Health and Safety Policy

VICS Construction Company is committed to providing a safe and healthy workplace for
all our employees, contractors and those who may be affected by our business
undertakings. We believe that all injuries are preventable and that excellence in health,
Safety and Environment is the key to our long term success.

VICS Construction Company is committed to compliance with any and all government
agencies, regulations, and industry best practices and will use audits to measure, share
and improve our health and safety programs.

In all its activities, VCC shall:

 Provide and maintain Plants, equipment and system of work that are safe without
risk to any person.
 Provide a strong and effective leadership in HSE management.
 Set target for measuring, appraising and reporting HSE performance
 Prevent environmental incidents
 Use materials and energy efficiently and minimize waste generated
 Promote a vibrant HSE culture

This Policy covers all areas of VCC operations, drives the company’s general HSE
commitment and guides supplemental policies as regards Health and Safety.

……………………
Managing Director

SAFETY, HEALTH AND ENVIRONMENT PROGRAM

It is the policy and top priority of this Company to provide an accident-free and comfortable work
environment by eliminating recognized hazards from the workplace. Our health and safety
program, and specific individual programs, have been developed to assure compliance with
federal, state, and local regulations with particular emphasis on the VCC Occupational Health and
Safety Rules and Regulations that apply to our operations. In order to maintain the safety
standards desired by our company, it is necessary to actively pursue an accident prevention
program through all levels of our company, from top management through all employees. Health
and safety are functional responsibilities of each supervisor. Health and safety are of vital interest
to everyone in the company. Each level of our organization is accountable for safe performance.
Compliance with this program and safety and health rules are taken very seriously. This means
that failure to comply is sufficient ground for disciplinary action or for termination of
employment. These policies are an integral part of the company's personnel policies.

HEALTH AND SAFETY RESPONSIBILITIES

Our goal is to protect employees from injury while working for our company. This must receive
top priority from everyone. Duties and responsibilities of all personnel under our health and
safety program are in the following

Health and Safety Manager (Or management personnel if none assigned)

a. Administers all aspects of the occupational health and safety program.

b. Develops programs and technical guidance to identify and remove physical, chemical,
and biological hazards from facilities, operations, and sites.
c. Assists management and supervisors in the health and safety training of employees.
d. Conducts inspections to identify unhealthy or unsafe conditions or work practices and
completes written reports of inspections.
e. Recommends programs and activities that will develop and maintain incentives for and
motivation of employees in health and safety.
f. Recommends disciplinary action for repeat violators of health and safety rules.
g. Maintains the state health and safety poster, emergency telephone numbers, and other
notices required by VCC Workers' Safety. Ensures this information is posted in places
where employees can see them on each job.
h. Develops and maintains accident and incident investigation and reporting procedures and
systems. Investigates serious or reportable accidents and takes action to eliminate
accident causes. Reportable incidents consist of fatalities, lost work day cases, and
 without lost work days requiring medical treatment. Keep management informed of
findings.
i. Report accidents that result in an occupational fatality or three or more hospitalized
workers within eight (8) hours of occurrence.

First Line Supervisor

a. Be familiar with, explains, and enforces health and safety regulations that apply to
company operations within his/her area of responsibility.
b. Ensures that safety devices and proper individual protective equipment are used by
persons under his/her supervision.
c. Instructs and trains all persons within area of responsibility in job health and safety
requirements and requires compliance by workers with the safety rules established.
d. Conducts frequent and regular safety and health inspections of his/her work areas and
ensures that no unsafe conditions exist in area of responsibility.
e. Conducts weekly (or more often if needed) safety briefings with all workers under his/her
supervision.
f. Ensures that injuries are treated promptly and reported properly.
g. Investigates all accidents/incidents, obtains all pertinent data, and initiates/takes
corrective action.
h. Acts on reports of hazards or hazardous conditions reported to them by employees

All Employees

a. Be familiar with and comply with proper health and safety practices.
b. Use the required safety devices and proper personal protective safety equipment.
c. Notify supervisor immediately of unsafe conditions/acts, accidents, and injuries.

DRUG-FREE WORKPLACE

a. The unlawful use, possession, transfer, or sale of illegal drugs or controlled substances
and the misuse of alcohol by employees during work hours are prohibited.
b. The consequences for violation of the drug-free policy may include, but are not limited
to, a referral for therapeutic help, discipline and/or discharge.
c. A list of community resources that provide substance abuse treatment and prevention
services is posted at the bulletin board where they may be regularly viewed by
employees. The Department of Health also provides information on their website, or may
be contacted directly.
d. Encourage the designation of a totally or partially smoke free workplace.

