INJURY AND ILLNESS PREVENTION PROGRAM

Transcription

1 INJURY AND ILLNESS PREVENTION PROGRAM 2014 TrueBlue Inc. (rev. 12/19/2014) 1 IIPP

2 Injury and Illness Prevention Program Labor Ready/TrueBlue, Inc. Table of Contents TrueBlue Safety and Health Policy Statement INTRODUCTION Branch Office Safety Objectives Premise of Program Scope and Requirements of Program Applicability of the Program / Terms Used TRUEBLUE INFRASTRUCTURE and GENERAL RESPONSIBILITY Identification of Program Administrator Availability of Program Support Structures Health and Safety Teams REGULATORY COMPLIANCE Basic Duties of TrueBlue as Primary Employer Communication (A) From TrueBlue to Secondary Employer (B) From TrueBlue to Employees (C) From TrueBlue to Branch Staff Hazard Assessment by TrueBlue (A) Telephone Screening (B) On Site Assessment Hazard Correction Training and Instruction by TrueBlue (A) New Employee Safety Training (B) TrueBlue Field Employee Training (C) Management Training Accident/Injury Investigation Procedures Basic Duties of Secondary Employer Communication (A) To TrueBlue Temporary Workers (B) To TrueBlue Branch Staff Hazard Assessment by Secondary Employer Hazard Correction by Secondary Employer Training and Instruction by Secondary Employer Accident Investigation and Hazardous Substance Exposures Basic Duties of TrueBlue Temporary Workers Basic Duties of TrueBlue Field Employees RECORD KEEPING HAZARD COMMUNICATION PROGRAM / GHS Hazardous Material Inventory Safety Data Sheets (SDS) Labeling Training of Employees EMERGENCY PROCEDURES FOR TRUEBLUE OFFICE LOCATIONS INJURY and ILLNESS PREVENTION PROGRAM EVALUATION TrueBlue Inc. (rev. 12/19/2014) 2 IIPP

3 2014 TrueBlue Inc. (rev. 12/19/2014) 3 IIPP

4 1.0 INTRODUCTION 1.1 Branch Safety Objectives In accordance with Section 5(a)(1) of the Occupational Safety and Health Act of 1970 and other specific state agency standards, we want to ensure a safe workplace for our employees. The purpose of this Injury & Illness Prevention Program (IIPP) will be to provide a guide to TrueBlue staff, field employees, and temporary workers to aid in compliance with these adopted, and in some states, legally required, company standards. 1.2 Premise of Program The program is designed to comply with all applicable Federal and State standards as well as company rules regarding written safety programs. 1.3 Scope and Requirements of the Program This program will address and include the following elements: 1. Responsibility 2. Regulatory compliance 3. Communication 4. Hazard assessment 5. Accident/incident investigation 6. Hazard correction 7. Training and instruction 8. Record keeping 9. Program evaluation All TrueBlue Branch offices must utilize this program and adopt it as the standard IIPP for their operations. 1.4 Applicability of the Program / Terms Used The following terms and definitions will be used for the purpose of applicability of the program: Primary Employer: This term will apply to TrueBlue as being the employer that provides temporary workers to a customer, or secondary employer. Secondary Employer: This term will apply to the customer of TrueBlue that controls the workplace where the temporary workers will be assigned. Temporary Workers: This term will be used to identify those employees of TrueBlue that work under the care, custody, and control of the secondary employer. TrueBlue Field Employees: This term and the term branch staff will be used to identify employees of TrueBlue that work in the branch office (i.e. customer service representatives or CSRs ). Agent of TrueBlue: This term will apply to any outside person or company authorized by TrueBlue to represent TrueBlue s interests TrueBlue Inc. (rev. 12/19/2014) 4 IIPP

5 2.0 TRUEBLUE INFRASTRUCTURE AND GENERAL RESPONSIBILITY As the primary employer, TrueBlue will assume the following general responsibilities of IIPP administration: 2.1 Identification of Program Administrator TrueBlue Branch/Operations/Market Managers will be the administrators of this program. Employees with concerns relating to health and safety will be directed initially to communicate these concerns to the manager. The name of the manager will be posted in a conspicuous location in the branch office. (Perceived problems may also be reported anonymously, as described in Section 3.3). The manager is responsible for the implementation of this program at the individual branch, along with the support of the branch staff members. 2.2 Availability of Program A copy of this program will be maintained in the branch office and will be made available to temporary workers or regulatory personnel upon request. Branch staff will be made aware of the location of the program in the office and will be required to read this document so that they understand their roles and responsibilities. 2.3 Support Structures A support structure for branch staff and management in issues of health and safety is established and consists of: 1. Field Safety Specialists Responsible for providing support and safety-related coaching to branch, district, and area staff through on-site branch visits, and telephone and electronic support. 2. District/Market/Area Managers Responsible for supporting the message and coaching on behalf of the field safety specialist to branch staff. 3. Vice Presidents Responsible for supporting the message and coaching on behalf of the field safety specialist to branch staff and district/market/area managers. 4. Area Claims Coordinators/Managers Responsible for supporting branches through the management of injury/illness claims for workers and employees. This structure will provide assistance and direction as required relating to program administration and specialized health and safety issues. A list of telephone numbers for these persons/departments will be maintained in the branch office. Standard form Emergency Telephone Numbers (Appendix 3) will be used for this purpose. Washington State Addendum (12/7/09) Branches will be audited semi-annually by the area field safety specialist or district manager to ensure compliance with the IIPP and best practices. Specifically this audit will address the following: Branch safety team is meeting and compliance checklist is completed monthly The job order form is completed, documenting the critical information Workers receive job specific training (reminders) at the time of dispatch Job site evaluations are routinely performed on new and high volume customers Job site evaluations are completed and documented for every high hazard job If deficiencies are found, corrective action will be taken TrueBlue Inc. (rev. 12/19/2014) 5 IIPP

6 2.4 Health and Safety Teams Branch Teams will meet monthly. All team meetings will be documented and will include: 1. Review of employee concerns about health and safety issues; 2. Review of health and safety citations issued since last meeting; 3. Review of accidents, injuries, and illnesses since last meeting; 4. Status of remedial actions taken since last meeting concerning health and safety issues; and 5. Reminders of operational-safety issues (i.e., taking complete job orders, giving complete dispatches, interviewing workers during payout, etc.). Documentation of these meetings shall be done in accordance with Section 4.0 of this IIPP. The branch manager will ensure that meetings are documented and that the documentation is retained in the files. 3.0 REGULATORY COMPLIANCE TrueBlue provides temporary workers to a secondary employer work site that is under the control and supervision of that secondary employer. 3.1 Basic Duties of TrueBlue as Primary Employer TrueBlue branch offices, as the primary employer, will take steps to ensure and document that our temporary workers: 1. Are covered by an effective IIPP. In states where such programs are not required of our customers by law or regulation, this IIPP will serve as the TrueBlue program for our employees at our branches and temporary workers at customer job sites. 2. Receive all required general and site/task specific training. General training is to be provided by TrueBlue while site/task specific training is to be provided by the secondary employer prior to the start of the job. Workers will be informed to expect this additional training at the time of dispatch. 3. Are provided with necessary personal protective equipment (PPE) as follows: a. As necessary, TrueBlue will provide general PPE consisting of hard hats, safety glasses, hard-toed shoes, and leader or rubber gripped gloves, and training in their prior to the start of the work. b. The secondary employer will provide site/task specific PPE, along with the required training in the use of the PPE prior to the start of the work. c. In special circumstances, TrueBlue may agree to work with the secondary employer toward providing specialized PPE and PPE related training. Such situations will require advanced written approval from the field safety specialist and/or Corporate Risk Management Department Communication Effective communication of responsibilities concerning health and safety are critical to the success of this program. Communication that flows among TrueBlue field employees, TrueBlue temporary workers, and secondary employers is the foundation of a safe and healthy workplace. Communication materials including training materials are available to TrueBlue field employees and temporary workers. These materials will be developed with appropriate multi-lingual considerations in mind to assure that TrueBlue field employees and temporary workers receive the proper instruction and direction required to perform their work safely TrueBlue Inc. (rev. 12/19/2014) 6 IIPP

