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Chapter 1 - Introduction and Table of Contents

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TABLE OF CONTENTS CHAPTER 1 - INTRODUCTION AND TABLE OF CONTENTS CHAPTER 1 INTRODUCTION CHAPTER 2 ORGANIZATION POLICY AND MANAGEMENT COMMITMENT CHAPTER 2 - ORGANIZATION POLICY AND MANAGEMENT COMMITMENT 1 10 11 11

2.1 HEALTH, SAFETY AND ENVIRONMENTAL VISION STELCO INC...................................................11 2.2 HEALTH AND SAFETY POLICY..........................................................................................................13 2.3 HEALTH AND SAFETY RESPONSIBILITIES..........................................................................................14 CHAPTER 3 - ORGANIZATION POLICY AND MANAGEMENT COMMITMENT 14

2.4 HEALTH AND SAFETY ACCOUNTABILITY.........................................................................................16 CHAPTER 4 - ORGANIZATION POLICY AND MANAGEMENT COMMITMENT CHAPTER 3 EMPLOYEE COMPETENCY CHAPTER 5 - EMPLOYEE COMPETENCY 16 20 20

3.1 NEW EMPLOYEE ORIENTATION........................................................................................................20 3.2 EMPLOYEE TRAINING, COMPETENCY, AND AUTHORIZATION........................................................22 CHAPTER 6 - EMPLOYEE COMPETENCY 22

3.3 EMPLOYEE EMERGENCY RESPONSE TRAINING...............................................................................24 CHAPTER 7 - EMPLOYEE COMPETENCY 24

3.4 REGULATORY REQUIREMENTS.........................................................................................................25 CHAPTER 8 - EMPLOYEE COMPETENCY 25

3.5 JOB SPECIFIC MEDICAL REQUIREMENTS........................................................................................26


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3.6 SAFETY CONCERNS, COMPLAINTS AND WORK REFUSAL ...............................................................27 CHAPTER 10 - EMPLOYEE COMPETENCY 27

3.7 CONTACT PERSON TRAINING AND AUTHORIZATION......................................................................29 CHAPTER 11 - EMPLOYEE COMPETENCY CHAPTER 4 HEALTH MANAGEMENT CHAPTER 12 - HEALTH MANAGEMENT 29 30 30

4.1 HEALTH MANAGEMENT SYSTEMS....................................................................................................30 4.2 OCCUPATIONAL HEALTH PROGRAM................................................................................................31 CHAPTER 13 - HEALTH MANAGEMENT 31

4.3 INDUSTRIAL HYGIENE PROGRAM.....................................................................................................32 CHAPTER 14 - HEALTH MANAGEMENT 32

4.4 HEARING PROTECTION PROGRAM...................................................................................................33 CHAPTER 15 - HEALTH MANAGEMENT 33

4.5 MEDICAL RECORDS...........................................................................................................................35 CHAPTER 16 - HEALTH MANAGEMENT 35

4.6 MODIFIED WORK PROGRAM............................................................................................................36 CHAPTER 17 - HEALTH MANAGEMENT 36

4.7 EMPLOYEE IMPAIRMENT...................................................................................................................38 CHAPTER 18 - HEALTH MANAGEMENT 38

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4.8 POTABLE WATER................................................................................................................................39 4.9 INDOOR AIR QUALITY........................................................................................................................40 CHAPTER 5 HAZARD IDENTIFICATION CHAPTER 19 - HAZARD IDENTIFICATION 41 41

5.1 HAZARD IDENTIFICATION AND ANALYSIS ........................................................................................41 CHAPTER 20 - HAZARD CONTROL CHAPTER 6 HAZARD CONTROL 44 44

6.1 HAZARD CONTROL SYSTEM..............................................................................................................44 6.1.1 ORGANIZATION OF PROCEDURES.....................................................................................................46 CHAPTER 21 - HAZARD CONTROL 46

6.2 HAZARDOUS MATERIALS..................................................................................................................47 CHAPTER 22 - HAZARD CONTROL 47

6.2.1 WORKPLACE HAZARDOUS MATERIALS INFORMATION SYSTEM (WHMIS)....................................47 6.2.2 TRANSPORTATION OF DANGEROUS GOODS.....................................................................................48 CHAPTER 23 - HAZARD CONTROL 48

6.2.3 RADIATION AND RADIOACTIVE MATERIALS.....................................................................................49 CHAPTER 24 - HAZARD CONTROL 49

6.2.4 PCB CONTROL..................................................................................................................................50 6.2.5 ASBESTOS CONTROL.........................................................................................................................51 CHAPTER 25 - HAZARD CONTROL 51

6.3 WORK REQUIRING PERMITS.............................................................................................................52 CHAPTER 26 - HAZARD CONTROL


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6.3.1 HIGH VOLTAGE PERMITS..................................................................................................................52 6.3.2 GAS AND OXYGEN WORK PERMITS..................................................................................................53 CHAPTER 27 - HAZARD CONTROL 53

6.3.3 CUTTING AND WELDING PERMITS....................................................................................................54 CHAPTER 28 - HAZARD CONTROL 54

6.3.4 EXCAVATION PERMITS......................................................................................................................55 CHAPTER 29 - HAZARD CONTROL 55

6.3.5 MAN BASKET AND AERIAL PLATFORM PERMITS..............................................................................56 CHAPTER 30 - HAZARD CONTROL 56

6.3.6 ELECTRICAL PERMITS.......................................................................................................................57 CHAPTER 31 - HAZARD CONTROL 57

6.3.7 CONFINED SPACES.............................................................................................................................58 CHAPTER 32 - HAZARD CONTROL 58

6.3.8 CONTRACTOR WORK.........................................................................................................................59 CHAPTER 33 - HAZARD CONTROL 59

6.4 CONTROL OF CRANES AND MOBILE EQUIPMENT...........................................................................60 CHAPTER 34 - HAZARD CONTROL 61

6.4.1 MODIFICATION TO CRANES AND MOBILE EQUIPMENT AND LIFTING EQUIPMENT...........................60 6.4.2 CRANE BOARDING AND SECURITY....................................................................................................62 CHAPTER 35 - HAZARD CONTROL 62

6.4.3 CRANE AND MOBILE EQUIPMENT OPERATION..................................................................................63


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6.4.4 AUTHORIZATION OF CRANE AND MOBILE EQUIPMENT OPERATORS................................................64 CHAPTER 37 - HAZARD CONTROL 64

6.4.5 OPERATOR INSPECTION OF CRANES AND MOBILE EQUIPMENT........................................................65 CHAPTER 38 - HAZARD CONTROL 65

6.4.6 NON DESTRUCTIVE TESTING OF STRUCTURES, CRANES, MOBILE EQUIPMENT AND LIFTING EQUIPMENT.................................................................................................................................................66 6.5 CONTROL OF EQUIPMENT REQUIRED FOR SAFETY AND EMERGENCY RESPONSE........................68 CHAPTER 39 - HAZARD CONTROL 68

6.5.1 RESPIRATOR PROGRAM.....................................................................................................................68 6.5.2 FAILURE OR DISABLING OF SAFETY DEVICES AND ALARMS............................................................70 CHAPTER 40 - HAZARD CONTROL 70

6.5.3 PERSONAL PROTECTIVE EQUIPMENT.................................................................................................71 CHAPTER 41 - HAZARD CONTROL 71

6.5.4 WORKING AT HEIGHT &SAFETY BELTS AND HARNESSES................................................................72 CHAPTER 42 - HAZARD CONTROL 72

6.5.5 USE OF RADIOS.................................................................................................................................74 CHAPTER 43 - HAZARD CONTROL 74

6.5.6 USE OF CELL PHONES.......................................................................................................................75 CHAPTER 44 - HAZARD CONTROL CHAPTER 45 - HAZARD CONTROL 75 76

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6.5.7 EMERGENCY LIGHTING.....................................................................................................................76 6.5.8 GAS TESTING EQUIPMENT.................................................................................................................77 CHAPTER 46 - HAZARD CONTROL 77

6.5.9 MANAGEMENT OF FIRE EXTINGUISHERS, STRETCHER STATIONS, EYE WASH STATIONS, SAFETY SHOWERS AND WATER JEL BLANKETS......................................................................................................78 CHAPTER 47 - HAZARD CONTROL 78

6.6 OTHER WORK PROCESSES................................................................................................................79 CHAPTER 48 - HAZARD CONTROL 79

6.6.1 DESIGN AND MAINTENANCE OF EQUIPMENT....................................................................................79 6.6.2 CONSTRUCTION AND REPAIR GUIDELINES........................................................................................81 CHAPTER 49 - HAZARD CONTROL 81

6.6.3 LOCKOUTS AND ZERO ENERGY STATE.............................................................................................82 CHAPTER 50 - HAZARD CONTROL 82

6.6.4 RESTRICTED ACCESS AREAS.............................................................................................................83 CHAPTER 51 - HAZARD CONTROL 83

6.6.5 GRINDERS..........................................................................................................................................84 CHAPTER 52 - HAZARD CONTROL 84

6.6.6 WORKING ALONE..............................................................................................................................85 CHAPTER 53 - HAZARD CONTROL 85

6.6.7 PRESSURE VESSELS & PRESSURE RELIEF VALVES...........................................................................86 CHAPTER 54 - HAZARD CONTROL 86

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6.6.8 HEAT STRESS AND COLD WEATHER.................................................................................................87 CHAPTER 55 - HAZARD CONTROL 87

6.6.9 HOUSEKEEPING..................................................................................................................................88 CHAPTER 56 - HAZARD CONTROL 88

6.6.10 PIGEON CONTROL............................................................................................................................89 CHAPTER 57 - HAZARD CONTROL CHAPTER 7 REGULAR INSPECTIONS CHAPTER 58 - REGULAR INSPECTIONS 89 90 90

7.1 DEPARTMENT SAFETY INSPECTIONS...............................................................................................90 7.2 ALBERTA DEPARTMENT OF OCCUPATIONAL HEALTH AND SAFETY INSPECTIONS......................92 CHAPTER 59 - REGULAR INSPECTIONS 92

7.3 JOINT MANAGEMENT/UNION INSPECTIONS......................................................................................93 CHAPTER 60 - REGULAR INSPECTIONS CHAPTER 8 EMERGENCY RESPONSE CHAPTER 61 - EMERGENCY RESPONSE 93 94 94

8.1 EMERGENCY PROCEDURES ACTION PLAN DESCRIPTION............................................................94 8.2 EVACUATIONS....................................................................................................................................96 CHAPTER 62 - EMERGENCY RESPONSE 96

8.3 FIRST AID - SUPPLIES, FACILITIES AND SERVICE...........................................................................97 CHAPTER 63 - EMERGENCY RESPONSE 97

8.4 EMERGENCY RESPONSE DRILLS........................................................................................................98


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9.1 INCIDENT, ACCIDENT, AND CONCERN INVESTIGATION..................................................................99 CHAPTER 10 PROGRAM ADMINISTRATION CHAPTER 66 - PROGRAM ADMINISTRATION 101 101

10.1 EFFECTIVE SAFETY COMMUNICATION.........................................................................................101 10.2 SAFETY PERFORMANCE MANAGEMENT........................................................................................102 CHAPTER 67 - PROGRAM ADMINISTRATION 102

10.3 SAFETY MEETINGS.........................................................................................................................104 CHAPTER 68 - PROGRAM ADMINISTRATION 104

10.4 EMPLOYEE PARTICIPATION AND RECOGNITION..........................................................................106 CHAPTER 69 - PROGRAM ADMINISTRATION 106

10.5 REPORTING SAFETY STATISTICS...................................................................................................108 CHAPTER 70 - PROGRAM ADMINISTRATION 108

10.6 SAFETY AUDITS...............................................................................................................................109 CHAPTER 71 - PROGRAM ADMINISTRATION CHAPTER 11 FACILITIES AND SERVICES CHAPTER 72 - FACILITIES AND SERVICES 109 110 110

11.1 VISITOR AND CONTRACTOR MANAGEMENT.................................................................................110 11.2 TOURS AND TOUR GUIDES.............................................................................................................111
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Chapter 1 Introduction
This Health and Safety Manual contains statements of safety policies and procedures to be followed by all employees of AltaSteel. It is to serve as a permanent reference and working guide for management, supervision, and employees in the day-to-day administration and compliance with safety policies, practices and procedures. The purpose of the manual is to increase understanding, eliminate the need for personal decisions on matters of safety policy and systems, and help to assure uniformity throughout our organization. It is the responsibility of supervision to administer these policies in a consistent and impartial manner. It is essential that employees not only understand the safety policies but also actively support and apply the safety policies, practices and procedures. This will ensure that our company can achieve productivity and performance objectives in a safe work environment, allowing us to challenge our competitors in terms of cost, efficiency and product quality. Policies, practices, and procedures in the field of health and safety are subject to modifications and further development in light of internal needs, and compliance with changing statutes and industry standards. Therefore, changes will occur periodically. All such changes will be recorded in the form of a Health and Safety Manual amending statement and issued to holders of the manual. All personnel can assist in keeping our Health and Safety Program up to date by notifying their immediate supervisor whenever problems are encountered, and to suggest improvements to the administration of safety policies. It is the responsibility of supervision to ensure that this manual is kept current, policies are understood by all employees, and that they are interpreted and administered uniformly and consistently. The safety information in this manual has been developed to comply with applicable Occupational Heath and Safety Act, Regulations and Code. Excerpts from the Act, Regulations and Code appear in the manual to emphasize and demonstrate specific points. Users are advised to refer to current editions of the Occupational Health and Safety Act, Regulations and Code before making any safety-related decisions to ensure that source information is current.

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Chapter 2 Organization Policy and Management Commitment 2.1 Health, Safety and Environmental Vision Stelco Inc.
The health and safety of our employees and protection of the environment are THE top priorities at Stelco. We are committed to continued leadership and excellence in the health and safety of employees and in protecting and enhancing the environments of the communities where we have operating facilities. We will continue to manage our business in a manner that leaves employees and our communities healthy and safe while producing quality products for our customers. We recognize this is a long term commitment which requires continual improvement to our practices as new understandings occur in health, safety and in environmental science, and as advances are made in technology. We will work toward this vision by: A) Employing safe technologies and operating procedures and by being prepared for emergencies including co-operation with government and other businesses where community action is needed. B) Developing internally or seeking out on a world-wide basis, the best available technology which is health, safety and environmentally compatible. C) Minimizing and striving to eliminate the release of substances that adversely affect the work environment or cause damage to the natural environment. D) Committing management resources, including a Health, Safety and Environment Committee of the Board of Directors, to ensure the implementation of our policies and procedures, and compliance with regulatory requirements. E) Conducting regular self-evaluations of health, safety and environmental performance at each facility. Risk evaluation techniques will be employed to prevent environmental incidents. F) Maintaining a system of pre-evaluation of capital appropriations to ensure compatibility with our Health, Safety and Environmental policies and procedures. G) Requiring all our people to share the responsibility of reporting and improving upon conditions that pose heath and safety risks or threaten the environment. H) Continually improving the education of our people in health, safety and environmental matters including joint programs with the Unions at our manufacturing sites. I) Making sustainable use of renewable natural resources, conserving non-renewable natural resources through efficient use and careful planning, and continuing to recycle products after use for the production of new steel. J) Minimizing the creation of waste and maximizing the reuse and recycling of materials. Disposing of all wastes will continue to be done through methods known to be safe and responsible. K) Investing in improved energy efficiency and conservation in our operations and making every effort to use environmentally safe and sustainable energy sources to meet our needs.

