Parmalat Canada OHS requirements 2016

• Parmalat OHS Corporate requirements 2016

MANAGEMENT COMMITMENT

• When supervisory staff is not available : system is in place to ensure a competent person has
  been assigned as a direct contact.
   Safety is always on the agenda at meetings.
   Site involves employees to address specific safety issues affecting them.
   Policy is signed by local senior site manager.
   Policy is accessible, visible and understood by the employees.
   Available safety action plan :
  o goals / objectives
  o objectives based on identified hazards, requirements
  o communicated to employees
   Follow up status of corporate safety audits, monthly safety audits, safety issues / problems
  posted at a visible location to the employees.
   Safety meetings are documented.
   All supervisors received location specific safety competency training, completed within two (2)
  weeks of starting.
   Process in place (e.g. checklist) to promote shared responsibility among employees for
  housekeeping in their area.
   The location has conducted a violence assessment.
   A project safety review (PSR) is completed when required (use Ontario requirements for all
  provinces).
   Recognitions Program is implemented for safety results or individual contributions to site
  safety program.

HAZARD IDENTIFICATION AND RISK ASSESSMENT

• Hazards inventory : must be completed after the JSA is conducted; based on this inventory
  (a qualitative identification of hazards), a workplace safety card (containing the recommended
  information about hazards identified and recommended control measures) must be posted to
  inform the employees about their hazard exposure and control measures.
   Engineering checklist, H&S review is mandatory for all new projects / new equipment and /or
  modifications at the following stages : Pre-project (Planning), Project execution (Mid
  Assessment) and Upon Completion.
   Monthly inspections or audits are conducted by the Sites employees to proactively identify
  safety hazards.
   Sufficient industrial hygiene monitoring must be conducted to assess and document employee
  exposures to hazardous substances and agents, including :
  o indoor combustion gases
  o noise and vibration
  o illumination
  o VOC (solvents)
   Frequencies are established according to the Corporate IH Guidelines.
   Employees are informed of the results of industrial hygiene monitoring.
   Monthly JHSC inspections are documented.
   Daily / work shift pre-operational inspections of workplace equipment’s.
   Up to date job safety analysis (JSA) are conducted and this information included in SOPs or
  some other format which clearly identify the hazards and precautions required for the job.
   JSA are reviewed every three (3) years or before, if there is any major upgrade of the job.
   The participation of employees (JHSC, works that conduct the task, supervisors) is necessary
  for a successful assessment.
   Recommended steps for the completion of the JSA :
  o STEP 1 : after a clear understandings of the sub-tasks by the assessment team, a
  qualitative assessment of the potential hazards will be completed
  o STEP 2 : risk assessment
  o STEP 3 : implementation and follow up of recommended control measures
  o STEP 4 : re-evaluation of risk
   Risk assessment and action plans for JSA :
  Risk calculation : High and Medium risk will trigger the evaluation and implementation
  of control measures - Only Low and Very Low assessed risks will be considered as
  acceptable for no corrective action proposal
  
  Medium risk : Job hazards have to be controlled by engineering, ppes and
  administrative controls as soon as possible
  
  High Risk : Work activities must be suspended immediately until hazard is
  controlled or reduced or eliminate
   Personal protective equipment assessments documented, reviewed every two (2) years.
   Fall protection assessments are documented.
   Ergonomic assessment is documented

CARDINAL RULES

• Communication to employees.
   Applicable to employees and contractors.
   Cardinal rules violation are :
  o employee loading trailer with mechanical operating device without locking the trailer to
  the dock and / or not following other procedures to prevent the trailer from moving
  while loading it
  o employee not wearing fall arrest protection
  o employee working in a confined space situation without the proper safety protection
  o employee doing welding and / or cutting without a work permit
  o tampering with disengaging or removing a safety device (including but not limited to
  safety guards, interlocking devices, and safety placards...)
  o operating a company owned, leased or rented forklift and / or any mechanical lifting
  devices in a critical defective condition
  o employee not protected while performing work which requires lockout and tag out
  o employee not protected while performing work that requires them to use personal
  protective equipment, the lack of which may result in serious injury or worse to the
  employee
  o employee not following the site pedestrian safety rules, which may result in serious
  injury or worse to the employee

INCIDENT REPORTING AND INVESTIGATION

• The following incidents reportable by a narrative report within Parmalat Canada to Functional
  VP, Human Resources VP, Health & Safety Manager and Human Resource Manager are the
  following:
  a) All recordable incidents (lost time, medical aid injuries and illnesses and modified work )
  b) Major property damage cases;
  c) near misses of experience value (An event where, if circumstances had been slightly
  different, a major injury or illness, property damage or environmental incident could have
  occurred. ) Any incident that could potentially result in an adverse citizen action or media
  coverage.
  The narrative report will be written and distributed within 24 hours of the event unless the
  injury is a critical injury then the details available must be reported immediately??.
  The narrative report will include 1) Plant or other location 2) Date and time of injury/incident 3)
  Brief description of the injury/incident and severity and 4) Status of investigation and response
  activities
  It will be the responsibility of the appropriate function Vice President and/or the head of
  Corporate Human Resources to report the circumstances of the accident/incident to the CEO.
   Incidents reports shall be :
  o completed within two (2) days
  o witnesses
  o site investigation
  o root cause(s) identified
  
