Minimum Safety & Loss Control Guidelines

ULLICO Casualty Company ("ULLICO Casualty"), in conjunction with the Trowel Trades Industry Insurance Company, designed the following safety and loss control guidelines as part of a broad effort to reduce signatory contractors' workers' compensation losses, as well as to meet regulatory requirements. All signatory contractors participating in the program must comply with the loss control requirements, unless given written approval by ULLICO Casualty. We have also included loss control recommendations that may help further reduce the cost of workers' compensation losses.

Requirements

Federal Regulations. Signatory contractors' safety and loss control programs must comply with Federal OSHA regulations, including applicable sections of CFR 1920 and 1926, and MSHA regulations where applicable (i.e., refractory work).

State OSHA Regulations. Signatory contractors' safety and loss control programs must comply with state OSHA regulations.

Collective Bargaining Agreement. BAC signatory contractors' safety and loss control programs must comply with the collective bargaining agreement with the International Union of Bricklayers and Allied Craftworkers (BAC) and/or affiliated Local Unions, as well as other collective bargaining agreements which they may be signatory to with other labor unions.

Employees and Training. All employees of the BAC signatory contractor must have the appropriate training, including safety training, for their assigned tasks. Training must be provided for all new employees on any equipment or processes that the employee is likely to use as part of his/her employment, assuming the employee has not demonstrated sufficient knowledge and skill. The date of training, the scope of areas covered, and the supervisor should all be noted in the employee's file. This requirement also applies to any existing employee changing jobs or using new equipment.

Safety Meetings. Each signatory contractor must hold safety meetings for all employees, including management and line employees, at regularly scheduled intervals. Attendance will be mandatory and attendance should be taken. The frequency of meetings and the topics are at the discretion of the signatory contractor.

Safety Committee. Each signatory contractor must have a formal safety committee. The safety committee is responsible for implementation of the safety and loss control program. The committee should include representatives from ownership/senior management, supervisors, and line employees.

Post Accident Investigations. Each signatory contractor must perform an investigation of every incident. Results of the investigation should be reported both to the safety committee and, if relevant, at safety meetings.

Claims Reporting Lag. The claims reporting lag is the time that it takes for a workplace incident to be reported from the employer to the claims administrator. Signatory contractors will be expected to keep their average claims reporting lag time under four days, or within the time period required by state law if less then four days.

Fall Protection. All signatory contractors will be required to provide fall protection appropriate to the type and conditions of the work being performed for employees working at heights above six feet from the ground level. This may include, scaffolding with a guardrail system, safety nets, positioning device systems and/or personal fall arrest equipment. Controlled access zones should be used when, due to the conditions, tie-off is not practical.

Scaffold Training. Signatory contractors will be required to provide training to employees on the use of scaffolding based on manufacturer requirements, and ensure that a competent person (that meets federal, state or city requirements and/or certifications) oversees and/or inspects (when the masonry contractor is not responsible for supplying or maintaining the scaffold) the erection, moving, dismantling and altering of scaffold used by employees.

Types of Scaffolds include:

Hazard Communications. All signatory contractors will be required to provide employees with effective information and training on hazardous chemicals and materials in their work area, where to find, and how to read, Material Safety Data Sheets (MSDS), and necessary precautions to protect themselves when using these products or materials, including the use of PPE and/or apparel.

Equipment Training and Maintenance. Signatory contractors will be required to ensure that employees are trained on all equipment required for their assigned job, that the equipment meets OSHA and/or ANSI specifications, and the equipment is maintained and in proper working order, for example:

• Ladders/Stairs/Walkways - Signatory contractors must require that employees use only approved ladders, stairs and walkways that are in good condition at all times, and to use them in accordance with manufacturer instructions (i.e., never stand on the top rung/step of a ladder). All ladders should be labeled as being designed and manufactured in accordance with the provisions of the American National Standards Institute. Ladders should be 1-A duty rated.
• Power Tools - Signatory contractors must require that all equipment and power tools, including saws and dustless vacuum systems, used by employees are in safe and fully functional working order.
• Power Cords - Signatory contractors must require that all power cords used on their jobsites be rubber covered 3-conductor, properly grounded, and have inspection labels. Power cords must be kept in good condition, free from exposed wire and with no cuts or splices.
• Handheld tools - Signatory contractors must require all handheld tools, such as chisels and hammers, to be in good condition.

Welding and Cutting. Signatory contractors that engage in welding and cutting must require employees involved in this type of work to have appropriate training for the job, and meet state certification requirements.

Personal Protective Equipment. Signatory contractors must assess the workplace for hazards and use appropriate engineering controls, work practice controls, and/or personal protective equipment to eliminate or reduce hazards. In addition, signatory contractors must train employees on the need for and use of PPE, and require the wearing of appropriate personal protective equipment for all operations where there is an exposure to hazardous conditions or where it is needed to reduce the hazards.

Types of PPE include, but are not limited to:

• Hardhat-Class A
• Safety Glasses/Face Shields
• Respirators - half-face, full-face, disposable, PAPR, SCBA
• Gloves - (e.g., rubber, neoprene, polyurethane)
• Work Shoes/Boots
• Hearing Protection - Ear muffs, disposable and reusable ear plugs, headband plugs
• Aprons Nests
• Disposable Suits - (i.e.., Tyvek suits, coveralls)
• Rain Suits - partial or full body suit
• Knee pads
• Fall protection/harnesses

Respiratory Protection. When respiratory protection is required, signatory contractors shall comply with the OSHA Respiratory Protection Standard 29 C.F.R. 1926.103. The signatory contractor shall select, provide, and require the use of an appropriate, clean respirator based on the respiratory hazard(s) to which the worker is exposed, taking into consideration workplace and user factors that affect respirator performance and reliability. When respirators are required, the signatory contractors must provide respirators, fit-testing, training and medical evaluations at no cost to the employee.

• Where engineering controls and work practices are inadequate to prevent workplace exposures to airborne crystalline silica from exceeding the PEL, respiratory protection is required in accordance with OSHA's Respiratory Projection Standard 29 C.F.R. 1926.103 (or other related standards issued by OSHA to control exposures to crystalline silica).

Material Handling Equipment. Signatory contractors will require their employees to use appropriate equipment, including: forklifts, dollies, carts, straps and proper lifting techniques in the handling of materials. In addition, signatory contractors will require employees to keep aisles and passageways clear to allow the safe movement of material handling equipment, and to be trained in the use of appropriate hand-signals for moving materials. Signatory contractors will require employees to limit material stored on scaffolds or runways to the amounts needed for immediate operation.

Confined spaces. Signatory contractors will be required to comply with any specific regulations that apply to work in confined spaces, including ensuring they are well lit and properly ventilated, and will require employees to take necessary precautions and be trained in the use of protective and emergency equipment required by OSHA and MSHA, as well as any company/owner job-specific training.

Housekeeping. Signatory contractors must require that employees keep their working areas free from hazards, such as irregular building material piles, buckets, dust, sharp objects left uncovered, etc.

Recommendations

Drug & Alcohol Prevention Program. Pre-employment, and post accident drug testing can all help foster a drug free work environment. Any drug and/or alcohol prevention program should conform with the collective bargaining agreement and state law.

Early Return to Work Program. An early return to work program helps maintain the morale of injured employees, decreases lost time payments, and facilitates rehabilitation. Any early return to work program should conform to the collective bargaining agreement.

Claims Liaison. A claims liaison is an assigned employee who coordinates activities on open claims. The liaison will contact each injured employee at least every two weeks. The liaison will review the adjuster's notes at least every two weeks on all open claims. The liaison will meet with the healthcare provider at least once a year to maintain open lines of communication and a good rapport. The liaison will also provide coordination between the injured employees and the contractor's early return to work program.

Suggestion Box. Making a safety suggestion box accessible to all employees will enable employees to anonymously make suggestions regarding safe work practices.