7 3.1.1(A) Communication from TrueBlue to Customer (Secondary Employer) TrueBlue will acquire the following information from secondary employers in order to ensure that health and safety roles and responsibilities are clearly defined: a. Verification of whether the employer has an IIPP in states where these programs are required. The program may be known by other names such as accident prevention program, or safety and health program. b. Verification that the employer will provide necessary site/task specific training to TrueBlue temporary workers at the site prior to the start of work. c. Verification that required site/task specific PPE will be provided by the secondary employer, along with the associated training pertaining to the PPE prior to the start of the work. TrueBlue transfers to the secondary employer the care, custody, and control of the TrueBlue temporary workers at the customer s work site, and TrueBlue exercises no control or supervision of the customer s work site. This transfer of responsibility regarding site specific training and PPE shall be documented by a statement on the work ticket signed by agent of the secondary employer, and/or by completion of the telephonic screening and Job Order Sheet (Appendix 1), as discussed in Section 3.1.2(A) of this IIPP. TrueBlue s standard work ticket terms and condition also make clear this transfer of responsibilities to our customers (B) Communication from TrueBlue to All Employees All employees must receive basic safety training as a part of their new employee orientation prior to dispatch to their first assignment. Training will include an overview of this IIPP and at least the following topics: Hazard Communication Personal Protective Equipment Fall Hazard Protection Hazardous Energy Control (Lockout) Emergency Response Chemical Hazard Protection Accident/Injury Reporting Procedures Asbestos Awareness Lead (Pb) Awareness Electrical Safety Machine Guarding Ladders Trenching/Excavation Materials Handling OSHA Right to Know Confined Space Entry Silica Awareness Heat Stress/Illness The presentation of these topics will be general in nature only due to the diversity of work performed by TrueBlue workers. The secondary employer will cover site/task specific issues. During dispatch of workers to a secondary employer s worksite, workers will be informed of the following information: The assigned job Hazards associated with the job; Methods of protecting against those hazards; What to do if the workers are told to do something significantly 2014 TrueBlue Inc. (rev. 12/19/2014) 7 IIPP

8 different than what is being explained to them at dispatch; and Safety reminders unique to the assigned job (back injury prevention, tool safety, etc.) In addition, if TrueBlue is properly made aware by the customer or by reports from TrueBlue temporary workers at the site of new equipment, procedures, or job requirements that constitute potential hazards at a customer s work site, the temporary workers will be informed before dispatch to the work site to request and require from the customer site specific training concerning these hazards before starting their work assignments. Temporary workers will be made aware prior to dispatch that they are to receive site specific training from the customer prior to commencement of work. Employees will be made aware that it is not the intention of TrueBlue to expose them to unsafe work practices or conditions. Employees will be instructed to contact the program administrator (i.e., the branch/operations/market manager) if they feel their health and safety is threatened due to a workplace condition, practice, or lack of proper training. If their concerns are not resolved, they may anonymously contact TrueBlue Corporate at This number will be posted at all branch locations (C ) Communication from Corporate/Management Support Departments to Branch Staff Information will be posted as required in all branch offices. These postings will include such information as state workers compensation and equal employment opportunity information. The procedures outlined in the TrueBlue Operations Manual will be the guideline for these postings. Other postings may be added at TrueBlue management discretion such as: 1. Intra-company correspondence of incident/injury information ( s, mailings, paycheck stuffers, etc.) 2. Employee safety suggestions 3. Safety/Accident Prevention Posters 4. Safety Tips of the Day (STOTD) Hazard Assessment by TrueBlue TrueBlue will take appropriate and reasonable steps to ensure that temporary workers are provided with a safe workplace. These steps will include the following: (A) Initial Telephone Screening (Job Order Process) Prior to commencement of work on any job, branch staff will complete with the secondary employer a telephonic screening assessment of the potential hazards related to the job. This screening will include at least the following elements: 1. Name of secondary employer and their agent requesting temporary workers. 2. Nature of business (construction, excavating, etc.). 3. Nature of work to be performed (for workers compensation coding and matching of employees to job duties) TrueBlue Inc. (rev. 12/19/2014) 8 IIPP

9 4. Does the secondary employer have a written safety program (such as an IIPP), and will TrueBlue temporary workers at the customer s site be covered by this program? 5. What special qualifications, certifications, PPE, and training are necessary for TrueBlue temporary workers to safely perform work at the customer s site? 6. Does the secondary employer agree to provide necessary site/task specific training to TrueBlue temporary workers prior to the start of the work? 7. Will the secondary employer provide the required site/task specific PPE prior to the start of the work? 8. Name of TrueBlue field employee conducting telephonic survey. This telephonic screening will become part of the client file and will be retained in the branch office. The Job Order Sheet (Appendix 1) developed for this purpose will be utilized by all offices to conduct the telephonic screening. All sections of the Job Order Sheet must be completed and the job properly authorized before dispatch of employees to the site. Also refer to Explanations and Examples for the Job Order Sheet (Appendix 1A), which answers frequently asked questions about filling out the Job Order Sheet. Secondary employers must consent to perform the site/task specific training and provide the site/task specific PPE for the temporary workers, and the secondary employer must certify to TrueBlue that these requirements will be met prior to commencement of work at the site (B) On-site Assessment Every effort will be given to provide branch managers (and other branch staff, on a case-by-case basis) OSHA-10 training early-on in the tenure to provide a knowledge base for completing job site evaluations. Field safety specialists will be available for on-site assistance of job site evaluations, or will be available via telephone as a resource. If the telephone screening conducted in accordance with Section 3.1.2(A) above reveals that TrueBlue temporary workers will or may be exposed to any of the following hazards, then in addition to the telephonic screening procedures of Section 3.2.1(A), the jobs will be considered to be potentially high hazard and will require an on-site inspection by a field employee or agent of TrueBlue prior to commencement of work: 1. Work in elevated areas or on platforms more than six (6) feet in height (e.g., roofs, scaffolds, residential/commercial framing, ladders, etc.). 2. Trench work/excavation greater than four (4) feet in depth. 3. Confined space entry or associated duties. 4. Moving machinery (mobile equipment, assembly lines, conveyors, etc.) 5. Machines with moving parts that can cause serious injury (punch presses, cranes, drills, etc.) 6. Dispatch of twenty TrueBlue temporary workers to one (1) site at the same time TrueBlue Inc. (rev. 12/19/2014) 9 IIPP

