: SAFETY RULES
A: The Company’s Safety Rules are an important part of the overall Safety Program. Because some activities and equipment represent potential for injury, definite guidelines are necessary to protect the employees. These following general Safety Rules as well as the Specific Safety Rules located on each piece of equipment are to be adhered to at all times. Production demands should not be the cause of employees, supervisors, or managers short cutting the appropriate policies and procedures specifically designed to ensure their safety.
B: Management has an open-door policy regarding safety. If in doubt, check it out. If there is a reason to think that a job is unsafe, any employee can stop working and ask a foreman to determine whether the job is safe, without fear of sanctions.
C: Employees who do not follow the proper safety procedures will be subjected to disciplinary action and/or termination.
1) Any safety violations or concerns should be reported to a supervisor immediately. If an employee believes that their reported concern has not been satisfactorily addressed they should make their concerns know to either the Safety Manger or the HR Manager.
2) Per Arizona State Law without a hands free devise. If a hands free devise is not available, pull off road to a safe stop and make/take any calls or texts once you have completely stopped and put the vehicle in park.
3) All accidents should be reported to an employee’s supervisor immediately.
4) The use of alcohol or any other controlled substance during working hours, including lunch hour are prohibited.
5) All extension cords should be inspected for fraying before being put into use. Extension cords shall be used only as a means of temporary wiring.
6) Furthermore, extension cords shall not be run through holes in walls, doorways, walkways or run across pinch points or near any moving part of machinery.
7) All employees are required to provide, maintain, and wear appropriate personal protective equipment (PPE) for their department and suitable for the job that they are doing. This would include safety glasses, hearing protection, work boots and when on a job site, hardhat.
8) Mechanical safeguards must always be kept in place. Saws or tools without their guards shall not be used at anytime. They shall be removed from the worksite until properly repaired.
9) Adjusting or re-adjusting machine set-ups while a machine is operating is strictly prohibited.
10) A ring test should be used before mounting a grinding wheel on a grinder.
11) Only authorized forklift drivers will be permitted to operate forklifts.
12) Employees should follow the proper body mechanics when handling and moving material.
13) Machines cannot be operated without the appropriate guarding in place.
14) All employees working in the high noise areas must wear hearing protection.
15) Lockout/Tagout Procedures should be followed for all machines taken out of service. Lockout/Tagout is to be performed only by authorized and trained employees.
IV: DISCIPLINE FOR NONCOMPLIANCE
A: Disciplinary action will be taken against any employee who fails to observe any part of the safety policy or procedure or that violates any OSHA standards, any City, County, or State Fire ordinance, or any State or Federal Department of Transportation regulations.. Any foreman, supervisor or manager, as soon as he/she becomes aware of any such failure shall ensure that the following is taken:
B: FIRST OFFENSE: A written report of the incident shall be made and placed in the employee’s personnel file. The Supervisor will also give immediate on-the-job instruction to prevent further violations. The instruction will be part of the written report and be signed by both parties.
C: SECOND OFFENSE: The employee shall be immediately suspended from employment without pay for a period of one day. A written report of the incident shall be made and placed in the employee’s personnel file. Upon his/her return to work, he must undergo additional, formal training in the area of the violation before he/she is permitted to work so as to prevent injury to that employee or fellow co-workers.
D: THIRD OFFENSE: The employee shall be immediately terminated.
V: ACCIDENT INVESTIGATION
A: The objective of Stan Greer Millworks safety program is to provide a safe and healthy working environment for all employees. As a part of this program the company has a responsibility to investigate all reported accidents or near misses regardless of severity. The intent of an accident investigation is to identify root cause and to eliminate any potential reoccurrence by implementing realistic corrective actions.
B: When an accident has occurred, employees involved in, or witnessing, the accident have a responsibility to report the incident to their immediate supervisor. The treatment of any injuries should be given priority by either getting the individual to a treatment facility or by calling 911 for paramedics to be dispatched to the seen. Although employees may choose to visit their own physician at a later time, initial treatment authorized by the Stan Greer Millworks, and paid for by our Workers Comp provider, shall be implemented first.
