Safety Policy and Procedure

Safety Policy and Procedure Policy Number: 029 Authorized By: The Cianbro Companies Alan Burton Title: Safe Handling and Effective Date: 04/01/94 Page 1 of 7 1 Status 1.1 Update of existing policy, effective 09/02/11. 2 Purpose 2.1 To protect team members and the public from the hazards of storing and using compressed gas. 3 Applicability 3.1 This policy applies to all subsidiary companies and departments of The Cianbro Companies. 3.2 All organizations are required to comply with the provisions of this policy and procedure. Any deviation, unless spelled out specifically in the policy, requires the permission of the Corporate Safety Officer or designee. 4 Definitions 4.1 HMIS: Hazardous Materials Identification System. 4.2 NFPA: National Fire Protection Association. 4.3 The abbreviation MT refers to empty. 5 Policy 5.1 All team members and subcontractors working for Cianbro will follow the procedures outlined in this written policy. 6 Responsibilities 6.1 The top Cianbro manager on the job site is responsible for the implementation of this policy on the project. 6.2 The corporate safety department is responsible for maintaining this document. Policy: 029 Safe Handling and Rev. 09/02/11 Page 1

6 Safe Handling and Index 7.1 Transporting, Moving, And Storing Compressed Gas Cylinders:... 2 7.2 Training And Set-Up... 4 7.3 Reverse Flow, Back Fires And Flashbacks... 5 7.4 Dangers Of Oxygen... 5 7.5 Rosebuds... 5 7.6 Dangers Of Acetylene... 6 9.1 Appendix A Flashback... 7 7.1 Transporting, Moving, and Storing compressed gas cylinders: Always use proper methods for transporting or lifting compressed gas cylinders. Use single or double bottle carts when applicable. When using equipment to carry or lift cylinders make sure they are securely fastened into a rack that is properly designed and built to accommodate the task you are planning. Each project is responsible to check our bottle racks that will be lifted by crane or forklift to make sure that they are load rated as stated in 1926.251 (a)(4). If the racks have not been rated we need to do a visual inspection and a dynamic load test for 125% of the rated load capacity and if they pass we can mark those 100% of the loaded capacity. You will need to document and put the capacity on the rack. The documentation will have the date tested, the racks small tool number, the weight applied and the new rating. A copy of the test will be sent to the small tool group and a copy kept on site. When you ship the rack off of the project the documentation needs to go with the rack. All racks coming through the shop in Pittsfield will be engineered and the weights will be welded to the rack. Even if the racks are done on a project they will be retested in the shop and the dry weight of the rack and the safe allowable load will be labeled on the rack. 7.1.1 Never lift or transport cylinders with gauges or torch set-ups still in place. Always disconnect torches and make sure all safety caps are installed properly. 7.1.2 Never use valve protection caps for lifting cylinders from one vertical position to another. Bars shall not be used to pry caps loose when frozen. If a cap cannot be removed by hand, either use a tool specifically designed for removing caps or tag the cylinder Do Not Use and return it to the vendor. Never use a tool that is not designed for removing caps. 7.1.3 When cylinders are transported by forklift, pickup or any other vehicle they must be secured in a vertical position. Compressed gas cylinders are very heavy and should be handled with every mechanical advantage available such as single bottle carts for changing empties, lift gates on trucks or approved hoisting racks to prevent strains/injuries. 7.1.4 Unless cylinders are firmly secured on a bottle cart designed for this purpose, regulators shall be removed and valve protection caps put in place before cylinders are moved from one area to another. 7.1.5 Some federal, state and local firms or agencies have governing limitations on the amount of a particular compressed gas that can be transported over the road. These agencies also control the proper licensing and permitting required to transport. Due to the changing situations from state to state you should contact Corporate Safety before moving cylinders over the road. In all cases, you need a completed bill of lading. 7.1.6 Compressed gas cylinders must be secured in an upright position at all times by bottle carts, chains, or other sturdy non-combustible hold down devices to prevent bottles from being knocked over while in use or in storage. Valves shall be closed at all times except when cylinders are in use. This includes whenever the bottles are unattended. Policy: 029 Safe Handling and Rev. 09/02/11 Page 2

