Environmental, Health & Safety Policy

Purpose

Provide a place of employment free from hazards which may cause illness, injury, or death to our employees. 

Establish an effective and continuous safety program incorporating educational and monitoring procedures maintained to teach safety, correct deficiencies, and provide a safe, clean working environment.

Definitions

• DOT – Department of Transportation
• OSHA – Occupational Safety and Health Act 
• EPA – Environmental Protection Agency

Responsibilities

Facility Management is responsible for the enforcement of safety policies and practices. They must ensure that staff members are trained in appropriate safety procedures.  Complete the necessary forms if an accident or work-related health problem occurs.  Training is completed and records kept.

EH&S Representative – Responsible for ensuring Environmental, Health & Safety risks are identified through t analysis and Management Programs are implemented  proactively to manage EH&S Risks.

All Employees are required to comply with all federal, state, local and company rules and regulations relevant to their work.  Observe all company rules and regulations related to the efficient and safe performance of their work.  Report or correct unsafe equipment and practices.  Report any accidents that occur while on the job.

Types of Written EH&S Plans Addressed

Because we care about our employees and strive to provide a safe workplace, we have put into place a number of written safety plans. These written plans provide guidance and direction for the safety issues they cover. The topics covered in written safety plans include the following:

• Accident Reporting & Investigation
• Emergency Preparedness & Evacuation
• Fire Prevention
• Hand and Power Tools
• Hazard Communication
• Personal Protective Equipment

EH&S Management System Certification

Elite Cellular will maintain integrated certification to QEHSMS Standards from an accredited certification body to the R2 and RIOS Standards.

All documents and relevant records to demonstrate conformance will be kept for 3 years.

Environmental Health & Safety Risks – Identified and evaluated annually.

QEH&S Goals are documented and tracked.  Goals are developed in line with ranked environmental and health & safety risks.

The EH&S specialist will have a direct communication avenue with employees.  This is done via safety meetings, phone communications, email communications.

Worker Care:

Elite Cellular maintains Workers Compensation Insurance and provides the same level of care to all employees, volunteers, contractors and others.

Elite Cellular maintains First Aid kit in the facilities for minor response to injuries.

Accident/Exposure Investigations

Although every effort is made to prevent workplace injuries and illnesses, we realize that accidents can happen, and we are prepared to handle these unexpected situations.

If an accident occurs in our establishment, employees must notify the Management and seek appropriate medical attention.  

• After the risk has been mitigated, use the Accident Incident Reporting Form to document the injury and investigate the injury.  
• Only injuries that require severe medical treatment or death that need to be reported to OSHA shall be done within 5 days of the accident.
• Injuries or illness investigations should be investigated and if deemed necessary corrective actions should be implemented.

OSHA Injury/Illness Recordkeeping and Reporting

Yearly Summary Logs:

According to 29 CFR 1904.29, Record and Reporting Occupational Injuries and Illness, all injuries meeting the criteria of a recordable case must be recorded and reported using the OSHA 300 form (latest revision), Log of Work-Related Injuries and Illnesses, or comparable in-house form. This information must be recorded on the summary log within 7 days of the first report of the incident.

At the end of every calendar year, the manager will review all cases for the year to ensure all reports are summarized correctly on the OSHA 300 A Log. 

It is imperative that only recordable injuries are recorded on the OSHA 300 A form. Once again recordable injuries are those injuries that involve:

• Loss of consciousness;
• Restricted work activity or job transfer;
• Days away from work;
• Medical treatment beyond first aid;
• Or any work-related injuries that meet any of the specific recording criteria listed in the 29 CFR 1094.8.

OSHA Reporting Regulations and Requirements:

Anti-Relation Protection – the rule prohibits from discouraging workers from reporting an injury or illness or relating or discriminating against any employees who report injuries or illnesses.  The final rule requires employers to inform employees of their right to report work-related injuries and illnesses free from retaliation.

Posting Requirements

The OSHA 300 a log is posted by February 28th of each calendar year in all facilities.

The form will remain posted until April 30th of that same year. 

This form must be posted even if there are no injuries or illnesses to complete for the previous year. If there were no cases a “0” must be inserted into the blanks where appropriate.

Emergency Response 

Plans for emergency actions are documented in EHS-02 Emergency Preparedness Plan.

Fire Prevention 

Any material with potential to cause a fire will be stored according to OSHA/EPA regulatory requirements.

Fire extinguishers are only to be used by designated and trained personnel. In addition, all of the following must be in place:

• The employee must feel comfortable using a fire extinguisher.
• There must be a safe escape route at all times.
• The employee must not utilize more than one extinguisher for the fire.