C: The immediate supervisor who received the report of an accident is responsible to either initiating the accident investigation, or to aid a manager in the investigation. Documentation of accidents shall be completed on the company approved accident report form within one (1) business day. The supervisor shall investigate how the accident occurred and immediate actions taken to correct the deficiency. The investigating supervisor or manager shall complete the accident report. Recommended controls or corrective actions should be completed jointly between the supervisor and or safety manager. The supervisor or manager shall sign and date the report and provide it to the company HR Manager with a copy to the Safety Manager no later than one (1) full working day following the accident. The company HR Manager shall utilize provided information to complete the OSHA 300 Log (if appropriate) and submit the report to the Workman’s Comp Insurance provider if there are injuries involved. The Safety Manager may recommend additional corrective actions, or procedural changes to reduce the possibility of the same type of incident happening again.
VI: SAFETY TRAINING
A : The company is committed to providing its employees with the proper training necessary to ensure that they can perform their jobs without placing themselves at risk of injury. All training will be documented in writing, signed by the trainer and trainee. All employees will be given the following training on an ongoing basis as indicated below:
B: Training Type & Frequency
Office personnel:
General Health & Safety Rules Annually
Emergency Action Annually
Employee Emergency Action Plans Annually
Production personnel:
Forklift training New drivers and every 3 years
General Safety, Lockout, PPE, SDS, Ladders, Etc Annually as part of weekly topics
Installation personnel:
General Safety, Lockout, PPE, SDS, Ladders, Etc Annually as part of weekly topics
C: In addition, supervisors and managers will be given training in:
Employee Safety Training, Safety Auditing Return to Work Program, Job Skill Assessment, Accident Investigation Training. Training is an important part of the overall Safety Program. Employees, supervisors, and managers must participate in required training and give 100% commitment to insure full understanding and utilization of the training in their jobs on a daily basis.
VII: FIRST AID
A: Stan Greer Millworks will provide a basic first aid kit for “non-life threatening” emergencies.
B: If an employee is unconscious or there is any life threatening emergency 911 should be called for emergency personal to be dispatched.
C: An employee seeing or observing an emergency situation is under obligation to call 911 or contact their supervisor so 911 can be contacted.
VIII: SAFETY MEETINGS
A: Weekly safety topics will be covered by the production and installation teams.
B: There are over 52 topics available for the Production Department tailored to department and over 52 topics for the Installation Department tailor to the department. They are to be covered in order from January through December weeks 1-52 so that the seasonal Safety topics will be in correct order.
IX: Hazardous Communication Program
The purpose of this program is provide information to employees about potential hazards in the work place, make sure that employees understand and are aware of these hazards, and keep employees notified as these hazards change.
A: Container Labeling
Stan Greer Millworks policy is to only use containers with original manufacture labeling intact. Any containers with missing labels will be relabeled by Foreman or Supervisors with clear product identification that includes hazardous information from the Safety Data Sheets (SDS) before any employee is allowed to use the product.
B: Safety Date Sheet Locations
Safety Data Sheets for all chemicals and materials for production, installation, fleet service and building repair and maintenance are located on our website at www.stangreer.com/sds and can be accessed from any smart phone, PC, tablet computer or smart TV at any time. The conference room computers in all occasions are available for anyone without a company phone or PC to access these files.
The Health & Safety Manager will be responsible for making sure SDS books are updated annually. The Purchasing Manager will be responsible for coordinating with the Health and Safety Manager to obtain SDSs for new products purchased. Department Managers will be responsible for coordinating crew training on new products.
C: Employee Training
SDS’s will be obtained for every product used before initiating the use of that product. In addition, affected employees will be trained in Personal Protective Equipment (PPE) needed, appropriate uses of, and possible hazards involving use of each product or material before introducing its use.
D: Non-routine Tasks
If an employee is required to work in another department, or at a task he is not familiar with, the employee will be trained in the task as if he were a new hire employee, including relating SDS information necessary for the new task.
X: Forklift Operator Safety Plan
OBJECTIVE
The major goal of Stan Greer Millworks in creating a Forklift Compliance Program is to minimize the number of accidents and injuries due to incidents involving forklifts which are operated by our employees. Because we recognize a number of employees are affected by our use of forklifts, we have committed ourselves to doing as much as is practically possible to protect them from incidents involving this equipment.
