ESS’ HEALTH AND SAFETY PROGRAM

I. INTRODUCTION

ESS provides on-site spiking services to Fortune 500 chemical & pharmaceutical manufacturing facilities and remediation sites which are conducting CAA/RCRA/TSCA/CERCLA tests on hazardous waste combustion (HWC) units. Specifically, ESS provides complete heavy metals, ash, and POHC spiking services to owner/operators of HWC units in support of informal miniburns and formal Trial Burns (RCRA, TSCA, & CERCLA), Comprehensive Performance Tests (CAA, HWC MACT) and Re-Certification of Compliance Tests (RCRA, interim status BIFs).

To successfully complete this service, ESS personnel must safely perform the following functions with ESS’ spiking equipment:

1. Set-up and operate;
2. Decontaminate (e.g., by pumping mineral seal oil through the closed pumping/tubing system into the HWC device), disassemble (the cleaned equipment), and pack for transport to ESS’ shop; and
3. Maintain & repair (at ESS’ shop).

These spiking systems may contain or have contained:

1. Heavy metals in the form of:
   1. A dispersion (of very fine TiO2 & insoluble metal oxides particles suspended in an oil or aqueous matrix), and/or
   2. An aqueous solution; and/or
2. Volatile/semi-volatile organic compounds, such as Perchloroethylene (perc), Monochlorobenzene MCB), and Naphthalene in a Toluene solution.

The purpose of this safety plan is to detail the measures ESS’ has adopted to protect its personnel during the completion of these duties. This plan will be reviewed annually and revised whenever the need for more protective measures is identified. Additionally, every ESS employee will be trained on this plan prior to completing any on-site spiking function or opening any spiking equipment which has been used with heavy metals or POHCs and will be retrained and tested annually as part of ESS’ Annual Technician Certification program as described in ESS’ QA Plan.

DEFINITION OF ESS PERSONNEL WORK RESPONSIBILITIES AND A SUMMARY OF HEALTH & SAFETY RELATED HAZARDS OR EXPOSURES

ESS personnel fall into three primary work function categories:

1. Spiking Technicians (Techs) set up, operate, decontaminate, and disassemble the spiking systems and have the greatest opportunity for exposure to site specific and spiking material related hazards. As a result of this potential for exposure, spiking technicians will be required to meet the most stringent health & safety precautions.
   At a minimum, ESS requires that all spiking technicians:
   1. Maintain compliance with OSHA 1910 (40 hour initial & 8 hour annual refresher) training*,
   2. Meet annual medical monitoring* requirements, as described herein, and
   3. Satisfactorily complete annual training/testing on this safety plan.
      * As a condition of employment, all ESS technicians must receive these training and medical monitoring examinations annually and provide a clear copy of the training certificate & drug screen results to the Spiking Coordinator.
2. The Spiking Coordinator (SC) interfaces with the client’s representative(s), ESS’ Project Manager (PM) and with the Spiking Techs to implement each project-specific spiking plan, as defined by the ESS PM. The SC works with the PM to ensure that all personnel, materials, equipment, etc., are available when needed. The SC responsibilities are strictly administrative without opportunity for test site exposure. Therefore, the SC is not required to meet the safety precautions required of the PM and Techs.
3. The ESS Project Manager (PM): handles initial client contact & is the primary ongoing contact with the client &/or clients test manager; defines the project scope; prepares (w SC) proposals/project-specific spiking plans based on the clients’ needs, agency requirements, and ESS’ standards and experience; and prepares the spiking report based on test data provided by the spiking technician(s). The majority of the PM’s responsibilities are technical and administrative and are not usually performed in the plant site where opportunity for exposure is greatest. The PM does, however, have on-site responsibilities including periodic job safety inspections, and will, therefore, be required to meet many of the training and monitoring requirements for the Spiking Technician. The ESS PM is required to maintain current OSHA 1910 Training & Medical Monitoring.

ESS personnel (primarily technicians) may be exposed to three major types of risks while carrying out these ESS assigned tasks:

