CC CC Chief Construction Equipment Employee Participation Program Page 8 of 9

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CC

Chief Construction Equipment

Employee Participation Program

Page 8 of 9

Effective Date: 09/10/2019

Responsible Department: EHS

S-1.001

Approved By: __________Joe Shirly_________

Revision: A

CC

CC

Chief Construction Equipment

Employee Participation Program

Page 1 of 9

Effective Date: 09/10/2019

Responsible Department: EHS

S-1.001

Approved By: __________Joe Shirly_________

Revision: A

Overview

Here at Chief Construction Equipment, we manufacture a variety of heavy machinery that includes backhoes, dozers, excavators, utility vehicles, off-highway trucks, and compactors. We are committed to safety and working safely is a requirement of employment. Participation is valued and we want to give workers the opportunity to share their knowledge and voice their opinions. This includes the assignment of roles and responsibilities to employees at all levels that are designed to enhance the safety of Chief Construction Equipment operations. Safe operation and maintenance procedures require both employer and employee involvement. Employees will have the opportunity to actively participate in safe work programs through anonymous communication efforts, consultation, safety committee representation, and voluntary direct contributions. We want to encourage our workers to participate in the program, because we value their input and want to use it to positively impact our safety and health decisions.

The intent of this element is to provide a structured approach for a collaborative hands-on environment that aims to ensure the flow of information from senior management to employees and vice versa on process safety issues. Workforce involvement is a system that provides employees with a direct connection in protecting their own welfare. To encourage workers to participate in the program they must be provided with the necessary time and resources. We have an open-door policy that invites workers to talk about safety and health concerns without the fear of retaliation. Management will provide timely feedback to show employees that their concerns are being heard and will be addressed. Employees should feel empowered to stop work or request a shutdown if they believe an activity to be unsafe.

Active involvement entails open and effective communication, mutual trust, individual empowerment, and responsiveness to suggestions. The element is not to give responsibilities to employees but rather to take advantage of their valued expertise and unique perspectives on process safety matters. Workers will attend awareness training on workforce involvement that will provide them with the necessary tools and information that is needed to understand and participate in safe programs. This information can include but is not limited to Safety Data Sheets (SDS), Job Hazard Analysis (JHA), inspection reports, injury and illness data, results of environmental exposure monitoring, among various other useful sources of information. By promoting active involvement of personnel, we can support our commitment to process safety.

Definitions

Process Hazard Analysis (PHA) – An analytical tool used to identify causes and consequences to potential accidents or scenarios that involve fires; explosions; toxic release; biological agents; and spills in order to recommend corrective measure to prevent such occurrences.

Management of Change (MOC) – A practice used to ensure risks are controlled when a company makes changes that impact the safety, health, and environment in their facilities.

Pre-Startup Safety Reviews – A review and inspection of equipment modifications before startup to ensure that the adjustment has been installed properly by approved design standards, that training of affected personnel has been completed, and that procedures in place are adequate.

Failure Mode and Effects Analysis (FMEA) – A structured approach to discovering potential failures that may exist within the design of a product or process.

Fault Tree Analysis (FTA) – A visual account of a system that shows the relationship between an event and the causes that led to the event or failure.

Employee Consultation – Establishing a dialogue for the exchange of views or collaboration input between employees and management.

Incident Investigation Team – A group of qualified people that analyze an incident in a timely manner and examine factual information pertaining to the event to determine cause(s) and understanding and ensure documentation.

Safety Data Sheet – A document that contains information about the potential health effects of chemical exposure in the workplace, hazards associated with the chemical, precautions to take, and safe working procedures when handling chemicals.

Job Hazard Analysis – A technique used to identify danger associated with a task in order to reduce the risk of injury to workers. Once hazards are identified, the elimination and reduction process begin before an injury occurs.

Training Criteria

Workforce involvement awareness training promotes the active participate of workers at all levels. This training will discuss the diversity of roles that workers can fulfill in support of process safety procedures such as volunteering to be on the Safety Committee, writing Hazard ID and safety concern cards, and communicating effectively with management. Key topics will include identifying the roles that workers can play in support of the Employee Participation program as well as how to measure the effectiveness of the program by use of key performance indicators. The training will be taught by the EHS department and introduced to all incoming employees as well as refresher training for current employees. This will take place bi-annually or on a need-based schedule.

