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EHS Admin Policy Programs

  • 1. Is this location combined with any other location(s) for purposes of the ARR reporting/tracking? If not, answer NA (Not Applicable) to this question. If yes, answer 'yes' to this question, then go to the comments section of this question and add the region/locations for the other (combined) locations.

  • Please list the location building ID's included as part of this Account Risk Review Profile.

  • 2. Posting EHS documents: Have all required postings been completed, including the Company's Health & Safety Policy, the Company's Environmental Policy, Federal OSHA poster, Safety Pledge and Posters?<br>- Are the company's Safety & Health Policies posted? <br>- Are the company's Environmental Policies posted? <br>- Are Federal OSHA posted?<br>- Are all Posting in a high traffic area (near worker entrance, time clock, bulletin board, site trailer/vehicles) and are they all workers? Guidance: 1. All sites are required to post the federal OSHA poster, Job Safety and Health Protection.<br>2. Sites in states operating OSHA-approved state plans should obtain and post their state's equivalent poster. Check with EHS for state-specific posting requirements.<br>3. Posting should be made in a high traffic area (worker entrance, near time clock, bulletin board, site trailers/vehicles) and be accessible to all workers.

  • 3. Safety Pledge: Have all site employees, including Management and Supervision, been given the opportunity to sign the Safety Pledge? Guidance: All employees at each site must sign the safety pledge. The records must be readily available for each employee.

  • 4. Cardinal Rules: Have all site employees, including Management and Supervision, been given the opportunity to sign the Cardinal Rules? Guidance: All employees at each site must sign the Cardinal Rules. The records must be readily available for each employee.

  • 5. Stop Work Authority (SWA): Have site employees been trained, empowered, and authorized to initiate SWA when warranted? Management must establish and support clear expectations to exercise SWA, create a culture where SWA is exercised freely and hold those accountable that chose not to comply with established SWA policies. Guidance: SWA involves a stop, notify, correct, and resume if safe to do so approach for the resolution of a perceived unsafe condition, act, error, omission or lack of understanding that could result in a undesirable event. All employees have the authority and obligation to stop any task or operation where concerns or questions regarding the control of health, safety or environmental risks exist.

  • This ARR Program requirement applies to all C&W site locations. Guidance: A WHA is required to be completed (and maintained) by all C&W sites/accounts, without exception. The WHA serves as the starting point for identifying, assessing and controlling worksite hazards/risks, with JSAs serving as the primary means for organizing and communicating the means for controlling these hazards/risks.

  • Manager Responsibilities: Has the Site/Regional Manager reviewed the "Operational Management Responsibilities" specified in the Company's Health & Safety Policy? Guidance: The Company's Policy Statements and a document outlining the Company's Program Responsibilities are available on SharePoint. Measurable responsibilities must be defined for Management to ensure the performance of the following<br>activities:<br>1. Workplace inspections<br>2. Information sessions (safety talks, staff meetings, tail gate meetings)<br>3. Incident reports and investigations<br>4. Worker training<br>5. Correcting substandard acts or conditions<br>6. Commending worker and supervisor health and safety performance<br>7. Appointment of competent supervision<br>8. Observing worker safety (e.g., CWalk observations), where applicable to site operations<br>9. Documenting/posting required information to the appropriate information boards and/or management system

  • Do all employees receive annual refresher training on EHS rights and responsibilities? Guidance: Annual HSSE refresher training should include the following topics:<br>(1) Basic HSSE responsibilities;<br>(2) Right to refuse work;<br>(3) Right to participate (Safety Committee and/or H&S Representative);<br>(4) H&S Policy (and progressive discipline program for failures to adhere to policy);<br>(5) Return-to-Work Program.

  • Has the site designated a person to manage WC/GL cases and has that person reviewed the WC/GL Program guidance available on SharePoint?

  • Is employee safety orientation provided to all personnel and is documentation readily available at the site? Guidance: New Employee Orientation (NEO) Training is required for:<br>(1) Newly hired workers<br>(2) Employee returning from an extended absence<br>(3) Employee hired on a contract basis<br>(4) Student workers<br>(5) Supplied/contracted labor workers<br><br>Responsibilities for orientation training should be Assigned Time frames for orientation training should be set<br><br>Components of orientation training should include:<br>Health and Safety Policy<br>Employee Responsibilities and Rules<br>Standards/procedures for: Reporting Injury/illness; Reporting Hazards; Emergency Response/Evacuation; Early and Safe Return to Work; Worker Health and Safety Representative activities.<br>Refusal to Work<br>Workplace tour, including: Introduction to the Worker Health and Safety Representative, Emergency equipment, exits, first aid stations, etc. Health and Safety postings<br>

  • Do all employees receive annual refresher training on EHS rights and responsibilities? Guidance: Annual HSSE refresher training should include the following topics:<br>(1) Basic HSSE responsibilities;<br>(2) Right to refuse work;<br>(3) Right to participate (Safety Committee and/or H&S Representative);<br>(4) H&S Policy (and progressive discipline program for failures to adhere to policy);<br>(5) Return-to-Work Program.

  • Does the site train employees on the required monthly safety training topics and able to obtain documentation of the training upon request?

  • Has the site identified and ensured that employees exposed to HiPo hazards are properly trained? Guidance: Review C&W's HiPo Training Program requirements on the SharePoint site. The site must Identify training needs, assign training requirements, and verify completion of training by doing the following:<br>(1) Identify personnel/occupations that perform activities with major (HiPo) task hazards*, e.g., authorized drivers, BBP clean-up personnel, Confined Space Entry Teams, personnel required to wear respirators, ...<br>(2) Review the Groups of major (HiPo) task hazards and update each category with the names of any new personnel/occupations.<br>(3) Review training progress reports on a periodic (monthly) basis and take action as needed to ensure completion of all required HiPo training.

  • Has the site established an approach and location for managing required EHS Program Documentation? Guidance: Required storing/maintaining EHS Program Documents include:<br>- Ensuring all employee know how to access company EHS programs<br>- Know how to request copies of EHS program documents<br>- Maintaining required training records<br>- Maintaining required EHS program compliance documentation

  • Is the site aware and utilizing the Company's Transitional (Light Duty) Work Program to manage WC cases? Guidance: If/when an injury occurs and a worker is placed on work restrictions it is critical we get that employee back to work as quickly as possible. Is the site aware of the company's return to work program, or have a process established to get injured employees back to work?

  • Has the site established a working relationship with a local Occupational Health Clinic to promote effective management of WC claims? Guidance: C&W uses Travelers for workers' comp claims. Travelers offers a list of in-network clinics close to your location. Have you identified a local clinic to send an employee in the event of a on the job injury? In addition, once a clinic is identified you should provide the company's work comp information, site contacts, job descriptions for each employee type, establish drug/alcohol testing for post injury, and inform them of our return to work (light duty) program.

  • Has the account/site established a working relationship with the customer and site security to ensure that all 3rd party incidents (and other potential GL claims for which the Company may be liable) are communicated immediately to Company's site management?

  • Has the site implemented C&W's nurse triage program and ensured all employees are trained on how to use/contact the nurse triage service provider? Guidance: C&W has a nurse triage provider that any employee who is involved in a workplace incident must contact for any injury/incident that is not an emergency.

  • Emergency Response/Evacuation: Does the site limit the Company's involvement in emergency response activities to employee evacuation (only)? Guidance: Note, as regards Emergency Preparedness and Response, Company scope of services is typically limited to Emergency Evacuation (i.e., evacuating the area in cases of an emergency, not Responding to Emergencies). Contact your EHS Resource if your site plans to utilize Company employees to provide Emergency Response (HazWoper; 29 CFR 1910.120(q)) services.<br><br>Emergency Evacuation Planning should include the following:<br>1. Define the training requirements:<br>2. Develop Drills or practice scenarios.<br>3. Establish Time frames for training completion.<br>4. Assign responsibility for training delivery<br>5. Evaluate the training and make changes to plans as needed.<br>6. Record training.

  • KPI Monitoring: Does the site (and/or Region) have a process and schedule for comparing Account performance KPIs/targets and taking action, as needed? Guidance: Each region/site is required to track and monitor EHS KPIs that align with the Account's overall EHS performance metrics. Does your site/region have a tracking process specific to your site/region?

  • Does your site conduct self-inspections on a scheduled basis? Guidance: Self Inspections are a requirement of all sites/regions. The types and schedules for self-inspections is to be determined by Operations, in consultation with your EHS resource. Self Inspections are available on SharePoint as an attachment to each Program document.

  • Incident Reporting: Does the account report incidents in accordance with Company program requirements? <br>1 Initial reporting within 24 hours;<br>2 Investigation within 72 hours and;<br>3 Notifying the Insurance company. Guidance: Requirements include: Completing the forms in Gensuite in a timely manner<br>You can find the Incident Reporting/Management Process on SharePoint<br>1. Initial reporting/notification within 24 hours<br>2. Investigations within 72 hours and<br>3. Notifying the Insurance company once a determination has been made that the incident is work-related.

  • Records Administrator: Has the site designated responsibility for managing EHS records? Guidance: Someone within your site/region should be designated to manage and administer EHS recordkeeping.

  • Is the site's current OSHA Log (OSHA 300 Form) being properly maintained? Guidance: OSHA requires each OSHA Recordable Incident be posted on the site log within 7 days. This will typically be done within Gensuite.

  • Is the OSHA 300A Form being managed/posted in accordance with OSHA regulatory requirements? Guidance: The 300A must be reviewed, signed by the Account Director, and posted in a prominent location annually, from February 1 to April 30 of the year following the year that is covered by the Form. For example, the 300A for 2019 must be posted starting Feb 1, 2020 until April 30th. Contact your EHS Resource with any questions.

  • Does the account/site maintain OSHA Records in the secure location in accordance with regulatory requirements? Guidance: Recordkeeping requirements include:<br>1 OSHA Logs (Form 300) must be up-to-date for the current CY (w/in 7 days of the most recent recordable) and copies of Logs must be maintained for the previous 5 CYs;<br>2 OSHA Annual Summary (Form 300A), signed and dated copies, must be maintained for the previous 5 CY.

  • Are training records filed in a secure location and do records of completed training include a class roster (or equivalent) with signatures and a description of the training and trainer? Guidance: Review a sample of records for the core compliance programs (HazCom; BBP; PPE; Emergency Evac) to assess compliance.

  • Are employee medical records/files kept confidential and maintained in a locked file cabinet or other secure location? Guidance: Examples of Medical Records: BBP HBV shots and/or BBP incident exposure records, HazWoper medical surveillance records, chemical or asbestos exposure monitor, Medical Physician's notes. Additionally, respiratory medical evaluations is another example.

  • Is the access to each employee medical file restricted to the site manager, the designated records admin, and the employee (and their designee)? Guidance: Medical Records should be restricted to certain individuals, employees should be allowed access to their personal medical files upon request.

  • Do all management and supervisory personnel have access to Gensuite and understand the requirements for entering work related incidents? Guidance: Gensuite is used for the following:<br>- Incident reporting and management<br>- OSHA recordkeeping<br>Management and supervisory personnel should have access to the system and be trained in how to use the system. Contact EHS with access/permissions request.