Selection and Distribution

Portable fire extinguishers shall be provided for employee use and selected and distributed based on the classes of anticipated workplace fires and on the size and degree of the hazard which would affect their use:

• Class A: Ordinary combustibles or fibrous material, such as wood, paper, cloth, rubber and some plastics.
• Class B: Flammable or combustible liquids such as gasoline, kerosene, paint, paint thinners and propane.
• Class C: Energized electrical equipment, such as appliances, switches, panel boxes and power tools.

Location of Fire Extinguishers

Fire extinguishers are to be mounted in easily accessible locations that are indicated by a sign that reads “Fire Extinguisher”. 

Inspection, Maintenance and Testing

All fire extinguishers shall be maintained as follows:

• Fully charged and in operable condition
• Clean and free of defects
• Readily accessible at all times
• An annual maintenance check by a certified professional.
• Fire extinguishers are to be inspected and recharged by certified personnel after any use and when any fire extinguisher shows a loss of pressure

Use PASS System to extinguish the Fire.

1. Pull the pin at the top of the extinguisher. 
2. Aim at the base of the fire, not the flames. 
3. Squeeze the lever slowly. This will release the extinguishing agent in the extinguisher.
4. Sweep from side to side. 

Hand and Power Tools

Hand tools being used shall be of an approved type and maintained in good condition.

Tools are inspected on Monthly Facility Inspections.

Employees have the authority and responsibility to condemn unsafe tools.

Employees shall use the proper tool for the job to be performed.   

Makeshift and substitute tools shall not be used.   

Hammers with metal handles, screwdrivers with metal continuing through the handle, and metallic measuring tapes shall not be used on or near energized electrical circuits or equipment.  

Impact tools such as chisels, punches, and drift pins that become mushroomed or cracked shall be dressed, repaired, or replaced before further use.  

Tools with sharp edges shall be stored and handled so that they will not cause injury or damage.  They shall not be carried in pockets unless suitable protectors are in use to protect the edge.  They shall not be carried in pockets unless suitable protectors are in use to protect the edge. 

Wooden handles that are loose, cracked, or splintered shall be replaced.  The handle shall not be taped or lashed with wire.  

Tools shall not be left lying around where they may cause a person to trip or stumble.  

Hazard Communications

Our chemical inventory is a list of hazardous chemicals known to be present in our workplace. It is located in the SDS binder.  

Anyone who comes into contact with the hazardous chemicals on the list needs to know what those chemicals are and how to protect themselves. That is why it is so important that hazardous chemicals are identified, whether they are found in a container or generated in work operations.  

The EH&S Representative updates the inventory as necessary.  After the chemical inventory is compiled, it serves as a list of every chemical for which an SDS must be maintained.

The EH&S Representative is responsible for obtaining/maintaining the SDS’s at our facility.  All new procurements for the company must be cleared by the CEO, who in-turn will obtain the SDS sheet and update the chemical inventory.  

New chemicals, such as cleaners, should be selected with the hazards considered prior to purchase.  All steps should be taken to select items that are not flammable, caustic, hazardous, or present any other dangers to employees.  When it is not feasible, then the hazards of the chemicals must be planned for to ensure the proper safety equipment and handling is in-place prior to usage.

The EH&S Representative is responsible for ensuring that all hazardous chemicals are properly labeled and updated, as necessary.  He/she also ensures that newly purchased materials are checked for labels prior to use.

Personal Protective Equipment

All personnel and visitors in the facility will be required to wear appropriate personal protective equipment (PPE) in light of the risks posed by the location and the activities.  

PPE must be inspected and maintained prior to usage to ensure effectiveness.

When the need for appropriate PPE cannot be determined, it will be used as a precaution.

The following table lists specific PPE requirements, but may not be inclusive of all activities as they change often.

PPE Requirements

Maintenance of PPE

Facility Management, i.e., Supervisors, shall ensure that employees have adequate supplies and facilities to maintain required PPE. These persons are responsible for ensuring compliance with cleaning responsibilities by Employees.

PPE needing repair or replacement must be brought to the attention of the Employee’s Manager or the HSE Coordinator.

Employee Training

Training is provided to all employees based on job role, work assignments. 

I. POLICY

It is the policy of this company to take every possible action to comply with all emergency regulations and protect employees in emergency situations.

II. EMERGENCY PLAN COORDINATOR 

The CEO, known as the emergency plan coordinator, is responsible for making sure this emergency action plan is kept up to date, practiced, and reviewed periodically.