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In addition to protecting the health and safety of our employees and the environments of the communities where we have operating facilities, we believe that adherence to these principles will sustain the viability of our business, and enable us to continue to provide value to our employees, communities, customers and shareholders.

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2.2

Health and Safety Policy

AltaSteel Ltd. is committed to a Health and Safety Program that protects employees, property, other employees on our property, the general public, and the environment. Our goal is a healthy, injury free work place. By working together in all parts of the Health and Safety Program, we expect to achieve zero incidents, losses and injuries. Management sets an example and provides leadership in the Health and Safety Program. Management ensures that safe work practices are developed through hazard analysis and that these practices are followed. Management provides proper equipment and training including familiarizing all employees with the applicable requirements of the Occupation Health and Safety Act, Regulations and Code, and language in the Basic Agreement. The Joint Safety, Health and Environment Committee is recognized as a key component of the health and safety program. Employees at every level are accountable for and are recognized for health and safety performance. Active participation by everyone, every day in every job is expected. Employees are accountable for safe behavior including reporting all injuries and safety issues and participating in improving health and safety.

______________________________________ P.M. Ouellette President and CEO Table of Contents

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2.3

Health and Safety Responsibilities

Purpose: To define the responsibilities necessary to demonstrate a commitment from all that we will not compromise the health and safety of our employees, contractors, customers or community in the operation of AltaSteel and to demonstrate that Health and Safety is our first priority. Responsibilities: 1. The companys responsibilities are to: Establish a safety culture and expect all employees to work safely and efficiently. Insist on safe performance throughout operations by ensuring employees and contractors are competent and expected to do their work efficiently and safely. Have an effective Safety Program. Ensure the safety program and operations comply with regulatory requirements. Ensure employees and contractors know the operating companys expectations. Provide sufficient time for employees and contractors to do their jobs safely. 2. The contractors and subcontractors responsibilities are to: Support the companys safety culture and expect their employees to work safely and efficiently. Insist on safe performance throughout their operations by ensuring their employees are competent, and expected to work safely. Have effective safety programs. Ensure their employees and subcontractors meet the contractors and AltaSteels safety expectations. Ensure their programs and operations comply with contractual and regulatory requirements. Provide the time and resources required enabling employees and subcontractors to do their work safely and properly. 3. Visitors responsibilities are to: Follow the instructions of the site supervision or personal escort. Wear personal protective equipment when required. Never enter or move about the work site unescorted (walking or driving). Comply with the Employee Guided Tour Procedure Documentation and Records: Employee Guided Tour Procedure Related Procedures:

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15 of 111 Practice: 1. These responsibilities will be reviewed with new employees during the orientation process. 2. These responsibilities will be reviewed with all employees during annual safety reviews. 3. These responsibilities will be reviewed with contractors and contractor employees during their training. Table of Contents

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2.4

Health and Safety Accountability

Purpose: To assign accountability for every action that contributes to health and safety, and to review those accountabilities on a regular basis. Responsibility: All employees at AltaSteel are responsible for being familiar with and carrying out the accountability for their position. Documentation and Records: Safety Performance Reviews Related Procedures: Practice: 1. President, Vice Presidents and Managers are accountable to: a. Provide a health and safety policy and commitment to safety. b. Provide leadership in the Health and Safety Program to progress towards and achieve zero injuries in the workplace. c. Monitor department safety performance and hold staff accountable for their individual safety performance. d. Meet responsibilities as defined in the Occupational Health and Safety Statutes and Regulations including providing familiarization to all employees. e. Ensure health and safety policies and language in the Basic Agreement are administered and enforced. f. Provide information, instruction and assistance to all supervisory staff to protect the health and safety of all employees. g. Provide ongoing safety education programs and first aid training as required. h. Communicate to all employees at least annually: i. The organizations commitment to health and safety. ii. Why health and safety is important and who it affects. i. Tour the worksite routinely to observe health and safety practices and behaviours. j. Set a good example by following the rules and policies. 2. The following items are monitored to evaluate accountability for the President and Managers: Accident frequency Accident severity Major violations O. H. & S. orders Audit results Recorded Safety Initiatives
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17 of 111 3. Day Supervisors are accountable to: a. Monitor safety performance of area and hold staff accountable for their individual safety performance. b. Ensure health and safety policies and language in the Basic Agreement are administered and enforced. c. Develop and maintain safety systems such as: Crane and mobile checklists Qualified operator lists Inspection tours Crew safety meetings Contractor safe work permits Cutting and welding permits Emergency response procedures Hazard analysis Safe work procedures WHMIS Modified work Accident and incident investigations Annual safety reviews. Provide information, training, instruction and assistance to supervisory staff to protect the health and safety of all employees. Meet responsibilities as defined in O. H. & S. Statutes and Regulations and provide necessary information on regulation to supervisory staff. Tour the worksite routinely to observe health and safety practices and behaviours. Set a good example by following the rules and policies. 4. The following items are monitored to evaluate Day Supervisory level accountability: Area accident frequency Area Accident Severity Major violations O. H. & S Orders Audit Results Logs of non-compliance with procedures and wearing of personal protective equipment Safety Meeting minutes and inspection reports Recorded Safety Initiatives Audits of safety system performance 5. Shift Supervisors are accountable to: a. Monitor safety performance of employees and hold them accountable for their individual safety performance.

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18 of 111 b. Know and apply company safety policies and relevant Occupation Health and Safety Statutes and Regulations, and language in the Basic Agreement. c. Ensure that all employees are educated to work in a safe and competent manner and that they use all protective devices and procedures required by the company and safety legislation. d. Advise all employees of any potential or actual dangers and how to isolate, prevent, or remove them. e. Record and investigate accidents and incidents that may have caused injury or damage. f. Carry out inspection tours as required. g. Correct physical conditions that are likely to cause accidents. h. Provide a good example to employees by always directing and performing work in a safe manner. i. Maintain a good housekeeping standard and assign definite responsibilities for housekeeping. j. Enforce all established safety regulations and work rules. k. Hold safety meetings with employees, record and issue minutes of those meetings, and correct health and safety concerns that were identified. l. Tour the worksite routinely to observe health and safety practices and behaviours. 6. The following items are monitored to evaluate Shift Supervisor accountability: Accident record of employees reporting to him/her Safety meeting minutes Inspection tour reports Logs of non-compliance with procedures and wearing personal protective equipment O. H. & S. orders Recorded Safety Initiatives 7. All employees are accountable for the following: a. Carry out work using safe behaviours that will not create a hazard to your health and safety or that of your fellow employee. b. Work with your supervisor to help create safe working conditions. c. Use all protective equipment and procedures required by the company or safety legislation. d. Set a good example by following work rules, procedures, and language in the Basic Agreement. e. Report and correct unsafe conditions. f. Report any accidents, incidents, near misses or unsafe acts to the area supervisor. g. Conduct inspections of your work area before starting work. h. Take defective tools out of service, and report equipment that is not functioning in the manner for which it is designed. i. Participate in the Health and Safety Program by making safety suggestions and providing your expertise. j. Refuse work that presents imminent danger. 8. The following items are used to monitor employee accountability:
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19 of 111 Personal accident Record Logs of non-compliance with procedures or wearing of personal protective equipment Attendance at safety meetings Recorded Safety Initiatives 9. These responsibilities will be reviewed with new employees during the orientation process. 10. These responsibilities will be reviewed with all employees during annual safety reviews. Table of Contents

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Chapter 3 Employee Competency 3.1 New Employee Orientation

Purpose: To ensure that new employees at AltaSteel receive appropriate training and orientation when they begin working. Responsibility: It is the responsibility of the Human Resources Department to ensure that each new employee receives safety orientation before being placed on the job. The employees supervisor is responsible for ensuring that the new employee is paired up with an experienced employee for a number of days until the employee is able to work safely alone and for providing the necessary training prior to the employee starting work on his own. Documentation and Records: Job Training Requirements WHMIS Binders Due Diligence Training Material AltaSteel Health and Safety Manual Plant wide Safety Procedures Basic Agreement Related Procedures: Practice: 1. All newly hired employees are given a general safety orientation on their first day of employment. They spend their first morning in the Human Resources Department at which time they receive a copy of and review excerpts from the Employees Health and Safety Manual as well as Plant wide safety procedures. The orientation will emphasize real and potential hazards, safety requirements, first aid location(s), alarm systems, and emergency response procedures. 2. The employee will be scheduled to receive WHMIS training. 3. The principals of Due Diligence will be reviewed with the employee. 4. The Chairman of the Union Health and Safety Committee is provided time to reinforce the unions commitment to health and safety, and reinforce the new employees responsibility for health and safety. 5. A competent individual is assigned to arrange for the issuing of personal protective equipment and to provide specific training on its selection, care and use. The competent individual also provides a general plant tour. 6. The supervisor ensures that a new employee is paired up with an experienced employee until they achieve familiarity with the work area. 7. The new employee's supervisor ensures that the new employee is familiar with the job safety analysis developed for the work he/she will be performing. Health hazards such as noise,
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chemicals, radiation, harmful dusts, mists, or gases are to be identified. In addition, the supervisor ensures that the new employee is familiar with the safe work practices/procedures developed to control the real and potential hazards associated with the work being performed. This training is to occur before the new employee is allowed to proceed with the work. Table of Contents

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3.2

Employee Training, Competency, and Authorization

Purpose: To ensure a system is in place to provide new and existing employees with job specific training. This training is to be conducted: 1. At the time of hire. 2. When an employee is assigned new or different work. 3. When an employee is moved to a new site or location. Responsibility: Managers, Day Supervisors and Shift Supervisors are responsible for ensuring that employees receive job specific training. Documentation and Records: Organizational policies, practices and procedures. Job Safety Analysis to identify specific job hazards. Safety precautions. Job responsibilities. Regulatory requirements. Organizational enforcement policy. Employees right to know and refuse unsafe work. Employee Training Records. Due Diligence.principles Job training requirements Related Procedures: Practice: Job-Specific Training for Employees 1. Specific job training is to be provided to an employee when: The employee is newly hired The employee is an existing employee assigned new or different work The employee is an existing employee moved to a new site or location The requirements of the work being performed change and The employee requires the training in order to satisfactorily carry out the requirements of the work to be performed. 2. Job-specific employee training needs will be determined from:
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a. Specific internal requirements, b. The Occupational Health and Safety Statutes and Regulations c. Industry standards. d. Plant wide and department safety training requirements The respective operating departments will identify their specific needs to the Learning Coordinator, who will research the most practical and cost effective means of achieving the training and make recommendations. 3. Day & Shift Supervision will establish job training requirement lists for each job in order to ensure that the appropriate training content is covered. 4. Each employee receiving training will be required to demonstrate competence and mastery of the knowledge and/or skill associated with the training before being considered competent. 5. When demonstration of competence is evaluated via direct observation by the employees supervisor (or designate), the Supervisor or designate are required to sign off on the evaluation. 6. The respective departments will develop and maintain training records for all specific training provided for new and existing employees. Employees are required to acknowledge that they have received specific job training by signing-off on training records. Health and Safety/Assessment Training Records - Departmental. 1. A formal record will be created and maintained for each worker, indicating training: a. Date b. Subject matter c. Competent employee providing the direction/instruction d. Employee sign-off e. Supervisors signature 2. An employees record of training will be made available to the new supervisor when an employee is transferred from one department to another. 3. Records of any health assessments such as audiometric tests, pulmonary function tests, etc. are to be maintained by the medical department. 4. Employees who terminate employment will have their records forwarded to Human Resources. Related Procedures:

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3.3

Employee Emergency Response Training

Purpose: To provide Emergency Response training to all AltaSteel employees in situations which potentially involve: AltaSteel personnel. The public in the surrounding area. The environment or significant damage to the facilities. Responsibility: Managers in conjunction with the Supervisor Personnel and I. R. are responsible for implementing and maintaining this practice. Documentation and Records: Training records Plant wide safety procedures Evacuation Procedures Oxygen, Gas and Water schematic drawings Related Procedures: Section 8 Emergency Response Practice:
1. Day and Shift Supervision are responsible for indoctrinating their employees in the Management

"On Call" Practice, Emergency Action Plan, Emergency Procedures, Fire Fighting procedures and Evacuation procedures as part of the employees orientation. 2. Employees are to be given refresher training on the location and operation of the major shut off valves for gas, oxygen and water and evacuation gathering points via a tour on an annual basis or when locations or procedures change. 3. This information is to be recorded on the employees training record. Table of Contents

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3.4

Regulatory Requirements

Purpose: To ensure employees understand responsibility and accountability under regulatory requirements and that AltaSteel is in compliance. Responsibility: All employees are responsible for complying with government regulations. Vice Presidents, Managers, and supervisors are responsible for being familiar with regulatory requirements and communicating them to employees. The Supervisor Personnel and I.R. is responsible for monitoring regulations and communicating any changes to management. Documentation: Occupational Health and Safety Act The Regulations and Code under this Act Related Procedures: Practice: 1. Supervision is responsible for the health and safety of employees and is also responsible for making employees aware of their responsibilities and duties under the Act and applicable regulations. 2. Employee competency and training must meet the regulatory standards. 3. Regulations covering equipment and physical safeguards are primary performance standards that must be met. Table of Contents

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3.5

Job Specific Medical Requirements

Purpose: To outline where there are specific medical requirements for certain jobs or tasks at AltaSteel. Responsibility: AltaSteel medical staff in co-operation with the Supervisor - Personnel and I.R. determine which jobs and tasks have specific medical requirements. AltaSteel medical staff will determine the nature of the requirements and advise management of those requirements. AltaSteel medical staff will schedule and perform the necessary testing, retain the medical records, and advise supervision of the status of employees who have been tested. Management and supervision will report any concerns about medical requirements on a job or task to AltaSteel medical staff so a determination can be made. Documentation and Records: Medical Records Job Training Requirements Authorized Operator Lists Related Procedures: Practice: 1. Operating supervision is to identify any jobs that may have medical requirements to AltaSteel medical staff. 2. AltaSteel medical staff will advise operating supervision that there are medical requirements for a job or task and organize testing of the individuals involved. 3. Operating supervision will include any medical requirements in the job training requirements and ensure that all employees performing the job are medically certified. 4. AltaSteel medical staff will be responsible for keeping medical records up to date, identifying time frames for any recurring medical testing, and notifying operating supervision and employees of the need for recurring medical testing.

