Safety Policy

MAMMOTH COMMITMENT TO SAFETY

The safety of our employees and the clients we serve is a top priority to the management of our company. Mammoth is committed to conducting all operations of the company in a safe manner for the protection of our employees and the general public. Cost and competitive pressures of managing a business in today’s economy and environment dictate the need to minimize accidental losses because they rob us of essential human and financial resources. Failure to allocate proper attention to safety can impair operational capabilities, endanger the overall health of the company and disrupt long-range goals.

Furthermore, it is the explicit and continuing policy of Mammoth, Inc. that an effective Safety Program be established throughout the organization subject to reasonable and cost-effective guidelines. This program is set in place to identify and mitigate exposures, which can result in injury to our employees or guests, interrupt productivity or damage property, equipment, materials and the environment. Our ultimate goal for safety and health is the prevention of all loss incidents.

Our management team is expected to take a continuously active role in the development and amendment of safety policies and programs for themselves and his/her area of responsibility. No employee is permitted to work in an unsafe manner, and there will be zero tolerance of such. No supervisor is permitted to require or allow employees reporting to them to work in an unsafe manner. These policies and programs are clearly communicated in writing, implemented throughout the organization, and monitored for effectiveness.

The responsibility, authority and accountability for safety are clearly defined for all employees. Each employee’s results in the management of their safety responsibilities will be a major factor in measuring performance. By these initiatives, we will attain our goal of creating a safe and healthy working environment for all of our employees. – MAMMOTH INCORPORATED

SAFETY AND HEALTH PLAN

Mammoth Incorporated – Revised 2022

AUTHORITY AND SCOPE

Authority: This Safety and Health Plan is authorized by Mammoth Incorporated.

Scope: This Plan applies to all employees and other personnel working for Mammoth, Inc. who may encounter health and safety hazards while performing their assigned work duties.

POLICY STATEMENT

The personal safety and health of each employee of Mammoth Incorporated is of primary importance. The prevention of occupational injuries and illnesses is of such consequence that safe working conditions and practices will be given precedence over operating productivity whenever necessary.

We will maintain a safety and health program conforming to the best practices of organizations within the construction and restoration industry. To be successful, such a program must emphasize injury and illness prevention on the part of both management and employees. It also requires cooperation in all safety and health matters, not only between management and employee, but also between each employee and his or her coworkers and subcontractors that work under direction of Mammoth Incorporated only through a cooperative effort can a safety program be in the best interest and preserve the health and safety of all.

Our safety and health program will include:

Providing physical safeguards from injury to the maximum extent possible.
Striving to eliminate hazards through engineering controls whenever possible.
Conducting a program of safety and health inspections to detect and eliminate unsafe working conditions or practices, to control health hazards, and to comply with the safety and health standards for our industry and jobs.
Training employees in safe and healthy work practices.
Providing personal protective equipment (PPE) required on designated jobs and instruction for its correct use and care.
Developing and enforcing safety and health rules and requiring that employees cooperate with these rules as a condition of employment.
Investigating, promptly and thoroughly, accidents and near-miss situations to determine the root causes and to correct the problem in order to prevent recurrences.

Our objective is a safety and health program that will exponentially reduce injuries and illnesses, and that surpasses the best experiences of other operations and industries similar to ours.

PLAN ADMINISTRATION

Function	Name/Department
Plan Administrator	Jon Vogt
Job Hazard Analyst	Local Production Managers
Safety Consultant	Matthew Klunk / Risk Management
Chief Culture Officer	Michael Bevilacqua

Plan Administrator. The Plan Administrator will ensure that safety and health hazard assessments, inspections, accident investigations, and employee training are conducted in a timely manner, and will be responsible for maintaining all records and other documentation related to such activities.

Job Hazard Analyst. The responsibility for conducting job hazards analyses (JHAs) rests with technically qualified safety personnel. Such personnel may be managers, supervisors, or consultants/contractors.

Safety Consultant. In order to enhance our safety program and initiatives, Mammoth engages a safety consulting entity. This resource may be provided by our insurance partner. This consultant has many responsibilities in the area of safety planning and leadership throughout the organization. This party will serve on the safety committee and help guide policy and implementation as required. This consultant will provide review and advice on any potential hazard or enhancement, and will provide expert assistance with specific workplace or job site safety events. Any employee may contact the safety consultant if they feel that input from the consultant is needed.

