AMERICAN DEMOLITION AND NUCLEAR DECOMMISSIONING INC. CORPORATE HEALTH AND SAFETY PROGRAM (H.A.S.P.)

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1 American D N D Demolition & Nuclear Decommissioning, Inc. PO Box 553 Grand Island, NY Phone: Fax: ADND@AmericanDND.com AMERICAN DEMOLITION AND NUCLEAR DECOMMISSIONING INC. CORPORATE HEALTH AND SAFETY PROGRAM (H.A.S.P.) THIS IS CONTROLLED COPY NUMBER

2 AMERICAN DND, INC. HEALTH AND SAFETY PLAN (HASP) INTRODUCTION This Health and Safety Program (HASP) establishes standard processes and procedures for preventing accidents and injuries on American DND, Inc. job-sites. The health and safety protocol established in this program are based on representative site conditions known and anticipated to be present on job-sites, and at our corporate location. These processes and procedures, combined with Site Specific Safety and Health Plans (SSHASP) will constitute the overall Environmental, Safety and Health Plan for each American DND, Inc. Project. All operations and equipment used by American DND, Inc. shall comply with: Applicable Occupational Safety and Health (OSHA) Regulations 29 CFR Occupational Safety and Health (OSHA) Regulations 29 CFR NESHAPS Asbestos Regulations Applicable State and Local rules governing Asbestos Abatement Operations. National Association of Demolition Contractors (N.A.D.C.) Revision. Before site operations begin, all employees shall have; 1. Read or reviewed the contents of this HASP and SSHASP, and 2. Acknowledge, in writing on the Safety Orientation of Understanding Record their understanding of this HASP and all revisions 1 made to it. 1 This HASP is subject to ongoing review and revisions by American DND, Inc. pending approval by the QA/QC Team Members.

3 - SAFETY PROGRAM SYNOPSIS - American DND, Inc. utilizes an assigned Health and Safety (HASP) manual that is issued by job number to each Supervisor / Foreman / Safety Coordinator who operates a site-specific jobsite. The entire manual is a living document which is to be used to create the site-specific safety plan for a given jobsite. The manual becomes active & effective when proactively and consciously utilized by the supervisor / foreman to create a safe work-site. The Project Manager / Supervisor / Foreman as well as Site Safety Coordinators are the Competent Persons on any American DND jobsite. These persons possess the necessary training and experience to recognize and anticipate hazards, the knowledge and capacity to implement site procedures and controls to avoid accidents and create a safe workplace, and they have the authority to stop work in the event of unsafe conditions and implement corrective actions immediately. This manual contains copies of the American DND s Safety Policies and general safety rules that apply to all job-sites. The manual also contains Hazard Assessments and Site Specific Policies, which set forth the basis of the anticipated hazards of the specific job and the work practices that will be implemented to avoid these hazards. The manual contains safety awareness programs. The manual provides orientation forms, training forms, and tool box safety forms on which all safety meetings and training is recorded. It also provides a staged disciplinary procedure for the supervisor to use to upgrading the overall safety awareness. Employees / subcontractors who do not embrace and wholeheartedly practice safe work ethics and procedures are removed from the job-site. Job-site HASP s are audited monthly by the Corporate Health and Safety Director and QA/QC Management to ensure their use and quality of implementation / maintenance. The efforts are audited on an annual basis to evaluate ranking of the supervisors and employee s safety record. The manuals are updated semi annually, or as needed to include updates in regulations and to communicate notifications to the field workforce. In addition to the manual, American DND shall complete weekly and monthly facility and job-site inspection forms and audit forms that shall be used by the supervisor / foreman and the safety department and administrative supervisors to quantitatively measure the safety performance on each jobsite. Audit checklist is located in HASP Section 9.33 It is the Management of American DND, Inc. opinion, the combination of all these efforts and the constant hands-on management of the safety personnel and general supervision that keeps our safety awareness at the highest level. It is the cooperative team effort, and daily practice of safe work procedures that will enable American DND to succeed in maintaining zero-injury safety performance.

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5 AMERICAN DND, INC. HEALTH AND SAFETY PLAN TABLE OF CONTENTS INTRODUCTION CHECKING AND VERIFICATION QA/QC PAGE SAFETY PROGRAM SYNOPSIS DESCRIPTION SECTION CORPORATE SAFETY STATEMENT EEO POLICY / AFFIRMATIVE ACTION STATEMENT - Competent Person Acknowledgement & Commitment to Safety SAFETY MANUAL MECHANICS Purpose 2.2 Scope 2.3 Policy 2.4 Responsibility / Competent Person Acknowledgement 2.5 Control and Distribution 2.6 Site Specific Safety / Hazard Assessment Requirements 2.7 Field Change Requirements / Field Change Request Exhibit A CODE OF STANDARDS AND CONDUCT Purpose 3.2 Scope 3.3 Policy 3.4 Requirements 3.5 Conduct on Customers Property 3.6 Bilingual Communication / Translation Plan 3.7 Classified and Top Secret Government Installations 3.8 Anti-Harassment Policy 3.9 Mobile Phone use 3.10 Disciplinary Policy / Penalties / Notices ADMINISTRATION AND ORGANIZATION Purpose 4.2 Scope 4.3 Administration 4.4 Stop Work Authority 4.5 Corporate Safety Flowchart 4.6 Responsibilities QA / QC PROGRAM Introduction 5.2 Purpose and Scope 5.3 Program Quality Level 5.4 Quality Assurance Program Requirements 5.5 Table of Contents 5.6 Job Close-Out Report