  Corporate recommendation : the use of the 5 Why tool is strongly
  recommended
  o corrective actions and behavioural change identified
  o changes implemented
  o employees informed of corrective action
   Counseling takes place upon injured employees return to work.
   Return to work tracking form is used for all modified duties including work hardening.
   Location reports any injury beyond first aid immediately to the appropriate person and
  complies with reporting regulations to WSIB, CSST, WCB and MOL.
   Location reports any injury beyond first aid immediately to the appropriate person and
  complies with reporting regulations to WSIB, CSST, WCB and MOL.
  Annual trend analyses of injuries and illnesses are conducted in an effort to direct the safety
  and accident prevention efforts in a preventive direction.
   Leadership reviews all reports to ensure actions implemented.
   First aid incidents must be recorded in a site log-book.
   Injured employees : it is strongly recommended , injured employees to be escorted to the
  hospital / clinic by a certified first aid certified employee
   The transportation will not be done, under any circumstance , with the car of an employee ;
  public transportation like taxi / cab , if approved by the driver , or if not by an ambulance
   Communication to all employees shall be done , at least , quarterly.
   Definition of Corporate reportable injuries :
  o Lost Time Injury : employee who will not return to his / her next scheduled shift as a
  direct result of his / her work related injury. Lost-time absences not medically
  authorized in writing may be coded separately on report pending decision by WCB /
  CSST / WSIB. In such circumstances, you shall have contacted your H&S manager
  and agreed with him for the codification of this case.
  o Medical Aid : employee who, after a work related injury, receives medical treatment
  that only a physician can perform and returns to his / her regular job the same day or
  on their next scheduled shift. Do not report first aid cases. Examples of medical
  treatment : stitches, prescription of a drug not available without prescription.
  o Modified work case : employee who, after a work related injury, will return to his / her
  next scheduled shift but will not perform > 80% of the components or tasks of the
  regularly assigned job, or cannot work a full shift or is assigned to an irregular job as a
  direct result of his/her work related injury.
   An "irregular job" is not one usually performed by this type of worker e.g. photocopying or
  paper-shredding.
   Reoccurrences of case already registered should NOT be entered as new cases. However it is
  imperative that all additional lost days and additional modified work days resulting from the
  reoccurrence of the injury be also registered.
   Root cause(s) are identified (incident investigation must be started within 48 hours).
  TRAINING
   It will be the responsibility of all sites to ensure documented training is provided to all
  employees responsible for investigating incidents. (The Occupational Health and Safety
  Manager will train a Trainer for each location).
   This training will be standardized and specifically address the loss causation model and root
  cause analysis.

CHEMICAL MANAGEMENT

• Available updated chemicals master list.
   Updated MSDS (less than three (3) years from date of preparation / review), mandatory for
  controlled products.
   An effective WHMIS / Hazard training program been implemented
  o training material up to date
  o tests used
  o training program reviewed annually
  o training provided when new chemical hazards introduced or employee transfers to new
  job
  o new hires and contract employees provided with training at time of initial assignment
   Chemicals which are compatible and pose a risk of explosion, ignition or release of a toxic gas
  are stored separately.
   Spills are immediately cleaned up in a safe manner.
   Use only compatible containers when transferring chemical from one container to another.
   Use required personal protective equipment.
   Use grounding equipment when pouring flammable chemicals.
   Flammable storage cabinets have containment or containment devices that are capable of
  handling total volume stored if all contents were to leak / spill - Flammable specifications
  guidelines from Lactalis are available
   Tanks used to reclaim acid and caustic for re-use are
  o Stored in an area below 50C
  o Secured or fixed on a trolley
  o Stored right side up with valves on the top
  o Stored with a cap when not installed to be used
  o In the case of propane, stored outside in a locked metal caged area
   Aerosols not immediately in use must be stored in flammable cabinet.
   Away from
  o places where there is a risk of fire
  o combustive and oxidizing agents
  o Unexposed to sun rays
  o In flammable cabinets
  Acids away from alkalis.
   Tanks / barrels well covered / closed and identified.
   Tanks / barrels equipped with spill containment.
   Review, approval and control process for new chemicals implemented.
   Pipes containing hazardous materials labelled to indicate contents and direction of flow.
   New hazardous materials : a documented formal review and signed approval for new
  chemicals or biological materials using standard form (see Annex).
   Written chemical handling program that includes
  o training frequency
  o management and location of MSDS
  o container, tank and pipe labelling requirements
  o material handling precautions and PPE.

