WEST POINT ROOFING

Corporate Safety Program

Revised: 8/14/2024

7346 S Alton Way Unit 10-I Centennial, CO 80112

 Table of Contents

Safety and Health Policy Statement ................................................................................................ 3

Program Responsibilities ................................................................................................................ 4
Reporting of Injuries and Illnesses ................................................................................................. 8
Accident Investigation .................................................................................................................... 9
Heat Illness Prevention Plan ......................................................................................................... 12
Injury and Illness Prevention Program ......................................................................................... 16
Scaffolding .................................................................................................................................... 31
Fall Protection / Prevention .......................................................................................................... 34
Tool and Equipment Safety .......................................................................................................... 34
Ladder & Stair Safety ................................................................................................................... 36
General Safety Policies / Procedures ............................................................................................ 39
Personal Protective Equipment ................................................................................................. 39
Housekeeping ............................................................................................................................ 39
Material Handling ..................................................................................................................... 39
Return to Work Program ............................................................................................................... 40
Fleet Safety Program..................................................................................................................... 41
Hazard Assessment / Safety Inspections....................................................................................... 46
Substance Abuse Program ............................................................................................................ 47
Disciplinary Procedure.................................................................................................................. 49
Appendices and Forms .................................................................................................................. 50
Policy Acknowledgement ......................................................................................................... 51
Appendix A

Safety and Health Policy Statement

It is the policy of WEST POINT ROOFING to provide a safe and healthy work environment for
all employees and to abide by all federal, state and local regulations as they pertain to our
operations. All practical steps shall be taken to maintain a safe, healthful workplace for all of our
employees. We will maintain this Corporate Safety Program which has been designed to train our
employees to follow safe practices and to recognize and correct unsafe working conditions.

Our Safety Policy has equal importance with the company’s policies of providing the best quality
and most productive service in our industry. It is our goal to completely eliminate accidents and
injuries. Because of the many different hazards within our industry, we must maintain a constant
safety awareness to achieve this goal.

The employees of WEST POINT ROOFING are considered our most valuable asset. For this
program to be effective, the company requires the cooperation of all employees. Any observed
unsafe act and/or condition in our work environments must be immediately reported.

Accidents and injuries can be prevented. When an accident occurs, everyone suffers: employees,
their families, dependents and the company. Let’s work together, safely.

______________________________
Brad Streich
Vice President - Operations

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Appendix A

Program Responsibilities

In order for a safety and health program to be successful, individual responsibilities must be clearly
identified and distributed throughout all levels of company personnel. WEST POINT ROOFING
feels that safety is the primary responsibility of all employees.

Although different levels of personnel are identified below, any employee on a WEST POINT
ROOFING site may shut down a particular work operation that poses imminent danger, or if a
situation arises which is immediately dangerous to life or health. When such action has been taken,
the on-site foreman shall be immediately notified and actions to remedy the situation shall be
implemented.

Senior Management:

The effectiveness and success of this safety program depends heavily on the support and
commitment shown by Senior Management. Senior Management is responsible for funding and
providing the necessary safety resources to the project management team. Other responsibilities
include:

• Assisting the Project Manager in determining staffing and facility needs with regard to
project safety and health.
• Establish rules and programs designed to promote safety and make known to all employees
the established rules and programs.
• Establish safety training schedules.
• Perform periodic audits (sometimes by an outside party or resource) to evaluate the
effectiveness of the Safety and Health Program and performance of the project
management team.

Project Manager:

The Project Manager plays a very important role in administering safety and health
responsibilities. Not only with WEST POINT ROOFING personnel, but the Project Manager is
the communication link between the General Contractor and / or other subcontractors (whichever
is applicable), who may be exposing WEST POINT ROOFING employees to unsafe acts or
conditions. In this case, the Project Manager must notify the controlling party and ensure that
corrective action is taken to eliminate the hazard(s), ultimately ensuring a safe working
environment for WEST POINT ROOFING employees. Project Manager responsibilities shall
also include the following:

• Identifying and planning ahead for project specific safety requirements noted in the
contract documents (example: Controlled Insurance Programs).
• Assist Superintendent in monitoring compliance with Safety Program. (If applicable)
• Advise Senior Management on possible safety program deficiencies or new ideas.
• Plan ahead for added safety costs during the project’s bidding process.

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Appendix A

• Communicate customer’s (GC / owner) safety, health, and loss control requirements to
construction project team.
• Participate in pre-construction safety planning meeting for specific projects as necessary.

Superintendents:

The Superintendent is the on-site (or roaming from site to site) coordinator and overseer of all field
construction operations, including safety. It is the duty of the Superintendent to ensure that site
security is established and maintained, to supervise on site personnel, to coordinate WEST POINT
ROOFING activities on the site and to verify that all activities are performed in a safe manner.
The Superintendent is responsible for the overall safety and health practices and conditions on site.
The Superintendent responsibilities shall also include the following:

• Give ongoing input into to Senior Management regarding necessary changes to this safety
policy.
• See that all injuries are reported and treated.
• Require and review reports and investigations of all accidents.
• Plan production so that all work will be done in compliance with established safety
regulations.
• Make sure that proper safety materials and protective devices are available and used, and
that all equipment is in safe working order.
• Provide for the protection of the public from company operations.
• Review all accidents with foremen and file completed reports.

Field Foremen:

Foremen play an essential role in the successful implementation of this program. Foremen
translate management’s policies into action and promote safety directly among the employees on
site. Foremen have the responsibility of safeguarding, educating and training those employees
who have been placed under their direction. Specific safety and health responsibilities shall
include the following:

• Administer and enforce established safety and health programs at the project level.
• Set proper examples for subordinates – “Leadership by example”
• Sell the employees on the value and importance of jobsite safety.
• Know and enforce company safety and health requirements.
• Secure prompt medical attention for injured employees. Investigate all accidents
immediately and correct any obvious causes of incidents immediately.
• Personally address safety and working conditions with employees daily.
• Instruct new and existing employees who are performing new or unusual tasks on the
required safe working practices necessary to complete the task
• Report unsafe conditions such as faulty equipment.
• Recognize jobsite hazards and develop / implement corrective action.
• Perform accident investigations and complete accident reporting forms.
• Field and evaluate employee(s) safety complaints.

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Appendix A

• Ensure adequate supply of personal protective equipment.

• Cooperate with Senior Management in utilizing the company’s “Return to Work Program”
• Communicate with other jobsite contractors and / or General Contractor to ensure hazards
are controlled for all exposed parties.
• Act as WEST POINT ROOFING “competent person” when required and authorized to
do so by management.

Field Employees:

WEST POINT ROOFING recognizes that its employees are the most valuable asset the company
has. The actions taken by each employee during his / her daily routine will ultimately determine
whether or not the established safety and health program is successful.

WEST POINT ROOFING has identified the following items as being the minimum necessary
responsibilities, which must be undertaken by all field employees, during the course of their
employment:

• Work safely to ensure your own safety as well as that of co-workers and others.
• Participate in all safety and health training programs and orientations as required.
• Understand and comply with all safety directives as issued by company management.
• Arrive at work, mentally and physically prepared to perform assigned work in a safe
manner.
• Immediately correct any noticed unsafe condition(s)
• Use all required personal protective equipment as directed by company supervision.
• Maintain and properly use all tools under your control.
• Read, understand and follow all safety signs, posters, instructions and materials used to
indicate warnings, instructions and directions for safe work performance.
• Inform the foreman / supervisor of any concerns about the safety of work activities and
any injuries sustained while on the job (no matter how seemingly insignificant).
• Practice good housekeeping measures while on the jobsite.
• Abstain from any horseplay, fighting and / or gambling.
• Abstain from the usage of drugs and other banned substances, as well as the usage of or
possession of firearms and / or weapons.
• Become familiar with and follow all jobsite safety programs, policies and procedures,
jobsite hazard communication process and any applicable emergency evacuation plan.

Competent Person(s):

OSHA requires a competent person be designated for particular construction activities, who can
recognize hazards or potential hazards and who has the authority to correct or abate the hazard.
For this reason and when required, the Project Management Team will identify who the competent
person will be, in order to meet the definition set by OSHA as a Competent Person, which is
defined as follows:

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Appendix A

“Competent Person” means one who is capable of identifying existing and predictable
hazards in the surroundings or working conditions which are unsanitary, hazardous or
dangerous to employees and who has authorization to take prompt corrective measures to
eliminate them.

