ArcelorMittal Dofasco Inc. Third Party Health, Safety and Environment Program

Transcription

1 ArcelorMittal Dofasco Inc. Third Party Health, Safety and Environment Program Copyright by ArcelorMittal Dofasco Inc., 2013 All Rights Reserved Questions or Comments Contact the Manager of ArcelorMittal Dofasco's Health and Safety Department at (905) X2095 or fax at (905) , should you have any questions or comments related to the content of this Program or the Third Party Contractor Employee Handbook or Outside Carrier and Supply Companies Handbook.

2 TABLE OF CONTENTS PURPOSE AND SCOPE... 3 GENERAL INFORMATION... 3 ArcelorMittal Dofasco s Third Party Health, Safety & Environment Program Elements Health and Safety Policy Preventing Workplace Violence & Harassment Policy Environment Policy Compliance Process Third Party Employer Requirements Commitment and Registration Third Party Employee Orientation Safe Work Permit Meeting & Site Specific Information... 8 Project Kick-off Meeting... 8 Safe Work Permit Meeting... 8 Site Specific Documentation Project Site Documentation and Record Keeping Audit for Compliance Third Party Community of Practice THIRD PARTY HEALTH, SAFETY AND ENVIRONMENT PROGRAM IMPLEMENTATION 1. Workplace Inspections Pre-Task Health & Safety Plan and HIRA Accident Investigation and Reporting Accident Response Accident Investigation Accident Review Critical Injury Lost Time Injury or Medical Aid Injury Reporting Performance Definition of Terms Layered Compliance Audits THIRD PARTY EMPLOYER S HEALTH AND SAFETY PROGRAM EXPECTATIONS OF ALL THIRD PARTY EMPLOYERS AND/OR EMPLOYEES HS Copyright by ArcelorMittal Dofasco Inc., 2013 All Rights Reserved Page 1 of 19

3 ROLES AND RESPONSIBILITIES ArcelorMittal Dofasco Duties and Responsibilities Owner Constructor Specific Assignment Supplemental Labour Third Party (Contractor) Duties and Responsibilities Specific Assignment Supplemental Labour Health & Safety Representatives / Committee Sub-Contractor Duties and Responsibilities Third Party Employee Duties and Responsibilities RULES ArcelorMittal Dofasco Major Safety Rules ArcelorMittal Corporate Golden Rules DISCIPLINARY ACTION RESERVATION OF RIGHTS REVISION HISTORY APPENDIXES: APPENDIX 1 Notification of Injury to Third Party Employee While Working On-Site at ArcelorMittal Dofasco Inc. APPENDIX 2 Pre-Task Health & Safety Plan APPENDIX 3 Third Party Layered Compliance Audit APPENDIX 4 User Guide for Document Completion and Submission HS Copyright by ArcelorMittal Dofasco Inc., 2013 All Rights Reserved Page 2 of 19

4 PURPOSE AND SCOPE ArcelorMittal Dofasco has developed this program for use by all Third Party companies who perform work or provide services on ArcelorMittal Dofasco premises. Third Parties include all on-site service providers, construction contractors, outside carriers and supply companies, and all subcontractors. ArcelorMittal Dofasco is committed to the health and safety of all of our people, and expects the same commitment by each Third Party (contractor) to its own people. For the remainder of this document the ArcelorMittal Dofasco Third Party Health, Safety and Environment Program will be referred to as the program. The Third Party Contractor or Outside Carrier and Supply Companies Employee Handbook(s) may also be referred to as the handbooks. GENERAL INFORMATION Reference to a Third Party in this document means the company of a contractor and the companies of their subcontractors, consultants, vendors, and suppliers, and carriers. Reference to Third Party management means people responsible for managing, supervising, or directing contract activities and employees. Reference to an employee or Third Party employee means the contractor s employees, and employees of subcontractors, consultants, vendors and suppliers. Non-compliance with health, safety, or environmental requirements is treated the same as non-compliance with any contract provision, and may result in work interruptions, work stoppages, or employee removal from the premises. Willful or repeated non-compliance may result in Third Party dismissal and contract termination. This program is an important part of ArcelorMittal Dofasco s Health and Safety and Environment Management Systems. Third Party employers must ensure that their employees, sub-contractors, consultants, vendors, suppliers, and visitors comply with the provisions of this program while on ArcelorMittal Dofasco premises. Compliance with federal, provincial and municipal codes or regulations established in the interest of health and safety is required by law and by contract. The program is a supplementary document to governmental rules, codes and regulations having jurisdiction and does not negate, abrogate, or minimize any provisions of these rules, codes, and regulations. It is intended to supplement and enforce the individual program of the Third Party and to coordinate the overall health and safety effort. Third Party employers are responsible for the health and safety of their employees, subcontractors, consultants, vendors, suppliers, and visitors while on ArcelorMittal Dofasco property. Health and safety will not be sacrificed for production. Health and safety is considered an integral part of quality control, cost reduction, and job efficiency. Managers and supervisors are accountable for the health and safety performance demonstrated by their employees. ArcelorMittal Dofasco s Third Party Health, Safety and Environment Program Elements 1. ArcelorMittal Dofasco s Health and Safety Policy 2. ArcelorMittal Dofasco s Preventing Workplace Violence & Harassment Policy 3. ArcelorMittal Dofasco s Environment Policy 4. Compliance Process 5. Third Party Employer Requirements 6. Commitment and Registration 7. Third Party Employee Orientation 8. Safe Work Permit Meeting and Site Specific Information 9. Project Site Documentation and Records 10. Audits for Compliance 11. Third Party Community of Practice HS Copyright by ArcelorMittal Dofasco Inc., 2013 All Rights Reserved Page 3 of 19

5 1. Health and Safety Policy HS Copyright by ArcelorMittal Dofasco Inc., 2013 All Rights Reserved Page 4 of 19

6 2. ArcelorMittal Dofasco s Preventing Workplace Violence & Harassment Policy HS Copyright by ArcelorMittal Dofasco Inc., 2013 All Rights Reserved Page 5 of 19

7 3. Environmental Policy HS Copyright by ArcelorMittal Dofasco Inc., 2013 All Rights Reserved Page 6 of 19

8 4. Compliance Process All new Third Party employers must complete the ArcelorMittal Dofasco Third Party Health and Safety Compliance Process and provide all information and documentation as outlined on the form(s) which includes the following: Workplace Safety and Insurance Board (WSIB) Account Number and Firm Number. At all times while providing services on ArcelorMittal Dofasco premises the Third Party is required to maintain in good standing any required Workplace Safety and Insurance Board coverage Proof of Liability insurance as specified by ArcelorMittal Dofasco WSIB CAD-7 experience rating and/ or NEER experience rating Proof of C-TPAT membership and SVI number for all Carrier Companies delivering to the United States ArcelorMittal Dofasco will determine, based on risk of work to be performed, whether a Health and Safety Qualification Audit is also required. If a Health and Safety Qualification Audit is deemed necessary, the Third Party is required to complete the Health and Safety Qualification Audit form and submit a copy of the Third Party s Health and Safety Policy and supporting Health and Safety Program. A site audit of the Third Party for validation may also be performed by an ArcelorMittal Dofasco representative(s). Third parties that are approved to work at ArcelorMittal Dofasco may be subject to a Health and Safety Qualification Audit at the discretion of an ArcelorMittal Dofasco representative at any time. The following circumstances are examples that may warrant a Health and Safety Qualification Audit be performed:» Numerous Accidents (with or without injury) within 1 year» Concerns or Complaints from ArcelorMittal Dofasco Project Managers/Representative» Non reporting of accidents Based on the results of the Health and Safety Qualification Audit, a Third Party may be removed from the approved list at the discretion of an ArcelorMittal Dofasco representative. 5. Third Party Employer Requirements After a potential Third Party Employer has been qualified, ArcelorMittal Dofasco will provide the Third Party Health, Safety and Environment Program and applicable employee handbooks. Not all information in this program or the handbook(s) applies to all third parties. Third Party employers must review the program and the applicable handbook(s) and understand the applicable sections based on the work or service that they will be providing to ArcelorMittal Dofasco. 6. Commitment and Registration Once the potential Third Party employer has reviewed the ArcelorMittal Dofasco Health, Safety and Environment Program they will be requested to complete two (2) copies of the ArcelorMittal Dofasco Third Party Health and Safety Program Commitment Agreement. This Commitment Agreement must be signed and dated by a representative of the Third Party who has the authority to commit the Third Party company to compliance with the ArcelorMittal Dofasco Third Party Health, Safety and Environment Program. One copy is to be returned to the ArcelorMittal Dofasco Purchasing Department and one copy is to be retained by the Third Party. The commitment agreement must be resubmitted if the name of the company has changed or the Third Party signing representative has changed or no longer has the authority to commit the Third Party company to compliance with the ArcelorMittal Dofasco Third Party Health, Safety and Environment Program. HS Copyright by ArcelorMittal Dofasco Inc., 2013 All Rights Reserved Page 7 of 19