ELECTRICAL SAFETY

• SCOPE :
  o this document applies to all electrical work done in this facility. It applies to all
  electrical equipment, wiring and all voltages in this facility including all distribution
  electrical equipment as well as all service of electrical components of any equipment.
  o The safety practices as outlined in this policy must be followed for all employees
  engaged in work on electrical equipment.
  o Facility management authorizes in writing those personnel specifically permitted to
  perform electrical work and the work they are authorized to perform.
  o All electrical wiring, service, and maintenance will be performed in accordance with the
  national and provincial electric code.
  o New equipment shall be approved as complying with applicable electrical safety
  standards and a comprehensive electrical safety analysis shall be completed (Analysis
  includes short circuit study, arc flash hazard assessment, installation of arc flash hazard
  labels, updated one line drawings)
  o Electrical equipment should be installed in a neat and professional manner
   Disconnects legibly marked to indicate their purpose.
   Circuit must be legibly marked unless located and arranged so that the purpose is evident.
   Covers are in place and properly secured on all electrical boxes, receptacles, switches,
  panels, etc.
   Electrical equipment and utilities been installed and maintained so that there are not electrical
  hazards present to employees.
   General electrical awareness training been provided for unqualified persons and is
  documentation of training maintained.
   Electrical rooms must be kept limited to Maintenance personnel, if possible locked with the key
  in possession of authorized employees (by the local Maintenance Manager and Site Leader).
  If the rooms can’t be locked, the access must be reinforced through posters or warnings.
   Electrical e-stops must be kept operational and employees trained for their proper use.
   Electrical interlocks must be inspected (pre-operational inspections) and employees must be
  trained for their proper use. Any shortcut actions taken to avoid the use of interlocks in order
  as shorten the job must be considered as a violation of a cardinal rule and discipline be
  established.
  Site has established electrical safety policies / procedures.
   Electrical safety Training :
  All employees - all employees must be trained in “general electrical safe procedures” and to
  recognize potential electrical shock or arc blast hazard situations when live electrical repairs take
  place near their work stations.
  Qualified personnel – training for personnel authorized to perform electrical work must include the
  following;
  1. Information on local and CSA standards including Z-462
  2. Skill and techniques necessary to distinguish live electrical parts
  3. Skill and techniques to determine the nominal voltage of electrical parts
  4. Clearances necessary for working near live voltage and proper use of barriers
  5. Proper use, selection and maintenance of PPE (insulating tools, gloves, clothing, boots,
  mats etc.)
  6. Skills and techniques necessary for their responsibilities and safety
  7. Specific training on job hazards and equipment
  Refresher training – shall be provided every three years or as needed to keep employees aware
  of the standards and to ensure their safety
   Qualified persons are trained
  o work on energized electrical circuitry
  o personal protective equipment
  o qualifications of personnel performing electrical work
  o arc flash precautions
   Assessment to conduct
  o IR - every year (maximum TOLERATED every two (2) years , if the conditions justify
  )
  o Arc Flash : once in the lifetime or with major modifications
   SAFE WORK PRACTICES WHILE WORKING ON ELECTRICAL EQUIPMENT
  a. Only qualified personnel are authorized to work on electrical equipment or to perform any service
  on electrical components of any equipment.
  - Electrical rooms must be locked to allow access only to authorized personnel
  - Electrical cabinet doors and covers shall be closed, secured and locked to allow access
  only to authorized personnel.
  b. Electrical equipment shall be de-energized, before and while work is done on the equipment.
  • All lockout/ tagout procedures must be followed.
  • De- energized electrical equipment shall be tested to ensure equipment is de-energized
  using properly rated devices. All capacitors on equipment being serviced are considered
  “energized” until they are properly discharged.
  c. Re-energizing electrical equipment can be done only when;
  - No automatic restart of the equipment will occur when it
  is reenergized
  - Employees exposed to the potential electrical hazard are at a safe distance
  - Each lockout and tag is removed by the employee who placed them on the
  equipment
   EXCEPTIONS FOR WORKING ON LIVE ELECTRICAL EQUIPMENT
  i. No work can be performed on live electrical equipment if an arc flash assessment has not
  been done.
  ii. Only equipment that is infeasible to de-energize due to design or testing requirements or
  that would create an increased hazard to other individuals from being de-energized can be
  worked on in a live condition.
  iii. Voltages over 750V will be serviced by electrical utility personnel and not company
  personnel.
  PROCEDURES FOR WORKING ON LIVE ELECTRICAL EQUIPMENT
  a. A written energized work permit is required to work on live electrical equipment
  above 50 volts.
  b. Safe work distance shall be maintained when working on energized electrical
  sources. (Refer to “voltage range/ restricted approach boundary”).
  c. Do not blindly reach into an area that contains energized components.
  d. Do not enter spaces that contact energized electrical equipment unless proper
  illumination is provided.
  e. Electrical panels – opened hinged doors and cabinet covers shall be secured to
  prevent accidental closure.
  f. Signs and Barriers – signs must be placed in the area of live repairs being performed
  to warn other employees of the hazard present. Barriers of a non-conductive
  material shall be placed around a working area where energized components are
  exposed and other personnel could come into contact with the components.
  Unqualified personnel are not permitted inside the barricaded area. When signs and
  barricades will not provide sufficient protection of other employees, then an
  attendant will will be placed at the site to verbally warn and protect personnel.
  Barrier distances shall be as listed in “limited approach boundaries”
  g. Electrical conductive cleaning materials are not to be used while performing
  energized servicing operations. No housekeeping operations are allowed near a
  servicing operation when energized repairs are being performed.
  h. PPE, clothing and equipment when working on or testing live equipment;
  i. Insulated tools must be used.
  i. The appropriate PPE shall be used depending on the voltage and the
  arc flash rating of the equipment. Refer to section __ PPE required.
  PPE must be in good condition when used. At a minimum it must be
  inspected and replaced as per manufacturers recommendations.
  ii. Electrical test equipment shall be inspected on a regular basis and
  repaired or replaced as necessary.
  iii. Employee clothing must be of non-conductive material.
  iv. Servicing of energized components in a conductive area (water, floor
  grates etc.) can be performed only after sufficient insulting
  equipment has been placed in the location.
  v. all ropes, chains and ladders used near an operation on energized
  equipment must be of non-conductive material
  vi. When working with conductive materials around energized
  components or during operations on live components located within
  a confined space, additional precautions or PPE may be necessary.
  Protective insulting head covering must be worn if head is near a
  potential source of live electrical energy.
  ARC FLASH RISK ASSESSMENT
  • An arc flash risk assessment shall be performed to determine if an arc flash hazard
  exists.
  • The risk assessment shall determine
  o Appropriate safety practices
  o Arc flash boundary
  o PPE that personnel within the boundary shall use
  • Arc flash risk assessments shall be updated when a major modification takes place. It
  shall be reviewed at intervals not to exceed 5 years to account for changes in the
  distribution system, design and maintenance
  GENERAL ELECTRICAL SAFETY PROCEDURES FOR ALL EMPLOYEES
   Circuit breakers
   shall not be used as switches for electrical equipment\
   Circuits that repeatedly trip or blow fuses will be investigated and load
  problems corrected. Fuses or breakers will not be replaced or reset until it is
  determined the circuit is safe to operate. Problems will be identified by a
  qualified person.
   Fuses will not be replaced with higher rated fuses or makeshift devices.
   Ladders
  • Non-conductive ladders should be used when working on or near any electrical equipment
  Overhead power lines
  • overhead power lines will be de-energized and grounded before any work is performed by any
  vehicle or mechanical equipment near the power line. If the power line cannot be de-energized,
  then the equipment will be operated so that a clearance of 10 feet is maintained.
  • Cords and plugs
  • No employee shall plug or unplug a cord with wet hands. No handling of power cords that
  have been immersed in water or other conductive liquid is allowed. Power cords used in any
  area that has any conductive liquid present must be approved for such service.
  • Cords and plugs shall be handled in safe manner so as not to damage insulation
  • Power cords shall be visually inspected prior to beginning of shift and repaired as necessary.
   ELECTRICAL EQUIPMENT MAINTENANCE AND CONDITION
  • All electrical connections to equipment must be secure so that cord or cable tension is not
  transmitted to electrical terminals within the equipment.
  • Temporary wiring that is being used on a permanent basis should be replaced with fixed wiring.
  Conduit or cable systems must be protected from damage.
  • No exposed wiring is allowed
  • All electrical equipment must be grounded as per code. Alteration of grounding type
  connections are not allowed. Where there is employee exposure to potential ground-to-shock
  hazards, GFCI protection should be provided.
  • Electrical panels – Panels must be empty of materials.
   IR thermographic analysis must be performed annually as part of electrical maintenance
  program
   Three feet is the minimum clearance distance.
   Arc Flash program meet requirements of CSA Z462 - assessment complete, labelling
  complete, training complete, personal protective equipment are available, capital requested for
  major items.
   Extension cords on the floor protected from being damaged and are not causing a trip hazard.
   In Quebec, extension cords hanging must be of sufficient height so as to not impede
  pedestrians, but cannot be higher than two metres.
   All main electrical rooms and motor control centres (MCC) have smoke detection.
   Live circuits exceeding fifty (50) volts to ground. “Live electrical parts of which an employee
  may be exposed shall be de-energized before the employee works on or near them, unless
  the employer can demonstrate that de-energizing introduces additional or increased hazards
  or is unfeasible due to equipment design or operational limitations.” Examples of increased or
  additional hazards include interruption of life support equipment, deactivation of emergency
  alarm systems, shutdown of hazardous locations ventilation equipment, or removal of
  illumination for an area. Examples of work that may be performed on or near energized circuit
  parts because of unfeasibility due to equipment design or operational limitations include
  testing of electric circuits that can only be performed with the circuit energized and work on
  circuits that form an integral part of a continuous industrial processing a chemical plant that
  would otherwise need to be completely shut down in order to permit work on one circuit or
  piece of equipment.
   Use of insulated tools.
   Labeling and appropriate personal protection equipment

LOCK OUT TAG OUT

• Specific lockout / tag out procedures for all equipment, which are accurate and current, must
  be available to lock any residual energy.
   Written program, site-specific, must be prepared by the sites.
   Training records must be kept
  o authorized employee records
  o affected employee
  o other employees
   Internal Training for LOTO must be given by competent trainers; competent training is defined
  by :
  o Certified external training
  o Accreditation of the trainer (for example, an electrical engineer or an electrician)
   LOTO devices must be
  o durable : LOTO devices must be capable of withstanding the environments to which
  they are exposed.
  o standardized : LOTO devices must be standardized in color, shape or size. Printed
  tags must be standardized in print and format.
  o substantial : LOTO devices must be substantial enough to prevent removal without the
  use of excessive force or unusual techniques (e.g. bolt cutters).
  o identifiable : LOTO devices must indicate the identity of the employee applying the
  device. Tag out devices shall guard against hazardous conditions or use legends such
  as “DO NOT START”, “DO NOT OPEN”, “DO NOT OPERATE”, etc.
   Out of service electrical boxes that do not have the power / wires to that electrical box
  disconnected must have the fuses pulled and LOTO with the standard plant LOTO. The key to
  this lock must be in the control of the manager of the plan maintenance / electrical department.
   Hazardous energy control plan include provisions for coordinating with outside contractors and
  is the method of coordination being utilized and effective.

MACHINE GUARDING

• Machines guarding inventory is documented.
   Guarding by point of operation, ingoing nip points, rotating parts, flying chips & sparks, etc.
   Guarding means have been installed and are effective in minimizing employee exposure to
  equipment hazards. Particular focus should be placed on equipment such as packaging
  machines, conveyor and chain drives, compactors, etc.
   Mechanical or electrical power control provided on each machine to make it possible for the
  operator to cut off the power from each machine without leaving his / her position at the point
  of operation.
   All gears, pulley, belt and chain drives completely enclosed.
   Conveyors installed over working and walking surfaces equipped with guards to prevent
  objects from falling from the conveyor.
   All air guns have an unobstructed air release mechanism on them.
   Daily / shift check question on the employee checklist that all lubrication systems on the infloor
  carton conveyors in fluid plants and warehouses are functioning properly.
   Grinders
  o guarding : abrasive wheels have proper guards that cover the spindle end, nut, and
  flange protection.
  o work rests : adjusted closely to the wheel with a max opening of 1/8 inches to prevent
  the work from being jammed between the wheel and rest, which may cause wheel
  breakage.
  o mounting: immediately before mounting, all wheels are closely inspected and sounded
  by the use (ring test) to make sure they have not been damaged in transit, storage, or
  otherwise.
   Each machine should be provided with an E-stop or other means to shut off the machine.
   Pedestal-mounted machines or shop equipment designed for fixed location securely anchored
  to prevent walking or moving.
   Guards for
  o mechanical press
  o drills
   Emergency stops for pneumatic and hydraulic press.
  All chain drives and sprockets / transmission pulleys guarded to prevent access to and egress
  of parts if chain or drives break on floor carton conveyors in fluid plants and warehouses.
   Plant pressure should never be more than 200 psi unless in an enclosed room; pressure to be
  reduced at max 30 psi, manual air pressure guns.
   Will stop when tension on track surpasses load limit or are there guards (e.g. bollards) where
  chain makes turns in floor.
   By-passing interlocks or violation of interlock procedures is strictly forbidden, unless an
  Interlock by-pass permit is available (see Annex).

PPE

• Personal protective equipment policy is available, documented and communicated.
   Personal protective equipment training provided to each affected employee prior to use and is
  training documented.
   Elements of the personal protective equipment program
  o when personal protective equipment is necessary
  o what personal protective equipment is required
  o how to wear personal protective equipment
  o proper care, maintenance, useful life & disposal of personal protective equipment
   Contains the name of each employee trained, the date(s) of training, and also identifies the
  subject of the certification (e.g. self-contained breathing apparatus, fall arrest harness,
  respirator, etc.)
   Personal protective equipment being stored in a clean and sanitary condition.
   Where eye protection is required, such equipment must meet CSA 294.3-92. “Street wear”
  frames and lenses do not meet CSA / ANSI specifications for eye protection and are not
  acceptable to be worn in eye protection areas.
   Safety hats, if required, are compliant with standard CSA Z89.1-1986.
   When required, are aprons designed and worn in a manner that prevents a spill from falling on
  unprotected areas (e.g. legs, and feet).

HEALTH AND FIRST AID

• Monthly inspection records of the first aid room.
   First aid assistant training valid.
   All events are recorded.
   Re : Provincial or State standard
  o first Aid box with the required first aid items
  o monthly inspection of the First Aid room
   All events must be recorded in the site log-book with the following information
  o accident description
  o date and time of occurrence
  o names of witnesses

CONFINED SPACES

• Location survey and inventory records.
   Written procedure and program.
   Records of method of evaluation (e.g. written tests, skill evaluation, etc.).
   Certified training records documented.
   Calibration and PM records for the equipment (internal bumping test and external calibration).
   Each shift has at least one employee / resource with a valid first aid certificate.
   If the site is relying on an outside rescue service , conditions must be met
  1. detailed written confined space program must be developed, containing the following
  elements:
  a. measures to prevent unauthorized entry
  b. identification and evaluation of hazards before entry
  c. means, procedures and practices necessary for safe entry
  d. safety equipment
  e. evaluation of permit space conditions (monitoring)
  f. provisions for attendants outside the space
  g. provisions for providing emergency means/procedures when attendants are monitoring
  multiple spaces
  h. designation of personnel
  i. rescue and emergency procedures
  j. entry permit system
  k. contract coordination procedures
  l. permit termination procedures
  m. program review process (e.g. audits)
  2. that specify:
  a. all precautions and procedures to be performed in a confined space before any worker
  enters the confined space
  b. the location of the confined space
  c. a description of the work to be performed
  d. a description of the hazards and the corresponding control measures
  e. the time period for which the entry permit applies
  f. the name of the attendant
  g. a record of each worker's entries and exits
  h. a list of the equipment required for entry and rescue, and a verification that the
  equipment is in good working order
  i. results obtained in atmospheric testing
  j. if the work to be performed in the confined space includes hot work, adequate
  provisions for the hot work and corresponding control measures
  k. during the time period for which it applies, is readily available to every person who
  enters the confined space and to every person who performs related work with respect to
  the confined space
  3.
  a. information : employees who are exposed to confined spaces must be informed of the
  existence and location of dangers posed by confined spaces. This information may be
  conveyed via a combination of signs posted at confined spaces and training
  b. training : must be conducted so that all affected employees (entrants, attendants, entry
  supervisors and rescuers meet CSA Standard Z1006-10), acquire the understanding,
  knowledge and skills necessary for the safe performance of their duties
  c. frequency of training : required to be conducted initially, upon changes in the
  employee’s duties and whenever new hazards have been introduced about which the
  employee has not been trained and whenever program/procedure deficiencies are
  identified.
   Method of evaluation (e.g. written tests, skill evaluation, etc.) level of proficiency is required.
   Certification of training is required. Certification must include the employee’s name, signature
  or initials of the trainer(s) and dates of training. Must post list of certified site confined space
  entrants and trained attendants.
  1. whether being done by Parmalat employees or on-site contractor
  a. necessary personal protective equipment / rescue equipment provided and
  immediately accessible
  b. rescuer trained in use of rescue equipment required
  c. annual practice sessions that are documented
  d. trained in first aid and CPR
  e. rescue equipment identified in the relevant plan is readily available to effectively rescue
  in the confined space, is appropriate for entry into the confined space and is inspected
  as often as is necessary to ensure it is in good working order, by a person with the
  adequate knowledge, training and experience who is appointed by the employer
  f. the inspection is recorded in writing
  g. the employer/contractor has established methods of communication that are
  appropriate for the hazards identified in the relevant assessment, and are made readily
  available for rescuer to communicate with the attendant
  2. (e.g. Fire department) [not applicable in Ontario]:
  a. pre-arrangement with outside rescue service
  b. provide outside rescue service with access to all permit spaces for planning and
  training
  c. have documentation showing outside rescue service has training/competence to
  conduct a confined space rescue at location.
   Calibration and PM records for the equipment. Routine, internal equipment calibration records
  should be readily available and properly documented. Calibration of monitors must be
  coordinated outside in the fresh air and should read 20.9% O2.