ASSIGNMENT OF RESPONSIBILITY
A. Plan Administrator
Health & Safety Manager shall manage and update the Forklift Operator Safety Plan for Stan Greer Millworks, and maintain all records pertaining to the plan.
B. Management
Stan Greer Millworks will implement this plan and provide safe equipment that, when used properly, will minimize or eliminate risk of occupational injuries and deaths.
C. Supervisors and Managers
Supervisors and Managers shall themselves follow and ensure their employees are trained in and follow proper forklift safety procedures as outlined in this plan.
D. Employees
Employees are responsible for adhering to proper forklift safety procedures as described in this plan. Employees are also responsible for reporting all accidents or near misses to HR Manager and Health & Safety Manager immediately or within 24 hours.
E. Contractors
Contract employees shall be responsible for complying with this plan and may be provided the training described herein by Health & Safety Manager.
LOCATIONS OF OPERATION
At both our facilities the forklifts may be used in all areas of the facility accessible by their physical size (if they will fit through the door opening without any modification to the door opening they can be used in that area.)
Operators will be trained to operate forklifts differently in parking lots from warehouse areas, and production areas. More care will be show in areas where employees are present, and or in areas of pedestrian traffic. When accessing pallet racking employees will be asked to leave temporarily from any affected areas, and a spotter will be used when necessary.
FORKLIFT INSPECTIONS AND MAINTENANCE
In order to make sure our powered industrial trucks are maintained appropriately and are functioning correctly, they are inspected every 8 hours of operating time (or sooner - more frequently.) To facilitate this process, and make sure the trucks are thoroughly inspected, we are using a "Forklift Inspection Checklist" or each lift. The Production Manager at Hereford Office, and Tucson Facility Manager at Tucson Office as well as the Health & Safety Manager are responsible for making sure that these inspections are carried out appropriately. They will also be inspected by an outside certified forklift repair company every 250 hours of service (or sooner – more frequently.) The checklists will be collected and kept on file by the Health & Safety Manager.
If the inspection of one of our forklifts indicates it is in need of maintenance, or if a forklift is damaged during operation, we immediately remove the forklift from service and schedule it for maintenance. Production Manager at Hereford Office, and Tucson Facility Manager at Tucson Office (or if he is not available the Health & Safety Manager) is responsible for overseeing these activities. To disable the forklift for repair: the forklift needing repair will be parked in an out of the way place that will not interfere with production, and the key removed. The key for the forklift needing repair will be kept in the Production Manager’s at Hereford Office, and Tucson Facility Manager’s at Tucson Office office until the repair can be completed.
OPERATOR SAFETY TRAINING
A: We understand a large percentage of accidents involving forklifts are due to operator error. In order to make sure our employees are appropriately trained before operating their forklifts, they are given both classroom and hands-on instruction in the following areas:
1) The contents of the OSHA Standard 29 CFR 1910.178
2) Types & characteristics of forklifts
3) Operational inspections
4) Basic driving, stability and load handling
5) Fueling
6) Attachments
B: We also provide our truck operators with retraining under the following circumstances:
1) New hire, or newly assigned forklift driver
2) If they have been involved in an accident or near-miss incident.
3) If they have been observed operating their truck in an unsafe manner.
4) If they have been assigned to drive a different type of truck than they have been trained on.
5) At least every 3 years.
Health & Safety Manager is responsible for overseeing these training activities.
XI: Emergency Action Plan
A: Fire
1. In the event of a fire all employees should follow evacuation procedures.
2. Small fires that can be extinguished with a portable fire extinguisher can be extinguished by employees. A small fire is a fire of less than 100 square feet (or 10’ x 10’.)
3. An employee seeing or observing an emergency situation such as a fire is under obligation to call 911 or contact their supervisor so 911 can be contacted.
B: Evacuation
1) In the event of an emergency, or when instructed to do so, all employees should move to the closest exit that is not in the direction of the fire or hazardous condition.
2) Employees should group in the primary meeting area by the front gate (front side walk for Tucson location) and check in with their supervisors, or the coordinating manager.