  • Are all site/region employees in the SafetySkills system and completing training on a monthly basis? All site/region employees should be enrolled in Safety Skills to complete monthly EHS training.

  • Is the site/regional locations listed in KHA, and do all supervisors/management have access to the system to monitor chemical inventories? Guidance: All site chemical inventory and SDS should be available in KHA and up to date at all times.


  • This Program applies to all C&W site locations. Guidance: The ARR requirements of this Program must be reviewed by all C&W worksites, without exception. The ERGO Program applies to both field (e.g., janitorial and maintenance) workers and administrative office personnel. Strains and sprains from improper lifting and movement are a major source of C&W incidents and losses. In addition, administrative office personnel working at Video Display Terminals (VDT) are susceptible to various injuries, including Carpal Tunnel Syndrome.

  • Are employees trained on proper body position and/or lifting techniques and the consequences of improper lifting? Guidance: Each site should evaluate ergonomic risks and provide safety training related to the work task hazards. Training should include reporting early warning signs/symptoms of ergonomic related injuries.

Walking Working Surfaces

  • This Program applies to all C&W site locations. Guidance: The ARR requirements of this Program must be reviewed by all C&W worksites, without exception.

  • Has the site adopted the Company Walking and Working Surfaces Program (or one that is equivalent or safer)?

  • Is there a documented, functioning housekeeping program in place? Guidance: Are housekeeping inspections conducted regularly to assure areas are clean, sanitary and orderly?

  • Are aisles and passageways inspected regularly to assure they are kept clear, and are walking and working surfaces inspected regularly for holes in the floor, sidewalk or other walking surface and are they repaired promptly, covered or otherwise made safe?

  • Are all employees informed of the requirement for spills to be cleaned up immediately?

  • If the site(s) has aisle or walkway surfaces elevated more than 48 inches above an adjacent floor or ground, are standard guardrails provided?

  • If the site(s) has floor openings are they guarded by a cover, a guardrail or equivalent? Guidance: if floor tiles are removed for service/maintenance the open hole shall always be guarded per policy.

  • Stairways– For all stairways having four or more risers, are standard stair rails or handrails present?

Bloodborne Pathogens BBP

  • This Program applies to all C&W site locations (see Guidance). Guidance: "The ARR requirements of this Program must be reviewed by all C&W worksites, without exception. In addition to basic program requirements, such as an ECP (Exposure Control Plan), C&W's BBP Program requires training. For purposes of BBP training, each C&W employee is classified as either a BBP Affected Worker or a BBP Clean-up Worker: <br>(1) BBP Awareness training applies to all employees, both Affected and Clean-up Workers. The Awareness Training includes; (a.) a description of the two types of workers and their roles and responsibilities; (b.) the prohibition on blood clean-up by Affected Workers and; (c.) informing employees of the names of the site's authorized BBP Clean-up Workers and how to contact them for BBP clean-up; <br>(2) Additional training for BBP Clean-up Workers applies only to C&W employees who are formally authorized by their site/account management to clean up blood and Other Potentially Infectious Materials (OPIM). The training includes procedures and practices for cleaning up blood and OPIM.

  • Written Bloodborne Pathogen (BBP) Program - Is the site using the Company's written BBP Program (or using an alternative written program that is equivalent or safer) to develop its site-specific BBP Program, including Exposure Control Plan? Guidance: If your site is using an alternative written BBP program, it must be reviewed and approved by EHS.

  • Does the site management conduct a review and update of its written site-specific BBP Program, including its Exposure Control Plan, at least annually? Guidance: Annual reviews must be documented and maintained on file for review upon request.

  • Training: For employees whose job assignments include Occupational Exposure to BBP or OPIM, is BBP training provided before or at the time of the employee's initial assignment, and annually thereafter? Guidance: Employees with Occupational exposure to BBP and OPIM are those employees who are assigned/authorized to clean up blood or OPIM. In general, all employees who work in a healthcare environment have occupational exposure.

  • BBP Awareness Training – Is BBP Awareness Training provided to the Company's employees who do not have Occupational Exposure to BBP, particularly information regarding: (a.) who is authorized for BBP clean-up and (b.) the prohibition on BBP clean-up by other than authorized staff?

  • HBV shots - Are employees with occupational exposure to Blood or OPIM offered the Hepatitis B Vaccination (HBV) series within 10 days of their initial job assignment? Guidance: "Note, the HBV Series is typically provided to: (a) a select number of C&W employees at non-health care facilities where C&W is responsible for BBP clean-up and (b) all C&W personnel at health care facilities, since most personnel at such facilities are considered to have occupational exposure to BBP). Contact EHS with any questions."

  • HBV Declination Form - Have all those employees who refused to receive the HBV series read and signed a "declination" statement. Guidance: The HBV Declination Form can be found within the C&W BBP program. Once an employee is offered the vaccination, if they decline they should complete and sign the declination form. This document must be retained in the employees medical file for the duration of employment. If the employee refuses the vaccination this does not mean they can't elect to receive the vaccination at a later date.

  • Post-exposure Evaluation and Follow-up - If BBP exposure incidents have occurred at the site, were the incidents managed in accordance with the BBP Standard, as specified in our BBP program, including providing confidential medical evaluations and follow-up with a healthcare professional? If not, contact EHS immediately.

  • Equipment: Are "sharps containers" (i.e., containers for disposal of sharps/needles) at the site, closable, puncture resistant, leak proof on sides and bottom, and labeled with a biohazard warning label and/or colored red? In some cases the client may provide sharps containers at the site, and in others C&W may provide this service under the SOW. If C&W is responsible for this service, does the site provide the appropriate equipment and have a disposal vendor established for routine pick up and disposal at an approved disposal facility?

  • Sharps Injury Log - Does the site maintain a sharps injury log for the recording of (percutaneous, i.e., skin puncture) injuries from contaminated sharps/needles, is the information in the sharps injury log maintained in a confidential manner, and are the incidents treated as OSHA Recordable?

  • Recordkeeping (Training Records) - Are BBP Training records maintained for a period of at least 3 years from the date of initial training, including the dates of each training, contents of training, names of trainers, and the attendance sheet for each training session, which includes the names and job titles of the attendees along with their signatures? Guidance: Training records should be available at the site upon request.

Personal Protection Equipment

  • This Program applies to all C&W site locations (see Guidance). Guidance: "The ARR requirements of this Program must be reviewed by all C&W worksites, without exception. The requirements of our PPE Program apply to all C&W worksites, without exception. Compliance with C&W's PPE Program [and key requirements of the OSHA PPE Standard (29 CFR 1910.132(d), Hazard Assessment & Equipment Selection] is based on completion of the ARR Worksite Hazard Assessment (WHA), which requires: <br>1. JSAs (Job Safety Analyses) be developed for jobs with significant hazards; <br>2. The JSAs specify PPE usage and maintenance; <br>3. Employees are trained on the JSAs/PPE (and the training is documented and maintained); <br>4. The PPE specified in the JSAs is provided to employees, at no cost to the employees."

  • Has the site adopted the Company PPE Program (or one that is equivalent or safer)? Guidance: In some cases the customer may also have specific PPE program requirements that C&W employees must follow.

  • Has a job/task hazard assessment been conducted in the workplace to identify possible hazards that would require the use of PPE? (e.g., PPE requirements specified on SDSs or JSAs)

  • Based on the hazards identified for each job/task, has appropriate PPE been selected? (PPE may be required for hazards to the eye (glasses/goggles); face (face shield); head (hard hat); body (electrical/fire resistant clothing), hands (gloves), feet (steel toed shoes).

  • If PPE is necessary to prevent injury or impairment from a job/task (based on exposure to chemical hazards, radiological hazards, or mechanical irritants through absorption, inhalation or physical contact), is it provided and at no cost to employees? (note, in addition to PPE, eyewash stations and/or showers are required where corrosive chemicals may be used and where required by a SDS) Guidance: The site(s) should have a PPE program in place and monitored and evaluated on a routine basis. In addition, PPE inventory should be established and readily available to employees.

  • Has the site implemented a PPE program and store PPE supplies at the site?

  • Are protective helmets (e.g. hard hat or bump cap) required when performing over head work such as working in the ceiling, removing ceiling panels, overhead piping, etc. Protective helmets are also required wherever there is the possible danger of head injury from impact, or from falling objects, or from electrical shock and burns. Guidance: it is recommended to supply hard hats with chin straps so they do not fall off while working and working at-heights.

  • Footwear Policy: Has the site implemented a protective footwear program? Guidance: All maintenance/engineers personnel are required to wear 6" safety boot, lace up, protective toe, slip resistant soles, EH rated, and footwear must meet the most recent ASTM standard.

  • Glove Policy: Has the site implemented a protective glove program? "No bare handed work". All work tasks require the use of protective gloves selected for each work task. Guidance: The site should evaluate job tasks and select appropriate gloves for each job. No bare handed work.

  • Safety Glasses Policy: Has the site implemented a safety glasses policy? Safety glasses are required when engaging in any work task, and in areas where safety glasses are required. Guidance: Consideration should be given to employees who wear prescription eye wear. RX glasses should meet the ANSI Z87 standard. Over the glass safety glasses may be needed to comply with this standard/policy. Authorized electrical persons shall wear non-conductive frames.

Emergency Action Plan (EAP)

  • This Program applies to all C&W site locations. Guidance: The ARR requirements of this Program must be reviewed by all C&W worksites, without exception. Compliance with C&W's EAP Program requirements [and OSHA EAP Standard (29 CFR 1910.38(a)] is typically achieved by following our customers/client's EAP program, including training on customer/client alarms, escape routes, and rally points. Note, EAP requirements are different from Emergency Response (Spill) Response, with the latter addressed under a separate Program.

  • Does the site have a written Emergency Action (Evacuation) Plan that is kept in the workplace and is available to employees? Note, the site should utilize the customers EAP whenever possible. Guidance: If the client does not have an EAP Plan, C&W should develop a plan for the site.

  • Minimum elements of an EAP - Does the EAP include (a.) procedures for reporting a fire or other emergency; (b.) procedures for emergency evacuation, including type of evacuation and exit route assignments; and shelter in place (c.) procedures to be followed by employees who remain to operate critical plant operations before they evacuate; (d.) procedures to account for all employees after evacuation; (e.) procedures to be followed by employees performing rescue or medical duties; and; (f.) the name or job title of personnel who employees may contact if they need more information about the plan or an explanation of their duties under the plan.

  • Alarms - Does the EAP include an employee alarm system with distinctive signal for each purpose?

  • Training of support personnel - Have (supervisory or other) personnel been designated and trained to assist in a safe and orderly evacuation of employees? Note- this should be specific to the site EAP.

  • General training - Do all Company employees receive EAP training: (a.) when the employee is assigned initially to a job; (b.) when the employee's responsibilities under the plan change; and/or (c.) when the plan is changed? Guidance: Training should be documented and readily available at the site upon request.

  • Do employees participate in evacuation drills, at least annually? Guidance: Evacuation drills should be documented and readily available at the site upon request.

Hazard Communication (HazCom)

  • This Program applies to all C&W site locations. Guidance: The ARR requirements of this Program must be reviewed by all C&W worksites, without exception.