Chief Culture Officer. In the event that any employee feels they are asked by their supervisor to do any work that puts them in an unsafe condition, employees should report such situation to the Chief Culture Officer. It will be the responsibility of the Chief Culture Officer to investigate and institute an acceptable resolution on a case by case basis.

Supervisors. Supervisors will regularly monitor work areas and employee activities for unsafe incidents or equipment. The supervisor must take the initiative to make corrections where authorized to do so. If supervisor does not have direct authority, the supervisor must immediately report any condition or employee practice that is likely to cause an accident to the applicable Job Hazard Analyst. Every supervisor will ensure that:

Work is not assigned that is hazardous or located in a hazardous area until all steps have been taken to provide for employee safety.
All employees receive proper job instruction and are familiar with safety and health rules and regulations. Supervisors will make sure that new employees know all safety and health rules to which their jobs are subject to.
Work areas will be examined frequently to ascertain that the work environment is safe and that employees are working in a safe manner.
All safety and health deficiencies are corrected immediately and actions are taken so that such deficiencies are not repeated.
Accidents are investigated and corrective action is initiated where necessary.

Employees. Every employee has a specific role in our loss-prevention efforts. All employees will:

Participate actively in the company’s safety program and observe all safety measures.
Report all accidents.
Correct or report any safety hazard in his or her work area.
Wear the proper PPE

Plan Review and Update

This Plan will be reviewed at a minimum of an annual basis and updated as needed to reflect changes in the work and/or common worksite conditions, and when injury or illness incidents warrant a review.

SAFETY COMMUNICATION

Management ensures that all employees, including themselves, have clearly written safety and health responsibilities included within their job description, with appropriate authority to carry out those responsibilities. In addition, management ensures that all employees, including all levels of management, receive performance evaluations that include a written evaluation of the accomplishment of assigned safety and health responsibilities.

Management ensures that all visitors to the site have knowledge of site hazards applicable to them and how to protect themselves against those hazards, including personal protection equipment, location of safety equipment, awareness of emergency alarms, and specific site safety procedures. Management also ensures that these visitors do not introduce hazards to the site that can be prevented or that are not properly controlled.

Management ensures that at least several avenues exist for employee involvement in safety and health decision making and problem solving. These avenues may include serving on committees and ad hoc problem-solving groups, acting as safety observers, assisting in training other employees, analyzing hazards inherent in site jobs and how to protect against those hazards, and planning activities to heighten safety and health awareness. Management encourages employees’ involvement and devises appropriate recognition for outstanding employee participation.

JOB HAZARD ANALYSIS

A JHA will be conducted for each work project and activity at Mammoth Incorporated. Part of the purpose of the JHA process is to determine whether hazards exist through careful and regular examination of the location(s) and procedures involved in the project. If there is a project or activity that truly has no potential for employees to be exposed to hazards, the JHA will note that that is the case.

Activity Selection

Personnel authorized by Mammoth Incorporated to perform JHAs (i.e., JHA Analysts) will select the job(s), tasks, operations, or processes to be analyzed by reviewing:

Injury and illness data
Good Catch / Near-miss reports
New or modified work tasks, activities, or projects
Employee safety process comments, surveys, and reports
Regulatory requirements

A JHA will be conducted for any job or task to which one or more of the following apply:

The job or process has a history of causing injury or illness.
There have been many near misses for the job or task.
The job or task has a potential for catastrophe (e.g., fire, explosion, large chemical release, massive equipment failure) if something goes wrong.
A simple human error in the task could lead to serious consequences.
The people performing the task have changed recently.
The job or task itself has changed recently.
The job or task is rarely performed.
The job is complex enough to require written instructions.
The job is done under a safety permit, such as a confined space entry permit or a hot work permit.