9 7. Third Party Employee Orientation Before work is performed at ArcelorMittal Dofasco, the Third Party must review the ArcelorMittal Dofasco Health, Safety and Environment Program with all employees who will be performing work on ArcelorMittal Dofasco properties. In addition to ArcelorMittal Dofasco Health, Safety and Environment Program, companies must also review the Third Party Contractor or Outside Carrier and Supply Companies Employee Handbook(s) as applicable with all employees entering ArcelorMittal Dofasco properties. The ArcelorMittal Dofasco Health, Safety and Environment Program and the Third Party Contractor and Outside Carrier and Supply Companies Employee Handbook(s) are all located on ArcelorMittal Dofasco s website ( under Sustainable Development/Health & Safety ). The Third Party employer is responsible to print out and review the content of the program and the handbooks with each Third Party employee working at ArcelorMittal Dofasco at least once a year. Third Party employees must sign the Third Party Employee Compliance Agreement (included at the end of the Third Party Contractor and Outside Carrier and Supply Companies Employee Handbook(s) to acknowledge the information has been reviewed. Third Party employers shall retain signatures for their records. The review of the ArcelorMittal Dofasco Health, Safety and Environment Program and the Third Party Contractor and Outside Carrier and Supply Companies Employee Handbook(s) is the responsibility of the Third Party employer and must be completed by competent persons. After reviewing the program and the applicable handbook(s), the Third Party employer will then issue the most current ArcelorMittal Dofasco Third Party Health and Safety Orientation sticker to the Third Party employee who will place the sticker on their hard hat. Third Party Health and Safety Orientation stickers can be obtained by contacting ArcelorMittal Dofasco s Purchasing Department at extension Third Party employees will not be allowed to work on site at ArcelorMittal Dofasco unless: (a) the Third Party employer has documented proof of employee orientation which includes, but not limited to, a copy of the Third Party Employee Compliance Agreement; and (b) employees have an orientation sticker on their hard hat. The ArcelorMittal Dofasco Health, Safety and Environment Program and the Third Party Contractor and Outside Carrier and Supply Companies Employee Handbook(s) will be updated on-line as changes are necessary, and third parties will be notified of the revision and the need to review the revised material with their employees. Training of Third Party employees by the Third Party employer is deemed to be acceptance by the Third Party and their employees of the revisions made to the manual. New hard hat stickers noting the year that the ArcelorMittal Dofasco Health, Safety and Environment Program revision will be issued for distribution to trained employees. Please note: Hard Hat Stickers are no longer issued on an annual basis. Stickers are only issued when there are significant changes to the ArcelorMittal Dofasco Health, Safety and Environment Program. Third Party Carrier Compliance System Transport Companies The Third Party Carrier Compliance System for Transport Companies was developed to ensure all employees driving for Third Party Transport Companies are trained in the requirements of ArcelorMittal Dofasco s Third Party Health, Safety, and Environment Program and Handbooks. The program requirements are broken into three main steps: 1) Qualifying / Registration Health & Safety Compliant Transport companies were provided with a user name and password. The company Administrative Assistant or designate enters the company information, driver names, address and driver s license numbers into the Third Party Compliance System. 2) Training - Drivers receive an with user name and password and are required to enter the site, confirm information and request to be associated with one or multiple companies (brokers) and proceed to the elearning module. Each driver is required to complete two (2) modules and a short test following each, to validate retention. HS Copyright by ArcelorMittal Dofasco Inc., 2013 All Rights Reserved Page 8 of 19

10 3) Validation - Following registration by company and driver into the Third Party Carrier Compliance System, each time a driver arrives for their designated appointment they will be required to swipe their driver s license at the new kiosks. Driver and company compliance is confirmed and driver will be required to answer three quick random site specific and or plant safety questions. The terminal then proceeds to the registration screen. Transport Companies are denied entrance to our site to pick up their load if: The transport company is not Health & Safety Compliant The driver is not registered in the Third Party Compliance System The driver has not completed the e-learning module and passed the knowledge test Transport companies registered with the Third Party Compliance System are not required to complete a Third Party Employee Commitment Agreement as the system includes a tracking mechanism for annual training completion. 8. Safe Work Permit Meeting and Site Specific Information Project Kick-Off Meeting A kick-off meeting may be held with the ArcelorMittal Dofasco Project Manager / Coordinator, Project team, and the Third Party Employer / Sub-Contractor to discuss the manner in which the project will be executed. This meeting will follow a pre-determined agenda. Safe Work Permit Meeting Prior to the start of any work at ArcelorMittal Dofasco, the Third Party and all Third Party sub-contractors must attend a Safe Work Permit Meeting to review the site specific hazards and requirements necessary to ensure the work will be done in a safe manner. The Third Party employer, supervisor or representative must have visited the site where the work will take place prior to attending the Safe Work Permit meeting. This information must be reviewed prior to starting the job with all Third Party employees who will be on- site. A Safe Work Permit Meeting Validation form must be signed by all Third Party employees on the job and returned to the ArcelorMittal Dofasco Coordinator to acknowledge they have read and understood the information in the Safe Work Permit. Where there is an established scope of work, location, conditions, and hazards within a specific Business Unit/Department, and they will not change during a twelve-month period, then an annual safe work permit meeting can be held. Where the scope of work defined on the safe work permit changes, (job specific or annual permits), the work must stop and the ArcelorMittal Dofasco Coordinator must be notified so that a new Safe Work Permit Meeting can be held. Third party employees are restricted from touching ArcelorMittal Dofasco equipment outside the defined scope of work, including equipment failure emergencies. Such events should be identified to the ArcelorMittal Dofasco contact. Site Specific Information Document As part of the Safe Work Permit Meeting, Third Party employers or their representative will be issued a Site Specific Document for the area in which they will be working. This document outlines all of the area specific rules, procedures, personal protective equipment requirements, confined space entry and gas hazard locations, isolation procedures, and area MERP procedures. The information contained in this document must be communicated to all Third Party employees who will be working in the area. HS Copyright by ArcelorMittal Dofasco Inc., 2013 All Rights Reserved Page 9 of 19

