BASF Corporation Safety & Loss Prevention Manual

Transcription

1 TABLE OF CONTENTS Environmental Protection, Health & Safety Policy - BC032 Preface.. Page i Introduction Management Commitment and Support Responsibility, Authority and Accountability 3 3. Working Conditions that Minimize EHS Impact Training Incident Reporting and Analysis Emergency Procedures and Programs 4 7. Personal Accountability.. 4 Minimum Requirements Guideline 6 I. Management Commitment and Support (in Draft)... 6 II. Responsibility, Authority and Accountability (in Draft). 6 III. Working Conditions that Minimize EHS Impact 6 A. Engineering and Project Review.. 6 B. Operating and Maintenance Procedures 7 C. Medical Programs... 9 IV. Training... 9 A. New Employee Orientation 9 B. New Employee Training. 9 C. Experienced Employee Retraining... 9 D. Supervisor Development Training 10 E. Safety Meetings F. Training Documentation. 11 V. Incident Reporting and Analysis. 11 A. Nonconformance Notification and Reporting - BWP-009 B. Accident/Incident Reporting - BC VI. Emergency Response (in Draft). 11 VII. Personal Accountability (in Draft) Procedures (Located at Policy and Procedures under EHS) Accident/Incident Reporting - BC Category II Safety Instrumented Systems - BC Confined Space Entry BC Contractor Selection, Oversight and Safety Requirements - BC Ecology & Safety Project Reviews - BC Grounding and Bonding - BC Hose Applications - BC /2007 Page i

2 Procedures (continued) Hot Work - BC Inspection and Testing of Metallic Vessels - BC Line Breaking - BC Lock, Tag and Try BC Personal Protective Equipment - BC Portable Ladders BC Powered Industrial Trucks - BC Powered Mobile Platforms - BC Pressure Relieving and Venting Devices - BC Regulatory Inspections - BC Safe Driving Program - BC Safe Work Permit - BC Scaffolds - BC Written Operating Procedures - BC /2007 Page ii

3 PREFACE A strong, aggressive, positive and effective Safety & Loss Prevention Process (S&LPP) is a fundamental component of Environmental, Health and Safety (EHS) excellence and Responsible Care. The S&LPP represents minimum requirements that must be met by all locations and operations in the NAFTA region, including subsidiary and BASF operated joint ventures. The requirements have been defined broadly enough to allow for differences in facility size and type of operations or business but are not intended to be all-inclusive. Each location may need to develop its own requirements and procedures in order to meet the specific needs of that location in addition to those identified here. The applicable safety laws, regulations and codes must be consulted to assure compliance. Where facilities do not meet these minimum requirements, prompt action must be taken by local management to correct any identified non-compliance. A written improvement plan must be developed and implemented according to a firm time commitment. Management has the primary responsibility for BASF Corporation s S&LPP and must communicate and implement these principles into local policy and actions involving every employee. The application of these requirements and principles then becomes the individual responsibility of each and every employee. Professional safety and loss prevention support will be provided by the Ecology & Safety organization to assist management, supervision and employees in carrying out this responsibility. 06/30/2010 Page 1 of 16

4 INTRODUCTION BASF locations operate under a common EHS management system framework. This framework provides the most consistent and effective path to managing activities and pursuing continuous environmental, health and safety improvements. A successful S&LPP is aimed at incident prevention and elimination. It is both a moral obligation and a sound business practice to operate in a safe and environmentally sound manner and is the only acceptable standard of performance. Management is accountable for preventing incidents by: Providing a safe and environmentally sound working environment with the proper equipment to perform each job, Training and motivating supervision to instruct their personnel thoroughly in all aspects of their jobs, including safety and health. Training and motivating each employee to work safely, and Requiring safe operation as a part of each employee s job - making this a condition of employment. The ultimate responsibility for incident prevention rests with each individual employee. All employees are obligated to actively participate in the safety process in order to prevent adverse impact to themselves, their fellow employees, their community and the company. The basic framework of BASF Corporation s S&LPP is the Seven Elements of EHS Process (Seven Elements), which is based on proven, sound management principles: Element 1: Management Commitment and Support EHS is an organizational value, treated equally to other business aspects in decision-making, goal setting and resource allocation. The efficiency and effectiveness of EHS is monitored through a balance of leading and lagging measures Regularly scheduled meetings focused on EHS are a primary mechanism to promote EHS consciousness, hazard awareness, sharing lessons learned and dialog between management and employees. 06/30/2010 Page 2 of 16

5 Element 2: Responsibility, Authority and Accountability Specific, meaningful EHS responsibilities are assigned to and understood by each individual, including management. o Employees at every level are responsible and accountable for their own incident prevention activities. Employees are given the authority to carry out their assigned responsibilities. Employees are held accountable through the assignment of specific performance-based objectives. All individuals are measured and recognized on their individual contributions to the EHS continuous improvement process. Element 3: Working Conditions that Minimize EHS Impact Engineering and procurement standards and inherently safer design concepts are established to provide a foundation for this environment. Risks from chemical and physical hazards are minimized during the development of products and the design/construction of facilities and processes. EHS reviews are conducted on all capital projects and when revisions to existing facilities/processes may create sufficient hazard based upon the findings from the change management review. Systems are in place to assure safe and environmentally sound conditions are developed and maintained: Clear, precise operating, work procedures and instructions are developed and maintained. Inspection and change management procedures verify and ensure ongoing adequacy of the systems. Hazardous conditions and exposures are recognized and action is taken to either eliminate them or mitigate them to an acceptable level. A mechanical integrity program is in place to assure the continued integrity of the process and related equipment. Periodic audits are conducted to measure the effectiveness of process implementation in production, maintenance and support areas of the location. 06/30/2010 Page 3 of 16

6 Element 4: Training Each individual has the skills, knowledge and competencies to conduct their job according to EHS requirements and to recognize/control hazardous conditions in the workplace. o Each location shall have an ongoing developmental learning and communication process for all employees to assure their skills, knowledge, and competencies are maintained. o Systems are in place to assess the effectiveness of training and implement corrections when training deficiencies are identified. Element 5: Incident Reporting and Analysis Employees accept the belief that all incidents are preventable. This is the foundation for a Zero Incident Mindset. Thorough investigations and analysis of all incidents are conducted to identify root causes. Each location will record and investigate incidents according to BASF Corporation, federal and state/provincial requirements. Appropriate corrective actions are implemented to prevent recurrence Incident investigation findings are openly shared across the corporation as lessons learned. Accuracy of the incident report investigation findings will be assessed and periodically reported. Element 6: Emergency Procedures and Programs 1. Written plans are in place to ensure the safety of employees, contractors, neighbors and our facilities and to minimize environmental impact in the event of an emergency o Each facility must have a written emergency plan to address likely scenarios. 2. Plans must be routinely tested through drills, exercises and documented critiques of these events o Each location must complete at least one simulation per year drill or exercise to ensure each person with emergency response responsibilities is included. o Facilities that operate around the clock must complete at least one simulation per shift per year. o An emergency response may count as a drill only if the incident involved an adequate number of personnel (5 out of 20 would not be adequate). o An emergency response must be critiqued and documented. 06/30/2010 Page 4 of 16

7 Element 7: Personal Accountability Each individual establishes a personal value of (1) working safely and in an environmentally sound manner and (2) maintaining a clean and orderly work area. Each individual accepts a personal goal of Zero Incidents Each individual commits to the safety of all and exercises their personal authority to correct recognized hazards. All individuals are recognized and measured on their individual and team contributions to EHS excellence. Individual performance and participation in the location s EHS process is considered an essential part of every employee s total job performance and shall be part of the performance evaluation process. Safety & Loss Prevention Process Verification In addition to local inspections and audits, formal audits will be conducted on a regular basis for manufacturing, warehousing, offices, laboratories and other operating units to ensure acceptable conditions and confirm compliance with BASF Corporation, locally established requirements and governmental regulations. Knowledgeable persons independent of the facility being audited will conduct the audits. They will be performed in a constructive and positive manner, identifying both the strengths and weaknesses of the program, with emphasis on improvement. Written action plans are required to address deficiencies. 06/30/2010 Page 5 of 16