Visitors:

As with any construction project, it is a common occurrence to find visitors present on the jobsite
at any given time. Some examples of “visitors” are as follows:

• Owners or owner’s representatives

• Architects / engineers
• Members of the public
• City / county codes personnel
• Demonstrators
• Emergency personnel (fire, ambulance, hazmat team, etc.)
• Vendors / suppliers
• Insurance representatives

Just like any employee performing work on the jobsite, visitors have safety and health
responsibilities as well. They are as follows:

• Become familiar with and follow all jobsite safety programs, policies and procedures,
jobsite hazard communication process and any applicable emergency evacuation plan.
• Understand and comply with all safety directives posted by the company and all OSHA
state and federal safety laws and standards and any site-specific standards or requirements
established by the project’s owner.
• Read, understand and follow all safety signs, posters, instructions and materials used to
indicate warnings, instructions and directions for safe work performance.
• Participate in all safety and health training programs and orientations as required.
• Abstain from any horseplay, fighting and / or gambling.
• Abstain from the usage of drugs and other banned substances, as well as the usage of or
possession of firearms and / or weapons.

Pre Construction Planning

Pre-Construction planning is essential to ensure that safety is “built-in” to the job from start to
finish. The real starting point for pre-job planning is during the preparation of the estimate / bid,
which should include a realistic allocation for safety. If a successful low bid results, one of the
first orders of business for the contractor is a pre-job planning meeting. Those directly involved
with these meetings should include owners of the contracting agency, project superintendent,
safety coordinator (if applicable), and superintendents of other contractors who will be working
on the job and their safety coordinators. It is vital that these individuals develop and agree on a
specific safety program for the project.

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Appendix A

Reporting of Injuries and Illnesses

WEST POINT ROOFING expects all work-related injuries, illnesses, accidents or “near miss
accidents” to be reported to a company supervisor or other member of management as soon as
possible after the employee learns of the incident and no later than 24 hours. Reports may be
verbally made.

Employees have the right to report work-related injuries and illnesses. WEST POINT
ROOFING is prohibited from discharging or in any manner discriminating against employees for
reporting work-related injuries and illnesses.

All employees and their representatives are advised of their right to access relevant exposure and
medical records which WEST POINT ROOFING is required to maintain under OSHA’s Access
to Exposure and Medical Records and Recordkeeping standards, or similar state requirements.
This includes injury and illness records (i.e., OSHA 300 Logs). Employees should contact their
supervisor or another member of management for more information.

For further information on employee safety and health rights under the law, employees should read
OSHA’s “It’s the Law” poster which has been posted in each WEST POINT ROOFING facility.

-------------------------------------------

Note: See “Injury / Incident Reporting Form” located in the “Appendices and Forms” section.

8
 Accident Investigation
It is the policy of WEST POINT ROOFING that all incidents, accidents and near-miss events be
thoroughly investigated by the project Superintendent or his/her appointee(s), as soon as
reasonably possible following the event.

A thorough and properly conducted investigation is necessary to obtain facts. The investigation
should focus on the root cause(s) of the incident to prevent recurrence, not to assign blame.

An accident investigation report should contain, at a minimum, the following items:

• Individuals and contractors involved.

• Worksite information – address of jobsite, employee occupation, weather conditions, any
unusual circumstances or activities, etc.
• Accident data – information what the employee was doing, how the accident occurred, who
was injured and where. Diagrams, photos, video footage, etc. should be included.
• Witnesses-names of eyewitnesses and their independent statements.
• Safety rules – what safety rules were in effect, which rules in effect were not followed and
what could have been done to prevent the accident.
• Analysis – primary, secondary and contributory causes of the accident.
• Corrective action – steps to be taken to prevent recurrence of the event or similar incidents.

Upon completion, the final investigative report and related materials must be submitted to the
corporate office. Through detailed analysis of the results, accident patterns and improvement
opportunities may be detected, and resources directed toward future prevention.
First Aid / Employee Injury

• If an employee is injured, WEST POINT ROOFING’s Superintendent must be immediately

notified.

• If applicable, do not allow the injured party to move themselves or be moved (unless imminent
danger is present).

• First aid and/or medical facilities will be made available to employees.

• First aid kits must always be adequately stocked, readily accessible and located in all WEST
POINT ROOFING offices (main office and each project site) or in the Superintendent’s
vehicle, in the absence of a project site office. Travel team members should carry basic first
aid kit in their company vehicle.

• Only people having been trained in Basic First Aid / CPR or beyond, shall administer first aid
to the injured party.

• Prior to beginning work on a new project site, WEST POINT ROOFING will ensure that
emergency response assistance is available, such as calling “911” for ambulance or fire.
Should 911 service be unavailable, the company will arrange for alternative transportation of
injured personnel to the appropriate, predetermined medical clinic or emergency facilities.

• Remember, the most important issue in this situation is the care and treatment of the injured
person(s).

Property Damage:

• Any property damage resulting from a project site incident must be immediately reported to
WEST POINT ROOFING, regardless of who the owner of the property is, or the parties who
appear to be involved in the incident.

• This section includes, but is not limited to the following properties being damaged:

1. Utility lines or pipes (above or below ground)

2. Contractor vehicles located on site
3. Equipment / tools
4. Project site trailers / offices
5. Project site fencing / barricades

• Depending on the nature of the damage, some incidents involving property damage may
require an immediate employee evacuation.
Appendix A

Public Property Damage:

• In the event that public owned property is damaged resulting from WEST POINT ROOFING
activities, the following items at a minimum, should be noted:

✓ Time of incident
✓ Location of incident
✓ Contractor(s) involved
✓ Cause of incident (if known)
✓ Extent of damage sustained
✓ If property is a vehicle: obtain vehicle identification number, license plate number
and state, color, make and model
✓ Property owner’s name, home address and phone number
✓ Any abnormal weather conditions or unusual jobsite circumstances

• The person collecting the above listed information must not admit guilt or make corrective
recommendations. Simply collect the information.

Weather Related Emergencies:

• When experiencing lightning, severe thunderstorms, flooding or tornado threatening weather,

WEST POINT ROOFING will warn all its employees of the current weather conditions, as
well as closely monitor up to the minute forecasts and instructions issued by local and state
authorities, local media and/or the National Weather Service.

• When seeking shelter from a tornado, the preferred choice should be as far below the ground’s
surface as possible (cellar, basement, ditch, protected excavations, covered parking garages,
etc.). If inside a building, all windows and doors shall remain open.

• Employees should avoid using equipment and small structures as a means of shelter from a
tornado, nor should they position themselves in an area where there are materials, tools or
equipment being stored nearby or overhead.

This emergency action plan will be periodically reviewed to ensure that the policies outlined above
remain effective and applicable, when faced with an emergency. In the event that this policy is
altered, all effected employees will be notified of the amendments and receive new emergency
training if necessary to comply with the plan.

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Appendix A

Heat Illness Prevention Plan

Scope and Application for WEST POINT ROOFING

This section applies to the control of risk of occurrence of heat illness on WEST POINT
ROOFING projects. Supervisors have been informed on how to monitor weather reports and how
to respond to hot weather advisories. Preventing these symptoms is the key in keeping all our
employees healthy & safe.

Definitions

“Acclimatization” means temporary adaptation of the body to work in the heat that occurs
gradually when a person is exposed to it. Acclimatization peaks in most people within four to
fourteen days of regular work for at least two hours per day in the heat.

“Heat illness” means a serious medical condition resulting from the body's inability to cope with
a particular heat load, and includes heat cramps, heat exhaustion, heat syncope and heat stroke.

“Environmental risk factors for heat illness” means working conditions that create the
possibility that heat illness could occur, including air temperature, relative humidity, radiant heat
from the sun and other sources, conductive heat sources such as the ground, air movement,
workload severity and duration, protective clothing and personal protective equipment worn by
employees.

“Personal risk factors for heat illness” means factors such as an individual's age, degree of
acclimatization, health, water consumption, alcohol consumption, caffeine consumption, and use
of prescription medications that affect the body's water retention or other physiological responses
to heat.

