CONTRACTOR SAFETY AUDIT GUIDELINES. We Will Utilize an Observation and Feedback Program

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1 CONTRACTOR SAFETY AUDIT GUIDELINES MANAGEMENT MUST AUDIT PERFORMANCE (From Entergy Utility Group Safety Process) We Must be Very Strong on Housekeeping We Will Utilize an Observation and Feedback Program We Must Detect Specific Problems and Help to Identify Weaknesses in the Safety Effort We Must Implement an Action Plan Consistent with Audit Results We Must Communicate Audit Results and Action Taken DEFICIENCIES MUST BE CORRECTED PROMPTLY We Must Audit to Improve Performance and Identify Deficiencies When Safety Deficiencies are Found with Our Procedures, Equipment and Facilities, Prompt Action Must be Required to: Overcome Safety Hazards JOB AUDITS 2. Reinforce the Message that Safety is a priority We Must Communicate Action Taken and Status of Correcting Deficiencies Audits are used to review and observe employees in action for good work practices, following procedures (safety, operational, etc.) and for site housekeeping. Results of audits indicate whether adjustments in processes, procedures, equipment, and work practices are needed. EXPECTATIONS (A) Safety Representatives and Supervisors will conduct daily job audits containing the following areas: (1) Observance of employees for adherence to procedures, for proper work location, etc.

2 (2) Wearing of proper personal protective equipment for the task and area, (3) Following proper safe work procedures and safe work rules, JHA and job briefing recommendations, and (4) Housekeeping of the work area and site. (B) Superintendents / Site Managers will conduct Weekly site audits to: IMPLEMENTATION (1) Observe employees working in their work environment (2) Observe the general housekeeping condition of the site, and (2) To review the effectiveness of supervisor s audits. (3) It is recommended that an audit be conducted of the entire job site as defined by Entergy outage or project management be conducted by all management and craft, contractors and Entergy personnel periodically. This effort reinforces management roles in safety as well as demonstrates that safety is everyone s business and is a team effort. This may be referred to as a Runway Audit. 1. As a minimum all supervisors and safety representatives should be trained in hazard recognition. 2. Supervisors and safety representatives should be familiarized with the site, with work scopes being performed, and with Entergy safety audit guidelines. 3. Supervisors, safety representatives and others involved in audit process should receive copies of guidelines and forms. 4. Outage or Contract manager should give criteria such as area assignment, number of audits and intervals required, specific concerns, etc to all auditors. 5. At the prescribed intervals, or more often, including the pre-outage period, auditors should carefully and thoroughly inspect areas or job sites, noting all deficiencies and successes on the audit form. Detailed notes describing the conditions should be taken. Minor deficiencies should be corrected on the spot by the auditor if possible. (Auditor is encouraged to bring an associate to help.) Digital cameras may be used provided documented permission is granted by Entergy site manager. (See site contact for camera authorization process.) Area and job site audits should be coordinated with other auditors to allow all areas to be audited at different times by different auditors to take advantage of a different perspective. 6. Documented audit findings should be presented to outage or contract manager for review.

3 7. Outage or contract manager shall review audit findings and make necessary assignments to correct findings. Any issues that cannot be quickly mitigated should have a safety WR generated by an Entergy employee, and the Safety WR process should be followed. 8. Outage or Contract manager should communicate all audit findings to all supervisors immediately for inclusion in tailboard briefings, JSHA development, and safety meetings 9. Follow up audits should be performed to insure the mitigation of the finding. Copies of previous audits should be used to insure mitigation of specifically noted hazards has taken place. 10. The use of an audit finding tracking process is encouraged to document finding, plan for mitigation, person(s) responsible, and communication of resolution back to all stakeholders. The following sections include general guidelines for recognizing hazards and deficiencies during job or site audits: Section I - PPE 1. Personal Protective Equipment (PPE) is important to a worker's protection and is required to be used for the hazards of the job. PPE includes such items as hard hats, safety glasses, goggles and face shields, gloves, steel toed shoes, protective clothing and hearing protection. 2. Two major articles of PPE are hard hats for head protection and safety glasses with side shields for eye protection. 3. Face shields are to be available and worn when grinding, handling chemicals, and other such work where face protection is needed. 4. Hearing protectors are available in multiple sizes, shapes and forms. The more common are disposable and permanent ear plugs. Other hearing protectors are ear muffs (both hard hat mounted and band type) and sound bands (ear plugs attached with a plastic band). The hearing protectors worn should have an NRR rating of 26 or higher. The higher the rating, the more protection provided.