8 MINIMUM REQUIREMENTS GUIDELINE I. Management Commitment and Support Executive management will accept the safety and health process requirements and responsibilities that correspond with their level of authority by: empowering the process with the development and assignment of safety and health roles and responsibilities that correspond with each level of authority; establishing and supporting a system to ensure compliance with all pertinent safety and health regulatory requirements and BASF safety and health policies, procedures, standards, requirements, and guidelines establishing a system of measuring the effectiveness of a location s process by requiring periodic evaluations; establishing an organizational system of sequential safety and health meetings/networking systems; requiring all levels of management to establish strategic planning that integrates and supports key improvement objectives. Executive, senior and middle management will measure the implementation of those assigned safety and health responsibilities within the safety and health process. This flow of information becomes the control system of the process. Each level within the organization will regard their assigned safety and health responsibilities and key improvement objectives as targeted output. As part of the management review process the Site/Plant or business location managers will self-audit the organization's effort. by the reviewing of information, activities, and key improvement objectives of all levels of the site organization to the defined requirements and responsibilities. Information that indicates counter productive shifts in safety and culture, values, and process implementation will be recognized and acted upon. II. Responsibility, Authority and Accountability A. LEADERSHIP (Directors, Business Managers, Site/Plant Managers) Leadership has the ultimate responsibility and accountability for safety performance within their organization. Leadership establishes practices and procedures and outlines the basic safety responsibilities required of all employees. o Listed below are examples of activities that can demonstrate involvement in the safety process. issuance of a policy statement, development of a specific roadmap for EHS improvement 06/30/2010 Page 6 of 16

9 Participation on committees, in safety meetings, task/job observations, incident investigations or Management By Walking Around. Safety related communications to personnel and executive management. Development and maintenance of a workplace evaluation and inspection program with tracking and resolutions of findings in a timely manner. B. MANAGEMENT (Managers, Superintendents, or other positions that have first-line supervisors, team leaders, self-directed work teams as their direct reports). Management is given the authority, responsibility, and accountability for operation of their departments/areas. When Leadership establishes a safety process with assigned responsibilities, Management is then held accountable for implementing the process. These individuals must ensure that all who report to them do likewise in their areas of responsibility. Listed below are examples of activities that can demonstrate their involvement in the process: actively support and communicate the Vision, Values and Beliefs, EHS Policy, 7 Element Process to all department/area personnel. participate in EHS committees and sequential meetings provide regular EHS communication to all personnel. assign specific EHS responsibility, authorities, and accountabilities to include a periodic evaluation of performance and monitoring of process information, develop a roadmap with key improvement objectives that are in line with the strategic planning process and culture development establish KPI s (key performance indicators) for the roadmap require supervision to develop strategic planning that is in line with the roadmap, establish a departmental inspection and health evaluation program with resolutions of findings and tracking in a timely manner. require supervision to provide periodic status of relevant safety workorders and projects, ensure cooperation and department/area participation in corporate EHS audits ensure implementation and execution of procedures and practices that will establish the reporting of all incidents personally review all incident findings that occur within their department/area and ensure causal factors and appropriate corrective actions are identified and tracked, 06/30/2010 Page 7 of 16

10 ensure fair and consistent enforcement of EHS policies, procedures, and practices, C. SUPERVISION Supervision is responsible for safety concerns of its operation. This responsibility covers employees, equipment, materials, and methods. They are required to provide adequate safeguards against known or potential hazards through communication, by furnishing proper equipment, materials, by training employees, and by achieving employee participation in the safety process. Management expects the immediate supervisor more than anyone else to set a good example of safe and environmentally sound work practices. Listed below are examples of activities for supervisors to demonstrate their involvement in the process: lead through participating in safety committees and sequential safety meetings with direct reports safety communications to plant personnel and plant management, require that direct reports communicate: I incidents, including contractors facility/equipment deficient conditions operational procedural changes, etc. personally review all /incidents that occur within their department/area and ensure causal factors and appropriate corrective actions are identified and tracked, assume authority, when empowered, to implement, direct, and control specific courses of action. enforce application and implementation of relevant regulations, codes, standards, and practices to identify and meet process and occupational safety requirements. establish area inspections, health evaluations, and safety workorder tracking programs develop clear and concise instructions for all tasks with potential safety negative impact or personal injury as well as process manufacturing and maintenance procedures execute and coordinate the site/plant emergency plan, including testing and drills, within the department/area, participate in activities and systems that develop, maintain, and enhance safe behaviors of subordinates, especially immediate, positive reinforcement. ensure fair and consistent enforcement of EHS policies, procedures, and practices, 06/30/2010 Page 8 of 16