“Shade” means blockage of direct sunlight. One indicator that blockage is sufficient is when
objects do not cast a shadow in the area of blocked sunlight. Shade is not adequate when heat in
the area of shade defeats the purpose of shade, which is to allow the body to cool. For example, a
car sitting in the sun does not provide acceptable shade to a person inside it, unless the car is
running with air conditioning. Shade may be provided by any natural or artificial means that does
not expose employees to unsafe or unhealthy conditions.

“Temperature” means the dry bulb temperature in degrees Fahrenheit obtainable by using a
thermometer to measure the outdoor temperature in an area where there is no shade. While the
temperature measurement must be taken in an area with full sunlight, the bulb or sensor of the
thermometer should be shielded while taking the measurement, e.g., with the hand or some other
object, from direct contact by sunlight.

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Appendix A

Drinking Water

Employees will have access to potable drinking water meeting the requirements applicable. On
job sites where drinking water is not plumbed or otherwise continuously supplied, WEST POINT
ROOFING will supply sufficient quantity of water at the beginning of the work shift to provide
one quart per employee per hour for drinking for the entire shift. WEST POINT ROOFING
may begin the shift with smaller quantities of water if they have effective procedures for
replenishment during the shift as needed to allow employees to drink one quart or more per hour.
The frequent drinking of water will be encouraged by WEST POINT ROOFING management.
Travel employees should purchase water prior to being on a roofing install site.

Access to Shade

WEST POINT ROOFING employees are allowed and encouraged to take a cool-down rest in
the shade for a period of no less than five minutes at a time when they feel the need to do so to
protect themselves from overheating. Such access to shade is permitted at all times.

Cooling measures other than shade (e.g., use of misting machines) may be provided in lieu of
shade if upon approval by WEST POINT ROOFING where these measures are at least as
effective as shade in allowing employees to cool.

High-Heat Procedures

WEST POINT ROOFING will implement high-heat procedures when the temperature equals or
exceeds 95 degrees Fahrenheit. WEST POINT ROOFING procedures will include the following
to the extent practicable as determined by the supervisor:

• Where practicable, WEST POINT ROOFING will ensure that effective communication
by voice, observation, or electronic means is maintained so that employees at the work site
can contact a WEST POINT ROOFING supervisor when necessary. An electronic
device, such as a cell phone or text messaging device, may be used for this purpose only if
reception in the area is reliable.

• Where practicable, WEST POINT ROOFING will observe employees for alertness and
signs or symptoms of heat illness through direct supervisor observations and/or regular
communications with sole employees by radio or cellular phone.

• WEST POINT ROOFING authorizes any employee to call for emergency medical
services, should the need arise.

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Appendix A

Emergency Response Procedures

WEST POINT ROOFING supervisors and employees will follow the procedures set forth in the
Emergency Action Plan section of the Corporate Safety Program, detailing all requirements as it
relates to emergency situations that require medical attention and employee transport.

Acclimatization

Acclimatization is the temporary and gradual physiological change in the body that occurs when
the environmentally induced heat load to which the body is accustomed is significantly and
suddenly exceeded by sudden environmental changes. In more common terms, the body needs
time to adapt when temperatures rise suddenly, and an employee risks heat illness by not
temporarily reducing work intensity when a heat wave strikes or when starting a new job that
exposes the employee to heat to which the employee’s body hasn’t yet adjusted. Inadequate
acclimatization can be significantly more perilous in conditions of high heat and physical stress.

WEST POINT ROOFING supervisors will regularly perform the following to ensure employees
are appropriately acclimated to their working conditions:

1. Be on the lookout for sudden heat wave(s) or increases in temperatures to which employees
haven’t been exposed to for several weeks or longer.

2. Be extra-vigilant and closely supervise new employees for the first 14 days of the
employee's employment with WEST POINT ROOFING, unless the new employee
indicates at the time of hire that he or she has been doing similar outdoor work for at least
10 of the past 30 days for 4 or more hours per day.

3. Stay alert to the presence of heat related symptoms.

4. Monitor weather reports provided through agencies such as the National Weather Service
at www.nws.nooa.gov/, or by calling the National Weather Service telephone numbers
below, the Weather Channel TV Network, or other local news and weather stations on TV
and/or radio.

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Appendix A

Training

All Employees

WEST POINT ROOFING will provide training to all affected employees (supervisory and non-
supervisory) in the following topics, prior to them beginning work that should reasonably be
anticipated to result in exposure to the risk of heat illness:

1. The environmental and personal risk factors for heat illness, as well as the added burden of
heat load on the body caused by exertion, clothing, and personal protective equipment.

2. The importance of frequent consumption of small quantities of water, up to 4 cups per hour,
when the work environment is hot and employees are likely to be sweating more than usual
in the performance of their duties.

3. The concept, importance, and methods of acclimatization pursuant to WEST POINT

ROOFING’s procedures.

4. The different types of heat illness, the common signs and symptoms of heat illness, and
appropriate first aid and/or emergency responses to the different types of heat illness, and
in addition, that heat illness may progress quickly from mild symptoms and signs to serious
and life-threatening illness.

5. The importance of employees to immediately report to WEST POINT ROOFING,

directly or through the employee's supervisor, symptoms or signs of heat illness in
themselves, or in co-workers.

6. WEST POINT ROOFING’s procedures for responding to signs or symptoms of possible

heat illness, including how emergency medical services will be provided should they
become necessary.

7. WEST POINT ROOFING’s procedures for contacting emergency medical services, and
if necessary, for transporting employees to a point where they can be reached by an
emergency medical service provider.

8. WEST POINT ROOFING’s procedures for ensuring that, in the event of an emergency,
clear and precise directions to the work site can and will be provided as needed to
emergency responders. These procedures shall include designating a person to be available
to ensure that emergency procedures are invoked when appropriate.

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Appendix A

Injury and Illness Prevention Program (OSHA)

Introduction

The IIPP is intended to augment WEST POINT ROOFING’s Corporate Safety Program. It
does not take the place of the company’s Corporate Safety Program. It is simply one piece of the
overall safety program.

Any questions pertaining to the Injury and Illness Prevention Program should be directed to the
WEST POINT ROOFING Safety Manager in the corporate office addressed below:

Corporate Headquarters:

WEST POINT ROOFING

7346 S Alton Way Unit 10-I Centennial, CO 80112

Injury & Illness Prevention Program

16
Appendix A

Table of Contents

Section I: Management Commitment & Assignment of Safety Responsibilities

Section II: Communication of Safety & Health Matters

Section III: System for Assuring Employee / Subcontractor Compliance with Safe Work
Practices

Section IV: Scheduled Inspections / Evaluation System

Section V: Accident Investigation & Reporting Procedure

Section VI: Procedures for Correcting Unsafe / Unhealthy Conditions

Section VII: Safety and Health Training and Instruction

Section VIII: Recordkeeping and Documentation

Section IX: Code of Safe Practices

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Appendix A

Section I: Management Commitment & Assignment of Safety

Responsibilities

Safety Policy

The purpose of the Company Injury and Illness Prevention Program (IIPP) is to establish a safety
culture that demonstrates management’s firm commitment to worker safety as an integral part of
conducting business. It is the intent of the Company to foster and promote the concept of an
injury free environment for employees. One of our company's safety goals calls for the
elimination of unsafe acts, unsafe conditions and of near-miss incidents on our job-sites.

Our safety goals will be accomplished with a collaborative team effort between management,
and field employees, and personal commitment to the success of this IIPP by all employees.

Following this plan will help employees reduce at-risk behaviors and eliminate unsafe job
conditions. Furthermore, it will facilitate cooperation and communication within the company.
Every employee is expected to perform their work in a safe manner.

All site supervisory personnel are responsible for the actions of those whom they supervise, and
are responsible for maintaining safe and healthy working conditions in their areas of
responsibility. Therefore, they will be held accountable for strict enforcement of all safety rules
and regulations.

To effectively motivate employees, and to monitor safe work practices, all levels of company
personnel will become familiar with this IIPP.

The Safety Administrator for the company IIPP is the WEST POINT ROOFING Safety
Manager (HSM). The HSM will be assisted with these duties by field supervisors and other
personnel as necessary.

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Appendix A

Introduction

The company has developed and implemented this written IIPP as part of our Corporate Safety
Program. The work by employees, is varied, both in nature and location. Under all
circumstances, it is the intent of the company to comply with the requirements and spirit of the
State Code of Regulations, other State Plan Regulations, Federal OSHA Regulations and any
other applicable safety regulations.

It is the company’s intent to provide an injury-free environment to employees. Accordingly, the

company has implemented this IIPP in compliance with Senate bill 198, encoded as Labor Code
6401.7. The company expects all employees to follow the requirements set forth in this IIPP.

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Appendix A

Responsible Person – 8 CCR 3203(A)(1)

WEST POINT ROOFING has designated its Employee Health and Safety Manager, Nathan
Campbell as the responsible person for the IIPP. It is the responsibility of this person to ensure
overall implementation for the IIPP. In addition, each level of WEST POINT ROOFING
management has the responsibility for the enforcement of this IIPP at the job-site.

The duties of the Responsible Person are to:

1. Identify and evaluate workplace hazards, including procedures for investigating occupational
injuries and illnesses.

2. Establish and/or review methods or procedures for correcting unsafe and unhealthy conditions
and work practices.

3. Ensure that employees receive training programs on general and specific safety and health
practices at time of hire and on each of their job assignments.

4. Ensure that there is a procedure for communicating to employees, in an understandable

manner, the company's safety and health rules and procedures.

5. Adopt a written Code of Safe Practices that relates to our business operations and ensures
compliance with safe and healthy work practices.

6. Ensure that records on training, inspection, corrective measures are properly maintained, as
required by this IIPP and other required programs in accordance with OSHA and other
regulatory agencies.

Jobsite Management’s safety responsibilities for this IIPP are as follows:

1. Know and enforce the safety rules and policies / procedures.

2. Manage safety on the job-site by taking the necessary actions to provide employees and
subcontractors with an injury-free work environment.

3. Recognize and/or reward employees, where appropriate, for following the safety rules and
policies / procedures.

4. Ensure safety is communicated to employees and subcontractors in an understandable manner

via training, postings, personal contacts, and other forms of communication as appropriate.

5. Conduct safety inspections on the job-site and document unsafe acts and conditions and take
the steps necessary to control / eliminate them in your project daily diaries.

6. Conduct investigations of all incidents, with documentation of each investigation.

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Appendix A

7. Document any ‘safety violations’ and work orders that are issued to employees or
subcontractors for unsafe conditions and unsafe acts, and that they are completed, including
dates of correction noted.

8. Maintain bulletin board(s) with current safety and health materials, required postings, and other
matters to be communicated to employees.

9. Attend or participate in all company safety training meetings, group or electronic media, when
conducted / requested, and stay current on safety and health matters as they relate to the
company.

Company and Temporary Employee IIPP safety responsibilities:

1. Promptly report any unsafe conditions you find to management.

2. Follow all safety rules and policies / procedures.

3. Immediately report all injuries, no matter how slight, to management.

4. Attend / participate in all safety training as requested.

5. Review the safety bulletin board(s) periodically.

6. Attend a safety orientation meeting upon hire / rehire, which covers the company’s Safety
Program key points.

7. Sign and acknowledgement form confirming your agreement to follow the Company Safety
Program and its rules, policies and procedures.

Subcontractors’ IIPP safety responsibilities:

1. Observe all FED/ OSHA Standards / Safety Orders, company safety program / policies and
any additional job-site specific safety policies, rules and requirements per contract.

2. Provide properly trained ‘Competent Persons’ on all jobsites for exposures and hazards for
work activities that involves falling from elevated work surfaces, excavations, scaffolding,
electrical safety and any / all other ‘hazardous activities’ that meet or exceed FED/ OSHA
training requirements. jobsites

3. Provide the necessary ‘safety training’ to supervisors or craft employees to meet or exceed
FED/ OSHA Standards / Safety Orders and/ or job-site specific safety policies, rules and
requirements per contract.

4. Ensure all subcontractor craft personnel are equipped with and properly use the required safety
and/or personnel protective equipment to meet or exceed FED/ OSHA Standards / Safety
Orders or job-site specific safety policies, rules and requirements.

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Appendix A

5. Notify job-site project management team promptly of ‘imminent danger’, ‘serious hazards’
and ‘other than serious hazards’ in the workplace that could harm, injure or pose an ‘imminent
danger’ to construction personnel.

6. Upon request, provide the company with subcontractor employee safety training
documentation records, safety inspection and/or maintenance records for cranes, written
company safety policies including written Hazard Communication policy including SDS and
any other safety records specifically requested for.

7. Provide basic First Aid care to their workers on the job-site and/or medical care for more
serious injuries that can not be treated at the job-site Each subcontractor must have ‘First Aid’
trained person(s) on site, that meets OSHA Standards / Safety Orders. ‘First Aid’ trained
personnel are to maintain their ‘certification’ and not allow it to expire.

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Appendix A

Section II: Communication of Safety & Health Matters

The company has an ongoing commitment to safety and injury prevention. A communication
program to carry out this commitment has been implemented to establish and maintain safe work
habits in the workplace. A reporting program has been instituted for reporting safety issues to
job-site management, reporting accidents and investigating accidents.

Communication System

The following alternative means of communicating safety compliance information to employees

is provided:

1. Periodic job-site visits by authorized project management personnel.

2. Employee training programs.

3. Video / electronic media systems.

4. Posting of notices and/or bulletins.

5. E-mails, letters, and memo’s.

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Appendix A

Section III: System For Assuring Employee / Subcontractor

Compliance With Safe Work Practices
All employees and subcontractors are required to follow company safety policies and work
procedures. When needed, company employees will be provided with additional training and
information, or retraining, to maintain their knowledge.

The discipline policy of the company is intended to encourage employee and subcontractor
compliance with the IIPP. The company reserves the right to discharge employees or
subcontractors found performing work in an unsafe manner that would endanger job-site
construction personnel. The supervisor will determine the course of action best suited to the
circumstances. The steps to be taken at a minimum will include:

DISCIPLINARY PROCEDURES:

Verbal Warning

As the first step in correcting unacceptable behavior, the supervisor will review the pertinent
facts about the safety infraction with the employee / subcontractor. The supervisor will consider
the severity of the problem and the employee’s / subcontractor’s past safety performance. A
verbal warning will be issued to the employee / subcontractor, which will be documented by the
supervisor in the employee / subcontractor’s file.

Written Warning

If the unacceptable performance continues with the employee / subcontractor, the next step will
be a written warning. The written warning will clearly state the safety policy that was violated
and the steps the employee / subcontractor must take if it is to be corrected. A probationary
period may be part of the written warning. It may also include time off without pay, stopping a
subcontractors work in progress or dismissal of a subcontractor’s employee from the job-site. It
may require completion of a training / retraining session within the probationary period, with
documentation of training / retraining. At completion of the probationary period, the supervisor
will meet with the employee / subcontractor to determine if the employee / subcontractor has
achieved the required level of performance.

Termination

The employee / subcontractor may be terminated if the person / subcontractor does not improve
their performance while on probation or has violated another company safety policy within two
(2) months following the initial safety infraction. The project’s manager must be informed of the
seriousness of the safety infractions involving subcontractors.

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Appendix A

Section IV: Scheduled Inspections / Evaluation System

Initial Jobsite Inspection

An initial inspection to identify and evaluate workplace hazards was planned for and/or
conducted when this IIPP was initiated and will be conducted whenever new substances, jobs,
processes, procedures, material or equipment are introduced into the workplace, that represents a
new occupational safety and health hazard. An initial inspection will also be conducted when the
company is made aware of any new or previously unrecognized hazards. All inspections of
reported or discovered hazards will be made in a timely manner based on the severity of the
hazard.

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Appendix A

Section V: Accident Investigation & Reporting Procedure

The purpose of an incident / accident investigation is to find the ‘root cause’ of the incident /
accident and prevent further occurrences, not assign blame. A thorough and properly completed
incident / accident investigation is necessary to obtain facts. The investigation should focus on
causes and hazards. Analysis of what happened and why it happened is aimed at determining
how it can be prevented in the future.

Injury & Illness

The investigation should be completed promptly and documented in an incident report. This
electronic ‘Incident Report’ must be completed promptly and submitted within 24 hours of the
occurrence or being notified. Provide as much information as possible in the report and attach
pictures. Incident reports are required for a subcontractor employee injured on the job. Scan the
subcontractors ‘accident investigation report’ and attach it to the incident report. If you need any
assistance with completing these electronic reports, please contact the corporate office.