DRIVING SAFETY

Vehicle operations are an integral part of our business. Therefore, the following rules shall apply
to all business vehicle operations. Hopefully, employees will follow these rules when operating
their own personal vehicles.
 a. All vehicle operators are required to have a current and valid drivers’ license for the
vehicle to be operated, i.e., motorcycles, trucks, commercial drivers’ license (CDL).
b. No unauthorized use of company vehicles shall be permitted.
c. All cargo or other items, i.e., laptops, suitcases, etc, shall be loaded and secured to
prevent them from creating hazards in the event of hard braking.
d. Prior to entering the vehicle visually inspect the entire vehicle. Look for broken windows,
light covers, low tyre pressure, etc. Report all damage to your supervisor.
e. Adjust all mirrors for the proper vision of the operator.
f. All occupants shall fasten their seat belts. The vehicle shall not be started until all
occupants have fastened their seat belts.
g. Check all gauges and switches for proper function and location, i.e., cruise control,
windshield wipers, lights, gearshift, and radio. Do not look for these while you are
operating the vehicle. Test the brakes to determine their effectiveness and get a “feel” for
the necessary brake pressure.
h. Obey all traffic laws while operating the vehicle. This includes the speed limit.
i. Vehicles shall NOT be operated while under the influence of alcohol or drugs which may
impair your driving ability. Some prescription drugs and over-the-counter drugs also may
affect your driving and decision-making abilities.
j. Cell phone operation must be conducted ONLY while stopped and out of traffic.
k. Pay attention! Keep your mind on driving and watching the road. Watch out for other
drivers. Make sure you are well rested and alert.
l. Don’t get involved in “road rage”. Don’t become angry at aggressive drivers. Simply pull
over to the right lane or the side of the road and allow them to pass.
m. Always stay at least two (2) seconds behind the vehicle in front of you. If driving
conditions are not optimal, i.e., rain, ice, snow, wind, or visibility, allow a further
following distance.

Hazard Communication Program

This company has a Hazardous Communication Program in place because of our work with and
exposure to hazardous chemicals in the workplace. Important elements of this program are: a
written program explaining what the program is about; a master listing of hazardous chemicals in
the workplace; material safety data sheets (MSDSs) of those chemicals; labeling requirements of
chemicals containers; and training for all employees on the program and its elements. Employees
are encouraged to review this program at any time.

TRAINING

Training and education cannot be over emphasized as a means of learning a healthful and safe
approach to employee work effort. Knowledge of the safety rules and how and when to function
under the rules, supplemented by compliance, is essential to safety.
 a. Employees scheduled for any safety and health training will attend such training.
b. New employees will be provided orientation training and will be furnished information
and literature covering the company health and safety policies, rules, and procedures.
This orientation training must be provided prior to the employee's exposure to the work
environment.
c. Individual job/task training will be provided to all employees. Included in this training
are the applicable regulations/standards for their job; the recognition, avoidance, and
prevention of unsafe conditions; areas and activities that require personal protective
equipment; and how to use protective equipment (such as respirators, etc.).
d. Monthly/quarterly on-going safety training sessions will be conducted to provide
information and training on new equipment, new procedures, new chemicals,
refresher/remedial training in specific areas, or meet annual requirements. Such training
may be held in conjunction with the safety briefings/meetings addressed elsewhere in this
program.
e. Various individual VCC Workers' Safety programs specify that training be provided to
employees. Supervisors will ensure their employees are scheduled and provided this
training as required. Examples of specified training include but not limited to:
* Fire extinguisher training
* Confined space entry
* Respirator care and use
* Hazard communication
* Lockout/tagout procedures
* Industrial truck/forklift operation
* Electrical work

HAZARD IDENTIFICATION, ASSESSMENT, AND CONTROL

Hazard identification and elimination is not only an inherent responsibility of supervision in

providing a safe workplace for employees, but also requires employee involvement. As such,
hazard evaluation and control shall be an on-going concern for all. It is the responsibility of
everyone (management, supervisors and all employees) to identify, report, and correct, all
possible hazards. Employees are particularly important in this process as they are in the best
position to identify hazards in the workplace and day-to-day operations. Reporting hazards is a
protected activity and no action will be taken against anyone for identifying unsafe conditions.
Reports should be made to the safety manager or supervisor for appropriate action. This company
has a procedure for conducting inspections of workplaces/jobsites for compliance with health and
safety rules. The purpose of the in-house inspection is to identify hazards and unsafe practices
before they cause an injury or accident.

Formal safety and health inspections will be conducted under the following minimum timelines:

a. Health and Safety Manager: {Monthly/quarterly} of all fixed facilities and shops.
b. Manager/superintendent: {Monthly/quarterly} of his/her area of responsibility.
c. Supervisors: {Weekly/monthly/quarterly} of area of responsibility, not in conjunction
with the above inspections.
d. The company's health and safety program will be reviewed at least annually.

Inspection Guideline

This listing includes items, areas, and categories that may be looked at during health and safety
inspections of the workplace. It is generic and not all inclusive, but provides a guideline of areas
to be surveyed or developed into a checklist for use during the inspection.

a. First aid safety and health equipment.

b. Accident reporting records.
c. Employee training provided, such as health and safety talks, worker orientation. Records
10 maintained.
d. Equipment and tools (hand, power, welding, etc.): condition, use.
e. Protective guards and devices: availability, use, proper maintenance and operating
condition.
f. Housekeeping: maintaining clean work areas, free of trash/debris accumulation, tripping,
and slipping hazards.
g. Lighting: for adequacy and safety.
h. Sanitation: water, toilets for cleanliness and proper operation. j.
i. Noise hazards, hearing protection.
j. Ventilation for gases, vapors, fumes, dusts.
k. Availability of personal protective equipment: Hard hats/head protection, respirators,
safety belts, life lines, safety shoes, eye protection, gloves.
l. Fire protection, prevention and control, use of fire protection equipment.
m. Temporary buildings, trailers, sheds.
n. Open yard storage.
 o. Storage of flammable and combustible liquids including service and refueling areas for
vehicles.
p. Temporary heating devices.
q. Fall protection requirements: in place and in use.
r. Electrical system and devices; condition and use of cords; ground fault protection; circuit
breaker panels; receptacles and switches.
s. Openings: floor, wall, safety railings.
t. Materials: handling equipment and elevators.
u. Ladders: condition and use.
v. Hazard communication program and material safety data sheets (MSDS).
w. Stairways: safety railings, condition.
x. Scaffolds: Safety railings, secured.
y. Lockout/Tagout procedures.
aa. Machines and equipment: condition, guards in place.
bb. Forklifts: condition, operation.
cc. Preventive maintenance program: all inclusive, up to date.
dd. Other items as appropriate.

HEALTH AND SAFETY RULES

General Workplace Safety Rules

a. Report unsafe conditions to your immediate supervisor.

b. Promptly report all accidents/injuries/incidents to your immediate supervisor.
c. Use eye and face protection where there is danger from flying objects or particles, (such
as when grinding, chipping, burning and welding, etc.) or from hazardous chemical
splashes.
d. Dress properly. Wear appropriate work clothes, gloves, and shoes or boots. Loose
clothing and jewelry shall not be worn.
e. Operate machines or other equipment only when all guards and safety devices are in
place and in proper operating condition.
f. Keep all equipment in safe working condition. Never use defective tools or equipment.
Report any defective tools or equipment to immediate supervisor.
g. Properly care for and be responsible for all personal protective equipment (PPE). Wear or
use any such PPE when required.
 h. Lockout or tagout or disconnect power on any equipment or machines before any
maintenance, unjamming, and adjustments are made.
i. Do not leave materials in aisles, walkways, stairways, work areas, or other points of
egress.
j. Practice good housekeeping at all times.
k. Training on equipment is required prior to unsupervised operation.
l. Compliance with all governmental regulations/rules and all company safety rules in the
following sections are required.

Housekeeping

a. Proper housekeeping is the foundation for a safe work environment. It definitely helps
prevent accidents and fires, as well as creating a professional appearance in the work
area.
b. All work areas, floors, aisles, and stairways will be kept clean and orderly, and free of
tripping and slipping hazards. Oils, greases, and other liquids will be immediately
cleaned up if spilled.
c. Combustible scrap, debris, and garbage shall be removed from the work area at frequent
and regular intervals.
d. Stairways, walkways, exit doors, in front of electrical panels, or access to firefighting
equipment will be kept clear of storage, materials, supplies, trash, and other debris at all
times.
e. Overhead storage areas will be marked as to maximum load rating.