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3.6

Safety Concerns, Complaints and Work Refusal

Purpose: To ensure that a process is in place that can address safety concerns, complaints, or refusals to perform work expediently and in a timely manner. Responsibility: The respective supervisor holds the prime accountability for responding to the concern or complaint. The employee and safety representative play an integral role in developing, implementing, and applying the necessary control(s) to correct the substandard condition and to prevent recurrence. Documentation and Records: Occupational Health and Safety Act Workplace Procedures Related Procedures: Practice: 1. When a employee expresses a safety concern, it is incumbent upon the supervisor to develop an appropriate resolution to the concern or complaint. This practices recognizes that it is unusual for a employee to approach a supervisor and declare that he is exercising his right under the Occupation Health and Safety Act to refuse to perform a job because it is unsafe. More often, a safety concern is expressed in terms such as: a) I dont think that job is very safe. b) Im not sure about the safety of that job. c) Ive been told that job is not very safe. d) Im not sure that the procedure on that job is right. 2. The supervisors responsibility is to recognize the concern, then listen, and understand what the employee is saying. 3. If it is a concern or complaint that can be dealt with quickly and effectively, corrective action is taken to resolve the issue. If longer-term action is required, the employee and safety representative are involved in developing a plan for resolution and other employees advised of the issue, hazard and any interim procedures. 4. If it is a refusal to work, the supervisor first reviews with the employee and the safety representative the definition of a refusal to work under the Occupational Health and Safety Act as follows: No employee shall carry out work or operate any tool, appliance or equipment if, on probable and reasonable grounds, he believes that it will cause to exist an imminent danger to the health or safety of that employee or another employee. Where imminent danger means in relation to any occupation: a) a danger which is not normal for that occupation, or b) a danger under which a person engaged in that occupation would not normally carry out his work.
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If the employee believes his concern satisfies the existence of imminent danger, the supervisor and safety representative jointly: c) investigate the concern as identified by the employee. d) prepare a written record of the employees concern. 5. One of the following situations may then occur: a) If the supervisor, union representative and employee agree, the situation is rectified immediately if possible. The recommended action taken to resolve the concern is recorded with the written record of the employees concern and a copy given to the employee. b) If the supervisor, union representative and employee agree, however, it is going to take some time to correct the situation; this is explained to the employee. The employee may agree to perform the work in an alternate manner until the situation is corrected. The recommended action to resolve the concern is recorded with the written record of the employees concern and a copy given to the employee. The supervisor/union representative will follow up to ensure the agreed to action is carried out. c) If the employee, the supervisor and the union representative are unable to reach agreement, or if the concern is beyond their technical knowledge, the Manager and a union member of the Joint Health, Safety and Environment Committee are contacted and involved in the resolution of the concern. 6. Should the concern remain unresolved, the employee is provided with a copy of the written record of his concern, the investigation and any action taken. If the employee continues to believe that imminent danger still exists, an officer of Alberta Labour is contacted and involved in the resolution discussions. 7. The Alberta Labour officer, upon investigation, prepares a written record of the employees complaint, the investigation and the action taken and gives the employee, supervision and union representatives, a copy of the record. 8. The decision of the officer may be appealed by the employee or the employer. 9. Once it is determined that a employee is refusing to work, the work in question can be assigned to another employee providing the employee so assigned is not exposed to imminent danger and is made aware of the specifics of the ongoing refusal. 10. Since some operations cannot simply be stopped and left unattended, consideration is given to ensure the safety of people and the protection of equipment. Therefore good judgment must be exercised when determining whether to continue the work or stop. Operations are maintained until it can be safely shut down on an emergency basis. Maintaining production is not a factor when considering whether to continue work or stop for safety reasons. 11. The following order should be used when attempting to obtain a Union Health and Safety Representative to be involved in the work refusal: a) a representative within the department on shift. b) a representative from another department on shift. c) a representative from off shift. 12. The supervisor advises subsequent crew(s) of the issue and its status if the concern is not resolved within the same shift. Table of Contents
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3.7

Contact Person Training and Authorization

Purpose: To ensure that people working as contact persons for contractors at AltaSteel are properly trained and authorized. Responsibility: The Supervisor Personnel and I.R. is responsible for providing training for contact persons and maintaining a record of authorized contact persons. Management and supervision is responsible for ensuring that only authorized contact persons perform this work. Documentation and Records: Training Records Authorized Contact Person List Related Procedures: Practice: 1. 2. 3. The Supervisor Personnel and I.R. will determine training requirements and time frames and organize training sessions. The Supervisor Personnel and I.R. will maintain a list of authorized contact persons and publish this to management and supervision. Managers and Supervisors will ensure the appropriate people are trained as contact persons and that only authorized contact persons are used.

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Chapter 4 Health Management 4.1 Health Management Systems

Purpose: Health Management Systems are designed to detect chronic problems that may otherwise go undetected until they become severe, and to uncover worksite hazards that require corrective action. Responsibility: Supervision have the responsibility of identifying real and potential health hazards specific to the work being performed. The medical staff in cooperation with the Supervisor Personnel and I. R. are to keep abreast of health hazards that are being identified in similar industries, and develop and apply the necessary controls. Documentation and Records: Government Regulations for Silica, Asbestos, Noise, Metals, Total Particulate Medical Records MSDS program Test Results External Sources of Information Related Procedures: Practice: 1. Supervision is to identify real or potential health hazards to the Supervisor Personnel and I. R. 2. The Supervisor Personnel and I. R., in cooperation with the line operating area and the medical staff will develop the necessary strategies to monitor and control the health hazard. 3. External professionals may be required to identify and monitor specific problems. The Supervisor Personnel and I. R. will research the availability of these professionals and make recommendations to the respective stakeholders. 4. Records are to be developed and maintained regarding the testing, and effectiveness of the controls for any health hazard. 5. The medical staff will monitor health hazards that are identified in similar industries and develop and apply the necessary controls. Table of Contents

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4.2

Occupational Health Program

Purpose: To ensure a system is in place to provide AltaSteel employees with an Occupational Health Program in compliance with Corporate Guidelines and Occupational Health and Safety Acts, Regulations and Code. Responsibility: The Medical Department is responsible for pre-employment medical examinations, emergency treatments for illness or accident, periodical medical examinations, medical counsel and health guidance for employees, supervision over sanitation and industrial hygiene. Documentation and Records: Audiograms Medical Examinations Injury Reports and Records WCB Forms and Records Related Procedures: Practice: 1. All injuries are to be reported to supervision no matter how slight. 2. All injuries reported to the first aid attendant or medical department are to be recorded. 3. Form P1036A "Request for Medical Service" will be completed for each employee treated. 4. Those people requiring additional medical treatment will be provided transportation to a MediCenter or hospital as conditions warrant. 5. The Nurse will train and supervise those individuals assigned to first aid duties. Table of Contents

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4.3

Industrial Hygiene Program

Purpose: The Industrial Hygiene Program requires the evaluation of chemical agents including toxic dusts, gases, mists, vapours, fumes and liquids, etc. Physical stresses include noise, vibration and extremes of temperatures, humidity and pressure, etc. Radiant energy includes ultra violet, infrared, ionizing and non-ionizing radiation. Responsibility: The Human Resources department is responsible for carrying out the evaluations required by Government Regulations and monitoring any changes in regulations or industry concerns. Technical direction and assistance will be provided by Engineering and Stelco Industrial Hygiene. The Human Resources department is responsible for carrying out evaluations deemed necessary by Operating or Engineering. Operating departments are responsible for monitoring operations for any areas of concern and following up to ensure the necessary testing is done and that appropriate engineering and administrative controls are put in place. Documentation and Records: Test Results Government Regulations for Silica, Asbestos, Noise, Metals, Total Particulate Medical Records Material Safety Data Sheet (MSDS) system Related Procedures: Practice: 1. Each department identifies potential occupational health hazards based on Government regulations and industry knowledge. 2. Evaluation of these hazards is done by the Human Resources Department through environmental monitoring which includes tests for ambient levels of dust, mists, gases, the analysis of noise and assessment of radiation levels. These tests provide a basis for determining whether Industrial Hygiene standards are being met. 3. Workplace conditions are to be reviewed at appropriate intervals, and all occupations tested as required. 4. The Human Resources Department will issues schedules outlining the type of testing to be done and the timing. 5. Monitoring is to be carried out where employees may be exposed to chemical agents or physical stress. Monitoring results will be posted in the workplace. 6. The main goal of this program is the preservation of health through control of exposure to these hazardous agents. 8. If exposure exceeds the "Occupational Exposure Limits" (OEL) studies are to be initiated as soon as possible to find methods of protecting employees. This includes engineering controls, personal protective devices or administrative controls. Table of Contents
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4.4

Hearing Protection Program

Purpose: To ensure a system is in place to provide AltaSteel employees with a hearing protection program in compliance with Occupational Health and Safety Acts, Regulations and Code and to ensure that hearing protection is worn as required. Responsibility: The Supervisor Personnel and I. R. will be responsible for coordinating the hearing protection program. Equipment will be specifically approved by the Canadian Safety Association (CSA). The Medical Department will be responsible for ongoing audiometric testing. Documentation and Records: Audiograms Medical Records Noise Study Reports Alberta Occupational Health & Safety Act and applicable regulations Related Procedures: Practice: 1. Engineering, Operations and Maintenance will consider methods of reducing noise at the source and along the path when equipment is be selected and repaired. 2. Engineering and the Supervisor Personnel and I. R. will organize and update noise studies in consultation with Industrial Hygiene, and notify the chairman of the Union Health, Safety, and Environment Committee. 3. The Supervisor Personnel and I. R. will review and assess the effectiveness of personal hearing protection. 4. Employees who are or may be required to wear hearing protection are to be medically examined and given regular audiometric hearing tests by the Medical Department. Employees will be informed of the results of the hearing tests and will be referred to an ear specialist for further testing should the results warrant it. 5. The Medical Department will review the importance of wearing hearing protection and its limitations and how to test for a satisfactory fit. 6. Hard hat mounted hearing protectors, replacement parts and earplugs will be obtained from Stores and must not be ordered directly from suppliers. Special requirements will be approved by the Supervisor Personnel and I. R.. 7. Each employee is responsible for ensuring that hearing protection is worn and the supervisor is responsible for ensuring compliance. 8. Hard hat mounted hearing protection (earmuffs) are to be maintained in good working order to ensure that a good seal around the ear is obtained. Employees are to regularly inspect the seals on earmuffs to check for signs of wear and check the integrity of the earmuff arm. Employees
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are to install new seals, liners and arms every 3 months or earlier when necessary. Earplugs can be cleaned as necessary and reused until replacement is warranted. 9. In excessively noise areas it is required that both earplugs and earmuffs be worn. 10. Day Supervision shall determine which areas or activities require hearing protection and ensure areas are properly signed. Table of Contents

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4.5

Medical Records

Purpose: To record the treatment of employees illnesses and injuries and to maintain a history of testing required by government regulation and company rules. Responsibility: The Medical Department is responsible for pre-employment medical examinations, emergency treatment for illness or accidents, periodical medical examinations, medical counseling and health guidance for employees in personal and industrial hygiene. Documentation and Records: Dockets X-rays Pulmonary Function Tests Audiograms Respirator Fit Testing records Mobile Equipment Operators Medicals Related procedures: Practice: 1. All medical records are confidential and may not be removed from the Medical Department. Employees have access to these records through the doctor who will discuss them with the individual employee at any time. 2. The company's medical authorities only give medical information to other parties with the employees signed consent. 3. Results of testing of employees as required by regulations will be provided to government. Table of Contents

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4.6

Modified Work Program

Purpose: To have a program in place that will allow an employee who is temporarily or partially disabled to function in the workplace for a limited duration of time until they are able to perform their normal job. Responsibility: Modified work will only be entertained when the employees attending physician authorizes this course of action. The AltaSteel Medical Department will decide if the employee is medically fit to perform modified work and identify the restriction. Supervision will decide if suitable work is available. Documentation and Records: Workers Compensation Board Guidelines Medical records Modified Work Policy Related Procedures: Practice: 1. Normally, written approval from the employees doctor listing the restrictions is required. 2. The Medical Department and the supervision will closely monitor the employees condition and progress. 3. Employees are to report their injuries to their supervisor and seek treatment at First Aid. If the employee chooses to seek additional medical treatment, he will be provided transportation to a medical centre or hospital and given a Modified Work form to be completed by the attending physician. 4. Supervision will: a) Review the completed Modified Work form and comply with the attending physician's instructions. b) Send the employee home if the physician indicates the employee should be off work. c) If the physician indicates modified work, the supervisor will make a decision if such work is available. If no work is available, the employee is to be sent home. d) Brief the employee if given a modified work assignment covering the following points: I. His welfare and performance will be monitored to ensure there is no aggravation of the injury. II. The company medical facilities are at his disposal. III. The Medical Department will approve his return to normal duties. IV. Modified work does not provide him special status outside his personal work assignment. V. In cases of work related injury, he is eligible for all Employees' Compensation benefits except wages.
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Refusal to perform modified work must be supported by a medical authority.

5. Employees placed on modified work on off shifts must be sent to the Medical Department as soon as possible for confirmation of the assignment. 6. Day Supervision is responsible for monitoring the progress of employees on modified work and weekly reporting findings to the Medical Department. 7. First Aid Attendants are to treat the injured and provide assistance to employees who require additional treatment at medical centres or a hospital. Modified work evaluation or assignments are not part of their responsibilities. 8. Medical Department will approve all modified work and monitor the employees progress while on the program, and authorize all employees return to regular duties. 9. The modified work policy detailed below will be followed. Definition "Modified Work" is defined as work assigned to an employee because of a temporary physical restriction which prevents performance of the full functions of the incumbent job. Based on this definition, an employee who cannot perform all of the major routine components of his or her job is considered to be on "modified work". In this circumstance, the Medical Department would categorize the employee as capable of returning to modified work and would detail any specific restrictions as to type of work. Modified Work Policy AltaSteel recognizes the benefits available to both the company and its employees by providing continuing employment that is modified to reflect temporary physical disability resulting from personal illness or injury occurring at home or at work. Therefore, provided legitimate and useful work is available throughout a scheduled shift, an employee will be provided the opportunity to maintain employment commensurate with his physical restrictions. Such employment will be provided on the same basis as specified in the Alberta Employees' Compensation Act, which reads as follows: "Where work is made available to a employee who is temporarily partially disabled and the Board is satisfied that the employee is medically and physically capable of doing the work and that considering all the circumstances, it is fair and just to expect the employee to accept the work. The suitability of a specific employment opportunity is determined by the company Medical Officer in consideration of the restrictions imposed by the temporary physical disability and in conjunction with the attending physician. This decision is not to be made by the employee or the supervisor.