Implementation of Involvement Programs

Employee input is valued and communicating concerns, issues, or suggestions can help to improve safe work procedures. Workers will be able to express their ideas on issues related to the design, development, implementation, and continuous improvement of the Process Management Safety (PSM) program. Auditing tools will be utilized by employees to determine the effectiveness, reliability, and compliance level of our health and safety systems. Knowledge of the industry and equipment manufacturing process will always be sought out as a source of information that will be used in the development of incident prevention plans, risk assessments, auditing tools, and the performance of Process Hazard Analysis (PHA) among other activities that can be reviewed in Table 1.

Table 1. Employee participation areas in PSM program

Emergency Preparedness

Safe Work Plans

Toolbox Talks

Incident Investigation Teams

Hazard Identification Process

PSM Training Programs

Pre-Startup Safety Review

Management of Change Evaluation

Safety Concern Card

Near Miss Documentation

Process Hazard Analysis will contribute to the employee participation program through the use of what-if analysis, failure mode and effects analysis (FMEA), fault-tree analysis, and checklists. An example of the fault-tree analysis can be seen in appendix A. A team comprised of the EHS Leader, Operations Manager, and Plant Leader will review and update the Process Hazard Analysis methods annually.

Safety Committee

A Safety Committee will be developed to inspire employee participation and promote the exchange of ideas. The purpose of the committee is to encourage employee interest in health and safety topics, provide an opportunity for discussion of safety issues and possible solutions, inform and educate all members of staff about safety, and aid in the reduction of risk in workplace injuries and illnesses. The committee will share responsibilities with management regarding monitoring and implementing company safety programs. The EHS Department will review the Safety Committee’s progress annually to evaluate the group’s success in meeting safety goals and objectives. Evaluation of the committee’s effectiveness will be based on key performance indicators that include data such as the percentage of required attendance achieved at Safety Committee meetings that address process safety concerns and the number of meetings that are conducted per year.

Duties include:

Accident Investigations – determining the facts that occurred during an incident or accident that aids in identifying the root cause. Then a corrective action or recommendation can be made to prevent future occurrences of the event.

Developing Safe Work Practices – outlining how to perform a task with minimum risk to the worker, processes, environment, and equipment.

Workplace Inspections – a tool to help prevent incidents by critically examining work areas for hazards and then recommending a corrective action.

Review of Safety Concern Cards – compile concern cards and determine where/what hazards are occurring most frequently.

Evaluation of Safety Programs – in order to determine the effectiveness of a program it must be continuously evaluated to find gaps or opportunities for improvement.

Hazard Control and Assessment – evaluate the workplace for potential hazards that may be encountered while performing a task and implement a control.

The Safety Committee will be comprised of 15 members elected by their peers that represent various areas and levels of the company (maintenance, equipment operators, warehouse personnel, union representative, etc.) and meet monthly to discuss safety and health programs. The structure of the committee includes a chairperson, vice-chairperson, secretary, and general members. The primary duties of these positions will be listed below.

Chairperson

Vice Chairperson

Secretary

General Member

Promote health and safety by personal example.

Take an active role in committee activities.

Actively promote health and safety by personal example.

Actively promote health and safety by personal example.

Serve as a communication liaison between management and the workforce.

Undertake leadership of the committee when the chairperson is unavailable.

Maintain an accurate account of the minutes to each meeting.

Help develop safe work practices and behaviors.

Develop meeting agendas and conduct orderly meetings.

Assist with the coordination and direction of committee activities.

Distribute meeting notes so that non-members can view the progress of the committee.

Conduct workplace inspections and safety audits.

Provide timely follow-up on problems and recommendations developed by the committee.

Promote and engage others in health and safety programs.

Identify problems in the safety and health programs and suggest possible solutions.

Safety Concern Card

Employee’s that have concerns or suggestions regarding safety matters will use safety concern cards to provide commentary. An example of a safety concern card can be seen in appendix C. The Safety Leader will evaluate the cards and implement countermeasures depending on the urgency of the concern and review them with the Safety Committee monthly. The effectiveness of the card will be evaluated by tracking the number of process safety suggestions reported each month and analyzing the average response time to the resolution of the process safety suggestion.

Hazard ID Card

Employees will be involved with recognizing and reporting hazards, unsafe conditions, near misses, and actual incidents. The hazard ID card will be used to address issues before someone gets hurt or becomes exposed to a hazard. An example of a Hazard ID card can be seen in appendix D. The EHS Department and the Safety Committee will use the data from the cards to track the number of communications from senior management to the general workforce promoting or discussing process safety in order to improve workplace safety and health.

