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Site Safety Plan

Hazardous Waste Operations Compliance Plan

Administrative Duties:
Shepler Well Drilling Inc has developed this program to ensure proper protection against hazardous environmental exposures at sites where there is environmental contamination, because such exposures can pose significant safety and health risks to our workers when not handled properly.

General:
The Hazardous Waste Operations and Emergency Response standard is a complicated regulation, with many different elements required. As a well drilling contractor, we have done a thorough job of complying with those aspects of the HazWOpER standard that affect our scope of work when conducting drilling operations at sites with environmental contamination. It is our policy to comply with all aspects of any master site safety and health plan being utilized at a site with environmental contamination, as well as providing our own site-specific safety plan covering our employees and their specific scope of work, when required.

Medical Surveillance:
Because of potential exposures that workers might have at sites with environmental contamination, we make a medical surveillance program available, under the HazWOpER standard, when an employee is at risk of exposure to one or more environmental contaminants above a permissible exposure limit, as published in the NIOSH Pocket Guide to Chemical Hazards.

Respiratory Protection:
Because Shepler Well Drilling Inc employees may be required to use other than standard Level D personal protective equipment on sites with environmental contamination, we have adopted a plan to provide respirators selected for effectiveness against site-specific contaminants on a case-by-case basis. Fit testing is conducted before entering any site area where direct respiratory contaminants might exceed a published permissible exposure limit for one or more environmental contaminants. All requirements of OSHA 29 CFR 1910.134 respiratory protection are met in this plan.

Site Safety Responsibilities:
Brandi Shepler is in charge of the hazardous waste operations, and emergency response safety and health programs.

Decontamination:
Since our equipment is likely to come in direct contact with soil and groundwater contamination, decontamination is a crucial aspect of environmental drilling operations. The decontamination procedures used at our facility are selected on a project-specific basis, and include but are not limited to chemical decontamination solutions such as distilled water, detergents, surfactants, organic solvents or disinfectants. When physical decontamination proves to be more effective, methods such as wiping, brushing, absorption, or forced, compressed air removal could be employed.

Site Control:
Controlling access to drilling operations at sites with environmental contamination is traditionally the responsibility of the primary contractor. However, employees are trained to discourage outside onlookers and, when necessary, may stake off areas with caution tape if necessary.

Training Program:
As part of Shepler Well Drilling Inc’s Hazardous Waste Operations and Emergency Response program, we have implemented a program to inform workers (including any subcontractors) performing drilling operations on sites with environmental contamination of the level and degree of exposure they are likely to encounter.

Training makes workers aware of the potential hazards they may encounter, and provides the necessary knowledge and skills to perform their work with minimal risk to their safety and health.

Supervisors and workers are trained to:

• Become familiar with pertinent OSHA, EPA and DOT regulations relevant to sites with environmental contamination.
• Understand the Hazard Communication Standard.
• Recognize physical hazards.
• Identify chemical hazards.
• Recognize biological hazards.
• Understand basic air-monitoring procedures and instrumentation.
• Use safe chemical handling practices.
• Select, care for and use personal protective equipment properly.
• Understand engineering controls and their use.
• Use proper decontamination procedures.
• Understand the Hazardous Waste Operations and Emergency Response planning process.
• Understand medical surveillance requirements.
• Identify a confined space, and understand confined space entry procedures.
• Implement common spill containment or confinement procedures.
• Prevent slipping, and trip-and-fall accidents.
• Use ladders and scaffolding safely.
• Implement hearing- and eye-protection procedures.
• Use fire extinguishers effectively.
• Prevent lifting and back injuries.

Workers also must know the names of personnel and their alternates responsible for site safety and health. Shepler Well Drilling Inc’s field personnel are trained to the level of Hazardous Materials Specialist, requiring completion of a 40-hour hazardous-waste operations and emergency-response training course, pursuant to OSHA 29 CFR 1910.120 standards, and have been certified by their instructor as having completed the necessary training. All new employees are trained before being dispatched to a project involving environmental contamination.

All field personnel receive refresher training sufficient to maintain or demonstrate competency annually.

In order to offer the best training for our workers, Shepler Well Drilling Inc utilizes outside training services to conduct this training in a face-to-face, live format. Certificates signed by employees as well as the instructors are handed out upon completion of their training.

Pre-Project Briefing:
We provide for pre-entry briefing to be held before initiating any site activity on a site with environmental contamination, and at such other times as necessary to ensure that employees are apprised of all aspects of the site safety and health plans.

We ensure that these plans are being followed by random, supervisory, surprise safety inspections, conducted during operations at sites with environmental contamination.

Lines of Site Safety Responsibility:
Randy Shepler is the general supervisor who has the responsibility and authority to direct all operations subject to the HazWOpER standard.

Brandi Helsel is the site safety and health supervisor, who has the responsibility and authority to develop and implement a site’s safety and health plan, verify safety compliance, appoint project safety supervisors and delegate safety oversight responsibilities.

Site-Specific Safety and Health Planning:
Site-Specific Safety and Health Planning programs aid in effectively controlling anticipated safety and health hazards at specific project sites. Whenever a project performed on a site with environmental contamination entails risks of exposure not anticipated by our standard operating procedures, a site-specific safety and health plan will be developed and implemented. This site-specific safety and health plan is intended to identify and address any hazards entailing an environmental risk or exposure that cannot be controlled using our standard operating procedures, and addresses each phase of the operation. This plan is kept on the work site, includes the requirements and procedures for employee protection, and will be written to comply with, and implemented in conjunction with, any master site-safety and health plan. This plan will contain a hazard or health risk analysis for each task within our scope of work.

Air Monitoring:
Shepler Well Drilling Inc typically relies on the prime contractor for air monitoring on sites with environmental contamination. However, if required, Shepler Well Drilling Inc will arrange for a health / safety professional to conduct necessary air monitoring and record-keeping services.

Contractor Safety:
Subcontractors working under our direction need to be protected from hazards that may be encountered on sites with environmental contamination. Because we occasionally use subcontractors’ services for work on sites with environmental contamination, Shepler Well Drilling Inc has implemented plans to inform subcontractors of all aspects of the site-safety and health plan, all emergency response procedures, and any potential fire, explosion, health, safety, or other hazards presented by the operations within our scope of work.