1. Traffic-Related Hazards (Driving to and from the client’s Test Site):
   To minimize traffic-related hazards, ESS requires that Spiking Technicians who drive to/from the test site through routine traffic:
   A. Possess a valid Texas (or other) State Drivers’ License,
   B. Maintain all vehicles used for ESS work in “safe working order” (i.e., at a minimum, pass annual state safety inspections),
   C. Maintain a safe driving record, and
   D. Drive safely, defensively, and in observation of all state highway safety laws. Defensive driving precautions are discussed in tool box safety meeting prior to every mobilization.
2. Host Test Site Operations-Related Hazards:
   Since ESS conducts its work at chemical and pharmaceutical plants, and remediation sites; ESS’ technicians are exposed to the same test site-specific hazards as are client employees. Clients provide detailed on-site (& off-site, as needed) site-specific safety training for contractors who work at their site. This training covers these hazards and the precautions needed to minimize exposure and adverse effects. Test-site specific hazards are generally identified and avoidance measures discussed in videos provided by client facilities. ESS believes that the OSHA 1910 and ESS’ annual safety training combined with the client provided site-specific training address these site-specific hazards. ESS personnel are required to complete this training and meticulously follow all site specified precautions while at client’s test facilities.
3. Spiking Material Exposure Hazards (Exposures):
   Spiking materials used for ESS projects include heavy metals in the form of fine particles dispersed in a water/oil-based matrix, aqueous solutions, and/or volatile and semi volatile organic liquids.
   A. ESS Spiking Techs are required to fully understand and employ all safety precautions prescribed to avoid eye, dermal, oral, and inhalation exposures/contact which can occur as a result of improper handling of these spiking materials.
   B. Techs are required to use appropriate PPE.
   C. Techs are required to use ESS provided equipment to avoid back strains. Because ESS technicians must move several pieces of equipment (@ 50 lb each) in the course of their on-site responsibilities, they are provided with hand trucks, and heavy-duty carts to ease lifting and moving strains. ESS Techs are expected to use this equipment safely and to request additional help from site personnel when necessary to avoid back strain, etc.
   The hazards associated with exposure from spiking materials are discussed in more detail in Section IV.

DEFINITION OF ESS ASSIGNED SAFETY RESPONSIBILITIES

1. Owner’s/PM’S Safety Responsibilities
   A. Define Regulatory & Job Specific (Hazard/Exposure Based) Safety Requirements
   B. Develop ESS’ Health & Safety Program/Plan in Response to These Identified Hazards & Requirements
   C. Establish an Environment Where “Safety Comes First” Is Known & Understood by All ESS Employees.
   D. Establish ESS as a Drug Free Firm & Communicate that Policy to All Employees
   E. Allocate Company Resources as Needed to Support a Strong Safety Program
   (1) Scheduled Safety Training & Meetings
   (2) Provide All Necessary PPE
   F. Assign Safety Responsibilities to All ESS Employees in Accordance w ESS’ Safety Program
   G. Conduct Periodic Audits, Assessments, and Reviews of the Safety Program, Employee Adherence to their Responsibilities to the Safety Plan, and ESS’ Safety Performance
   H. Enforce ESS’ Policies as Necessary to Maintain a Safe Work Environment
2. Technicians
   A. Maintain Current Status with All Safety Training & Medical Monitoring Schedules
   B. Understand & Follow All Safety Precautions, Programs, & Requirements
   C. Proactive Participate in Identifying & Avoiding Hazards to Themselves, Others, & Property in the Work Place
   D. Bring Identified Hazardous Conditions to the Attention of the Client’s Contact & ESS’ PM
   E. Use/Follow All Designated PPE, SOPs, & Precautions
   3. Coordinator
   A. Follow all Safety Policies and Requirements in the Execution of Responsibilities
   B. Assist ESS’ PM & Technicians as Needed

POTENTIAL EXPOSURE ROUTES AND EXPOSURE ROUTE SPECIFIC SAFETY PRECAUTIONS

1. Heavy Metal Dispersions and Aqueous Solutions:
   The potential exposure routes for the heavy metal dispersions and aqueous solutions are eye/dermal contact or oral ingestion from contaminated hands. It is highly unlikely that these materials would ever be sufficiently finely divided (atomized) that they could be suspended in the air, possibly resulting in respiratory exposure.
   The precautions exercised to avoid exposure to heavy metals dispersion and solutions via eye/dermal contact and oral ingestion from contaminated hands/gloves include:
   A. Maintain full OSHA 1910 Training including Annual 8-Hour Refresher Training.
   B. Acquire all site-specific safety training and HWC facility training. Adhere meticulously to all prescribed safety requirements. ESS personnel hold toolbox-trainings prior to every job.
   C. Read the MSDSs associated with each spiking material upon arrival at the test site (before opening containers) and adhere to precautions provided.
   D. Inspect the job site routinely for unsafe conditions and report unsafe conditions to the client contact and/or ESS PM before endangering yourself or others.
   E. Avoid drips, etc., from spiking systems and immediately clean up even small drips. Properly dispose of any contaminated cleaning materials, PPE, etc., at the client’s site in accordance with all client directions/requirements in order to minimize further contamination, secondary contamination, or exposure.
   F. Use appropriate gloves and other PPE to prevent the possibility of contacting the spiking material with the skin. Since the dispersions are composed of fine particles of chemically stable metal compounds (typically insoluble oxides) in a light oil or an aqueous solution, latex or rubber gloves are appropriate for this exposure.
   G. Thoroughly wash any skin areas that may come in contact with spiking dispersions and/or solutions immediately upon even possible exposure. Do not eat, drink, or smoke in the spiking area. Wash hands, arms, and face before eating, drinking or smoking in designated areas. Remove and replace contaminated clothing immediately.
   H. Use secondary containment. Do not open any spiking material container except after it has been moved inside of the ESS secondary containment area. Keep all spiking material containers tightly closed and sealed except when in use.
   I. Maintain a current annual medical monitoring examination including facemask fit testing/certification.
   J. To the extent that site-specific or project-specific safety hazards exist, they are to be discussed with the PM/client contact and measures taken to minimize identified hazards.
   K. During summer conditions, avoid heat exhaustion by taking periodic breaks, drinking plenty of fluids, etc.
2. Organic Liquids/Vapors:
   Potential exposure pathways for organic compounds include the same two pathways as for metal dispersions and solutions (eye/dermal penetration from direct contact, and the oral ingestion from contaminated hands/gloves), plus the respiratory (respiration of organic vapors) pathway. Thus, precautions exercised to avoid exposure to organic vapors and liquids include all those listed above (I.A. through K.), plus the following:
   L. Work only in well ventilated areas.
   M. Avoid breathing organic vapors (as from an even a minor drip).
   N. Use half-face respirator with organic vapor cartridges whenever exposed to vapors.
   O Use gloves that are impermeable to the organic liquid (e.g., Viton™) when working with and the potent to be exposed to organic liquids exists.

SAFETY REPORTS

ESS personnel are responsible for immediately reporting by phone even the most minor accidents, cuts, back aches, etc. to the Client’s Test Manager and ESS’ Project Manager, who may require that a written report be submitted. The ESS Technician is responsible for recording in the daily logs any incident which occurred including an accident which almost happened and/or may happen under similar circumstances in the future. The PM is responsible for following up on all such reports, identifying necessary changes in ESS’ safety program, and identifying and keeping necessary safety records, and making all regulatorily required reports.

SCOPE OF MEDICAL MONITORING EXAMINATIONS

The specific type of medical monitoring required of ESS personnel (Technicians and Project Manager) are customized in response to problems which would likely result from ESS spiking activities.

ESS Technicians, who have a greater opportunity for exposure than other ESS personnel are typically at client test sites between 12 and 24 times per year. Tests typically take a half-day to setup for a test and one to four test days, and very occasionally up to 10 test days to complete the spiking aspects of the test. Each test is at a different site and usually with different spiking materials, i.e., non-spiking exposures are brief and vary from site to site.

1. Thus, unless ESS, or an employee, has reason to believe that a significant exposure to a client-specific material has occurred, medical monitoring will focus primarily on spiking material related exposures.
2. Similarly, everyone (including ESS personnel) must wear hearing protection when exposed to high noise level environments. For this reason, annual hearing tests are not required for these occasional, brief, protected exposures.
3. Pulmonary function especially as it relates to the use of face masks and fit testing will be a part of every medical examination.
4. ESS has a strict policy forbidding drug use by ESS employees. As a means of ensuring that the policy is consistently observed by all employees, and as a condition of employment, all ESS employees will be subject to: (a) an annual, (b) “for cause”, (c) “post-incident”, and/or (d) “random” drug screens. Thus, ESS Technicians will be tested annually and must test clean in order to represent ESS on spiking projects. Additionally, drug screens may be initiated by the PM on a “random,” “post-incident”, and/or “for cause” basis.

ESS-REQUIRED PPE

All ESS personnel are required, at a minimum, to have, maintain, and wear the following PPE when needed while at client sites:

1. Hard hats (nonmetallic).
2. Safety glasses with side shields.
3. Steel-toed safety shoes.
4. Face masks with organic vapor canisters when exposed to organic vapors.
5. Impermeable gloves when exposed to organic liquids, and metal dispersions and/or solutions.
6. Ear muffs and/or ear plugs.
7. Any PPE required by the client at that site.

DOCUMENTATION

In addition to the OSHA 1910 Training & Medical Monitoring Examination discussed above, each ESS technician will be required to:

1. Receive training on the ESS Safety Plan annually; and
2. Document:
   A. The Training, and
   B. Acknowledge agreement to adhere to its requirements by signing the plan at the space provided below.

I hereby acknowledge that I have been trained and understand the ESS Safety Plan and document my intention to adhere to its requirements by my signature below: