Safety Policy

Injury and Illness Prevention Plan For TPM Solutions, LLC: Reviewed July 2018

This Injury and Illness Prevention Plan (IIPP) applies to all TPM Solutions projects within the United States. The contents of this Plan include the following sections:
Section 1- Management Commitment and Assignment of Responsibilities
Section 2- System for Compliance Assurance
Section 3- Safety Communications
Section 4- Hazard Identification/Assessment
Section 5- Hazard Correction
Section 6- Accident Investigation
Section 7- Training
Section 8- Record Keeping

1. Management Commitment and Assignment of Responsibilities

Commitment: TPM Solutions is fully committed to the safety of our employees. Our objective is to become recognized as a leader providing a safe and healthy workplace. Safety performance and compliance are an integral part of how we conduct our business. Consequently, our safety initiatives are designed to reflect our commitment to incident free operations and support our philosophy of Safety First. This philosophy include the following principles:
Accidents are caused, accidents can be prevented, and if we eliminate the cause, we will eliminate the accident.
TPM Solutions' process to a safe and healthful work place is as follows: Hazard Assessment Safety Action Plan (HASAP); Safe Plan of Action (SPA); Safety Observation Report (SOR); Formal Accident Investigation; and commitment from all employees in helping each other work safely and providing positive reinforcement for safe behaviors through utilizing the Behavior Based Safety Process.
Safety is a condition of employment and each individual is accountable for adhering to safe work practices.

Assignment of Responsibilities
Supervisor/managers for each TPM Solutions work-group/team will use this plan to comply with the CAL-OSHA SB-198 requirement of a written Injury and Illness Prevention Plan (IIPP) for their work group.
The Project Manager has the overall responsibility and authority for implementing and reviewing this safety plan with all TPM Solutions employees onsite. As set forth in the TPM Solutions' Health & Safety Procedure, each employee will work safely as a condition of employment, accepting responsibility for his/her personal safety performance and for his/her job performance as it affects the safety of others. Each employee shall encourage others to work safely, sharing responsibility for the safe action of those fellow workers.

2. System for Compliance Assurance

TPM Solutions will ensure that all employees comply with safe and healthful work practices. Processes to ensure compliance include:
Management and Supervision will use positive reinforcement to encourage, commend, and reward employees in compliance and working safely during their day-to-day job observations and should by their actions demonstrate visible safety leadership. All employees are empowered and responsible to stop any unsafe act and/or to correct any unsafe condition.
Progressive disciplinary actions with employees will be used for those not following safe and healthful work practices.
Drug and Alcohol annual testing will be performed on DOT and Company safety sensitive employees. Random, pre-placement, and for cause, testing will be conducted. Contraband searches will be administered as needed.
Safety Evaluation Reports.
Task Quality Safety Auditing to be performed by Project Manager.

3. Safety Communications

Effective safety communications are a critical component of our safety management processes. TPM Solutions' communication systems include:
General Safety Meetings
Job Hazard Analysis Meetings – for field oriented tasks, conducted on a daily basis and documented on the relative Job Hazard Analysis.
Routine work-group/team and Project meetings
Safety Suggestion Program
Safety Observation Report (SOR) process
Safety Steering Committees (roles and responsibilities for both employee and management members are defined in the TPM Solutions' Health & Safety Procedure)
Anonymous compliance concern reporting by SOR’s, safety suggestion box, and/or the TPM Solutions Open Door Policy.
Ongoing continuous initial training & annual review.
Written communications/postings

4. Hazard Identification/Assessment

TPM Solutions has procedures in place to identify and evaluate work place hazards. These include regularly scheduled inspections, audits, and evaluations. All of these procedures are designed to mitigate/eliminate workplace hazards. Included are:
Hazard Elimination Form
Safety Evaluation Reports
Job Hazard Analysis
Standard Operating Procedures
Safety Suggestion

5. Hazard Correction

Once an unsafe condition(s) or work practice(s) has been identified and evaluated, they shall be eliminated in a timely manner. The way in which the hazards are eliminated shall be based on the severity of the situation. In all cases, the situation shall be dealt with in an appropriate manner by the person who first observes it, through the following methods:
If the problem is minor, the person who discovered it should correct it. If the problem cannot be corrected on the spot, it should be barricaded, or otherwise identified, so that other employees are aware of it.
If supervisory guidance is needed in correcting the problem, it shall be handled through the formal supervisory process, starting with the immediate supervisor of the person who identified the problem.
It is also established that the TPM Solutions Project Manager is notified of any unsafe or unhealthy condition, work practice, or work procedure in a timely manner when observed or discovered.
The hierarchy of control, as prescribed by Cal/OSHA, should be engineering controls first, then administrative controls and lastly personal protective equipment. PPE may be utilized until engineering or administrative controls are in place.

Whenever a newly discovered or previously unrecognized hazard is identified, it is the responsibility of the first line supervisor to arrange for an inspection and hazard assessment by the TPM Solutions Project Manager.

Whenever possible, it is the company’s intention to abate immediately any hazard which is in imminent danger. When such a hazard exists, which cannot be abated immediately without endangering employees, all exposed employees will be removed from the area of potential exposure except those with the necessary safeguards and PPE. In situations which it is not possible for employees to correct the hazard, without placing themselves in danger, outside experts trained in abatement of the particular hazard will be hired to correct the condition as soon as possible.
Processes to correct unsafe conditions include:
Safety Suggestion Process
Hazard Elimination Form
Near miss program
Safety Steering Committees

6. Accident Investigation

All work related incidents (e.g. injury, illness, vehicle, property damage, spills, third party, etc.) shall be investigated using the appropriate level of accident investigation technique. Minor incidents and near misses, as well as significant near misses, shall also be investigated.

The investigation process involves the following components:
Joint investigation of TPM Solutions personnel, client, subcontractor and/or 3rd party when involved.
Investigation teams consist of management, employee, supervisory, safety and client representation.
Sharing findings and lessons learned via both presentation and the electronic mediums.
Corrective actions are implemented as soon as possible with documentation of completion.

7. Training

TPM Solutions considers safety and health training to be a critical aspect of safety management concerning all projects. To that extent, multiple training venues exist to facilitate effective learning and develop the skills necessary to work safely on all locations.

Those training mechanisms encompass:
New Hire Safety Training/Orientation
Formal Classroom Training
SPA (Job Hazard Analysis)
SOR (Hazard Elimination Form)
Informal/Hands-on training
General Safety Meetings
Distribution of written safety material
Project safety module training process
Annual review and re-certification

8. Record Keeping

Record keeping and documentation processes are managed at a corporate level. Records are maintained on computer database and/or hard files. Legally required records are retained for a minimum of three years.

Examples of the records maintained include:
Employee personal training records
Safety meeting topics and attendance
OSHA 300 logs