4 5. Respirators are PPE devices worn when protection from a hazardous environment is required. The more common type used is the half-face negative pressure cartridge type. Several other types are the full-face negative pressure cartridge type, Power Air Purifying type (which is like a full face but uses a battery to draw the air through the filter medium), and air-supplied and Self Contained Breathing Apparatus (SCBA). 6. You may find some respiratory equipment stationed in certain areas of the plant for easy access. These are usually in weather protective enclosures marked with the type of equipment stored inside. Most often these are SCBA type respiratory protection devices. The containers should be well marked as to what equipment is stored. 7. Air packs (SCBAs) must be checked monthly with the air cylinders full or very near full at all times. 8. Other protective equipment includes special gloves, aprons and suits for handling chemicals & chemical goggles and face shields for eye protection. Some other equipment not shown are Electrical Flash Suits for electric arc exposures. Section II - Fire Protection 1. Fire extinguishers are one of the primary resources for fire prevention around the plants. They must be charged and readily accessible at all times. They should not be blocked by staged material, trash cans or debris, scaffold or any other item which may prevent access to the fire extinguisher in an emergency or routine circumstance. 2. Fire extinguishers come in a variety of sizes from large wheeled units to small hand held types. All of these are considered portable equipment. 3. Some types of extinguishers found on the plant site will include carbon dioxide or CO2 type extinguishers, externally charged dry chemical fire extinguishers, internally charged dry chemical type fire extinguishers, Halon extinguishers, All fire extinguishers must be labeled as to their type and for what fire types they can be used to extinguish. 4. Hose reels must also be kept readily accessible and if damaged, repaired or replaced immediately. Hose reels should be checked for damage that may have occurred by pressurizing the hose while it is still on the reel. 5. Some other fire protection devices include flammable cabinets used to store flammable products such as paint, solvents and other such materials that are flammable. Doors are to be kept closed and cabinets should be placed in well

5 ventilated areas. Flammable materials such as the boxes shown here should not be stored near this cabinet. 6. All fire fighting equipment and building exits are to remain freely accessible at all times. Most fire fighting equipment requires monthly documented inspections. Section III Ladders 1. When inspecting step ladders, always check for proper operation of safety feet and spreader locks. Check steps and other areas for damage. 2. Damaged ladders of any type must be taken out of service immediately and repaired or replaced. A tag is required to be attached to the ladder when it is taken out of service. The tag should read 'Do Not Use' or similar wording. 3. Areas around ladders should be kept clear of obstacles to prevent injury from tripping when getting on or off the ladder. 4. Extension ladder locking devices should be checked to see if they are in place and properly working. Ladders in use should be tied or fastened securely at the top, with a minimum of 4 extended above the surface being accessed by the ladder. 5. The rope used for raising and lowering the upper section of an extension ladder should also be inspected. Worn rope should be replaced. All ladders are to be inspected by the user prior to actual use. 6. All ladders are required to have safety feet as designed by the manufacturer. If they are not so equipped, the ladder must be removed from service. Section IV - Tool Inspection 1. When inspecting electrical cords and equipment, make sure the ground prong is in place (if so equipped), the cord is in good condition and the connectors are not damaged. The covering or outer insulation of the cord should be in good condition. 2. Wire rope slings are required to be free from kinks and other damage. Slings must not be used beyond their design capabilities and ratings. They should be stored properly when not in use. 3. Web slings should be free from damages such as tears or cuts in the webbing. All damaged slings are to be taken out of service immediately. Web slings are not to be used around chemicals and oils which will destroy the web material. They should not be used to lift equipment with sharp edges as the potential for cutting can easily occur. All slings should be inspected annually, and should have a tag noting the date of the last inspection.