Fire Prevention

a. All portable fire extinguishers will be conspicuously located, accessible, and maintained
in operating condition. Portable fire extinguishers will receive an annual service check
and a monthly visual inspection. These will be documented on the tag on the extinguisher
or other form.
b. All employees must know the location of firefighting equipment in the work area and
have knowledge of its use and application.
c. Exits will be marked as such by a readily visible sign. Other doors likely to be mistaken
for an exit will be marked as to their character or "Not An Exit".
 d. Only approved safety cans shall be used for handling or storing flammable liquids in
quantities greater than one gallon. For one or less gallon, only the original container or a
safety can will be used.
e. When heat producing equipment is used, the work area must be kept clear of all fire
hazards and all sources of potential fires will be eliminated. f. Fire extinguishers will be
available at all times when utilizing heat-producing equipment.

Industrial Hygiene and Occupational Health

a. When no medical facility is reasonably accessible (time and distance) to the workplace, a
person who has a valid certificate of first aid training and first aid supplies will be
available at the workplace to render first aid.
b. Employees exposed to noise levels above the permissible noise level will be included into
the hearing conservation program. Hazardous noise areas will be posted and hearing
protection worn in those areas as required.
c. Employees exposed to harmful gases, fumes, dust, and similar airborne hazards will be
furnished protection through proper ventilation or personal respiratory equipment.
d. Any demolition, renovation, or self-help work will be assessed for lead exposure,
particularly if drywall or any painted surfaces or abrasive blasting/grinding is involved,
and asbestos exposure.

Personal Protective and Related Equipment

a. Personal protective equipment must be worn as required for each job in all operations
where there is an exposure to hazardous conditions. This exposure is determined by a
personal protective equipment hazard assessment of the workplace by the supervisor.
Equipment selection and wearing requirements are determined from this assessment.
b. Safety glasses, goggles, or face shields will be worn in those areas where there is a
reasonable probability of injury to the eye from flying particles, molten metal,
chemicals/acids/caustics, or light radiation, or other eye hazards.
c. Head protection (hard hats) will be worn for protection from falling objects or work near
energized electrical contact.
d. Foot protection will be worn where there is danger to the foot from falling/rolling objects,
objects piercing the sole or electrical hazards.
e. Hand protection is required when hands are exposed to severe cuts/abrasions,
chemical/thermal burns, or chemical absorption.
 f. Appropriate gloves, aprons, goggles, and boots will be used when necessary for
protection against acids and other chemicals which could injure employees.
g. The use of safety harnesses and lanyards are required when working more than five feet
above a floor or ground level and there are no guardrails or other form of fall protection,
and on certain suspended scaffolds. Each employee will be on a separate safety line, and
this line will be adjusted so that the employee cannot fall more than six feet.

Ladders a. Ladders

will be inspected frequently to identify any unsafe conditions. Those ladders which have
developed defects will be removed from service, and repaired or replaced. They will be tagged or
marked as such. b. Portable ladders will be placed as to prevent slipping, or if used on other than
stable, level, and dry surfaces, will be tied off or held. A simple rule for setting up a ladder at the
proper angle is to place the base from the vertical wall equal to one-fourth the working length of
the ladder. c. Portable ladders will extend at least three feet above the upper level to which the
ladder is used to gain access. d. The top of a stepladder will not be used as step. e. Only one
person will be on a ladder at a time.

Flammable and Combustible Liquids

Only approved safety cans, original containers, or portable tanks will be used to store flammable
or combustible liquids. Above ground storage tanks will be separated from each other by a
minimum of three feet or 1/6 the sum of their diameters. Dikes or drainage to prevent accidental
discharge from reaching adjoining property or waterways will be provided.

Cranes/Hoists

a. All cranes/hoists will be inspected prior to each use to make sure it is in safe operating
condition.
b. A monthly inspection of hooks, running ropes, and hoist chains will be made and a
certification record to include date, inspector signature, and hook/rope/chain identifier
will be maintained.
c. Inspections of frequent (daily-monthly) and periodic (1-12 months) intervals, depending
on severity of use, will be made of all cranes. See 1910.179(j) for inspection
requirements.
 d. The rated load of the crane/hoist will be plainly marked on each side of the crane. If the
crane has more than one hoisting unit, each rating will be marked on the unit or its load
block.
e. Loads will never be swung over the heads of workers in the area.
f. Tag lines must be used to control loads and keep workers away.
g. Loads, booms, and rigging will be kept at least 10 feet from energized electrical lines
rated 50 KV or lower unless the lines are de-energized. For lines rated greater that 50 KV