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4.7

Employee Impairment

Purpose: To have a system in place to respond to concerns about an individual employees ability to perform work due to an impairment of his or her health. Responsibility: All employees have a responsibility to report concerns about their own or another employees ability to safely perform their work . Supervision is responsible for investigating any concerns about a employees ability to safely perform their job. Medical Staff will provide assessments of an employees ability when requested. Documentation and Records: Workplace procedures Related Procedures: Practice: 1. When a concern is raised about a employees ability to safely perform his job the supervisor will investigate and make an assessment. If necessary another supervisor or medical staff will be asked to assist. If there is doubt, the employee will not be allowed to perform the work until a medical assessment has been made. Employees with an ongoing record of concerns will be referred to the Medical department for assistance.

2. 3.

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4.8

Potable Water

Purpose: To ensure that potable water at AltaSteel is safe for consumption. Responsibility: The Manager Environment and Major Projects will ensure that regular sampling of potable water supplies is done to ensure it meets Provincial Regulatory requirements. AltaSteel Managers will ensure that potable water piping and containers in their area are maintained properly to prevent contamination. Documentation and Records: Workplace Procedures Provincial Regulations Related Procedures: Practice: 1. The Manager Environment and Major Projects is responsible for conducting regular sampling of potable water and test for compliance with Provincial Standards. Table of Contents

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4.9

Indoor Air Quality

Purpose: To ensure that the quality of the air in offices, pulpits, meeting rooms, etc. meets regulatory requirements. Responsibility: Managers will establish smoking policies that are in compliance with regulatory and local government requirements. Managers will respond to any concerns raised about indoor air quality. Documentation and Records: Smoking Policy Provincial Regulations Strathcona County Smoking Bylaws Related Procedures: Practice: 1. A smoking policy will be issued by the HR department. 2. Plant workplace air quality will be monitored as per the Industrial Hygiene program. Table of Contents

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Chapter 5 Hazard Identification 5.1 Hazard Identification and Analysis


Purpose: To ensure that workplace hazards at AltaSteel are identified and analyzed so that they can be controlled. The system must identify hazards on an ongoing basis and analyze work to be performed in a way that details real and potential hazards, hazard sources inherent in the work, and the controls required to minimize or eliminate those hazards. Definitions Hazard - is any circumstance or condition with potential for human injury and/or damage to property or the environment. Hazard Identification - is a thorough evaluation of all equipment, machinery, work areas, and work processes and procedures. Each hazard is recorded, and prioritized with the most dangerous situations being addressed first. This information forms an essential part of employee training and is used to develop hazard controls. Hazard Analysis - involves establishing the mechanism of the hazard, estimating the consequences of the hazard, and identifying controls. Risk/Hazard Classification System - is the quantitative evaluation of the likelihood of a hazard occurring and of its consequences. From this an estimate is made of the likelihood of death, injury and loss in a specific period; the forecast is of a probability of occurrence, not of the exact timing of a potential accident. Hazard Control - is the process of ensuring that control measures are in place to eliminate or reduce the risk of harm to employees. Inspection (Formal and Informal) - is an observation tour of the work site to check that controls to eliminate or reduce the risk of known hazards are in place and working, and to look for real or potential hazards that have not been noted before. Evaluation/Audit - is a comprehensive examination of managements performance in establishing and maintaining a safety program. An audit is conducted periodically by a trained safety auditor either from within the organization or from outside. Responsibility: Managers are responsible for ensuring that Supervisors, in co-operation with employees implement a system of regularly conducting hazard analyses on new or modified equipment and processes as well as reviewing the hazards in existing processes or equipment.

Documentation and Records: Job Safety Analyses Hazard Analyses Occupational Health & Safety Statutes and Regulations Workplace Procedures
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Related Procedures: LIBRARY\PROCEDURES\PLANTWIDE\SAFETY 3.1 HAZARD IDENTIFICATION AND ASSESSMENT Practice: 1. Review current hazard analyses on an annual basis. 2. Conduct a hazard analysis when new equipment is added, or existing equipment is modified. 3. Conduct a hazard analysis when changes to the process are made or when new work is to be performed. 4. Hold pre-job/commissioning meetings to ensure that employees are aware of the hazards associated with performing the work. 5. Correct hazards that are identified and maintain records of those corrections. 6. Use the following approach for hazard analysis: i. Select the work, machinery, tools, equipment, and/or environment that poses a hazard. ii. Examine and discuss job with experienced supervisor and employee. iii. Seek professional assistance on matters that require specialized expertise. iv. Identify, locate, and read the regulations and/or industry standards that apply to the job. v. Locate all appropriate manufacturers recommendations. vi. Locate any existing administrative controls that are in place. vii. Review quality control, accident/incident investigation or other records that may provide a history. viii. Develop the hazard analysis. The analysis needs to identify controls for each of the hazard sources. Hazards having the greatest potential for injury need to be addressed first. ix. Use the following guidelines for hazard classification: Risk/hazard classification is a method of determining the likelihood of a hazard occurring and of its consequences. To be effective, it requires using sound judgment and experience, consulting with employees who may also be exposed to that hazard, looking over accident or incident reports, quality control records, and other information that may be available. Consider loss exposures that could cause problems but havent yet. Choose the most serious reasonably likely loss that could be expected to occur from an identified potential hazard. Use the rule of thumb that if it worries you, its likely enough. The system we use places hazards into three classifications: 1. High Hazard, 2. Medium Hazard, and 3. Low Hazard. High Hazard: Conditions or practices with the potential for permanent disability, loss of life or body part, and/or extensive loss of structure, equipment or material. With this type of hazard a course of action may require shutting down a piece of equipment.
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Medium Hazard: Conditions or practices with potential serious injury or property damage that is disruptive, but less severe than HIgh hazards. Example: Oily conditions in an aisle way. Broken rung on a ladder. Low Hazard: Conditions or practices with the potential for minor injury or illness or non-disruptive property damage. Example: Employee walking through plant without wearing safety glasses. Forklift operator not blowing horn before backing up.

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Chapter 6 Hazard Control 6.1 Hazard Control System


Purpose: The purpose of the hazard control system is to ensure that control measures are in place to eliminate or reduce the risk of harm to employees, contractors or visitors. Control measures consist of three types: Engineering controls deal with systems that protect employees. Examples of engineering controls include installing ventilation equipment to remove dust or toxic vapors, installing guards around moving machinery parts, and making repairs to equipment to ensure it can perform the function for which it is intended, etc. Administrative controls deal with directing people and include broad topics such as policies, practices, procedures, and training. Also included are specific approaches such as scheduling jobs to avoid crowded work areas, rotating employees that perform repetitive work or during severe conditions, and planning jobs with special hazards. Personal protective equipment (PPE) is the least desirable method of hazard control as there is no direct impact on reducing or eliminating the hazard. PPE can only lessen the potential harmful effects of exposure to a known hazard. PPE should be used only to supplement administrative and engineering controls, and not as a substitute for them. Whatever method of control is used, an ongoing system for checking that the method is effective is necessary. Responsibility: Managers are responsible for ensuring systems are in place that establish controls for recognized hazards and monitoring effectiveness of the controls. Day Supervision are responsible for implementing and maintaining hazard control systems. Supervisors are responsible for the day-to-day application of company and departmental hazard controls. Employees are responsible for complying with hazard controls. Documentation and Records: Workplace Procedures and Safety Rules Hazard Analyses Safe Work Practices Occupational Health and Safety Legislation Related Procedures: Practice: 1. Safe work practices and procedures are to be in writing and contained in paper or electronic manuals. 2. All safe work practices and procedures must meet or exceed all applicable legislation and industry standards.
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3. Employees are made familiar with safe work practices and procedures developed to control hazards before they start work. 4. Known hazards that can not be readily controlled must be brought to the attention of employees. 5. Safe work practices may not be limited to a specific task, but deal with a fairly wide range or work activities (e.g. using an overhead crane, entering a confined space, handling chemicals, and locking out equipment). They are especially useful in situations where employees perform a large number of tasks infrequently or where specific tasks are hard to proceduralize because of the way they are done varies greatly with the specific situation. 5. The following areas should be emphasized in developing safe work practices: a. Explain why the employee should comply with the Safe Work Practice. b. Point out the most probable sources of problems; the things to which special attention should be paid. c. Specify required clothing and equipment, the conditions under which it is required, and the reasons for its use. d. Emphasize proper use of special guards, barriers, switches, locks and emergency equipment. e. Reinforce the most important rules by including them in the Safe Work Practices. Keep them as short and simple as possible, and give the reason for the rules. f. Highlight the things that the employee can do to ensure efficient, safe, productive results. Keep the thou shall nots to a minimum. Work on the positives. g. Summarize the most important points.

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6.1.1 Organization of Procedures


Purpose: To provide an organized system of workplace procedures at AltaSteel such that procedures can be easily used, accessed and revised. Responsibility: The Vice President Administration will provide an electronic file system that is accessible at all AltaSteel computer stations and can be accessed by the procedure writers for issuing and modifying procedures. Managers and Vice-Presidents will co-ordinate procedure organization so that procedures can be easily accessed and used. Documentation and Records: Manuals and Workplace Procedures Templates Related Procedures: Practice: 1. The systems department will maintain a common electronic file organization system for use by all personnel issuing procedures. 2. The normal practice for manuals and procedures will be electronic. Where paper manuals or procedures are used, it will be noted on the electronic system. 3. The systems department will provide templates for use in developing procedures, manuals and practices. 4. Plant wide workplace procedures will be administered and controlled by the Supervisor Personnel and I.R. 5. Department workplace procedures will be administered and controlled by the respective Manager. Table of Contents

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6.2

Hazardous Materials

6.2.1 Workplace Hazardous Materials Information System (WHMIS)


Purpose: To ensure that employees of AltaSteel are trained in the WHMIS requirements and a program is in place to classify and identify controlled products as required by legislation. There will be Union/Company participation in the program. Responsibility: The Supervisor Personnel and I. R. is responsible for providing core WHMIS training for all employees and new hires and maintaining a record of that training. Job specific training for employees who are "in contact with", "in proximity to", or "use" controlled products is the responsibility of supervision. Documentation and Records: Government Regulations Workplace Procedures WHMIS Binders Related Procedures: Practice: 1. All employees will receive four hours of instruction on the WHMIS core program. 2. Requests for new products require form A1999 "Request for Approval of New Material" to be forwarded to Purchasing by the requesting department. 3. Employees having received core WHMIS training must be familiar with labels, MSDS and the information provided. 4. Departments will train employees in safe storage, handling, use and disposal of controlled products. 5. If required, safe job procedures will be written for controlled products that are used and they will be reviewed with employees. 6. The training program is to be reviewed annually by the Joint H&S committee. 7. WHMIS compliance will be part of Joint H&S inspection tours. 8. Job training requirement lists should identify WHMIS controlled products regularly used in the area so that employees can familiarize themselves with the MSDSs. Table of Contents

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6.2.2 Transportation of Dangerous Goods


Purpose: To ensure that Dangerous Goods at AltaSteel are handled in accordance with the requirements of the Transportation of Dangerous Goods (TGD) Act and Regulations. Responsibility: The Senior Stores Administrator is designated and qualified as the TGD shipper for AltaSteel. Managers are responsible for ensuring that receiving or shipping of Dangerous Goods is done in compliance with the regulations. Documentation and Records: Transportation of Dangerous Goods Act and Regulations Shipping and Receiving Documents AltaSteel TDG Procedures Related Procedures: Practice: 1. All shipping and receiving is to be conducted in compliance with the TDG Act. 2. Dangerous goods are broadly defined as any product or substance that presents a threat to human health or the environment. 3. There are exemptions to the regulations but exemptions can be complicated and must be reviewed carefully to avoid non-compliance. AltaSteel has resolved to treat certain goods that might be exempt as "dangerous" so that there is less chance of personal error and a high standard of safety is maintained. If you are dealing with new products, contact purchasing. If you require assistance contact Stores. 4. Dangerous Goods regulations are closely related to WHMIS in a general way. There are nine classes of Dangerous Goods and these classes may be further divided into divisions. The key difference to WHMIS is that materials off the property are Dangerous Goods and on the property are controlled products.

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6.2.3 Radiation and Radioactive Materials


Purpose: To ensure a system is in place to protect AltaSteel employees from exposure to radiation from radiation sources used in process control equipment, and to ensure that radioactive sources contained in steel scrap are detected before they enter the plant or before they are melted down and contaminate our products and our facilities. Responsibility: The Supervisor Electrical Steelmaking is the designated Radiation Safety Officer and is responsible for implementing and maintaining systems that detect and prevent radioactive scrap from entering the plant and down stream Steelmaking processes. He is also responsible for the program that monitors employee radiation exposure levels for employees working on the caster floor. Supervisors of areas utilizing detectors or sources are responsible for training personnel in proper handling and response to emergencies or alarms. Documentation and Records: Atomic Energy Control Act Monthly Survey Reports Radiation Monitoring and Control Procedures Radiation Alarm Procedures Radiation Incident Reports Related Procedures: Practice 1. All employees responsible for using, maintaining or operating the detection equipment will receive appropriate training and instruction. 2. Procedures will be written and maintained to monitor and protect AltaSteel employees and facilities from radiation sources. 3. Radiation detectors will be fully operational to monitor incoming scrap at all times. 4. Response to radiation alarms will be immediate. All radiation incidents will be investigated and a report will be issued. 5. Radiation incidents will be reported to the Atomic Energy Control Board, as determined by the Atomic Energy Control Act. 6. The system will be audited by the Joint H&S committee. Table of Contents

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6.2.4 PCB Control


Purpose: To ensure that PCB containing products are safely managed at AltaSteel. Responsibility: The Manager Environment and Major Projects is responsible for ensuring that AltaSteels practices meet government regulatory requirements. The Managers are responsible for ensuring procedures are in place to respond to emergencies involving PCBs. The Supervior Electrical Steelmaking is responsible for maintaining the PCB storage facility and maintaining an inventory list of PCB materials (except transformers). The Manager Environment and Major Projects is responsible for reviewing the status of PCB containing transformers and planning replacement with non-PCB transformers. Documentation and Records: Workplace Procedures PCB Inventory list Federal PCB Regulations Related Procedures: Practice: 1. 2. 3. 4. Waste PCB materials will be disposed of at the earliest practical time in accordance with Regulations. Until they are disposed of, waste PCB materials will be stored in the PCB Storage facility in the AIM Building. The PCB storage facility will be regularly inspected and carefully monitored for fire prevention and to ensure compliance with Regulations. Transformers containing PCBs will be identified and procedures put in place for emergencies involving them.

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6.2.5 Asbestos Control


Purpose: To ensure safe management of asbestos materials at AltaSteel. Responsibility: The Manager Environment and Major Projects is responsible for ensuring that AltaSteels practices meet regulatory requirements. The Manager Environment and Major Projects is responsible for maintaining an inventory list of asbestos materials at AltaSteel. Documentation and Records: Asbestos inventory list Alberta Regulations Workplace Procedures Related Procedures: Practice: 1. All areas containing asbestos material will be inventoried and where necessary, regular work place air quality surveys will be done. 2. Materials containing asbestos will be managed to ensure that the workplace air quality meets regulatory requirements. 3. Cleanup and disposal of asbestos containing materials will be done in accordance with the Regulations. Table of Contents

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6.3

Work Requiring Permits

6.3.1 High Voltage Permits


Purpose: To ensure that all high voltage electrical work at AltaSteel is done safely and in a consistent manner. Responsibility: The Superviors Electrical are responsible for ensuring that a permit system is in place to authorize any high voltage electrical work and that all regulatory requirements are met. Documentation and Records: Workplace Procedures High voltage permits Provincial Regulations Related Procedures: Practice: 1. All work done on or near high voltage electrical equipment will be done using a permit system and following the procedures issued by either the Bar Mill or Steelmaking Maintenance departments. 2. High voltage at AltaSteel is defined as 750 volts and higher. 3. The Supervisors Electrical will maintain the permit system and retain copies of permits issued in the previous 2 years. Table of Contents

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6.3.2 Gas and Oxygen Work Permits


Purpose: To ensure that work on natural gas and oxygen systems is done in a safe, controlled and consistent manner. Responsibilities: Day Supervision are responsible for implementing and maintaining a permit system for new installations and modifications to existing installations of natural gas and oxygen systems. Documentation: Workplace Procedures Gas and Oxygen Permits Related Procedures: Practice: 1. All work done on new installations of, or modifications to, natural gas and oxygen systems must be done using a permit system and following established safe work procedures. Repairs of existing equipment do not require a Gas and Oxygen permit but may require cutting and welding permits. 2. The Supervisors Electrical and Mechanical will implement and maintain the permit system as well as retain the completed permits used in the past 2 years. Table of Contents

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6.3.3 Cutting and Welding Permits


Purpose: To ensure that all cutting and welding work is done in a safe, controlled and consistent manner. Responsibilities: Day Supervision are responsible for implementing and maintaining a permit system for cutting and welding work at AltaSteel. Documentation: Workplace Procedures Cutting and Welding Permits Related Procedures: Practice: 1. Cutting and welding work will require permits if done in high hazard areas or areas where cutting and welding is not routinely performed. These areas will be defined in the system and the type of permit required will be outlined. 2. The Supervisors Electrical and Mechanical will implement and maintain the permit system as well as retain the permits used in the past 2 years. Table of Contents

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6.3.4 Excavation Permits


Purpose: To ensure that all excavation and pile driving work at AltaSteel is done in a safe, controlled and consistent manner. Any work that can result in damaging buried utilities is covered by this permit system. Responsibilities: Day Supervision are responsible for implementing and maintaining a permit system for excavation work at AltaSteel. The Engineering Manager responsible for establishing standards for excavation work and ensuring they comply with regulations. Documentation: Workplace Procedures Excavation Permits Alberta Regulations Related Procedures: Practice: 1. All excavation work requires permits. This includes work such as driving piles, fence posts, bumper or guard posts, directional drilling and augering. 2. The Supervisors Electrical and Mechanical will implement and maintain the permit system as well as retain the completed permits used in the past 2 years. 3. Prior to permits being approved locations of underground utilities must be clearly identified. Table of Contents

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6.3.5 Man Basket and Aerial Platform Permits


Purpose: To ensure that man baskets and aerial platforms are operated safely and in a consistent manner. Responsibility: Day Supervision are responsible for establishing plant wide procedures that include permitting for the operation of man baskets and aerial platforms. The Purchasing Department is responsible for ensuring that rented aerial platforms meet AltaSteel and Alberta regulatory requirements. Documentation and Records: Workplace Procedures Man basket Permits

Related Procedures: Practice: 1. All man basket and aerial platform operations require permits approved by the supervisor. 2. Aerial platform operators must be qualified as per AltaSteel procedures. 3. Man baskets may be used only on certain cranes at AltaSteel. See the Manager Maintenance and Engineering for details. Table of Contents

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6.3.6 Electrical Permits


Purpose: To ensure that all electrical installations at AltaSteel are done in compliance with Alberta regulations. Responsibility: The Manager Environment and Major Projects and Managers are responsible for ensuring that all new installations are done in compliance with Alberta regulations and that all necessary permits are obtained. The Supervisor Electrical Steelmaking is responsible for organizing annual inspection(s) and renewal of AltaSteels annual electrical permit. Documentation and Records: Electrical Permits Alberta Regulations Related Procedures:

Practice: 1. If required, a permit will be obtained before commencing any new electrical installations. 2. Annual permit(s) will be obtained as per provincial regulations. Table of Contents

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6.3.7 Confined Spaces


Purpose: To ensure that work done in confined spaces is done safely and in accordance with all provincial regulations. Definition: Confined Space: - An enclosed or partially enclosed space, having restricted access and egress and which, due to its design, construction, location, atmosphere, the materials or substances in it or other conditions, is or may become hazardous to a employee entering it or does not have an easy means of escape for or rescue of a employee entering it. Responsibility: The Managers are responsible for ensuring that a code of practice is in place to control entry into and work in confined spaces. This will include a permit system. Managers are responsible for ensuring that employees, visitors and contractors know and understand the code of practice and follow it. Day Supervision are responsible for implementing the code of practice. Documentation and Records: Code of Practice Alberta Regulations Workplace Procedures Confined Space Entry Permits Related Procedures:

Practice: 1. All employees will follow the code of practice for confined spaces. 2. All confined spaces will be clearly identified. 3. All employees required to enter confined spaces must be properly trained and qualified. 4. The Supervisor Electrical and Mechanical will control the issue of entry permits and retain all permits issued in the past 2 years. 5. Gas Testers must be properly qualified, trained and authorized. Table of Contents
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6.3.8 Contractor Work


Purpose: To ensure that contract work done at AltaSteel is done in accordance with Alberta Regulations and AltaSteel procedures, practices and safety rules. Definition: Contact Person a designated AltaSteel employee who is in direct control of the contractor work. Responsibility: The Managers are responsible for ensuring that a system is in place for controlling contract work at AltaSteel. This will include a permit system. All Managers are responsible for ensuring that employees and contractors know and understand the CSWP system, their role in it and comply with the requirements. The Supervisor Personnel and I.R. is responsible for training of Contractor Supervisors. Documentation and Records: Contractor Safe Work Procedure Manual Alberta Regulations Workplace Procedures Contractor Safe Work Permits Related Procedures:

Practice: 1. All Contractor work done at AltaSteel will be done in accordance with the Contractor Safe Work Procedure Manual including having a designated Contact Person for each job. 2. All Contact Persons must be trained and authorized. 3. Contractor Supervisors will be trained in the requirements of the Contractor Safe Work Procedure Manual and familiarized with the plant site. 4. Supervision and Maintenance and Engineering personnel will control the issue of Contractor Safe Work Permits and retain all permits issued in the past 2 years. Table of Contents
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6.4

Control of Cranes and Mobile Equipment

6.4.1 Modification to Cranes and Mobile Equipment and Lifting Equipment


Purpose: To ensure that modifications to cranes, mobile equipment and lifting equipment at AltaSteel are completed in a controlled manner in accordance with recognized engineering standards and provincial regulations. Responsibility: The Operating Managers are responsible for ensuring that modifications to cranes, mobile equipment and lifting equipment are done only when written approval from AltaSteel Engineering has been received. The Maintenance & Engineering Managers are responsible for ensuring that modifications are done in accordance with recognized engineering standards and applicable regulations. Maintenance & Engineering Managers are responsible for implementing a system of written requests for modifications to cranes, mobile equipment and lifting equipment. Documentation and Records: Written requests for modification. Alberta Regulations Workplace Procedures Crane Design Standards Related Procedures: ESM-MT-209.004Code of Practice for Lifting Equipment ESM-MT-209.012Temporary Lifting Lugs AS-BM-218.01 Procedures and Policies AS-BM-218.02 Repair Flow Chart AS-BM-218.03 Department Policies AS-BM-218.05 Temporary Lifting Lugs AltaSteel Safety Manual Module 6.4.6 Non Destructive Testing of Cranes and Mobile Equipment Practice: 1. All modifications to cranes or mobile equipment require the written approval of AltaSteel Engineering or qualified consulting engineers external to AltaSteel.
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2. The Maintenance and Engineering Managers will retain the records of crane modification approvals. Table of Contents

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6.4.2 Crane Boarding and Security


Purpose: To ensure that access to overhead cranes at AltaSteel is properly controlled. Responsibility: Day Supervision are responsible for ensuring written procedures are in place to control access to critical overhead cranes. Documentation and Records: Workplace Procedures Related Procedures:

Practice: 1. Day Supervision will issue procedures for boarding of overhead cranes. These will be communicated to all persons who board the crane. 2. Day Supervision will issue procedures outlining the requirements for locking out cranes that are not in use. This includes methods of control for radio control boxes and pendants.

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6.4.3 Crane and Mobile Equipment Operation


Purpose: To ensure that cranes and mobile equipment at AltaSteel are operated safely and consistently. Responsibility: Day Supervision are responsible for ensuring written procedures are in place for operation of cranes and mobile equipment. Day Supervision are responsible for ensuring that all cranes and mobile equipment are equipped with safety equipment required by Alberta legislation. Purchasing will ensure that any rental cranes or mobile equipment meet AltaSteel requirements for safety equipment as specified by the requisitioner. Documentation and Records: Workplace Procedures Alberta Legislation Related Procedures:

Practice: 1. Day Supervision will issue procedures for operation of cranes and mobile equipment. 2. Day Supervision will issue requirements for cranes and mobile equipment when rentals are ordered. Table of Contents

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6.4.4 Authorization of Crane and Mobile Equipment Operators


Purpose: To ensure that cranes and mobile equipment at AltaSteel are operated safely and consistently by properly qualified Operators. Responsibility: Day Supervision are responsible for ensuring written procedures are in place for authorization of crane and mobile equipment Operators. Supervision are responsible for training and qualifying personnel to operate cranes and mobile equipment. Day Supervision are responsible for maintaining qualified operator lists for every overhead crane and piece of mobile equipment operated by AltaSteel people. Purchasing will ensure that any crane operating service purchased includes appropriate provincial certification and the Contact Person involved will ensure that rented cranes are operated only by Operators with provincial certification (if required) or authorized AltaSteel Operators. Documentation and Records: Workplace Procedures Alberta Legislation Authorized Operator Lists Training Records Medical Records Related Procedures: Practice: 1. Day Supervision will issue procedures for authorization of crane and mobile equipment Operators. 2. Day Supervision will maintain authorized Operator lists. 3. Operators who have not operated equipment for more than a year must be re-familiarized with the operation before being permitted to operate. 4. Operators who have not operated equipment for more than 3 years must be removed from the authorized operator list. 5. Crane and mobile operators who are AltaSteel employees must meet AltaSteel medical requirements before being authorized.
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6.4.5 Operator Inspection of Cranes and Mobile Equipment


Purpose: To ensure that operator inspections of cranes and mobile equipment are performed consistently and to AltaSteel and regulatory requirements. Responsibility: Day Supervision are responsible for ensuring written procedures are in place for frequency and type of operator inspection for each crane and piece of mobile equipment and that the procedures comply with provincial regulations. Qualified Operators who operate cranes and mobile equipment are responsible for carrying out inspections according to the checklists and established frequency for the specific crane or piece of mobile equipment. Documentation and Records: Workplace Procedures Provincial Regulations Related Procedures: Sub module 6.4.4 Authorization of Crane and Mobile equipment OperatorsPractice: 1. Day Supervision will issue procedures and checklists for operator inspection of mobile equipment and cranes. 2. Day Supervision will retain completed checklists for at least 3 months. 3. For regularly operated production cranes and mobile equipment inspection frequency will be once per operating shift. 4. Cranes and mobile equipment that are not regularly operated will have inspection frequency specified by Day Supervision. Table of Contents

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6.4.6 Non Destructive Testing of Structures, Cranes, Mobile Equipment and Lifting Equipment
Purpose: To ensure that structures, cranes, mobile equipment and lifting equipment are inspected regularly to avoid potential failures. Responsibility: The Engineering and Maintenance Managers are responsible for establishing the required inspection frequency and the type of inspection required for each piece of equipment and ensuring that it complies with Provincial Regulatory requirements. The Bar Mill Engineering and Maintenance Manager is responsible for implementing and carrying out the Non Destructive Testing program and providing feedback to equipment owners. Operations Managers and Supervisors are responsible for making equipment available for testing and providing the necessary assistance to the NDT Inspector to complete the testing. The NDT Inspector is responsible for performing crane and mobile equipment testing as per Engineering requirements and assessing the result of the testing. The Bar Mill Maintenance and Engineering Manager is responsible for scheduling and carrying out structural inspections of cranes, crane runways, crane cabs, buildings and other critical structures.

Documentation and Records: Workplace Procedures Provincial Regulations NDT Schedules and Reports Structural Inspection Schedules and Reports CMMS reports Related Procedures: ESM-MT-209.004Code of Practice for Lifting Equipment ESM-MT-209.012Temporary Lifting Lugs AS-BM-214.01A Inspections on Overhead Cranes AS-BM-218.01 Procedures and Policies AS-BM-218.04 Approved Department Equipment AltaSteel Safety Manual Module 6.4.1 Modification to Cranes, Mobile Equipment and Lifting Equipment
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Practice: 1. 2. 3. 4. 5. 6. The NDT Inspector will issue schedules of testing and regular reports of testing results. The AltaSteel civil engineer will schedule and carry out structural inspections of runways, crane cabs, buildings and other critical structures. Testing requirements must be authorized by Engineering and cannot be changed without Engineering approval. Any purchased cranes, mobile equipment, or lifting equipment will be examined by a qualified NDT Inspector prior to being put into service. Equipment put on hold by the NDT Inspector must not be used until released by the NDT Inspector or the Engineering and Maintenance Manager. Third party Structural inspection of cranes is to be done once every 3 years for the Scrap Crane, Charge Crane, Pouring Crane, Merchant Bar Crane and Rebar Runway Cranes. All other cranes are to be done every 5 years.