Other Accidents & Incidents

The majority of accidents do not cause injury or illness, yet result in property damage and/or lost
time. Such mishaps usually indicate an unsafe act, faulty procedure or hidden hazard.
Investigations of these occurrences are conducted at the discretion of the job-site supervisor,
program administrator or designee. All investigation facts, findings and recommendations will
be fully documented on the Incident Report. This report is filed in accordance with the
instructions in Record Keeping

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Appendix A

Section VI: Procedures For Correcting Unsafe / Unhealthy

Conditions
All recognized safety and health hazards must be abated in a timely manner based on the severity
or risk posed by the hazard. Following the discovery of the workplace hazard, the supervisor
will ensure one of the following steps being taken on the findings of the severity of the hazard:

1. If an accident is caused by a recognized hazard, the supervisor / subcontractor will direct the
appropriate personnel to correct the hazard.

2. When an ‘imminent danger’ hazard exists which cannot be immediately corrected without
endangering employees, subcontractors personnel and/or property, only personnel who are
properly trained and equipped to make the necessary repairs will be allowed to perform work
in the affected area or on the affected equipment. Employees or subcontractors necessary to
correct the hazardous condition will be provided the necessary safeguards. No other employee
/ subcontractor will be allowed in the affected area or on the affected equipment until the hazard
is corrected.

3. If the workplace hazard is a result of an improper procedure, the supervisor and/or

subcontractor will develop an alternative work procedure so as to reduce the likelihood of
another accident.

4. If the workplace hazard is the result of a human error or carelessness, the supervisor /
subcontractor will conduct the appropriate training of affected personnel and reprimand the
appropriate personnel if warranted.

5. Documentation of the corrective measures will be maintained with the associated report that
disclosed the hazard.

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Appendix A

Section VII: Safety & Health Training and Instruction

Training is essential to maximizing the skills and knowledge of company employees. It is the
key to productivity. Supervisors must know how to perform a designated job, and be aware of
safety and health hazards facing employees / subcontractors under their immediate supervision.
Supervisors are responsible for ensuring that they themselves and those under their direction
receive training on general workplace safety, as well as safety and health issues specific to each
job.

The program administrator or designee will determine the training topics and needs of the
supervisors / jobsite supervisory personnel. Training needs may include human relations, trainer
skills, production/process skills, and familiarization with hazards and risks faced by employees /
subcontractors. Supervisors who recognize their own need for training are encouraged to submit
a direct request to their superior or the Safety Manager for training in any area in which they feel
deficient.

The company recognizes that continuing safety and health training is needed for:

1. Familiarization with hazards and risks faced by the employees / subcontractors under the
Supervisors direction.

2. Whenever new substances, processes, procedures or equipment pose a new hazard.

3. Whenever the supervisor, program administrator, subcontractor or designee becomes

aware of the previously unrecognized hazard.

4. All employees in a periodic refresher safety training involving general workplace safety,
job-specific hazards, and/or hazardous materials as applicable.

5. All training will be documented in electronic format either on the training resource student
repository or in other company files

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Appendix A

Section VIII: Recordkeeping & Documentation

No operation can be successful without recordkeeping that enables our company to learn from
past experience and make corrections for future operations. In addition, the IIPP regulation
requires records to be kept of the steps taken to establish and maintain the IIPP.

IIPP RECORDS

Supervisors will maintain an updated copy of the IIPP at the corporate office. The program
administrator or designee will retain the following records for at least three (3) years:

1. Master copy of the IIPP, with all changes or updates.

2. Documents verifying that the company has maintained on going two-way communication
with employees and subcontractors. Documents can include memo’s, letters to employees
on safety and health issues

3. New employee safety orientation session acknowledgment form

4. All records of inspections / investigations

The inspection / investigation, unsafe conditions and work practices identified, corrective action
taken and date of correction forms:

1. Electronic Incident Accident report.

2. Meeting Minutes from subcontractors / owners meetings.

Records of Safety & Health training received by company employees containing the employee’s
name, training date, type of training and identification of trainer, examples include:

1. Computer e-Learning System

2. First Aid & CPR Training

3. OSHA 10 and/or 30 Hour Construction Outreach Programs

29
Appendix A

Section IX: Code of Safe Practices

The company has adopted a Code of Safe Practices that relates to our business operation as a
general contractor. All company employees will administer the Code of Safe Practices for the
jobsite. This Code of Safe Practices is posted in a conspicuous location at each job-site office or
WEST POINT ROOFING operated facility and is made available to employees.

The company is committed to providing their employees, temporary workers and subcontractors
a safe workplace. The field management team and supervisor are informed and knowledgeable
of the OSHA IIPP requirements and will enforce the following requirements:

1. Verifying trade subcontractors are adhering to and complying with all applicable OSHA
safety Construction Orders where applicable.

2. Verifying trade subcontractors are adhering to and complying with all applicable company
site specific safety rules.

3. Enforce all OSHA Standards / Construction Orders and company safety rules &
disciplinary procedures with company employes and contractors.

4. Have available first aid or medical treatment clinics for work related injuries.

5. Enforce the safe use and maintenance of all company tools, machinery and/or equipment.

6. Wear the proper personal protective equipment required for the work.

7. Report unsafe conditions to subcontractors and abate the hazard promptly.

8. Drive motor vehicles safely on the jobsite.

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Appendix A

Scaffolding
WEST POINT ROOFING has adopted the following guidelines, in order to protect employees
from hazards associated with the usage of scaffolding. These policies are mandatory and must be
complied with by all employees.

• A competent person before each work shift, and after any occurrence, which could affect a
scaffold’s structural integrity, shall inspect scaffolds and scaffold components for visible
defects.

• Each platform on all working levels of scaffolds shall be fully planked or decked between the
front uprights and the guardrail supports.

• Each scaffold platform and walkway shall be at least 18 inches wide.

• Each end of a platform unless cleated or otherwise restrained by hooks or equivalent means,
shall extend over the centerline of its support at lease 6 inches.

• Each end of a platform, 10 feet or less in length shall not extend over its support more than 12
inches.

• On scaffolds where platforms are overlapped to create a long platform, the overlap shall occur
only over supports, and shall not be less than 12 inches, unless the platforms are nailed together
or otherwise restrained to prevent movement.

• Vertical ties/braces shall not exceed a 4:1 ratio with the base width of the scaffolding (i.e., if
the base width of the scaffolding system is 5’, then vertical ties must be installed in no more
than 20’ increments). Horizontal increments for ties shall not exceed 30 feet.

• Supported scaffold poles, legs, posts, frames and uprights shall bear on base plates, mudsills
or other adequate firm foundation. Footings shall be level, sound, rigid and capable of
supporting the loaded scaffold without settling or displacement. Unstable objects shall not be
used to support scaffolds or platform units. Unstable objects shall not be used as working
platforms.

• A ladder or equivalent safe access shall be provided on all scaffolding systems. If a ladder is
used, it must extend 3’ above the landing or platform that is being accessed. It must also be
secured to the scaffolding system to prevent displacement.

• Employees are prohibited from working on scaffolds covered with snow, ice or other slippery
material except as necessary for removal of such materials.

• A guardrail system consisting of a toprail, midrail and toeboards (where necessary) shall be
installed on all open sides and ends of scaffolding that is at or above a height of 10 feet.

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Appendix A

• Cross bracing can be used in lieu of a toprail or a midrail, but not both.

Aerial / Scissor Lifts

(Technically considered scaffolding)
General Requirements:

• Only authorized persons shall operate an aerial or scissor lift.

• All lifts should be equipped with operator’s manual and / or checklist. All operators should
become familiar with and fully comply with all manufacturers’ safety instructions.

• A placard or sign identifying the lift’s load capacities must be displayed somewhere on the lift.
Maximum weight capacities of the lifts should never be exceeded under any circumstances.

• Lift operators should never ignore, disable or alter an installed safety device, switch or alarm.

• Lift operators must be conscious of their surroundings, with respect to pedestrian traffic and
nearby activities on the ground near the base of the lift.

• Lift controls shall be tested each day prior to use to determine that such controls are in safe
working condition.

• All materials, tools or components being elevated in the lift, must remain on the floor and not
so positioned that they are protruding through the handrails, or could fall from the lift.

• Lifts should only be operated on flat, level surfaces.

Fall Protection Requirements while Operating Lifts:

• Employees working from scissor-lifts / aerial lifts must remain on the floor of the basket at all
times and shall not sit or climb on the edge of the basket or use planks, ladders or other devices
for a work position.