Initial JHAs will be scheduled by priority, starting with tasks or operations that pose the highest risk of severe injuries. Incident history as well as the potential for future accidents will be considered in making these risk determinations. Where accident or near-miss data are lacking, a review of the nature of the job and the equipment and/or materials being used will be conducted to help determine which jobs will receive a JHA. Employee participation in the JHA selection and implementation process will be encouraged and solicited. The analysis of methods to control hazards will incorporate regulatory requirements for each type of activity.

All JHA Analysts will consider the potential for chemical, explosion, electrical, ergonomic, fall, fire, heat and cold, machinery, noise, radiation, struck by/struck against, weather, and other relevant hazards and the likelihood of accidents in their operations when determining the priorities.

Management encourages employees to report hazards to their supervisor or Safety Plan Administrator. Employees will use the Employee Report of Hazard form for this purpose. See copy of the Employee Report of Hazard.

JHA Procedures

Following are the specific JHA procedures, listed in the order that they will be performed.

List specific activities. Make a list of specific activities that will be performed by employees at a particular jobsite, for the use of machines and equipment, or for a specific process or project. Where projects are very broad and involve diverse activities, conduct a JHA for each activity.
When projects or activities involve the same tasks and the similar conditions for commonly performed jobs, a single JHA will suffice for the reoccurring tasks and conditions encountered. For a simple activity, use Job Hazard Analysis Worksheet (simple).
For uncommon activities and “higher risk” projects and work conditions with complicated tasks and require multiple steps, use Job Hazard Analysis Worksheet (detailed).
For activities that may require other PPE, use Personal Protective Equipment Hazard Assessment Certificate.
List each potential hazard. Examine the hazards or potential hazards associated with each task or activity. Continue to use the worksheet or certificate used to list the specific tasks.
Examine the location where the activities are or will be performed to determine if there are any apparent hazards, such as poor lighting, live electrical contacts, improperly stored materials or waste, adjacent operations that may affect the safe operation of the job under review, etc.
Interview appropriate personnel who are familiar with the job and/or equipment. The intent of the interviews is to determine the orderly sequence of job tasks and any perceived hazards.
Observe, where possible, employees performing the actual job tasks. Thoroughly document the findings on the JHA worksheet.
Review available literature associated with the particular activity for additional hazards, including safety data sheets (SDSs), equipment manuals, safety checklists, and existing health and safety plans and manuals.
List corrective controls. Once the hazards are identified, select the corrective controls that will be implemented to ensure employee safety and health, and list them on the appropriate worksheet or certificate. Corrective controls will be considered in the following order of precedence:
Elimination–Removing the hazard or hazardous work practice from the workplace. This is the most effective control measure.
Substitution–Substituting or replacing a hazard or hazardous work practice with a less hazardous one. As an example, substituting a less hazardous or toxic solvent for a highly flammable or carcinogenic solvent.
Engineering control–If the hazard cannot be eliminated or substituted, an engineering control is the next preferred measure. This may include modifications to tools or equipment such as providing guards to machinery or equipment, or providing local exhaust or general ventilation to control emissions of toxic or hazardous gases, vapors, or particulates.
Isolation–Isolating or separating the hazard or hazardous work practice from people not involved in the work or the general work areas. This can be done by marking off hazardous areas, or by installing screens or barriers.
Administrative control–Introducing work practices that reduce the exposure to workers. Some examples include limiting the amount of time a person is exposed to a particular hazard, demarcating exclusion areas and establishing physical access controls to prevent workers from entering hazardous areas, and ensuring proper training of employees.
Personal protective equipment–Consider the use of PPE when other control measures are not feasible or as an interim control until one of the other described controls can be implemented. If PPE is required, complete Personal Protective Equipment Hazard Assessment Certificate.
Certify and document the JHA. Ensure that the JHA is reviewed and signed by an authorized Job Hazard Analyst, and shared with all of the employees who will be doing the work.
Write safe job procedures. For jobs deemed “high-risk”, a written procedure for safely performing the job should be completed. Use clear, simple language. Make sure to specify safe work practices and any required PPE in your written procedures. Review the completed safe job procedures with workers who perform the tasks, and keep a written copy of the safe job procedures in a location that is easily accessible to workers.
Review and modify the JHA as necessary. Repeat the JHA process as necessary by evaluating new equipment or work processes, reviewing accident records, and periodically reevaluating the suitability of previously selected PPE and/or engineering controls.

HAZARD PREVENTION AND CONTROL

Once the JHA has been conducted for projects or common activities, corrective actions recommended in the JHA that are approved by management will be implemented. Supervisors will inform employees of the hazards and corrective actions, and conduct employee training before the commencement of related tasks.

Management will implement the following protective measures when hazardous conditions are present:

Correct the hazard when observed or discovered with administrative controls, engineering controls, training, and/or PPE.
Remove workers from an area where an imminent hazard is present that cannot be corrected without endangering employees or property.
Provide workers who will correct the hazard with appropriate hazard controls and PPE.

Management ensures that the worksite and all equipment and machinery will be maintained properly so that the workplace remains safe and healthy. If maintenance needs exceed the capability of the worksite employees, contract employees will be hired to do the work, and they will be screened and supervised to ensure they work according to the site’s safety and health procedures.

Corrective Actions

Corrective Actions shall be determined in JHA’s for primary or common hazards that do not require a separate safety and health program.

Additional Safety and Health Programs

Mammoth, Inc. has determined that the following OSHA standards apply to the worksite. Individual safety and health programs for each of these standards will be written and implemented. Employees affected by these standards will be trained to follow the programs’ directions. These standards are:

Hazard Communication
Hearing Conservation
Bloodborne Pathogens
Emergency Action Plan
Personal Protective Equipment

See Mammoth Safety Website at for more information about these additional safety and health programs.

EMERGENCY RESPONSE

The site works with appropriate outside agencies, such as the fire department, the police department, and the hospital, to write emergency plans for all potential emergencies, including fire, explosion, accident, severe weather, loss of power and/or water, and violence from an outside source. Drills are conducted periodically so that all employees can practice the procedures for different types of emergencies. Each drill is evaluated by the drill planning committee, consisting each year of two managers or supervisors and two hourly employees who volunteer. This committee’s written report is posted each office, and supervisors ensure that all employees know the results. When necessary, the emergency procedures are revised on the basis of the evaluation report.

Persons who require emergency care are transported by company vehicle or community ambulance to the nearest hospital or clinic. On-site during all shifts, designated persons fully trained in cardiac pulmonary resuscitation (CPR), first aid, and the requirements of OSHA’s Bloodborne Pathogen Standard are the first responders to any emergency. One of these designated person’s safety and health responsibilities is to ensure that first-aid kits are stocked and readily accessible in the marked locations throughout the jobsites and facilities. Appropriate PPE is provided for the different types of accidents possible at the site. All emergency responders have been offered the hepatitis B vaccine.

DISCIPLINARY ACTION

All employees, including all levels of management, will be held accountable for obeying site safety and health rules. Mammoth Incorporated has a defined disciplinary policy contained within its Team Member Handbook. Violations of elements within the Safety Policy shall follow the same disciplinary practices defined within that Handbook.

Visitors, including contractors who violate safety and health rules and procedures, will be escorted from the site. Should the disciplined person request a review of the disciplinary action, Safety Plan Administrator will review the situation and make a recommendation to management, which reserves the right for final decision.

PERSONAL PROTECTIVE EQUIPMENT

Mammoth, Inc. will provide the necessary PPE to ensure the well-being of the employee. These items include:

Safety glasses
Gloves
Hard hats
Hearing protection
Safety shoes (Company provides allowance)
Respiratory equipment

Supervisors must review work areas and operations and provide the necessary protection. Employees are expected to wear such PPE. Failure to do so may lead to discipline up to and including termination.

SAFETY ORIENTATION AND TRAINING

All workers, managers, and supervisors will receive training and instruction on general and job-specific safety and health practices. Training and instruction will be provided:

When the training program is initiated
When new employees are hired
When existing employees are reassigned to jobs for which they have not received prior safety training
Whenever new substances, procedures, processes, equipment, or facilities are introduced and represent a new hazard
On a regular basis to reinforce existing safety and health procedures

General job safety and health training will include:

An explanation of the organization’s safety program and general safety rules
Instructions to report unsafe conditions, work practices, and injuries
Information about medical services and first-aid assistance and location of assistance and materials
The use of PPE on designated jobs
Information about chemical hazards to which employees could be exposed
Elements of chemical labels and SDSs
Procedures for responding to emergencies and fire prevention

In addition, we will provide specific instructions and training to all workers regarding the hazards that are unique to their job assignments, including wearing and caring for PPE, if required for the job.