11 Note: Outside carriers, delivery, or pick-up personnel are generally not required to have a safe work permit and site specific meeting unless the scope of the service that they provide will go beyond the routine delivery / pickup of commodities at approved points within ArcelorMittal Dofasco. 9. Project Site Documentation and Record Keeping It is a requirement of the Ontario Occupational Health and Safety Act and the Regulations for Industrial Establishments, Construction Projects, and Mines and Mining Plants to have available or to post specific information directly at the project site. Depending upon the task, the responsibility to provide and/or post this document may reside with ArcelorMittal Dofasco or the Third Party Employer. Items to be posted or made available at the project site will be determined on a project-by-project basis. There are specific requirements for recordkeeping in various sections within this manual that must be kept on file for a period of two years. These records must reflect the appropriate training for the work that the Third Party will be performing. ArcelorMittal Dofasco also expects that all trades people possess all current and valid trade certificates deemed necessary by governing legislation and trade regulations for the nature of the work they are performing. A guide for Document Completion and Submission is included at the end of this document (see Appendix 4). 10. Audit for Compliance The ArcelorMittal Dofasco Third Party Health, Safety and Environment Program and the Third Party Contractor and Outside Carrier and Supply Companies Employee Handbook(s), outline specific information the Third Party needs to know before and be aware of during the performance of work at ArcelorMittal Dofasco in order to ensure compliance with our program. ArcelorMittal Dofasco personnel will conduct formal audits on a regular basis to assess the level of program compliance. The audit will be based upon the rules, responsibilities, and safe work practices contained in the ArcelorMittal Dofasco Third Party Health, Safety and Environment Program. 11. Third Party Community of Practice Third parties regularly working at ArcelorMittal Dofasco (>3,000 hours annually) are expected to participate in the Third Party Community of Practice group. The purpose of the group is to: Share safety information and experiences Share implementation or execution tips Discuss which practices work or don t work Discuss pros/cons of new programs or practices Point out hazardous practices or pitfalls Provide/receive expertise on safety related topics Participate in solving common safety related concerns Community of Practice meetings are held three times per year. Community of Practice group members will periodically be asked to participate in improvement activities above and beyond the requirements for all third parties (i.e. monthly performance reporting, layered compliance audits, health and safety improvement plans). ARCELORMITTAL DOFASCO S THIRD PARTY HEALTH, SAFETY & ENVIRONMENT PROGRAM IMPLEMENTATION HS Copyright by ArcelorMittal Dofasco Inc., 2013 All Rights Reserved Page 10 of 19

12 The following represents the minimum list of activities a Third Party must engage in to ensure the Health, Safety and Environment Program is effectively implemented: 1. Workplace Inspections Third Party employers are to conduct regularly scheduled inspections. The scope or duration of work may regulate the frequency of these inspections. Third Party employers must take immediate corrective action when a violation of job safety, health, fire, or environmental hazard is observed. Failure to correct a problem may result in work stoppage in the related area, and work will not be permitted to resume until the problem is corrected. Additionally, if a Third Party employer fails to correct the problem, ArcelorMittal Dofasco will take corrective action, and the cost will be the responsibility of the Third Party employer. A copy of the completed workplace inspection is to be forwarded to the on-site ArcelorMittal Dofasco representative. Note: Outside carriers, delivery, or pick-up personnel are not required to conduct workplace inspections unless the scope of the service that they provide will go beyond the routine delivery / pickup of commodities at approved points within ArcelorMittal Dofasco. 2. Pre-Task Health and Safety Plan and HIRA(Hazard Identification & Risk Assessment) The Third Party supervisor is responsible for identifying jobs or tasks assigned and any hazards associated with those jobs/tasks, including the working environment or processes, by completing a daily Pre-Task Health & Safety Plan. Once hazards have been identified, an assessment of risk associated with each of the hazards needs to be conducted and the necessary controls put in place to safeguard against the hazard. An additional assessment must be completed to determine if the risk has been mitigated by the addition of the controls put in place. The completed plan must be communicated to all Third Party employees involved in the work and signed by those employees to acknowledge their review and understanding of the Pre-Task Health & Safety Plan. Either the Pre-Task Health and Safety Plan & HIRA template provided by ArcelorMittal Dofasco (see Appendix 2) OR a third party employer s own form may be used if it fulfills the above requirements. The signed document must be retained until work is completed. If there is an accident during the shift, maintain the Pre-Task Health and Safety Plan as part of your accident investigation file. Note: Outside carriers, delivery, or pick-up personnel are generally not required to complete daily pre-task health and safety plans, unless the scope of the service that they provide will go beyond the routine delivery / pickup of commodities at approved points within ArcelorMittal Dofasco. 3. Accident Investigation and Reporting Third Party employers are required to: Have an effective accident reporting system in place which is understood and implemented by each Third Party employee and sub-contractor employee. Report all accidents (with and without injury) to the ArcelorMittal Dofasco representative as soon as practical. Provide suitable modified work for all employees who cannot perform their regular duties following an injury. Accident Response HS Copyright by ArcelorMittal Dofasco Inc., 2013 All Rights Reserved Page 11 of 19

13 1. If the accident results in a serious injury, contact ArcelorMittal Dofasco Medical Services (ambulance) at (905) , Ext immediately. Be prepared to supply your location (Gate # and Door #) and then position a person at this location to meet the Emergency Response team when they arrive to direct them to the specific location. 2. If the injury is not serious, the site supervisor should arrange transportation to the ArcelorMittal Dofasco Medical Services facility. 3. Notify the ArcelorMittal Dofasco representative as soon as practical. Accident Investigation In the event of an accident involving a Third Party employee, sub-contractor or agent, the Third Party employer will conduct an accident investigation as early as possible and practical. ArcelorMittal Dofasco personnel shall be involved in the accident investigation as appropriate where ArcelorMittal Dofasco employees, equipment or property is involved. A copy of ALL completed accident investigations (with and without injury) must be forwarded to Dofasco s Health and Safety Department within the reporting period of the event either by ([email protected]) or Fax ( ). Accident Review In addition to reporting the above mentioned accidents, the Third Party employer (senior management and site supervision) will also be required to perform a RCA (root cause analysis) investigation and be prepared to present the findings of the investigation to ArcelorMittal Dofasco Senior Management for the following types of accidents: Accidents (with or without injury) with major result or having the potential to be life threatening or to cause permanent disability or loss of function Accidents that result in a lost time injury (LTI) Accidents reported as a Critical Injury as defined in Ontario s Occupational Health & Safety Act Deliberate violation of a Major Safety Rule Critical Injury In the case of a critical injury, secure the scene of the accident and do not disturb, unless disturbance is necessary in order to eliminate danger to other persons. Notify the ArcelorMittal Dofasco representative immediately. Reporting of accidents and/or critical injuries to the Ministry of Labour must be coordinated by ArcelorMittal Dofasco s Health and Safety Department. Lost Time or Medical Aid Injury Within 48 hours of confirmation of a Medical Aid or Lost Time Injury accident, the Notification of Injury to Third Party Employee While Working On-Site at ArcelorMittal Dofasco Inc. form (see Appendix 1) must be sent with a copy of the accident investigation to ArcelorMittal Dofasco s Health & Safety Department either by ([email protected]) or Fax ( ). A copy of the accident investigation must also be provided to the ArcelorMittal Dofasco representative. Reporting Performance Each Third Party employer and sub-contractor will submit their daily Incident Summary Report to the ArcelorMittal Dofasco Project Manager / On Site Contracting Coordinator. This includes all accidents with or without injury on ArcelorMittal Dofasco sites. Companies that are part of the Third Party Community of Practice group are required to submit to Purchasing on a monthly basis: HS Copyright by ArcelorMittal Dofasco Inc., 2013 All Rights Reserved Page 12 of 19

14 Monthly total person hours worked by trade (separate hourly and supervision hours) Number of accidents without injury Number of First Aid Injuries Number of Medical Aid Injuries Number of Lost Time Injuries Days lost to date resulting from a Lost Time Injury Number of Restricted Workday Cases Number of days an individual is assigned to restricted work Report only the worse outcome of the injury (ie. First Aid or Medical Aid or Restricted Work or Lost Time). Definition of Terms Hours Worked Total hours of all contractor employees working on-site. This includes, but is not limited to trade labour, supervision, support, etc. Accident without Injury Total number of unplanned events, near misses and incidents in the month that did not result in a work related injury, but may have resulted in property damage. Accident with First Aid Injury - A work related injury that requires one-time treatment or care and any follow-up visit(s) for observation purposes only. First aid includes, but is not limited to cleaning minor cuts, scrapes, or scratches; treating a minor burn; applying bandages and/or dressings; applying a cold compress, cold pack, or ice bag; applying a splint; changing a bandage or a dressing after a follow-up observation visit. Accident with Medical Aid Injury - A work related injury requiring the professional skills of a Medical Aid practitioner (e.g., doctor, registered nurse, chiropractor, or physiotherapist); services provided at hospitals and health facilities (other than first aid); prescription drugs. Accident with Lost Time Injury - A work related injury which results in loss of at least one full work shift after the day of accident. NOTE: Person must have received medical aid treatment for the injury. Restricted Workday Case Total number of work related injuries in the month which resulted in the employee being assigned modified work (i.e. unable to perform pre-injury work). Restricted Work Days - Total number of workdays that an employee is performing modified work as a result of a work related injury. This includes restricted workdays from injuries that occurred in a previous month. Restricted workdays end when the employees can perform all of their pre-injury work tasks without restrictions. Restrictions and the ability to return to pre-injury tasks are to be determined by a physician. 4. Layered Compliance Audits Companies that are part of the Third Party Community of Practice group are required to conduct monthly on-site audits with the Third Party Site Supervisor and the ArcelorMIttal Dofasco Project Manager/Coordinator (if available). The goal of the audit is to observe behaviours of employees working on site and review work practices with them as well as reinforce or raise expectations for safe behaviours. A Layered Compliance Audit template is available at the end of this document (see Appendix 3). THIRD PARTY EMPLOYER S HEALTH AND SAFETY PROGRAM HS Copyright by ArcelorMittal Dofasco Inc., 2013 All Rights Reserved Page 13 of 19

15 Under the terms and conditions of the contract documents, Third Party employers are required to administer their own health and safety activities and are responsible for the health and safety of their employees. As requested by ArcelorMittal Dofasco, Third Party employers will submit a written copy or description of their company s health and safety program. The Third Party employer s health and safety program must at all times be compliant with federal, provincial and local regulatory requirements and be equivalent to or more stringent than ArcelorMittal Dofasco s program. Where the programs are in conflict or the Third Party employer s program does not address an issue, the ArcelorMittal Dofasco Health, Safety and Environment Program as defined in this program will govern. EXPECTATIONS OF ALL THIRD PARTY EMPLOYERS AND/OR EMPLOYEES Third parties employers and/or employees must: Comply with current federal and provincial health, safety and environmental legislation. This includes, but is not limited to, the Ontario Occupational Health and Safety Act and regulations for Industrial Establishments, Construction Projects, and Mines and Mining Plants, Highway Traffic Act etc. Cooperate with various governing authorities (e.g. Ministry of Labour, Ministry of Environment, Electrical Safety Authority, or TSSA) that have the authority to inspect or audit the job site or any part of an ArcelorMittal Dofasco location. Cooperation with government inspectors and immediate compliance with any directions or orders of these authorities is essential to limit the potential for downtime resulting from work stoppages, or the assessment of penalties. ArcelorMittal Dofasco protocol requires that an ArcelorMittal Dofasco representative accompany all government inspectors or representatives while on ArcelorMittal Dofasco property. As well, the ArcelorMittal Dofasco Project Coordinator must be immediately advised of any inspection / investigation by a governing authority on an ArcelorMittal Dofasco worksite and be copied on all reports. ROLES, DUTIES AND RESPONSIBILITIES ArcelorMittal Dofasco Duties and Responsibilities Owner For all types of work performed on ArcelorMittal Dofasco-owned property, ArcelorMittal Dofasco is always deemed the owner. As the owner, ArcelorMittal Dofasco is responsible to ensure that facilities are provided and maintained and that the workplace is in compliance under the law. Constructor If ArcelorMittal Dofasco chooses to perform any of the following activities involving third parties, ArcelorMittal Dofasco assumes the role of Constructor: Specify and hire multi-prime contractors Manage day-to-day work on the project Schedule work on the project Exercise cost control on the project Include any ArcelorMittal Dofasco employees to work on the project. As the Constructor, ArcelorMittal Dofasco is required to do the following: File Notice of Project with the Ministry of Labour (if required) HS Copyright by ArcelorMittal Dofasco Inc., 2013 All Rights Reserved Page 14 of 19