• In aerial lifts, personal fall arrest systems (full-body harness and 6’ shock-absorbing lanyard)
must be used and secured to the boom or basket during lift operation. The usage of personal
fall arrest systems in scissor lifts is not required.

• Tie off to the boom or basket only (not to anything outside the basket).

• Body belts are not allowed for fall protection equipment, they may be used for positioning
work only.

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Appendix A

• Fall arrest systems must be inspected prior to each use for wear, damage and other
deterioration.

• Ensure all buckles and straps of body-harnesses are secured and snug against your body.

• Never climb up the side of the lift to enter it. Always use the steps located at the base of the
lift, or equivalent, to gain access to the platform.

• Keep the end gate or chain secured at all times during use. This acts as a midrail and is
necessary to protect employees from a fall hazard.

• Remain tied off at all times while in the basket (aerial lifts only).

• Never connect two (2) lanyards together to make one longer lanyard.

• Always use a “locking” type snaphook.

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Appendix A

Fall Protection / Prevention

It is the policy of WEST POINT ROOFING to take all practical measures possible to prevent
our employees and subcontracted employees from being injured by falls from heights. The
company will take necessary steps to eliminate, prevent and control fall hazards. The first priority
is given to the elimination of fall hazards. If a fall hazard cannot be eliminated, effective fall
protection will be planned, implemented and monitored throughout the course of the project, in
order to control the risks of injury due to falling.

Specifically, WEST POINT ROOFING’s fall protection policy requires employees and
subcontractors on all projects to be protected from fall hazards by fully complying with all
applicable Occupational Safety and Health Administration (OSHA) standards pertaining to fall
protection.

All exposed employees will be protected from fall hazards via the usage of one or more of the
following OSHA compliant systems: personal fall arrest, guardrail, safety net or warning line.

Tool and Equipment Safety

Each Superintendent and foreman is responsible for the safe use of hand tools, power tools,
power actuated tools, mechanized and all other machines and equipment. All operations will
confirm to the safety requirements of all federal, state and local codes.

Machinery and Mechanized Equipment

1. All machinery and mechanized equipment shall be inspected, tested and determined to be in
safe operating condition prior to use.

2. Any machinery or equipment determined to be in an unsafe operating condition shall be

marked or tagged, "Out of Service, Do Not Use" and its use shall be prohibited until the
unsafe conditions have been corrected.

3. Only qualified and trained operators will be allowed to operate machinery and or
mechanized equipment.

4. Hoisting of personnel on machinery or mechanized equipment is expressly prohibited unless

the machinery or mechanized equipment is designed to do so.

5. A full body harness with shock absorbing lanyard shall be worn and attached to the boom or
the basket when working from an aerial lift.

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Appendix A

6. Personnel on material handling equipment other than the operator are strictly prohibited.

Hand Tools

1. Only authorized personnel may use hand tools.

2. All hand tools shall be kept in good repair and safe condition, including tools and equipment,
which may be furnished by employees.

3. Hand Tools shall not be left on scaffolds, ladders or overhead working spaces when not in
use.

4. Moving tools from one location to another shall be done in a manner so as not to jeopardize
safety. Dropping tools from overhead to ground, and throwing tools from one employee to
another is expressly forbidden.

5. Only non-sparking tools shall be used in areas where sources of ignition may cause fire or
explosion.

6. Any damaged or malfunctioning tool will be removed from service when discovered, and not
returned to service until repaired or replaced.

Power Operated Tools

1. Only authorized personnel will be allowed to use power tools.

2. All power tool operators shall wear appropriate eye protection while operating power tools.

3. Electric tools will be provided with grounding connections or doubly insulated cases.

4. Electric power tools operated in wet areas expose the operator to greater shock hazard. Wet
areas should be avoided when using electric power tools.

5. Electric power tools shall be disconnected when changing attachments, making adjustments or
repairing.

6. All power cables shall be frequently checked for wear, breaks in the insulation and missing
grounding connection. Defective cables shall be repaired or replaced immediately. If not, the
equipment must be taken out of service until it has been repaired.

7. Electric power equipment shall not be used when the guarding system has been removed or in
any way tampered with.

8. Gasoline driven power tools shall not be used in an unventilated areas.

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Appendix A

Ladder & Stair Safety

Some of the most commonly used pieces of equipment in the construction industry are stairs and
ladders. Although they are very simple devices, if used incorrectly they can be very dangerous.

A stairway or ladder shall be provided at all personnel points of access where there is a break in
elevation of 19 inches or more and no ramp, runway, sloped embankment or personnel hoist is
provided. WEST POINT ROOFING has adopted the following safe work practices and
procedures, which are required to be implemented by all employees who use ladders and/or stairs.

Ladders

• A double-cleated ladder or two or more separate ladders shall be provided when ladders
are the only means of access or exit from a working area for 25 or more employees or when
a ladder is to serve simultaneous two-way traffic.

• Extension ladders shall be placed with a secure footing and tied or otherwise positioned to
prevent displacement.

• Extension ladders must be long enough for the intended job and extend at least 3 feet above
the access point.

• Always face the ladder when climbing up or down.

• Employees must use both hands and both feet when ascending and descending ladders.

• Use the 4-to-1 rule when putting an extension ladder into position (for every 4 feet of
vertical rise, there should be a 1 foot horizontal distance between the wall and the base of
the ladder).

• Short ladders shall never be spliced together to make long ladders.

• Ladders shall never be used in the horizontal position as scaffolds or work platforms.

• Never use a stepladder in place of an extension ladder. Stepladders are designed to be

opened completely with their leg supports locked into position.

• Employees must never stand on the top two steps of a step ladder

• Wooden ladders must never be painted, and kept clean of oil, grease or other slippery
materials.

• Do not use damaged or broken ladders, or ladders without safety feet.

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Appendix A

• When working from a ladder, do not lean or reach out beyond arm’s length to either side.
Move the ladder.

• Ladders shall be inspected by a competent person for visible defects on a periodic basis
and after any occurrence that could affect their safe usage.

• Ladders shall have nonconductive side rails if they are used where the employee or the
ladder could contact exposed energized electrical equipment.

• Ladders shall not be loaded beyond the maximum intended load for which they were built,
not beyond their manufacturer’s rated capacity.

➢ Type 1A – 300 lbs.

➢ Type 1 – 250 lbs.
➢ Type 2 – 225 lbs.
➢ Type 3 – 200 lbs.

Stairs

• Stairways having four or more risers or rising more than 30 inches, whichever is less, shall
be equipped with:

1. At least one handrail; and

2. One stairrail system along each unprotected side or edge.

• The height of handrails shall be not more than 37 inches not less than 30 inches from the
upper surface of the handrail to the surface of the tread, in line with the face of the riser at
the forward edge of the tread.

• Stairrails must be at least 36” from tread to top of rail.

• Midrails must be located halfway between the top rail and the steps.

• Handrails and stairrails must be able to support a force of 200 lbs. applied in any downward
or outward direction.

• Handrails and stairrails must be surfaced to prevent punctures / cuts, and to prevent
snagging of clothing.

• Ends of stairrails and handrails shall not create a projection hazard.

• A 3-inch clear space must be provided between handrails and walls, stairrail systems, or
other objects.

• Employees must not run up or down stairs; or jump from landing to landing. Walk down
stairs normally.

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Appendix A

• All stairways must be installed at an angle between 30 and 50 degrees from horizontal.

• Where doors or gates open directly on a stairway, a platform shall be provided and the
swing of the door shall not reduce the effective width of the platform to less than 20 inches.

• Spiral stairs are not permitted unless they are a permanent part of the structure.

• Stairway access points must be kept clear for free passage.

• The riser height and tread depth (usually 6-1/2” to 11” respectively) must be uniformly
spaced. There can be no variations over ¼ inch for any stairway.

• Metal pan landings and treads must be secured in place before filling them with concrete
or other materials.

• All stairs must be kept free of hazardous projections and slippery conditions.

• Skeleton metal pan stairways cannot be used as a means of travel until the stairs are filled
with temporary treads and landings, made of solid materials, which have been installed the
full width and depth of the stair system.