List of Training Subjects

Following is a list of safety topics that will be covered, depending on each employee’s work assignments:

Safe practices for operating equipment, including procedures for cleaning, repairing servicing, and adjusting
Lockout/Tagout procedures for each type of equipment and machine
Machine guarding for power-driven equipment
Electrical hazards, including working around high-voltage lines
Material handling
Forklift truck operations
Ergonomic hazards, including lifting and repetitive motion
Proper use of power tools and hand tools
Ladders, scaffolding, and elevated platforms
Fall protection from elevated locations
Hazard communication
Fire prevention
Safe driving
Good Housekeeping
Permit-required confined space operations
Welding/hot work permits
Heat stress
Bloodborne pathogens
Workplace violence
Crane operations
Trenching and excavation work
Noise and hearing protection
Proper use and care of PPE

SAFETY MEETINGS

Management will conduct safety meetings for employees monthly and more often to discuss safety issues as they arise. A safety meeting includes all employees in a work area and at least one manager or supervisor to ensure that all appropriate issues are addressed. A manager or supervisor will cover one or more of the following issues:

Review key safety topics.
Review safety and health inspection reports to help correct safety hazards.
Evaluate the accident investigations conducted since the last meeting to determine if the cause(s) of the unsafe situation was identified and corrected.
Review any observed unsafe practices and ways to correct them.
Reaffirm the need for safe work practices.
Answer any questions employees may have about a safe practice, equipment operation, or other safety-related issues.

Formal safety meetings may be supplemented by “toolbox talks” of 10 or 15 minutes at the start of a work shift, or at other times as designated by a supervisor.

Safety Meeting Documentation

Each safety meeting will be documented with an attendee sign-in sheet and a meeting agenda that includes the supervisor’s name, date of meeting, and subject(s) covered.

ACCIDENT INVESTIGATION

If an employee sustains a work-related injury, the employee or a co-worker will immediately notify the supervisor of the work-related injury or illness, and the supervisor will ensure the injured or ill employee receives prompt medical treatment.

If an incident results in an employee fatality, it must be reported to OSHA within 8 hours. Any incident that results in an amputation, inpatient hospitalization, or the loss of an eye must be reported to OSHA within 24 hours. Reports may be made by calling the local OSHA area office (https://www.osha.gov/html/RAmap.html), by calling the OSHA 24-hour hotline at 1-800-321-6742, or online at https://www.osha.gov/pls/ser/serform.html. The individual making the report must be prepared supply the business name, the names of employees affected, the location and time of the incident, a brief description of the incident, and a contact person and phone number.

The employee will complete the employee part of the Accident Report Form that can be located on the Mammoth Intranet or by going directly to https://westarete.wufoo.com/forms/m1t9tkcl0vix27f/. If the date and time of the injury or illness cannot be determined, such as an injury caused by cumulative or repeated stress, the date of the last time that the employee worked is entered on the form.

Any person who observes or causes damage to property or equipment will immediately report such damage to a supervisor.

Injury to Visitors

Injuries sustained by visitors at a Mammoth, Inc. work site must be reported to the Safety Plan Administrator, and the local Production Manager. Injured visitors will be immediately provided medical treatment if necessary. The causes of injuries to visitors will be investigated through the same processes as an employee accident investigation.

Good Catch / Near-Miss Incident

Good Catch Form that can be located on the Mammoth Safety Website or going directly to. The investigation procedures for near-miss incidents will follow an abbreviated outline derived from the Accident Investigation Report procedures.