6 4. Hooks are to be inspected for distortion. All hooks require safety latches. 5. All lathes require a guard over the chuck to prevent the operator from getting into the chuck dogs when the equipment is operating. 6. Bench and stand grinders require a tongue guard (located at the top of the grind wheel) and a work rest (located at the bottom of the wheel) properly adjusted. The tongue guard setting is one-quarter inch and the work rest is one-eighth inch from the grinding face of the wheel. Grind wheels should be free from imbedded material and the wheel face properly surfaced. 7. Portable grinders require guards or shields and are to be maintained in good working condition. Section V Housekeeping 1. Housekeeping is very important in the work environment. Poor housekeeping can contribute to a number of unsafe conditions, increase probability of injury, and slow down production. 2. Trash and debris contribute to trip and fire hazards (especially if the fire hazards are easily ignitable materials). 3. Materials and debris improperly stored causes a messy work site and contributes to potential trip hazards, especially in poorly lit areas. 4. Disposable clothing should be placed in trash containers when no longer needed. They should not be left on the floor or in work areas causing clutter. 5. Spills in walk ways or in work areas need to be cleaned up promptly and/or barricaded to alert others of potential slipping or other hazards. 6. Grating over ditches and loose catwalk grating should be repaired to prevent tripping hazards. Inspect grating carefully for looseness or uneven placement that could create tripping hazards. Use barricades to mitigate immediate hazards. Use Safety WR process to make permanent corrections. 7. Items such as hoses and extension cords left in walkways are potential trip hazards. They should be routed overhead if possible or along the side of walkway areas. 8. Tools and equipment should be properly stored when not being used. This reduces the clutter of the work area and potential trip hazards.

7 9. All exits from buildings are required to be properly marked and clear of any obstructions that would hamper exiting in case of an emergency. 10. Air hoses and equipment attached to them are required to have safety pins installed or wired to prevent the couplings from separating while under pressure. 11. Hoses, welding leads, and extension cords should be properly stored when not in use. 12. Trash containers should be emptied when full to prevent unsightly areas and potential safety and health problems. Section VI - Warning/ Information Signs 1. All sites are required to have an OSHA Job Safety & Health Protection poster posted at the work sight. This poster must be in areas normally accessed by employees. Due to work site arrangements, there may need to be multiple postings. 2. Warning signs are required to keep employees alert and informed of hazards in the work place. Signs need to be maintained in good readable condition. Eye protection should be worn when handling chemicals, grinding, and while working in high dust areas. 3. Exit Signs are required to direct people from the inside of a building or structure to the outside. Exit signs are required at all exits leading from a building or structure. Lighted signs should be checked to ensure they are working properly. Exit signs are required to be of contrasting colors. 4. No Smoking signs are required to be placed in areas and on materials that are easily ignited. Some areas such as around hydrogen, gasoline, etc., may require that no flames be closer than 50 feet. 5. No Smoking signs may be required inside of buildings where oils and other such flammables are stored. These areas often require doors leading to them to be closed at all times and such doors should not be blocked open. 6. One of the primary areas where NO SMOKING signs are required to be posted are those areas where hydrogen gas is stored and/or used in plant operations. 7. There is No Smoking allowed inside any building on any Entergy site. Smoking areas should be designated, with proper receptacles placed for smoking refuse, and housekeeping should be maintained in these areas.

8 8. Storage facilities such as flammable cabinets require the word FLAMMABLE labeled on their exterior. These cabinets should be placed in a well ventilated area and free from paper and other such easily ignitable materials. They are to be used for storing solvents, paints, fuels, etc. All such cabinets are required to be grounded and vented. 9. Warning signs are required around energized electrical equipment. Electric power load centers need to be properly marked with Danger signs as well as other areas where a contact can be made with electrical equipment. This also includes signs around transformers and switch yards. 10. Warning or Information Signs need to be very visible around such areas as safety eyewash stations and/or safety shower facilities. 11. Safety signs and warning information such as barricade tape/flagging need to be adhered to. The signs are posted and/or barricaded to warn people of potential danger or hazards such as overhead work, hot work, or asbestos work in progress. 12. All tanks are required to be labeled with their contents, even water tanks. This is a requirement under the Hazard Communication Standard of OSHA and the Right to Know Law. Proper labeling becomes very important in times of emergency and as an alert to people working in the area. All signs and labels need to be maintained and replaced with new signs/labels when they become unreadable. 13. All fill/discharge locations need to be well labeled and/or signed to prevent injury and damage to equipment. If multiple connections are in an area, each connection point needs to be identified clearly and plainly. Without clear labeling such connection points can be confusing and result in serious injury and/or equipment damage. Section VII Other 1. Compressed gas cylinders come in all sizes, shapes and colors. Compressed gas cylinders are required to be secured by wire or chain. Rope is not to be used for securing these cylinders. When cylinders are used for cutting/brazing, and not in use, the gauges are to be removed and the safety caps installed on the cylinders. 2. Compressed gas cylinders are required to have their safety caps installed when not in use. They are also required to be properly secured, with a non-flammable partition between the fuel cylinder and oxygen cylinder. This partition should be a minimum of 5 high with a fire rating of at least 30 minutes. 3. Should a compressed gas cylinder tip over without the cap in place, the valve could be broken off allowing the cylinder to become a missile. Compressed gas cylinders should not be used near electrical equipment or flammable materials.