10 7. Special PPE requirements (i.e., fall harnesses, chemical suites, etc.). 8. Special qualifications or certifications required to perform the work. Asbestos abatement or exposure to friable asbestos is covered in the Asbestos Awareness Policy in the Health and Safety Manual. Any job dealing with asbestos related hazards must be approved by the Corporate Risk Management Department prior to dispatch. Ideally, all job sites should be evaluated on a regular basis to ensure the safety of TrueBlue temporary workers (for example on the first day, after the first week, and monthly thereafter). Branch staff should prioritize non-high hazard jobs based on the probability and potential severity of injuries associated with the individual job assignments. TrueBlue personnel must document these on-site inspections on the Job Site Evaluation Report (Appendix 2) and retain the documentation in the branch files. Also refer to Explanations and Examples for the Job Site Evaluation Report (Appendix 2A), which provides explanations and examples to assist in filling out this report. In addition, the branch manager will be required to approve all high hazard jobs and certify, by that approval, that all actions required by our IIPP have been met. On-site customer inspections will include at least the following: 1. Verification that the secondary employer has a written safety program, if applicable. 2. A visit to work area to observe working conditions and clarify what training will be provided, as well as availability and use of required PPE. 3. Temporary workers dispatched to the site will be informed of the site specific training that is required prior to the start of work and will be instructed to immediately notify the branch manager of any hazards encountered resulting from working conditions or lack of training. Authorized agents of TrueBlue shall visit the site periodically as needed to update the Job Site Evaluation Report (Appendix 2) Hazard Correction If TrueBlue branch staff is made aware of any health and/or safety hazard in a workplace to which our field employees or temporary workers are exposed, immediate action shall be taken to work with the secondary employer toward abatement of the hazard. The secondary employer is in control of the worksite, and TrueBlue understands and respects this position. Therefore, abatement of workplace hazards will be the responsibility of the secondary employer. But, TrueBlue will not knowingly allow its field employees or temporary workers to be exposed to the hazards. In cases of imminent danger situations where TrueBlue temporary workers face a reasonable probability of serious injury or death, TrueBlue will inform its temporary workers and prohibit them from performing work in the affected area of the secondary employer s site. If a field employee or temporary worker observes and reports an unsafe condition or practice, or a site visit reveals a condition and the observer is uncertain concerning the safety impacts or compliance issues, the field 2014 TrueBlue Inc. (rev. 12/19/2014) 10 IIPP

