Safety is a priority at HELM Builders, LLC. OSHA regulations are part of our everyday hazard communication program, which is implemented and referenced throughout the job site. Safety meetings and inspections are ongoing weekly.

The safety program for HELM Builders is an active process that involves all members of the team. Through the use of the Tool Box safety

talks, publications, and training, we are able to provide all of our employees and subcontractors with a safe working environment. The management of HELM Builders is committed to job-site safety and will continue to do everything necessary to instill safety consciousness among its employees. Job safety is always priority number one, anything less than 100% effort is unacceptable.

HELM Builders is committed to a safe working environment for the benefit of its employees, subcontractors, and the general public and considers no phase of its operations of greater importance than safety. For this reason, HELM Builders hereby establishes this policy in order for employees, clients, and others to better understand our position on accident prevention and safety.

Construction, by nature, is a very hazardous business and it is necessary that we establish safety rules and policies. These rules and policies, in accordance with the Occupational Safety and Health Act (OSHA), are reviewed with our employees at weekly project safety meetings. Our subcontractors are also required by contract to provide weekly safety instructions.

It is this company’s policy to

1. recognize and accept its responsibility to establish the guidelines and framework within which a good accident prevention program can operate;

2. emphasize to all supervisors their responsibility to enforce safe working procedures and conditions with their workers, subcontractors, suppliers, and other persons while on the job site;

3. comply with OSHA and the regulations issued under this act; and

4. conduct an ongoing safety program with appropriate documentation as evidence of our interest in our employees and our goal of achieving zero losses.

Personnel with Safety Responsibilities

The following are job descriptions of those most directly involved in safety activities. Some of these may not apply in all cases.

Safety Committee

The safety committee is responsible for the development and implementation of the company’s safety program. These responsibilities include, but are not limited to, keeping project personnel advised of federal and state safety legislation and standards, developing training programs to assist field supervisors in hazard identification and compliance with safety standards, and developing procedures for handling inspections and citations under OSHA. This committee also serves as liaison with the company’s insurance carrier on accident prevention and claim matters, and is responsible for the preparation of corporate statistical data and review of loss runs supplied periodically by the insurance carrier.

Project Manager

The project manager is responsible for all safety on the project and for ensuring that our safety program is implemented. He will assist the on-site management personnel and work with the safety committee in implementing safety training programs in the field. The project manager also works closely with the superintendent to identify potential safety hazards and ways to correct these hazards.

Superintendent

The superintendent is responsible for implementing and enforcing company programs on a major project or within a geographical area. He works in conjunction with the company’s insurance carrier and may supervise safety inspectors. In addition, the superintendent is responsible for preparing various statistical data and special reports, and organizing and directing the work of guards and watchmen at major construction sites. He should also have knowledge of police techniques and investigative procedures, and be familiar with all aspects of theft and fire prevention. The American Red Cross must certify all superintendents in first aid.

Safety Coordinator

On projects that do not justify the employment of a full-time safety engineer, the superintendent will be responsible for safety matters. This person shall be known as the safety coordinator.

Care must be taken in the selection of this person. Federal laws and insurance requirements are more than simple guardrails and hard hats. A period of time spent in managing the safety affairs of a project can only result in him becoming a better contractor as he regards safety not as a necessary burden, but as an actual tool of production.

If the safety coordinator’s job becomes more than he can handle in the time that he has, he should form the safety committee, which will relieve him of some of the daily duties, particularly the safety inspections.

The HELM Builders safety coordinator must familiarize himself with OSHA standards and procedures and handle all documentation required by law. Specific details are covered in other portions of this manual.

Project Level Safety

The superintendent on each project shall assume full responsibility for the conduct of the daily safety activities on that project, although specific safety related functions may, and should, be delegated to others on the supervisory staff. Safety should occupy an important part of every staff meeting and anyone or any company to which we have subcontracted work should be made to account for their safety activities and performance.

Safety responsibilities:

1. Planning and job startup safety

2. Public protection

3. Fire prevention

4. Providing safety equipment

5. Posting emergency phone numbers

6. Indoctrinating and training new employees (HELM Builders and subcontractors)

7. Conducting safety meetings weekly, at a minimum (including subcontractors)

8. Enforcing project safety rules

9. Establishing safety committees

10. Providing and staffing first aid facilities

11. Accident reporting (OSHA and state)

12. Conducting inspections of project activities

13. Complying with OSHA regulations as a minimum standard

14. Maintaining the project bulletin board

15. Working with the insurance carrier

16. Monitor for hazardous chemicals and maintain HazCom manual

17. Perform and/or delegate competent person requirements

Subcontractors/Supplier Safety

All contractors working for us are required by the terms of their contract to comply with the regulations issued under OSHA. They are also required to demand the same compliance of any and all contractors and suppliers whom they employ on our projects.

When subcontractors first report to the job site and prior to beginning work each day, the superintendent shall review with the subcontractor’s representative, his contractual obligation to safety and the project safety rules that he and his employees are required to follow and enter this fact in the job site journal. The subcontractor will also provide the superintendent with copies of MSDS sheets for all chemicals that will be brought onto the job site. The subcontractor will also be required to submit all tools and equipment for the superintendent’s inspection. Our subcontractors shall keep us informed as to the status of recordable injuries to their employees. While the injured employees are not our direct responsibility, we could easily be involved at a later date in a court action. Subcontractors shall also provide us with copies of citations that they may receive as a result of OSHA inspections.

Subcontractor supervisors are to attend each scheduled job progress meeting, and they will be asked to report on their safety performance. Also, certain subcontractor employees may be asked to serve on the safety committee or fire brigade if they are going to be on the job long enough to make it worthwhile.

It is the intent of HELM Builders to assist any of our subcontractors in matters of safety for our mutual benefit. However, in the event that there is a failure to show good faith in cooperation with safety requirements, a noncompliance order is issued to the home office of that firm demanding action be taken. If this is unsuccessful, we have no choice but to withhold payment until the desired result is obtained.