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Appendix A

General Safety Policies / Procedures

Personal Protective Equipment

1. Hard hats shall be worn at the discretion of the employees are on the project site

2. Safety Glasses must be worn when:

a. Grinding
b. Chipping welds
c. Wire brushing
d. Sawing
e. Working with any chemical or doing any work where chips, sparks, dust or foreign
matter might injure eye

3. Sturdy leather work boots or shoes must be worn by employees at all times, while working
on any project site.

Material Handling

1. Use proper lifting techniques when handling materials:

a. Get down close to the load.

b. Keep your back straight.

c. Lift gradually. Use your legs; do not jerk or twist.

d. Get help for heavy, bulky or awkward loads.

2. If when carrying or pushing a load it should become unbalanced and start to fall, let it fall
clear, rather than risk strain or injury trying to balance it.

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Appendix A

Return to Work Program

It is the policy and goal of WEST POINT ROOFING to provide a safe and healthful workplace
for all its employees. Although we strive to eliminate hazards in the workplace and due to the
inherent danger of the construction industry, some exposures remain. When these hazards are
identified, WEST POINT ROOFING will take immediate action to reduce or eliminate the
exposure.

If a job related injury is reported, prompt first aid or medical treatment will be provided if
necessary. Once an employee has been treated and the extent of their injuries has been determined,
all injured employees are expected to return to work as soon as possible.

In accordance with WEST POINT ROOFING’s Return to Work Program, transitional duty will
be provided consistent with the doctor’s recommendation. The program is designed to provide
short-term transitional duty at no reduction in salary or benefits, until it has been determined by
the treating physician that the injured employee is able to return to full duty.

Employees assigned to transitional duty work assignments are expected to report to all follow-up
doctors appointments on time, on the date scheduled, unless previous arrangements have been
made with WEST POINT ROOFING. In addition, all employees placed on transitional duty are
expected to report to work on time each day as scheduled. Failure to do so may result in
disciplinary action or termination.

It is the responsibility of the injured employee, as well as WEST POINT ROOFING, to ensure
that while on transitional duty assignment, the employee does not exceed physical restrictions
outlined by the treating physician. In addition, it is also the responsibility of the employee to
follow the policies listed below:

• Promptly report a work related injury

• Provide accurate information to the treating physician concerning physical capabilities
• Communicate any concerns regarding the injury with WEST POINT ROOFING
• Fully cooperate with treatment and appointment schedules
• Return to full duty work as soon as possible

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Appendix A

Fleet Safety Program

Policy

Many employees operate company owned (including leased and rented) or personal vehicles as
part of their jobs. Employees are expected to operate vehicles safely to prevent accidents which
may result in injuries and property loss. It is the policy of WEST POINT ROOFING to provide
and maintain a safe working environment to protect our employees and the citizens of the
communities where we conduct business from injury and property loss.

WEST POINT ROOFING considers the use of vehicles as part of the working environment. The
company is committed to promoting a heightened level of safety awareness and responsible driving
behavior in its employees. Our efforts and the commitment of employees will prevent vehicle
accidents and reduce personal injury and property loss claims. This program requires the full
cooperation of each driver to operate their vehicle safely and to adhere to the responsibilities
outlined in this Fleet Safety Program.

Driver Qualifications

No driver will operate company owned vehicles nor be considered for employment in a driving
position, unless all of the below listed criteria are met:

• Minimum age of 21 years.

• Possession of a valid driver's license.

WEST POINT ROOFING will maintain a list of company employees who are authorized and
qualified to drive company owned vehicles. All others are prohibited from driving company
owned vehicles or personal vehicles on company business.

Current company drivers must immediately report the following to management:

• Any and all traffic violations and accidents for which they are ticketed (during business or
personal time);
• Any and all traffic violations for which they are convicted, or plead guilty or no contest to;
• Any change in driver’s license status including suspension, revocation or restriction.

Motor Vehicle Records Review

It is the policy of WEST POINT ROOFING to obtain motor vehicle records on all persons who
operate company vehicles or personal vehicles on company business every twelve (12) months.
MVRs will be obtained prior to employment for those individuals seeking positions that necessitate
the operation of a motor vehicle.

MVRs will become part of the individual’s personnel file and must be retained for a period of
twelve (12) months.

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Appendix A

In order to review an MVR, permission must be obtained from the employee or prospective
employee. This will be accomplished by having the employee / prospective employee sign the
consent form (see “Driver Consent / Acknowledgment Form” in the “Appendices and Forms”
section of this program). This consent form will also be maintained in the employee’s personnel
file.

The following risk matrix is used by company management to score MVRs:

Number of Number of Preventable Accidents

Violations Past
3 Years 0 1 2 3+

0 Clear Acceptable Questionable Poor

1 Acceptable Acceptable Questionable Poor

2 Acceptable Questionable Poor Poor

3+ Poor Poor Poor Poor

Any Major
Poor Poor Poor Poor
Past 5 Years

Notes:

1. Individuals who score “Clear” or “Acceptable” pass the MVR review process.
2. Individuals who score “Questionable” pass the MVR review process but are given a
warning from management.
3. Individuals who score “Poor” are not authorized to drive company vehicles or their own
vehicle on company business.
4. Examples of “Major” violations include but are not limited to:
a. Leaving the scene of an accident
b. Driving under the influence of drugs or alcohol
c. Racing or excessive speed (>20 MPH over speed limit)
d. Reckless, negligent or careless driving
e. Felony, homicide or manslaughter involving the use of a motor vehicle
f. License suspension or revocation resulting from accidents or moving violations
g. Following too closely or tailgating
h. Erratic lane-changing
i. Attempting to elude a police officer

Any disciplinary action taken as a result of MVR reviews and/or accidents must be documented
and consistently applied to all employees who fail to comply with company safety policy.

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Appendix A

Personal Use of Company Owned Vehicles

Company owned vehicles are to be used for company business only. Personal use of a company
vehicle is prohibited. Company vehicles may be driven home and used as transportation to and
from work only if approved by management.

Employees who drive or take home a vehicle are responsible for all fines and parking expenses.
The driver must make sure that the vehicle and toolboxes remain locked and equipment is stored
or secured as to prevent theft.

Personal Vehicles Used on Company Business

Employees who drive their personal vehicles on company business are subject to the requirements
of this program including the following:

• Maintain auto liability insurance with a minimum combined (bodily injury and property
damage) limit of $1,000,000.
• Maintain current state vehicle inspections when required.
• Maintain their personal vehicle in a safe operating condition when driven on company
business.
• Submit proof of insurance and a copy of the policy declarations page initially and at every
policy renewal.
• Pass Motor Vehicle Records (MVR) review
• No “business use” exclusion on personal insurance policy.
• Compliance with the policies and rules set forth in this Fleet Safety Program.

General Driving Instructions

• Drivers must always obey traffic signs and signals.

• Company owned vehicles must never be driven at a speed, which exceeds the area’s posted
speed limit.
• All passengers in the vehicle must wear seat belts.
• Drivers must always yield to emergency vehicles.
• No person(s) other than on-the-job employees and authorized personnel are permitted to
ride in or operate company vehicles. Operators who drive company owned vehicles must
be properly licensed and authorized by management to do so.
• Personnel will not be allowed to operate a company owned motor vehicle after having
consumed any amount of alcohol and / or illegal drugs. Vehicle operators under the
influence of a prescribed medication must first obtain approval from the prescribing
physician before operating the vehicle.

Distracted Driving

Drivers must remain alert at all times and not allow other things inside the vehicle to distract them.
43
Appendix A

The handheld use of a cellular phone or similar communication device while operating a motor
vehicle is prohibited unless the person is utilizing hands-free technology (where legal) for all calls
and communications. Calls while operating the vehicle shall be limited to essential business needs
and shall be suspended when heavy traffic, inclement weather or other conditions requiring
additional driver attention are present. If hands free technology is unavailable or the hands-free
conversation requires additional attention, drivers shall find a legal and safe parking spot prior to
engaging or continuing a conversation.

Creating or reading text messages and email, accessing the internet or any other function associated
with smartphone technology is prohibited while operating a motor vehicle. When using the
navigation feature, the destination shall be entered into the device prior to moving the vehicle.

Vehicle operators are required to know and comply with state and local laws which may be more
restrictive.

Accident / Incident Reporting

Any incident involving the use of a company vehicle or personal vehicle being used on company
business, whether or not it results in any injury to a person(s) or damage to any vehicle or property,
and regardless of fault, must be reported immediately to management.