11 E. HOURLY OR NON-EXEMPT EMPLOYEES All employees have a responsibility to themselves, their families, their fellow workers, the community, and their employer to work in a safe and environmentally sound manner. While accepting this responsibility in the performance of their duties, they shall be expected to participate in the Seven Elements. This participation will consist of knowing and accepting those specific safety responsibilities that apply to their job and their facility. Listed below are examples of activities that employees can demonstrate their involvement in the process: lead and participate in monthly safety meetings participate on standing or ad hoc safety committees or teams identify and support the implementation and subsequent evaluation of their respective roadmap key improvement objectives and measures know and understand their EHS responsibilities and accountabilities described in the Seven Elements. Actively participate in the following processes: hazard reviews, management of change, IH monitoring, safety inspection/audits, development of safety rules/procedures, Task or Job Safety Observations/Analyses, incident investigation, emergency response planning/drills, safety suggestions positive reinforcement of co-workers and contractors, constructive coaching of unsafe conditions or behaviors, know and maintain excellent housekeeping standards participate in safety training through assessment, development, attendance or feedback n these areas: safety rules, operating procedures, new/transferred employee orientation, IH programs/procedures, emergency procedures and safety awareness or skills understand and adhere to requirements to report all incidents (medically treated injures, minor injures, first-aid cases, property damage, vehicle, fires, spills, releases. near-hits, consistently communicate the culture and values of BASF. III. Working Conditions that Minimize EHS Impact A. Engineering and Project Reviews Engineering design forms the foundation for providing safe and environmentally sound working conditions. It is essential EHS considerations be included in the early design phase of all projects. It is important that every phase of all capital and expense work be reviewed from the EHS viewpoint. Equipment procurement, material selection and construction must be closely reviewed and checked. The following references must be reviewed for applicability: 06/30/2010 Page 9 of 16

12 1. Engineering Standards Facilities must be designed and constructed to meet the applicable governmental regulations, codes and BASF Corporation Technical Standards to permit safe operations. 2. Design and Layout Process Design Processes will be reviewed and evaluated to both identify EHSrelated hazards as well as the risk associated with those hazards, including those that may be caused by improper operation or malfunction of the process. A formal, systematic method of evaluation shall be used to identify potential problem areas and incorporate appropriate EHS prevention measures. The design will incorporate the latest technology with fail-safe and redundancy as needed. Where global safety concepts have been identified, they shall form the design basis. The principles of inherently safer design will be considered where possible. Plant Layout Safety factors, such as egress from and access to equipment will be considered in plant layout to achieve optimum equipment placement, flow of process materials and separation of process units. Consideration must also be given to: (1) human factors and appropriate ergonomic equipment installed and (2) future expansion. Building and Structural Design Design guidelines and proper materials of construction shall be used to provide protection against losses from fire, explosion or natural forces such as flood, wind, earthquake and electrical storms. Building and structural design shall conform to the prevailing building codes. Protective Systems and Equipment Protective systems and equipment shall be designed, purchased and installed in accordance with recognized standards. Protective systems will be reviewed and approved by the appropriate insurance carrier and loss prevention specialists. Ecology & Safety Project Reviews All capital projects must comply with the BASF Group Directive for Ecology & Safety Project Reviews and BASF Corporation Procedure Ecology & Safety Project Reviews BC Contractors Each location that uses contractors will have a written program that provides for adequate safety qualification, oversight and review of contractors performing work on engineering projects. (Contractor Selection, Oversight and Safety Requirements - BC ) 06/30/2010 Page 10 of 16

13 Insurance Interface All major projects shall be reviewed with the appropriate Loss Prevention specialists for concurrence in the design, construction and operation of the facility. B. Operating and Maintenance Procedures 1. Written Instructions Each location shall develop written procedures for equipment use and work tasks. They will be designed to standardize the safest and most efficient method to perform a task, operate equipment or perform periodic maintenance or repairs to equipment. These procedures may be in the form of a total job analysis, essay, rules, etc. They must, at a minimum, include the key steps of the operation in chronological order; the associated hazards, steps that must be taken to eliminate the hazard or precautions to use when the hazard cannot be eliminated. A safe work permit must be used for unusual tasks with safety implications that do not have an established operating procedure. (Written Operating Procedures - BC and PSM/RMP Guide Operating Procedures) 2. Personal Protective Equipment - BC Chemical and Physical Hazard Identification and Control Identification and control information shall be maintained for: (1) all chemical substances used, stored or produced at a location and (2) physical hazards to which individuals may be exposed. Each location must develop and maintain a written hazard communication program that provides a means of informing personnel about the hazards of the chemicals they work with or around, how the hazard information is provided and precautions that should be taken. Each location that handles hazardous chemicals must develop and maintain the Industrial Hygiene Exposure Assessment Standardized Process to evaluate, monitor and maintain records of personnel exposures. Where exposure to a chemical or physical agent is found above an occupational exposure limit, action to reduce this exposure will be taken. Appropriate engineering controls shall be the primary means of exposure control, with personal protective equipment used only as a temporary measure or when engineering controls are not feasible. (Exposure Assessment - BWP-008 [RCMS]) 06/30/2010 Page 11 of 16