7.1.7 When designing and fabricating gas storage racks on jobsites give particular thought to making these racks ergonomically correct. Platform height from the ground and accessibility and operation of doors are important items to remember for team member daily usage and scheduled delivery personnel. 7.1.8 Be sure that storage racks are clearly and correctly marked and labeled. Design and implement some kind of marking or labeling system for full or empty cylinders. Example: Mark them MT or similar. 7.1.9 Cylinders shall be kept far enough away from actual welding or cutting operations so that sparks, hot slag or open flames will not reach them. When this is impractical, a fire resistant shield shall be provided. Oxygen must be separated from fuel gas by a minimum of 20 or have a ½ hour fire barrier of at least five feet in height plus be kept 50 from any combustibles or flammable materials. (See sketch as a good rule of thumb for storage of cylinders). Please note that cylinders in a bottle cart but not in use are considered in storage and therefore a citable violation unless there is a fire barrier between them. The material used for a fire barrier according to NFPA must provide a 30-minute fire barrier. A suggested fire barrier would be 1/8 minimum carbon steel plate. Flammable Containers Oxidizers (Oxygen & Chlorine) Combustibles Ignition Sources (Oil and Grease) 7.1.10 Cylinders must be stored in well ventilated areas. 7.1.11 In HMIS (preferred) or NFPA label should be on all cylinders or at the wall of the storage area above the cylinders (e.g. acetylene storage area marked with appropriate HMIS or NFPA label for acetylene). Also, all cylinders must have a DOT label attached. All cylinders on site must be clearly marked for contents. 7.1.12 Securing cylinders with materials such as rope or duct tape is not an allowable practice. Materials such as chain or other fire resistant material should be used in an appropriate manner. 7.1.13 Cylinders shall be placed where they cannot become part of an electrical circuit such as electrode arc strikes or near open flames, hot metal, or other external heat sources. Ambient temperatures should not be allowed to rise beyond 130 F maximum. Note: Special care should be taken to ensure that arc strikes do not occur when power cable connections for the tig torch are located near argon cylinders. 7.1.14 Cylinders containing oxygen or acetylene or other fuel gases shall not be taken inside of confined spaces. 7.1.15 Treatment of cylinders Cylinders, whether full or empty, shall not be used as rollers, supports or other than the original intent. 7.1.16 Torch set ups need to be broken down at the end of each shift. Bottle caps must be secured to prevent damage to the valves of the bottles. Policy: 029 Safe Handling and Rev. 09/02/11 Page 3

7.2 Training and Set-Up 7.2.1 All team members must be trained in the safe use, handling, and storage of gas cylinders. 7.2.2 Inspect all gas cylinders, hoses, regulators, and other accessories before using. Do not use if defective. 7.2.3 Before a regulator is connected to a cylinder the valve should be cracked slightly and shut back off immediately (except hydrogen). Use the tool provided by the gas supplier if needed. This will blow out any dirt or debris that has settled within the valve that might otherwise enter the regulator. The person cracking the cylinder valve should stand to one side of the outlet and make sure that the blast of gas is not directed towards team member work areas, open flames or other possible sources of ignition. 7.2.4 Before opening the cylinder valve, make sure the adjusting screw on the regulator has been backed all the way off. This prevents damage to the outlet pressure gauge and premature purging of the gas lines. Please refer to the manufacturer s recommended pressure settings. 7.2.5 Leak Testing Connections: Check for gas leaks at the fittings every time equipment is set up. Apply leak test or Snoop non-petroleum based soapy water to valves, joints, connections, and around the regulator gauges. If bubbles appear a leak is present. Never use an open flame to test for leaks. Depressurize the hose, regulator, or torch if a leak is found. If the leak is at a threaded connection, open the connection and wipe the sealing surfaces with a clean, dry cloth. Check threads to make sure they are clean and that they are not stripped or bent. Damaged fittings should be replaced. Tighten the connection and re-pressurize the system. Test again for leaks. If they are found, depressurize the system again and add a tag marked Danger Do Not Use and return the equipment for repair. If the leak is at the junction of the cylinder valve and cylinder, do not try to repair it. Move the bottle to an outside location away from ignition sources and contact the supplier for further instructions. 7.2.6 Oxygen cylinders contain 2,000 PSI or more. Always open cylinder valves slowly! 7.2.7 If pressure hits the regulator all at once, it can mean hundreds of degrees of temperature rise and severe shock to the regulator. Under the right circumstances this could cause ignition of the regulator seat. Remember that what can hurt your equipment can hurt you! Always turn oxygen valves to the full open or closed, intermediate positions could leak. Once the valve has been fully opened adjust regulator to desired pressure and purge the oxygen line. Never use oil/grease or petroleum based lubricant on any threaded connection or parts. 7.2.8 Acetylene is stored in specially constructed cylinders that contain a porous filler material. The porous mass is wetted with acetone in which the acetylene is dissolved. The combination of porous filler and acetone allows the acetylene to be safely contained in the cylinder at 250 PSI. Never use an acetylene cylinder on its side due to the liquid acetone being allowed to flow into the regulator and hoses. Once the acetylene is released as a gas from the cylinder, the working pressure at the discharge side of the regulator should never exceed 15 PSI. Acetylene becomes dangerously unstable at 15 PSI and above. It is recommended that the cylinder valve be opened no more than ¼ to 1 full turn. Many acetylene cylinders have a hand-wheel valve but for those requiring a tank wrench, the wrench must be left in place while in use so that the valve may be closed quickly in the event of an emergency. 7.2.9 The use of propylene as the cutting gas instead of acetylene is recommended: A 63 lb bottle of propylene will last as long as five # 4 (81 lb) bottles of acetylene. Reduce chances of back injuries by changing bottles less frequently. Propylene is 20 times more stable according to the gas industry and there is a lower tendency for flashback than acetylene. Cylinders are lighter to the same comparable size acetylene bottle. Policy: 029 Safe Handling and Rev. 09/02/11 Page 4

7.2.10 Always use flint/spark strikers to light a torch. Never use matches, cigarette lighters or hot metal. 7.2.11 Clean tips with proper tool and only when torch set is shut off. 7.2.12 Never use the torch as a hammer or pry bar. 7.2.13 Anyone using a torch set should be adequately trained in its safe use by a qualified, knowledgeable trainer. Note: Plastic lighters shall never be stored in your pocket while doing hot work. Slag can penetrate the lighter causing an explosion and serious injury. 7.3 Reverse Flow, Back Fires and Flashbacks 7.3.1 Reverse flow of acetylene or fuel gas may occur when the oxygen cylinder is low or empty. Fuel gas at a higher pressure than the oxygen can travel up the oxygen line to mix with gas in the hose, regulator and possibly the cylinder. Lighting the torch without purging the hoses can result in a rapid burn-back, possibly causing an explosion in the torch, hose and regulator. (See 9.1 Appendix A). 7.3.2 Although OSHA has not set specific standards on the type and location of combination reverse flow/flash arrestors concerning single bottle installation, Cianbro and our suppliers agree that the following configuration offers the safest means of protection. 7.4 Dangers of Oxygen Install reverse flow check valves at the regulator. Ensure arrow on check valve is pointed in the proper direction for correct flow. Note: Carefully follow the manufacturer s specific instructions for installation, maintenance and inspection. Combination reverse flow/flash back arrestor. Check reverse flow part of valve every six months. Change the flashback arrestors annually. Victor torches have flashback arrestors built in. When they are sent back to Supply they are sent out to be inspected. 7.4.1 Oxygen is a colorless, odorless and tasteless gas. It makes up about 21 percent of our atmosphere. 7.4.2 Reduce oxygen levels to 15 percent and a candle won t burn. Increase oxygen content to 25 percent and cotton thread burns eight times faster than normal. 7.4.3 When using oxyfuel torch and hoses, much of the oxygen goes straight through the cut and enriches the surrounding air. Cutting in confined spaces, therefore, requires ventilation not only to remove fumes but also to remove excess oxygen. 7.4.4 Another danger of oxygen is related to its action in the presence of oil or grease. Together oxygen and hydrocarbons may react violently. This effect is particularly dangerous when it occurs in the confined space of a regulator body when a cylinder valve is opened. Never store oxygen regulators or accessories in the presence of oil, grease or petroleum-based lubricants and always bag, place in plastic containers with lids (i.e. Rubber maid) or cap ends of gauges and other oxygen accessories when not mounted on cylinders. 7.5 Rosebuds 7.5.1 It is not recommended to use flashback arrestors on rosebud operations, because of flow restrictions on acetylene tanks. 7.5.2 Anyone using a rosebud should be adequately trained in its safe use by a qualified, knowledgeable trainer. Policy: 029 Safe Handling and Rev. 09/02/11 Page 5

7.6 Dangers of Acetylene 7.6.1 Acetylene is very flammable and explosive and must be handled with respect. 7.6.2 At pressures above 15 PSI, acetylene is very unstable and can explode without a source for ignition. 7.6.3 All flashbacks have the potential to create a bottle explosion and must be prevented with the proper training and protective equipment. (See 9.1 Appendix A). 7.6.4 Reverse flow can occur when the oxygen cylinder is low or empty. 7.6.5 OSHA reports its regulations for using gas regulators and cylinders are among the 25 most frequently cited rules in the industry. This safety policy and procedure provides suggested information for safe storage and handling. Activity planning and thorough training are the keys to keeping our jobsites safe. For more information, contact Corporate Safety. 8 Budget / Approval Process 8.1 It is the responsibility of each jobsite to procure and provide all PPE requirements under this policy and to provide necessary training. 9 Related Documents 9.1 See attachment. Policy: 029 Safe Handling and Rev. 09/02/11 Page 6

9.1 Appendix A Flashback Policy: 029 Safe Handling and Rev. 09/02/11 Page 7