Employees will take the following actions when there are injuries to persons and/or damage to
other vehicles or property:

1. If possible, move the vehicle to a safe location out of the way of traffic. Call for medical
attention if anyone is hurt.

2. Secure the names and addresses of drivers and occupants of any vehicles involved, their
operator's license numbers, insurance company names and policy numbers, as well as the
names and addresses of injured persons and witnesses. Record this information on the
Accident Report form (in the reporting packet). Do not discuss fault with, or sign anything
for anyone except a police officer.

Note: Every company vehicle should have an accident reporting kit in the glove box. This should
include an accident report form, pen and additional instructions to follow.

Vehicle Inspection and Preventive Maintenance

Daily, the employee operating the vehicle will visually inspect the vehicle prior to operating. Any
deficiencies which impact the safe or mechanical operation of the vehicle shall be reported to
management prior to operating.

Monthly, the employee operating the vehicle will complete a documented safety inspection of the
vehicle using the “Vehicle Inspection Report” found in the “Appendices and Forms” section of
this program.

44
Appendix A

Regular, preventive maintenance of company owned vehicles will be performed on a mileage or

time basis. Typical maintenance items include oil/filter changes, lubrication, tightening belts and
components, engine tune-ups, brake work, tire rotation, hose inspection/replacement and radiator
maintenance.

Request maintenance is performed only when the need arises. Some vehicle parts are replaced
only when they fail. These include light bulbs, window glass, gauges, wiring, air lines, etc. Other
"demand maintenance" items involve vehicle components that are worn based on information from
the vehicle condition report. These include tires, engines, transmissions, universal joints,
bushings, batteries, etc. Since these situations are identified through periodic vehicle inspection,
they can be classified within the preventive maintenance.

Driver Training

Drivers hired by WEST POINT ROOFING to operate a motor vehicle will have the basic skills
and credentials necessary to perform this function as confirmed through the driver selection
process.

New employees will receive a copy of this program as part of their initial orientation. A formal
orientation program is established to help assure all drivers are presented with the company policy,
understand their responsibilities and are familiarized with their vehicle. Areas that must be
addressed, with the driver, include:

• Understand, review and given a copy of the Fleet Safety Program.

• Understand accident reporting & emergency procedures.
• Review operation and controls of vehicle being assigned.
• Inspect vehicle using Vehicle Inspection Report.

Additionally, all drivers are required to complete a company-approved defensive driving training
course, either online or in a classroom environment.

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 Hazard Assessment / Safety Inspections

It is the policy of WEST POINT ROOFING to provide a competent person to conduct frequent
and regular safety inspections of all company project sites.

All findings of noncompliance during inspections shall be immediately corrected by WEST

POINT ROOFING personnel or the responsible subcontractor. If the identified unsafe act or
condition cannot be immediately corrected, an abatement plan will be developed, and WEST
POINT ROOFING will ensure to the greatest extent possible, there is no employee exposure to
the hazard during the abatement period.

WEST POINT ROOFING personnel will use the company’s Safety Inspection Checklist form
(see the “Appendices and Forms” section of this program) as a means of documenting safety
inspections and tracking / correcting any deficiencies found.
Appendix A

Substance Abuse Program

Purpose

WEST POINT ROOFING is committed to maintaining a drug-free workplace. The use of

alcohol and drugs is incompatible with our obligation to provide a safe and productive work
environment for our employees and business invitees.

All individuals employed by WEST POINT ROOFING will be subject to “pre-employment”

testing, “for cause” testing and “post-accident” testing. It is the responsibility of all individuals
employed by WEST POINT ROOFING to become familiar with and to faithfully understand the
policy.

Policy

Alcohol - The consumption of, possession of, or being under the influence of alcoholic beverages
on company property, company job sites, in the office, or in any vehicle used for company business
is strictly prohibited. Any employee who violates this policy will be subject to disciplinary action,
including immediate termination of employment. Any employee who reports for work, or who is
at work, is subject to blood or alcohol testing to determine the presence of alcohol in the body.

Illegal Drugs or Controlled Substances - WEST POINT ROOFING prohibits the sale, use of,
possession of, or being under the influence of any illegal drug or controlled substances on company
property, in the office, on a company job site, or in any vehicle used for company business. Illegal
drugs or controlled substances shall include, but are not limited to, marijuana, cocaine,
amphetamines, opiates (heroine), phencyclidine (PCP), hallucinogens (LSD), and barbiturates.
Any employee who violates this policy will be subject to disciplinary action, including immediate
termination of employment. Any employee who reports for work or who is at work is subject to
testing to determine the presence of unauthorized drugs or controlled substances in the body.
Involvement with unauthorized drugs or controlled substances on non-company time, including
conviction of drug-related or controlled substance offenses may also be the basis for termination.
All employees are required to notify WEST POINT ROOFING of any criminal drug or
controlled substance statute conviction, whether under State or Federal Law. The employee must
make such notification to WEST POINT ROOFING no later than five (5) days after the
conviction.

Prescription Drugs and Controlled Substances - Employees are permitted to take drugs or
controlled substances prescribed for them by a licensed physician provided that such drugs or
controlled substances do not affect their work performance. WEST POINT ROOFING reserves
the right to have a licensed physician determine if the use of a particular prescription drug or
controlled substance may increase the risk of workplace injury. All prescription drugs or
controlled substances must be kept in their original container and labeled with the employee’s
name.

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Appendix A

Testing Guidelines

1. Testing for Cause - Individuals employed by WEST POINT ROOFING will be subject
to the drug and alcohol testing procedure when there is reason to believe an individual
employee may be under the influence of drugs, controlled substances, or alcohol while on
the job at the discretion of management. WEST POINT ROOFING is particularly
concerned that an individual who is under the influence of drugs, controlled substances, or
alcohol while on the job may present a danger to the safety of that individual, other
employee(s), business invitees of the Company, the public, or the property of the company.

2. Post-Accident Testing - Work related accidents are a detriment to the company, our
employees, and business invitees because of the potential for personal injury and property
damage. Therefore, WEST POINT ROOFING must strive for an accident-free workplace
through its safety program and by testing for illegal or unauthorized drug, controlled
substance, or alcohol use of those employees involved in a work-related accident in which
human error could have been a factor.

Employee Assistance Program

WEST POINT ROOFING encourages employees to seek help. To assist employees in obtaining
treatment, the company will refer the employee to a provider or the employee may choose a
provider. Confidentiality is assured. Employees who undergo voluntary counseling or treatment,
and continue to work are subject to the same job performances and behavior standards as other
employees. As is the case of all employees, those seeking voluntary counseling or treatment who
fail to meet performance standards will be subject to disciplinary action. Employees are solely
responsible for all costs of treatment not covered by their applicable medical benefits plan.

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 Disciplinary Procedure
WEST POINT ROOFING is committed to providing a safe and healthful work environment for
its employees, which is free from recognized hazards. To help maintain this goal, a three-step
disciplinary procedure has been implemented into our Corporate Safety Program. The procedure
is as follows:

1. First Offense: A verbal warning will be given to the employee.

2. Second Repeated Offense: A written warning will be issued to the employee, along with
a copy to his/her supervisor and a copy on file in the corporate office.

3. Third Repeated Offense: Employee will be subject to termination, pending a decision

from WEST POINT ROOFING management.

This three-step disciplinary action may not apply to the items listed below:

• Any WEST POINT ROOFING employee engaged in fighting or creating a disturbance

on company grounds, company jobsites or in a company vehicle.

• Any WEST POINT ROOFING employee found with a weapon and/or firearm in their
possession while on company grounds, a company jobsite or in a company owned vehicle.

Any act of blatant disregard for the above stated violations, will be looked upon by management
as a hindrance to company safety goals and objectives and is subject to immediate termination of
employment.

Note: See “Disciplinary Action Form” in the “Appendices & Forms” section of this program
Appendix A

Appendices and Forms

Appendix A - Signature page acknowledging review / receipt

50
Appendix A

Policy Acknowledgement

I, _________________________, hereby acknowledge that I have received a copy of the

company safety program in its entirety. I further understand that I am responsible for complying
with the policy rules and must immediately report issues and concerns as it relates to successful
implementation of this program.

_________________________________________ _________________________
Signature of Employee Date

_________________________________________
Printed Name

_________________________________________ _________________________
Signature of Company Representative Date

_________________________________________
Printed Name

51