Welding and Brazing

a. Combustible material will be cleared for a radius of 35 feet from the area around cutting
or welding operations. If the combustible material cannot be cleared or the work cannot
be moved, then the welding/cutting will not be done.
b. Welding helmets and goggles will be worn for eye protection and to prevent flash burns.
Eye protection will be worn to guard against slag while chipping, grinding and dressing
of welds.
c. Oxygen cylinders will be stored at least 20 feet from fuel gas cylinders, or separated by a
noncombustible fire wall with a one-half hour rating at least five high.
d. Valve protection caps will be in place on cylinders not in use.
e. Ventilation is a prerequisite for welding in any confined spaces.

Tools

a. Hand tools with broken/cracked handles, mushroomed heads, or other defects will not be
used. Files will have handles installed.
b. Take special precautions when using power tools. Defective tools will be removed form
service.
c. Power tools will be turned off and motion stopped before setting tool down.
d. Tools will be disconnected from power source before changing drills, blades or bits, or
attempting repair or adjustment. Never leave a running tool unattended.
e. Power saws, table saws, and radial arm saws will have operational blade guards installed
and used. Anti-kickback teeth and spreaders will be used when rip sawing.
f. Portable abrasive side-winder grinders will have guards installed covering the upper and
back portions of the abrasive wheel. Wheel speed ratings will never be less than the
grinder RPM speed.
 g. Pedestal grinders will be permanently mounted, tool rests installed and adjusted to within
1/8 inch of the wheel, tongue guards installed and adjusted to within 1/4 inch of the
wheel, and side spindle/nut guards installed.
h. Air compressor receivers will be drained frequently to prevent buildup of water in the
tank

Safety Railings and Other Fall Protection

a. All open sided floors and platforms four feet or more above adjacent floor/ground level
will be guarded by a standard railing (top and mid rail, toe board if required).
b. All stairways of four or more risers will be guarded by a handrail, or stair rails on the
open side.
c. When a hole or floor opening is created during a work activity, a cover or a barricade
must be installed immediately.
d. Safety harnesses, belts, lanyards, lines, and lifelines may be used in lieu of other fall
protection systems to provide the required fall protection.
e. Adjustment of lanyards must provide for a not more than a six foot fall, and all tie off
points must be at least waist high

Scaffolds

a. Scaffold platforms more than ten feet above the ground, floor, or lower level will have
standard guardrails (consisting of top rail, mid rail, and toe board) installed on all open
sides and ends of platforms.
b. Planking will be laid tight; overlap at least 12 inches, and extend over end supports 6 - 12
inches.
c. Mobile scaffolds will be erected no more than a maximum height of four times their
minimum base dimension.
d. Scaffolds will not be overloaded beyond their design loadings.

Forklifts

a. Only authorized and trained employees will operate forklifts and other industrial trucks.
b. Safe speeds, load handling, turning, and other safe driving practices will be followed at all
times.
c. Operators will ensure loads are stable and/or secure before moving.
d. Employees will not operate any forklift that is in need of repairs, defective, or unsafe. Such
forklifts will be removed from service for repair.

Aerial Lifts

a. Only trained employees will operate aerial lifts (cherry pickers, extensible and
articulating boom platforms).
b. A body belt or harness will be worn and a lanyard attached to the boom or basket when
working from an aerial lift.
c. Employees will stand firmly on the basket floor, and not sit/stand/ climb on the edge of
the basket. Planks, ladders, or other devices will not be used for additional elevation.
d. Aerial lift trucks will not be moved with workers in an elevated basket.
e. Lift controls will be tested each day prior to use.

Excavations and Trenches

a. Any excavation or trench five feet or more in depth (or less than five feet and showing
potential of cave-in) will be provided cave-in protection through shoring, sloping,
benching, or the use of trench shields. Specific requirements of each system are
dependent upon the soil classification as determined by a competent person.
b. A competent person will inspect each excavation/trench daily prior to start of work, after
every rainstorm or other hazard increasing occurrence, and as needed throughout the
shift.
c. Means of egress will be provided in trenches four feet or more in depth so as to require
no more than 25 feet of lateral travel for each employee in the trench.
d. Spoil piles and other equipment will be kept at least two feet from the edge of the trench
or excavation