Detailed Accident Investigation Procedures

The Principal Accident Investigator and/or other Accident Investigator(s) will follow the procedures outlined below to conduct accident investigations:

Launch an accident investigation after a significant work-related injury or illness that requires medical treatment or property damage occurs at any Mammoth, Inc. worksite. Additionally, repetitive stress injuries (not the result of a single accident) will be investigated. Serious Good Catch / Near-miss incidents will also be investigated.
Assign investigators to carry out specific tasks. Such tasks include:

Inspect the accident site
Interview witnesses and injured person(s)
Compile and review data
Develop recommendations for corrective action(s)
Compile the written investigation report

Present a preliminary briefing to the investigating team, including:

A description of the accident, with damage estimates
Normal operating procedures
Maps (local and general)
The location of the accident site
List of witnesses
Events that preceded the accident

Visit the accident site to:

Secure the site to protect evidence and prevent further injuries.
Inspect the area, including walking and working surfaces, equipment, entrances and exits, air quality systems, and all other conditions, processes, or items that could possibly have contributed to the accident or injury.
Record by tape recorder (if feasible) and in writing the details of the accident site, including lighting conditions, other environmental factors, and any unsafe conditions, tools, equipment, or operations.
Document the location of victims, witnesses, machinery, energy sources, and hazardous materials.
Prepare the necessary sketches and photographs, label each item carefully, and keep accurate records.

Interview each injured person and witness. Also, interview those who were present before the accident and those who arrived at the site shortly after the accident. Keep accurate records of each interview. Use a tape recorder if desired and if approved.
Conduct a change analysis of all the information from the accident site and interviews:

Define the problem (what happened?).
Establish the norm (what should have happened?).
Identify, locate, and describe the change (what, where, when, to what extent?).
Specify what was and what was not affected.
Identify the distinctive features of the change.
List the possible causes.
Select the most likely causes.

Analyze the data collected from the determination/analysis of accident causes. Repeat any of the prior steps, if necessary. Determine:

Why the accident occurred
A likely sequence of events and probable causes (direct, indirect, and basic)
Alternative sequences

Check each sequence against the data from the determination/analysis of accident causes.
Determine the most likely sequence of events and the most probable causes.
Develop recommendations for corrective action, if needed.
Conduct a post-investigation briefing.
Prepare a summary report including the recommended actions to prevent a recurrence, and distribute the report according to applicable instructions. See copy of the Accident Investigation Report form and instructions.

SAFETY DATA SHEETS

All Mammoth employees shall have access Safety Data Sheets through the mobile application SDS Mobile, and any supplemental Safety Data Sheets not accessible in the mobile application SDS Mobile shall be made available at Mammoth’s Safety Website.

RECORDKEEPING

The Mammoth Incorporated Safety Committee will maintain all records related to this Plan. Unless otherwise noted, the records will be kept virtually and/or at Mammoth’s corporate office. All records are available for employee and regulatory agency review on request.

JHA Records. All JHA records and forms will be kept by the Mammoth Safety Committee for no less than five (5) years.

Illness and injury records. Our organization must record all employee injuries and illnesses on the following three forms:

All supervisors are required to fill out the OSHA Form 301–Injury and Illness Incident Report for each injury or illness that is considered recordable under OSHA regulations at 29 CFR 1904. The supervisor must fill out the form within 7 calendar days after finding out about the injury or illness. A copy of this record will be sent to Mammoth Safety Plan Administrator. The company will keep these records for 5 years.
Mammoth Safety Plan Administrator is responsible for entering the information on the OSHA FORM 300–Log of Work-Related Injuries and Illnesses within 7 calendar days of receiving notice of a recordable illness or injury. This form will be retained for 5 years even if there are no recordable injuries or illnesses.
At the end of each calendar year, Mammoth Safety Plan Administrator will review the OSHA 300 Log to verify that the entries are complete and accurate. This information will be summarized and entered on OSHA Form 300A–Summary of Work-Related Injuries and Illnesses. The Summary will be signed and dated by a company executive and will be posted in a conspicuous place available to all employees from February 1 to April 30.

Accident investigation records. Mammoth Safety Plan Administrator will maintain comprehensive accident/ injury records and will maintain records of all accident investigation reports and data for seven (7) years.

Training records. Supervisors shall submit training records to Mammoth Safety Plan Administrator, who will keep employee training records (e.g., curricula, written or electronic materials, sign-in sheets, individual employee records) for no less than five (5) years.

Emergency Contact Form

Safety Policy