Roles & Responsibilities

The following list of job titles has specific responsibilities and duties outlined below that were assigned to them in regard to the Employee Participation program.

EHS Leader:

Oversee all aspects of the Process Safety Employee Participation program.

Track metrics established for this element such as blank and blank, and report findings to the leadership team.

Provide opportunities for employees to actively participate in PSM program development, implementation, modification, and training sessions.

Review department records associated with employee engagement quarterly.

Provide timely feedback to employees who have had concerns or suggestions regarding process safety.

Safety Officer:

Coordinate implementation of the Employee Participation program within the work group.

Participate in PHA’s, Pre-Startup Safety Reviews, Incident Investigation Teams, Management of Change Assessments, Toolbox Talks, and Safety Committee meetings.

Review and assess training programs annually to ensure the required training is effective and provided to employees.

When unsafe process safety conditions or behaviors are observed or reported institute a corrective action in a timely fashion.

Management

Acknowledge and positively reinforce those who are engaged in the program.

Encourage workers to identify shortcomings and report all safety and health concerns.

Management is responsible for reporting back to workers about actions taken in response to their concerns and suggestions in a frequent manner.

Area Supervisors:

Ensure that employees within their area are aware of responsibilities and understand employee participation requirements outlined in this procedure.

Take prompt corrective action when unsafe process safety acts or conditions are observed or reported.

Provide opportunities for employees to actively participate in the PSM program.

Contribute to Management of Change assessments, incident investigation teams, pre-start-up safety reviews, PHA’s, and toolbox talks.

Employees:

Actively participate in Process Safety Management program elements.

Report process safety issues to appropriate management heads.

Engage in safety tasks and follow program instructions regarding the health and safety of self and others.

Attend safety training.

Report hazards and defects observed in the workplace.

Tracking

Metrics will be utilized to show performance indicators on the Employee Participation element and programs. These leading metrics listed below will serve as early indication tools for process safety failures that can be corrected before a major event occurs.

Percentage of workers trained on workforce involvement and their responsibilities.

Percentage of managers trained on workforce involvement and their responsibilities.

Percentage of workers who have participated in key defined workforce involvement activities, such as submitting a suggestion, serving on a risk analysis team, or participating in an incident investigation, over the past 12 months.

Number of suggestions that have not been evaluated (no decision made to accept or reject) and average/maximum delinquency.

Percentage of suggestions accepted.

Results of worker attitude surveys with respect to acceptance of process safety responsibilities.

Review

Commitment to employee empowerment and engagement is demonstrated through various activities and programs (e.g. Safety Committee, FMEA, Safety Concern Card, Incident Investigation teams, etc.), but it also must be incorporated into day-to-day activities (daily forklift inspection checklist). An example of Failure Mode and Effects Analysis (FMEA) can be seen in appendix B. The following measures outline the requirements of the Employee Participation element within the PSM Program.

The objective of this element is to promote active engagement in various phases of process safety efforts. The intent is to provide employees with the necessary tools in order to empower them in making important decisions and ensuring those decisions are correct. Employees must be given the authority to make independent decisions appropriate to their role in the company.

An important method of identifying potential hazards within an area is to establish clear lines of communication on process safety issues. It also provides an effective system where employees are encouraged to exchange process safety concerns or suggestions with management.

Employees should also be aware of other resources available to them such as the Safety Committee and EHS department. Employees who wish to remain anonymous when reporting concerns or suggestions may do so through the safety concern card.

Employee participation within the PSM program will be appropriately documented by the EHS department. Documentation will include but is not limited to meeting minutes, Pre-Startup Safety Review team lists (PSSR Form), Hazard ID Cards, Management of Change Authorization (MOC Form), email correspondence on safety matters, training sign-in sheets, PHA Report Forms, and Incident Investigation Forms.

Contract workers must also be integrated into the employee participation program and encouraged to engage in involvement activities. Contract workers will attend toolbox talks and discuss health and safety concerns associated with their job duties.

In addition to actively engaging employees through various participation activities, employee consultation is also included within this element. Consultation activities will consist of employee perception surveys or a specific selection from various options such as the selection of PPE. We will analyze the results of the surveys and make improvements to our safety and health programs. These activities will also be documented by the EHS Department in accordance with the PSM program.

Chief Construction Equipment actively seeks new workforce involvement opportunities to integrate into the employee participation program.

Appendix

Fault-Tree Analysis Example

Failure Mode and Effects Analysis (FMEA)

Safety Concern Card

Hazard ID Card