WALKING AND WORKING SURFACES - INDUSTRIAL SAFETY

• All stairs with four (4) or more steps have standard stair railings or handrails.
   All elevated work platforms that are four (4) feet or more above the floor equipped with a
  standard railing, including top-rail, mid-rail and toe board.
   All wall and floor openings properly covered or guarded (e.g. mezzanines and drains).
   Floors, passageways, exits, and general working areas maintained in a clean and so far as
  possible, a dry condition, from housekeeping related hazards.
   Walkways in location have
  o at least 600 mm of width and 1100 mm of width if an emergency route
  o lighting to ensure safety in power outages
  o clearance height along walkways and at exit must be at least two (2) metres
   If clearance height along walkway at exist is not at least two metres, obstruction needs to be
  identified by some form of warning signage.
   Outside and inside the plant, walkways are well marked as well as driveways and intersections
  for vehicles. An assessment of these pedestrian paths must be completed by the site.
   The location has conducted a documented assessment of their outside and inside pedestrian /
  vehicle traffic and parking areas and put in place measures to ensure pedestrian safety.
   Outside the plant, areas used for transportation and material handling level are drained and
  maintained.
   Toe boards are required wherever, beneath the open sides, persons can pass, there is moving
  machinery, or where there is equipment with which falling materials could create a hazard.
  Regardless of height, open-sided floors, walkways, platforms or runways above or adjacent to
  dangerous equipment to be guarded with railings and toe boards.
   Ladders and stepladders maintained in good condition
  o CSA Standard for existing ladders - CSA Z11-1969
  o CSA Standard for purchasing new ladders - CSA3 Z11-M81
   Ensure stability of loads, vehicles and equipment.
   Portable or powered dock boards structurally sufficient to carry the load imposed on them.
   Storage racks free of damage.
   Load capacity indicated and easily visible on plant racking and mezzanines.
   Personnel trained in recognizing the weight of equipment and materials before they are
  placing it in racks or in storage areas.
  Stored materials properly secured from rolling or falling.
   Built, mounted, installed and maintained to support worker(s) and load they have
  o installed level and / or secured
  o equipped with railings if more than 3 metres high

HOT WORK

• A hot work permit must be produced for all hot works performed by
  o employees
  o contractors.
   It should cover one day only.
   A maximum period of 5 working days may be allowed for the permit provided that
  o the work is unchanged,
  o the location unchanged
  o the personnel carrying out the work are unchanged.
   Daily re-assessment before work is mandatory (indicated on the hot work permit).
   In all cases (daily permit or 5-day permit), written daily records are to be kept for the
  inspection taking place 90 minutes after work ceases.
   Prior to starting hot work, combustible materials must be removed from the area or
  protected and the works area equipped with the necessary means of extinction.
   watchman/surveillance
  o Surveillance must be carried out by internal or external qualified personnel both
  during and outside of operating hours.
  o Instructions must be formalised (documented).
  o Fire watchers are trained by competent trainers (example : firefighters). As a reference,
  the Fire watch training guidelines from Alberta can be considered as an example.
   A cutting and welding permit written program must be established for the facility, including
  contractors.
   Records of hot work permit (min last year) must be kept for at least one year
   Training for personnel involved in hot work must be scheduled and conducted; this training
  must be provided by competent employees or companies this competent training is also
  applicable to fire watchers.
   Oxygen cylinders in storage must be separated from fuel-gas by a minimum distance of 20 ft.
   Adequate mechanical ventilation provided in cutting and welding areas when such activities
  are in a limited space.
   When arc-welding equipment is not in use, electrodes have been removed to prevent
  inadvertent operation.
   Oxygen cylinders are stored at a minimum of six (6) m away from combustibles gases
  (acetylene and propane) or combustible materials (e.g. oil and grease).
  Confined spaces or where welding space contains partitions or structural barriers that
  significantly obstruct cross ventilation.
   Hot works designated areas (like maintenance workshops) are accepted to have permanent
  hot work permits (instead of ad hoc permits), that must be permanently posted and signed by
  the local Director and Site Maintenance manager.

POWERED INDUSTRIAL TRUCKS

• Operators have been trained and certified to operate powered industrial trucks as per
  provincial regulations.
   Daily inspections conducted prior to operation and are powered industrial trucks that are in
  need of repair defective or not in safe operating condition, removed from service.
   Manufacturer’s recommended operating criteria.
   Inspections records : minimum three-month history of inspections retained.
   Personal protective equipment (e.g. gloves, face shield, apron) readily available and used
  when performing battery maintenance or changing LPG cylinders.
   Licensing is generally an accepted method of “authorizing” operators (battery powered lifts,
  LPG, diesel, stand-up, sit-down, pallet-jack, etc.).
   Evaluate the training to ensure that it is specific to the type of equipment.
   The manufacturer’s recommended operating criteria should be included in the specific training
  o retraining is to be at intervals not exceeding three years as per CSA Standard B 335-
  04 s.6
  o also, retraining must happen when we acquire or modify equipment, working
  environments, changes, and when skill or knowledge deficiencies have been identified
   Good practices and safety requirements
  o loads and forks lowered when travelling or parked
  o excessive damage to structure, equipment and facility
  o trucks operated at safe speed
  o operator must wear seat belts when required as per CSA Standard B335-04 s.4.9.2.3
  o the forklift complies to lift truck's CSA Standard B335-04 s.4.9.9
  o the person(s) in the lifting device must wear a safety harness as prevention in case
  they fall from / out of the lifting device
  o the lifting device is prevented from movement on the forks and is secured (e.g.
  chained) to the forklift
  o the total weight lifted never exceeds 50% of the maximum load capacity of the forklift
  o the forklift operator is always at the operating position for the duration of the work,
  except if the person being lifted has main operation controls with him
  o cage must have capacity ratings
   Wheel chocks or dock restraints are utilized.

CRISIS MANAGEMENT AND EMERGENCY PREPAREDNESS

• A crisis coordinator must be appointed.
   Fire drills records, minimum one fire drill / year.
   All emergency exits, exit access and exit discharges arranged and maintained as to provide
  free and unobstructed egress from all parts of the building at all times when occupied.
   All emergency exit doors marked with a readily visible sign.
   Doors, passageways, or stairways which are neither an exit nor a way of exit access, and
  which are so located or arranged as to be likely to be mistaken for an exit, prominently
  identified by a sign reading "NOT AN EXIT".
   Emergency exit routes been developed and posted throughout the location. This information
  must be kept up to date.
   An emergency notification system been installed, is it functional, regularly tested and is a
  documented PM program in place.
   The emergency notification system is heard in all areas of the facility.
   Emergency lighting been installed, is it functional, regularly tested and is there a documented
  PM program in place.
   A comprehensive written crisis management plan been prepared
  o covers necessary emergencies
  o tested or reviewed annually
  o it includes an emergency contact listing outlining chain of command
  o posted in several places to be readily accessible
  o crisis management plan reviewed annually with employees
   Locks or other fastening devices that would prevent free escape are prohibited.
   Access to exits must be marked with a readily visible sign in all cases where the exit or way to
  reach it is not immediately visible to the occupants.
   An address list expected emergency situations for the location, and is it up-to-date.
   Handheld spray nozzles are not acceptable as emergency eye wash stations.
   Emergency eye wash stations should be of the fixed bubbler type. Emergency eye wash
  stations should be designated and installed to provide a minimum of 15 minutes continuous
  flow of water.
   Portable units that cannot provide 15 minutes of continuous flow are unacceptable.
   Self-contained eye wash stations must meet CSA specifications.
  Emergency Plan for Ammonia leaks :
   An ammonia Emergency Preparedness Plan must include the following elements
  • establish the levels of detection ( measured by a calibrated and maintained instrument)
  • clearly define the actions triggered by these alarms
  • establish the emergency contacts,
  o telephone numbers
  o company responsibility
  o external resources
  • have defined an internal and external Preventive Maintenance Program
  • have available and known to pre-established contacts, the work flow for external
  communication in case of a major and uncontrolled leak
  • plan in advance emergency drills to practice the emergency preparedness
  • have this information posted and available to employees / contractors and visitors
  • in case any Parmalat employee will respond to an emergency situation, it must be assured :
  o proper certified training by an external institution / company
  o available personal protective equipment (recommended by the company or institution
  that provided the training), inspected and maintained
  o this information is backed up and communicated to the local HazMat external Team
  Example of an Ammonia Emergency Plan :
  First level of detection (TBC : 30) ppm : ventilation fan starts and a message is addressed to........
  1. Verify the % of ammonia on the detection panel, and confirm the functioning of the ventilation
  fan
  2. Contact the maintenance supervisor, that will be asked to be available at the control panel
  3. If needed, contact the ammonia system specialist
  4. If the leak continues and the level is detected over (100) ppm, push the alarm button to
  activate the building alarm and continue with step 2
  Second level of detection (TBC: 160) ppm; the sound alarm will trigger
  1. Contact 911 services, explaining the nature of the call (clearly : ammonia leak), with the last
  reading of detected leak percentage and the address of the plant
  2. Request the maintenance supervisor to inform the list of valves to be shut-downed, any other
  pertinent information and the town emergency procedure
  3. Request the emergency assembling point responsible to activate the emergency evacuation
  procedure
  4. Inform the ERT (Emergency Response Team) of the plant, including
  1. Site Leader
  2. Regional Production Director / VP
  3. Communicate the Corporate resources of the emergency
  4. Inform the Town services, with all necessary data : where, quantity, leak level (ppm),
  etc.
  5. Launch the Plant Emergency plan (evacuation, communication, etc.)

CRANES AND HOISTS / MATERIAL HANDLING

• Lifting equipment inventory documented and reviewed annually.
   Procedures and training records.
   Daily inspection records
  o daily functional operating mechanism check
  o daily checks for leaks in air/hydraulic system
  o daily inspection of hook and safety clip
  o daily inspection of hoist locking or clamming attachments
  o daily inspection of hoist rope/cable/chain conditions
  o daily inspect to see hoist rated for load being lifted
   Quarterly inspection records
  o check for loose bolts / rivets
  o check for worn sheaves and drums
  o inspection of brake system parts
  o check for any indication of use of loads over the rated capacity of the hoist or rope /
  cable / chain
  o check for excessive wear of chain drive sprockets and excessive chain stretch
  o check for signs of pitting or any deterioration of the controller, limit switches and push
  button stations
   Maintenance procedure.
   Rated load of all cranes / hoists plainly marked on each crane / hoist.
   If the crane / hoist has more than one hoisting unit, rated load marked on each hoist. The
  marking must be legible from the floor.
   Procedures / training used to authorize employees as “designated personnel”. At a minimum,
  the training should include the following topics regarding the handling of the load
  o size of the load
  o moving the load
  o hoist limit switch
  o safe operating procedures
  Maintenance procedure which should include the following precautions
  o Crane / hoist to be repaired shall be run to a location where it will cause the least
  interference with other cranes / hoists and operations in the area
  o all controllers shall be in the off position and locked out
  o the main or emergency switch shall be open and locked in the open position
  o warning or “Out of Order” signs shall be placed on the crane/hoist, also on the floor
  beneath or on the hook where visible from the floor
  o where other crane/hoists are in operation on the same runway, rail stops or other
  suitable means shall be provided to prevent interference with the idle crane / hoist
  o after adjustments and repairs have been made, the crane/hoist shall not be operated
  until all guards have been reinstalled, safety devices reactivated and maintenance
  equipment removed
   File on an individual crane / hoist must be kept for the lifetime of the crane / hoist as per CSA
  B167-96.

FIRE PREVENTION AND PROTECTION

• Fire extinguishers readily available, properly located and installed, appropriate for type of fire
  and are extinguishers INDIVIDUALLY checked on a monthly basis.
   Portable fire extinguishers hydrostatically tested annually.
   Employees training records.
   Fire extinguishers inspection records : three (3) year training, how to (based on Lactalis
  Policy).
   Extinguishers should be
  o secured to the wall
  o unobstructed
  o immediately accessible
  o identified with a sign
  o monthly inspection program documented
  Regular inspections for preventing fire
   Fire inspections are to be carried out on a monthly basis using a specifically drawn up checklist.
   They are aimed at guaranteeing high levels of housekeeping, particularly in technical areas,
  as well as to check on the presence and efficiency of fire-fighting means, along with their
  accessibility.
   written report covering the different check points and any discrepancies noted must be
  produced and sent to the managers of the relevant departments so that corrective or
  improvement measures may be taken
  Smoking
   Smoking is banned from all areas other than designated smoking areas.
   Rules are to be clear (signage) and adhered to by all (employees, visitors, contractors,
  transporters, etc.).
  No storage of combustibles in the vicinity of buildings
  No storage of pallets, waste bins, gas bottles, flammable liquids, etc. against the walls or too
  close to buildings.
  Technical rooms ( boiler rooms, power or control rooms, laboratories, server rooms )
   Technical rooms (boiler rooms, power or control rooms, laboratories, server rooms or any area
  designated as being central to operations) must be clean and exempt from the storage of all
  combustible materials (paper, cardboard boxes, etc.).
  compliance of electrical installations
   An inspection of the electrical installations is carried out by a qualified body annually
  Infrared thermography
   Infrared thermographic survey allows the detection of abnormally hot spots that could cause a
  fire or stop production.
   A minimum of one infrared thermographic inspection per year, suited to the location and the
  activity carried out (powders, etc.).
   This check is to be carried out by a qualified individual and any non-conformities solved
  Monitoring electric transformers
   Physico-chemical analysis allows the state of the dielectric, cleanliness qualities of the oil to be
  determined (wear by ageing).
   Dissolved gas chromatography allows the evaluation of the intrinsic state of the transformer
  and, in particular, its active parts (flashover, heating, corrosion, etc.).
   Analyses must be performed at least once every 4 years.
  Maintenance of sprinklers and impairment procedures
   Sprinkler systems are monitored and maintained with :
  o weekly tests on sprinkler control / alarm valves and sprinkler pumps
  o monitoring water storage tanks valves and control/alarm valves that must remain open
  and be padlocked or sealed at all times
  o six-monthly checks
   When a sprinkler system is partially or fully shut down, preventive measures must be taken
  (informing Management and other persons concerned, banning of hot works in the areas
  that are unprotected, increased inspections by security staff, etc.).
  A sprinkler system impairment notification (Group form) is filled in and sent to the Group Risk
  Management Department and, when impairments exceed 10 hours, to the Broker and the
  Insurer.

FALL PROTECTION

• Fall protection equipment is readily available and in acceptable condition for employees who
  are exposed to fall hazards.
   Fall protection hazard assessment (potential fall hazards of greater than three (3) metres).
   Fall protection training records documented.
   Emergency rescue plan.
   Documented visual and operational inspection records (visual thorough inspection prior to
  use).
   Harness internally inspected (before use) and externally inspected (once / year).
   Mobile elevating platform/ lift: documented measures taken to ensure it is safely used -
  external inspections documented.
   Identify any frayed threads, cuts, tears and loose connections.
   Fall protection training (performed by a competent person) should include the following
  elements at a minimum
  o nature of fall hazards in the workplace
  o correct procedures for erecting, maintaining, disassembling and inspection all
  protection systems to be used
  o use and operation of fall protection systems
  o employee accountabilities and responsibilities
   Emergency rescue plan should be
  o location specific
  o should anticipate potential emergency situations and methods to rescue employees in
  the event of a fall
  o consideration should be given to identification of rescue personnel, ladders or other
  rescue equipment
   Operator must have training / permit to operate such equipment
  o documented visual and operational inspection must have been completed
  o operator/occupants must wear fall arrest safety harness
  o platform must be stable and leveled

CONTRACTORS MANAGEMENT

• Contractors files up to date
  o current certificate of clearance from WCB, CSST or WSIB
  o valid private liability insurance certificate
  o licensing documentation and training with regard to procedures if they are required as
  part of the contracted work (eg. electrical licence, confined space etc.) certificate of
  insurance updated to the current year - WCB / WSIB certificates up to date
   Require contractors’ licenses (to inspect or work on equipment).
   Chemical hazard information / documents provided by and to contractors.
   Files must be kept on file at location.
   Must be able to show when licensed person is required to inspect or work on equipment (e.g.
  elevator, refrigerator, boiler, LOTO, confined space entry / work, forklift training). Must be kept
  on file at location.
   Ensuring that the contractor activities cannot lead to hazardous conditions for plant personnel
  and surrounding community and have signed his/her name on the contract (site monitor
  contractor safety behaviour and address any safety issues).
   Available and documented policy with regards to visitor safety.
   Visitors always accompanied while on site.
   Suitable personal protective equipment available for visitors.
   Means to properly notify visitors of emergencies or hazardous situations to avoid.
   Standard written policy and safety procedures are available for review and sign off with
  contractors.
   A contractor pre-qualification review form is completed.
   Contractors have work permit.

ERGONOMICS

• Ergonomic training is documented.
   Ergonomic assessments conducted for all jobs to identify those jobs / tasks which need further
  evaluation
  o e.g. scissor lifts, mechanical lifting devices for film rolls, boxes, bags, etc.
  o e.g. adjusting chairs, platforms, conveyors, etc.