3) The coordinating manager will be the Operations Manager, the Health and Safety Manager, or another manager or supervisor on the site.
4) The coordinating manager will make sure that emergency response providers have been called, and that all employees are accounted for. If an employee is not accounted for they will ascertain where they were last working and provide that information to emergency responders as soon as they arrive on the scene.
5) After the emergency situation has been eliminated and emergency personal have given the “all clear” to return to the building the coordinating manager will inform all employees.
6) If only part of the building can be accessed, the coordinating manager will inform all employees of the access limits or any hazards that still exist that they need to be aware of.
7) In the event of a limited evacuation the same steps would be follower as a full evacuation. A limited evacuation would be when an area of a building, or only one building in the Hereford complex is evacuated.
8) Evacuations should be done in the event of a power outage unless it has been determined that there is enough outside sunlight entering your work area to continue in the building safely, and that there is no danger from the cause of the power outage to the building or employees. If an employee is unsure they should evacuate.
C: Fire Extinguisher Use
1) Only hand held fire extinguishers should be used by employees to fight fires, and they should only try to extinguish fires up to 100 square foot, and only determining from a safe distance away that they can safely approach the ignition source and discharge a fire extinguisher.
2) All employees should be aware of the types of fire extinguishers in their work area, and the closest exits for evacuation.
D: Fall Restraint Retrieval
1) If an employee who falls, while wearing a Fall Restraint harness, and is knocked unconscious, or is unable to get to a ladder to retrieve himself safely with or without help of others on site, the spotter on site should call 911 without delay.
2) Sales personal should notify the Health & Safety Manager when bidding on jobs that are more than 15 minutes away from emergency response providers where Fall Restraint harnesses will be needed. If an alternate retrieval method for the project cannot be devised (and built into the quote if need be) then the job should not be bid on.
XII: Lock-out Tag-out
A: Program Objectives
Stan Greer Millworks, after analyzing each workers activities, all equipment, equipment operations, and worker procedures has found the need for the following training related to Lock-out Tag-out.
1) Every employee will be educated on why locks and tags are used and that unauthorized employees are not be allowed to remove locks or tags.
2) Production personnel will be considered affected employees, and will be educated in the implementation of Lock-out Tag-out.
3) Program will identify authorized employees and affected employees.
B: Training
1) Training will be done annually
2) All personnel will be trained on why locks and tags are used and that unauthorized employees are not allowed to remove locks or tags.
3) All affected employees will be trained on implementation of Lock-out Tag-out.
4) All authorized employees will be certified to perform Lock-out Tag-out.
5) Affected and authorized employees will be trained on when Lock-out Tag-out needs to be implemented, and if there are any other energizing sources in each piece of equipment other than electrical (such as pneumatics.)
C: Identification of employee groups
1) All personnel includes all employees working at Stan Greer Millworks
2) Affected employees are all employees that use or maintain equipment that requires
Lock-out Tag-out to be implemented for maintain or repair of that equipment.
3) Authorized employees are employees that are trained and certified to perform Lock-out Tag-out on equipment at Stan Greer Millworks.
D: Equipment to be Lock-out Tag-out
1) All equipment that is hardwired into a circuit shall be locked out at the power disconnect.
2) All equipment controlled by a wall mount switch or similar devise, or that has a continuous source of electrical power should be locked out with a breaker locking type devise at the electrical panel.
3) Any corded devise that is damaged or will be down while the person doing the repair is leaving for the day or leaving the corded tool unattended. (Example: A hand held grinder that is getting a new grinder wheel, or a hand held saw that is receiving a new blade would not need to be locked out unless it is left overnight, or during a shift change, while it remains disassembled or with a guard removed.)
E: Identifying of Lock-out Tag-out location
1) All Lock-out Tag-out locations will be marked.
2) Power disconnects that are more than ten feet away from the equipment to be
Locked & Tagged should be labeled as the Lock-out Tag-out location for that equipment.
F: Company Provided Lock-out Tag-out tools
1) Locks that are uniquely keyed
2) Cord plug covers for locks to attach to cord ends
3) Breaker attachment for locks to attach to breakers in electrical panels
4) One time use tags, to be turned into Health & Safety Manager after use.
G: Procedure
1) An affected or authorized employee identifies that maintenance or repair needs to be done on equipment that requires Lock-out Tag-out to be implemented.
2) In the case of an affected employee identifying that maintenance or repair needs to be done on equipment that requires Lock-out Tag-out to be implemented, he would contact an authorized employee to perform the procedure.
3) Authorized employee notifies all affected employees that Lock-out Tag-out is to be implemented and specifies the equipment that will be locked out.
4) Authorized employee locks out and tags the power disconnect for that specific piece of equipment.
Tag should listed the: a) date, b) time, c) reason, and d) authorized employee performing the Lock-out Tag-out
5) Authorized employee or someone designated by him, commences repair or maintenance on that equipment.
6) When work has been completed, the authorized employee notifies all affected employees that the equipment will be re-energized.
7) The authorized employee removes the locks and tags from the equipment and re-energized and follows any manufactures recommendations for power up proceed to make sure that the equipment is functioning properly.
8) The authorized employee turns the equipment operation back over to the current operator.
9) The authorized employee should turn in the used tag into the Health & Safety manager as documentation (for OSHA inspectors or accident investigators) that the Lock-out Tag-out procedure was properly implemented.
XIII: Safety during Facility Tours
The Safety of our Employees and Customers is of upmost importance and should be top priority when giving facility tours. Since forethought and planning is the best way to prevent accidents, it is logical to provide well thought out guidelines in advance to help prevent accidents. These basic principles should always apply:
1) Only a Stan Greer Millworks employee who has read over this memo can be a tour guide.
2) The tour guide should coordinate with all department managers (for departments affected by the tour) before each tour and let them know well in advance when the tour will be. Also, the affected managers should be reminded the morning of the tour so they can pass on any information regarding special circumstances to the tour guide that involves safety issues that could affect or might come up during the tour. Effective communication is essential.
3) Before starting the tour, the tour guide should instruct all tour members of the tour group that for their own safety they need to listen to all instructions. If anyone in the group ignores the instructions of the tour guide, the tour guide has the option to stop the tour for the safety of everyone in the group.
4) Whenever possible tours should be planned when forklift trucks are not in use. If that can’t be avoided then all members of the group should be kept at least 50 feet from any forklift activity, and out of blind spots of any forklift or company truck movements.
5) No tour will be conducted when any equipment is running that has a high-level of noise, (for example the large radial arm saw in the main door shop.)
6) Tour members are not required to wear safety equipment, because tour members are not authorized to enter any high-risk areas. High-risk areas include, within 20 feet of any operating piece of equipment including chop saws, table saws, door machines, air compressors, band saws, staple guns (air or electric), planners, and within view of any welding equipment that is in use (the bright arc of welding equipment can burn the retina of the eyes.)
7) No tours of the Hollow Metal area will be given when welding in progress.
8) Tours can be given of the lock cutting room, but no tour member should be allowed to go into the lock/hardware storage area because of the risk of fall from the loft area and because of the chemicals being stored there (thinking of children in tour groups.)
9) No tour group should be allowed to enter areas that are being remodeled or are under construction.
10) If a piece of equipment is down while giving a tour, or is shut down when the tour is approaching the equipment, and the tour guide would like to allow the tour group to get closer than 20 feet, then the tour guide should communicate with the machine operator to make sure that the equipment is completely deenergized and not fired up while the group inspects the machine. Even then all members of tour group should be more than 5 feet (more than an arm’s length) away so that no equipment is accidentally energize.
11) No tour group guide should take a tour down an aisle between pallet racking when a forklift is working in the next aisle over. This would even be the case if an employee is on a ladder removing an item from a pallet racking on the next aisle over. This is to prevent an accident from something being pushed or knocked off the racking on your side because of movements on the other side.
12) No tour group should go in the compressor room, or within 5 feet of any electrical panel.
13) Tour guides should keep in mind that this list is not all inclusive, and that special circumstances that will affect the tour can change on a daily basis. It would be better to reschedule a tour, or cancel it all together, then to continue a tour when it is unsafe condition is present.