11 safety specialist, district/market/area manager, or Corporate Risk Management Department should be notified to clarify the situation as quickly as practical. TrueBlue policy requires that all field employees and temporary workers follow the safety rules and regulations that pertain to their job activity and this should be made clear to both secondary employers and employees Training and Instruction by TrueBlue It is vital to the success of this program that those involved in the daily administration of the program understand its provisions and how to apply them to the job. The foundation of a safe workplace is employees who know how to perform their job duties safely. With this in mind, TrueBlue will train and instruct temporary workers in general workplace safety and require that secondary employers give site/task- specific training to our temporary workers before they start to work. Upon adoption of this program, branch management and staff will be trained as to the contents and application of the program. Branch management and staff will also be trained when future revisions are to be implemented (A) Temporary Worker Safety Training As a part of the application process, temporary workers will be trained in general safety practices and will be required to pass an examination pertaining to this training. Any questions missed on the safety exam will be reviewed with the temporary worker and initialed by the temporary worker to document that the temporary worker was instructed as to that item. For the content of the current Temporary Worker Training refer to Section (B) of this program. Persons who have difficulty reading and/or understanding the English language will be provided with training materials in a language they understand. Materials in several languages that may be typically spoken by TrueBlue temporary workers have been developed for this purpose. Contact the Corporate Risk Management Department for assistance in these situations. In special circumstances, TrueBlue branch staff will present and review the training materials and associated examination in an oral format. The training record will indicate that the material was presented and reviewed with the temporary worker in an oral format. All required elements of this temporary worker training must be completed by branch staff and the temporary worker before dispatching any temporary worker to his or her first customer site (B) TrueBlue Field Employee Training All TrueBlue field employees must review the Temporary Worker Safety Training Manual and the Safety video (C) Management Training TrueBlue will periodically conduct training for management personnel at all levels including OSHA-10 level training for branch managers (and for other branch staff, on a case by case basis). This training will include training in risk management and other issues relating to employee health and safety. The content of these programs will be at the discretion of TrueBlue management and may vary according to geographic region, particular branch specific issues, or other constraints TrueBlue Inc. (rev. 12/19/2014) 11 IIPP

12 3.1.5 Accident/Incident Investigation Branch managers will be trained in accident investigation techniques semi-annually. Field safety specialists will be available to assist branch staff with the investigation or to provide telephone assistance when necessary. In the event of a workplace injury or illness, branch staff will complete the Accident/Injury Report (Appendix 8) and follow the established notification procedures. If the accident is of a nature that notification of regulatory agencies (OSHA, MSHA, etc.) is required, then immediately notify the district/market/area manager and field safety specialist for assistance in making required notifications. Although this responsibility lies with the secondary employer, it is important that the regulatory agencies be notified within the required time frame when serious injuries or fatalities occur. Therefore, TrueBlue will ensure that such notifications are completed. Injuries and incidents that require medical treatment will be investigated. This will be initiated by means of completion of the Accident/Injury Report. The branch office must contact the secondary employer within 24 hours to complete the necessary forms and facilitate the injury/incident investigation. The investigation report should include the following: 1. A description of the incident/injury. 2. Location, date, and time of the incident/injury. 3. Cause/effect of the injury. 4. Recommendations for prevention of similar incidents, as applicable. Additional information is available from the field safety specialist. In every case of injury resulting in hospitalization and/or death of an employee, a site investigation will be performed immediately by a TrueBlue employee and/or an authorized agent of TrueBlue upon notification of the accident. OHSA, MSHA, and state health and safety agency reporting requirements differ. Consult the field safety specialist assigned to the area if there are any doubts as to what is reportable. The investigator at the scene will perform such functions as: 1. Ensuring that the scene is safe for the temporary workers and investigators. 2. Obtaining drawings and/or photographs of the scene. 3. Interviewing witnesses of the accident. 4. Obtaining copies of reports from police, fire department, or other investigating agencies. 5. Making notes of conditions, statements, and other information pertaining to the accident. The focus of the investigation is to find the cause of the injury and work with the secondary employer to correct any hazards that may still exist to temporary workers at the site. The object is to find out what happened and how to prevent reoccurrence of the incident. Concentrate on fixing the problem, not fixing the blame on someone. Make sure that the secondary employer is made aware of the fact that the injury is to be recorded on their OSHA 300 log in accordance with 29 CFR or other specific agency requirement TrueBlue Inc. (rev. 12/19/2014) 12 IIPP

13 3.2 Basic Duties of Secondary Employer (Customer) The secondary employer has the obligation to control and supervise the workplace. Care and custody of temporary workers is handed over to the secondary employer at the worksite Communication The secondary employer has a critical function in the communication process. During the pre-dispatch telephone screenings and/or on-site surveys conducted by TrueBlue, it is the responsibility of the secondary employer to fully and accurately inform TrueBlue field employees of specific work place hazards. Before TrueBlue temporary workers begin work at the job site, it is the responsibility of the secondary employer to conduct other site/task/special PPE specific training that is required for the TrueBlue temporary workers to perform their work safely. Secondary Employers will also be required to communicate with branch staff to ensure that all required training will be completed prior to commencement of work as agreed to on the Work Ticket and the Job Order Sheet. Secondary Employers must also inform branch staff as to whether or not they are covered by an IIPP or similar program. This communication may take the form of telephone conversations, , fax, or other media to assure the timely flow of required information. Personal interaction between the secondary employer and TrueBlue branch staff during site visits is another opportunity for effective safety and health communication (A) Communication to TrueBlue Temporary Workers The secondary employer must conduct at least the following communication with TrueBlue temporary workers performing work at the job site: 1. Site/Task specific hazard training prior to beginning the work. 2. Training relating to any site/task specific PPE requirements prior to beginning the work. 3. Identification of the site supervisor or other person who is responsible for health and safety at the site. 4. Site specific training relating to hazardous substances that may be encountered at the secondary employer s site. 5. Secondary employer s IIPP requirements if and as they apply to TrueBlue employees (B) Communication to TrueBlue Branch Staff It is the responsibility of the secondary employer to accurately communicate to TrueBlue branch staff the information required for proper hazard assessment (i.e. hazardous substances used at site, nature of work, PPE requirements, etc.) prior to commencement of work and, during the contract period, if conditions, procedures, practices, or other job elements change that create new hazards Hazard Assessment by the Secondary Employer (Customer) Periodic assessment of hazards at the work site should be conducted by the secondary employer in accordance with their site/company specific IIPP or similar program requirements TrueBlue Inc. (rev. 12/19/2014) 13 IIPP

14 3.2.3 Hazard Correction by the Secondary Employer (Customer) Generally, the provisions of the secondary employer s site/company specific IIPP will define this responsibility. TrueBlue temporary workers must not be permitted to work in areas where to do so would place them in imminent danger of death or serious injury. The secondary employer controls and supervises the worksite; therefore, it is their responsibility to correct hazards and to assure safe and healthy conditions for TrueBlue temporary workers Training and Instruction by the Secondary Employer (Customer) Training as outlined in Section 3.2.1(A) will be conducted by the secondary employer. This training will be site/task specific and should include a section on what to do in case of emergency (location of telephones, emergency phone numbers, location of first aid supplies and identity of persons trained in first aid, etc.) This training is to be site/task specific, as described in the Job Order Sheet, based on the information provided to TrueBlue by our customer. If an employee needs additional information pertaining to the EAP or their respective duties they should contact their Site Supervisor or a TrueBlue staff member Accident Investigation and Hazardous Substance Exposures The secondary employer will follow its established procedures for accident investigation, as established in its site/company specific IIPP. TrueBlue temporary workers involved in accidents or exposures at the site are to report the incident to branch staff, which may conduct its own investigation at the branch and/or corporate level. 3.3 Basic Duties of TrueBlue Temporary Workers TrueBlue temporary workers are the front line of this IIPP. Temporary workers will be required to: Perform their work safely. Communicate unsafe conditions and practices to each other and to management. Report all workplace injuries, illnesses, near misses, and potentially unsafe conditions/situations. Use standard form Appendix 5 (Safety Concern) for written documentation of these matters. Intentionally misleading the branch by failure to disclose unsafe work practices or conditions at a customer s site, or failure to inform the branch of relocation to an undisclosed job site, or change in job duties may result in disciplinary action up to and including termination. For most instances where the worker did not intentionally mislead but failed to inform the branch of such acts or condition, progressive discipline will include: 1. Reassessment and training through the safety quiz/video and counseling; 2. Suspension from the branch (one week) and counseling 3.4 Basic Duties of TrueBlue Field Employees TrueBlue is the primary employer of the field employees and will require that these employees work in accordance with applicable company safety and health policies, as instructed during new field employee safety training. Failure to follow the established TrueBlue Health and Safety policies will result in disciplinary action up to and 2014 TrueBlue Inc. (rev. 12/19/2014) 14 IIPP

15 including termination of employment. TrueBlue will follow a disciplinary program, which can include: 1. Counseling and additional training for an initial violation of a safety rule; 2. Suspension without pay for up to five days, in addition to counseling and follow-up training, for subsequent violations; or 3. Termination of employment. There are circumstances under which employment is subject to immediate termination. TrueBlue retains discretion to utilize whatever form of discipline is deemed appropriate under the circumstances. TrueBlue s policy of disciplinary action in no way limits or alters the at-will employment relationship. This program for discipline applies to temporary workers as well as field employees. All disciplinary actions, including counseling and training, will be documented and the documentation will be retained in the personnel file. TrueBlue field employees and temporary workers are encouraged to make suggestions for the improvement of health and safety. The Report of Safety Concern (Appendix 5) will be the standard form for this communication. All employees will be instructed to contact the program administrator (i.e. branch manager) if they feel that their health and safety is threatened due to a workplace condition, practice, or lack of proper training. As mentioned previously, a toll free number for anonymous reporting of health and safety related problems will be provided. This number will be posted in the branch office. The number is RECORD KEEPING The following records will be retained in the branch files for three years: 1. Records of field employee and temporary worker safety training and completion of safety examinations. The records for active employees will be kept in the employee file. For inactive employees, these records should be kept for three (3) years after termination of employment. 2. Records of hazard assessments conducted by TrueBlue, either by telephone, onsite visit, or both. These records will include: a. Work Ticket / Time Sheet b. Job Order Sheet (Appendix 1) c. Employee Sign Out Sheets (Appendix 4) 3. Records of all site visits and any safety related activities associated with the visits including the Job Site Evaluation Report (Appendix 2). 4. Documentation of any follow-up or remedial actions to reports from field employees or temporary workers of unsafe work conditions or practices at the work site including the Report of Safety Concern (Appendix 5). 5. Documentation of Health and Safety Team Meetings (Appendix 6). 6. Records of employee injuries, illnesses, or exposure to hazardous substances, including OSHA 300 logs, will be retained in the branch files for five years. * All recordable injuries/illnesses must be recorded within 7 calendar days. * All OSHA 300 logs will be signed by the highest ranking company official at each facility. * All OSHA 300 A Summaries at each facility will be posted in a location visible to employees from February 1 st through April 30 th each year TrueBlue Inc. (rev. 12/19/2014) 15 IIPP

16 California State Addendum (6/19/14) SB 1360, Padilla. Compensation: rest or recovery periods As used in this addendum, recovery period means a cool down period afforded an employee to prevent heat illness. Branches shall comply with all federal, state and local wage and hour and safety rules set forth by the U.S. Department of Labor, State of California Department of Labor, Occupational Safety and Health Standards Board and the Division of Occupational Safety and Health. Branches will ensure temporary workers receive their off-duty state meal and rest periods and when applicable, cool down periods of not less than 5 minutes. If a branch fails to provide and/or make available to a temporary worker a meal, rest and/or recovery period in accordance with state law, including, but not limited to, an applicable statute or applicable regulation, standard, or order of the Industrial Welfare Commission, the Occupational Safety and Health Standards Board, or the Division of Occupational Safety and Health, the employer shall pay the employee one additional hour of pay at the employee s regular rate of compensation for each workday that the meal or rest or recovery period is not provided. The additional hour shall be counted as hours worked for which there shall be no deduction from wages and factored into premium pay. 5.0 HAZARD COMMUNICATION PROGRAM / GHS In accordance with 29 CFR or other specific state agency requirements, TrueBlue will communicate to all employees the potential hazards of substances used by all employees at the TrueBlue office or other area where TrueBlue retains care, custody, and control of employees. TrueBlue will provide specific Hazard Communication training only to employees in situations where TrueBlue exercises care, custody, and control of the employee. These situations may include cleaning or maintenance duties in the branch office or maintenance of branch equipment. TrueBlue will provide general hazard communication training to all employees as discussed in Section 5.4. As discussed throughout the IIPP, the secondary employer will be responsible for site specific Hazard Communication at the work site and will also be responsible to provide site/task specific PPE. 5.1 Hazardous Materials Inventory TrueBlue branch staff will inventory all substances used at the branch office or in TrueBlue vehicles and will make a list of these substances. The list will be checked against the following criteria to determine if they are potentially hazardous. Are any of the materials on the list: 1. Toxic (i.e. chlorine bleach) 2. Flammable Liquids (flash point < degrees F.) (i.e. gasoline) 3. Explosive 4. Reactive (materials that become a hazard or become more hazardous when they are mixed with other materials i.e. chlorine bleach and ammonia) 5. Corrosive (i.e. battery acid, industrial lye, some drain cleaners, etc.) The product labels will be utilized to make these determinations. Most products also provide toll free telephone numbers and/or Internet web sites to assist in making the determination of potential hazards. Refer any questions to the local field safety specialist TrueBlue Inc. (rev. 12/19/2014) 16 IIPP

17 5.2 Safety Data Sheets (SDS) SDS will be maintained in the branch office and will be made available to any and all employees that are required to use hazardous substances in the course of their work under the care, custody, and control of TrueBlue. Whenever a new SDS is received, it shall be retained in the branch office and employees will be trained on a timely basis, not to exceed 30 days, if the new material or requirements in the SDS pose an increased risk to the employee. 5.3 Labeling Hazardous substances should be stored in their original containers with the original label intact. If secondary storage containers are used, they must be labeled in such a way that any user of the material will be able to determine the following: 1. Product name 2. Signal word 3. Physical, health, environmental hazards 4. Precautionary statements & pictograms 5. Product identifier 6. Supplier identification 7. Supplemental information (if available) 5.4 General Training of Employees All TrueBlue employees will receive at least the following training concerning hazardous substance exposure: 1. The rights of employees to know what they are working with and the potential hazards of the substances. 2. The location of the SDS in the branch office. 3. Methods of detection of the substances used (odor, color, etc.). 4. The employee shall be informed that their physician may also receive information concerning substances to which they may be exposed. There will be no termination of employment or discrimination toward employees who exercise their rights of employment or discrimination toward employees who exercise their rights under the Hazardous Substance Information and Training Act or any other state or Federal health and safety right to know standard. 5. The employee shall be given appropriate PPE for protection against the hazardous substance and will be given task specific training concerning the use of the PPE. 6.1 EMERGENCY PROCEDURES FOR TRUEBLUE OFFICE LOCATIONS TrueBlue branches will establish procedures for guidance in the event of an emergency. These procedures will be as follows: 1. All building exits will be clearly marked and maintained in a passable condition when the building is occupied. a. Pathways to exits shall not be used for storage of supplies or records and are to be kept free of debris at all times. 2. Building evacuation plans will be posted in conspicuous locations. a. An evacuation plan shall be drawn up showing the basic layout of the branch including all walls, doors and restrooms. b. Evacuation plan will clearly identify the closest exit from any point in the branch. c. Evacuation plan will clearly identify an assembly area outside of the building where occupants are to meet at the time of an emergency so that all occupants are accounted for. 3. Branch staff will know the location of emergency supplies such as first aid kits, fire 2014 TrueBlue Inc. (rev. 12/19/2014) 17 IIPP

18 extinguishers, etc. a. Access to fire extinguishers and first aid kits shall be kept clear at all times. b. Fire extinguishers shall be properly mounted with proper signage to indicate fire extinguisher location. 4. Emergency telephone numbers will be posted in a conspicuous location near the telephone(s) for rapid notification of Police, Fire Department, Ambulance, or other emergency response personnel. a. Emergency Telephone Numbers (Appendix 3) may be used for this posting. b. Branch staff is responsible for ensuring that this information is kept up to date. 5. Training on this plan shall be conducted semi-annually by each branch. a. Training shall be conducted during a regularly scheduled monthly branch safety meeting. i. New employees of the branch shall be trained on this plan at the time of hire. ii. Additional training shall be conducted if there are any modifications to the building that impact this plan. iii. All training on this plan shall be documented. 1. Documentation shall be kept with the monthly branch safety meeting report. b. Evacuation plan drill i. During the semi-annual training on this plan, all branch staff members will participate in a drill based on this plan. 1. Sound the alarm The person that spots the emergency shall sound a verbal alarm within the branch telling all occupants that there is an emergency and that the building is to be evacuated. 2. Exit the building All occupants shall evacuate the building and gather in the pre-designated location in the parking lot. 3. Account for all occupants The most senior staff member shall determine if all persons have evacuated the building are at the pre-determined location in the parking lot. 4. Report to first responders the most senior staff member shall report to the first responders (fire department or police) that: a. All occupants are out of the building, or; b. There are occupants unaccounted for and possibly in the building. 6. All training will be documented in the branch monthly safety meeting notes and kept in the file with each monthly safety meeting notes. 7.1 INJURY AND ILLNESS PREVENTION PROGRAM EVALUATION Changes in conditions, practices, procedures, and regulations are occurring constantly. TrueBlue understands that this IIPP may need to be revised periodically for a variety of reasons, including improvements in current safety technology, changes in injury/accident trends, or changes in regulatory requirements. At intervals not to exceed 12 months, TrueBlue will re-evaluate the current Injury and Illness Prevention Program for effectiveness and will revise the program as it is deemed necessary to improve its effectiveness. Review criteria will include one or more of the following: 1. Review of TrueBlue accident/injury data TrueBlue Inc. (rev. 12/19/2014) 18 IIPP

19 2. Review of current safety and information technology and application of these technologies to TrueBlue. 3. Temporary worker and branch staff safety concerns. 4. Audit reports from internal audits. 5. Audit reports from external audits and inspections (including OSHA inspections). 6. Review of current regulations and changes in the regulations since the last program review. When changes are made to this Injury and Illness Prevention Program, TrueBlue employees affected by the changes will be made aware of the changes. Any training of TrueBlue employees required by the changes will be conducted in a timely manner. The effective date of this program will be April 1, 2000, and it shall remain in effect until specifically rescinded by the True Blue, Inc, Corporate Office in Tacoma, Washington TrueBlue Inc. (rev. 12/19/2014) 19 IIPP