6 FITNESS FOR DUTY PROGRAM Letter from President 6.2 Table of Contents 6.3 Policy 6.4 Scope ON-SITE SAFETY PREPERATION Pre-Demolition Survey 7.2 NESHAPS 10 Day Demolition Notification - Insert 7.3 Remote office trailer safety compliance setup procedure s / Postings 7.4 Baseline medical record requirements / Medical Condition Form 7.5 Hazard assessments 7.6 Basic PPE items / First Aid items 7.7 Emergency Procedures SAFETY EDUCATION AND TRAINING Purpose 8.2 Scope 8.3 Frequency 8.4 Requirements 8.5 Documentation / Forms 8.6 Required Topics for Safety Orientation 8.7 Record of Acknowledgment / Understanding SITE SAFETY INSPECTIONS Purpose 9.2 Frequency 9.3 Site-Safety Inspection Forms 9.31 Weekly 9.32 Monthly 9.33 Management Audit 9.4 Equipment Safety Inspection Forms 9.41 Equipment Inspection Form 9.42 Bobcat Inspection Form 9.43 Crane Inspection Form 9.44 Wire Ropes, Chains, Slings 9.45 Ladder Inspection Form 9.46 Hand tool Inspection Form 9.47 Aerial Lift Inspection Form HAZARD COMMUNICATION PROGRAM Introduction 10.2 Scope 10.3 Description / Training Outline / Maintenance / Right to Know Law / MSDS 10.4 Partial Material Safety Data Sheet Collection Gases Liquids Solids Fuels

7 LEAD PROGRAM Compliance Plan Scope 11.2 Definitions 11.3 Lead Impact Activities 11.4 Employees Responsibilities Attachment Exposure Assessment Summary Appendix A - Hazard Assessment Form Appendix B - Sampling Material Appendix C - Respirator Flow Chart Appendix D - Medical Surveillance CONFINED SPACE PROGRAM Purpose / Scope 12.2 Definitions 12.3 Procedures / permits RESPIRATORY PROTECTION PROGRAM Purpose 13.2 Scope / Table of Contents 13.3 Definitions 13.4 References 13.5 Responsibilities 13.6 Requirements 13.7 Appendix D Voluntary use GENERAL SAFETY - STANDARD OPERATING PROCEDURES (SOP) Digest of Part 1926 Safety and Health Regulations 14.2 General Safety Standard Operating Procedures (SOP) DEMOLITION SAFETY PLAN REQUIREMENTS Purpose / Scope 15.2 Preparation of Site Specific Health and Safety Plan (SSHASP) 15.3 Preparatory Operations / Pre-Demolition Engineering Survey Fire protection Purging Guarding Passageways Chutes Material Handling Demolition methodology / General CFR1926 Subpart T-Demolition CRANE RIGGING AND MATERIAL HANDLING Purpose 16.2 Scope 16.3 Definitions / References 16.4 Responsibilities / Guidelines / Requirements Exhibit A - Crane Rigging Inspection Report Exhibit B - Lift Rigging Plan

8 FALL PROTECTION Purpose 17.2 Scope 17.3 Policy 17.4 Responsibility 17.5 Program ASBESTOS (GUIDELINES OF ASBESTOS CONTRACTORS) Purpose 18.2 Scope 18.3 Work Practices and Forms RADIATION (GUIDELINES OF RADIOGRAPHIC CONTRACTORS) Purpose 19.2 Scope 19.3 Work Practices MISC. PROCEDURES AND REPORTS Occupational Heat and Cold Stress Programs 20.2 Blood borne Pathogen Program 20.3 Adverse weather procedures / protective measures 20.4 Incident Report SUBCONTRACTOR AGREEMENT (SCA) Article 1. Safety Article 2. Work to be Performed Article 3. Time of Essence and Delays Article 4. Schedule of Work Article 5. Insurance Article 6. Bonds Article 7. Subcontract Price and Payment Article 8. Final Payment Article 9. Assignment Article 10. Claims and Disputes Article 11. Indemnity Article 12. Termination Article 13. Employment Article 14. Miscellaneous ATTACHMENT Attachment A Subcontractor Minimum Safety Requirements Attachment B Subcontractors Safety Orientation Attachment C Subcontractor Fitness for Duty Attachment D Subcontractor Insurance Requirements Attachment E Subcontractor Insurance Requirements