16 Ensure that the relevant sections of the ArcelorMittal Dofasco Health and Safety Program are identified and followed, and that employees are protected during the project Retain copies of relevant documents on-site Ensure that the Third Party establishes a joint health and safety committee when required. Specific Assignment Whether work is deemed Construction or Industrial, ArcelorMittal Dofasco may choose to contract the services of a Third Party for a specific assignment. If ArcelorMittal Dofasco contracts a Third Party for a specific assignment, the Third Party is responsible to provide direct supervision to their employees for the duration of the work. In such cases, ArcelorMittal Dofasco is responsible: To ensure that relevant sections of the ArcelorMittal Dofasco Health and Safety Program and the Third Party Contractor and Outside Carrier and Supply Companies Employee Handbook(s), are carried out for Third Party employees through Third Party supervisors, and To audit the performance of the Third Party. To fulfill these responsibilities, the following actions are required by the ArcelorMittal Dofasco Project Manager / Coordinator responsible for supervising the project work. Ensuring that the contract with the Third Party: Defines Third Party responsibilities Specifies that ArcelorMittal Dofasco has the right to stop work for health and safety violations, without any financial penalty, and expects the Third Party to take all actions necessary to correct any unsafe conditions or acts. Ensuring that the Third Party and its employees complete the requirements of the ArcelorMittal Dofasco Third Party Health, Safety and Environment Program Ensuring that the Third Party employees are properly trained in the use of ArcelorMittal Dofasco equipment, where required Ensuring that all ArcelorMittal Dofasco equipment used by the Third Party is in good condition, and that the required indemnification and release form is signed by the Third Party prior to use Ensuring that the required Safe Work Permit process is followed Conducting additional health and safety meetings with the Third Party where required Stopping and correct any unsafe work by Third Party employees and reporting immediately to the Third Party supervisor. Validate correction of any unsafe conditions. Providing the appropriate progressive discipline to the Third Party or through the Third Party to its employees for health and safety violations Maintaining a record of the performance for each Third Party and reviewing prior to any further contracting. The ArcelorMittal Dofasco Project Manager / Coordinator responsible for the supervision of the project work must fulfill the following responsibilities: Perform required workplace inspections (or assign to a designate) Document all inspections, stop-work activities and all safety-related meetings; Report any violations of Third Party obligations to the Business Unit Manager and to the Purchasing Department. ArcelorMittal Dofasco employees (including ArcelorMittal Dofasco supervisors) must not give work direction to Third Party employees when they are engaged in work identified as specific assignment (except to stop work because of health and safety concerns). Supplemental Labour Whether work is identified as Construction or Industrial, ArcelorMittal Dofasco may choose to contract the services of a Third Party as supplemental labour. If ArcelorMittal Dofasco contracts a Third Party as supplemental labour, HS Copyright by ArcelorMittal Dofasco Inc., 2013 All Rights Reserved Page 15 of 19