14 4. Safe Work Procedures Contractor Selection, Oversight and EHS Requirements BC PSM/RMP Guideline: Contractors Confined Space Entry BC Line Breaking BC Lock, Tag and Try BC Grounding & Bonding BC Hot Work BC PSM/RMP Guideline: Hot Work Hose Applications BC Portable Ladders BC Powered Industrial Trucks BC Powered Mobile Platforms BC Safe Driving Program BC Safe Work Permit BC Scaffolds BC Pressure Vessels and Relief Devices All pressure vessels and relief devices shall be registered, inspected and tested as scheduled to assure damage or ruptures do not occur. A documented log of this information shall be maintained for the life of the equipment. (Inspection and Testing of Metallic Vessels - BC and Pressure Relieving and Venting Devices - BC ) 6. Preventive Maintenance Each location shall establish a preventive maintenance program for all equipment and systems. Inspection and maintenance of equipment safety devices, critical alarms and instrumentation installed specifically for environmental, health or safety reasons shall be emphasized. No process or equipment on which a local exhaust ventilation system has been installed for occupational exposure protection or fire control shall be operated when the exhaust system is not functioning properly. The user shall establish a program of preventive and scheduled maintenance. Manufacturers recommendations for the maintenance of local exhaust ventilation system components shall be included in the maintenance schedule. Maintenance personnel responsible for local exhaust systems shall be instructed on its proper operation and the reason for the installation. 06/30/2010 Page 12 of 16

15 The program will establish frequency of the inspections, minimum standards for the inspections and recordkeeping. Records should include conditions found and corrective actions taken. Both the owner and maintenance responsibilities must be defined in the program. Safety Instrumented Systems BC Inspection and Testing of Vessels BC Grounding & Bonding BC Hose Applications BC Pressure Relieving and Venting Devices - BC C. Medical Programs Each location must establish a medical program to monitor, evaluate and protect the health of employees according to Corporate Medical Policy - BC009 and all associated procedures. IV. TRAINING The ability of employees to perform their jobs safely, in an environmentally sound manner and efficiently is highly dependent upon their job knowledge and skill, which is influenced by how well they were provided instruction and guidance. Effective training results in fewer mistakes, incident reduction, fewer delays and lower overall operational costs. In addition, less supervision is necessary in the long run. It is easier to educate employees on how to form good (safe) habits while learning their jobs than it is to correct bad (unsafe) habits later. All management and employees will receive training in the fundamentals of the safety process and information as to each person's role in the implementation of the process. The following are some of the required training programs beyond the minimum EHS initial and recurring regulatory topics: A. New Employee Orientation Proper safety orientation of new employees is important to instilling the proper attitude and awareness from the onset of employment with BASF. Therefore, a safety orientation must be conducted with each new employee prior to assignment of regular duties. The manager, immediate supervision or EHS will perform the orientation. Emphasis should be on the close relationship between safety and general performance efficiency. When an employee is re-assigned to another department, the supervisor explains the applicable rules, protective devices and emergency actions prior to task assignment. B. New/Reassigned Employee Task-specific Training - Initial New or reassigned employee task training must include review of the written procedures for that task and job instruction training conducted by 06/30/2010 Page 13 of 16