The Emergency Plan Coordinator can be reached at 2209 Regency Drive, Irving, TX 75062 (214) 956-0500 (location and phone number).

III. REPORTING PROCEDURES

Reporting procedures must be submitted in writing, including via email, except in the case of emergency. Emergency notifications are verbally passed on to Management.

IV. EVACUATION PROCEDURES

A. Emergency Escape Procedures and Routes 

Emergency escape procedures have been trained by supervision in the correct procedures to follow. New employees are trained when assigned to a work area.

B. Procedure for Employees Who Remain to Operate Critical Operations Before They Evacuate 

During some emergency situations, it will be necessary for some specifically assigned and properly trained employees to remain in work areas that are being evacuated long enough to perform critical operations. These assignments are necessary to ensure proper emergency control.

The following lists these employees and their duties:

The preceding individuals have received special instructions and training by their immediate supervisors to ensure their safety in carrying out the designated assignments. A training record describing the instructions provided and the detailed procedures to be followed is maintained in the Office Manager’s Office.

C. Employee Accountability Procedures after Evacuations

Each supervisor is responsible for accounting for all assigned employees, personally or through a designee, by having all such employees report to a predetermined designated rally point and conducting a head count. Each assigned employee must be accounted for by name. All supervisors are required to report their head count (by name) to the Emergency Evacuation Coordinator, Shairose Ali. A summary of the evacuation rally points, together with the identities of supervisors and assigned employees who must report to each, is included with this plan.

D. Alarm System 

Describe the alarm system to be used to notify employees (including disabled employees) to evacuate and/or take other actions. The alarms used for different actions should be distinctive and might include horn blasts, sirens, or even public address systems.

Alarm systems for notifying all employees in case of an emergency are: 

E. Sheltering in Place

In the event of a need to move to an interior room with no windows, employees shall move to the production room and take cover if appropriate. The production room is marked as the Emergency Shelter Area.

F. Training

The following personnel have been trained to assist in the safe and orderly emergency evacuation of other employees. 

Training is provided for employees when: 

• The plan was initiated 
• Responsibilities change 
• New employees are hired or transferred 
• At least annually

G. Periodic Evaluation of Program

Periodic evaluation of the Emergency Preparedness and Evacuation Program will be conducted to ensure all regulations are met and that all employees are adequately trained on all current evacuation procedures.

This periodic evaluation will be documented using Emergency Evaluation Form.  Once completed, it will become part of facility recordkeeping.

V. FIRE EXTINGUISHERS

Fire Extinguishers are located in the kitchen, lobby, production room and warehouse. Use of Fire Extinguishers shall be at the discretion of Management or Supervisor.

VI. EMPLOYEE ACCOUNTABILITY PROCEDURES FOLLOWING AN EMERGENCY EVACUATION

Each supervisor is responsible for accounting for each assigned employee following an emergency evacuation. The following procedures apply:

1. Rally points have been established for all evacuation routes and procedures. These points are designated on each posted work area escape route. 
2. All work area supervisors and employees must report to their designated rally points immediately following an evacuation. 
3. Each employee is responsible for reporting to his or her supervisor so that an accurate head count can be made. Supervisors will check off the names of all those reporting and will report those not checked off as missing to the Emergency Evacuation Coordinator. 
4. The Emergency Evacuation Coordinator will be located at one of the following locations: 
   1. Primary Location: Business parking lot located across Regency Drive when exiting dock doors or front door
   2. Secondary Location: International Parkway for those exiting the back production exits 
5. The Emergency Evacuation Coordinator will determine the method to be utilized to locate missing personnel in each situation. 

VII. RESCUE AND MEDICAL DUTIES 

It may become necessary in an emergency to rescue personnel and perform some specified medical duties, including first-aid treatment. All employees assigned to perform such duties will have been properly trained and equipped to carry out their assigned responsibilities properly and safely. 

(Most small businesses rely on local resources such as hospitals or fire departments to provide rescue and medical services. Where that is the case, list those resources. If employees have such duties include a list of these individuals and the training they have received.)

Special Instructions and Procedures 

All personnel performing emergency rescue and medical duties must follow these instructions:

• Call 911

• Contact AJ Jamal 214-995-3700

VII. EMPLOYEE TRAINING

Employee training shall occur at least on an annual basis for this emergency action plan

VIII. CONTACTS 

For more information about this plan, contact the Emergency Action Coordinator.

The following people should be contacted during off-hours emergencies: 

• AJ Jamal 214-995-3700