  • Written HazCom Program - Has the site adopted the company's written Hazard Communication Program (or an equivalent written program)?

  • Is the program readily available to any Company employee upon request (and do all employees know where the program is located on site)?

  • Are all non-routine tasks evaluated prior to initiation to determine chemical hazards present? Guidance: Employees should review chemical Safety Data Sheets (SDS) prior to using a chemical in the workplace.

  • Chemical Inventory/List - Has an inventory of the chemical substances used on site been conducted and documented on a Chemical Inventory List, and is the List readily available to Company employees? Guidance: Site chemical inventory should be updated continuously in the KHA Online SDS System. The site should dedicate someone as the HazCom coordinator responsible for updating the chemical inventory and associated SDS.

  • Is the Chemical Inventory List kept current to reflect the products currently used on site and has it been reviewed and updated within the past 12 months?

  • Safety Data Sheets (SDS) - Is a SDS available for each chemical stored/used on site and each chemical shown on the site's List? Guidance: All SDS should be updated and available in the KHA Online SDS system.

  • Are SDSs readily available to all potentially affected Company employees, including those on shift work? Do all employees know how to access KHA Online SDS, or know how to request a copy of an SDS? Guidance: Site employees should be trained on how to access or request of copy of an SDS. If asked if someone knows how to access an SDS would site employees know how to properly respond?

  • Labeling - Are all chemical containers properly labeled, including limited or secondary use containers? Guidance: A process should be in place to ensure limited and secondary containers are labeled. Employees should be trained on the labeling requirements.

  • Subcontractors - Are Company subcontractors required to provide information/SDS for all hazardous chemicals they plan to bring on site? Guidance: Contractors bringing chemicals/substances on site should be approved in advanced and uploaded in the sites chemical inventory within KHA Online SDS system. Once contractors remove the chemicals the system should be updated to reflect current site inventories.<br>

  • General Training - Are employees provided with information and training on the general hazards of chemicals, initially upon hire and whenever a new hazard is introduced into their work area? Guidance: Employees shall receive training on chemical hazards upon initial hire. When new chemicals/hazards are introduced additional training shall be provided prior to being assigned additional job assignments.

  • Are employees prohibited from working unsupervised with chemicals until their HazCom training has been completed?

  • Job (Product-Specific) Training - Do employees receive training on the product-specific chemical hazards to which they might be exposed when performing their job tasks?

  • Use of chemicals - If chemicals are used by employees are eye-wash stations and showers installed in close proximity (within 25 ft; 10 seconds) of the task hazard or, if not, are emergency eye wash bottle stations available in the immediate vicinity? Check chemical SDSs for corrosive properties. Note, some concentrates used in mixing stations and caustic chemicals used in battery charging stations are corrosives. Tasks involving the use of corrosive chemicals, including reloading corrosive concentrates into mixing stations, require employee training on required PPE (use of goggles and gloves) and the location of eye wash stations (and emergency eye wash bottles, if eye wash stations are not in immediate proximity). Guidance: Eye wash and shower stations shall be available in areas where chemicals are stored and handled. Eye wash stations shall be inspected at a minimum on a monthly basis, inspections shall be documented by use of a inspection tag located on the eye wash station.

  • Do employees receive a HazCom Refresher Training, at least annually?

  • Does site management conduct an annual review of the HazCom program? Has a site HazCom coordinator been assigned?


  • This Program applies to all C&W site locations. Guidance: The ARR requirements of this Program must be reviewed by all C&W worksites, without exception. Note, this Program applies to general electrical safety awareness. In contrast, Qualified Electrical workers, i.e., those who are authorized by site management to service or repair electrical machinery or equipment, are required to comply with the additional, more rigorous Program requirements of the Qualified Electrical Workers Program.

  • General Electrical Awareness - Have all Company employees with exposure to “cord and plug” equipment completed Electrical Safety Awareness training? Guidance: Cord and Plug equipment includes backpack vacuums, stand-up vacuums, buffing machines, wet/dry vacuums, power washers, scrubbers, etc. Employees who only operate “cord and plug” equipment, are only required to complete Electrical Safety Awareness training on cord and plug equipment (to prevent potential exposure to hazardous situations).

  • Do any C&W employees serve as Qualified Electrical workers (see Guidance)? Guidance: "This C&W program applies to C&W employees who service or repair electrical machinery or equipment, including verifying equipment is de-energized using volt meters, conducting infrared scans of equipment by testing current and/or removing/installing electrical panel covers. This type of work requires compliance with both OSHA (and NFPA 70E 2021) requirements for Qualified Electrical Workers. Note, per OSHA (29 CFR 1910.332), employees in the following occupations face risk of electric shock and must be managed as OSHA Qualified Workers: <br>Blue collar supervisors(1); Electrical and electronic engineers(1); Electrical and electronic equipment assemblers(1); Electrical and electronic technicians(1); Electricians; Industrial machine operators(1); Material handling equipment operators(1); Mechanics and repairers(1); Painters(1); Riggers and roustabouts(1); Stationary engineers(1); Welders; Other employees who also may reasonably be expected to face comparable risk of injury due to electric shock or other electrical hazards must also be trained.<br>_________________________<br> Note (1): Workers in these groups do not need to be trained if their work or the work of those they supervise does not bring them or the employees they supervise close enough to exposed parts of electric circuits operating at 50 volts or more to ground for a hazard to exist."

  • Has the site adopted the company's written Electrical Safety Program? (or one that is equivalent or safer)?

  • Arc Flash and Shock Protection PPE – Is shock and arc flash protection provided to all qualified electrical persons (QEP)? Guidance: Shock protection at a minimum includes rubber insulating gloves with leather protectors rated for the voltage the QEP is authorized to work on. Arc Flash PPE includes at a minimum CAT 2 and 4 PPE as outlined in NFPA 70E 2021 and the C&W electrical safety standard.

  • Has the site(s) implemented the C&W Electrical Glove Program? Guidance: The electrical glove program can be found on the C&W @ Citi EHS SharePoint site. Rubber insulating gloves shall be shipped to our 3rd party vendor and tested every six months and follow the color coding methodology outlined in our program/policy. Black gloves are in service October-March and Red gloves in service April-September each calendar year.

  • Arc Flash and Shock Protection PPE- Is shock and arc flash protection inspected and calibrated at the required intervals? Guidance: All PPE requires routine inspection and maintenance. Rubber insulating equipment shall be inspected and calibrated at required intervals as specified by the manufacturer or as outlined in the C&W electrical safety standard (Attachment G). All testing/calibration testing shall be documented and retained on file.

  • Training - Have all employees who are designated as “qualified electrical persons” completed initial NFPA 70E training prior to performing electrical work and complete refresher training every 3 years thereafter? Guidance: Qualified Electrical Persons shall receive training in NFPA 70E and retraining at a minimum of every 3 years thereafter. Training documentation must be retained at the site and provided upon request.

  • Have all qualified electrical persons completed an QEP electrical qualified person evaluation to demonstrate competency for the tasks in which they perform? Guidance: The C&W electrical safety standard requires all QEPs complete a demonstrated electrical evaluation by a competent person. The evaluation should document proficiency in electrical task(s) and safe performance of the work. Evaluations should be updated at a minimum of every three years, or when new hazards are introduced.

  • Are qualified electrical persons provided with a UL approved CAT III or IV voltage meter that's rated for the voltages for which they are exposed and/or work with? Guidance: QEP's should verify competency in the use of using a voltage meter properly and be able to verify zero voltage/energy using the "testy-verify-test" method. Test-verify-test involves testing the meter on a known voltage source, verifying the equipment being worked on is de-energized, and then testing again on a known voltage source to verify the meter is still working properly. Recommended BMP: All QEP's to be provided with a Fluke "proving unit" to perform meter testing prior to working on electrical equipment. <br>

  • Have all qualified electrical persons reviewed and been trained on the C&W Lighting Ballast Policy? Guidance: Training on the C&W Lighting Ballast Safety Policy must be completed upon initial assignment and reviewed on a periodic basis. Training documents must be available at the site and provided upon request.

  • Have QEP's been provided with first aid training? Guidance: NFPA 70E and the C&W Electrical safety standard requires that QEP's be provided with first aid training. Sites are encouraged to provide certified CPR/AED training, but at a minimum basic first-aid training should be provided.

Portable Ladder Safety

  • Do any C&W employees use portable ladders? Guidance: Falls from portable ladders (step, straight, combination and extension) are one of the leading causes of occupational fatalities and injuries.

  • Has the site adopted the company ladder safety program (or one that is equivalent or safer)?

  • Is the site using only approved Ladders of the correct Ladder Type (e.g., Type 1- 250 lbs. Industrial, Fiberglass Ladders in cases where all potential users weigh less than 250 lbs., when fully loaded with tools and equipment; Type 1A - 300 lbs. Industrial, Fiberglass for all other applications)? Guidance: Wooden ladders are not permitted for use at C&W work sites.

  • Has a Formal Ladder Inspection program (Company or equivalent) been implemented, including documented inspections? Guidance: Formal Ladder Inspections must be completed at least Monthly/Quarterly by the site supervisor/manager and must be maintained for review by Company Auditors? Refer to the C&W Ladder safety program for ladder inspection criteria and documentation requirements.

  • Are ladders inspected by employees before and after each use, including verifying the ladder rating? Guidance: All ladders must include the manufacturer's rating sticker. If the sticker is missing, notify your supervisor, so they can obtain a sticker from the manufacturer.

  • Are damaged ladders removed from service and tagged "Do Not Use."

  • Are all Company employees who use ladders properly trained in ladder selection, use, and the need for inspection, prior to each use? Guidance: Training should be documented and readily available at the site upon request.

Work at Heights - Fall Protection

  • Do any C&W work tasks expose C&W employees to fall hazards from an unprotected edge greater than 4 feet? Guidance: This Program is also applicable to sites with employees using or having harnesses, lanyards, or other types of fall protection equipment, as well as any sites with tasks with employee exposure to the potential for falls from an unprotected edge of over 4 feet. This also applies to roof access and tasks on the roof of buildings.

  • Has the site adopted the Company Work at Heights (Fall Protection) Program (or one that is equivalent or safer)?

  • Have areas/tasks with fall-from-height exposure been documented and communicated to staff? Guidance: Fall from heights also includes roof work. If employees are exposed to fall hazards within 6ft of the leading edge fall protection measures shall be implemented (e.g. gaurdrailing, anchorage points, fall restraint, etc.). Contact EHS with any questions.

  • Roof Access- do employees perform work within 6 feet of the roof edge, if so are there adequate fall protection controls in place? Guidance: OSHA requires fall protection controls in areas where employee perform within 6ft from the leading edge (roof edge). Fall protection controls include parapet walls (42" +/- 3" from the walking surface), fall arrest/restraint, guard railing, etc..

  • Roof Access- Has the site(s) adopted/implemented the C&W roof access policy? Guidance: Cushman & Wakefield has a roof access policy which includes the use of a work permit prior to personnel and contractors accessing the roof. The permit is used to address hazards and to ensure appropriate fall protection controls are in place based on the work that is to be performed. The permitting process is required unless the site has a roof access fall protection plan in place specific to the building.

  • Are employees with tasks involving fall-from-height exposures trained on and provided with required fall protection and/or fall restraint equipment?

  • Are employees trained in fall protection prior to initial assignment and annually re-trained in the proper use of fall protection and/or fall restraint equipment? Guidance: Fall Protection Training must be performed by a competent person. Training should also include "hands-on" training to demonstrate proper use and application of the fall protection each qualified person is expected to use.

  • Has a plan been developed to promptly rescue any employee who has fallen while using a fall protection system? Guidance: If the plan includes the use of local fire or rescue services – have they been consulted to ensure that they have the capability to make the rescue?

  • Does a Competent person, other than the employee assigned the equipment, conduct documented periodic inspection of personal fall protection equipment according to manufacturers instructions? Guidance: Manufacturers will specify the inspection criteria for the fall protection equipment (i.e. harnesses, self-retracting life lines, lanyards, etc.). In some cases equipment will need to be shipped to a certified testing facility annually for 3rd party inspection. All inspections shall be documented for ALL equipment.

  • Does the site have roof anchorages for window washing or other fall protection anchorage devices/systems? If so, these anchorages shall be inspected annually by a competent person. Guidance: C&W requires the use of 3rd party competent person inspections for all fall protection anchorages, fall restraint, and fall arrest systems. Inspections shall be documented and retained at the site and made available upon request. Documentation should be retained for at least 5 years.

  • Does the site have fixed ladders 24ft or greater? If so, are these ladders equipped with a fall arrest system affixed to the ladder and authorized personnel required to tied off when using the ladder? Guidance: ladders 24ft or greater must have a fall protection system installed and certified by a competent person to ensure the design of the ladder and fall protection system are adequate for the design.

Lockout Tagout - LOTO

  • Do any C&W employees perform Lockout Tagout, e.g., for service or maintenance tasks? Guidance: The LOTO Program applies to C&W employees who perform any of the following activities: (1) Service and/or maintain machines and equipment; (2) Move or bypass a guard or other safety device during normal operations; (3) Place any part of their body into an area on a machine or piece of equipment where work is performed on material (point of operation) or a danger point exists.

  • Has the site adopted the Company's LOTO Program or an equivalent program that has been reviewed and approved by EHS (for equivalent programs, see the Guideline text)? Guidance: Note, any equivalent program, such as a customer LOTO Program, must either: (1.) have ECPs (Energy Control Procedures) for every piece of equipment on their worksite(s) or (2.) have a procedure for developing ECP (similar to our Work Authorization Permit (WAP) process) or (3.) be amended to include our WAP process, to ensure we can develop ECPs as needed/required.

  • Are Energy Control Procedures (ECPs ) and/or Work Authorization Permits (WAP) available or developed prior to servicing any piece of equipment or machinery involving potential for exposure to hazardous energy? Guidance: C&W LOTO program requires the use of ECPs and/or WAPs for all equipment regulated under the program and the account scope of work (SOW). The ECP/WAP shall be equipment and task specific for the control of the hazardous energy.

  • Has each "authorized" employee been issued personal identifiable locks and tags? Guidance: "Authorized Employee = A person who locks out or tags out machinery or equipment in order to perform servicing or maintenance on that machinery or equipment. An affected employee becomes an authorized employee when that employees duties include performing servicing or maintenance covered under this program.<br>The term “authorized employee” is used to designate an employee who has been formally authorized, by management, to perform LOTO on machinery or equipment"

  • Are lockout/tagout devices standardized within the facility as outlined in the C&W lock and lockout device equipment standards: color, shape, size, print and format? Guidance: Personal Red Locks should be issued to each authorized person. Each lock set should be keyed alike and have only one key for each set. Blue Locks provided for equipment locks. Black Locks are used for "departmental" locks for out of service equipment. The site may choose to have lockout stations for equipment locks and out of service locks.

  • Are chains, wedges, key blocks, adapter pins, self-locking fasteners, or other LOTO hardware provided for isolating, securing or blocking of machines or equipment from energy sources? Guidance: The site should survey equipment and ensure all lockout devices are available to appropriately isolate all equipment's hazardous energy.

  • Initial Training - Have all Authorized Employees who perform LOTO received authorized employee training? Guidance: Sites shall provide training to ensure that employees understand the purpose and function of the LOTO program and they have the knowledge and skills needed for safe implementation. Training should include a documented demonstration that each authorized person can properly lock/tagout equipment and understands how to complete a WAP/ECP prior to performing LOTO.

  • Initial Training - Have all Affected Employees been instructed in the purpose and use of the energy control procedures? Guidance: Affected Employee = An employee whose job requires him/her to operate or use machinery or equipment on which servicing or maintenance is being performed under lockout or tag out, or whose job requires him/her to work in an area in which such servicing or maintenance is being performed.

  • Refresher Training: Has refresher training been provided at least annually or when a change in condition requires it? (See Guidance for "Change in Condition") Guidance: "Change in Condition means any of the following:<br>1) A change occurs in an authorized and/or affected employee job assignment, a change occurs in the machinery, equipment or processes that might present a new hazard, or a change occur in the LOTO Program.<br>2) An inspection of equipment reveals the need for a change in the LOTO Program.<br>3) The site management/supervision has reason to believe there are inadequacies in the employees knowledge or implementation of the LOTO Program.<br>4) C&W identifies the need to reestablish employee proficiency and/or introduce new or revised control methods and procedures.

  • Site LOTO Program Review (Annual) - Has the site performed a documented inspection on the ECP/WAP at least annually by a person who is: (a) knowledgeable in the Company's LOTO Program and (b) NOT participating in the operation being inspected? Guidance: OSHA requires an annual review/audit of the company/site LOTO program to ensure the program is implemented and effective. Site(s) shall use the documented inspection within the company LOTO standard (Attachment D)

Driver Safety

  • Do any C&W employees operate motor vehicles (company or private/employee owned) on US or Canadian roads for business purposes?

  • Has the site adopted the Company Driver Safety Program (or one that is equivalent or safer)?

  • Has the site documented and maintained a list of employees who are authorized to operate a vehicle (company owned or privately owned) for business purposes?

  • Have all employees operating a vehicle (company owned or privately owned) for business purposes received driver safety training?

  • Have Driver History checks (also known as Motor Vehicle Record) been done on all employees who have been authorized to operate a vehicle (company owned) for business purposes?

  • Are periodic license and/or DMV background checks performed? Guidance: C&W employees authorized to operate a vehicle for company business should demonstrate proof of a valid state drivers license on an annual basis.

  • Are monthly/quarterly required periodic vehicle checks being documented and audited to ensure vehicle safety? Guidance: For all company owned or leased vehicles documented inspections are required on a quarterly basis. Vehicle inspection forms are found in the C&W Fleet Policy located on the SharePoint website.

  • Are mobile engineers required to place cones out when stopped at a location? Guidance: When a vehicle is parked at a customer location or any other location cones shall be deployed in the front and rear of the vehicle.

  • Is the use of cell phones, including calls, texts, and emailing prohibited while operating a motor vehicle? Guidance: C&W policy prohibits the use of mobile devices while operating a motor vehicle.

  • When parking at a client site or other location are drivers trained to utilize parking lots vs street parking whenever designated lots are available? Guidance: by parking in dedicated parking lots at a location this reduces the risk of a motor-vehicle incident when parking on the street.

Waste Management. Recycling

  • Do any C&W employees manage "highly regulated" wastes (see guidance)? Guidance: "The scope of this Program does not include on-site collection and management of typical municipal trash. This Program does include local recycling requirements, as well as on-site management and/or off-site disposal of highly regulated waste, including:<br>1. Hazardous waste, under RCRA or state regulations, either ""listed"" or ""characteristic"" (e.g., ignitable, corrosives, reactives of toxics), waste oil; <br>2. Universal wastes, including waste batteries, pesticides, and mercury containing equipment and/or mercury containing light bulbs;<br>3. Asbestos Containing Building Material/ACBM/ACM waste, from pipe or equipment insulation, wall board, ceiling tiles, and/or floor tile/mastic;<br>4. PolyChlorinatedByphenol (PCB) waste, e.g., from old electrical transformers;<br>5. Lead Based Paint (LBP) wastes, e.g., from sanding or scraping LBP.

  • Has the site adopted the Company Waste Management Program, WMP (or one that is equivalent or more environmentally protective)? Guidance: Services related to the on-site management of hazardous/universal wastes may be provided if these services comply with all regulatory and Company requirements. Services related to the off-site disposal of wastes, of any kind, including characterization of wastes and/or signing of waste manifests or bills-of-lading, are strictly prohibited without the review and approval of both Legal and the EHS Department.

  • Waste Inventory - Has the Account/Site developed an inventory/list of all waste streams managed by the Company, e.g., waste oils and solvents from maintenance tasks and/or wastes from janitorial tasks, including floor mopping, stripping, auto scrubbing, refurbishing, recoating? Guidance: The C&W site operations, including projects, shall create a waste "inventory" documenting the waste stream(s) generated from C&W operations and contractors.

  • Waste Water Management - If any Company operations result in the discharge of waste water, e.g., discharge of wastewater from janitorial or maintenance cleaning tasks to drains, did the site do all of the following: (a.) consult with the customer to verify and document the location of sanitary and storm sewer drains; (b.) verify that any waste water (from C&W operations) that are discharged into the sanitary sewers complies with local discharge requirements; (c.) train the appropriate C&W personnel on the proper disposal of waste waters (via designated sanitary sewer drains, e.g., slop sinks) and the prohibition on discharge of wastes to storm sewers/drains and (d.) inspect the discharge operations periodically to verify that the proper procedures are being followed by Company employees? If these requirements have not been met, the site must complete these tasks immediately. Guidance: Waste Water Management should be approved and evaluated by EHS.

  • Hazardous Waste Management (on-site) - If C&W is responsible for on-site management of hazardous waste (e.g., movement and labeling of containers of hazardous waste) has this service been reviewed by EHS? If not, contact EHS immediately.

  • Universal Waste Handling (on-site) - If C&W is responsible for on-site handling of universal wastes has this service been reviewed by EHS? If not, contact EHS immediately. (note, Universal Wastes include (1) waste batteries; (2) certain pesticide products; (3) discarded mercury-containing thermostats and (4.) hazardous waste lamps. Guidance: Waste Disposal companies must be approved by C&W procurement and properly permitted to collect and dispose of the regulated waste materials.

  • Waste Minimization/Recycling - Are there any local requirements for waste minimization/recycling and, if so, have they been incorporated into C&W operations? Guidance: In some states and local agencies their will specific waste minimization/recycling requirements. C&W operators should ensure any state and local requirements are being followed.

  • Manifests and Bills-of-Lading - Have C&W personnel been made aware of the prohibition on signing waste manifests, bills-of-lading and wastewater DMRs? Guidance: C&W personnel are not authorized to sign waste manifests, bills-of-lading and wastewater discharge monitoring requirements (DMRs) without approval from Corporate EHS.

Hand & Power Equipment

  • Do any C&W employees use hand or power tools? Guidance: Hand and power tools are a common and present in nearly every industry. However, these tools can be hazardous and have the potential for causing severe injuries when used or maintained improperly. Special attention toward hand and power tool safety is necessary in order to reduce or eliminate these hazards.

  • Has the site adopted the Company Hand & Power Tool (HPT) Program (or one that is equivalent or safer)? Guidance: One or more sections of this Program typically apply to all Company work sites, without exception.

  • Hand Tools - Are all tools and equipment inspected and maintained in accordance with HPT Program requirements?

  • Are appropriate PPE (safety glasses, face shields, etc.) provided and required to be worn while using hand tools or equipment that might produce flying materials or be subject to breakage?

  • Are all cord-connected, electrically-operated tools and equipment inspected periodically to assure they are effectively grounded or of the approved double insulated type? Guidance: It is recommended battery powered tools are utilized as much as possible.

  • Portable Power Tools and Equipment - Are grinders, saws, and similar equipment inspected periodically for appropriate safety guards?

  • Are ground-fault circuit interrupters (GFCIs) provided on all temporary electrical 15 and 20 amp circuits (e.g., used for power tools during periods of construction, repair and/or maintenance)? Guidance: Note- GFCIs are required when using portable power tools including extension cords. It is recommended to use a portable GFCI as breaker GFCIs are not always most reliable.

  • Abrasive Wheel Equipment - Grinders - Are work rest used and kept adjusted to within 1/8 inch of the wheel?

  • Are employees required to wear goggles or face shields when grinding? Guidance: Note- when using face shields, safety glasses or goggles are required to be worn under the face shield.

  • Does each grinder have an individual on/off control switch? Guidance: If grinders are not used answer N/A.

  • Powder-Actuated Tools - Are employees who operate powder-actuated tools trained in their use and in accordance with the HPT Standard, prior to use? Guidance: If powder-actuated tools are not used answer N/A.

  • Are powder-actuated tools left unloaded until they are actually ready to be used? Guidance: If powder-actuated tools are not used answer N/A.

  • Are powder-actuated tools inspected for obstructions or defects each day before use? Guidance: If powder-actuated tools are not used answer N/A.

  • For powder-actuated tools, is use of PPE, such as hard hats, safety goggles, safety shoes and ear protectors, specified and enforced? Guidance: If powder-actuated tools are not used answer N/A.

  • Training - Have employees who use HPT been trained in accordance with the requirements of the HPT program and is the training documented?

Confined Space Entry

  • Do any C&W employees enter spaces that meet the definition of a confined space (see guidance)? Note- in some cases Cooling Towers are classified as confined spaces. Check with EHS with any questions you may have. Guidance: Note, according to OSHA's definition, a confined space is an enclosed area that has the following characteristics: (1) Is large enough for an employee to enter fully and perform assigned work; (2.) Is not designed for continuous occupancy by the employee; and (3.) Has a limited or restricted means of entry or exit. These spaces may include underground vaults, tanks, storage bins, pits and diked areas, vessels, silos and other similar areas.<br><br>Furthermore, by definition, a permit-required confined space has one or more of these characteristics: (a.) Contains or has the potential to contain a hazardous atmosphere; (b.) Contains a material with the potential to engulf someone who enters the space; (c.) Has an internal configuration that might cause an entrant to be trapped or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross section; and/or (d.) Contains any other recognized serious safety or health hazards. <br><br>Confined Space Entry (CSE) work is extremely hazardous and requires significant amounts of training and may require the use of complex (personnel extraction) equipment. C&W employees may only self-perform tasks involving CSE after review and approval of the site-specific program by their EHS. Also, note, C&W does not perform CSE work involving non-C&W personnel, e.g., customer or non-C&W subcontractor personnel.

  • Has the site adopted the Company's Confined Space Entry Program (or one that is equivalent or safer)?

  • Has a facility evaluation been performed to identify and label any confined spaces or permit required confined spaces? (By the customer or our representative) Guidance: Cooling towers, depending on design, are considered confined spaces, and in some cases may be permit required. Sites should also review cooling tower operations as it pertains to periodic maintenance and cleaning activities. Contact EHS with further questions.

  • Has a list of confined spaces been received from the customer, or has the site developed a list of confined spaces? Guidance: If a site specific confined space inventory has not been completed the site should complete a list of permit required confined spaces as required by OSHA and the C&W confined space standard. In some cases the customer may have a confined space inventory to provide us.

  • Are all employees who enter permit-required confined spaces (or confined spaces) trained and informed of the hazards associated with the space?

  • For permit required confined space or non-permit confined spaces that employees enter have rescue procedures been developed, documented, and verified? Guidance: The preferred method for confined space rescue is "non-entry rescue" through the use of a retrieval device (e.g. tri-pod, davit system, etc.). In the event outside rescue services are utilized the site should verify the 3rd party has the training and capabilities to perform confined space entry rescue at the site.

  • Are Attendants, Authorized Entrants, and Entry Supervisory Personnel identified and trained in their responsibilities? Guidance: Employees who are authorized in confined space entry shall complete an approved confined space entry course which includes classroom and hands-on exercise as applicable.

  • If site employees enter confined spaces, does the site have air monitoring equipment, mechanical ventilation, entry/retrieval equipment, and all other required PPE and equipment to perform confined space entry operations safely? Guidance: Confined Space Equipment can include, but not limited to 4 gas air monitoring direct reading instruments and calibration equipment, tri-pod/davit systems, rescue equipment, PPE, etc.

  • If site personnel enter cooling towers for scheduled cleaning maintenance are they required to wear an air-purifying respirator, Tyvek suite, gloves, safety glasses/goggles, and other required PPE? In addition to air monitoring (4 gas personal air monitor)? Guidance: if cooling tower cleaning is self-performed the site is required to implement a safety procedure for the cooling tower cleaning including the outlined PPE in this section. In some instances cooling towers must be entered where this PPE is required. Contact EHS with questions or assistance with further evaluation specific to your site/region.

  • Has an Annual review of this Program been conducted including canceled permits issued within the past year? Note: If no permits were issued within the past year, answered "N/A". Guidance: OSHA and C&W confined space standard requires an annual review/evaluation of the confined space program. Confined space permits (including cancelled permits) shall be retained on file for at least 1 year.

Asbestos Safety (Awareness)

  • Do any C&W employees work in buildings with Asbestos Containing Materials (ACM)? Guidance: The Asbestos Safety Awareness program applies to sites with Asbestos Building Materials (ACM), including floor tile/mastic, pipe insultation, ceiling tile, wall insulation, etc. The program is aimed at "Class IV Workers," which includes janitorial and maintenance workers who do not disturb asbestos. Any work involving disturbance, removal or abatement of asbestos (i.e., Classes II through IV work) must be reviewed by the EHS prior to responding to any such work request from a customer.

  • Has the site adopted the Company Asbestos Safety Program (or one that is equivalent or safer)?

  • Asbestos Survey - Does the site have an up to date asbestos survey/assessment documented? Has the customer provided or are they conducting an asbestos survey to identify locations of ACM?

  • If an asbestos survey has not been completed, are there site specific procedures in place that outline when testing is required to detect ACM or PACM materials? Guidance: Asbestos Containing Material (ACM) is any material containing more than one percent (1%) asbestos. Presumed Asbestos Containing Materials (PACM) - Thermal system insulation and sprayed on and/or troweled or otherwise applied surfacing material in buildings constructed no later than 1980. The material is "presumed" to contain asbestos unless it is demonstrated in accordance with the OSHA Standard that PACM does not contain asbestos.

  • Equipment and Operating Practices (floors) - Are employees who polish and strip finishes on asbestos-containing flooring materials, trained to only use low abrasion pads and machines operating at lower than 300 RPM?

  • Training - Have all affected employees received Asbestos Awareness Training within the last 12 months and are training records completed

  • Have all trained employees signed the "Asbestos Awareness Training Agreement" Attachment A?

  • Have all Company employees who perform Class III or IV work received the required annual training and been provided with the necessary PPE to perform their tasks safely? Guidance: See definition of Class III and IV work in the asbestos awareness program located on the SharePoint site.

Machine Guarding

  • Do any C&W employees perform tasks (e.g., repair and/or maintenance) that require manipulation (opening, removal, repair) of machine guards? Guidance: Maintenance/repair of machines has the potential to cause severe workplace injuries, such as crushed fingers or hands, amputations, burns, or blindness. Safeguards are essential for protecting workers from these preventable injuries. Any machine part, function, or process that may cause injury must be safeguarded. Maintenance/repair following removal of these safeguards, must follow strict safety guidelines.

  • Program – Has the site adopted the Company's Machine Guarding Program (or one that is equivalent or safer)?

  • Training – Have employees who operate or maintain machinery received training on safe methods of machine operation/maintenance and is the training documented? Guidance: Training documentation should be available at the site and provided upon request. Machine guarding training may be included as part of Lockout/Tagout (LOTO) training.

  • Inspections – Does the site conduct and document regular safety inspections of machinery and equipment using the Company Self-Inspection checklist, or equivalent? Guidance: The site may choose to use the provided inspection checklist found on the EHS SharePoint website.

Cranes, Hoists and Slings

  • Do any C&W employees operate or maintain cranes, hoists or slings? Guidance: "Slings" include: alloy steel chain, wire rope, metal mesh, natural fiber rope, synthetic fiber rope, synthetic web, and synthetic round slings. "Hoist" means a mechanical device for lifting and lowering loads by winding a line onto or off a drum. "Hoisting equipment" includes, but is not limited to, cranes, derricks, tower cranes, barge-mounted derricks or cranes, gin poles and gantry hoist systems. A "come-a-long" is a mechanical device, usually consisting of a chain or cable attached at each end, that is used to facilitate movement of materials through leverage and is not considered "hoisting equipment." (126.751)

  • Has the site adopted the Company Crane, Hoist & Sling Program (or one that is equivalent or safer)?

  • Have CHS activities been inspected in accordance with the CHS Self-inspection checklist and have all deviations been corrected? Are cranes inspected for defective components prior to the beginning of any work shift when the CHS is to be used and the inspections documented?

  • Are all employees who perform CHS related tasks trained in accordance with the Company's CHS Safety Program prior to performing such tasks? Guidance: training should be specific to the equipment employees use.

  • Are all CHS inspected and maintained in accordance with the manufacturer's recommendations? Guidance: Ensure documentation of these inspections and maintenance. The site should be able to provide documentation upon request.

  • During projects where cranes are utilized to lift heavy equipment (e.g. HVAC equipment) are lift plans developed and implemented by the sub-contractor and provided to the site manager and project manager?

Flammable & Combustible Liquids

  • Do any C&W employees perform tasks involving the handling or management of flammable or combustible liquids? Guidance: Flammable and combustible liquids are liquids that can burn. The main difference between the two is that flammable liquids can catch fire and burn easily at normal working temperatures, whereas combustible liquids require higher than normal temperatures to ignite. Different Regulatory agencies (OSHA, DOT, NFPA) specify different temperature ranges, and different requirements, for each class. NFPA classification examples include the following, from most flammable to least combustible: <br>- Class IA - Diethyl Ether, Ethylene Oxide, some light crude oils<br>- Class IB ‐ Motor and Aviation Gasolines, Toluene, Lacquers, Lacquer Thinner<br>- Class IC ‐ Xylene, some paints, some solvent‐based cements<br>- Class II ‐ Diesel Fuel, Paint Thinner<br>- Class IIIA ‐ Home Heating Oil<br>- Class IIIB ‐ Cooking Oils, Lubricating Oils, Motor Oil.

  • Has the site adopted the Company's Flammable & Combustible Liquid (FCL)Program (or one that is equivalent or safer)?

  • Has the FCL checklist (available on the SharePoint site under FCL) been completed, including corrective actions? Guidance: Sites may choose to use the inspection checklist, or an equivalent checklist that meets or exceeds the C&W standard.

  • Does the site store gasoline and other flammable or combustible liquid in an approved Fire Rated storage cabinet? Guidance: The amount of flammable liquid storage and location of cabinets are also regulated. 1910.106 (d)(3)(i) states, Not more than 60 gallons of Category 1, 2 or 3 flammable liquids, nor more than 120 gallons of Category 4 flammable liquids may be stored in a storage cabinet.

  • Does the site use "approved containers" to store 5 gallon flammable liquids? Guidance: OSHA defines a safety can as "an approved container, of not more than 5-gallons capacity, having a spring-closing lid and spout cover and so designed that it will safely relieve internal pressure when subjected to fire exposure" (1910.106(a)(29)).

Powered Industrial Trucks (PIT)

  • Do any C&W employees operate Powered Industrial Trucks (PIT), including forklifts, powered hand-jacks, as well as golf carts and gators used/designed for materials movement). Guidance: Regarding use of golf carts, gators, and other similar "recreational vehicles" Golf carts and gators are typically, by design, considered to be recreational vehicles and are, therefore, traditionally held to be exempt from the PIT regs (29 CFR 1910.178). However, it is the design of the vehicle that is the determining factor of whether or not it is considered a powered industrial truck, rather than the manner in which it is utilized. For this reason, C&W requires use of such vehicles for materials handling to follow PIT requirements.

  • Has the site adopted the Company's Powered Industrial Truck (PIT) Program (or one that is equivalent or safer)? Guidance: If another program has been adopted the site must be able to produce a copy upon request.

  • Are employees trained, certified and authorized to operate each specific type of PIT they use? Training must be provided at a minimum of every three years, and includes classroom training and documentation of equipment observation/competency training. Guidance: A list of authorized employees must be available, and training documentation available upon request.

  • Do employees perform and document pre-shift inspections of PIT? Guidance: Inspections shall be documented prior to use of PIT equipment. Inspections are required to be completed at the beginning of each shift if the equipment is used.

  • Are the forklifts in your facility correctly designated for your type of operation (based on atmosphere, hazards of materials handled (exhaust - floor weight load, etc.))?

  • Are clearance signs warning of clearance limits provided? Guidance: In areas where clearance is a potential risk/hazard for PIT operations, clearance and warning signs shall be posted.

  • Are only trained personnel allowed to operate PIT?

  • Have you documented what methods you use to train forklift operators? Guidance: C&W's PIT program outlines our training requirements. It is important to ensure that all authorized operators have been trained and have demonstrated competency in operating all PIT classified equipment at your site(s). All training and demonstrations need to be documented and provided upon request.

  • Is refresher training conducted at least every 3 years or whenever a "change in condition" requires it? Guidance: Change in Condition for PIT refresher training equals any of the following:<br>1) The operator has been observed to operate the vehicle in an unsafe manner<br>2) The operator has been involved in an accident or near-miss accident<br>3) The operator has received an evaluation that reveals that the operator is not operating the truck safety<br>4) The operator is assigned to drive a different type of truck<br>5) A condition in the workplace changes in a manner that could affect safe operation of the truck

Welding Cutting Brazing

  • Do any C&W employees perform tasks involving welding, cutting, or brazing? Guidance: Health hazards from welding, cutting, and brazing operations include exposures to metal fumes and to ultraviolet (UV) radiation. Safety hazards from these operations include burns, eye damage, electrical shock, cuts, and crushed toes and fingers. Many of these can be controlled with proper work practices and personal protective equipment (PPE).

  • Has the site adopted the Company's Welding, Cutting & Brazing Program (or one that is equivalent or safer)? Guidance: If another program has been adopted the site must be able to produce a copy upon request.

  • Have designated areas been established for welding, cutting, and brazing at the facility?

  • Is suitable fire extinguishing equipment maintained for use whenever hot work is being performed?

  • Is a hot work permit issued anytime welding, cutting and brazing is being performed? Guidance: Hot work permits are required per the C&W Welding, Cutting, Brazing standard as well as OSHA regulatory requirements when work involves welding, cutting, brazing, soldering, burning, and grinding. Other operations where sparks or open flames are produced can also be considered hot work and should be evaluated prior to work taking place.

  • Is welding, cutting and brazing equipment inspected prior to each use? Guidance: Equipment should be properly inspected prior to use. Are employees trained and properly performing equipment inspections prior to performing hot work activities? <br>

  • Is a fire watch maintained during hot work activities and for 30 minutes after the welding, cutting and brazing is completed?

  • PPE: Is proper PPE provided to employees performing hot work? Are employees trained in the requirements of performing hot work at the facility?

  • Training: Is the fire watch trained in fire extinguisher use? Guidance: Employees who perform fire watch must be trained the use of fire extinguishers.

  • Will employees perform welding, cutting or grinding of stainless steel? If so, this work may trigger requirements of the OSHA Hexavalent Chromium Standard. Guidance: Contact EHS is you answer Yes to this question.

  • Does the site provide and maintain first aid supplies? Guidance: OSHA requires that employers provide first aid supplies when employees perform Hot work related tasks.

Compressed & Liquified Gases

  • Do any C&W employees perform tasks involving the use, handling, or storage of compressed or liquefied gases? Guidance: Employers are responsible for safe use of compressed gas cylinders and liquid containers and their contents. Compressed-gas hazards include oxygen displacement, explosion, and toxic effects as well as the physical hazards of a ruptured cylinder. Employers must evaluate compressed-gas hazards and have an emergency-response plan that defines procedures and responsibilities to address emergencies.

  • Has the site adopted the Company's Compressed & Liquefied Gas (CLG) Program (or one that is equivalent or safer)? Guidance: If another program has been adopted the site must be able to produce a copy upon request.

  • Are cylinder storage areas designated and properly labeled? Guidance: Cylinder storage areas should be labeled for the contents stored (e.g. oxygen, chlorine, etc.)

  • Have employees delivering, storing, handling and using compressed gases received training? Guidance: Training should be documented for each authorized employee and provided upon request.

  • Are all gas cylinders properly restrained and stored? Guidance: Cylinders should be stored in a rack and/or secured with straps.

  • Are empty or full cylinders properly marked as such? Guidance: It is recommended that empty cylinders are stored together and labeled.

  • Special (high hazard) gases - Is C&W responsible for maintaining cylinders/systems involving Oxygen and/or other high hazard gases? Guidance: If so, contact EHS to review the associated personnel training and maintenance procedures.

Laboratory Safety

  • Do any C&W employees perform tasks in a laboratory where chemical, radiologic, laser, and/or biologic hazards exist?<br>If Company employees do not perform job tasks (e.g., cleaning or maintenance) in a laboratory, then select N/A for the questions in this section. Guidance: Laboratory workers are exposed to numerous potential hazards including chemical, biological, physical and radioactive hazards, as well as musculoskeletal stresses. Laboratory safety is governed by numerous local, state and federal regulations. There are several primary OSHA standards that apply to laboratories as well as other OSHA standards that apply to various aspects of laboratory activities. The Occupational Exposure to Hazardous Chemicals in Laboratories standard (29 CFR 1910.1450) was created specifically for non-production laboratories.

  • Has the Company obtained a copy of the customer's Chemical Hygiene Plan (CHP)? (Per 29 CFR 1910.1450)

  • Do all C&W employees conduct an evaluation of the lab before work is performed in the lab?

  • Has an exposure assessment been conducted to determine possible Company employee exposures?

  • Has the Site Management reviewed the elements of our customer's CHP and implemented the applicable requirements?

  • Does the site Hazard Communication training include lab chemical safety? Are the chemicals included in the site's chemical inventory and SDS's made available in KHA Online SDS system?

  • Have C&W employees been made aware of physical hazards in the lab(s)?

  • Have C&W employees been made aware of biological/chemical hazards in the lab(s)?

  • Have our employees been made aware of routine hazards encountered in labs?

  • Have our employees been issued the appropriate PPE for working in the labs?

  • Have our employees been trained to meet the requirements of the "Laboratory Safety Program" and is the training documented? ( Per customer's Lab Safety Program)

Manual Material Handling

  • Do any C&W employees operate manual material handling devices to move objects/equipment (e.g., furniture, pumps, pallets, shipments) over 50 lbs.? Guidance: Manual material handling devices include, but not limited to, manual pallet jacks, dollies, carts, wooden frame caster, winches, and snow blowers.

  • Are manual material handling devices (e.g., manual pallet jacks, dollies, carts, wooden frame caster, winches, hoist) kept in good working order?

  • Are employees properly training on the operations of manual material handling devices? Guidance: All training should be documented for authorized employees who use manual material handling equipment. Documentation should be made available upon request.

  • If employees use snow blowers and other similar outdoor power equipment have they been provided with proper training? Guidance: All training should be documented for authorized employees who use snow blowers and other similar outdoor power equipment at the site. Documentation should be made available upon request.

  • If employees use snow blowers, are they trained on how to properly use the equipment they perform work with? Guidance: training on snow blowers should include safe operations, maintenance, and instructions on how to use the equipment each employee operates.

Aerial Lifts

  • Do any C&W employees operate an aerial lifts as part of their job duties? Guidance: An aerial lift is any vehicle-mounted device used to elevate personnel, including: extendable boom platforms, aerial ladders, scissor lifts, articulating (jointed) boom platforms, vertical towers, and any combination of the above

  • Has the site adopted the Aerial Lifts Program (or one that is equivalent or safer)?

  • If modifications have been or are made to aerial lifts are they approved by the manufacturer prior to being made?

  • Have employee authorized in the use of aerial lifts trained and upon initial assignment and at least every three years following? Guidance: All training shall be documented and made available upon request. Training for aerial lifts includes classroom instruction and the operator must demonstrate competency in safe operation for each type of equipment they are authorized to operate.

  • Are pre-operational inspections performed prior to each shift that the equipment is used? Guidance: All equipment inspections shall be document, filed and provided upon request.

  • Are aerial lifts inspected and serviced (maintained) in accordance with the manufacturer's recommendations by a third party service provider at least annually?

  • Are authorized operators trained and provided with fall protection while using/operating aerial lifts? Guidance: Authorized users should be provided with a full body harness, Self-Retracting Lifeline, and a restraining lanyard. The self-retracting lifeline should be used on boom and scissor lifts, while the restraining lanyard provided for use while the boom lift is in transport. Contact EHS with any questions regarding fall protection requirements.

  • If applicable, are employees trained in handling battery's and the use of charging stations? Is appropriate PPE provided for battery filling operations?

  • Are the correct types of lifts provided for the environments they are used (e.g. in-doors, terrain, etc.)?

  • Is a work area inspection completed prior to operating an aerial lift using Attachment F or equivalent documented inspection? Guidance: Prior to operating an aerial lift, the work area shall be inspected to ensure that conditions are safe to operate the aerial lift. Operators must ensure that pedestrian traffic can be diverted accordingly. Operators must observe any additional hazards such as power lines, cranes, structures, driving surfaces (including uneven surfaces) and other aerial lifts being used in the area before operating the aerial lift.

  • Are hard hats required when using aerial lifts? Guidance: It is recommended to provide hard hats with a chin strap to prevent the hard hat from potentially falling off while working overhead.

  • Do employees deploy caution tape, safety cones, or other protection barriers while using aerial lifts in the area they are working and operating the equipment?

Hearing Conservation

  • Do any C&W employees work in "high noise areas" ? Guidance: The ARR requirements of this Program area must be reviewed if C&W employees work in any of the following types of "high noise areas": (1.) Areas where C&W employees are exposed to an 8 hour TWA sound level of 85dB or higher; (2.) Areas where C&W employees are exposed to intermittent and impulsive sound levels from 80dB to 130dB and/or; (3.) Areas where it is necessary to raise one's voice to communicate with someone standing at a normal conversation distance in any work area.

  • Has the site adopted the Company Hearing Conservation Program (or one that is equivalent or safer)?

  • Is suitable hearing protection provided to all employees who work or enter work areas designated as "Hearing Protection Required" areas?

  • Is the use of hearing protection mandated and enforced in the affected areas of the facility? Guidance: If you have areas in your facility that present noise hazards a noise survey may need to be completed to determine if the TWA meets or exceeds 85 dB, if you have not already completed one. In some cases adding new equipment that may present noise hazards (e.g. generators) may necessitate the need for a noise evaluation.

  • Has a baseline audiogram been conducted for all employees working in an area with noise above 85 decibels TWA, with follow-up audiograms repeated annually? Guidance: If you have areas in your facility that present noise hazards a noise survey may need to be completed to determine if the TWA meets or exceeds 85 dB, if you have not already completed one. In some cases adding new equipment that may present noise hazards (e.g. generators) may necessitate the need for a noise evaluation.

  • Are employee training and audiometric testing properly documented and are the resultant (private) medical records properly maintained? (Audiometric test results should be kept in each employees' confidential medical file)

  • Have all affected employees received training within the last 12 months on the effects of noise on hearing, and how to select and use proper hearing protection?

Respiratory Protection

  • Does the site provide information to employees who elect to wear respirators when they are not required? (Attachment M) Guidance: In some cases respirators, including N-95 masks are provided on a voluntary basis. Does the site comply with the C&W respirator-voluntary use policy? Voluntary use of N-95 masks or other NIOSH approved respirators requires compliance with C&W respirator voluntary use policy which includes documentation of the OSHA appendix D.

  • Do any C&W employees perform tasks with potential respiratory hazards requiring use of a respirator? Guidance: This program does not apply to employees using single-strap filtering facepieces (dust mask) on a voluntary basis.

  • Has the site adopted the Company Respiratory Protection Program (or one that is equivalent or safer)?

  • Has air monitoring been performed for proper respiratory protection selection? Does the site conduct air monitoring in areas where it is anticipated that employees will be exposed to contaminants in excess of the Permissible Exposure Limit (PEL)?

  • Does the site communicate results of air monitoring to affected employees?

  • Does the site list all areas or tasks that require use of a respirator using Attachment A, or equivalent documentation? Guidance: All tasks should include the required respiratory protection to be used.

  • Have all authorized users been medically evaluated/qualified and fit tested (Qualitative) for respirator use upon initial assignment and annually thereafter? Guidance: All medical evaluations and fit testing documentation should be filed in the employees personal medical file in a secure location. (3 year documentation retention) Guidance: All medical evaluations and fit testing documentation should be filed in the employees personal medical file in a secure location. (3 year documentation retention)

  • Have all authorized employees who use respiratory protection received training and has the training been provided within one year? Guidance: All training must be documented and made available upon request.

  • Are all authorized employees who use respiratory protection clean shaved and have no other conditions that may interfere with respirator fit?

  • Do the employees at the site inspect respirators before and after each use and during cleaning?

  • Do employees at the site change chemical cartridges in accordance with either the End of Service Life Indicator (ESLI) or the established schedule? Guidance: when respirator cartridges are used, the site shall have a policy established that outlines when cartridges should be changed out with new ones.

Air Emission Management

  • Does C&W have any responsibility for maintaining, operating or reporting on regulated sources of air emissions, such as boilers, cooling towers, emergency generators, or use of solvents?

  • If the Company has any responsibility for air emissions permits, has the site/account management obtained copies of the permits?

  • Does the Company have any responsibility for reporting on equipment air emissions, such as completion of logs, on a routine or non-routine basis, e.g., run logs for generators, boiler natural gas consumption, solvent usage, etc.? If the company has no responsibility for such reporting, answer N/A to this question and move to the next question.

  • Are the reporting requirements clearly defined in the work instruction, work order or on the equipment? Guidance: All permitting conditions should be documented and tracked for recordkeeping purposes.

  • Have all personnel, including vendors, been properly trained in the requirements for operating and maintaining the equipment?

Wastewater & Storm water Management

  • Does C&W have any responsibility for maintaining, operating or reporting on regulated sources of wastewater or stormwater discharge? Guidance: C&W may be subject to various Plans, including Spill Prevention, Control, and Countermeasure, SPCC, Plans (required for storage/use of specified quantities of petroleum/oil) and Federal NPDES Program requirements, such as a Storm Water Pollution Prevention Plan, SWPPP (required for storage of certain equipment and materials outdoors). Note, sites are not authorized to develop such plans for customers w/o review and approval by EHS.

  • Is the Company exposed to risk of Storm Water Pollution events based on either of the following:<br>(1.) Risk of storm water pollution from Company operations/maintenance activities (see Guideline Text for explanation)? or<br>(2.) Client BMPs [Best Management Practices from NPDES Storm Water Permit (Storm Water Pollution Prevention Plans* )] that apply to Company operations? Guidance: Note, storm water pollution risks include activities conducted outdoors, such as cleaning surfaces and/or equipment, and/or storage of chemicals, materials, and/or equipment, including landscaping equipment, in an outdoor setting that is not enclosed and managed to prevent stormwater runoff. See the Guideline Text or contact EHS if you have questions regarding applicability of this program.<br>Stormwater runoff is generated from rain and snowmelt events that flow over land or impervious surfaces, such as paved streets, parking lots, and building rooftops, and does not soak into the ground. The runoff picks up pollutants like trash, chemicals, oils, and dirt/sediment that can harm our rivers, streams, lakes, and coastal waters. To protect these resources, communities, construction companies, industries, and others, use stormwater controls, known as best management practices (BMPs). These BMPs filter out pollutants and/or prevent pollution by controlling it at its source.<br>Verification :<br> * The NPDES stormwater program regulates some stormwater discharges from three potential sources: municipal separate storm sewer systems (MS4s), construction activities, and industrial activities. Operators of these sources might be required to obtain an NPDES permit before they can discharge stormwater. This permitting mechanism is designed to prevent stormwater runoff from washing harmful pollutants into local surface waters. Company services might be subject to these permitting requirements if (1.) the client has a NPDES permit for storm water, which typically includes a Storm Water Pollution Prevention Plan (SWPPP) and (2.) the Company is performing activities that are regulated by the permit/SWPPP.

  • Potential Risks/BMPs: Does the site conduct outdoor cleaning activities (e.g., clean sidewalks, loading docks, HVAC equipment, trash areas, vehicles, compactors) that have the potential to pollute storm water, e.g., discharge of cleaning<br>solution offsite via release to creeks, rivers, or storm water drains?<br>If yes, has the company evaluated and established BMPs (Best Management Practices) to prevent a release? See the guidance and/or contact EHS if you have questions regarding BMPs. Guidance: Best Management Practices (BMPs) are required when there is a risk for stormwater discharge from work procedures/processes. BMPs are intended to manage stormwater discharge to comply with Federal, State, and local regulations. In some cases a permit may even be required.

  • Potential Risks/BMPs: Does the company store hazardous chemicals/materials (e.g., cleaning/maintenance products, detergent, paint, oil) in an outdoor setting that could impact storm water via a release to creeks, rivers or storm drains?<br>If yes, has the company evaluated and established BMPs (Best Management Practices) to prevent a release? Guidance: Contact EHS if you have questions regarding BMPs.

  • Potential Risks/BMPs: Does the site operate lift stations, oil/grease interceptors, or other devices that could overflow or cause storm water releases, e.g., to storm drains, during a malfunction? If yes, has the company evaluated and established BMPs (Best Management Practices) to prevent a release? Guidance: Contact EHS if you have questions regarding BMPs.

  • Potential Risks/BMPs: Does the site have a procedure and train/instruct employees on proper disposal of wastewater [from washing activities such as floor mopping and washing outdoor equipment (HVAC coils)] and does the procedure include the following requirements?:<br>1. Disposal of wastewater via toilet and/or slop sink, which discharges to on-site or off-site waste water treatment plant and<br>2. Prohibition on the disposal of wastewater via storm sewers. Guidance: If the site does not have a procedure that meets the stated requirements, contact EHS.

  • Have work orders or other practices been created/modified to ensure best management practices are correctly followed when activities are performed that require BMPs.

  • Are all storm drains properly labeled and are employees working in the areas of these drains informed of their locations and the need to prevent discharge of pollutants to storm drains?

  • If landscaping services are provided onsite, are O&M procedures in place to prevent releases to storm water, e.g., all landscaping equipment is maintained/stored in a manner to prevent a release and landscape debris is properly disposed of or mulched and not stockpiled in water drainage areas?

  • Does the scope of work include the operation and maintenance of any equipment containing petroleum products (e.g., fuel for emergency generators)? If so, are there control measures in place to prevent stormwater runoff or unauthorized discharge of stormwater?

  • Client Storm Water Permit Requirements: Have all Best Management Practices (BMPs) from client NPDES Stormwater Permit (SWPPP) that apply to Company activities been identified and implemented (e.g., use of water and solid collection devices for outside washing; screening of run off; paint chip collecting; valve shut off during fueling)?

  • Client SPCC Planning requirements: Is the client responsible for having an SPCC Plan and is the Company responsible for operation or maintenance of any equipment (or oil storage area) that triggered the Client's SPPC Plan? If yes, has the site done the following:<br>1. Asked the Client if they meet the requirements for an Spill Prevention Counter Measure and Control (SPCC) Plan?<br>2. Obtained a copy of the Client's SPCC plan and reviewed it to identify and implement controls applicability to the Company scope of work?<br>3. Ensured periodic inspections of oil/petroleum containing equipment for which the company is responsible? Guidance: Note, Federal Spill Prevention Counter Measure and Control (SPCC) Planning requirements are triggered for sites containing oil/petroleum products above certain thresholds: 660 gallons in any single tank or a total storage capacity of greater than 1,320 gallons?

  • Is C&W responsible for maintaining and/or updating the clients SPCC plan as part of our SOW? Guidance: SPCC plans should be updated when facility equipment or layout changes occur, or at a minimum of every 5 years. PE stamps and approvals must be updated every 5 years or when changes to the facility/site occur.

Refrigerant Management

  • Do any C&W employees or contractors perform Refrigerant Management Services? Guidance: Refrigerant Management Services include, but are not limited to, those working with refrigerants (e.g., remove, recycle) or those overseeing vendors conducting these activities.

  • Has the site adopted the Company Refrigerant Management Program (or one that is equivalent or safer)? Guidance: If another program has been adopted the site must be able to produce the program upon request.

  • Has the site implemented the Trakref system? Guidance: C&W @ Citi Bank uses Trakref to track refrigerant assets and compliance information. At a minimum all assets containing 25 pounds of refrigerant or greater must be tracked in the Trakref system.

  • Have all personnel whose duties include installation, maintenance or repair of equipment that has the potential to release CFCs or HCFCs received USEPA approved technician training? (See attachment D). Guidance: See attachment D of the C&W Refrigerant Management Program found on the SharePoint website.

  • Has the Certification Posting been posted? (See Attachment E) It is recommended to also post copies of technician certifications.

  • Are refrigerants maintained (which includes substances in stock and/or equipment, recycling, recovery, loss by release, normal equipment operation and waste disposal) and tracked all sources of Class I and Class II refrigerants on the site using the Standard.

  • Has the site established record-keeping requirements for owners and operators of air-conditioning and refrigeration equipment containing CFC and HCFC refrigerants? ( See Attachment G of the program). Sites may choose to use an alternate tracking/record-keeping method (e.g. online record-keeping system) that meets or exceeds the C&W Refrigerant Management Standard.

  • Does the site(s) maintain an inventory of appliances?

  • Is leak detection performed routinely according to the policy of Company Service Contractor?

  • Do records indicating which technicians are assigned the responsibility to respond to releases or potential releases for the purpose of stopping the release have received training and have competency in the areas of training specified? (See Attachment H)

  • Has a 608 recycling certification form been submitted to the USEPA?

  • Do all recovery units purchased before 11/15/93 meet required USEPA evacuation levels?

  • Is all recovery equipment purchased after 11/05/93 ARI or UL certified?

Process Safety Management

  • Do C&W employees perform work "on or near" a PSM covered process? Guidance: PSM covered processes are governed by an OSHA Standard (29 CFR1910.119), which specifies requirements for contractors who perform work “on or near” PSM covered processes. The Standard identifies PSM covered chemicals/quantities, e.g., anhydrous Ammonia storage over 10,000 pounds. Contact EHS if you have questions as to whether any C&W site activities are subject to the PSM Standard. The PSM contractor requirements would apply to C&W if we perform maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to a PSM covered process. Note, however, the Standard does not apply to contractors who provide only incidental services that do not influence process safety, such as janitorial work, food and drink services, laundry, delivery or other supply services.

  • Are all C&W employees who perform work "on or adjacent to" a PSM covered process aware of and trained on the host-facility's emergency action (evacuation) plan and procedures?

  • Does site management assure compliance with the contractor provisions of the OSHA PSM Program? Guidance; For any PSM covered facilities the host-employer should provide the sites PSM covered processes and safe work practices to C&W management.

  • Has C&W EHS reviewed your site PSM process, if applicable? Guidance: If your site has operations covered under PSM, contact your EHS manager.

Spill Response (HazWoper)

  • Do C&W employees participate in Spill Response and/or Emergency Response Plans? Guidance: Contact your EHS Manager or corporate EHS if the scope of work requires C&W to develop or participate in site Emergency Response Plans, e.g., spill response involving hazardous substances, per the OSHA HazWoper Standard [29 CFR 1910.120(q). C&W may, under certain circumstances, support the customer’s response plan. Duties and training requirements depend on "responder level." C&W employee involvement is typically limited to the First-Responder, Awareness level. Any scope-of-service that involves C&W employees in Emergency/Spill Response services, including on-site Emergency Response Teams, must be reviewed and approved by EHS.

  • Are C&W employees limited to awareness level responders? Guidance: If C&W employees are involved in spill response of hazardous waste and/or hazardous substances contact EHS to review further.

  • Is HazWoper training provided to C&W employees who are involved in spill response at the awareness level? Guidance: if C&W employees are authorized to only observe hazardous waste and/or hazardous substance spills and initiate emergency response procedures awareness level is required. If C&W employees are authorized to respond and initially contain the spill, at a minimum 8 Hour HazWoper training is required.

  • Are C&W employees provided with appropriate PPE, spill containment, and other equipment to safely evaluate a spill? Guidance: C&W employees should be limited to awareness level response only. First responders at the awareness level are individuals who are likely to witness or discover a hazardous substance release and who have been trained to initiate an emergency response sequence by notifying the proper authorities of the release. They would take no further action beyond notifying the authorities of the release.

  • Does the site have a 3rd party spill response team contracted to respond to a Hazardous Waste/Substance spill incident? Guidance: Sites who participate in spill response and/or emergency response plans involving Hazardous Substances or waste should identify a 3rd party spill response provider and set up an MSA.

HazMat Shipping and Receiving (DOT)

  • Do any C&W employees serve as DOT "HazMat Employees" Guidance: The Department of Transportation (DOT) defines a Hazmat employee as any individual, employed on a full time, part time, or temporary basis, who during the course of employment: (i.) Loads, unloads, or handles hazardous materials; (ii.) Designs, manufactures, fabricates, inspects, marks, maintains, reconditions, repairs, or tests a package, container or packaging component that is represented, marked, certified, or sold as qualified for use in transporting hazardous material in commerce; (iii.) Prepares hazardous materials for transportation; (iv.) Is responsible for safety of transporting hazardous materials, e.g., a supervisor; (v.) Operates a vehicle used to transport hazardous materials on US roads.

  • Contact EHS if C&W employees serve as DOT "HazMat Employees". Guidance: Corporate EHS will need to evaluate and approve the services provided.

Water Damage & Fungi Mold

  • Do any C&W employees respond to water damage requests or perform other work activities that might require clean-up of fungi/mold (or work on building structures with EIFS cladding)? Guidance: While response to water-damage from floods/rains is a common service provided by C&W, fungi/mold remediation is not. Fungi are particularly problematic in wet, warm region, such as the southern US and fungi/mold exposure can be a significant health hazard. For this reason, C&W sites are required to follow the C&W Standard when responding to water damage service requests where cleanup of fungi/mold is encountered. Sites are prohibited from self-performing mold "remediation" or "abatement" activities. Such mold remediation/abatement activity is defined as clean-up of mold with a surface area > 10 sq. ft. Contact EHS with any questions. <br><br>In addition, Exterior Insulation and Finish System (EIFS), sometimes called "synthetic stucco", is a multi-layered exterior barrier type system designed to prevent moisture intrusion into exterior walls. Class action law suits involving improper installation and/or maintenance of EIFS are common. Any proposed work on EIFS, therefore, must be reviewed/approved by EHS, with a preference for use of an experienced EIFS subcontractor who has the necessary insurance coverages.

  • Has the site adopted the Company's Water Damage and Fungi Program (or one that is equivalent or safer)?

  • Has the "Mold Policy" been signed and posted and have all employees responsible for performing Water Damage repairs signed the "Mold Awareness Agreement"?

  • Have all employees responsible for mold water damage reviewed the Company's program/procedure for Water Damage 004 Clean-up within the last 12 months?

  • Have all buildings with EIFS been identified and have employees been informed of the requirements to avoid improper construction, renovation, or repair of this type of external building surface material?

Fire Protection (Life Safety)

  • Is the company responsible for inspecting, testing and maintaining Life Safety Systems (e.g., Portable Fire Extinguisher, Fire Detection, Alarm and Communication Systems, Emergency Lighting Systems, and Sprinkler systems. Guidance: This Program applies to all corporate accounts/worksites and is limited to the inspection, testing and maintenance (ITM) of existing Life Safety Systems. The design, construction, installation, and/or modification of Life Safety Systems are beyond the scope of this Program and, in general, beyond the scope of the company. Prior to pursuing any customer requests for design, construction, installation, and/or modification of Life Safety Systems, approval must be obtained from EHS and Risk Management.

  • Has the site adopted the C&W Life Safety (Fire Protection) Systems Program (or one that is equivalent or safer)?

  • Does the site use qualified contactors to perform annual ITM of existing Life Safety Systems? Guidance: Annual ITM includes but not limited to fire extinguishers, alarm systems, and sprinkler systems. In some cases local codes and laws provide additional testing and inspection requirements.

  • Does the site perform documented monthly inspections of Portable Fire Extinguishers?

  • Does the site perform documented monthly inspection of all emergency lights?

  • Has the customer provided a list of locations for all portable fire extinguishers and emergency lights throughout the facility? Guidance; The customer should provide the company with a map/inventory of the locations and types of extinguishers and emergency lighting. If not, the site should develop this list.

Golf Cart and Utility Vehicles

  • Does the site have or use golf carts or utility vehicles that C&W employees operate? The Golf Cart/Utility Vehicle Program was developed to ensure that safe practices are followed where employees are operating golf carts/utility vehicles and to ensure employee, customer and visitor safety. Guidance: The Golf Cart/Utility Vehicle Safety Program provides a company-wide tool to ensure the safety of all persons operating electric or gas-powered carts, golf carts, utility carts, low-speed vehicles and/or similar type vehicles (hereafter collectively referred to as “Carts”)

  • Has the site adopted the C&W Golf Cart Utility Vehicle Program (or one that is equivalent or safer)?

  • Have authorized C&W employees who operate golf carts and/or utility vehicles received safety training on the equipment and signed Attachment A (Golf Card/Utility Vehicle Training Verification) Form? Guidance: All authorized employees are required to review the C&W Golf Cart/Utility Vehicle Program.

  • Are all golf carts and/or utility vehicles inspected each day prior to use use Attachment B? Guidance: All golf carts and/or utility vehicles shall be inspected prior to use. Inspections shall be documented and made available upon request.

  • Are golf carts and/or utility vehicles stored in a secure location to prevent unauthorized persons from using the equipment?

  • Are carts used between dusk and dawn equipped and operated with working headlights, turn signals, and taillights.

  • Are golf carts and/or utility vehicles used on pubic roads or streets, and if so has the site verified this is permitted by state/local ordinances? Guidance: State law prohibits operation of golf carts on public roads or streets unless that use is allowed and the roadway has been so designated by the appropriate local authority (county or municipality). State law also requires golf carts to be equipped with efficient brakes, reliable steering apparatus, safe tires, a rearview mirror and red reflectorized warning devices in both the front and rear. If operated during the hours of darkness between sunset and sunrise, the cart must be equipped with headlights, brake lights, turn signals and a windshield.

The templates available in our Public Library have been created by our customers and employees to help get you started using SafetyCulture's solutions. The templates are intended to be used as hypothetical examples only and should not be used as a substitute for professional advice. You should seek your own professional advice to determine if the use of a template is permissible in your workplace or jurisdiction. You should independently determine whether the template is suitable for your circumstances.