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6.5

Control of Equipment required for Safety and Emergency Response

6.5.1 Respirator Program


Purpose: To ensure a system is in place to provide AltaSteel employees with a Respirator Program in compliance with Corporate Policies and Occupational Health and Safety Acts, Regulations and Code and to ensure that respirators are worn when required, and properly used and maintained. Responsibility: The Supervisor Personnel and I.R. will be responsible for coordinating the respiratory protection program. Equipment will be specifically approved by the National Institute for Occupational Health and Safety (NIOSH), Certified Equipment List. Day Supervision are responsible for ensuring written procedures are in place for areas or activities that require respirators. Day Supervision are responsible for ensuring that personnel are trained in use and maintenance of respirators and that necessary fit testing and medical clearance has been done. Day Supervision are responsible for reviewing the operations and determining where respirator use is mandatory or optional. This will be done in conjunction the HR and medical department. The Medical department is responsible for performing fit testing and reviewing employee fitness for respirator use and maintaining records of same. The HR department is responsible for maintaining a stores inventory of appropriate respirators for the different operational requirements. Documentation and Records: Workplace Procedures Medical Records Occupational Health & Safety Act, Regulation and Code Code of Practice Medical Records fit testing Medical Records pulmonary function tests Related Procedures:

Practice:
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1. In making a determination for the mandatory use of respiratory protective equipment the following shall be considered: a. The nature of any contaminant b. The concentration or likely concentration of any airborne contaminants c. The likely duration of the employees exposure d. The toxicity of the contaminant e. The partial pressure of oxygen f. The warning properties of the contaminants g. The need for emergency escape 2. Day Supervision shall maintain written procedures outlining which areas or activities require respirator use and what type of respirator is required. The HR department or Maintenance and Engineering department will provide technical assistance if required. 3. Employees will be responsible for the cleaning and maintenance of reusable respirators. 4. Each operating department is to train employees in the selection, care and use of the appropriate personal protective equipment, and enforce the developed controls. 5. Supervisors must assure that respirators are issued only for the purpose intended in accordance with this practice. 6. Employees who are or may be required to wear respirators are to be medically examined and fitted by the Medical Department. 7. Workers requiring respirators will be trained in their purpose including: a. Being informed of the airborne contaminant, including its properties and potential heath effects; b. Why the particular respiratory protective equipment was chosen and its limitations; c. How to put on and take off the respirator; d. Satisfactory fit procedure and requirements; e. This System description 8. Respirators are to be maintained in a clean and sanitary condition and stored in a manner to prevent their contamination. Respirators will be inspected before and after each use. 9. Respirators will be obtained from Stores and must not be ordered directly from suppliers. Special respirator requirements must be forwarded to the Supervisor Personnel and I.R. for evaluation of the most appropriate respirator, worksite evaluation, and respirator approval. Table of Contents

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6.5.2 Failure or Disabling of Safety Devices and Alarms


Purpose: To ensure the proper response occurs when critical safety devices and alarms fail or are disabled Responsibility: Managers are responsible for ensuring that written procedures are in place for responding to the failure of critical safety devices or alarms and that employees are trained accordingly. Documentation and Records: Workplace Procedures Related Procedures: Practice: 1. Each department will have written procedures in place outlining how safety device and alarm failure will be dealt with. 2. The normal practice should be to repair failures when they happen. 3. Where it is deemed acceptable to operate without devices it requires approval of Managers who will ensure appropriate protection is in place.

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6.5.3 Personal Protective Equipment


Purpose: To ensure that personal protective equipment (PPE) equipment such as safety boots, hard hats, safety glasses, heat coats, aprons, etc that is intended to provide protection from hazards employees are exposed to at work is worn and cared for. Responsibility: Day Supervision is responsible for recommending PPE for each area or task. The Supervisor Personnel & I.R. is responsible for authorizing PPE for use on the job and stores stock inventory items. Supervisors are responsible to ensure that PPE is used. Employees are responsible for wearing and caring for their PPE. Stores and HR will ensure stocks of commonly used PPE are maintained in stores. Documentation and Records: Workplace Procedures Provincial Regulations Related Procedures: Practice: 1. Day Supervision will review their operations and determine what PPE is required for each area or task. 2. PPE requirements will be documented in workplace procedures and included in job training. 3. Replacement PPE will be made available as required. Table of Contents

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6.5.4 Working at Height &Safety Belts and Harnesses


Purpose: To ensure that the hazards associated with working at heights are controlled and that safety belts and harnesses are properly used and inspected. Responsibility: Day Supervision are responsible for administering safety belt and harness procedures and ensuring that belts, harnesses, lanyards and training are provided. Day Supervision are responsible for establishing procedures for working off ladders. Employees are responsible for inspecting, wearing and caring for their safety belts and harnesses and for following procedures. The HR department is responsible for performing regular plant wide inspections of belts and harnesses and providing the results of the inspection to management. Documentation and Records: Workplace Procedures Provincial Regulations: GSR, Sections 21(1), 90, 91 & 92. CSA Standards: CSA approved safety belts and lanyards (CSA Z259.1-1976) and CSA approved full body harnesses (CSA Z259.10.M90). Related Procedures: Practice: 1. Day Supervision will review their operations and determine which tasks require safety belts and harnesses. Since it is not possible to anticipate every requirement employees must be aware of the regulations and use a harness or belt where required.

2. Full body safety harnesses, complete with lanyards are to be used by workers to provide fall protection when it is possible to fall a vertical distance greater than 3.5 meters from a temporary work area or 1.2 meters from a permanent work area unless other fall protection safeguards, such as; a guardrail or a safety net is in place. 3. Safety belts and lanyards are to be used only as a restraining device, or tether, that will prevent workers from approaching a fall zone hazard area, such as; the edge of a roof, a crane, a platform, or another elevated structure. 4. Full body harnesses, complete with lifelines, are to be used by workers so they can be pulled to safety when there is a danger of drowning, entrapment or engulfment from any free flowing material. 5. The HR department will regularly (at least every 2 years) perform a plant wide inspection of belts and harness and communicate the results of the inspection. 6. Maintenance Supervision will maintain procedures outlining proper ladder use and how to work off ladders and scaffolding.
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7. When work at a height is done, involving several people such as; crane cable reeving, or crane overhauls, pre-job safety meetings are required. Table of Contents

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6.5.5 Use of Radios


Purpose: To ensure that radio communication at AltaSteel is done in a professional manner and in compliance with federal regulations. Responsibility: Supervision are responsible for educating employees about proper radio use and etiquette. The Supervisor Electrical Steelmaking will maintain a written procedure outlining proper radio use and etiquette. The Steelmaking Maintenance and Engineering department maintains AltaSteels radio licenses and keeps up to date on regulatory requirements. Documentation and Records: Workplace Procedures Federal Regulations Related Procedures: Practice: 1. Supervision will provide training in radio use for all employees. 2. During emergencies, radio communication is restricted to only that required to deal with the emergency. Table of Contents

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6.5.6 Use of Cell Phones


Purpose: To ensure that AltaSteel employees use cell phones in a safe and proper manner. Responsibility: The Supervisor Personnel and Industrial Relations Documentation and Records: Related Procedures: Practice: 1. Cell phones are not to be used while driving motor vehicles. In the event that a call is received on a cell phone while operating a motor vehicle, the employee must pull over and stop at the side of the road, and then take the call. Table of Contents

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6.5.7 Emergency Lighting


Purpose: To ensure that emergency lighting at AltaSteel meets regulatory requirements and is properly maintained. Responsibility: Day Supervision are accountable for determining where emergency lights are required, ensuring that lighting systems meet the necessary requirements, and ensuring that appropriate testing and record keeping is done. Documentation and Records: Workplace Procedures Federal Regulations Related Procedures: Practice: A) Areas Requiring Emergency Lighting 1. Exit access areas from normally occupied work areas such as offices, pulpits, shops, etc. must have emergency lighting. An exit access area is defined as: stairs, aisles, corridors, ramps and passageways leading to a building exit. 2. Normally occupied offices, pulpits, shops, etc. which are not adjacent to a corridor with emergency lighting must have emergency lights. 3. Cab operated overhead cranes must be equipped with rechargeable flashlights for use by the crane operator in the event that emergency egress is required. 4. Areas such as conveyor galleries, tunnels, etc. which may become hazardous to exit in the event of a power outage must be signed to require carrying of a flashlight while in them. B) Emergency Lighting System Performance Requirements 1. Emergency lighting systems must at minimum meet the requirements specified in section 5.9.2 of the NFPA Standard #101. C) Emergency Light System Testing 1. Emergency light system testing must be periodically tested as per section 5.9.3 of the NFPA Standard #101. Table of Contents
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6.5.8 Gas Testing Equipment


Purpose: To ensure that gas testing equipment is properly calibrated and maintained. This typically includes testers used for oxygen level, combustible gases, carbon monoxide, sulfur dioxide, etc. Responsibility: The Maintenance Supervision will control the issue, inventory, calibration and testing of gas testing equipment. The HR department will organize training sessions for gas testers and maintain a list of qualified gas testers. Documentation and Records: Workplace Procedures Provincial Regulations Calibration Procedures Related Procedures: Practice: 1. Calibration of gas testing equipment will be done by qualified electrical personnel 2. Gas testing will be done by qualified gas testers.

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6.5.9 Management of Fire Extinguishers, Stretcher Stations, Eye Wash Stations, Safety Showers and Water Jel Blankets
Purpose: To ensure that this critical emergency response equipment is in place when needed and properly maintained and in compliance with provincial regulations. Responsibility: Managers are responsible for determining locations and quantities of each type of equipment. The HR department will provide technical advice on appropriate types and quantities of equipment. Day Supervision will implement regular inspections of this equipment in accordance with regulatory requirements. The HR department will implement annual inspections of this equipment utilizing outside expertise. Stores in conjunction with Purchasing and the HR department will establish a process for replacing spent fire extinguishers. Documentation and Records: Workplace Procedures Provincial Regulations Checklists Related Procedures:

Practice: 1. Managers will maintain a list of required equipment and locations and put in place procedures to maintain the equipment as well as identifying the locations with signs as required.
2. Day Supervision will develop an inspection checklist and ensure this is done weekly. Reports will

be submitted to Security who will summarize inspections done and report this back to the Managers.
3. Day Supervision will ensure spent fire extinguishers; used water gel blankets and stretcher

equipment are replaced promptly. Table of Contents

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6.6

Other Work Processes

6.6.1 Design and Maintenance of Equipment


Purpose: To provide the necessary measures and controls to address facilities design and construction process, facility layout, environmental control systems, and safety devices for the protection of employees performing work. To ensure that all tools and equipment are maintained in a condition that will not compromise the health and safety of employees using the equipment and that it will perform the function for which it is designed and is free from defects that will impair safety. To ensure that maintenance systems include tool/equipment inspections and follow-up, preventative and regularly scheduled maintenance, and effective fault reporting and handling. Responsibility: The Mangers Maintenance and Engineering are responsible for ensuring that design work will incorporate appropriate health, safety, ergonomic, and environmental protection and quality standards and that inspections, repairs, and preventative and regularly scheduled maintenance are done in accordance with the manufacturers specifications, regulatory requirements, and/or certified by a professional engineer as required. Documentation and Records: Manufacturers Specifications Maintenance Recommendations Plans and Drawings CSA Standards Alberta Fire Code OH&S Act, Regulations and Code, AltaSteel Manual of Engineering Practice Audit Reports AltaSteel Management Manual Related Procedures: Practice: 1. The Manager Maintenance and Engineering is responsible for the development and continuance of design and maintenance standards for mechanical, electrical and other technologies. 2. The Maintenance and Engineering Department in co-operation with Operations will ensure that all appropriate quality, health and safety, ergonomic, and environmental protection standards are applied in the design of the facilities. 3. The Maintenance and Engineering Departments will provide technical support to Operations/NDT Inspector on matters of design changes and/or modifications, inspections, repairs, preventative and regularly scheduled maintenance. 4. Operating departments are responsible for developing, conducting and recording routine tool/equipment inspections consistent with established Inspection Checklists.
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5. NDT Inspector and Maintenance and Engineering Departments are responsible for establishing preventative maintenance inspection schedules, conducting the inspections consistent with established checklists and scheduled frequencies, and maintaining records. The NDT inspector is responsible for advising operations, maintenance, and engineering when inspections are scheduled for cranes, lifting equipment, mobile equipment and hot metal equipment. 8. The Maintenance and Engineering Department in co-operation with the Supervisor Personnel and I. R. will interpret and communicate regulatory requirements. Table of Contents

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6.6.2

Construction and Repair Guidelines

Purpose: To ensure that critical repair and new construction of safety related equipment such as stairs, ladders, utility lines, handrails, pulpits, crane cabs, etc. is performed according to consistent guidelines. Responsibility: The Maintenance and Engineering Department will establish guidelines for repair and new construction of safety related equipment. They will also be available for consultation if standards are not clear or unavailable. Day Supervision and Maintenance and Engineering Departments will ensure that repair and construction of safety related equipment is performed according to the guidelines. Documentation and Records: Workplace Procedures Provincial Regulations Construction and Repair Guidelines Related Procedures: Practice: 1. Engineering will establish guidelines and publicize them for all operating and maintenance management. 2. Engineering, operating and maintenance management will educate their people and contractors in the use of the guidelines and ensure that they are followed. Table of Contents

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6.6.3 Lockouts and Zero Energy State


Purpose: To ensure that a system is in place for reduction to a zero energy state of equipment during construction, repair and maintenance. Responsibility: The HR department will maintain a system of safety lock issue and control which ensures that personal safety locks can be opened only by the lock owner or by a master key under carefully controlled conditions. Managers will establish procedures for lockouts and reduction to a zero energy state that meet all regulatory requirements and are consistent throughout the plant. Documentation and Records: Workplace Procedures Provincial Regulations Security Records Related Procedures:

Practice: 1. Safety lock issue will be controlled by security. 2. All employees will be issued personal safety locks when required. 3. Procedures for lockouts and reduction to a zero energy state must cover disconnecting and locking of electrical energy sources, blocking of any gravity or momentum energy source, bleeding of pressure from hydraulic or utility lines and testing to double check the lockout. 4. The HR department will establish a specific procedure for removing safety locks where the lock owner is not available. Except as outlined in the procedure locks shall only be removed by the owner. 5. All safety locks must be identified with the owners name or employee number. Table of Contents

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6.6.4 Restricted Access Areas


Purpose: To ensure that a system is in place for identifying areas which require restricted access and establishing procedures for controlling access to restricted areas. Responsibility: Managers will establish restricted area procedures that meet all regulatory requirements and are consistent throughout the plant.
Day Supervision and Maintenance and Engineering personnel will communicate the procedures to

employees, contractors and others as required and ensure they are followed. Documentation and Records: Workplace Procedures Provincial Regulations Related Procedures:

Practice: 1. Procedures for restricted areas will cover roping off, entry authorization, signing & identification of area. 2. Permanently restricted areas must be signed with access restrictions clearly identified. Table of Contents

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6.6.5 Grinders
Purpose: To ensure fixed and hand held Grinder use at AltaSteel meets provincial regulatory requirements and AltaSteel procedures. Responsibility: Day Supervision are responsible for ensuring that grinders and grinder operating procedures comply with Provincial regulatory requirements. Purchasing and the requisitioner are responsible for ensuring that purchased grinders and grinding tools meet Regulatory requirements. Day Supervision are responsible for implementing a program of regular inspection of grinders. The HR Department will conduct regular plant wide inspections of grinders and publicize the results. Documentation and Records: Workplace Procedures Provincial Regulations Related Procedures:

Practice: 1. Procedures must cover requirements for RPM labeling, matching speed requirements of the stone and grinder, tool rest installation and adjustment, grinding on the side of abrasive wheels, PPE requirements, and inspection of stones.
2. Day Supervision are responsible for establishing training requirements for operation of both fixed

and hand held grinders. Operators must demonstrate an understanding of the procedure requirements and competence in the use of the equipment. 3. Only trained personnel may operate grinders. 4. All fixed grinders must have a face shield available.
5. Day Supervision will implement a program of regular inspections of grinders utilizing a checklist.