9 American D N D Demolition & Nuclear Decommissioning, Inc. PO Box 553 Grand Island, NY Phone: Fax: ADND@AmericanDND.com CORPORATE SAFETY STATEMENT AMERICAN DND PLACES TOP PRIORITY ON THE SAFETY AND WELL BEING OF ALL PERSONNEL. NOTHING TAKES A HIGHER PRIORITY TO AMERICAN DND s MANAGEMENT THAN: ACCIDENT / INJURY PREVENTION WORKER SAFETY VISITOR SAFETY PUBLIC SAFETY & HEALTH ENVIRONMENTAL RESPONSIBILITY For AMERICAN DND s Safety Program to be effective, AMERICAN DND s management expects every person to participate in all aspects of safety, with the belief and understanding that ALL ACCIDENTS / INJURIES ARE PREVENTABLE. AMERICAN DND creates a safe attitude in a cooperative effort to continuously maintain an excellent safety record. AMERICAN DND expects everyone, including officers, management, supervisors, foremen, stewards, operators, laborers, and drivers, to participate and contribute, proactively, in the implementation and enforcement of the AMERICAN DND Safe Work Ethic. No unsafe acts are acceptable, nor will they be tolerated on any AMERICAN DND jobsite. AMERICAN DND s GOAL IS ZERO-INJURY SAFETY PERFORMANCE AMERICAN DND s management accepts the responsibility for implementing the Williams - Steiger Occupational Safety & Health Act of 1970 and will enforce compliance with all applicable safety laws and regulations.

10 AMERICAN DND embraces the core function elements to successfully implement the Integrated Safety Management (ISM) guiding principals; Line Management Responsibility for Safety Clear Roles and Responsibilities Competence Commensurate With Responsibility Balanced Priorities Identification of Safety Standards an Requirements Hazard Control Tailored to Work Being Performed Operations Authorization Project managers, superintendents, and site foremen fulfill the definition of Competent Person as defined by OSHA, and are responsible to plan out all activities, prior to execution, and are required to ensure that all adequate resources, including safety supplies, are on the job prior to the start of work. Superintendents and foremen will conduct site specific safety orientations for new hired employees and newly transferred employees, as well as subcontractors for awareness purposes. Superintendents and foremen will assign tasks to employees / subcontractors, commensurate with their level of experience and training. Every individual on an AMERICAN DND jobsite maintains the right to stop work on the project if any unsafe conditions or presence is suspected. The foreman, superintendent or project manager shall be informed immediately of any suspected unsafe conditions / situations, so corrective actions can be implemented immediately. In an effort to monitor compliance with our zero-injury and safe workplace philosophy, AMERICAN DND requires all accident / injury / mishap, no matter how small, incidental, or minor in severity, be reported immediately to the foreman, superintendent, project manager and corporate safety officer. Compliance with specific safety protocol is further reviewed as part of the AMERICAN DND QA/QC review process. AMERICAN DND further reinforces our commitment to safe work attitudes and zero-injury safety performance through a safety bonus incentive program administered, on a site by site basis, by the President/CEO and Vice President of Operations. AMERICAN DND firmly believes there is profit in safety and those profits should be shared with all those who contribute in a safe workplace. William C. Sundeen AMERICAN DND President/CEO

11 American D N D Demolition & Nuclear Decommissioning, Inc. PO Box 553 Grand Island, NY Phone: Fax: ADND@AmericanDND.com To Be Posted At All Job Sites EEO POLICY AFFIRMATIVE ACTION It is the policy of AMERICAN DND to take affirmative action in affording equal employment opportunity to all qualified persons without regard to race, color, religion, sex, physical impairment, or national origin. This includes, but is not limited to, the following: Hiring, placement, upgrading, transfer, demotion, or promotion: Recruitment, advertising, or solicitation for employment; Treatment during employment; Rates of pay or other forms of compensation; Selection for training, including apprenticeship; Layoff or Termination. All complaints which allege discrimination because of race, color, religion, sex, physical impairment, or national origin are to be brought to the attention of Mr. Bill Sundeen, President, immediately. AMERICAN DND shall ensure and maintain a working environment free of harassment, intimidation, and coercion at all sites, and in all facilities at which the contractor's employees are assigned to work. AMERICAN DND is bound to live up to the provision of the Civil Rights Act of 1964, Executive Order 11246, as amended, and other laws or regulations relating to equal employment opportunity. Anyone who believes he or she has been discriminated against should report this fact promptly to Mr. Patrick Callahan, President. AMERICAN DND reiterates its POLICY of equal employment and advancement opportunity for all qualified individuals without distinction or discrimination because of race, creed, color, sex, religion, national origin, physical or mental handicap, or status as a veteran and that Affirmative Action will be taken in the implementation of this policy. It is the policy of this company to cooperate to the fullest extent with the applicable regulations of the Civil Rights Act and the Executive Orders on Equal Employment Opportunity. I have urged my managers and staff to assist in every way possible to ensure that our policy is demonstrated by affirmative action. I would hope that each and every employee will do his or her utmost to provide both the spirit and letter of the policy.

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