17 ArcelorMittal Dofasco is responsible to ensure that the requirements defined by the ArcelorMittal Dofasco Health, Safety and Environment Program and the Third Party Contractor and Outside Carrier and Supply Companies Employee Handbook(s), are carried out for Third Party employees through direct supervising contact with those employees. Actions required by ArcelorMittal Dofasco to fulfill responsibilities for supplemental labour include: Contracting with the Third Party, specifying that Third Party employees are trained and certified as competent Ensuring that the Third Party and their employees comply with the ArcelorMittal Dofasco Health, Safety and Environment Program and the Third Party Contractor and Outside Carrier and Supply Companies Employee Handbook(s) requirements Implementing ArcelorMittal Dofasco Health and Safety Program requirements as required. These may include: Inductions Health and safety contacts Health and safety meetings Job Observations (Work Practice Evaluations) Layered Evaluations Any other action ArcelorMittal Dofasco undertakes for the health and safety of its employees. Stopping and correcting any unsafe work practices by Third Party employees and reporting such activity to the Third Party. Providing the appropriate progressive discipline to either the Third Party or through the Third Party to its employees for health and safety violations Maintaining a performance record on each Third Party and reviewing that performance prior to any future contracting with the company for supplemental employees. The Project Manager / Coordinator assigned by ArcelorMittal Dofasco to supervise the work that requires supplemental labour is responsible for: Ensuring that Third Party employees are treated in the same manner as ArcelorMittal Dofasco employees in terms of health and safety Ensuring that the people performing the work have the required competent ArcelorMittal Dofasco supervision. The Project Manager / Coordinator may also be identified by ArcelorMittal Dofasco as the direct supervisor of the people performing the work as well as having the overall responsibility for the supervision of the project Reporting problems with respect to a Third Party employee to the Third Party employer. THIRD PARTY (CONTRACTOR) DUTIES AND RESPONSIBILITIES Specific Assignment Whether work is deemed as Construction or Industrial, ArcelorMittal Dofasco may choose to contract the services of a Third Party for a specific assignment. If ArcelorMittal Dofasco contracts a Third Party for a specific assignment, the Third Party is responsible to provide direct supervision to their employees for the duration of the work. The responsibilities of the Third Party Employer contracted for work identified as a specific assignment include: Ensuring that the requirements of the ArcelorMittal Dofasco Third Party Health, Safety and Environment Program and the Third Party Contractor and Outside Carrier and Supply Companies Employee Handbook(s), are followed by their employees Providing competent supervision who give work direction to their employees Only provide competent employees who are certified in the compulsory trades or who are otherwise permitted by the appropriate Ontario Ministry under the relevant Ontario Statute and related Regulations. Implementing their own company health and safety program Ensuring that their employees comply with the Occupational Health & Safety Act and their own health and safety program Complying with the ArcelorMittal Dofasco Safe Work Permit process Communicating the required information obtained from the Safe Work Permit Meeting to their employees HS Copyright by ArcelorMittal Dofasco Inc., 2013 All Rights Reserved Page 16 of 19

18 Participating with the ArcelorMittal Dofasco Project Manager / Coordinator in conducting inspections of the project work site. Supplemental Labour Whether work is deemed as Construction or Industrial, ArcelorMittal Dofasco may choose to contract the services of a Third Party as supplemental labour. If ArcelorMittal Dofasco contracts a Third Party as supplemental labour, ArcelorMittal Dofasco is responsible to ensure that the requirements defined by the ArcelorMittal Dofasco Health, Safety and Environment Program and the Third Party Contractor and Outside Carrier and Supply Companies Employee Handbook(s), are carried out for Third Party employees through direct contact with those employees. The Third Party Employer is responsible to ensure that their employees are: Trained or certified as competent or who are otherwise permitted to perform the work by the appropriate Ontario Ministry under the relevant Ontario Statute and related Regulations for the trade or skill required Trained in the requirements of the ArcelorMittal Dofasco Third Party Health, Safety and Environment Program and the Third Party Contractor and Outside Carrier and Supply Companies Employee Handbook(s) as applicable. Health and Safety Representatives / Committee The Third Party employer must ensure a Health and Safety representative or Joint Health and Safety Committee are present at the job site as required and specified by the Occupational Health and Safety Act. Sub-Contractor Duties and Responsibilities Sub-contractor employers, management and supervision have the same duties and responsibilities as described under Third Party (Contractor) Duties and Responsibilities section of this manual. Third Party Employee Duties and Responsibilities All Third Party employees are responsible to: Report to work in an acceptable mental and physical condition to allow for the safe performance of all required work functions. Comply with ArcelorMittal Dofasco s Zero Tolerance policy: The possession and/or use of alcohol or drugs is strictly prohibited on ArcelorMittal Dofasco property and will result in the immediate and permanent removal of the Third Party employee from ArcelorMittal Dofasco property. Read and follow all precautions and safety procedures as detailed or referenced on the Safe Work Permit issued to your supervisor at the safe work permit meeting held prior to the start of any work and to sign off on the safe work permit acknowledgement document. Read and understand health, safety and environmental information. Review and understand the ArcelorMittal Dofasco Major Emergency Response Plan (MERP) for the plant area you will be working in. This information will be reviewed and a map issued to your supervisor at the safe work permit meeting. Read and understand the area site specific safety induction information issued to the employee by their supervisor. Advise supervision of unsafe conditions, procedures, and concerns that may result in an accident or injury. Report all accidents, with or without injury, immediately to supervision. Participate in accident investigations as required as held by ArcelorMittal Dofasco and Third Party supervision. Inspect and maintain the job or work site in a safe working condition and clean the work site of all tools and materials on a daily basis. Perform work only in the area and only on equipment identified on the Safe Work Permit. Exercise their right refuse work when they feel that the work to be performed is unsafe. Their concern must be reported to their immediate supervisor. HS Copyright by ArcelorMittal Dofasco Inc., 2013 All Rights Reserved Page 17 of 19

19 RULES Third Party employees are responsible for learning, understanding, and following the rules listed below as well as any regulations applicable to the work they are performing. ArcelorMittal Dofasco Major Safety Rules ArcelorMittal Dofasco has identified four (4) very specific existing rules that are critical elements of each work activity. You must lock out, when required. You must not disable safety devices. You must follow the confined space entry procedure before entering a confined space. You must use fall protection, when it is required. ArcelorMittal Corporate Golden Rules ArcelorMittal Corporate has also issued Golden Rules that are intended to create an easily understandable common vision for all employees and third parties working in all ArcelorMittal plants worldwide. Everyone should understand the requirements of these Golden Rules as they apply to our daily work and ensure that our behaviours and actions comply with these Golden Rules at all times. If there is an accident involving any of these rules, a thorough investigation will take place using Root Cause Analysis/Critical Decision Analysis tool to determine why, from a system and decision-making perspective, the plan failed. If the investigation determines that a deliberate violation of one of these major safety rules has occurred, the Third Party employer understands and agrees that this shall be sufficient cause for termination of Third Party s service by ArcelorMittal Dofasco pursuant to the terms and conditions of the contract. DISCIPLINARY ACTION Non-compliance with health, safety, or environmental requirements that are part of the contract documents may result in work stoppage and removal of the supervisor and/or employee from the premises. Willful or repeated noncompliance may result in dismissal of the Third Party and contract termination. Temporary or permanent removal from ArcelorMittal Dofasco property may occur if the Third Party s manager, supervisor, or person in charge of the work being performed requires, allows, or condones Third Party employees to work in or around unsafe acts or conditions or violate environmental permits or regulations. Immediate and permanent removal from ArcelorMittal Dofasco property may occur if the Third Party s manager, supervisor, or employee engages in any of the following activities: Openly exhibits disregard, defiance, or disrespect for the health, safety and environment program Knowingly falsifies investigative documents or testimony involving an investigation Participates in fighting, violence, threats of violence, theft, or destruction of property Violates established safety rules, regulations, or codes that endangers themselves or others Violates established environmental rules, regulations, or procedures that endanger the environment HS Copyright by ArcelorMittal Dofasco Inc., 2013 All Rights Reserved Page 18 of 19

20 RESERVATION OF RIGHTS During the performance of the work, the Third Party, Third Party employees, sub-contractors, agents and invitees shall strictly comply with all health and safety, environmental, security and other applicable rules and regulations. In the event any of them violate any such rules and/or regulations, the Third Party employer shall take appropriate action and shall have a disciplinary policy in place that includes for permanent removal from the work site. ArcelorMittal Dofasco reserves the sole right to determine if such act, or failure to act, constitutes a violation or deviation of any of the rules and regulations. ArcelorMittal Dofasco has the unilateral right to stop work whenever health, safety or environmental violations are observed which could jeopardize the well being of personnel, property or the environment. The expense of such work stoppage and resultant standby time shall be for the Third Party s account. The failure or refusal of the Third Party employer to correct the observed violation may result in the termination of the contract, and/or the dismissal from the work site of those responsible for such failure or refusal. In any event, the Third Party employer understands and agrees that any violation of applicable health, safety or environmental rules shall be sufficient cause for termination of Third Party s service by ArcelorMittal Dofasco pursuant to the terms and conditions of the contract. REVISION HISTORY: June 2012: Added exception to load securement rule; safety binders are permitted when securing wide coils loaded cross-wise from ground level. April 2013: Program Elements - added Third Party Community of Practice section. Program Implementation clarified requirements for Pre-Task Health & Safety Plans Program Implementation updated requirements/responsibilities for Accident Reporting and Investigation Program Implementation added section for Layered Compliance Audits Appendix 1 updated Injury Notification template Appendix 2 added Pre-Task Health and Safety Plan & HIRA template Appendix 3 added Layered Compliance Audit template Appendix 4 added User Guide for Documentation Completion and Submission HS Copyright by ArcelorMittal Dofasco Inc., 2013 All Rights Reserved Page 19 of 19

21 Appendix 1 Notification of Injury to Third Party Employee While Working On-Site at ArcelorMittal Dofasco Inc. This form must be sent to ArcelorMittal Dofasco s Health & Safety Department either by fax ( ) or ([email protected]) within 48 hours of confirmation of a Medical Aid or Lost Time Injury accident. Fax to: (905) Please deliver the following page(s), including cover page, to: Health & Safety Department Date: From: Please complete the following if not included on the accident investigation form Company Name Date of Accident Name of Injured Employee Nature of Accident Nature of Injury Classification of Injury (circle one) Medical Aid Lost Time Where Employee Was Working ArcelorMittal Dofasco Contact Person Name (i.e. OSCC or Project Manager) Last Revision Date: 2009-Mar-18 Page 1 of 1 Appendix 2

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23 Appendix 3 THIRD PARTY Layered Compliance Audit Information Name(s): Company: Location: Evaluators: Date: Time: Personal Protective Equipment (PPE) Identify Equipment Required Eyes & Face Hearing Protection Head Hand & Arms Feet & Legs Respiratory System Trunk Fall Protection Position of People Ergonomics Performing strike or Posture hammer motions Struck by other Type of Motion Caught Between Load handled Falling Repetition Others: Work Area Design Tools & Grips Potential for Exposure/Work Environment Electrical Current Inhaling Absorbing Ingestion Other Procedures Is standard practice adequate for job? Is standard practice established? Is standard practice being maintained? Safe Behaviours Unsafe Behaviours Tools & Equipment Suitability Used correctly In safe condition Orderliness Is workplace orderly? Housekeeping Lighting Noise Vibration (hand-arm; whole-body) Temperature Extremes Situational Awareness Hazard Control In Place? What Could Go Wrong? Could We Make it Safer? OBSERVATIONS Issues Responsible for Follow Up Follow Up Issues Solution Completion Date Audit Supervisor: Date: Form: Third Party Layered Compliance Audit April 13, 2011

24 Appendix 4