Completed checklists will be retained for 2 years. 6. The HR department will conduct an annual inspection of grinders utilizing outside expertise and report the inspection results to the Managers. Table of Contents

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6.6.6 Working Alone


Purpose: To ensure that people working alone at AltaSteel do so in a safe manner that complies with provincial regulations. Responsibility: The HR department will issue a policy on working alone that complies with Provincial Regulations. Supervision will ensure that the policy is complied with. Documentation and Records: Workplace Procedures Provincial Regulations Related Procedures:

Practice: 1. People who work in an isolated location on the plant site must establish regular communications with the security guard. 2. Where people are regularly working alone a written procedure will be developed. Table of Contents

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6.6.7 Pressure Vessels & Pressure Relief Valves


Purpose: To ensure that pressure vessels and pressure relief valves are maintained and inspected in compliance with Provincial Regulations Responsibility: Maintenance Supervision are responsible for maintaining a listing of all pressure vessels and pressure relief valves in the plant and arrange inspection by an outside inspector at the required frequency. Engineering will ensure that any pressure vessels which are purchased, leased or rented meet provincial regulatory requirements and that any modifications to pressure vessels are done in accordance with provincial regulatory requirements. Documentation and Records: Inventory Lists Provincial Regulations IGOR Records Related Procedures: Practice:
1. Maintenance Supervision will maintain a listing of all pressure vessels and pressure relief valves

in their department. 2. The IGOR system will be used to trigger the required inspections of the pressure relief valves. 3. All purchases, leases, rentals or modifications of pressure vessels must be reviewed by engineering. Table of Contents

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6.6.8 Heat Stress and Cold Weather


Purpose: To ensure that the hazards associated with heat stress and cold weather are controlled. Responsibility: The nurse will provide guidelines to recognize and control concerns with heat stress and cold weather. Day Supervision will educate people working in areas of extreme heat or cold about the guidelines. Documentation and Records: Workplace Procedures Related Procedures:

Practice: 1. Winter boots will be provided to people regularly working outside. 2. Cool water will be made available to people working in extreme heat. Table of Contents

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6.6.9 Housekeeping
Purpose: To maintain housekeeping at an excellent level in order to minimize accidents, increase operational efficiency, minimize potential hazards, and promote pride in the workplace. Responsibility: Supervision are responsible for housekeeping in their area. Documentation and Records: Workplace Procedures Related Procedures:

Practice: 1. All work areas are to look professional and organized. 2. Supervision will organize housekeeping duties in their areas. 3. The AltaSteel Visitor Tour route is visible to visitors and customers. It must be kept in excellent condition.

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6.6.10

Pigeon Control

Purpose: To ensure that the pigeon population is controlled and minimize health concerns associated with pigeon droppings and carcasses. Responsibility: The Supervisor Personnel and IR will conduct a program of pigeon control utilizing the necessary outside resources. Documentation and Records: Workplace Procedures Related Procedures:

Practice: 1. Procedures will be established for safe disposal of pigeon carcasses. 2. Build-up of pigeon droppings will be vacuumed and disposed of using appropriate PPE and practices.

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Chapter 7 Regular Inspections 7.1 Department Safety Inspections

Purpose: To ensure that a inspection system is in place to monitor hazard controls, identify safety rule violations, identify existing and potential hazards and reinforce and promote safe work practices and procedures. Responsibility: Managers are responsible for the implementation of regular planned/unplanned work site inspections for their respective departments. Department Joint H&S Meetings will review inspection performance at their monthly meetings. Documentation and Records: Health and Safety Inspection Reports AltaSteel Health and Safety Program AltaSteel Internal Standards for Health and Safety Occupational Health and Safety Statutes and Regulations Manufacturer Requirements Provincial and Federal Regulations Inspection Checklists Related Procedures:

Practice: 1. Department Worksite Safety Inspections are to be conducted on a monthly basis. 2. Worksite Inspection Report(s) are to identify substandard items, prioritize by hazard classification, identify who is responsible for making the corrections, set a projected date for the correction completion, and include a sign-off and date when the actual correction is made. 3, Supervisors hold the prime accountability for identifying the inspection team(s), for ensuring that work site inspections are being conducted on the scheduled frequencies, and for ensuring that the corrective actions are occurring. Inspection reports are to be forwarded to the respective Manager. Supervisors must immediately bring to the attention of the respective Manager any sub-standard item that is out of their immediate control and requires management involvement. 4. The inspection team(s) are to include employees. If a contractor/subcontractor is performing work on the site, then a representative(s) from the contractor/subcontractor are to be included in the planned work site inspection in the area where they are performing work. The inspection team(s) will, while conducting the inspection, look for items that are not in compliance with such items as practices and procedures, personal protective equipment policy, rules and regulations, safe hand tool usage and equipment operation. The team will also inspect other items such as guards, exit lights, fire extinguishers, emergency lighting, lighting, chains and hoists, emergency
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stop controls, warning signs, first aid supplies, electrical cords/wiring, housekeeping, aisles, work surfaces, and forklifts. The team will work towards developing a checklist. This will add continuity and ensure consistency in the inspection process. 5. Unplanned inspections can serve a useful purpose in determining health and safety performance. Respective area management has the responsibility for calling unplanned inspections. The same practice as identified in 2. above is to be followed in dealing with substandard items. 6. Worksite Inspection Reports are to be posted in the respective area(s). 7. Crew Safety Meetings, as part of their agenda, will review the substandard items found during inspections for the purpose of making employees aware of the substandard conditions and associated hazards. 8. Crew Health and Safety Committee(s) as part of their agenda, will review the progress of the identified substandard items. Exception Reporting is the process that is to be employed. Only items that are not successfully completed within the defined time parameters are to be reported to the Department Health and Safety Committee. 9. The respective Department Health and Safety Committee, as part of their agenda, will review the progress of the substandard items reported by exception and provide the necessary support. Any substandard items that cannot be resolved are to be reported to the Joint Health, Safety and Environment Committee. 10. Managers are accountable for monitoring the progress of all work site inspections conducted for their respective work area(s), summarizing the progress and forwarding this information to the respective stakeholders.

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7.2

Alberta Department of Occupational Health and Safety Inspections

Purpose: To comply with unscheduled inspections by the Occupational Health and Safety Officer which are done to ensure compliance with Occupational Health and Safety Regulations and Code. Responsibility: The Supervisor Personnel and I. R. is responsible for accompanying the Inspector on his tour of the plant. Documentation and Records: Occupational Health & Safety Inspector's Reports Occupational Health & Safety Inspection Notices Occupational Health & Safety Act, Regulations and Code Related Procedures: Practice: 1. The Department Manager(s) and the Vice President Administration will be notified that the Inspector is on site. 2. On off-hours the "On Call Manager" will be notified of the Inspector's presence. 3. The inspection notice will be signed for and posted. 4. Copies of the Inspection Notice will be circulated to all managers, and the chairman of the Union Joint Health and Safety Committee.

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7.3

Joint Management/Union Inspections

Purpose: To ensure a system is in place whereby senior management and the union executive can actively participate in worksite inspections and demonstrate company commitment to the Health and Safety Program. Responsibility: The President in conjunction with the union co-chairman of the Joint Health, Safety, and Environment Committee are responsible for conducting worksite inspections. Documentation and Records: Safety Inspection Report. Previous inspections and pertinent information from Joint Health, Safety and Environment Committee reviews of departmental work site inspections. Sample Checklists Related Procedures: Practice: 1. Plant Safety Inspections are conducted to determine whether implemented controls are working. 2. The Joint Health, Safety and Environment Committee performs the Inspection quarterly. 3. Observed results are documented and a summary report is distributed to the respective departments for correction, and to the committee members. Table of Contents

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Chapter 8 Emergency Response 8.1 Emergency Procedures Action Plan Description


Purpose: The purpose of these Emergency Procedures - Action Plan is to provide a course of action to deal with an emergency situation at AltaSteel, which potentially involves: AltaSteel personnel the public in the surrounding area the environment significant damage to plant facilities. Responsibility Managers have the responsibility for ensuring this plan is in place. The Supervisor Personnel and I. R. is responsible for ensuring that this plan is current. Documentation and Records: Level I/II Emergency Action Plan Level III Emergency Action Plan Management On Call Procedure Emergency Fire Fighting Procedure - General Emergency Fire Fighting Procedure - Security Emergency Fire Fighting Procedure Maintenance Emergency Procedure - Ambulance Related Procedures: Practice: 1. An emergency is a situation or set of circumstances which, if not promptly eliminated, controlled or contained, could result in significant danger or injury to: a. Plant personnel b. The public c. Plant facilities d. The Environment 2. Emergency situations may originate from a number of causes such as fuel explosion, loss of utilities (power, gas or water), ruptured gas mains, severe storms, and bomb threats. Plant personnel could also be endangered by such events occurring in locations outside the plant boundaries, such as fires that could spread into the plant, chemical spills from railroad cars or tanker trucks. The Level III Emergency Action Plans, 4. Potential Emergency Situations, lists items classified as emergencies under the above definition. It should be noted that this listing is not exhaustive, and that departmental procedures have been developed specific situations as noted (*).
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3. At AltaSteel, emergencies will be categorized into three main classifications generally as Level I, Level II, and Level III. a. Level I: Confined to a single managerial area, not likely to significantly affect other areas or the public. b. Level II: Involves two or more managerial areas but the effects of which can be confined to company property and do not immediately pose a significant hazard to the public. c. Level III: Involves any situation that could pose a significant hazard to the public and/or the environment. Would require activation of the Level III EMERGENCY ACTION PLAN. Our experience at AltaSteel has, to date, been confined to Level I Emergencies and, to a minor degree, Level II Emergencies. Fortunately, Level III Emergencies are rare occurrences. Therefore normal response will be to consider all emergencies in the initial stage as either Level I or Level II. In the event of escalation of an event to Level III the broad organizational plan in the Level III procedure is to be used. 4. Managers or the On Call Manager will determine when it is necessary to implement an emergency action plan. Table of Contents

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8.2

Evacuations

Emergency Evacuations Purpose: To ensure that procedures are in place for emergency evacuation of plant facilities. Responsibility: Managers are responsible for putting in place emergency evacuation procedures for their area. Documentation and Records: Workplace Procedures Evacuation Procedures Related Procedures: Practice: 1. Each manager will implement a written evacuation procedure for the areas required. 2. Procedures will outline a meeting place and head count requirements, communication plans and designated authorities.

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8.3

First Aid - Supplies, Facilities and Service

Purpose: To ensure that First Aid is available in compliance with Provincial Regulations. Responsibility: The HR Department is responsible for ensuring that Provincial Regulatory Requirements for First Aid Facilities and First Aider Coverage and Qualification are met. Managers are responsible for providing the facilities and personnel for First Aid. Documentation and Records: Workplace Procedures Provincial Regulations Related Procedures: Practice: 1. The HR department will provide First Aid training for First Aiders and monitor the number of qualified First Aiders to ensure regulatory requirements are met. 2. During normal operations First Aid will be administered from the First Aid Room in the Chem Lab building. During other periods a written notice outlining alternate First Aid response will be issued by the Nurse. 3. First Aid response will take precedence over any other duties of a First Aider. 4. The Nurse and the Supervisor Steelmaking Q.A.will implement a system to ensure First Aid supplies are properly maintained.

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8.4

Emergency Response Drills

Purpose: To conduct emergency response drills for emergencies that have the potential of occurring in the respective departments, and to analyze those drills to identify key learnings and areas of improvement. Responsibility: Mangers have the responsibility for identifying the potential types of emergencies that may occur in their areas and to schedule and hold an emergency drill(s) at least annually. The Supervisor Personnel and I. R. will provide assistance in evaluating the drills. Documentation & Records: Emergency Response Procedures and Action Plans Emergency Drill Reports

Related Procedures: Practice: 1. Supervision, in cooperation with safety representatives, are to identify the types of potential emergencies for their respective departments and work areas. 2. Emergency drills are to be conducted at a minimum of once per year. Where possible, emergency drills should be held on the back shifts. The Supervisor Personnel and I. R. will liaise with the operating areas to facilitate an emergency drill(s) for those areas in which employees work day shift only. 3. Supervision, the respective Union Health and Safety representative(s), and selected employee(s) are to analyze the drill and identify key learnings and areas for improvement. Review of the key learnings and areas for improvement is to be reviewed at the crew safety meetings. Information that may affect established emergency procedures is to be forwarded to the Supervisor Personnel and I. R. 4. The Supervisor Personnel and I. R. will initiate a review of the companys emergency response procedures on an annual basis to ensure that the procedures remain current.

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Chapter 9 Incident Investigation 9.1 Incident, Accident, and Concern Investigation

Purpose: To provide a uniform system for investigating incidents, accidents, and, concerns as well as health related incidents, and recording the information. Establishing cause and applying recommendations to prevent a recurrence and tracing the recommendations to their conclusion is a requirement. Responsibility: Employees are responsible for reporting all injuries, no matter how slight, to supervision. Employees are responsible for reporting all incidents which have potentially serious consequences to supervision. Supervisors are responsible for recording and investigating injuries, incidents, accidents and concerns. Managers are responsible for conducting investigations into serious accidents or incidents. Two members of the Joint Health, Safety and Environment Committee (one from the Union and one from management) are responsible for participating in investigations into incidents or accidents involving serious injury, cranes, mobile and lifting equipment.( Manager Environment and Major Project and Manager Maintenance and Engineering Bar Mill are considered members of the JHSC for the purposes of this clause). Definitions: Concern: Incident: Accident: Minor: Medical Aid: Lost Time: Serious Injury If an employee has a continuing, unsatisfied safety concern, it will be investigated. An unplanned event that could result in an injury or damage. An unplanned event that results in an injury or damage. Injury that does not require outside medical attention. Injury that is treated by a medical practitioner outside of work. Injury that causes the employee to miss time from work other than the day of the injury. as defined in the Occupational Health and Safety Act. This includes accidents that result in worker death or hospitalisation for more than two days, an unplanned or uncontrolled explosion, fire or flood that causes a serious injury or has the potential of causing a serious injury, or the collapse or upset of a crane, derrick or hoist or the collapse of failure of any component of a building or structure necessary for the structural integrity of the building or structure.

Documentation and Records: Request for Medical Service Supervisor's Accident & Employee's Compensation Report Employer's WCB Report Accident Investigation Recommendations Training Records Management On-Call Practice procedure
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Practice: 1. All injuries reported to supervision are to be recorded on the appropriate forms. 2. A supervisor's accident report will be completed on any incident/accident, consistent with following guidelines with respect to whom has the responsibility for conducting the investigation, before the end of the shift on which it occurred. 3. All those conducting investigations will be trained in Incident/Accident Investigation techniques. 4. Day Supervision will conduct medical aid injury investigations. Managers will make their respective comments and sign-off on the investigation. Investigations will be conducted at the earliest practical time and the reports completed in a timely manner. 5. Managers will conduct lost time accident investigations. The manager will make his/her comments and sign-off on the investigation. Investigations will be conducted at the earliest practical time and the reports completed in a timely manner. 6. The respective union safety representative(s) are to be included in all accident investigations as well as incident investigations where there is potential for serious injury. 7. An investigation report will include a clear description of the incident and circumstances, root cause(s), and recommendations to prevent recurrence. The report is to be concise and legible but does not have to be typewritten. 8. Where immediate action is required to resume work safely, such recommendations will include specific details on what will be done, and by whom. Supervisors have the prime accountability for communicating incident/accident investigation recommendations/requirements to all employees that may be affected. 9. The respective departments will put in place a system for ensuring that all incident/accident investigations are reviewed at all of their crew safety meetings. 10. The Supervisor Personnel and I. R. has the accountability for liaising with the departments and communicating all incidents/accidents that affect the site as a whole. 11. The medical department completes the Employers Report and sends to WCB within 72 hours. 12. When the injured employee sees a doctor the doctor completes a form and sends it to WCB within 48 hours of the injured employees visit. 13. For Medical Aid or Lost Time injuries, the injured employee completes a Employees Report of Injury Form and sends it to WCB as soon as possible. The medical department will assist the injured employee in completing this form if requested. 14. The Supervisor Personnel and I. R. will liaise with the respective department(s) to ensure the above reporting is occurring. Table of Contents

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Chapter 10 Program Administration 10.1 Effective Safety Communication


Purpose: To provide a means of communicating information to employees regarding accidents, incidents, health issues, equipment or other information that influences employees health and safety and to provide a means for employees to communicate feedback on health and safety issues. Responsibility: The Supervisor Personnel and I. R. is responsible for issuing Health and Safety Awareness Bulletins. Managers and Supervisors are responsible for communicating safety concerns to the employees in their department via word of mouth, safety contacts, posters and reports. The Supervisor Personnel and I.R. is responsible for conducting regular surveys of employee attitudes and opinions regarding health and safety. Documentation and Records: Accident and Incident Investigation Reports Health and Safety Awareness Bulletins Surveys AltaNews Safety Meeting Minutes Employee Surveys Related Procedures: Practice: 1. Safety Awareness Bulletins will be prepared and issued on a required basis and are not scheduled. Managers will be given an opportunity to comment prior to posting. 2. Managers will issue notices or pass on safety concerns to employee via business meetings, AltaNews, morning production meetings, discussions with supervisors or the mail. 3. Supervisors will review safety concerns with employees as required. This may be in a one on one format or in meetings. 4. The Supervisor Personnel and IR will periodically issue surveys to employees to obtain feedback. 5. AltaSteel accident or incident investigation reports that are pertinent will be circulated to the affected employees. 6. On occasion, serious issues or incidents will be reviewed at the AltaSteel monthly Business Meeting. Table of Contents
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10.2 Safety Performance Management


Purpose: To emphasize and reinforce individual safe work practices. Safety performance management accomplishes this by communicating health and safety performance expectations, responding to and publicizing both positive examples of safe work as well as safety violations, and conducting annual individual health and safety reviews. Responsibility: Managers are responsible for communicating the companys expectations with respect to health and safety performance, and establishing a process that focuses on safety as an integral part of work. Managers and Supervisors are responsible for giving positive reinforcement that focuses on safe work, and correcting safety violations as soon as they are noticed. Managers and Supervisors are responsible for conducting annual reviews of safety performance with their direct reports. Managers are responsible for conducting safety observations on a regular basis with a focus on positive reinforcement of safe work practices. Documentation and Records: Safety performance reviews Safety Statistics Safety observations Related Procedures: Practice: 1. Vice Presidents and Managers will set and communicate annual health, safety, and environmental performance goals. Departmental goals will define specific objectives that support the companys goals. 2. Safety observation forms will be filled out and forwarded to the area manager when positive reinforcement is done. 3. Exceptional examples of safe work performance are to be reported to the area Joint H&S committee for consideration for the Presidents Award. 4. When violations are noticed, they will be dealt with as follows: a. Work is to be interrupted. b. The violation is to be discussed with the employee. c. Assess the violation and select corrective measures to prevent recurrence. d. Discipline will be applied where work is not being conducted safely or repeated safety mistakes are made. 5. Managers and Supervision are responsible for meeting with their direct reports on an annual basis for the following purpose: a. Review the previous years safety performance. b. Discuss positive and negative aspects of performance.
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c. Determine what action is required, if any, for the following year. d. Establish specific, measurable goals for the next year. e. Establish and maintain records of the respective reviews. 6. Vice Presidents and Managers will conduct regular safety observations on employees carrying out normal duties. The observation will be reviewed with the employee with an emphasis on positive aspects of the employees behaviour. 7. The observation will be documented and retained for 3 months. 8. Observations will be reviewed at the weekly managers meeting. Table of Contents

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10.3 Safety Meetings


Purpose: To ensure a system is in place to review AltaSteel safety performance with all employees and instill an awareness of AltaSteels commitment to safety in the workplace. Responsibility: The President, Vice Presidents and Managers are responsible for implementing and maintaining this procedure. Documentation and Records: Business Safety Meeting Exhibits Managers Meeting Minutes Joint H&S Meeting Minutes Department Safety Meeting Minutes Crew Safety Meeting Minutes Safety Statistics Inspection Tour Reports Related Procedures: Practice: 1. The President chairs weekly meetings with Department Managers at which key safety concerns are reviewed. 2. The President and the Chairman of the Union Health, Safety and Environment jointly chair a Senior Joint Health and Safety meeting once per quarter. This is attended by the Vice Presidents and senior H&S representatives. Key safety concerns and policies are reviewed. 3. Committees may be formed at this meeting to review a specific issue in detail and then to report back at a subsequent meeting. 4. Managers chair monthly Safety Meetings with their supervision. This meeting is used for the review of accident statistics, safety policy changes, new practices, changes in safety regulations, and other issues of concern. 5. The Steelmaking and Bar Mill managers chair monthly safety meeting with Supervision and Union Safety Committee representatives at which accident statistics, investigation follow-up, crew safety meeting and inspection performance, issues arising out of crew safety meetings and significant safety concerns are discussed. 6. Each Supervisor conducts a monthly Crew Safety Meeting. A Union Safety Committee Representative also attends if available. Subject matter at these meetings focuses on crew members' safety concerns and also includes statistics review, accident review, review of the status of all accident recommendations, update on procedural changes or new equipment, and a general safety topic. 7. Minutes from the Crew Safety Meetings are provided to the other Shift Supervisors.
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8. Where possible, Union Health and Safety representatives are appointed. They report on situations or concerns that may affect department employees. 9. Minutes and attendance records will be kept of all safety meetings. 10. Managers will implement a follow-up system to ensure items raised at safety meetings and on inspection tours are dealt with. 11. Attendance records at these meetings will be reviewed periodically to ensure employee attendance is maintained. Table of Contents

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10.4 Employee Participation and Recognition


Purpose: To recognize employees contribution to the Health and Safety Program via a system of awards and public announcements. Responsibility: The Managers are responsible for monitoring and reviewing this program. The Supervisor Personnel and I.R. is responsible for administering the program. Documentation and Records: Accident Statistics Safety Targets Related Procedures: Practice: The following recognition is to be given to AltaSteel employees who achieve excellent safety performance: 1. When annual Safety Targets for Lost Time Accident Frequency and Lost Time Accident Severity are achieved the President may choose to authorize a memento for all employees to recognize the event. 2. At the end of each calendar year all AltaSteel employees who have worked accident free for the year will receive written recognition from their department manager. 3. A list of these employees will be included in the January bulletin and they will be recognized at the January business meeting. A $10 per person donation will be made to the United Way in honor of these employees by AltaSteel. 4. Each year AltaSteel will recognize those employees who have worked without losing time due to an accident with Safety Bucks redeemable for merchandise: 1 - 5 years $15 Safety Bucks 6 - 10 years $20 Safety Bucks 11 - 15 years $25 Safety Bucks 16 - 20 years $30 Safety Bucks 21 - 25 years $35 Safety Bucks 26+ years $40 Safety Bucks 5. In addition AltaSteel will give special recognition annually to employees who have worked safely during their career and have reached significant milestones. 5 years without a lost time accident special recognition 10 years without a lost time accident special recognition 15 years without a lost time accident special recognition 20 years without a lost time accident special recognition 25+ years without a lost time accident special recognition
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6. Presidents Award - Each Quarter the President will select an individual or group for special recognition for significant contribution to safety at AltaSteel. Nominations for this award will be submitted to the President by members of the Joint Health, Safety, and Environment Committee. Donations to the United Way in honor of an employee may be selected in lieu of merchandise. 7. This policy will be reviewed annually by management.

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10.5 Reporting Safety Statistics


Purpose: To ensure a system is in place to monitor AltaSteel safety performance on an ongoing basis and to demonstrate trends and continuous improvement with graphical summaries. Responsibility: The Supervisor Personnel and I. R. is responsible for collecting and analyzing accident and injury data from the Medical Department, Operating System Administrators, and supervision of the departments. Documentation and Records: Safety Statistics Various Management Reports Related Procedures: Practice: 1. A detailed statistical analysis is performed monthly on all accidents and injuries at AltaSteel and is made available to all levels of supervision. Information includes: Department Types of accidents/injuries Days lost List of people injured Frequency and severity by department Historical comparisons 2. A report summarizing the accident statistics by department will be issued monthly by the Nurse. 3. Each department is responsible for the analysis of the statistics and response to any unfavorable trends. Departments may also compile their own statistics. Table of Contents

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10.6 Safety Audits


Purpose: To ensure that a system is in place to evaluate the performance of the companys Health and Safety Program. Responsibility: The Department Manager(s), the Supervisor Personnel and I. R., and the Joint Health, Safety and Environment Committee have the responsibility for coordinating and ensuring that health and safety audit(s) are conducted consistent with predetermined frequency requirements. Related Procedures: Documentation and Records: Audit Protocol Audit Reports Practice: 1. A Health and Safety Audit is to be conducted on an annual basis. The audit will encompass the company as a whole. 2. Managers, in cooperation with the Supervisor Personnel and I. R., will set the timing for the annual audit. 3. The managers will determine the cycle and define the resource requirements for conducting audits: a. Note: Internal auditors are to be trained in conducting health and safety audits. 4. The Supervisor Personnel and I. R. is responsible for researching suitable available auditors and making a recommendation to the Joint Safety, Health and Environment Committee. 5. The Supervisor Personnel and I. R. has the responsibility of scheduling the activities required in the audit process, and will act as the key liaison with the auditor(s). 6. Audit reports are to be circulated to President, Department Managers and members of the Joint Health, Safety and Environment Committee members. 7. Managers, in cooperation with the Supervisor Personnel and I. R. will develop the necessary strategies and implementation schedules to correct any substandard audit items. These strategies are to be reviewed with the Joint Health, Safety and Environment Committee. 8. Department managers will conduct regular audits during major maintenance shutdowns. These audits will focus on lockouts and contractor safe work permits. 9. The Joint Health, Safety and Environment Committee has the responsibility of monitoring the progress of the strategies and implementation schedules as part of their meeting agenda.

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Chapter 11 Facilities and Services 11.1 Visitor and Contractor Management


Purpose: To provide a system to ensure that all outside personnel visiting or working on our property are properly outfitted and educated in AltaSteel Health and Safety Policies, philosophies and rules. Responsibility: Managers and Supervisors are responsible for ensuring that all visitors are dealt with according to the Contractors Safe Work Procedure Manual. The Supervisor Personnel and I.R. is responsible for resources and training in Contractor procedures. Documentation and Records: Contractor's Safe Work Permit General Safety Rules Material Safety Data Sheets Department Safety Rules Form A1999 - Request for Approval of New Material Contractor Safe Work Procedure Manual Plant wide safety procedures WHMIS Training Certificate Related Procedures: Section 3.7 Contact Person Training and Authorization Practice: 1. All visitors and contractors must sign in at the Guardhouse. 2. The Contractors Safe Work Procedure Manual is to be used for managing contractor work on site. 3. Visitors who are not doing work on site must be escorted. Table of Contents

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11.2 Tours and Tour Guides


Purpose: To ensure that tours of AltaSteel operations are conducted safely. Responsibility: The Steelmaking and Bar Mill Managers are responsible for establishing a marked tour route through the plant. The HR Department will establish procedures for the safe touring of the plant. Documentation and Records: Tour Route Tour and Tour Guide Procedures Authorized Tour Guide List Related Procedures: Practice: 1. The HR Department will provide a map and radio for the use of tour groups. 2. The HR Department will establish a procedure for authorizing tour guides. Managers must authorize this procedure. 3. Only authorized Tour Guides will be allowed to conduct tours. 4. Any employee can become an authorized Tour Guides by going through the established procedure. Table of Contents

Our mission is to create wealth for shareholders, employees and the community by producing quality steel bars.

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