16 the supervisor or other qualified instructor. A copy of the procedure should be available for quick reference. Prior to the employee performing the task alone, their performance should be formally assessed for competency. Periodic follow-up is necessary to assure adherence to the procedures and promote a thorough understanding of the task. C. Experienced Employee Retraining 1. Employees shall periodically review written procedures of all the tasks they perform. Procedures for infrequently performed tasks should be reviewed just prior to performing the task. The reviews can be performed in a number of ways: discussion in a shift safety meeting, individually or as a member of an ad hoc team. Follow-up job observations may be necessary to ensure understanding. 2. When employees experience an extended absence from work, written procedures should be reviewed before performing the task alone. 3. Employees shall also receive training when an incident occurs where lack of knowledge or skill was a cause. The retraining will include focus on the area of deficiency and a means to ensure understanding. D. Supervisor Development Training Supervisors are key to subordinates morale, work efficiency and safety commitment. They must be knowledgeable in their safety duties and the significance of their responsibilities. Supervisory training, education and development should be an ongoing process to constantly stimulate and motivate achievement to higher levels of safety performance. E. All training must be documented; attendance and successful completion must be recorded. Training materials and other sources of information used should be maintained. F. Safety Meetings 1. Safety meetings are training sessions that can heighten awareness, increase efficiency and improve morale. They provide a means to communicate BASF s commitment to safety and provide a forum to identify and discuss department issues. 2. A safety meeting program shall be established for each site or organization. At least monthly face-to-face sessions will be conducted for employees involved in production, maintenance, warehousing and laboratory operations. For office, remote and sales personnel, periodic meetings will be held at least once a quarter to provide and share pertinent safety information. 3. While training is not a required agenda topic, the safety meeting forum is an excellent opportunity to focus on department specific safety items. - These include incident investigation results, safety performance including department KPI's or general information related to department-specific activities. 06/30/2010 Page 14 of 16

17 4. When employees are unable to attend these meetings, there must be a mechanism to ensure the information is provided. 5. EHS meeting attendance must be documented. V. Incident Reporting and Analysis 1. Standardized Process - BWP-009 [RCMS] 2. Accident/Incident Reporting - BC VI. Emergency Response EMERGENCY PLANNING Two levels of emergency planning should be conducted by the site: 1. That which is done for emergencies that are completely contained within the boundaries of the site and present no danger to persons or properties outside those boundaries. 2. That which has potential for offsite impact and includes the coordination of planning efforts with local governmental or response agencies or with other facilities. The planning effort should address: o Identification of all response personnel and their roles, responsibilities, and authorities. o Identification of on-site and community resources that may be required. o General response procedures (alerting, warning, communication, evacuation, escape route assignments, accounting for employees/contractors, medical services, reporting requirements/procedures) o Strategies for specific emergencies (fires, spills, releases, etc). o Preparedness procedures (training, drills, exercises). o Hazardous materials response plan and team procedures (where applicable). o Hazard specific procedures (power outage, severe weather). o Community planning including public notification, alert procedures, response support from outside services. TESTING THE PLAN An emergency exercise plan will be established to simulate emergencies to maintain a high level of preparedness and periodically test the adequacy of the plan and training. The types of exercises to be used include "What-if" drills, emergency simulations, field drills and full scale exercises involving the response system of a facility and the community services. 06/30/2010 Page 15 of 16

18 VII. Personal Accountability Each site will implement and encourage participation in safety activities. These have a three-fold purpose. 1. reinforce employee knowledge and skill in the safe performance of job requirements. 2. promote safety awareness and mind-set that is a vital component in the acceptance of personal accountability. 3. support the safety culture and values of BASF Corporation. These activities can include: Individual EHS Contacts: These will be planned, brief one-on-one discussions about some specific aspect of workplace safety and health. The contact may refer to a specific safety and health procedure, an operating procedure or to some aspect of a job that has the potential to cause an incident. These contacts are made to enhance or maintain safety and health performance, awareness and mind-set and are to be done in a positive context. Task or Behavioral Safety Observations: These are planned training and coaching of actual jobs or tasks. They can be conducted by management, supervision or employees. The purpose is to generate safety awareness of hazards, provide positive reinforcement for safe behavior, correct unsafe behavior through consensus, and to assess the training and inspection needs of the organization. In addition, they can provide incident prevention data to be used in the Safety and Health training needs assessment. These assessments are to provide before-the-fact incident prevention data that can be used to identify areas where requirements must be upgraded. Employee Coaching and Counseling: On a scheduled basis site personnel participate in coaching and counseling sessions. These sessions will be used to review the past performance of the employee and determine an action plan related to safety and health activities for that employee and their supervision. DISCIPLINE All employees must know that compliance with safety and health procedures is not optional or discretionary. Management and employees must understand that compliance with safety and health procedures is a condition of employment. In cases of a willful transgression of a safety procedure in which an employee shows a disregard for the safety of other employees, his/her own safety, or the safety of the public, immediate use of disciplinary sanctions will be used. 06/30/2010 Page 16 of 16