9 4. Scaffolds are to be constructed in such a manner as to provide safety for the worker on the scaffold as well as workers walking or working nearby. If tools and/or materials are to be used on the scaffold it is required to have toe-boards and wire or mesh on the sides to prevent materials/tools from being dislodged and striking someone walking or working nearby or below. Scaffolds are to be tagged with a Red, Yellow or Green tag indicating the status of the scaffold. 5. The Lockout/Tagout Process requires tags to be installed on equipment that has been isolated or taken out of service. The tagging request form should be checked to ensure the procedure is being followed and all sign offs are made for closure of the request. Damaged tags need to be replaced. 6. Danger operation tags are required to be affixed to the equipment they respond to. Some equipment is more readily accessible than others for this process. Proper securing and/or locking of equipment may be achieved with locks or devices manufactured for molded case breakers. 7. All exposed wiring is required to be made safe and if such wiring is not electrical, the wiring should be tagged as to its identity, i.e., communication wiring that can be confused as being an energized electric wire. 8. Chemical/Petroleum product storage requires that all containers be properly labeled with their contents, appropriate drip pans or containers placed under spigots, and appropriate fire protection needs met for the area. This applies to any location where chemicals/petroleum products are used and/or stored. 9. All electrical breaker panels are required to be safe from possible contact with energized components and the breakers labeled with a copy of the legend in the breaker panel. The legend must be clearly readable. All breaker slots must have a breaker in them or closed to prevent contact through the opening. 10. Electrical receptacle face plates must be in place and junction boxes, inspection plates, and pull locations must be properly covered to prevent contact with electrical components and/or damage to conductors/components. 11. Electrical extension cords must be connected to a ground fault circuit interrupter (GFCI) to ensure protection of the worker when using portable equipment. GFCIs need to be checked to ensure they work properly. The GFCI shown here is a multiple connection device. Extension cords are for short term use and those used to power equipment such as soft drink machines or other such items require their power source to be permanently wired. 12. This GFCI is of the single socket type often used in the work place. If an electrical circuit is of the GFCI type, an electrical extension cord may be plugged into the receptacle without an additional GFCI.

10 13. Safety materials and supplies need to be readily available and accessible to employees. Storeroom areas need to be checked to ensure sufficient safety materials are available in the quantities needed for the work site and jobs performed. Section VII WORK AREA PROTECTION 1. When hazards exist in the workplace such as excavations, open manholes, pits, gratings, or equipment parked in work areas that may jeopardize the safety of employees or others, safeguards shall be maintained through the use of barriers, warning signs, lights, barricade tape/flagging, or other hi-level warning devices. 2. When working overhead, suitable warning signs must be placed so they can be readily seen. The areas below overhead work shall be suitably guarded or barricaded. Materials shall be placed to prevent tools and materials from falling to lower elevations. 3. Only employees working inside a barricaded area should enter that area (DANGER only when permission is given and very carefully if it is a CAUTION area). 4. When work conditions warrant, a suitable barricading curtain shall be placed to prevent injury from cutting/welding slag, flashburn, sprayed chemicals, flying chips from metal cutting, or concrete breaking operations. 5. When using barricading tape/flagging the following guidelines are to be used: Notify the Control Room when and where barricading is installed. a. RED Tape/Flagging - This shall be considered as a DANGER area and this tape/flagging is to be used to restrict those areas or jobs that necessitate protecting the general plant population from injuring themselves by entering. An area that is barricaded with RED tape/flagging must not be entered without permission of the person in charge of the worksite that is barricaded. The person installing the barricading is responsible for its removal. b. YELLOW or YELLOW/BLACK Tape/Flagging - This is considered CAUTION tape/flagging and shall be used exclusively to alert or warn personnel of physical hazards such as tripping, slipping, falling, congested work area, etc. The person installing this barricading is responsible for its removal. c. DANGER-ASBESTOS HAZARD - This tape shall be used exclusively for the purpose of enclosing a regulated area. This area can only be entered with the approval of the person in charge of the job. All required

11 PPE must be worn when entering the regulated area. The person installing this barricading is responsible for its removal. d. The following or similar worded signs should be attached to the barricading: DANGER SIGN A solid red sign with black letters. DANGER This area contains the following Hazard(s): Work Being Performed: Person Responsible: Persons Permitted Access: Date Installed: CAUTION SIGN A solid yellow sign with black letters CAUTION This area contains the following Hazard(s): Work Being Performed: Person Responsible: Date Installed: