OHS PROGRAM
2026 – 2027
CANWIDE STEEL
OHS PROGRAM
2026 – 2027
TABLE OF CONTENTS
CANWIDE STEEL
OHS PROGRAM
PROGRAM REVIEW
PROGRAM REVIEW
Policy Statement

Canwide Steel Ltd. recognizes the continuous requirement to review and update our safety policies and OHS Program on a regular basis. By constant review and update, we ensure that the information contained in this program remains relevant, applicable, effective, and aligned with the most recent regulation.

Management will perform an annual review of this program, and update, or delegate a qualified person(s) to update, when needed.

This review will take into account all significant events throughout the year and identify any need for improvement. Will also include any newly introduced or upcoming scope of work, considering its hazards and controls. All employees are encouraged – and expected – to provide feedback and suggestions to management on ways to improve this OHS Program. Talk to your direct supervisor or JOHS Committee member for any feedback or suggestions on how to improve this OHS Program, and Occupational Health and Safety in the workplace.

Review History

This program in its entirety must be reviewed annually or as procedures/scope of work requires:

Date Initially Written by Approved by Management
APRIL 2026
Name: Manwinder Singh
Signature: Manwinder Singh Signature
Date Review Done by Approved by Management
May 31, 2026 Mehakdeep Singh (Field Supervisor)
Signature: Signature
Lovepreet Singh (Field Safety Coordinator)
Signature: Signature
Name: Manwinder Singh
Signature: Signature
  Name:
Signature:

Note: A "revision date" indicates the date when a document or information was created, last changed or updated, while a "review date" signifies the date when the content was last checked for accuracy and deemed current, even if no changes were made at that time; essentially, "revision date" means the content was actively modified, while "review date" means it was simply checked and approved as is.

CANWIDE STEEL
OHS PROGRAM
Element 1
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
E01Created: Apr/2026Last rev: ---Rev. 1.11 of 1
ELEMENT 1 - OCCUPATIONAL HEALTH AND SAFETY POLICY

Canwide Steel Ltd. is committed to implementing a comprehensive Occupational Health and Safety (OH&S) Program to provide and maintain a safe and healthy work environment for our employees. Our company is committed to work in a spirit of consultation and cooperation with our employees. We will take all reasonable steps to prevent injury at the workplace and comply with all applicable legislated requirements. The information in this Policy does not take precedence over the applicable legislation, with which all employees shall be familiar.

We acknowledge our workers' right to work in a safe environment, the right to know and be informed, the right to participate in workplace health and safety activities, and the right to refuse to perform unsafe work.

Our workers are encouraged and trained to report Health and Safety concerns/incidents, including bullying and harassment, to Management. Our bullying and harassment policy is implemented with the management's objective to maintain and provide everyone a safe and healthy environment.

Management is responsible for the implementation of our OH&S Program that ensures the health and safety of our employees while providing healthy and safe working conditions. Management will provide resources to promote and support our Company's OH&S Program and ensure that all employees are informed of the Company's expectations regarding health and safety.

Superintendents and Supervisors are responsible and accountable for providing safety instruction to all new and reassigned employees before assigning any duties, including enforcing OH&S Regulations and this OH&S Program. They are also responsible and accountable for ensuring that regular inspections of our sites and workplaces are conducted with prompt corrective actions taken to eliminate hazards or minimize risks. All personnel with supervisory duties shall set a good example by following all safety regulations and implementing/promoting all safety activities addressed in the OH&S Regulations and this OH&S Program.

Safety Manager/Coordinators/Officers are responsible for the coordination and implementation of the OH&S Program and applicable OH&S Regulations on all our sites by supporting all levels of staff in the safe performance of their duties.

Employees & Subcontractors shall observe all safety rules, the company's OH&S program, and OH&S regulations. They will conduct themselves in a manner that does not endanger the well-being of themselves or others, or cause property damage. All workers, employees, and subcontractors shall report all incidents and injuries immediately to their supervisor and/or superintendent. Everyone is encouraged to submit recommendations for improved safety measures at the workplace.

Visitors shall comply with the company safety rules while on our property.

Our OH&S Program is written with the best interest of all employees, contractors, visitors, and customers in mind. We believe incident prevention and efficient production go together and insist on dedicated participation from all our employees. This Health and Safety Policy will be reviewed annually, in consultation with all employees, for proactive due diligence and regulatory requirements. Employees are encouraged to participate in the annual review process and to make suggestions for improvement.

Your cooperation and dedication to health and safety is greatly appreciated. It is our expectation that everyone's commitment to their health and safety responsibilities in this program will prevent harm.

Owner/Senior Manager – Manwinder Singh
Date: 2026-04-15
Manwinder Singh Signature

CANWIDE STEEL
OHS PROGRAM
Element 1B
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
E01BCreated: Apr/2026Last rev: ---Rev.1.11 of 1
ELEMENT 1B - OCCUPATIONAL HEALTH & SAFETY POLICY (SUBCONTRACTOR)

Canwide Steel Ltd. is committed to implementing a comprehensive Occupational Health and Safety (OH&S) Program to provide and maintain a safe and healthy work environment for our employees. We expect the same from our Subcontractors. All Subcontractors:

Management is responsible for the implementation of Canwide Steel Ltd. OH&S Program to ensure the health and safety of its employees and provide safe working conditions. The Subcontractor's management shall adhere to, provide resources for, promote and support Canwide Steel Ltd. OH&S Program and ensure that all its employees are informed of our expectations regarding health and safety. The Subcontractor's management personnel shall ensure the regular inspections are conducted to review the work activities and conditions, and that prompt corrective action is taken to eliminate hazards.

Supervisors/Foremen are responsible and accountable for providing safety instructions to all new and reassigned employees before assigning their duties and enforcing Safe Job Procedures, Safe Work Practices, safety rules and regulations. The Supervisors shall ensure regular inspections of conditions in their area of control and prompt corrective action to eliminate hazards. They shall set a good example by following all SJP, SWP, safety rules and regulations, and by promoting all safety activities addressed in our safety program.

Workers shall observe and follow all SJP, SWP, safety rules, all company OH&S program elements and regulations and conduct themselves in a manner that does not endanger the well-being of themselves or others, or cause property damage. Workers and subcontractors shall report all accidents and injuries immediately and are encouraged to submit recommendations for improved safety measures.

Visitors shall comply with Canwide Steel Ltd. and the General Contractor's safety rules while they are on our construction sites. They must be escorted while on site.

Canwide Steel Ltd. OH&S Program is designed in the best interests of all personnel, contractors, visitors, and customers. We believe accident prevention and efficient production go hand-in-hand and, accordingly, we insist on dedicated participation from all of our employees, management, subcontractors and visitors.

We expect everyone working with our company to cooperate and abide by this policy. Full co-operation from all personnel is required to meet this commitment.

Owner/Senior Manager – Manwinder Singh
Date: 2026-04-15
Manwinder Singh Signature

CANWIDE STEEL
OHS PROGRAM
Element 2
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
E02Created: Apr/2026Last rev: ---Rev. ---1 of 5
ELEMENT 2 - WORKPLACE HAZARD ASSESSMENT AND CONTROL
Policy Statement

Hazard Assessments and Control Processes must be used in all projects and Offices. This process is the foundation of managing health safety risks in the workplace and must include the documentation and review of actual and potential hazards. Hazard assessments must be conducted by personnel knowledgeable about the work, such as workers, supervisors, or managers. Review all applicable hazard assessments with crews prior to work commencing.

Canwide Steel Ltd. has established a Hazard Identification and Risk Assessment process to identify, assess and control any hazards in our workplace. The hazards will be assessed prior to starting work to identify hazards on an on-going basis to ensure the safety of the workers as the work processes change.

Formal Risk Assessment
Pre-Job Risk Assessment (PJRA)

Prior to the start of any new project or job, the project manager, safety manager, and the superintendent or Office Manager as applicable, for the project, with the support of external consultants, when required, will perform a Pre-Job Risk Assessment (PJRA) to identify hazards in the workplace and assess the associated risks, resulting in an action plan to control these risks.

The Risk Assessment process will identify, assess, and control critical tasks. This will also help to determine the training, equipment, tools and/or materials needed to complete the job safely. Critical tasks that are identified, form the base of our Safe Job Procedures included in our OH&S Program.

Risk Assessments will be reviewed regularly, as the job progresses, and updated as required to prevent the development of unsafe or unhealthy working conditions.

Daily Hazard Assessment (Ongoing)

Daily and as tasks change, all personnel, including subcontractors, will review and assess the work areas and specific tasks to ensure hazards are identified and proper controls are implemented. Complete a Daily Hazard Assessment (DHA) form, then review it with all workers involved in that task. Ensure that they understand the hazards and risks involved in their scope of work for the shift/day and how to carry out their job safely. Have them then sign the DHA. Records of both PJRAs and DHAs must be kept on file.

Performing a Risk Assessment (RA)

The most effective method to perform a Risk Assessment is to:

  1. Break down the task into steps
  2. Identify the hazards in each step, who is affected, and the type of harm/damage
  3. Assess the Risks associated with these hazards
  4. Develop appropriate control methods for these Risks following the Hierarchy of Controls
  5. Review applicability and effectiveness by assessing the residual (remaining) risks
  6. Communicate to all affected parties

RAs should be performed by:

  1. Workers doing the job
  2. Foremen / Supervisors
  3. Safety personnel / professionals (internal or external)

Some tasks may require the involvement of an external professional such as an Industrial Hygienist, P. Eng., CRSP, etc. Examples of such tasks are Confined Spaces, Exposure Control Plans, Hazardous Materials surveys, etc.

Hazard Identification and Risk Prioritization

Hazards must first be identified, then associated Risks are prioritized based on possibility of an incident occurring because of the hazard, and the severity of such incident. Hazards associated with high risks must be eliminated or corrected as soon as possible.

We use the Risk Matrix below to prioritize risks by providing a value based on the likelihood and severity of an incident/accident. There are 3 levels of Risk: Low, Medium, and High. As we put in our control measures, the severity and likelihood are reduced. Higher Risk tasks require management input and are added to the critical tasks list. No High-Risk situation will continue without appropriate controls in place to eliminate or reduce all risks to as low as reasonably practicable.

Likelihood /
Severity
Rare (1) Possible (2) Likely (3) Probable (4)
Minor (1) Low (1) Low (2) Low (3) Low (4)
Serious (2) Low (2) Low (4) Medium (6) Medium (8)
Major (3) Low (3) Medium (6) Medium (9) High (12)
Fatal (4) Low (4) Medium (8) High (12) High (16)
Likelihood Levels
Severity Levels
Risk Levels
Hazard Classification

All hazards can be classified as follows:

  1. Low Hazard (1-4)
    A condition or work practice that presents a risk of minor injury or loss. These hazards typically result in Low-Risk situations, requiring planned corrective actions.
  2. Medium Hazard (6-9)
    A condition or work practice with the potential for causing serious injury or property damage but does not present imminent life-threatening hazard. These hazards typically result in Low Moderate Risk situations. Corrective action should be identified and completed as soon as possible.
  3. High Hazard (12-16)
    A condition or work practice with the potential to cause permanent disability, loss of life or significant property or equipment damage. These hazards typically result in Moderate to High-Risk situations when workers are exposed to the hazard and would require immediate corrective actions.
Hazards & Risks Control

Once Hazards are identified and Risks prioritized, control measures must be implemented to eliminate or reduce the likelihood and/or severity of the hazard/risk. Control measures will be selected based on the following hierarchy:

  1. Elimination: Completely remove the hazard or redesign the job, tool, process, machine, or substance.
  2. Substitution: Substituting or replacing with another process/material that would be of lower risk.
  3. Engineering Controls: Physical controls such as redesign, automation, barriers, absorption, dilution, isolation, etc.
  4. Administrative Controls: Procedural controls such as SWPs, SJPs, Signs, danger/caution tape, training, etc.
  5. Personal Protective Equipment (PPE): Protective clothing, respirators, face shields, glasses, gloves, harness, etc.
Critical Tasks List

The tasks below are considered Critical Tasks on a construction site. These are by default, higher risk jobs if no controls were set in place, and workers must be made aware of them. Critical tasks are not suitable for new or young workers. If a new/young worker must be involved in any of these tasks, they must be under continuous and direct supervision by their supervisor, or an experienced worker formally assigned by their supervisor, and only involved in the lower risk aspects of the task. Only trained and qualified workers can perform the jobs outlined below.

This list will be continuously updated when new critical tasks are introduced, and based on the Risk Prioritization process detailed above, as needed.

Management Of Change (MOC)

Management of Change (MOC) is a systematic approach to dealing with organizational change. The goal of this approach is to safeguard workers from potential harm during the crucial period of transition. A change to core processes, even temporary ones, can endanger the health and even the lives of the workers. It's critical to recognize and define change before introducing it to the process. All affected personnel/stakeholders must participate in the Management of Change.

A lack of familiarity with new processes and equipment can lead to accidents that could impact the lives, property and environment.

A few examples of types of changes that should be assessed are:

Below is a step-by-step rundown of what it takes to perform Management Of Change:

  1. Recognize all changes. Without a thorough understanding of what changes are going to happen, it is difficult for a management team to evaluate its potential impact to the organization. Know the details of the change, so that it can be properly managed.
  2. Identify the hazards and risks. A careful risk analysis must be done to cover every potential hazard that the change will cause. Seemingly minimal effects should never be overlooked. Instead, they should be treated as though they can impact the organization in a big way. Worst-case scenarios for each risk must be identified, so that steps can be made to avoid them.
  3. Note hazards that can be minimized, controlled, or totally avoided. Management needs to accept the reality that not all risks can be avoided. Some can only be managed or reduced. It's important to determine which risks can be totally avoided. Plans should then be initiated to reduce or manage unavoidable hazards.
  4. Find out if the change is feasible or can be implemented given the circumstances. This is more like a risk-reward analysis. The management team can ask themselves, "Can the changes be done with the least amount of danger possible, or do the hazards caused by the change outweigh its rewards?"
  5. Conduct a Pre-Job Review. Before a change to facilities, equipment or work process is initiated, a pre-job review must be completed during the planning/development stage. It is a thorough review to ensure that safety measures and or quality standards are maintained.
  6. Implement the change — if safe to do so. The change must be implemented knowing all the risks in advance and how it might impact the workers. The goal of responsible leadership must be to help employees smoothly glide through the painful process of change without endangering them. Emergency measures should also be in place if a potential accident turns into a real one.
  7. Train all affected workers. Any involved employee, as well as all managers who will execute your new processes, should be carefully trained on the new procedures. More knowledge and hands-on-training will lead to fewer or zero instances of mishaps, or to less serious consequences when failures occur.
  8. Follow new procedures and continue to evaluate feedback from the ground. As changes are rolled out, management should continue to evaluate the worker's exposure to risk. This can be receiving continuous feedback and reports from the organization's day-to-day operations.
CANWIDE STEEL
OHS PROGRAM
Element 3
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
E03Created: Apr/2026Last rev: ---Rev.1.01 of 1
ELEMENT 3 – SAFE WORK PRACTICES
Policy Statement

Written and practical instructions are developed by the Company and will be maintained on an ongoing basis to eliminate or control the hazards likely to be encountered by our workers in the performance of their duties.

All workers and subcontractors must follow these written and practical instructions, and immediately report any concern to their supervisors. Sub-contractors are required to develop Safe Work Practices for their scope of work, and to educate and supervise their workers on the performance of their duties as per the instructions provided in the SWPs.

Safe Work Practices

Safe Work Practices (SWP) are a set of positive guidelines or "Do's and Don'ts" on how to perform a specific task that may not always be done in a certain way. SWPs are developed to control hazards that have been identified through the Hazard Identification and Risk Assessment process detailed in Element 2 of this OHS Program.

Copies of the SWPs are kept on site and are made readily available to each employee, who should know, understand, and follow all the Safe Work Practices that pertain to his/her specific work tasks. Supervisors must ensure SWPs are developed for common tasks performed by workers.

Scope of Work

Before work begins, supervisors are required to have a clear understanding of what is required to complete the work safely. Not having a clear understanding of how to do the work safely could expose the workers to possible risks. Assessing and controlling our work area, in conjunction with our contractors, must be done to ensure that we do not expose others to risks due to our work activities.

Developing Safe Work Practices (SWP)

A Hazard Assessment is conducted to identify the hazards and risks that will be addressed in the SWP. Hazards can also be identified during site inspections and walk-arounds, or by worker's suggestions and discussions in toolbox talks or through the JOHS Committee. Refer to Element 2 of this OHS Program for more information on performing Hazard Assessments. After the Hazard Assessment is performed, qualified person(s) will set general guidelines on how to perform the required task safely, with the involvement of Supervisors and workers who frequently perform the tasks addressed. These guidelines can be derived from OHS Regulations, equipment manuals, CSA/ANSI standards, and common best practices. The applicable rules and regulations must also be included in all SWPs so that all workers are aware and understand the safety requirement. All subcontractors are responsible for developing their own SWPs, however, our SWPs can be used as a guideline to assist if needed.

Training

Training is a vital aspect of our work and all training must be documented. Training should be performed in any area that the supervisor and/or employee deems appropriate to ensure competency. Training should include a theoretical and practical component as outlined in the Training & Communication element of our OHS Program. A copy of all training documentation must be available at the company's office and kept at the workplace.

Evaluation

The effectiveness of an SWP must be monitored and evaluated on a regular basis or as the work situation or equipment changes. Any discrepancies noted must be reviewed and addressed immediately. Workers must be re-trained and made aware of any and all changes. A revised copy of the SWP must be readily available at the workplace.

CANWIDE STEEL
OHS PROGRAM
Element 4
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
E04Created: Apr/2026Last rev: ---Rev.1.11 of 2
ELEMENT 4 - SAFE JOB PROCEDURES
Policy Statement

Written and practical instructions are developed by the company and will be maintained on an ongoing basis to eliminate and control the hazards likely to be encountered by our workers in the performance of their duties. All employees and contractors must follow these written and practical instructions, and immediately report any concern to their supervisors. Sub-contractors are required to develop Safe Job Procedures for their scope of work, and to educate and supervise their workers on the performance of their duties as per the instructions provided in the SJPs.

Safe Job Procedures (SJP)

Safe Job Procedures (SJP) are written, specific, step-by-step instructions of how to complete a job safely and efficiently from start to finish. They are a means of controlling the hazards that are identified in Pre-Job Risk Assessments, and of communicating these hazards and required controls to affected workers performing such jobs, with instructions on how to perform their tasks safely.

Copies of the SJPs are kept on site and are readily available to each employee, who should know, understand, and follow all Safe Job Procedures that pertain to his/her specific work tasks. Supervisors on all levels must ensure SJPs are developed for both critical and common tasks performed by workers under their supervision.

Scope of Work

Before work begins, all personnel are required to have a clear understanding of what is required to complete the work safely. Not having a clear understanding of how to do the work safely could expose everyone to possible risks. Assessing and controlling our work area, in conjunction with our sub-contractors, must be done to ensure that we do not expose others to risks due to our work activities. Supervisors, of both our company and sub-contractors, must ensure SJPs are developed for common tasks performed by workers under their supervision.

Developing Safe Job Procedures (SJP)

An SJP is written when:

Developing SJPs is a systematic process consisting of several steps:

Managers, supervisors & workers are all expected to participate in writing the SJP. Workers performing the task addressed in a Safe Job Procedure must be consulted when developing the procedure to ensure practicality and applicability.

Critical Tasks

Critical tasks identified in the Pre-Job Risk Assessments must have task-specific Safe Job Procedures and workers performing such tasks must be trained to perform tasks safely. Refer to Element 2 of this OHS Program for more information on performing Risk Assessments and identifying critical tasks. For tasks identified as critical, which can be different for each site, such as confined space entry, site-specific procedures are prepared when required.

Training

Training is a vital aspect of our work and all training must be documented. Training should be performed in any area that the supervisor and/or employee deem appropriate to ensure competency. Training should include a theoretical and practical component as outlined in the Training & Communication element of our OHS Program. Such training is typically done in toolbox talks, and records are kept on file. Workers can sign off directly on the SJP, or on a toolbox attendance record clearly showing which SJPs have been discussed in the list of topics, or both. Such training will be refreshed with the workers periodically (quarterly, annually, etc.) based on level of risk and repetition of task.

A copy of all training documentation such as sign-off sheets will be available on-site with a copy sent to the head office.

Subcontractors must communicate their SJP following the above training or follow their own process that meets or exceeds the one referenced above.

Evaluation

The effectiveness of SJPs must be evaluated on a regular basis or as the work situation or equipment changes. Any discrepancies noted must be reviewed and addressed immediately.

During the SJP training toolbox meeting above, workers are encouraged to provide feedback on the procedure being discussed. This feedback will be recorded on the toolbox meeting form and communicated to the responsible supervisor to review the feedback and update the procedure accordingly. All site supervisors are to be notified with any procedure change in order to communicate to all workers in their sites. JOHS Committee may also discuss workers' feedback on the procedures for any lessons learnt or further corrective actions. Workers, across all sites, must be re-trained and made aware of any and all changes within a reasonable time frame. A revised copy of the SJP must be readily available at the workplace, and kept at the head office, with previous versions removed from site and archived to avoid confusion.

*Refer to the SJP section of this OH&S Program for task specific SJP's

CANWIDE STEEL
OHS PROGRAM
Element 5
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
E05Created: Apr/2026Last rev: ---Rev. 2.91 of 3
ELEMENT 5 – COMPANY SAFETY RULES
Policy Statement

All Safety rules and procedures contained in this OH&S Program must be understood, practiced, and enforced by all personnel and subcontractors. All personnel on site must comply with all rules, regulations, procedures, and practices required by applicable safety legislation, including but not limited to: OH&S Regulations and in some cases OH&S Guidelines, Workers Compensation Act our OH&S Program, Building Codes, Federal, Provincial and Municipal Bylaws. Management may, at their discretion, refuse a worker(s) access to the site if any of these rules were deliberately violated, and/or when they foresee or deem a situation to be unsafe.

Company Safety Rules
  1. All workers must comply with Company rules, OH&S Regulations/Code/Act, applicable regulatory bodies, and the company's OH&S Program.
  2. All workers and visitors must report to site office to receive a Site-Specific Safety Orientation prior to commencing work.
  3. Consuming or being in possession of any alcohol or illegal drugs will not be tolerated. Being under the influence of any substance that prevents the safe operation of machinery and/or equipment is strictly prohibited.
  4. Bullying, harassment, and violence will not be tolerated and will be investigated and addressed immediately.
  5. Theft, vandalism and any other abuse or misuse of company and/or co-worker's property is prohibited.
  6. Cellular phones can be a distraction! Do not use your cell phone on site unless for company business. When answering/making a call, stop whatever you are doing and take a step back first. DO NOT operate any power tools or machinery while using cell phones or any other form of distraction.
  7. All unsafe acts, conditions, safety concerns, and 'near misses' must be reported to a Supervisor immediately.
  8. All incidents that result in injury and/or property damage are to be reported to a Supervisor immediately.
  9. First Aid treatment is to be obtained promptly.
  10. Basic PPE, in good condition, must be worn at all times at the workplace, except when identified by Risk Assessment. These items are inclusive of, but not limited to: Approved Hard hats, steel toe safety boots and high visibility vests.
  11. Specific PPE (harness, respirator, etc.) must be worn when and where required as specified by Risk Assessments, SWPs, SJPs, SDS, Fall Protection Plans, or any other document/procedure identifying such need.
  12. Loose clothes and accessories are not allowed on our sites. Dress according to the weather forecast and allow for changes in conditions.
  13. All work is to be carried out with regard to the appropriate Safe Work Practices, Safe Job Procedures, and the Supervisor's directions. Any worker who has any doubts about performing a job safely must report to the Supervisor.
  14. Proper tools, machinery and equipment are to be used only by a qualified and authorized people, in a safe manner, as per regulation and manufacturer's instructions. Do not modify, manipulate or remove any safeguards from any tools, machinery or equipment. If an item is found to be defective or has been previously modified; take it out of service and tag it/ lock it out so it cannot be used by others. All tools, machinery and equipment must be properly stored when not in use.
  15. Never use tools, machinery and equipment for anything other than their intended purpose.
  16. WHMIS requirements must be followed when using any controlled product.
  17. Housekeeping: Every worker must keep themselves, and their work areas neat, clean, and orderly at all times and specifically by the end of each workday. No dust is permitted to accumulate so as to constitute a hazard.
  18. Toolbox Meetings must be held weekly. All participating parties must sign the Toolbox Meeting form. The form must be forwarded to management or any required personnel.
  19. Smoking/vaping is only allowed in designated smoking areas. When smoking, always keep a minimum of 6m from a doorway, window, or air intake.
  20. Do not come to work if contagious or are not fit for duty.
Improper Conduct

We will ensure that workers conduct themselves in a responsible and mature manner while in the workplace. The following activities will not be tolerated:

Engaging in horse play, fighting, practical joking, unnecessary running or jumping and other similar conduct is forbidden and may result in disciplinary action.

Knowingly or intentionally engaging in hazardous behavior.

Spitting, or placing your spit on any surface with the intention of it being touched by others.

Responsibilities

All personnel must ensure that rules are adhered to according to their position in the company.

Management/Supervisors must ensure that:

Workers must ensure that they:

Subcontractors must ensure that:

Note – Temporary workers/ day hires are considered employees of a Sub-Contractor. All temporary workers must arrive to the workplace orientated and trained for their tasks and with the basic and specialized PPE required. The sub-contractor that hired them must supervise them.

Refer to Section 13 of this OH&S Program for more information about roles, right and responsibilities, including Refusal of Unsafe Work.

CANWIDE STEEL
OHS PROGRAM
Element 5A
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
E05ACreated: Apr/2026Last rev: ---Rev. --1 of 1
ELEMENT 5A – DUE DILIGENCE POLICY

All employees, sub-contractors, visitors, and every person involved in our operation is expected to take all reasonable steps to prevent incidents and minimize harm in our workplaces. This duty applies to situations that are not addressed elsewhere in Occupational Health and Safety Legislation. The following list are conditions as to how due diligence will be established.

CANWIDE STEEL
OHS PROGRAM
Element 5B
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
E05BCreated: Apr/2026Last rev: ---Rev. --1 of 1
ELEMENT 5B – DISCIPLINARY ACTION POLICY

All employees are expected to adhere to all aspects of our OH&S Program. Workers found in non-compliance will receive disciplinary action up to and including termination as follows:

Minor Infraction

Definition: Any infraction of government, corporate or client rules that does not have the potential to cause immediate serious damage or injury.

1st OffenceVerbal warning with written documentation and/or sent home
2nd OffenceFormal written warning and/or sent home without pay
3rd OffenceSuspension or Termination

Despite the above criteria for infractions, a gross safety violation may be cause for immediate dismissal.

Major Infraction

Definition: Any infraction of government, corporate or client rules, or legislation that has the potential to cause serious damage or injury.

1st OffenceFormal written warning and/or sent home without pay
2nd OffenceSuspension or Termination
Designated High Risk Violations

Violations of the Workers Compensation Act ("Act") or Regulation relating to the following circumstances are considered to be high risk violations by WorkSafeBC:

  1. Entry into an excavation over 1.2 m (4 feet) deep, contrary to the requirements of the Regulation.
  2. Work at over 3 m (10 feet) without an effective fall protection system.
  3. Entry into a confined space without pre-entry testing and inspection to verify that the required precautions have been effective at controlling the identified hazards.
  4. Causing work disturbing material containing asbestos, or potentially containing asbestos, to be performed without necessary precautions to protect workers.
  5. Hand falling or bucking without necessary precautions to protect workers from the tree that is being felled or bucked, or other affected trees.
  6. Work in the vicinity of potentially combustible dust without the necessary precautions to protect workers.
CANWIDE STEEL
OHS PROGRAM
Element 5C
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
E05CCreated: Apr/2026Last rev: ---Rev. --1 of 1
ELEMENT 5C – SANITARY CONDITIONS

Sanitary conditions are essential to preserve the health of all personnel. All personnel on site are to adhere to the Occupational Hygiene Regulations where applicable. Cleanliness is a priority to us, anyone caught urinating/defecating anywhere other than approved facilities may face disciplinary action. We will ensure that workers have adequate facilities to eat and rest during breaks. These facilities will be secure and dry so that personal equipment and clothing may be stored there safely. We will also follow our Communicable Disease Plan for sanitation of all areas. Any related issues must be reported to your supervisor to communicate to the Superintendent/Supervisor as needed.

We will coordinate with our Prime Contractor to ensure that the following applies:

In 2024, WorkSafeBC introduced new requirements for washrooms in construction. Under the new revisions to WSBC regulation part 20.3.1-.2 and 4.85 worksites must provide plumbed, or flush toilets when sites have at least 25 workers and where practicable. A Washrooms Assessment is intended to assist with the assessment process to determine what washroom facilities are appropriate for a project and it should be part of a project pre-start assessment and revised every 3-6 months for the estimated peak workforce to ensure sufficient facilities and adequate type for the worksite and at least annually or when the site conditions change.

The following information is to assist in determining the number of portable washrooms required on site:

  1. Where there are more than nine (9) workers, separate washrooms clearly marked for male and female workers. However, if the total number of workers on shift is nine (9) or fewer, or if a work area with nine (9) or fewer workers is located more than 60 metres (200 feet) from other washroom facilities, a single washroom for use by both male and female workers is generally suitable, provided it has a lockable door.
  2. In each female or male washroom, one toilet for nine (9) or fewer workers, two toilets for 10 to 24 workers, plus one more toilet for each additional 25 workers. If more than one toilet is required in a washroom for male workers, urinals may be substituted for half the recommended number of toilets.
  3. For plumbed washrooms, if any, one wash basin connected to a source of hot and cold water in each washroom containing one or two toilets and/or urinals, and at least one additional wash basin for each additional two such fixtures. If a large circular pedestal wash basin is provided, 60 centimeters (2 feet) of the circumference is generally considered equivalent to one wash basin.
  4. Washrooms should be designed to provide privacy for workers using the facilities.
Definitions

The handwashing facilities must be in or near the enclosed space where toilets are situated.

Washrooms must be maintained in proper working order and cleaned and sanitized regularly. Records of maintenance and cleaning activities must be kept for at least 30 days.

CANWIDE STEEL
OHS PROGRAM
Element 5D
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
E05DCreated: Apr/2026Last rev: ---Rev. --1 of 1
ELEMENT 5D – ENVIRONMENTAL POLICY

We are committed to establishing and maintaining sound business practices by working with the government, our clients and the public to minimize the impact our work has on the environment. All our employees and contractors will support this objective by ensuring the adherence to the following rules:

  1. Dangerous, hazardous, and toxic materials will be marked, handled and stored in an approved manner and in accordance with applicable legislation.
  2. Vehicles will be operated and maintained in accordance with manufacturer recommendations, to minimize their potential impact on the environment.
  3. Site generated waste is to be placed in designated containers only or as per site requirements.
  4. Environmental spill kits must be made available on site and secondary containment used if needed.
  5. Any loss of a hazardous product in liquid form of over five litres must be controlled, then reported to our management.
  6. Contaminated soil will be stored in a secure location on site until it can be disposed of in a proper manner or in accordance with contracts.
  7. Portable fueling (tidy) tanks will be protected by an environmental protection field equivalent to 120% of its capacity.
  8. Oily rags will be stored in a secure location on site until they can be disposed of in a proper manner.
  9. Adequate fire extinguishers will be available during all fueling operations.
CANWIDE STEEL
OHS PROGRAM
Element 5E
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
E05ECreated: Apr/2026Last rev: ---Rev. --1 of 1
ELEMENT 5E – WORKING ALONE OR IN ISOLATION

Where a worker is assigned to work alone or in isolation, the Supervisor will perform a Pre-Job Risk Assessment and a Daily Hazard Assessment to identify any hazards/risks to the worker. The Employer must first consider eliminating the hazards and provide necessary risk controls. They must also provide procedures to periodically check the well-being of their worker. This procedure must be developed in consultation with the JOH&S Committee or the worker health and safety representative, and must list:

The communication method will be secured/tethered to the lone worker, as practical. The procedure should be reviewed and amended if needed when the risk is high, such as working at heights. The Supervisor will ensure there is an assessment of all locations and tasks to identify situations where a worker may not be able to secure assistance in the event of an injury or incident.

CANWIDE STEEL
OHS PROGRAM
Element 5F
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
E05FCreated: Apr/2026Last rev: ---Rev. --1 of 1
ELEMENT 5F – AFTER HOURS WORK

All work to be conducted outside of normal site hours must be coordinated with the Superintendent before the scheduled start date of the work. Items listed below must be verified to ensure the safety of our workers staying after-hours:

CANWIDE STEEL
OHS PROGRAM
Element 6
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
E06Created: Apr/2026Last rev: ---Rev.1.31 of 4
ELEMENT 6 - PERSONAL PROTECTIVE EQUIPMENT
Policy Statement

We require all personnel, subcontractors, and visitors to always use Personal Protective Equipment (PPE) onsite. If OH&S Regulations, SWPs, SJPs, equipment manuals, risk assessments, and/or SDS indicate the need for additional PPE, Management will ensure that workers use PPE appropriate to their work activities. Clothing, jewelry, and hair can also cause serious injury when loose or torn. Do not wear loose or torn clothing, loose hair, or jewelry around any moving or rotating tool or equipment. Clothing made of polyester or synthetic fibers can easily melt and adhere to your skin causing serious burns, therefore should never be worn around molten metal, open flames, or any hot work. The information in this Policy does not take precedence over the applicable legislation, with which all employees shall be familiar.

Sub-contractors are expected to follow the requirements below and train their workers.

Training

Our employees receive training in the use, care, limitations, and maintenance of PPE prior to commencing any work activities. This training will be continuously reinforced through toolbox meetings, and as the job requires. Instructions on the proper fitting, care and correct use of specialized PPE will be provided by approved trainers, depending on the equipment, for example:

Selection

Personal protective equipment must be selected and used in accordance with the applicable recognized standards (CSA, ANSI, NIOSH, etc.), and must provide effective protection. PPE is the last line of defence and must be used in conjunction with other controls. Elimination, Substitution, Engineering and Administrative controls must be evaluated to minimize risk to workers and indicate the required personal equipment.

Basic Personal Protective Equipment
Specialized Personal Protective Equipment

Specialized PPE requires professional training due to the level of risk it poses. It is our policy to implement training and instructions to all our workers and subcontractors using Specialized PPE.

Supervisors will ensure that the Specialized PPE is available to their workers and that they are trained to use it. All workers that use a specialized Personal Protective Equipment (PPE) to perform their task must be trained prior to commencing any work activities.

Common Specialized PPE in our operations are:

PPE Rules

Mandatory PPE for our workers and sub-contractors:

  1. Always wear hard hats and work boots appropriate to the task.
  2. Always wear high visibility vest on site.
  3. Wear eye protection when exposed to eye hazards, such as when drilling, grinding, hammering, etc.
  4. Wear hearing protection when required as per the Hearing Conservation section of this Program.
  5. Use Specialized PPE as required.
  6. Prior to using any type of PPE, ensure it is in good working condition, free of dirt and debris, and fits properly
  7. Personal Protective Equipment must always be stored and maintained as per manufacturer's instructions.
  8. Workers are to remove or otherwise confine/contain any loose clothing, hair, neck chains and any other loose item that can get caught in any equipment or machinery when such hazard exists.
  9. Any defective PPE must be taken out of service and replaced immediately
  10. Follow regulatory requirement and manufacturer's instruction in the use, care, maintenance, inspection, and replacement of all PPE.
Inspection

All PPE must be inspected by the user prior to each use, and as required by manufacturer or applicable standard/legislation. Any defective PPE must be taken out of service and replaced immediately. Pre-use inspection of specialized PPE must be completed before each use. PPE that is found defective must be tagged out and reported immediately to the supervisor. Any inspection of the Specialized PPE must be recorded. Pre-use Inspection and Maintenance record of Specialized PPE must be kept available onsite and copy will be sent to Head Office. When disposing of defective PPE, supervisors must ensure PPE cannot circulate back into the workplace. For example, when disposing of a defective harness, cut in half to make it unusable. In our weekly toolbox meeting, all workers will perform a visual inspection of their PPE and this group inspection will be recorded in the toolbox meeting record.

Fitting, Care and Use of Specialized PPE

All workers required to use specialized PPE for their scope of work must be instructed in the proper fitting, care and use of such PPE. Performance of protective equipment is directly affected by its fit, overall condition and improper storage. Some PPE can increase the risk of injury if used improperly (e.g. harness). As a rule, all PPE is personal equipment, so it must be fitted for each person and inspected by the user who is trained on its proper maintenance in accordance with the manufacturer's instructions. Respiratory protection is specific to circumstances and requires the user to be fit tested by a trained professional. Refer to the Respiratory Protection section in this OHS Program.

Requirements for PPE Use:

Head Protection

  1. A Headgear assessment shall be completed and posted if there is risk of head injury in an area (see Forms)
  2. All workers shall wear, a CSA or ANSI approved safety hardhat while on job sites that have head injury hazards that cannot be controlled by other means.
  3. Workers must wear non-conductive safety headgear when exposed to electrical hazards.
  4. Chin straps, hardhat lanyards or other effective means of tethering must be used when working at height or handling material from inside a manhole.
  5. Painting, marking or decals on hard hats often hide defects and should be avoided.
  6. Inspect the shell and suspension of hardhats regularly for cracks, deep scratches, dents, or other defects. Inspect the suspension at the connection to the shell and ensure all points are connected.
  7. Replace a defective hardhat immediately. Recommended: replace after strong impact even if no sign of damage.
  8. Replace shell every 5 years and suspension every year, or as specified by manufacturer which is printed on the hard hat itself.

Foot Protection

  1. Workers must wear CSA certified Grade 1 footwear. This footwear bears the CSA logo inside a green triangle.
  2. Safety footwear is to be worn with laces tied at all the way to the top.
  3. Do not wear safety footwear that is cracked or cut through the leather. Always make sure the footwear has good slip resistant sole material that is not excessively worn.

Hand and Skin Protection

  1. Gloves are required when and where the possibility of injury to the hands exist. Ensure that the gloves being worn will allow the safe operation of the task at hand. There are many types of gloves for different applications. In some higher risk situations, a worker may be required to use two gloves simultaneously.
  2. Workers are encouraged to always dress suitably for work. Items such as denim coveralls and cotton shirts provide protection against minor scrapes and bruises as well as harmful ultraviolet radiation. Track pants, tights are not suitable for construction hazards.
  3. Workers are to remove or otherwise confine any loose clothing, hair, neck chains and any other loose item that can get caught in any equipment or machinery.
  4. Recommended to remove finger rings. They can easily get stuck and could cause amputation.
  5. Do not wear greasy or oily clothing, gloves or boots, torn or ragged clothing.
  6. Clothing made of synthetic fibers can be ignited and melted by electric flash. Cotton or wool fabrics are more flame retardant and are therefore recommended.
  7. Workers are advised to wear a shirt with sleeves to protect from sunburn and abrasion.
  8. Long pants and long-sleeved shirts are recommended for use to reduce minor cuts, scrapes and abrasions and should be worn when working with sharp or abrasive materials.
  9. Appropriate gloves should be worn when operating power tools such as drills, saws, table saws, etc or as mentioned on the manufacturer's instruction or risk assessment. Do not operate the equipment unless it is safe to do so.
  10. Workers should wear protective equipment when handling materials likely to puncture, abrade or irritate hands and arms, unless the use of this equipment introduces equal or greater hazards.
  11. Insulating rubber gloves may be required for some electrical work. Supervisors must confirm gloves are adequately rated for the work conditions.

Eye Protection

  1. It is mandatory to wear proper eye protection if there is a risk of eye injury. Such as when hammering, drilling, grinding, soldering, or other work that could cause flying debris or particulates.
  2. Workers must wear safety goggles over non-safety prescription glasses where an eye hazard exists or use prescription safety glasses.
  3. Workers using chemical products, which may splash into the eyes, shall wear safety goggles or chemical splash goggles dependent upon the requirements of the SDS for the product. The use of strong chemical products such as acids, base or alkaline products will require the use of a face shield as well as chemical goggles.
  4. Workers wearing contact lenses must inform their direct supervisor and/or first aid attendant so the lenses can be removed in the event of an accident.
  5. Workers must not wear contact lenses where gases, vapours, flying objects, mist, dust or other materials are present that may harm the eyes or be absorbed by the lenses.

Hearing Protection

Refer to the Hearing Conservation Program appendix of this OH&S Program for further details. The following points are the minimum standard to be achieved by trained workers:

  1. All workers engaged in Construction work are required to have an annual hearing test and are required to carry a current hearing test card.
  2. Workers engaged in activities, which generate noise, or who are exposed to noise from tools and equipment shall wear CSA approved hearing protection.
  3. Prolonged exposure to noise levels in excess of 85db is harmful.
  4. Always keep your hearing protection clean to avoid irritation to the ear and ear canal.

Respiratory Protection Refer to the Respiratory Protection Program element in this OHS Program

Fall Protection Refer to the Fall Protection Program element of this OHS Program

Annual Review

Our company will review on an annual basis related PPE documentation and process in consultation with the joint committee or worker health and safety representative. It will include assess exposure control measures to ensure their continued effectiveness, determine the need for further control, ensure the adequacy of instruction, and, when applicable, for respirators, assess the adequacy of exposure monitoring data and assess the need for further monitoring, and ensure the adequacy of the fit test program.

CANWIDE STEEL
OHS PROGRAM
Element 7
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
E07Created: Jul/2024Last rev: ---Rev. 1.11 of 1
ELEMENT 7 - PREVENTATIVE MAINTENANCE
Policy Statement

We have created a preventive maintenance program to protect personnel and property on site. This program is designed in accordance with applicable legislation and aligned with manufacturer's recommendations. All company owned, leased, or rented equipment must be included in this preventative maintenance element. All Equipment must be identified and tagged to create Maintenance schedules with documentation that can be monitored. Everyone is required to immediately remove or tag out of service and report to supervisors any unsafe equipment before operating it.

The information in this Policy does not take precedence over the applicable legislation, with which all employees shall be familiar.

List of All Equipment and Schedule of Repair

Create an inventory list of machinery, specialty tools and equipment used at the workplace. All scheduled preventative maintenance activities must be performed by a competent person as per manufacturer's specification, regulatory requirements and/or industry standards.

This schedule does not take the place of pre-use inspections and that all equipment must be continuously monitored for damages or other potential hazards. Speciality tools/equipment requiring 3rd party inspections, maintenance and calibration shall be included in the inventory and a schedule kept.

Equipment Manuals and Instructions

All equipment manuals, instructions and other relevant materials provided by the manufacturer must be readily available at the workplace. The operator's manual must be available to any worker operating the equipment when requested.

Access to an operator's manual does not replace the need for worker training, competency evaluations, supervision, or the creation of Safe Work Procedures.

All users and operators must adhere to all manufacturer's instructions.

Lock Out / Tag Out of All Damaged Equipment

Any defective equipment that poses a risk to workers must be removed from service and marked "do not use". Large pieces of machinery that cannot be removed must be "locked out" in such a way that they are not operable.

Equipment may not be returned to service until it has been repaired and deemed safe and operable by a qualified person.

Record Keeping

A pre-use inspection of equipment must be completed prior to each use. Pre-use Inspections, in addition to all repairs and maintenance performed on equipment must be recorded using paper-base, QR codes generated by QR Safety or another system in use. Records must be readily available/accessible onsite.

Daily pre-use inspection of PPE and non-powered hand tools may be done visually, with formal documented inspections done at longer intervals, e.g. quarterly or annually. Equipment users or supervisors may choose to document daily inspections as part of their hazard assessment process.

CANWIDE STEEL
OHS PROGRAM
Element 8
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
E08Created: Apr/2026Last rev: ---Rev. 2.41 of 4
ELEMENT 8 - TRAINING AND COMMUNICATION
Policy Statement

Our goal is to have zero incidents/injuries in the workplace by utilizing our Training Program to provide workers with the skills and instructions necessary to perform the task safely. Everyone must receive a Safety Orientation outlining our OH&S Program requirements and our safety expectations. Newly assigned and youth workers are at a higher risk of injury and as such must be trained, deemed competent and mentored by co-workers/supervision.

Ongoing Safety training includes weekly toolbox meetings, to ensure that employees are updated on current safety topics and are aware of the SWPs and SJPs pertaining to their scope of work. Specific training will be provided based on the scope of work, whether required in this OH&S Program, OH&S Regulation, or Pre-Job Risk Assessments, or as needed based on hazards encountered in the workplace.

Worker Site Orientation

Site Safety Orientation is mandatory for all employees and subcontractors and is provided by our company. Every employer is required to orientate their workers when they are hired and when changes require updating. In addition, our Company will orientate all new workers and update orientations when required. Our worker orientations will be conducted by our Safety Coordinator or a Supervisor who is deemed qualified by the Safety Coordinator. Project sites may require additional training to meet minimum requirements. On-site orientations will be completed prior to working on any of our job sites and we will participate in any orientations required by sites managed by others. On-site orientations will be conducted by the Site Safety Coordinator. The Orientation forms shall be kept confirming the worker received the orientation(s). Our Company expects all employees to take site orientation(s) seriously and will make periodic checks to ensure workers are adhering to the Occupational Health and Safety Program, and any instructions provided to them. Orientation of workers will include but not be limited to:

  1. Worker's rights and responsibilities.
  2. Familiarization with our Occupational Health and Safety Program, and Site Safety Rules.
  3. Site Safety Plan and Emergency Procedures
  4. Site-specific hazards and conditions, such as proximity to powerlines.
  5. The location of first aid facilities and attendants.
  6. Accident/Incident and injury reporting procedures.
  7. Review of existing hazards and any known problems in the workplace.
  8. Reporting hazards and near misses.
  9. Bullying and Harassment Policy.
  10. Workplace Violence Policy.
  11. Disciplinary action policy.
  12. PPE Requirements on site and as it pertains to the scope of work.
  13. First Aid facilities and attendants, worker representatives and JOH&S Committees as applicable.

It is the responsibility of everyone to ensure that safe working conditions are maintained at the workplace.

New and Young Worker Site Orientation

We also give special attention to new and young workers. We must ensure that every new or young Worker is provided with a Safety Orientation and training before work begins.

"New" and "Young" are defined by WSBC in OH&S R 3.22 as:

Regarding the Orientation form, the "Worker Orientation" form combines New Worker and Young Workers, being its last page dedicated to when the new worker is under 25 years of age.

All Contractors are responsible for identifying New and Young workers in their workforce, and providing the required training.

The following topics must be included in New and/or Young worker orientation(s) or training:

  1. The direct supervisor's name and contact information.
  2. The Employer's New and Young Worker's rights and responsibilities under the Worker's Compensation Act and this Regulation including the reporting of unsafe conditions and the right to refuse to perform unsafe work.
  3. Workplace Health and Safety Rules.
  4. Hazards to which the New & Young worker may be exposed, including robbery, assault, bullying & harassment.
  5. Working alone or in isolation.
  6. Violence in the workplace.
  7. Personal Protective Equipment.
  8. Location of first aid facilities and means of summoning first aid and reporting illness and injuries.
  9. Emergency Procedures.
  10. Instruction and demonstration of the New and Young worker's work activity.
  11. Our Occupational Health and Safety Program.
  12. WHMIS information requirements as applicable to the New and Young worker's workplace.
  13. Contact information of the Occupational Health and Safety Committee or the Worker's Health and Safety Representative as applicable to the workplace.

Upon completion of any site orientation, the Supervisors will:

  1. Ensure Worker Orientation form is complete and signed by the worker. The medical information requested on the questionnaire may be omitted by the worker if they so choose, however the intent of such information is to provide the First Aid Attendant with crucial information the worker may not be able to provide in emergencies.
  2. Keep the Orientation form in the company's record, arrange with the sub-contractors any additional Site Orientations required. If possible, a copy of the orientation to be obtained as well.
  3. Provide the worker with further instructions and demonstration of their scope of work and procedures to follow. This will be an ongoing basis and on the job. New & young workers will not participate in any work they are not instructed/trained for.
Orientation Review

For longer duration projects, employees' orientations will be refreshed annually. Orientations may also be refreshed if deemed necessary by supervisor or management, such as when a worker exhibits lack of awareness of its topics.

Training of Supervisors

Company's Supervisors must be trained in the below topics. This training can be provided for all the topics, or separately per topic as practicable. Supervisors must be able to demonstrate knowledge of:

  1. The need to maintain a safe, non-violent, and healthy working environment.
  2. Importance of developing and sustaining a psychologically healthy workplace based on a foundation of ethics, stated values, trust, transparency, open communication, and empowerment.
  3. The Supervisor's health and safety responsibilities and Due Diligence.
  4. How to identify risk and perform a risk assessment, whether at the beginning of a project or pre-shift.
  5. How to communicate information, by example and instruction, to employees, to ensure that they understand and follow the applicable SWPs and SJPs.
  6. How to investigate accidents and to take corrective action to prevent recurrence.
  7. Techniques of effective supervision and instruction, including safety motivation, communication and feedback to workers with regards to their job/task observation or performance.
  8. How to conduct inspections of their workplace conditions and workers' behaviors
  9. How to conduct effective Toolbox Safety Meetings.
  10. How to follow-up incidents, inspections, and corrective actions to ensure their completion and effectiveness.
  11. Record keeping and documentation requirements; and how to defend their Due Diligence.

Supervisors are expected to be aware of the hazards associated with the job, the potential effect on workers, and the rules, procedures, and practices for controlling these hazards and associated risks. Additional supervisory courses are recommended as needed, such as related to Mental/Psychological Health in the workplace.

Training of Workers

In addition to the site orientation, training requirements for each worker will be identified by the supervisor or management and may include, but is not limited to:

  1. Personal Protective Equipment.
  2. WHMIS.
  3. Fall Protection.
  4. Silica Exposure Control and Respiratory Protection
  5. Tools & Equipment Used.
  6. Additional task specific training as required (ex. mobile equipment, confined space, etc.)

All training of workers must be listed with a date of expiration to ensure that the training of workers will be easily tracked and renewed as required. Job observation/evaluation and feedback provided to the worker must be documented.

Training records and job observation/evaluation must be readily available upon request.

Site Specific Training

Site specific safety training will be provided by or arranged by the workers' Supervisor which may include work activities, use of tools, SWPs and SJPs. Regular Toolbox Meetings, one on one instruction and practical demonstrations are all considered specific training and must be documented, noting the training given and name & signatures of all participants.

Refresher Training & Worker's Performance

Ongoing evaluation or observation of worker's job performance shall be conducted by the supervisor. Once the observation/evaluation is complete, feedback will be provided to workers to mentor and help workers develop and improve their skill sets.

Periodic refresher training is necessary to re-certify workers for specific jobs or to review SWPs and SJPs in order to perform specific tasks safely. The frequency of training depends on the nature of the task, the skills and safety factors required to do the job, in addition to any specific requirements in regulation or applicable standards such as CSA. For example, a higher risk more frequent job would have its associated SWPs and SJPs reviewed with workers more than a lower risk, less frequent job.

Toolbox meetings will include a review of SWPs & SJPs and regular reminders on how to work safely. In the case of re-certification of workers for specific training (e.g. fall protection, heavy equipment operators, respiratory fit testing, etc.), third party trainers will be utilized.

Communication

Our Company wants to operate without costly disruption and injury to workers at their workplaces. Safety issues will be communicated to all employees on site by the following means:

  1. Management Meetings – Meetings that only include Site Supervisors, Superintendents, Trade Supervisors and Company Management.
  2. JOH&S Committee Meetings/Worker Representative.
  3. Toolbox Safety Meetings.
  4. Posting in the workplace on Notice/Safety Boards.
  5. Daily Hazard Assessment/Pre-Shift Hazard Assessment/Pre-job Planning Session.

Supervisors are to put an effort towards building a good, trusting relationship between themselves and workers under their supervision. And to always allow an open, honest, non-judgmental, and non-blaming communication across their teams.

In addition to the formal means of communication listed above, non-related work activities such as, ice-breaker and team-work workshops, and other social events, could benefit the intrapersonal communication between workers.

Toolbox Safety Meetings

Toolbox Meetings shall be conducted weekly in order to provide timely information on safety related issues and concerns relating to the projects activities and working environment. The person conducting the meeting will be responsible for the following:

  1. Specifying time and place for meeting.
  2. Determine the agenda and control the meeting.
  3. Provide instruction on required topic.
  4. Enforcing attendance of employees.
  5. Encourage workers to raise questions and safety concerns.
  6. Ensuring review of previous minutes.
  7. Providing positive direction to resolve problems.
  8. Ensuring workers sign the attendance sheet and documentation is completed.

In a Toolbox Meeting, workers are encouraged to raise their questions or safety concerns. All the safety concerns will be discussed during the Meeting and workers are encouraged to participate in developing a corrective action plan, which will be addressed in a timely manner. Meeting minutes and attendance sheets are submitted to management within 24 hours and made available to workers upon request. SWPs and SJPs will also be reviewed with workers in toolbox meetings on a regular basis, their feedback obtained and recorded, with documents updated and reviewed again if needed.

Management will also periodically attend Toolbox Meetings, and participation is encouraged as it sets a good example.

Training Documentation

Documentation and filing of training records is an essential component of our company's records and its due diligence. Appropriate forms are to be completed and copies are to be retained at head office as well as on the job site. These records must be made available for review by an authorized person and must always be available on site for review, using paper-base or another system in use.

All contractors on site are required to submit their records for all training provided to their workers.

CANWIDE STEEL
OHS PROGRAM
Element 9
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
E09Created: APRIL 2026Last rev: ---Rev. 1.21 of 6
ELEMENT 9 - INSPECTIONS
Policy Statement

Workplace safety inspections are key activities in the prevention of incidents. Their purpose is to:

It is management's responsibility to ensure that the hazards identified through these inspections are corrected and eliminated or, where elimination is not practical, controlled, and that workers are protected from them.

Daily Site Inspection

Daily inspections of the worksite are to be conducted by all supervisors as part of their continuous day-to-day supervisory role. These inspections are visual and are not necessarily required to be documented. However, findings must be reported to appropriate responsible persons for correction and follow up, such communication can be verbal or written.

The person performing the daily inspection may choose to document the inspection reports when high risk situations have been observed during inspection, or hazards that require a longer time frame to resolve.

These inspections will be documented using a paper form or in Digital Documents Portal under the Inspections or Task/Equipment Inspection module. The inspection report must be provided to management for review. Alternatively, management can log into Digital Documents Portal, review the inspections and document the review. Any concerns found during the inspection must be reported to management to take action.

Daily inspections are also to be performed by safety manager/officer. These inspections will be documented and the inspection report provided to management for info/action.

Weekly Site Inspection

Weekly inspections are formal inspections conducted by management, supervisors, JOHS Committee members, worker representatives and/or any person designated by management. Weekly Inspections must be documented, with reports sent to management and JOHS Committee to review, and follow up when required. Refer to the Forms section of this OHS Program for Weekly Site Inspection Form. Coordinate inspections to have them spread evenly across the month and across different sites in order to ensure all our workplaces receive regular inspections. Notify area supervisors of inspections in their area to avoid hazards and conflicts.

Monthly Office Inspection

Office inspections are conducted by qualified personnel who check for potential hazards, such as fire, electrical, ergonomic, or chemical risks. Office inspections also verify that the office complies with relevant laws and regulations, such as building codes, accessibility standards, and environmental policies. Office inspections should be performed regularly and documented properly, as they can help prevent accidents, injuries, and liabilities.

Pre-Shift Safety Inspection

Pre-Shift Safety Inspections will be performed at the beginning of each shift by supervisors or workers, to ensure the workplace is free of any newly introduced hazards that developed between shifts, or existing hazards that have yet to be corrected. Any hazards must be eliminated, or if elimination is not practical, controlled before shift can starts. Hazards and controls to be documented on the Pre-Shift Risk Assessment. See Element 2 of this OHS Program.

Performing Inspections

All levels of the organization are encouraged to participate in performing inspections. Inspections must, where feasible, include the participation of members of the JOHS Committee or Worker Health and Safety representatives, as applicable. When conducting inspections, follow these basic guidelines:

Corrective Action Plan

Unsafe conditions and behaviors are to be corrected as discovered during inspections. Supervisors must ensure that high-risk situations are remedied immediately, with other risks addressed in a timely manner. Recurring problems and non-resolved issues are to be brought to the attention of the superintendent, and/or the safety manager/officer for review and action when necessary. Reporting issues to management may also be necessary if matters are not resolved on a timely basis.

Equipment & Tools Inspection
  1. Vehicles:
    All company vehicles must be inspected daily by the vehicle operator. The results of these inspections should be recorded on the appropriate inspection record. If the vehicle is used routinely by a worker, the worker should ensure that scheduled maintenance checks are completed and recorded. All receipts for maintenance, fuel, and lubricants should be submitted a minimum of once per month to the superintendent. Refer to the Driving Safe Work Practice in the SWP section of this OHS Program for more information on vehicle inspection.
  2. Equipment:
    Any equipment must be inspected prior to use by the operator. The results of these inspections must be recorded in the applicable log record, typically kept in equipment. Refer to equipment operator manual and/or the forms section of this OHS Program for more equipment-specific instructions.
  3. Tools:
    All tools are to be inspected prior to use by the worker. Tools that are damaged are to be tagged and removed from service until repaired. Tools that cannot be repaired are to be removed from service and inventory updated.
  4. PPE:
    Basic and Specialized PPE must be inspected prior to use by the worker. Damaged equipment should be tagged and removed from service immediately. Some PPE inspections will be recorded. Refer to Element 6 of this OHS Program for more information about PPE Inspection.

Workers are not to attempt repairing vehicles, tools or equipment unless authorized to do so by management, regulation and/or equipment supplier/manufacturer, as applicable. Inspection to be performed after repairs are completed to ensure safe operating condition prior to return to service.

All vehicles, tools, machinery and equipment must be inspected as per their manufacturer's instructions.

Documentation

The appropriate inspection forms are to be used when completing routine inspections of the workplace or equipment. Completed forms will be posted in the workplace, distributed to all applicable personnel, filed in an accessible manner and retained through the life of the project. In the case of equipment inspections, such records must be retained with the equipment for the life of the equipment. Inspection forms/checklists are just guidelines to assist the person performing the inspection, any hazardous behaviors or conditions identified during the inspection that are not in the form/checklist used must also be recorded and corrected.

Appendix - Site Inspection Guideline

Use the following list of items as a guideline to assist the person(s) performing the inspection in identifying hazards, and is not an all-inclusive or mandatory list. Several items in this list will be under the direct control of trades and sub-contractors. In such case, record your findings, communicate to appropriate employer(s), follow up, and document. During the inspection, assess the following behaviors and site conditions:

  1. Access and Egress
    • Safe and stable means of entrance and egress
    • Clear of debris/slip/trip hazards
    • Allow for rescue
    • Hand-rails/guardrails
  2. Atmospheric hazards
    • Dust, fumes, vapors, etc. controlled at source
    • No visible airborne dust
    • Workers exposed to dust have appropriate engineering, administrative controls and PPE.
    • No dry sweeping observed
  3. Personal Protective Equipment
    • Basic PPE followed
    • No loose clothing near moving equipment
    • Hearing, respiratory, fall protection and other specialized PPE used
  4. Guardrails
    • Installed on work platforms above 4 feet.
    • Properly secured, with adequate strength (Minimum 125 lbs. along the span).
    • Complete with top rails between 40 and 44 inches, mid-rails, toe-board and spans less than 8 feet
  5. Pneumatic Tools
    • Air supply disconnected for servicing and adjustments
    • Trigger mechanism operating correctly
    • Hoses do not present tripping hazard
    • Hoses secured together with whip checks
  6. Onsite Vehicles
    • Parked in safe location
    • Operators are authorized
    • Operated at a safe speed
    • Operated in a safe manner
  7. Containers
    • Appropriate WHMIS labels (supplier or workplace label as applicable)
    • Contain what is on label
    • Stored in a manner compatible with contents and MSDS/SDS
    • No observed leaks
  8. Compressed Gas Cylinders
    • Secured from falling
    • Standing on end
    • Away from heat and sparks
    • Empty cylinders are capped
    • When in storage, oxygen and Fuel cylinders are separated 20 ft apart or with non-combustible barrier
  9. Electrical
    • Ground Fault Circuit Interrupters (GFCI)
    • Cord insulation intact
    • Cords elevated or covered, "no tripping hazards"
    • Three prong plugs are used
    • Energized junction boxes and electrical panels are covered
    • Energized rooms are locked
    • Temporary lighting does not have broken or missing bulbs
    • Clearance maintained for workers and equipment
    • Minimum Safe Approach Distance (MSAD) followed for power lines
  10. Confined Space Entry
    • Confined spaces identified with signs
    • Confined spaces not requiring entry are locked
    • Confined space entry program available on site
    • Confined spaces requiring entry has a hazard assessment and entry procedure prepared
    • Workers trained and instructed in confined spaces they are entering
    • Procedures followed
    • Stand-by person assigned and performing assigned duties
    • Rescue team assigned and properly equipped
  11. Fall Protection
    • Must have a written, site-specific fall protection plan when at or above 25 ft or when work procedures are used in place of a fall protection system (e.g. control zones & monitors)
    • Fall protection equipment used properly
    • Manufacturers' instructions available and followed
    • Workers trained
    • Proper storage of equipment
    • Compatibility followed, with no incompatible connections observed
    • Hierarchy of Controls followed
  12. Fire Protection
    • Fire equipment is accessible and in working order
    • Gasoline and flammables stored in approved containers
    • Danger signs and Emergency phone numbers posted
    • Temporary heating devices provided with adequate clearance
  13. Housekeeping
    • Work area is clean and free of debris
    • Spilled or leaked liquids are cleaned up
    • Adequate garbage containers available
    • Nails are bent over or removed
    • Materials and equipment stored in a safe manner
    • Combustible waste materials stored safely and removed from work site
  14. Ladders
    • Rungs, rails and ropes in good condition
    • Evidence of pre-use inspections performed
    • Placed at 4:1 ratio (75°)
    • Extends 3 feet above platform being accessed
    • No metal ladders in proximity to electrical hazards
    • Barricaded when used in passageways and stairwells
    • Secured to prevent movement
    • Job-built ladders built from lumber grade 2 or better and as per WCB Standard LDR-01
    • Broken ladders tagged and removed from site
  15. Machinery Guards
    • Not missing or damaged
    • Prevent contact with moving parts
    • Prevent access to danger area during operation
  16. Powder Actuated Tools
    • Hearing protection
    • Eye protection
    • Operators authorized and certified
  17. Repairs to Equipment
    • Out of order equipment are shut down and locked-out
    • Suitable signs have been posted
    • Suspended and raised equipment is blocked prior to work
    • Power sources Locked-out/Tagged-out
    • All repaired equipment to be tagged and identified
  18. Rigging Equipment and Slings
    • Loaded in accordance with allowable workload rated capacities
    • Check for wear on slings/chains
    • Check for safe work load tags
    • Check storage area - chains/slings should be hung up in dry, covered area
  19. Safe Work Practices and Safe Job Procedures
    • Available to workers
    • Signed-off by workers as applicable
  20. Scaffolds
    • All braces on
    • All connectors on
    • Firm base no concrete blocks
    • Guardrails on open sides and ends, including toe boards when required
    • Planks a minimum of 2-10" in width, no defect, 6-12" overhang
    • Plumb/tied to structure
  21. Stairway
    • Free of obstruction
    • Handrails
    • Adequate lighting
  22. Walkways
    • Railing/toe board
    • Adequate lighting
    • Free of obstacles
  23. General Public
    • Proper and visible signage in place
    • Public routes, roads, sidewalks free of obstacles
    • No debris or dropped objects in public areas
    • Hording, netting, and similar protection
CANWIDE STEEL
OHS PROGRAM
Element 10
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
E10Created: Apr/2026Last rev: ---Rev. 1.11 of 4
ELEMENT 10 - REPORTING AND INVESTIGATION
Policy Statement

Reporting and Investigation of accidents/incidents and near-misses must be performed to determine the root causes and prevent reoccurrence. An accident/incident investigation is conducted, and a report completed and reviewed by Management. Subcontractors will be made aware of incident reporting requirements. Subcontractors will have to report all incidents to us. If a subcontractor is involved in an incident, our company is responsible for reporting the incident to the hiring client. Our company will ensure the incident is investigated and must participate in the investigation. Lessons learned from an accident/incident will be communicated to all employees through Toolbox Meetings and posted in the workplace. Corrective Action Plan will be discussed to ensure that all personnel are aware of the incident/accident and will abide by the corrective action plan implemented to prevent reoccurrence.

The information in this section does not take precedence over the applicable requirements in the Workers Compensation Act and any applicable regulations, with which all employees shall be familiar.

Regulatory Requirements

In accordance with the Workers Compensation Act, the below accidents/incidents must be reported and investigated immediately:

  1. Resulted in a serious injury or death
  2. Involved a major structural failure or collapse of a building, bridge, tower, crane, hoist, temporary construction support system or excavation
  3. Involved a major release of a hazardous substance
  4. Involved a fire or explosion that had a potential for causing serious injury to workers
  5. Any accident/incident required by the regulation to be reported

The above situations require that the WorkSafeBC is contacted immediately and that the incident scene must not be disturbed unless directed by an officer of the board or a peace officer, except to:

  1. Attend to persons injured or killed;
  2. Prevent further injuries; and
  3. Protect property that is endangered as a result of the accident.

In accordance with the Workers Compensation Act, additional accidents/incidents below must be investigated immediately:

  1. Accidents that resulted in an injury requiring medical treatment by a physician
  2. Accidents/Incidents that did not involve injury but had a potential for causing serious injury
  3. Any accident/incident required by the regulation to be investigated

All investigations will be conducted by persons knowledgeable of the work involved. Managers, supervisors, Site Safety Coordinator, JOHS Committee members and a worker representative, if reasonably available, will participate in the investigation. Investigations carried out by our subcontractors shall be done with the participation of a representative from our company. The services of an external OHS Advisor/consultant may be procured if deemed necessary by management. Information shall be recorded on the form provided in the forms section of this OHS Program, and management shall review the reports with the employees.

Reports shall be sent to our Company's Office and will be forwarded to the appropriate parties, including the hiring client, by management. Under no circumstances are any reports to be submitted to WorkSafeBC on behalf of the company until management has reviewed them and signed off.

Objectives

Accident/Incident investigation is an important part of an effective Occupation Health and Safety Program. All significant accidents/incidents, as well as near misses, must be investigated as soon as possible. The goal of an investigation is to prevent future reoccurrence, not to find blame or place fault. All incident investigations will be initiated as soon as possible after the occurrence, in order to:

Investigation Requirements

Preliminary Investigation must be performed within 48 hours to the types of accidents indicated above, in order to:

A preliminary investigation is an opportunity for employers to identify any unsafe conditions, acts, or procedures that must be addressed so work can resume safely until a full investigation has been completed. The investigation may be requested by WSBC and must be provided upon request.

Any corrective actions identified during the preliminary investigation must be completed as soon as possible. Both the investigation report and corrective actions report are to be submitted to the site Joint Health and Safety Committee as soon as practicable.

The preliminary investigation report must contain as a minimum:

A Full Investigation must be performed directly after the preliminary investigation is completed, and within 30 days of the incident occurrence, the full investigation is to:

A full investigation involves carefully analyzing the facts and circumstances to identify the underlying factors that led to the incident. The investigation must be submitted to both WSBC and the Joint Health and Safety Committee within 30 days of the incident occurrence. Any corrective actions identified during the full investigation must be completed as soon as possible. And a report of these corrective actions is to be submitted to management and site Joint Health and Safety Committee as soon as practicable. The accident/incident report form in the Forms section of this program shows the information required by the regulations.

In addition to the information required in the Preliminary Investigation Report, the Full Investigation Report must provide:

  1. Our company's legal name, address, contact number, email address, and WorkSafeBC account number
  2. The identification and contact information of other relevant workplace parties such as an owner, prime contractor, any persons involved, or persons implementing the corrective action following the full investigation;
  3. The root causes (also known as underlying factors) of the incident.
  4. Full and detailed description of the incident.
  5. The names of the person(s) conducting the Full Investigation.
  6. Additional corrective actions necessary to prevent reoccurrence, with the estimated and actual completion dates.

Management must ensure that all accident/incident investigations have been followed up in order to ensure that corrective actions are completed in due time. Follow up will be based on estimated completion time.

Near Miss Investigation

All employees are required to report Near Misses to their direct supervisor. Near Misses with a high potential to cause a serious injury or property damage will be investigated, and communicated to all sites.

Conducting an Investigation

Three stages of an accident/incident should be investigated:

  1. Pre-accident/incident stage - the factors that permitted the sequence of events leading to the accident/incident. These may include:
    • Employer characteristics (trade, size, safety program, supervision, equipment maintenance, etc.).
    • Employee characteristics (age, sex, occupation, health, experience, training, etc.).
    • What wasn't "normal" before the accident/incident compared to other days where the same job/task is done; what new conditions were introduced this time.
  2. Accident/Incident stage - the immediate factors in the accident/incident. These may include:
    • What was the victim doing (task, specific activity, posture, location, etc.).
    • What's the usual way of doing this task, activity, etc.
    • What SWP, SJP, PJRA, etc. were in place, how applicable, instructed to workers, and followed.
    • Working conditions; was worker supervised, working alone, etc.
    • Materials and equipment directly involved (type, brand, size, guarding, condition, etc.).
    • Immediate causes and actions that led to the accident (fall, trip, slip, horseplay, etc.).
    • Environmental characteristics (weather, lighting, noise, temperature, vapours, ventilation, etc.).
  3. Post-accident/incident stage - the factors occurring after the actual incident that minimized or increased the seriousness of the incident. These may include:
    • Emergency response plans / Evacuation plans.
    • The response time of emergency personnel.
    • First aid available on site.
    • Location and condition of emergency equipment.
    • Personal protective equipment worn or unused.
During Investigation

Data collection during an investigation will include the below means:

Investigation Review

The Health and Safety Committee will review incident/accident Investigations and if the Committee makes further recommendations, they will be reviewed. Management, along with the Occupational Health & Safety Committee will assess the corrective actions when they are completed and determine if they have been successful.

Lessons Learned

Lessons learned from investigations will be communicated to all workers on all our sites. This will be done in the weekly Toolbox Talks with all workers. Management will be responsible for the implementation of company-wide action items that result from accident/incident investigations.

CANWIDE STEEL
OHS PROGRAM
Element 11
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
E11Created: Apr/2026Last rev: ---Rev. 1.31 of 7
ELEMENT 11 - EMERGENCY PREPAREDNESS AND RESPONSE
Policy Statement

Procedures for emergency response, care of injured workers, reporting and corrective follow-up of all injuries and serious accidents will be made available by management for all projects of substantial duration. The procedures will be thoroughly outlined, posted, made known to all workers, and enforced.

The following points outline what needs to be on site and office with regards to emergency procedures. Superintendent(s) and/or Office Manager will ensure procedures are comprehensive and will address possible emergencies.

Prevention

Superintendents, Managers, Supervisors, JOHS Committee members, worker representatives, safety manager/officer and/or management, will perform regular and effective inspections to ensure that the workplace remains free from hazards that may result in an emergency. Our workers will also be responsible to ensure their immediate work area is free from hazards.

Emergency Notification Protocols for the Site(s)

Emergency notification method for our site(s) is:

These procedures will be communicated to all workers during their site safety orientation.

As the project progresses it may be necessary to revise the emergency procedures to reflect new hazards or account for changes to the protocols on site. In these situations, it is imperative that all affected personnel be made aware of these changes before they take effect.

Emergency Response Team

Responses to emergency situations may be under the direction of the Safety Coordinator and/or superintendent unless otherwise directed by clients or emergency responders. Each location is different in size and distance to hospitals and risk levels that may require a dedicated emergency response team. This does not preclude the requirement for the site to have an emergency plan in place and for the plan to be reviewed and practiced regularly. Typically, an Emergency Response Team will be assigned by the Superintendent or Office Manager, with participation from trades as needed.

In addition to the procedures to follow in emergencies, the team should be familiar with the following, where applicable:

Evacuation Routes

Emergency evacuation routes must be identified and reviewed frequently to ensure access remains clear of any obstructions or hazards. All routes must be identified on the site plans and signage should be posted if the route is through an area which is not regularly accessed by workers. Access routes are inspected during Pre-Shift Inspection in order to confirm all workers in the starting shift have unobstructed access and evacuation routes. An example of this would be when access to the top deck/level is only via ladder, emergency evacuation could be done using the D.E.P. on site. Workers are instructed to not work in any area with limited or restricted access without proper emergency and evacuation procedures.

Emergency Transportation

Employers are to ensure that transportation arrangements are in place and available for transporting injured or ill workers to a health care facility when needed. Transportation must be either by provincially licensed ambulance or other means of transportation in accordance with regulations. Injured persons or those experiencing trauma must be accompanied and not driving themselves to initial first aid.

Rescue

Rescue will be done by trained personnel only or as specified in Safe Job Procedures. High risk jobs such as Working at Heights or Confined Spaces must have rescue procedures identified prior to starting work in the appropriate procedure.

Emergency rescue methods available on site will be confirmed at the beginning of any new project. Additional methods may be procured when required, such as confined space rescue equipment or similar.

Emergency Procedures Drills

Drills are used at least annually to test the effectiveness of the plan, and a review of all emergency drills will be conducted to ensure improvements to the emergency response procedures are performed, and documented.

Any type of emergency procedure drill must be coordinated with the applicable authorities and agencies to ensure we do not cause a panic. Drills should also consider current site activities and operations.

Reporting & Investigation

After any of the occurrence of any of the above scenarios, ensure proper reporting and investigation as per Regulations and the Section 10 of this OH&S program.

Visitors Emergency Procedures

In the event of an emergency occurring while visitor(s) are on site, it is the responsibility of the visitors to obey the accompanying guide and react calmly to given instructions without haste.

Possible Emergency Scenarios

The following section proposes a list of possible emergencies that could happen within our scope of work, and procedures to follow. Superintendent, with the participation of the safety coordinator as needed, will review these procedures at the beginning of each project and Office Manager reviews when someone new is hired and returns from a long absence.

Some of these scenarios will require notification to WorkSafeBC, and Investigation. Refer to Element 10 of this OHS Program for reporting requirements.

  1. Fire
    • If you're the first to see the fire, raise the alarm by using the air horn as directed above
    • Do not attempt to fight the fire unless you know how to use an extinguisher
    • Always position your body between the fire and the nearest exit, do not allow fire to corner you
    • Follow P.A.S.S.; Pull the pin, Aim at base of fire, Squeeze the trigger, Sweep from side to side.
    • If can't fight fire or can't see fire, proceed to the muster point via the nearest exit
    • Confirm co-workers are accounted for (workers for our company, employed or sub-contracted)
    • Report to your direct supervisor and notify Site Safety Coordinator
  2. Structure Collapse
    • The collapse of a structure is possible and can include the collapse of form or false work or temporary structure. The scene of the collapse must be controlled to prevent any worker from entering. A structural failure will result in the general evacuation alarm being raised, and all workers will leave the site and report to the muster area.
    • A designated person or Supervisor will do a head count and report to the site superintendent/designated person, the status of their workers. If a worker is missing, supervisor(s)/designated person will notify the site superintendent/designated person who will coordinate rescue on site. Our management should also be notified.
    • The rescue team will assess the area of the collapse and determine if it is safe to attempt a rescue unless Emergency responders have arrived in which case, they will take over the scene. If the area is deemed safe, then a survey will be conducted to locate any trapped worker(s). Any shoring required to secure the area will be added as the rescue progresses. When available, Red danger tape will be placed on either side of the access/egress route to mark the limits where rescue workers can go safely.
  3. Vehicle or Equipment Collision (on site)
    • If there is a vehicle or equipment accident on site where rescue is required, the Site Superintendent and Site Safety Coordinator will secure the area.
    • All non-essential personnel will be asked to leave the area.
    • It is imperative that the safety of any immediate response personnel is assured prior to them approaching the incident scene. This means that any possibility of fire or explosion must be assessed and controlled before workers are permitted to enter.
    • Any first aid required will be administered by the first aid attendant. If there is an immediate danger to the injured worker's life or health, it is permissible to move them from the accident scene, otherwise the injured worker is not to be moved until the arrival of emergency services.
  4. Equipment Tip Over
    • Equipment tip over may not be life threatening in many cases, as long as safety devices such as seat belts are used. However, the risk of injury will vary significantly depending on the machine and work environment.
    • In all cases of equipment tip-over, priority should be given to rescuing the operator of the equipment and any injured person involved in the incident, if safe to do so. Secure the scene to prevent any further repercussions till deemed safe by a qualified person.
  5. Earthquakes
    • Earthquakes are shelter-in-place emergencies, but in your immediate vicinity. Staying inside and sheltering in place is safer than going outdoors.
    • Whenever an earthquake starts, stop what you are doing.

    If indoors:

    • Drop, Cover and Hold on: Drop on the ground; Cover your body under a table or similar; Hold on to the table to make sure you shake together
    • Do not go outside until it is safe to do so.
    • Avoid any doors, windows or any heavy fragile objects
    • If you are in an elevator during the earthquake, hit all the floor buttons, and get out as soon as you can.
    • After the earthquake: Stay calm; Help others if needed; Listen to the news over radio or TV for more info from authorities; Use caution with windows, doors or other heavy fragile objects till you confirm their stability; Disconnect any lights or electrical appliances that got damaged during the earthquake, from the electrical panel, light switch or unplugging.

    If outdoors:

    • If possible, move to an open area.
    • Do not stand under formwork, freshly poured concrete or any scaffold under construction.
    • Assume a safe position and keep low.
    • Stay away from stored materials, trees, mobile equipment, gas or chemical storage, motor vehicles, crew and office trailers or any other objects than can fall and crush you.
    • After the shaking has stopped, move to the emergency muster area and report in with your name and injuries. If you are hurt and unable to move, remain calm to conserve energy and call out for help.
    • Be prepared for aftershocks.

    After the earthquake has ended, the Superintendent, Office Manager or his designate will ensure:

    • Triage and first aid of injured workers has started.
    • A head count will be conducted listing the last known location of missing workers.
    • Rescue teams will be formed to assist the injured and to search for any missing workers.
    • If necessary, hazardous utilities gas/electricity will be located and shut off.
    • No worker is to leave the site without authorization by the Site Superintendent/Office Manager.

    Additional Considerations:

    • Do not leave for home. Power can be out, leaving traffic lights out also.
    • Traffic congestion can occur, people will panic and emergency vehicles may not be unable to respond to the injured on time.
    • Have a home plan in advance to give your family its best chance of safely surviving the earthquake.
    • Stay where you are needed until advised by emergency services. If you are not part of the solution, you are part of the problem.
    • In case of a major disaster, emergency shelter locations will be broadcast by Emergency Services Radio. At this time the local authorities will be advised on how to contact family members.
  6. Emergencies involving Power lines on Site

    We will take necessary action to ensure power lines in the immediate work area guarded, rerouted or de-energized prior to commencement of work as required in OHSR Part 19. Our superintendent will contact the owner of the power system, typically BC Hydro, to arrange a pre-planning meeting to analyze any potential risks.

    Maintaining a safe distance from all electrical conductors is the best way to prevent power line accidents. For safe limits of approach refer to OHSR 19.24.1. If for some unforeseen circumstance, contact with an energized conductor occurs, the following must be taken into consideration:

    • If you are in mobile equipment, remain inside the cab and do not panic; you are safe where you are. The operator should never leave the machine unless absolutely necessary.
    • Alert other personnel to what has happened and instruct them to keep their distance from any part of the machine and ground affected by the power lines. The machine and ground are currently energized.
    • Try to remove the contact by moving the equipment away from the line in the reverse direction to which contact was made. Caution: once an arc has been struck, it can draw out a considerable distance before it breaks. Keep moving away from the line until the arc breaks and then continue moving until you are at least 3 to 4.5 m (10 to 15 ft.) away from the line. Caution: If a crane rope appears to be welded to the power line, do not move away from the line as it may snap and whip. Stay where you are until help arrives.
    • If mobile equipment cannot be moved away or disengaged from the contact, remain inside the mobile equipment until the electrical authorities de-energize the circuit and confirm that conditions are safe.
    • Completely inspect equipment that has contacted a power line for possible damage caused by the electrical contact. Affected sections of wire rope should be replaced if it touched a line since the arc is usually of sufficient power to weld, melt or badly pit the rope.
    • Report every incident involving contact with a live line to your supervisor who will in turn notify the electrical utility so that inspections and repairs can be made to prevent damaged power lines from failing at a later date.
    • If it is necessary for the operator to leave mobile equipment while it is still in contact with the electrical conductor, s/he must jump clear. S/he must never step-down allowing part of her/his body to be in contact with the ground while any other part is touching the machine.
    • Because of the hazardous voltage differential in the ground, the operator should jump with his feet together, maintain balance and shuffle or hop slowly across the affected area. Do not take large steps because it is possible for one foot to be in a high voltage area and the other to be in a lower voltage area. The difference between the two can kill.
    • Contact 911 and the powerline owner (BC Hydro) to inform them of the situation and the contact location.
    • Call office or management immediately and tell them: a power line has been contacted above/below ground; what project site you are calling from; any injuries and their status; what actions have been taken on site so far.
  7. Health related emergencies
    • Before approaching the scene, stop and access if it is safe to do so. Do not put your life or other's life in danger.
    • Call for safety coordinator/first aid help.
    • Immediately secure the area. Site Superintendent/Safety Coordinator/Supervisor/Office Manager to confirm the area is properly secured.
    • All non-essential personnel will be asked to leave the area.
    • Any first aid required will be administered by the first aid attendant. If there is an immediate danger to the injured worker's life or health, it is permissible to move them from the accident scene, otherwise the injured worker is not to be moved until the arrival of emergency services. – must follow OFA protocol
    • Do not disturb/quarantine the scene until the appropriate authority allows to do so.
  8. Terrorism/Shooting

    In the event of an attack or shooting, flee to safety immediately:

    • If there's a clear escape route, run to safety. Turn off anything that makes noise and call 911 as soon as it's safe. First responders are trained to help. As soon as you're able to, call emergency services and give the dispatcher the following information: a description of the shooter or shooters, what weapons they're using, where the shooter was last seen, and some details about the victims, if known.
    • Use available exits and escape routes and use all forms of cover during escape (e.g. concrete walls and pillars, iron doors, curtains, shrubs, etc.).
    • If the exit is blocked or inaccessible, hide. Find a place away from the shooter's view. If you can get into a room, lock the door and block the door with large furniture. If you can't find a locking room, choose large furniture or fixtures to hide behind or under.
    • Avoid open spaces and look for objects you can hide behind.
    • Encourage or help others to escape (especially children, the elderly, the disabled, pregnant women ...).
    • Leave your personal belongings behind and save yourself.
    • In the safe area, re-acquaint yourself with the place and its surroundings (e.g. exits, etc.).
    • Prevent others from accessing the event area.
    • Observe suspicious people in your vicinity.

    Hide:

    • If you can't reach an exit route, hide. Close the blinds and lock and barricade the door. Stay quiet and out of view until first responders arrive.
    • Silence all devices, shut any blinds, and turn off the lights. Stay out of view. Call emergency services if possible and remain quiet until the first responders arrive.
    • Turn off any devices that make noise, and head to a safe location away from the area. Call 911 as soon as it is safe to do so.
    • On your mobile phone, mute the sound and turn off the vibration.
    • Try to remain calm and have a calming influence on others (calm their crying and shouting, it may attract the attention of the attackers).
    • Check all possible additional exits, windows, emergency routes, vents.
    • If your hiding place is safe, stay until the police enable you to find a safe way out.

    If circumstances indicate that you cannot escape or hide, fight back:

    • If you can't run or hide, fight as a last resort if it's the only way to save your life.
    • Commit to the actions and act as aggressively as possible. Yell, shout, or throw things.
    • Improvise weapons from what's on hand.
    • If possible, coordinate an attack with others.
    • Remember, this is to save your life and you may have to hurt the shooter to escape.

    When emergency services arrive:

    • It's a crime scene. The officers don't know who the shooter is and will treat everyone with suspicion. Put your hands up with fingers spread and keep them visible to quickly show the officers you are safe.
    • Follow instructions. Officers will tell you what to do to stay safe. Following their direction lets them stay focused on their priority: stopping the attacker.
    • Stay calm. Quick movements, shouting, or grabbing the officers for safety will distract them from their goal. Remain quiet.
CANWIDE STEEL
OHS PROGRAM
Element 12
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
E12Created: Apr/2026Last rev: ---Rev. 1.11 of 1
ELEMENT 12 - RECORDS AND STATISTICS
Policy Statement

Our company will record and gather information about how it operates at the workplace. The information gathered will be used to track trends, compare with the industry standard and increase safe behaviors. Information recording and gathering, will assist us in achieving our goal of eliminating hazards before they become an issue to the well being of the workers.

Records and Statistics

Records and statistics pertinent to occupational health and safety at the workplace shall be compiled and retained on-site by us for the duration of the project. These records and statistics shall be used to identify and monitor problem areas, review the effectiveness of the Occupational Health and Safety program and provide important information for management and supervisors in order to assist them in providing a safe workplace.

Documentation and records shall be kept in an orderly fashion, which will provide quick and easy access to workers and a Regulatory Officer upon request and for potential audit requirements.

The documents that will be kept on file, where applicable, include but are not limited to:

Information provided in each of these records must comply with required applicable regulations.

Statistics

Each month the Management will fill out the Monthly Injury Report. The injury statistics are used to help identify injury trends based on a variety of different factors such as scope of work, type of injury, worker's experience, among others. Statics can also be compared year to year to assess the overall performance of the company.

Records

Records must be kept for the duration of the project and 2 years after. Some documents may be required to be kept longer as per OHS Regulations.

CANWIDE STEEL
OHS PROGRAM
Element 13
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
E13Created: Apr/2026Last rev: ---Rev. 0.11 of 2
ELEMENT 13 - LEGISLATION
Policy Statement

It is mandatory that all personnel, workers and management abide by the Company OH&S Program and any other applicable Regulation including but not limited to site safety rules, federal, provincial and city bylaws. A copy of the Workers' Compensation Act and Occupational Health and Safety Regulations are available to all workers in our site trailer, lunch room, or elsewhere on site as applicable. Along with the above, a copy of this OH&S Program is also to be readily available on site to all workers. During orientation, workers will be advised as to where such documents are kept.

Worker's Rights

All workers must be informed of their rights at orientation which occurs prior to the start of work or when a job process changes. Supervisors are encouraged to continuously remind workers of their rights during Toolbox Meetings.

All workers have the right to a safe and healthy work environment, along with:

Refusal of Unsafe Work
  1. A worker who refuses to carry out an assigned task must immediately report the circumstances of the unsafe condition to their supervisor or employer.
  2. A Supervisor or employer receiving a report must immediately investigate the matter and ensure that any unsafe condition is remedied without delay; or, if in their opinion the report is not valid, inform the person who made the report.
  3. If the worker continues to refuse to carry out the work process or operate the tool, appliance or equipment, the Supervisor or employer must investigate the matter in the presence of the worker who made the report and in the presence of a worker member of the JOH&S Committee. A worker who is selected by a trade union representing the worker; or, if there is no JOH&S Committee or the worker is not represented by a trade union, any other reasonably available worker selected by the worker.
  4. If the investigation under section (2) does not resolve the matter and the worker continues to refuse to carry out the work process or operate the tool, appliance or equipment, both the Supervisor, or the employer, and the worker must immediately notify the regulatory body who must investigate the matter and issue whatever orders are deemed necessary.
  5. If worker refuses work, the employer must not require or permit another worker to do the refused work unless:
    • the matter has been resolved under above section (2), (3) and (4) or
    • the employer has, in writing, advised the other worker and a person referred to in section (3) above of all of the following: (i) the refusal; (ii) the unsafe condition reported to the Worker's Supervisor or Employer; (iii) the reasons why the work would not create an undue hazard to the health and safety of the other worker or any other person; (iv) the right of the other worker under "Refusal of Unsafe Work" to refuse unsafe work.

Workers reporting any potential unsafe or hazardous working conditions to the supervisor or employer must not be subject to disciplinary action.

Worker Responsibilities
Supervisor Responsibilities
Employer Responsibilities
CANWIDE STEEL
OHS PROGRAM
Element 14
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
E14Created: Apr/2026Last rev: ---Rev. 1.21 of 3
ELEMENT 14 – JOINT OCCUPATIONAL HEALTH AND SAFETY (JOHS) COMMITTEE
Policy Statement

Any workplace that has twenty (20) or more regular employees must have a Joint Occupational Health and Safety Committee. The committee is an advisory group that will meet at least monthly to monitor and work towards improving the health and safety performance in all our operations. The committee will consist of both employer and worker representatives, who will work in a co-operative manner to identify hazards, support safe work practices and promote safety awareness.

Responsibilities

The Health and Safety Committee's responsibility is to:

  1. Identify hazardous situations and recommend safe work practices to the employer.
  2. Provide workers with guidance in protecting their health and safety.
  3. Deal with complaints relating to health and safety of workers.
  4. Consult with employer and workers on issues related to health and safety.
  5. Advise the employer on programs and policies required in the regulations and to monitor their implementation and effectiveness, and review these programs regularly, typically annually, as required by regulation.
  6. Advise the employer on proposed changes in the workplace, including significant proposed changes to equipment and machinery, or to the work processes that may affect the health and safety of workers.
  7. Participate in inspections, investigations and inquiries as per the OHS Regulations, in addition to their corrective actions and follow up.
  8. Advise the employer on proposed changes to the workplace and work processes to improve Psychological Health and Safety in the workplace, and to promote further involvement of supervisors and employees in Psychological Health and Safety matters.
  9. Carry out any additional requirements as per the OHS Regulations.
Guidelines for Operation
Agenda

The Health and Safety Committee meeting should be standardized in an order such as the following:

  1. Roll call
  2. Revision and adoption of previous meeting minutes, and discussion of old business.
  3. Discussion of worker complaints and suggestions.
  4. Review of recent incidents, investigations and corrective actions.
  5. Reports on special assignments.
  6. Reports on inspections, with recommendations.
  7. Discussion of new business.
  8. Adjournment.
Minutes

Minutes will be prepared immediately after the meeting and will be distributed to all members and substitutes. Any additions or corrections to the report must be received in writing within 5 working days after the date of issue or they shall stand as written. Minutes from the 3 most recent meetings will be posted where workers may read them. Copies of all reports will be retained for at least 2 years from the meeting date.

Training of JOHS Committee

Each member of the committee will receive, as soon as practicable but no more than 6 months after becoming a member, a total of at least:

The instruction and training must include the following topics:

Training isn't required for employer/worker representatives if:

Training records must be available to the members as soon as training is received, and must be kept for at least 2 years after the person ceases to be a member or a representative.

Training of JOHS Committee members is mandatory and is required by WSBC.

Sub-Program/Programs Evaluation by the JOHS Committee

In collaboration with the employer, the JOHS Committee will be required to review the effectiveness of WHMIS Program, Ergonomics (MSI), Chemical Agents and Biological Agents Exposure Control Plan, Personal Protective Equipment programs, and any other program/procedure required by WorkSafeBC Regulation.

The review should be documented through JOHS Committee Minutes of Meeting.

Evaluation of JOHS Committee

A written evaluation of the JOHS Committee must be conducted annually by either:

This evaluation must contain:

If the employer (or the person assigned) conducts the evaluation, they must, as part of the evaluation, obtain and consider the input of the committee's co-chairs (or the designated members), with regards to the items above. The employer and the joint committee must provide each other a copy of the evaluation if the other does not have a copy. The committee must discuss the evaluation at the first meeting immediately following the evaluation is completed/received, and the meeting minutes must show such discussion.

CANWIDE STEEL
OHS PROGRAM
Appendix A
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
APPX ACreated: Apr/2026Last rev: ---Rev. 1.01 of 2
APPENDIX A – BULLYING & HARASSMENT POLICY
Policy Statement

We are committed to providing a work environment that is supportive of the dignity and self-esteem of all employees. Any instance of Bullying or Harassment in the workplace violates this commitment, is oppressive, unacceptable, will not be tolerated, and may be cause for dismissal.

Prohibited grounds of discrimination identified by the Human Rights Act/Code are race, color, ancestry, place of origin, political belief, religion, marital status, family status, physical or mental disability, gender, sexual orientation, gender identity or expression, or age.

Any instance of bullying or harassment must be reported to senior management as soon as possible, whether directly or through a supervisor. The Safety Coordinator/Manager is also another person who can be informed. Once reported, the incident will be investigated, and the matter corrective actions taken.

Bullying and harassment:

Examples of conduct or comments that might constitute bullying and harassment include verbal aggression or insults, calling someone derogatory names, harmful hazing, or initiation practices, vandalizing personal belongings, and spreading malicious rumors.

Workers are expected and required to:

This policy applies to all workers, including permanent, temporary, casual, contract, and student workers. It applies to all forms of communication, including interpersonal and electronic formats, such as email.

Employer Responsibilities
Supervisor Responsibilities

Senior Management: Manwinder Singh     Date: 2026-04-15 Manwinder Singh Signature

THIS POLICY MUST BE POSTED AT THE WORKPLACE AND
IT IS NOT INTENDED TO DISCOURAGE A WORKER FROM EXERCISING RIGHTS PURSUANT TO ANY OTHER LAW
Investigation Process

Our company will investigate most reports on Bullying and Harassment internally. In complex or sensitive situations, an external investigator might be hired.

Investigations will be:

Investigations will include Interviews with the alleged target, the alleged bully and any witness. If these interviews result in the alleged target and alleged bully agreeing on what happened, then our company will not investigate any further. We will determine the corrective action, if any, is to be taken.

The investigator will also review any evidence, such as emails, handwritten notes, photographs, videos, social media posts or physical evidence like vandalized objects.

Investigations will be conducted by our Safety Coordinator/Safety Manager or a Senior level supervisor who is impartial to the incident. All investigation reports complete with conclusions will be forwarded to the top management level of our company. If an external investigator is hired the investigation report with conclusions will be received by the Safety Coordinator/Safety Manager and the top management level of our company.

Follow-up

Once the final investigation is complete the related parties will be advised of the findings by the Safety Coordinator/Safety Manager or a Senior level supervisor.

The Safety Coordinator/Safety Manager or a Senior level supervisor will review and update workplace procedures to prevent any future incidents in our workplace. Corrective actions will be taken as soon as reasonably possible and documented as complete on the investigation form.

If appropriate, workers may be referred, or encouraged, to seek employee assistance or other professional medical services.

Record Keeping

Our company expects that workers will keep written accounts of incidents to submit with any complaints. We will keep written records of investigations, findings and corrective actions.

Annual Review

Our company will review our procedures on an annual basis at same time as our OH&S Program review. All workers will be provided with the information and copies will be kept in our OH&S Program, forms and procedures.

CANWIDE STEEL
OHS PROGRAM
Appendix B
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
APPX BCreated: Apr/2026Last rev: ---Rev. 1.11 of 3
APPENDIX B – WORKPLACE VIOLENCE POLICY
Policy Statement

Our company is committed to providing a safe and respectful work environment for all employees, clients, and visitors. We do not tolerate any form of violence. Any employee who engages in such behavior will be subject to disciplinary action, up to and including termination of employment. Any client or visitor who engages in such behavior will be asked to leave the premises and may be reported to the authorities. We encourage everyone to report any incidents of violence or potential violence to their supervisor or the human resources department as soon as possible. We will investigate all reports promptly and confidentially and take appropriate measures to prevent recurrence. We also provide support and assistance to employees who are victims of violence or witness violence in the workplace. We value the safety and well-being of our staff and stakeholders, and we strive to foster a culture of respect and cooperation.

Definitions

"violence" means the attempted or actual exercise by a person, other than a worker, of any physical force so as to cause injury to a worker and includes any threatening statement or behavior which gives a worker reasonable cause to believe that the worker is at risk of injury.

Workplace violence is:

Supervisor/Managers Responsibilities
Employees Responsibilities

Senior Management: Manwinder Singh     Date: 2026-04-15 Manwinder Singh Signature

THIS POLICY MUST BE POSTED AT THE WORKPLACE
Employer Responsibilities
Joint Occupational Health and Safety (JOH&S) Committee
Reporting and Investigation
Response Procedures
Support for employees affected by workplace violence

Management will respond promptly, assess the situation and ensure that these interventions are followed:

Risk Assessment

Management (with worker involvement) assesses workplace violence hazards in all jobs, and in the workplace as a whole. It reviews risk assessments annually, as well as when new jobs are created, or job descriptions are changed substantially.

Education

New employees will receive both general and site-specific orientation to the workplace violence and harassment prevention program. In addition, all employees will receive an annual review of the program's general and site-specific components.

Any training developed, established and provided will be done in consultation with, and in consideration of, the recommendations of the JOH&S Committee.

Program Evaluation

The effectiveness of the workplace violence and harassment prevention program is evaluated annually by management and reviewed by the JOH&S Committee.

Workers, managers and supervisors are accountable for establishing and implementing the policy and procedures related to workplace violence. Responsibility for complying with the health and safety policy is part of a manager's, supervisor's and worker's job description. Included in the health and safety components of job descriptions are management responsibilities for enforcing policy and procedures, investigating, and responding to workplace violence.

Accountability

All workplace parties are accountable for complying with the policy, program, measures and procedures related to workplace violence.

Records

All records of reports and investigations of workplace violence are kept for five years.

Policy Review

This workplace violence prevention policy and program will be reviewed annually.

CANWIDE STEEL
OHS PROGRAM
Appendix C
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
APPX CCreated: Apr/2026Last rev: ---Rev. --1 of 1
APPENDIX C – RETURN-TO-WORK AND INJURY MANAGEMENT POLICY
Policy Statement

The goal of the Return-to-Work Program (RTW) is an early return to suitable and available employment that is within the worker's functional abilities and, if possible, restores the worker's pre-injury earnings. An injured worker can transition back into the workplace earlier and more safely when the employer takes immediate steps to accommodate the worker's injury.

Injury Management programs serve as a part of an injured worker's therapy and recovery by helping them stay at work, and/or return to productive and appropriate work as soon as possible. Injury Management programs are based on a philosophy that many injured workers can safely perform productive work during their recovery.

Benefits to workers
  1. Helps injured workers recover faster
  2. Reduces financial uncertainty for the worker and their family
  3. Reduces the concerns of employment security
  4. Maintains necessary job skills
  5. Maintains a sense of attachment with co-workers
  6. Reduces the risk of negative long-term health effects
Benefits for employer
  1. Demonstrates to all workers they are valued employees
  2. Returns injured workers to work in a safe and timely manner
  3. Maintains worker/employer relationships
  4. Reduces the cost of claims, which can help employers be more competitive
  5. Helps retain healthy and qualified workers
  6. Reduces the cost of training replacement workers
  7. Includes the employer in the recovery process for their injured worker

The information in this policy does not take precedence over applicable government legislation, with which all employees should be familiar.

Senior Management: Manwinder Singh     Date: 2026-04-15 Manwinder Singh Signature

THIS POLICY MUST BE POSTED AT THE WORKPLACE
CANWIDE STEEL
OHS PROGRAM
Appendix D
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
APPX DCreated: Apr/2025Last rev: ---Rev. 1.01 of 3
APPENDIX D – DROPPED OBJECT PREVENTION PROGRAM
Policy Statement

We recognize the hazard imposed by objects that might drop from heights at our construction sites. Tools, equipment, and material that may be dropped when working at heights, and when close to leading edges, can pose a significant risk to workers on lower levels, and to the public below.

The purpose of this program is to minimize and prevent objects and materials from dropping to lower levels or taking uncontrolled flight potentially causing injuries to the public and workers on or close to the site.

Scope

This procedure applies to all scopes of work at heights or in areas where the flight of materials may cause hazards. All tools and materials that could potentially be drop/flight hazards must be secured or otherwise controlled.

Considerations

Climate conditions can change the ability for a person's hand to grip a tool or material. Wet, cold, and even hot weather can change the grip ability and should be considered during hazard assessments.

Preparation
Prevention System
  1. Elimination

    Elimination is achieved by performing work activities in the Safe Zone wherever practical. The Safe Zone is an area 6.5 ft away (or more depending on weather) from all leading edges and floor openings on flat surfaces. The Safe Zone will be increased for sloped surfaces.

    Example – Frame/construct the form for curbs in the Safe Zone to reduce the amount of work done close to the leading edge. Do any assembly possible in the Safe Zone.

    Another form of Elimination is to leave the tools/material that are not needed for the task at hand in a safe area. Safe area could be on the same level or in a nearby location at least 6.5 ft away from edges.

    Example – leave your pliers, spray paint in the Safe Zone when you are doing work on the leading edge. Only keep on you the tools you will need for the specific task/job when entering the controlled area.

  2. Flight/Drop Prevention

    The Flight/Drop Prevention is used anytime a tool or material has to be used within 6.5 ft of a leading edge (or more depending on weather) or a floor opening that could have the object fall through it.

    • Flight prevention is the act of tying/securing materials to eliminate the possibility of them flying during wind gusts. (e.g. banding plywood sheets together)
      Materials that have a surface area/weight ratio that may allow "lift" during a wind gust must be secured if stored/used on an elevated surface or any area that flight could become a hazard.
      Securing methods must be sufficient to stop the material from lifting during high winds.
      Examples:
      • Placing rebar or heavy objects over/in bulk bags.
      • Leaving plywood bundled/banded until needed.
      • Nailing down plywood sheets.
      • Placing insulation, plastic, and tape in garbage bags and storing them in areas protected from wind.
    • Drop prevention is the act of securing tools, material to suitable anchors to stop them from falling to a lower surface. (e.g. tethering your hammer)
      All material that could roll/fall or be kicked must be secured, or stored to eliminate the hazard. Prevention measures include storing items in a way that eliminates the possibility of falling to the ground or lower levels.
      Examples:
      • End cuts of pipes are stored in burlap sacks away from edge.
      • Plastic "cans" are immediately placed in garbage receptacles and stored in safe area.
      • Pop cans are stomped on and placed in garbage receptacles immediately after consumption.
      • Stored objects/material that can roll (such as pipes) to be placed perpendicular to the edge and/or tethered.
    • Secondary Drop Prevention System
      The Secondary Drop Prevention System is an additional system used in conjunction with the systems listed above. It is used to prevent objects (example: loose debris and materials) from falling below. The system consists of mesh or solid guardrails either prefabricated or built on site.
      • Guard Rails with plywood for the active working deck.
      • Guard Rails with mesh for all levels below active working deck.
      Note: Guard Rails to be installed approximately 6.5ft from the edge and made of correct material.
      • Good housekeeping practices are vital to preventing loose materials and debris from falling. All loose materials and debris must be removed from the perimeter edge by sweeping it towards the core of the building prior to installing guardrails, toe boards or control zones. All trades are responsible for cleaning up their own debris immediately.
  3. Tool/Material Tethering/Arrest Systems – When elimination and prevention systems are not practicable or 100% effective, tool/material tethering systems are to be used. Management may require tool/material tethering at any time.
    1. Tool Connection Point
      • Clamps and heat shrink/webbing with D-ring attachment – to be attached to the tool or object using a system available from a manufacturer that has instructions on how to attach and the weight rating. This manufacturer's identified weight rating must be greater than the tool weight.
      • Anchor point for tool to be strong enough to arrest the drop of the tool that it is secured to it. Note – large tools (mag drills, coring drills etc.) require being secured to building anchorage points, and not to the person.
      • DO NOT secure any tool material to a guardrail or re-shore posts.
    2. Tool Tether (lanyard)
      • Tether/lanyard to be tagged with a maximum tool weight that exceeds the weight of the tool it is to be tethered to.
    3. Material Securement
      • Suitable rope, with a manufacturer breaking strength or working load rating, or approved tool lanyards for tethering equipment and materials.
      • Rope with a minimum breaking strength of 5 x object weight or working load limit of minimum 2 x objects weight. Such items include, but not limited to, re-shores, work bench, ladders, vacuums, concrete finisher hand equipment etc.
      • Secure one end of rope to the equipment or material and secure the other end to a suitable anchor point or permanent structure. Minimize excessive slack.
  4. Control Zones – used in addition to prevention systems when required

    When performing critical tasks/activities that move materials/workers into an area that cannot have a secondary system, a control zone must be used to control the area below the work/material.

    1. Control zones are used to prevent unauthorized access where falling objects can cause injuries to the public and workers on site. Red danger tape and signs must be used to identify the controlled zone.
    2. Spotter(s) are used to monitor critical task activities from below and to prevent traffic, the public and workers from coming into control zone area. Such activities include, but not limited to, stripping and flying tables.
    3. Control Zones cannot be set up if they stop access to the site. If a control zone is required over an access point, coordination with Site Safety Coordinator is required.
    4. Control Zones are owned by the person/crew who set them up. Ownership needs to be displayed on the zone in a high-profile location that states:
      • Name and Phone # of who set up control zone
      • Company that is working above
      • Date Control zone was set up
      • Task control zone was set up for
    5. Control Zone must be removed once task is complete
  5. Maintenance, Cleaning and Storage of Prevention Systems
    1. After each use of the Drop Prevention Systems, remove all dirt, corrosives and other contaminants with plain water or mild soap and water.
    2. If the Drop Prevention Systems cannot be cleaned, then rinse and wipe dry or allow to airdry. Store in a dry environment, away from excessive heat and light.
    3. If the Drop Prevention System has stopped a falling tool, remove from service immediately and do not use until a documented inspection, following manufacturers instructions, has been performed.
CANWIDE STEEL
OHS PROGRAM
Appendix E
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
APPX ECreated: Apr/2025Last rev: ---Rev. 1.11 of 5
APPENDIX E – ELECTRICAL SAFETY PROGRAM
Policy Statement

When work is being done close to energized electrical equipment, workers must be informed of the potential hazards, and instructed on how to control the risks associated with such hazards.

Before we start working in any project, we will:

  1. Identify the location of all surrounding power lines, and distances to the project and work activities.
  2. Determine the line voltage. If uncertain, contact the company controlling the system. In the lower mainland this is typically BC Hydro, with the exception of New Westminster.

Do not use objects to physically measure the distance from the work area to the energized power line. The distance must be estimated from the ground or elevated work location. If in doubt, contact the power authority.

Workers must be instructed in:

  1. The existence, location and voltage of the high voltage electrical equipment and conductors.
  2. The work arrangements and procedures to be followed to ensure compliance with the applicable regulations.
Passageways and Working Areas

All passageways, platforms or working areas around electrical equipment must:

In addition:

Minimum Safe Approach Distances

If our employees work in the proximity of the High Voltage powerlines:

  1. The voltage of any energized electrical equipment or conductor must be determined and the Minimum Approach Distance identified.
  2. The Minimum Approach Distances must be maintained between exposed, energized high voltage electrical equipment and conductors, and any worker, work, tool, machine, or material.
Minimum Approach Distances To High Voltage Conductors
Voltage (Phase To Phase)MetersFeet
Over 750 V to 75 kV310
Over 75 kV to 250 kV4.515
Over 250 kV to 550 kV620
If Minimum Approach Distances cannot be maintained

If the above Minimum Approach Distances from the energized lines cannot be achieved and maintained, contact the owner of the power system and arrange for a worksite meeting to decide if the conductors will be:

*** The hazards must be controlled before work commences ***

Depending on the work activities, multiple controls may be required, i.e. option 3 for the crane and option 4 for the other mobile equipment. The above controls will be decided and implemented by the power system owner, and our company will obtain assurance in writing indicating the type of control and expiry date.

This assurance will be obtained using WSBC Form 30M33, which is available from the power system owner or WSBC. A copy of the completed form must be posted at the work site and the workers instructed of the action taken.

Under no circumstances will work be performed within the Minimum Approach Distance without one of the above controls implemented, and the completed, approved form 30M33 is obtained.

A qualified Spotter is assigned to monitor equipment and material movement in close proximity to the power lines. The Spotter will give a "STOP" signal if the equipment or material gets too close to the conductor.

Adjusted Limit of Approach

When work activities must be inside the Minimum Approach Distance, work must not proceed without the consultation of a Safety Manager, Superintendent, WSBC and the power owner representative who issued the 30M33. Upon agreement, work may proceed and may require a Qualified Safety Watcher, as specified by the power owner.

A worker who has taken a course of instruction approved by the Board may work up to the adjusted limits of approach outlined below only when all the following conditions apply:

  1. The high voltage electrical is energized to a potential of not more than 75kV.
  2. The board has determined that rerouting, de-energizing or guarding of the equipment is not practical for the type of work being performed.
  3. The work is not being done for the owner of the power system.
  4. The work is of a type that must be done regularly.
  5. The worker follows written safe work procedures acceptable to the Board.
Adjusted Limits of Approach
Voltage (Phase to Phase)MetersFeet
Over 750 V to 20 kV0.93
Over 20 kV to 30 kV1.24
Over 30 kV to 75 kV1.55
Low Voltage (750 Volts or Less)

Contact with a low voltage electrical line or electrical source can result in serious injuries and/or death.

The severity is determined by three major factors:

  1. The amount of current
  2. The path of the current through the body
  3. The length of time the body is exposed to the current.

Effects can range from being barely noticeable to immediately fatal. Low voltage does not mean LOW Hazard. The amount of electricity used by one 7.5-watt Christmas tree bulb can be lethal if it passes through the chest. Even if the electric shock is not fatal, it can cause serious falls, or burns, or damage to internal organs.

The Trolley Overhead Power System carries 600V direct current. Although the power is considered "low voltage", 600V lines are sufficient to cause serious injuries or death. The Power Distribution System is over city streets, sidewalks and in close proximity to roadway structures in the City of Vancouver and in some areas of Burnaby. The Minimum Approach Distance is 10ft (3m). When this distance cannot be maintained, Management will contact Coast Mountain Bus Company who will determine the safest option.

Range of Body Tolerance
Electric Current in MilliampsEffect on Body
1 – 10Can just feel it
20 – 40Increasingly painful to the point of not being able to let go.
50 – 80Severe pain and muscular contractions, possible respiratory arrest.
90 – 100Increasing probability of the heart stopping, causing death.
Electric Tools
  1. Inspect tools, power cords and electrical fittings for damage before each use. Repair or replace damaged equipment.
  2. Disconnect the power supply before making adjustments.
  3. Make sure the tools are properly grounded or the double insulated type. The grounded tools must have a three-prong plug. The tool must be plugged into a properly grounded three-pole outlet.
  4. Do not break off the ground prong of the plug.
  5. Do not bypass the switch and operate the tools by connecting and disconnecting the power cord.
  6. Protect electric cords from vehicular traffic. Place the cord between planks.
  7. Keep power cords clear of tools during use.
  8. Suspend power cords over walkways or working area to minimize tripping hazards.
  9. Use power cords with sealed plugs reduce the danger of electric shock.
  10. Do not clean the tools with flammable solvents.
  11. Do not operate any electrical tools in an area containing explosive vapor and gases.
  12. Use a heavy-duty cord.
  13. Do not carry, lift or pull electrical tools by the cord.
  14. Do not tie knots in power cords. Loop the cords or use a twist lock plug. Knots can break the wire causing short circuits and electrical shocks.
  15. When unplugging the power supply, disconnect using the plug, pull from the end not the cord.
  16. Do not use the tools in wet areas or in wet weather without using a ground fault circuit interrupter.
GFCI and Assured Grounding Program

A GFCI is a device that detects current leakage in an electrical circuit and trips (turns off) the circuit whenever the leakage is greater than 5mA. WorkSafeBC Regulation 19.15(1) has set out the following guidelines regarding Electrical Safety and the use of GFCI's and/or Assured Grounding.

When used outdoors or in a wet or damp location, portable electrical equipment, including temporary lighting, must be protected by a ground fault circuit interrupter of the class A type installed at the receptacle or on the circuit at the panel, unless another acceptable means of protection is provided. Portable equipment will include, but not be limited to extension cords and power tools that are used on 120-volt systems at 20 amps or less and are not hard-wired to a permanent electrical system.

Three types of GFCI's may be used at our worksites depending upon circumstances surrounding the need:

  1. GFCI Receptacle – This type of receptacle may be used in place of a standard receptacle.
  2. Portable GFCI – This system allows a person to use a standard receptacle while converting that standard receptacle into a GFCI receptacle.
  3. A GFCI Circuit Breaker – This device combines leakage current detection with the function of a circuit breaker.
Preventing Nuisance Tripping
  1. GFCI receptacles and circuit breakers should be mounted in dry locations.
  2. Rainproof rated GFCI's should be use if unable to protect from wet or damp conditions.
  3. A GFCI shall only have one (1) power tool connected to it at any time.
  4. When power tools are not in use, they should be protected (covered) from damp or wet elements.
  5. Store power tools and extension cords in dry locations.
  6. Power tools and extension cords shall be maintained in good condition.
  7. Extension cord shall be free of various "taped" repairs throughout the length of the cord. Cords with frequent repair places will be taken out of service immediately.
  8. Extension cords that are rated for heavy-duty use shall only be used. No light or household cords shall be used at the workplace for any tools.
  9. Extension cords shall not exceed 150 feet (45 meters) in length.
Assured Grounding Program

NOTE – In the circumstance where special permission is required for the use of an AGP in lieu of GFCIs on construction and demolition sites, the permission is obtained from the electrical authority having jurisdiction.

As an alternative to GFCI's, assured grounding may be used at our worksites in accordance with Section 19.15(1) of the Regulation. The purpose of this program will be to ensure that all applicable wires, black (hot), white (neutral) and, in particular, green (ground) of extension cords and power tool cords are properly connected.

This will be done by testing every extension cord and power tool when it is first put into service, following repairs, and every three (3) months.

Training

All workers using extension cords for power tools are trained in the requirements of this Assured Grounding Program.

Inspections

Those using them no less than daily must visually inspect extension cords and power tools for damage. Damage must be corrected immediately before use. Cords must not be spliced on power tools or extension cords. Cords must either be replaced or shortened to remove the damaged area.

Continuity and Polarity Testing

A qualified worker must test every extension cord and power tool for circuit continuity and correct polarity before use when new, following repairs, and during the months of January, April, July and October.

Color Coding

Extension cords and power tools that have been inspected shall be tagged with a colored band (tape) about four (4) inches from the male plug. A different color shall be required for each quarter of the year. These colors will be standard on all worksites using the assured grounding program. Color codes shall be as follows:

RedJanuary, February, March
WhiteApril, May, Apre
BlueJuly, August, September
GreenOctober, November, December
CANWIDE STEEL
OHS PROGRAM
Appendix F
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
APPX FCreated: Apr/2025Last rev: ---Rev. 1.11 of 6
APPENDIX F – FALL PROTECTION PROGRAM
Policy Statement

We recognize that Fall Protection plays an important part of our operation. This Fall Protection Program identifies means of controlling fall risk and is prepared in accordance with WSBC Regulation Part 11 Fall Protection. The regulation will prevail over this program if any discrepancies are to occur.

Our company requires fall protection when work is located where a fall of 3m (10 ft) or more may occur or where a fall from height of less than 3m (10 ft) involves a risk of injury due to hazards below.

Responsibilities

Management is responsible for:

  1. Provide resources (equipment, training, PPE, etc.) required to implement this program.
  2. Ensure appropriate anchor points are identified or installed.
  3. Ensure that workers are instructed and trained in the identification and control of fall hazards.
  4. Ensure that written fall protection plans are readily available at the work site before work begins as required by regulation.
  5. Ensure the fall protection plans and controls consider the specific scope of work at the site.

Supervisors are responsible for:

  1. Ensuring employees and sub-contractors comply with fall protection instructions.
  2. Identifying workplace fall hazards and preparing site-specific fall protection plans for the scope of work.
  3. Holding pre-job planning meetings to discuss the fall protection required.
  4. Providing procedures for jobs involving work at height.
  5. Ensuring fall protection training is current.
  6. Ensuring fall protection equipment is available at the workplace.

Workers are responsible for:

  1. Use site-specific job fall protection plans and any procedure provided when working at height.
  2. Understand the requirements and use of Fall Protection Systems and the Hierarchy of controls.
  3. Use equipment supplied or approved by the employer.
  4. Not exposing themselves to fall hazards without proper training and controls.
  5. Not removing any fall protection systems and leaving the hazard uncontrolled.

Sub-Contractors are responsible for:

  1. Creating site-specific job fall protection plans and any procedure required when working at height.
  2. Understand the requirements and use of Fall Protection Systems and the Hierarchy of controls.
  3. Use equipment supplied or approved by their employer, the Prime Contractor and WorkSafeBC.
  4. Not exposing themselves to fall hazards without proper training and controls.
  5. Not removing any fall protection systems and leaving the hazard uncontrolled.
Fall Protection Plan

Prior to the start of any job/task, a review of the fall protection needs for the specific job/task shall be undertaken. A site-specific Fall Protection Plan shall be developed and implemented, and ongoing training and review of the program shall take place as the project proceeds.

A Site-Specific Fall Protection Plan must be in place when workers may be exposed to a fall hazard of 7.5 meters (25 feet), or more, unless work is protected by permanent guardrails. Fall Protection Plans are also required when work procedures, such as control zones, that are acceptable to the Board, are being used to minimize the risk of injury to a worker from a fall.

The written fall protection plan must be signed by all workers involved in the task it covers and must be updated if conditions change or the scope of work changes and present different hazards and fall protection requirements.

The plan shall include the identification of fall hazards, decisions on types and methods of fall protection to be used, procedures for inspection, assembly and disassembly of equipment, rescue requirements, fall clearance as well as workers' sign off.

Equipment Standards

Equipment used for fall protection systems must:

  1. Consist of compatible and suitable components. Compatibility of fall protection systems and connections must be part of Fall Protection training selected for our workers.
  2. Be sufficient to support the fall restraint or arrest forces.
  3. Meet, and be used in accordance with, an applicable CSA or ANSI standard in effect when the equipment was manufactured, subject to any modification or upgrading considered necessary by the Board.

Only CSA or ANSI approved equipment will be used by our workers and sub-contractors, and only for their intended purpose, as per manufacturer's instructions.

Anchors
  1. Anchors used in a temporary fall restraint system must have an ultimate load capacity in any direction in which a load may be applied of at least: (a) 3.5 kN (800 lbs.), or (b) Four times the weight of the worker to be connected to the system.
  2. Each personal fall protection system that is connected to an anchor must be secured to an independent point of anchorage.
  3. Anchors used in a temporary fall arrest system must have an ultimate load capacity in any direction in which a load may be applied of at least: (a) 22 kN (5,000 lbs.), or (b) Two times the maximum arrest force.
  4. A permanent anchor for a personal fall protection system must have an ultimate load capacity in any direction required to resist a fall of at least 22 kN (5,000 lbs.).
Using Rebar as Anchorage
Rebar Size No.Shear Load – ASTM A615 Grade 60 Rebar
#54,740 lb
#66,730 lb
#79,180 lb
#812,085 lb
#915,300 lb
#1019,430 lb
#1123,865 lb
#1434,425 lb

The use of Rebar as anchorage is only allowed when it's the only practical solution available, and must only be used as a last resort. The above table provides shear loads for Grade 60 rebar, based on rebar size. This table is intended as a guideline only, for more accurate data please refer to the applicable ASTM standards, and the rebar manufacturer.

Do not attach a snaphook directly onto rebar, instead, use anchor straps (such as blue dyneema straps). Attach the strap at the bottom of the vertical rebar, i.e. where the rebar exits concrete.

Use only Rebar #6 or higher. Based on the chart, #6 rebar would provide the strength required however it is important to consider the anchorage as a complete unit including how rebar is placed in the concrete.

Temporary Horizontal Lifelines

A temporary horizontal lifeline system may be used if the system is:

  1. Manufactured for commercial distribution and installed and used in accordance with the written instructions from the manufacturer or authorized agent, and the instructions are readily available.
  2. Installed and used in accordance with written instructions certified by a professional engineer, and the instructions are readily available.
  3. Designed, installed and used in a manner acceptable to the Board, as set in Part 11 – Fall Protection guidelines; G11.7 Temporary horizontal lifelines.
Certification by Engineer

The following types of equipment and system, and their installation, must be certified by a professional engineer:

  1. Permanent anchors.
  2. Anchors with multiple attachment points.
  3. Permanent horizontal lifeline systems.
  4. Support structures for safety nets.
Clean Up and Storage

All fall protection equipment should be stored in a dry area to prevent deterioration of the equipment. Always inspect fall protection equipment thoroughly prior to placing in storage. Remove any damaged equipment from service and replace.

Inspection, Maintenance and Removal from service

Equipment used in a fall protection system must be:

  1. Inspected by user before use on each workshift,
  2. Inspected as required by the manufacturer's instructions or at minimum of every 3 months. Inspections done by a competent/qualified person are required, or factory inspections as in the case of Self Retracteable Lifelines.
  3. Kept free from substances and conditions that could contribute to its deterioration.
  4. Maintained in good working order.

Inspect components of the fall arrest system before each use for wear, damage and other deterioration. Defective components are removed from service when the components' function or strength has been adversely affected. Refer to manufacturer's instructions for inspection requirements, and criteria for removal from service.

Once a fall protection system has arrested the fall of a worker, or has failed inspection, it must be clearly tagged and removed from service and not be returned, unless it has been inspected and certified as safe for use by the manufacturer or a professional engineer. Defective equipment that is to be disposed of, will be made unusable prior to disposal. Method can be decided on a case-by-case basis.

Training

All employees required to work at height, regardless of height if there is an additional risk of injury at less than 10', shall be trained in the application of this policy and the safe use of fall protection systems. Training must include:

Supervisors must follow up on the effectiveness of training for their workers and have them re-trained if necessary.

Hierarchy of Controls for Fall Protection
Elimination

Efforts will be made by our site supervisors to eliminate work at heights wherever practical including modifying or redesigning to avoid exposure to fall hazards.

Guardrails
  1. When eliminating the need to work at height or eliminating the fall hazard is not possible/practical, guardrails are the preferred fall protection method.
  2. Guardrails are to be installed as per the requirements of OHSR 4.58
  3. If a part of the guardrails is to be removed to accommodate work, then:
    • Only the portion of the guardrails necessary to allow the work to be done may be removed,
    • Workers working through that area must be protected by Personal Fall Arrest Systems.
    • Guardrails must be reinstalled immediately after the work is completed or when the area is to be left unattended.
    • Efforts should be made to divert the guardrails to accommodate work instead of removing them, in order to protect other workers.
Fall Restraint
  1. When setting up guardrails or working within the boundaries of existing guardrails is not possible/practical or may impose higher risk, a fall restraint system is the preferred fall protection method.
  2. Fall restraint means a system to prevent a worker from falling from a work position, or from travelling to an unguarded edge from which the worker could fall.
  3. It should be designed to allow workers to move freely within the required work area without reaching the fall hazard when the system is connected.
  4. To setup a fall restraint system, the person using the system is to:
    • Don and adjust an approved and inspected full body harness.
    • Use an anchor point that has a minimum breaking strength of 800lbs – check label.
    • Select a connecting device of adequate length to allow them to reach work but not long enough to let them reach the fall hazard.
    • Attach the connecting device between his/her harness back D-ring and the anchor.
    • Take into consideration all compatible and incompatible connections when connecting the system.
    • Remove any slack in the system that would allow a fall.
    • If rope grabs or any other adjustable system is used, workers' need to check regularly to ensure his/her fall restraint remains properly setup as the task progresses.
    • Manual rope grabs are preferred in fall restraint applications.
Fall Arrest
  1. When using a fall restraint system is not possible/practical or may impose higher risk, a fall arrest system would be the preferred fall protection method.
  2. A fall arrest system is a system that will stop a worker's fall before the worker hits the surface below.
  3. A fall arrest system allows movement within the required work area, but there is still exposure to a fall hazard.
  4. To setup a fall arrest system, the person using the system is to:
    • Don and adjust an approved and inspected full body harness.
    • Use an anchor point that has a minimum breaking strength of 5000lbs – Check label.
    • Select a connecting device of adequate length to allow them to reach work but minimizing free fall distance
    • Attach the connecting device between his/her harness back D-ring and the anchor point. Only energy absorbing lanyards are to be used in fall arrest.
    • Take in consideration all compatible and incompatible connections when connecting his/her system.
    • Ensure no slack in the system will increase free fall distance or put him/her at the risk of swing falls.
  5. Ensure free fall distance is limited to 6 feet when using an energy absorbing lanyard.
  6. Minimize free fall distance by:
    • Using a higher anchor point
    • Using shorter lanyard
    • Using Self Retracting Devices
  7. Rescue procedures must be part of planning for any fall arrest system.
  8. Fall clearance must be calculated for any worker in fall arrest situation.
Control Zones
  1. Control zones are to only be used when other types of fall protection were not practical or imposed higher risk to workers.
  2. Control zone is the area between an unguarded edge of a building or structure and a safe distance of at least 2 meters (6.5 feet)
  3. To only be used on flat surface or surfaces of slope 4:12 and below.
  4. A raised warning line to be setup at least 6.5 feet off the leading edge to alert workers consisting of:
    • A High visibility material or a line flagged or clearly marked with high visibility materials at intervals not exceeding 2 meters (6.5 ft)
    • Rigged and maintained to be between 34 and 45 inches above the working surface.
  5. A Site-specific Fall Protection plan must be prepared when control zones are used, regardless of height.
CANWIDE STEEL
OHS PROGRAM
Appendix G
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
APPX GCreated: Apr/2025Last rev: ---Rev. 2.21 of 5
APPENDIX G – SUSPECTED IMPAIRED WORKER PROGRAM
Policy Statement

We are committed to providing a safe work environment for all employees, managers, and sub-contractors. We recognize the potential negative effects of alcohol, drugs and any condition that impairs a worker's ability to maintain a safe workplace for themselves, their co-workers, and the public.

Drug and alcohol abuse is not acceptable in the workplace. We acknowledge our obligation to take all reasonable steps to ensure the health and safety of our workers and those around them, through the implementation of this Workplace Impaired Policy.

We support our employees and are committed to helping employees overcome substance use. All employees and sub-contractors who work for us or are visiting our projects will be required to meet:

WorkSafeBC Regulation 4.20 Impairment by alcohol, drug, or other substance:

  1. A person must not enter or remain at any workplace while the person's ability to work is affected by alcohol, a drug or other substance to endanger the person or anyone else.
  2. The employer must not knowingly permit a person to remain at any workplace while the person's ability to work is affected by alcohol, a drug or other substance to endanger the person or anyone else.
  3. A person must not remain at a workplace if the person's behavior is affected by alcohol, a drug or other substance to create an undue risk to workers, except where such a workplace has as one of its purposes the treatment or confinement of such persons.

Our Suspected Impaired Worker Program identifies any individual reporting for work who act or appear not fit for duty. Recognizing signs and symptoms of persons that may not be fit for duty is part of supervisor training. Anyone suspecting a person is not fit for duty can refer to this policy. We recognize that impairment may include emotional conditions, medical conditions, mental health issues, legal use of medication, alcohol use or hungover, a mixture of substances and conditions as well as the use of illegal drugs and fatigue. Any condition that impairs a worker could cause an unsafe workplace for themselves, other workers and the public is considered impaired work.

Policy Responsibilities for all Workers, Employees, Trades, Visitors
Program

We are committed to providing a safe work environment for all employees, managers, and sub-contractors. We recognize the potential negative effects of alcohol and drugs in the workplace and the hazard that those individuals who are impaired by alcohol and/or drugs pose to themselves, their co-workers, and the general public.

Drug and alcohol abuse is not acceptable in the workplace. Our company supports its employees and is committed to helping employees overcome substance use disorders. Any individual reporting for duty while their ability to work is affected by alcohol, drugs or other substances will not be permitted to remain on the premises and may be subject to disciplinary action.

Worker/Employee Responsibilities Under the Impaired Worker Program
Supervisor & Manager Responsibilities Under the Impaired Worker Program
Psychological Health and Safety

Psychological health of workers is an important factor in building a healthy and safe work environment for everyone. Mental well-being of workers allows them to realize their own potential, cope with life's stresses, work productively and to be able to better contribute to their workplace and their communities.

In order to improve psychological health and safety in the workplace, we will:

Suspicion of Impairment

Workers suspected of being impaired or otherwise in violation of the policy will be escorted to a private office by a supervisor. The supervisor may invite another senior manager to be in the meeting and will complete the "Impairment Observations Report" specific to this event. The worker will be given an opportunity to explain any changes in behaviors.

When a medical issue is suspected, call the First Aid attendant immediately. First Aid Attendant will assess and treat or call 911 if required.

If after conducting the interview, the supervisor believes the worker has violated this policy and is in a condition unsafe for normal duty, and after consultation and agreement of a second person where possible, the following actions will be taken:

  1. The "Impaired Observation Report" must be complete and kept on file at head office for 3 years.
  2. Where there are reasonable grounds to believe alcohol or drug use may be a factor, the worker may be required to submit to testing and medical assessment to determine if the worker has a substance use disorder.
  3. The worker will be provided with transportation to his/her place of residence or the care of another person; or at the supervisor's discretion, may be temporarily withdrawn or reassigned to another task pending completion of an investigation into a possible violation of this policy. No worker will be allowed to return to their position without management approval and review of the job function performed, the safety of the work environment and any appropriate conditions governing return of the worker.
  4. A documented meeting will be held between Supervisor, Senior Manager or HR Manager and the worker prior to the next shift to:
    • Review testing results/medical assessment and where the worker has been determined, by a substance abuse professional, to have a substance use disorder; issue a formal offer of assistance and establish a treatment process (See Treatment Programs) OR
    • Where a substance abuse professional determines the worker does not have a substance use disorder, the worker will be returned to their current position (provided they are fit for duty) and will be subject to standard disciplinary action.

Impairment may also be caused by psychological health problems that may be noticed by a friend, family member or colleague on a day-to-day warning sign, such as:

Alcohol and Drug Testing
Consent to Undergo Drug Testing

Upon review of this policy all employees are requested to sign the Consent to Undergo Drug Testing form, authorizing management to request drug or alcohol testing where there is reasonable cause or in the event of an incident or near miss with the potential for causing serious injury/damage.

Reasonable cause

Testing for drugs and alcohol occurs when it is determined there is reasonable cause to suspect alcohol or drug use or possession in violation of the Policy. The decision to test will be made by a supervisor in conjunction with a second person (e.g. another supervisor or other individual) wherever practical.

The decision will be based on specific, personal observations such as, but not limited to:

Supervisors must document the reasons for requiring a test as soon as possible through the "Reasonable Suspicion Impaired Behaviour Observation Report" form.

If driving a company vehicle or operating equipment and found impaired it is a Criminal Code offence, and local police should be contacted immediately.

Post-incident

Post-incident testing will be done after any significant accident/incident, or a near miss with potential for causing serious injury, where the cause may involve rule violation or employee judgement. This may be done under the direction of local police, WorkSafeBC or the company's direction.

Treatment Programs

Our company recognizes the severity of substance abuse issues, especially when left untreated. The health of our employees and their families as well as workplace productivity and safety is important to our company and we encourage the use of our employee assistance program.

No person with a substance uses disorder will have either job security or promotional opportunities jeopardized for having requested diagnosis and treatment.

Return to Work/Recurrence

The worker's return to the worksite is always a supervisory decision. If the supervisor continues to have concerns or if there is no change in work patterns, management action must follow whether the employee has sought help or not. If deemed necessary by a medical practitioner or substance abuse professional, the worker will follow the return-to-work program under the guidance of a medical practitioner and/or company supervisor.

Employees returning to work following treatment will be monitored under this program and should there be suspicion of impairment the process will be repeated, and treatment may continue.

Where a worker continually relapses despite participating in our treatment programs, termination may be necessary to protect the health and safety of both that worker and others.

Refusal to Cooperate

Accommodation of a disability requires cooperation from all parties, while denial is a symptom of substance abuse issues, employees are expected to cooperate with the rehabilitation and return to work process. Where repeated attempts have been made to accommodate an employee and the employee refuses to cooperate with the process, progressive discipline is required, up to and including suspension or termination of employment.

CANWIDE STEEL
OHS PROGRAM
Appendix H
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
APPX HCreated: Apr/2025Last rev: ---Rev. 1.11 of 4
APPENDIX H – HEARING CONSERVATION PROGRAM
Policy Statement

Employers must ensure that all employees working in or around noise levels above the allowable limits for noise exposure have proper hearing training and protection. A noise level exposure greater than 85 decibels (dBA) averaged over eight hours can permanently damage your hearing. Employers must also ensure that notices warning employees of noise hazards and identifying the proper hearing protection to be worn are clearly posted.

Noise Measurements

Noise measurements are not required in the construction industry when:

  1. An employer recognizes that workers may be exposed to noise levels above the allowable exposure limits, and
  2. An employer establishes an effective noise control and hearing conservation program for the workers.

Noise measurements are required:

  1. If a worker is or may be exposed to potentially harmful levels of noise, or if information indicates that a worker may be exposed to a level exceeding 85 dBA Lex, the employer must measure the noise exposure.
  2. The noise exposure measurement must:
    • Be performed in accordance with CSA Standard Z107.56-94, Procedures for the Measurement of Occupational Noise Exposure, except as otherwise determined by the Board, and
    • Be updated if a change in equipment or process affects the noise level or the duration of noise exposure.
  3. Except as otherwise determined by the Board, noise dosimeters and sound level meters used for measuring noise exposure must meet ANSI Standard S1.25-1991, Specification for Personal Noise Dosimeters.
  4. The employer must inform affected workers of the results of any noise exposure measurement and the significance of the measurement to risk of hearing loss.

Noise dosimeters measure the noise level and must meet requirements and standards acceptable to the board. See the OHS Regulation, Part 7.

The report of noise exposure shall include the following:

  1. A statement that the measurements have been conducted in accordance with CSA Z107.56, and which exposure was used (exceptions shall be noted),
  2. Date(s) and location(s) of measurements
  3. Name(s) and worker number(s), if known,
  4. The equivalent sound level, Leq, to the nearest decibel for each individual or job measured,
  5. The noise exposure level, Lex, to the nearest decibel for each individual or job,
  6. A description of the job activities of the worker(s) and their shift duration(s), and
  7. A list of equipment used to make the measurements, including make, model and serial numbers.

In addition, the following may be reported:

  1. The product, characteristics, and machinery operating parameters when the measurements were taken,
  2. Mean and standard deviation of group noise exposure,
  3. The equivalent sound level for each activity, and
  4. The calculated arithmetic mean noise exposure and precision for a group.

Results must be readily available for reference by an officer or the health and safety representative, if any.

In our operations, we are not measuring the noise exposure because we have identified that workers are being exposed to noise whenever they use power tools, and they are required to use hearing protection in this situation. Utilizing the exemption in OHSR 7.4.

Education and Training

Workers need to understand the nature of the noise hazard they are exposed to, and how to protect their hearing. Employers must provide workers with certain information. Where noise surveys are undertaken, employers must inform workers of the results of noise measurements and the possible risk of hearing loss.

When noise exposures are above the exposure limits (over 85 dBA Lex or 140 dBC peak), workers should be informed about the:

At the Orientation phase, General Contractor's employees (during company safety orientation) and subcontractors' workers (during site specific orientations) will have hearing protection and conservation discussed. Also, subcontractors' employers are expected to train their employees in hearing conservation. General Contractor will review hearing conservation information with sub-trades as corrective actions if/when required.

Also, periodically, management/supervisors may incorporate hearing loss prevention as part of a crew talk meetings/toolbox.

Another opportunity for worker education is during the annual hearing test. Workers must receive individual counselling from the audiometric technician regarding their hearing test results. This is a good time to review the use and care of workers' hearing protection, and to reinforce information on the effects of noise on hearing and the purpose of hearing testing.

Noise Control

If a worker is exposed to noise above exposure limits, the employer/supervisor must:

  1. Investigate options for noise control.
  2. When practicable, implement options to reduce worker exposure to or below exposure limit.
    Some suggested controls are:
    • purchasing/using tools with noise reducing components (engineering control)
    • putting up a physical barrier that will control sound (engineering control)
    • scheduling increased noise work outside of regular working hours or at a time where less workers will be exposed (administrative control)
Hearing Protection

If it is not practical to reduce noise levels to or below the exposure limits, the employer must:

  1. Reduce noise exposure to the lowest level practical.
  2. Provide and maintain hearing protection to all workers in accordance with CSA Standard Z94.2-94
  3. Provide hearing protection for the subcontractor workers if Prime Contractor has hearing protection available on site for Prime Contractor staff and will distribute to trades if there is none available from their employers with the expectation that they will provide it for their staff moving forward.
  4. Ensure that all hearing protection is worn effectively.

It is the responsibility of the workers to wear hearing protection when exposed noise levels above exposure limits or where a Noise Hazard Sign has been posted. It is also a requirement that workers must periodically replace any damaged ear protection and properly clean earplugs or earmuffs to maximize its life span.

The following chart outlines some common construction decibel levels:

ActivityDecibel Level
Chain Saw95 – 100
Pneumatic Drill100
Welding84 – 97
Normal Conversation50 – 60
Noise Hazard Areas

If it is not practical to reduce noise levels to or below the exposure limits, the employer/supervisor must:

Refer to Class of Hearing Protection below:

Maximum equivalent noise levelRecommended class of hearing protector
Less than 85 dBANo protection required
Up to 89 dBAClass C
Up to 95 dBAClass B
Up to 105 dBAClass A
Up to 110 dBAClass A plug plus Class A or Class B muff
More than 110 dBAClass A plug plus Class A or Class B muff and limited exposure

Ensure that all workers in such an area are wearing hearing protection at all times.

It is the responsibility of all employees to wear hearing protection in all posted noise hazard areas in accordance with the instructions received by the supervisor/employer.

For on-site operations, noise hazards from power tools such as grinders and drills, and equipment such as compressors and generators are regularly present.

Hearing Tests

The employer/supervisor must provide hearing tests to all on site employees exposed to noise levels exceeding 85 dBA as follows:

  1. Hearing tests are to be conducted by a WorkSafeBC recognized tester on an annual basis to effectively monitor the hearing of noise-exposed workers.
  2. A copy of the test results will be given and explained to the employee after the test is complete. A record of the results will be kept on file as well as at the employer's head office for the duration of the employee's tenure.
  3. Test records must be maintained in a manner acceptable to the board and kept as long as the worker is employed and treated as confidential, not to be released without written permission of the worker.

Maintenance of hearing protection must be available to the worker.

It is the responsibility of the workers to bring their hearing protection to their annual hearing re-test so that the fit can be assessed yearly. Employers must review the noise control and hearing conservation program annually to ensure its effectiveness. The review must address the following:

  1. The need for further noise measurement(s)
  2. Education and training of workers regarding noise exposure
  3. Adequate noise control measures
  4. Selection and use of hearing protection
  5. Hearing testing and information on the rate and extent of occupational hearing loss
  6. The requirement of worker representatives to be on site to participate in the program review.
Program Review

This Hearing conservation program will be reviewed on an annual basis.

CANWIDE STEEL
OHS PROGRAM
Appendix I
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
APPX ICreated: Apr/2025Last rev: ---Rev. 2.31 of 11
APPENDIX I – FIRST AID
Policy Statement

Management is responsible for ensuring that First Aid services are supplied and maintained for workers. This shall include Occupational First Aid Attendants and First Aid Equipment in accordance with the Workers Compensation Act Occupational First Aid Regulations. A basic first aid training program is available to all full-time workers.

The work activities assigned to the Site Safety Coordinator/First Aid attendant (e.g. daily inspections, labour, meetings, etc.) shall not interfere with his/her first aid responsibilities.

A first aid treatment facility shall not include any prescription drugs or medications unless otherwise approved by a physician or qualified practitioner. Non-prescription drugs shall be used in accordance with the drug manufacturer's recommendations or by a physician or qualified practitioner.

First Aid Assessment

To determine an adequate and appropriate level of first aid coverage, the first step is to complete a first aid assessment. This OH&S program contains the WorkSafeBC "First Aid Assessment Worksheet" form for its purpose. It must be prepared, reviewed and updated in consultation with the joint committee or the worker health and safety representative, as applicable.

The employer must review and update the assessment within 12 months after the previous assessment or review, and whenever a significant change affecting the assessment occurs in the employer's operations.

Minimum first aid services are determined by assessing three factors:

  1. The number of workers present at the workplace

    Consider the following factors when determining if an area or building is part of a single workplace, or may be considered a separate workplace for the purpose of establishing first aid requirements:

    Factors supporting a single workplace:

    • Fixed work locations under the control of a single employer
    • Multiple employer workplaces where a prime contractor has been established

    Factors supporting separate workplaces:

    • Locations leased by one employer that are part of a larger property leased to others
    • Locations controlled by one employer that are separated by locations controlled by other employers
    • Locations of one employer that are more than 10 minutes apart from each other, or where physical barriers might prevent a first aid attendant from reaching an injured worker in less than 10 minutes
    • A public roadway separates locations of one employer from each other in an urban area
    • Locations under separate administrative structures, controlled by one employer
  2. Hazard rating

    Hazard ratings assigned by WorkSafeBC can be found on the classification unit description sent to employers with their assessments rate letter every year. The hazard rating assigned by WorkSafeBC should be considered the minimum acceptable hazard rating for workplaces of employers assigned to that CU.

    Separate administrative locations – Administrative locations that meet the criteria of being separate workplaces, where the substantive hazards of the industry are not present may consider themselves a low hazard workplace for the purpose of determining minimum first aid requirements.

    Multiple-employer workplaces where the work is phased – Where the prime contractor of a multiple-employer workplace provides first aid services on a project where work is phased.

  3. The class of workplace (which includes consideration of both the accessibility and the remoteness of the workplace)

    Remote workplaces are defined to be those workplaces which, under normal travel conditions, an ambulance that is a motor vehicle cannot travel from its base in 30 minutes or less, but does not include a ferry.

    Less-accessible workplaces are defined as workplaces that include work areas that cannot be safely accessed by ambulance personnel. BCEHS will generally not access the following areas:

    • Backcountry areas that are only accessible by ATV, snowmobile, or similar
    • Areas where the only means of access involves steep or slippery slopes or embankments (without walkways)
    • Areas with rough or complex terrain
    • Areas where there is a significant risk of avalanche, landslide, flood, or other natural hazards

    BCEHS will also not rescue injured workers from hazardous work areas such as:

    • Confined spaces or where there is a risk of entrapment
    • Underground work
    • Excavations
    • Areas that are only accessible by ladders, scaffold, or temporary work platforms
    • Work at high angles, or where an unguarded fall hazard exists
    • Work on or over water
    • Areas requiring specialized PPE or areas where hazardous atmospheres may exist.
Additional First Aid Services

In addition to determining the minimum requirements for first aid, employers must also consider the unique circumstances of the workplace to verify that the minimum requirements are sufficient to meet the regulatory requirement of ensuring injured workers can be promptly provided first aid and transport to medical treatment.

The following additional factors must be considered as part of the employer's first aid assessment:

Hazard or riskAdditional first aid services
Possible exposure to chemicals or toxins whose safety data sheet recommends the use of specific first aid measures to counteract toxic effectsMaintain neutralizing compounds, or antidotes (e.g., calcium gluconate for the treatment of hydrofluoric acid burns)
Probability of intense physical exertion, or risk of exposure to electrical hazards.Accessibility and training on automatic external defibrillator (AED) (where practicable to supply and maintain)
Likely contact with hot surfaces or liquidsMaintain cooling packs, burn dressing, and/or other suitable treatment options (e.g., hydrogel, burn sheets)
Occupational risk factors that could lead to psychological injuryConsider providing first aid attendants (or other workers) training on recognizing and responding to mental health emergencies.
Workers work at heights or around hazards that are likely to result in spinal injuries in areas where BCEHS response may be delayedProvide equipment for spinal immobilization and transportation (ETV equipment), and train attendants in the appropriate procedures
Workers may be exposed to extreme temperaturesMaintain equipment suitable to treat hypothermia (cold stress) or hyperthermia (heat stress), as applicable
Barriers to first aid

Employers must consider additional barriers that could potentially limit or delay a worker's access to first aid. Examples of potential barriers may include:

Barriers to first aidPossible means to address
Physical obstacles or accessibility challenges first aid attendant may encounter at the workplaceEliminate obstacles; Provide alternative means to access areas (e.g. DEP Box, Rope Rescue System, THARRP); Embed first aid attendants into crews
Areas where workers may be unable to communicate their need for first aid or assistance (e.g., where workers may work alone or in isolation, or in areas without access to phones or other means of communication)Provide alternative means of communication; Assign workers to work with others; Provide regular check-ins
Workplace is large and workers work over large areasConsider the number and distribution of first aid attendants and equipment to ensure timely response (10 minute walking time) to all areas of the workplace
Where the employer expects first aid attendants to treat members of the public or others who may be present at the workplace, who were not counted in the number of workers used to determine minimum first aid requirements.Ensure the number of first aid attendants and procedures are sufficient to provide treatment to workers without undue delay
Language or cultural barriers between first aid attendants and injured workersConsider providing additional first aid attendants or additional training to existing attendants and/or workers to reduce perceived or actual barriers
Other hazardous areas that require specialized training or controls to accessProvide additional training or equipment to first aid attendants to enhance access to hazardous areas, if necessary
First aid attendant qualifications

Management must ensure that a designated first aid attendant:

  1. Is at least 16 years old.
  2. Has successfully completed the first aid training course
  3. Has the required level first aid certificate issued by the board or a person recognized by the board.
  4. Meets any other requirements determined by the board for designation as a first aid attendant.
Responsibilities

The first aid attendant must provide injured workers with a level of care within the scope of the attendant's training. He/she must objectively record observed or reported signs and symptoms of injuries and exposures to contaminants covered by Regulation. The attendant must also refer workers with injuries considered by the first aid attendant as being serious or beyond the scope of the attendant's training for medical treatment.

The first aid attendant must be physically and mentally capable of safely and effectively performing the required duties and the board may at any time require the attendant to provide a medical certificate.

The first aid attendant is responsible, and has full authority, for all first aid treatment of an injured worker until responsibility for treatment is accepted at a place of medical treatment, by an ambulance service or by a person with higher or equivalent first aid certification.

The first aid attendant does not have authority to overrule a worker's decision to seek medical treatment or the worker's choice of medical treatment. The worker has the right to refuse First Aid.

First aid certificates

The chart below aligns with CSA Z1210-17 and affect both the naming conventions and course duration of first aid program.

Prior to 2024Duration2024 WSBC AmendmentsDuration
OFA 11 dayBasic First Aid1 day
OFA 25 daysIntermediate First Aid2 days
OFA 310 daysAdvanced First Aid10 days

Transportation Endorsement course may be required on site for an Intermediate First Aid Attendant if packaging and transporting of an injured worker is required depending on hazards and rescue procedures in place.

First Aid Certificate Suspension or Cancellation

A first aid certificate issued to a first aid attendant may be suspended, cancelled or have conditions placed upon its use where the first aid attendant engages in inappropriate conduct, including:

  1. Smoking while assessing or treating an injured worker and/or while handling oxygen therapy equipment, or permitting others to do so.
  2. Failure to use the assessment and injury treatment techniques outlined in First aid training courses unless conditions precluded them
  3. Conduct that poses an unreasonable threat to the safety and wellbeing of others.
  4. Removing him/herself from being able to see or hear any summons for first aid at a workplace.
  5. Abandonment of an injured worker after beginning assessment or treatment.
  6. Refusal to treat an injured worker when acting as a designated first aid attendant
  7. Treating or transporting an injured worker while impaired or under the influence of drugs or alcohol.

Failing to provide competent care, failing to ensure first aid records are kept, and using intoxicants while on duty are common grounds for suspending and/or cancelling of certificates.

First aid procedures – General

Any worker sustaining an injury or illness that is, or may be, job related shall report to the First Aid Attendant for treatment as soon as possible, no matter how minor. The First Aid Attendant shall ensure that a record of every injury or illness, which requires first aid treatment, is kept in the First Aid Treatment Book and the Worker's Supervisor to receive the copy.

The First Aid Treatment Book shall be kept for at least three (3) years and shall be monitored, by Management, periodically. The First Aid Attendant is required to send in their First Aid Treatment Book to the head office at the completion of each project and to be filed in the Head Office.

The First Aid Attendant will be in complete charge of all first aid treatment until medical aid is available (i.e. B.C. Ambulance Service, Paramedics). First Aid Attendant with higher certification is the lead attendant for serious incidents and serious injuries. Supervisory personnel will not attempt to overrule the attendant's decisions relating to first aid or emergency transportation. Workers are expected to assist the first aid attendant if asked to do so.

First Aid statistics are reviewed by the OH&S Program Manager to determine trends and recommend corrective action.

Implementation

Site management are responsible to ensure that the following points are addressed prior to work commencing on site and that these same points are updated as work progresses on site. The written procedures for providing first aid at the workplace including the points below are kept up to date.

  1. The equipment, supplies and facilities available on site are maintained as required and that all designated first aid attendants are capable of completing their duties.
  2. The location of, and how to call for, first aid is revised if it changes on site.
  3. If there are any barriers to first aid being provided to injured workers, how injured workers will be accessed and moved.
  4. Transportation arrangements for workers who do not require evacuation from the site via ambulance.
  5. For non-ambulatory site evacuation, the prearranged routes in and out of the workplace and to medical treatment must be determined and posted.
  6. Ensure that suitable methods of transportation/rescue are arranged for locations considered "less accessible" as BC Emergency Health Services ambulance personnel are not permitted to enter hazardous areas, do not perform rescue activities and there are areas where cannot be reached by an ambulance travelling by land.
  7. Establish who will call for emergency evacuation of workers from the site. This is generally the Site Safety Coordinator/First Aid attendant but could be other workers depending on the situation.
  8. Ensure that emergency procedures are posted in suitable locations throughout the workplace. This information should also be sent to each sub-trade supervisor on site for their information.
Contacting Emergency Services

It is imperative that the first aid attendant and all other persons authorized to call for transportation for injured workers are trained in these procedures. The person placing the 911 call must know the following:

  1. The name and location of the project.
  2. Where to go in order to access the site.
  3. The extent of the injuries and the number of casualties.
  4. Any other information the Site Safety Coordinator/First Aid attendant feels is relevant.
Multiple Employer Workplaces

If workers of two (2) or more employers are working at a workplace at the same time, the prime contractor/General Contractor must:

  1. Conduct an assessment of the circumstances of the workplace under section 3.16(2) in relation to all the workers in the workplace, and
  2. Do everything that is reasonably practical to establish and maintain the first aid equipment, supplies, first aid attendants and services in accordance with the results of the assessment.

NOTE – Every employer is required to have their own first aid, in addition, to the coverage provided by the Prime Contractor.

If workers or sub-trade workers will be on site outside of scheduled working hours, the requirements for first aid coverage still exist and must be addressed by us and the sub-contractor(s) requesting to work outside of scheduled hours. This may require our first aid attendant to be on site or arrangements to be made for a temporary first aid attendant.

Alternatively, if a sub-trade has a first aid attendant that can provide first aid to other workers s/he may be utilized. If this option is selected, then we must ensure that a written agreement is in place and that all first aid equipment meets the requirements of the law and is available. Ensure that all workers are familiar with the emergency protocols on site, particularly those for summoning first aid. All parties must understand the arrangement and know how to contact the first aid attendant. All designated first aid attendants will have their credentials verified to ensure compliance with the OH&S Regulations and meet the minimum requirements, with consideration of work risk, distance to hospital and number of workers.

First Aid Equipment Requirements

The OH&S Regulations, under Part 3, outlines the different levels of first aid service requirements, based on travel time to transport an injured person to a hospital and the number of workers per shift.

Use the criteria to determine the level of first aid required on the job site, the appropriate first aid kit/equipment must be also determined, pursuant to the OH&S Regulations, under Part 3. Each kit has a required minimum content. It is the responsibility of the first aid attendant to ensure adequate supplies are contained inside each kit. Additional supplies may be ordered through the site superintendent.

First aid requirements prior to 2024First aid requirement based on WSBC 2024 Amendments
Personal KitCSA Z1220-17 Personal Kit
Level 1 First Aid KitCSA Z1220-17 Basic Kit (Medium) + tourniquet + PPE
Level 2 First Aid KitCSA Z1220-17 Intermediate Kit (Medium) + PPE
Level 3 First Aid KitCSA Z1220-17 Intermediate Kit (Medium) + Oxygen Therapy Kit + PPE
Emergency Vehicles and Equipment

The first assessment will help determine whether or not an emergency vehicle needs to be available on site.

  1. The emergency vehicle must be maintained and operated according to the general requirements in the OH&S Regulations.
  2. The emergency vehicle must be capable of being dispatched to the incident scene within five (5) minutes.
  3. The first aid attendant should not be operating the vehicle, as that could reduce their ability to treat the injured worker.
  4. The vehicle should be suitable for the terrain and area, and be able to provide proper warmth and protection from the natural elements.
  5. The vehicle should be equipped with effective communication between the vehicle operator and first aid attendant, and the vehicle operator and the hospital.
  6. It should be located where it will best serve the workers who are most likely to need an emergency vehicle.

Any costs associated with transporting injured works to the nearest hospital or medical facility is the responsibility of the employer.

If the first aid attendant accompanies the injured worker to the nearest hospital or medical facility via company vehicle or taxi/uber, Employers must have a plan in place to ensure first aid is available on site unless the site is shut down.

Follow-Up

The full extent of a worker's injuries may not be known at the time they are receiving first aid. The first aid attendant may deem the injuries serious enough that the worker should see medical aid. Transport to medical aid is either via ambulance or by another means such as taxi, uber or company vehicle(s).

The first aid attendant must note the fact that the worker departed the site for medical aid and must follow-up after the fact with the worker's supervisor or employer to ascertain the condition of the worker.

Once the worker departs the site, we still have a responsibility to determine the condition of the employee. Whatever the case, this information is critical for supporting any subsequent investigations that occur as a result of the incident. Information obtained from follow-up should be recorded in the first aid treatment record completed for that worker.

Reducing the Risk of Infection

Employer Responsibilities: Where it is reasonable to expect that workers could be exposed to blood and certain body fluids as part of their normal job duties, employers must comply with the sections on biohazardous materials in part 6 of the Occupational Health and Safety Regulation.

Employers should do the following:

  1. Ensure that a vaccination against Hepatitis B virus is available at no cost to the worker, upon request, for all workers who have or who may have occupational exposure to Hepatitis B.
  2. Inform and instruct workers in how to eliminate or reduce the risk of contact with blood and certain body fluids.
  3. Ensure that work practices eliminate or minimize the risk of unforeseen contact.
  4. Develop ways to address chance encounters with blood and certain body fluids.
  5. Provide workers with the equipment, tools, and personal protective equipment (PPE) needed to deal with an unforeseen contact.
  6. Monitor the workplace to ensure that safeguards are used and safe work practices followed.
  7. In case of an exposure incident, ensure that: (a) Prompt, easy-to-access first aid and medical attention are readily available and provided; (b) Employees are aware of procedures for obtaining immediate first aid and medical attention and for reporting incidents of exposure to blood and certain body fluids.

Worker Responsibilities: Workers must:

  1. Attend education and training sessions provided by the employer.
  2. Use controls and follow safe work practices established by the employer for their protection.
  3. Use the available tools and PPE provided for use in chance encounters with blood and certain body fluids.
  4. Know how to get immediate first aid and medical attention and how to report exposure incidents to blood and certain body fluids.
  5. Know that they should not clean up spilled blood and body fluids unless they have the proper equipment and PPE, and are trained to do so safely.

Tools and Equipment: An employer must provide workers with the tools/equipment and PPE needed to do the job safely. Even where workers are not expected to contact contaminated needles, it is good practice to have proper sharps containers, gloves, tongs, and pliers available to pick up needles, in case workers do encounter them.

Safe Work Practices: Even if workers are not expected to be in contact with blood and certain body fluids, all workplaces should have basic work practices to deal with the rare incidents that could occur.

  1. Follow universal precautions
  2. Get or administer first aid
  3. Report exposure incidents and seek medical attention
  4. Safely clean up blood and body fluids after spills
  5. Safely decontaminate or dispose of contaminated objects

Universal precautions are necessary because: (1) People can unknowingly carry HIV and the hepatitis B and C viruses without any signs. (2) It is possible to become infected with one exposure incident to infected blood and body fluids.

Musculoskeletal Injuries (MSI)

Some of the tasks we perform at work—such as lifting, reaching, and repeating the same movements—can strain our bodies. In some situations, these tasks can result in an injury to the muscles, tendons, ligaments, nerves, blood vessels, and joints of the neck, shoulders, arms, wrists, legs, and back. This type of injury is a musculoskeletal injury, or MSI.

Reduction of MSI can be obtained by:

The primary risk factors for MSI are the physical demands of a task such as: (1) Force, (2) Repetition, (3) Work posture, (4) Local contact stress.

Signs and symptoms of MSI may appear suddenly—for example, from a single incident, that causes an injury—or they may appear gradually over a longer period. Ignoring early signs and symptoms of MSI may worsen the problem causing further damage.

Signs (observable): Swelling, Redness, Difficulty moving a particular body part.

Symptoms (felt but not observable): Numbness, Tingling, Pain.

Health Effects: An MSI can affect your ability to perform tasks at work and at home. Early signs or symptoms of MSIs can progress into conditions such as: muscle strains, tendinitis, and carpal tunnel syndrome.

Treatment: Treatment will vary according to the type of MSI. Treatment can include the application of cold or heat, medication, physical therapy, and even surgery. Effective treatment is improved when an MSI is discovered and reported early.

First Aid Drill

At least once each year and whenever the procedures change, the employer must ensure that drills are conducted to ensure that the procedures are effective, and workers, first aid attendants and other persons are capable of fulfilling their roles and responsibilities.

Workplace characteristicsDrill considerations
Single or multiple employer fixed locationAnnually at each fixed location, and when procedures change
Single or multiple employer working at various temporary locationsAnnual drill at one location, provided procedures remain substantively the same; If procedures vary substantially between locations, then multiple drills will be required

Procedures and processes that should be assessed during first aid drills include:

Post-drill / When to conduct drills

The results of the drill and any subsequent changes to first aid procedures should be shared with all first aid attendants, as well as with the joint health and safety committee or worker health and safety representative as applicable.

Drills should be conducted as soon as practicable following the implementation of procedures, at least annually, and when procedures change. Drills must also be conducted when there are substantive changes to written first aid procedures. A substantive change in procedures may include:

Changes that are not considered to be substantial include: First aid procedures that are same, but with varied locations for medical aid; Changes to the location of the closest ambulance station without impacting the workplace class; Variations in who is acting as designated first aid attendant.

CANWIDE STEEL
OHS PROGRAM
Appendix J
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
APPX JCreated: Apr/2025Last rev: ---Rev. 2.21 of 5
APPENDIX J – INJURY MANAGEMENT PROGRAM
Policy Statement

We believe workplace injuries are preventable through everyone's commitment to health and safety including participation in all aspects of our program. We have emergency procedures in place to ensure injuries and/or illnesses are effectively managed. This program aims to assist personnel after the incident, whether dealing with an injury or illness, we are committed to protecting our people.

Commitment

We will make every reasonable effort to modify tasks, equipment or surroundings for any employee who is unable to perform his/her regular job as a result of a work-related injury/illness.

The Company, in cooperation with WorkSafeBC and healthcare providers, will facilitate the Return-To-Work of employees who are dealing with an injury/illness. This could include coordinating rehabilitation, follow-up appointments or other treatment to assist in a Return-To-Work.

All modified work assignments will be productive and meaningful and will not interfere with the employee's recovery or present a risk to that employee or to others. To ensure that modified work assignments are safe and appropriate, Return-To-Work (RTW) plans are developed and reviewed in consultation and cooperation with the employee and his/her physician's recommendations. The Program may be initiated by the worker and/or the employer in communication with the claim adjudicator.

Objective
  1. Ensure duty to cooperate - the injured worker and the employer must cooperate with each other, and with WorkSafeBC, to maintain workplace connections and facilitate timely and safe Return-To-Work.
  2. Ensure that all employees have equal access to the Injury Management Program and are supported for as long as it is required until returning to work after an injury/illness.
  3. Ensure all workers are aware of our Injury Management Program and how it works.
  4. Minimize the impact of injuries or illnesses on productivity by effectively managing them and modifying duties.
  5. Communicate the causes, signs and symptoms of the injuries/illnesses to our personnel with the intention of preventing similar incidents.
  6. Limit both the direct and indirect costs associated with claims with minimal impact to the worker and their earnings.
  7. Manage all workers participating in our Program with regards to physician's recommendations, combined with the worker's needs for successful Return-To-Work.
Our Strategy
  1. Respond quickly to all reports of injury in the workplace.
  2. Ensure all workers receive medical aid as quickly as possible.
  3. Report/Investigate all injuries which result in medical aid or lost time in the workplace.
  4. Work with the injured workers, Medical Practitioners, and RTW Coordinator, to determine the best course of action for an injured worker including the development of a return-to-work plan.
Confidentiality

Our injury management process is designed with a professional and ethical approach. Employees are able to participate in our program knowing their privacy and confidentiality rights are assured and protected. Only medical information that is necessary to the Return-To-Work/rehabilitation of an injured employee will be requested/obtained. All medical records will be kept strictly confidential and will be used only for the purpose of safely returning the employee to full duties. Information obtained will not be released to any other party without the written consent of the employee.

Process
  1. The injured worker notifies their supervisor that they have sustained a workplace injury. Supervisor will provide the RTW package to be completed by both injured worker and their physician.
  2. Once the forms have been completed by the Physician, they are then returned to the Company Return-to-Work Coordinator for review. A RTW plan will be developed in collaboration with the Physician and WorkSafeBC using the functional assessment form.
  3. Once a RTW plan has been developed with the worker and supervisor, the Return-to-Work Coordinator will review with the worker to ensure he/she is comfortable with the plan and adjust it accordingly. Have both worker and supervisor sign the form. A copy of the RTW Plan is forwarded to WorkSafeBC. The worker and supervisor then jointly manage the program along with the Return-to-Work Coordinator and WorkSafeBC case manager.
  4. When the worker is fully rehabilitated and is deemed fit for full-time duties by a physician, the program will be concluded with a short closing meeting attended by the worker, and their supervisor.
Refusal of Light/Modified Duties

Where a worker refuses to accept the offer, WorkSafeBC will consider the reasons for refusal and determine if they are reasonable. In making this determination, WorkSafeBC will give regard to the requirements of the work, medical opinion(s) and other evidence regarding the worker's medical restrictions, physical limitations and abilities. Should WorkSafeBC determine that the worker's refusal is unreasonable, benefit entitlement may be stopped.

Return-To-Work

The RTW plan will help injured workers Return-To-Work more quickly, reduce the likelihood of recurring injuries, and significantly lower wage loss payments.

Returning to work while recovering is a healthy and safe approach for most people with work-related injuries. Working is good for physical and mental health, and often supports healing. Making safe, sustainable work arrangements for people who were injured at work takes collaboration. Workers, employers, and health care providers all have important contributions to make.

Gradual Return-To-Work

Gradual Return-To-Work (GRTW) plans are generally no more than 4-6 weeks. The plan is implemented on an incremental basis (e.g. 2 hours per day for the first week, 4 hours the next week, followed by 6 and then 8 hours in the final week). The plan is generally generated by a Health Care Provider (i.e.: Physiotherapist, RTW Nurse) and provided to the company at the time of the injury occurrence with consent by the worker.

Roles and Responsibilities
RoleResponsibilities
First aid attendant 1. Administer First Aid
2. Record the treatment in First Aid Record
3. Provide copy of First Aid Record to worker and Supervisor including any observations to assist in the investigation
4. May be involved in RTW plan if the worker requires follow-on care on site
Injured worker 1. Obtain first aid record from First Aid Attendant and report injury to Supervisor
2. Ensure you provide to your Supervisor your updated contact information
3. Obtain Return-to-Work Package from Supervisor
4. Attend medical aid as required
5. Report injury to WorkSafeBC via Teleclaim
6. Submit RTW documentation to Physician for completion and return it to the Supervisor
7. Review RTW plan and sign-off on it
8. Follow and participate in the RTW plan
9. Check in with the supervisor daily and at any time they have concerns.
Supervisor 1. Provide Return-To-Work Package to the injured worker
2. Ensure to have injured worker(s) up to date contact information
3. Immediately notify Return-to-Work Coordinator of workplace injury
4. Work with Return-to-Work Coordinator to investigate and report on the circumstances of the injury
5. Send completed functional assessment forms to Return-to-Work Coordinator
6. Have employees sign modified work offer and send to Return-to-Work Coordinator
7. Provide Return-to-Work Coordinator with workers job demands
8. Monitor worker (when on site) and update Return-to-Work Coordinator as needed
Return-to-Work Coordinator 1. Complete Form 7 and submit
2. Contact injured employee on the same day of the injury
3. Review RTW Functional Assessment Form and develop written RTW plan
4. Coordinate RTW plan with WorkSafeBC
5. Monitor RTW plan and modify as required
6. Maintain effective communications with worker, supervisor, WorkSafeBC and other agencies as required
7. Monitor worker.
WorkSafeBC 1. Establish claim
2. Ensure all required therapies are being requested/completed
3. Helps decide whether specific work is suitable for the worker
4. Provides information about resources that help workers return to work early
5. May levy penalties for non-cooperation.
6. Helps to resolve difficulties and disputes (Mediation Services)
7. Determines the loss of earnings benefits due to the worker
8. Decides whether early and safe return to work has been successful or whether other approaches are required.
Health care provider (worker's physician or attendant practitioner) 1. Provides the injured worker's limitations by filling out functional assessment forms
2. Advocates on behalf of the worker
3. Monitors patient
Health care provider (specialists) 1. Provide insight into injuries which are complex (e.g. head injuries)
2. Apply therapies to the injured worker
3. Liaise with WorkSafeBC on the effect of therapies
Reporting Injuries
Types of ReportingDescription/Involvement
First Aid Only – worker returns to work • Worker returns to work with no medical aid or loss time
• First Aid is communicated to the Supervisor and record kept and copy available for the injured worker
Medical Aid (Worker sees Physician and returns to work the same day or next morning, start of next shift) • Provide The Injury Management/Return-To-Work (IM/RTW) package to the worker
• Inform worker that modified duties are available.
• Form 7 is filled out and submitted to WSBC within 3 work days of injury.
• Return completed Functional Ability form (completed by physician) same day or by beginning of next shift
• If required, complete the Modified Work Offer form with the worker and provide a copy to the worker.
• Complete a preliminary investigation within 48 hours, a full investigation with 30 days of incident and submit it to Return-To-Work Coordinator, WSBC and JOH&S Committee within 30 days.
• Follow up with injured worker and maintain all appropriate documentations
Lost time (worker goes to Physician and does not Return-To-Work by next shift) • Provide The Injury Management/Return-To-Work (IMRTW) package to the worker
• Inform worker that modified duties are available.
• Form 7 is filled out and submitted to WSBC within 3 work days of injury.
• Return completed Functional Ability form (completed by physician) same day or by beginning of next shift
• Preparation of the Modified Work Offer and review with the worker.
• Complete a preliminary investigation within 48 hours, a full investigation within 30 days and submit to Return-To-Work Coordinator, WSBC and JOH&S Committee.
• Follow up with injured worker and maintain all appropriate documentation between Injured worker, Supervisor, Return-To-Work Coordinator and WorkSafeBC.
• Keep the Claims Management Log Form updated – record the workers progress, list documents received and sent out, conversations, etc.
• Ensure that the re-assessment of the injured worker functional abilities is performed/planned as per the previous physician notes on the Functional Assessment form.
Flow-Chart
INJURED WORKER
Seek First Aid Immediately
All injuries must be reported to First Aid.
FIRST AID ONLY
Worker reports to Supervisor with First Aid Record
Supervisor submits First Aid record to the Return-to-Work Coordinator
MEDICAL AID
Worker reports to Supervisor with First Aid Record
SUPERVISOR
WORKER
Supervisor to inform worker that modified duties are available and issue the package with regulatory forms and functional assessment form for timely RTW
(Within 24 hours)
Conduct and submit Investigation & First Aid record sent to Return-To-Work Coordinator
(As soon as possible)
Call the Return-To-Work Coordinator with information on the clinic, physician or hospital.
Worker MUST call Teleclaim
1-888-WORKERS (1-888-967-5377)
Monday to Friday 8am to 6pm
Lost Time
Supervisor to ensure that the worker:
  1. Has the Office & Supervisor Phone numbers
  2. Knows that she/he must check in weekly
  3. Confirms the worker's current home and/or mobile phone number
No Lost Time
Return-To-Work Coordinator completes WorkSafeBC Employers Report of Injury Form 7.
It must be sent to WorkSafeBC within 3 working days.
Supervisors must review in a confidential manner, incidents with all workers at the next Toolbox Talks meeting.
CANWIDE STEEL
OHS PROGRAM
Appendix K
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
APPX KCreated: Apr/2025Last rev: ---Rev. 2.21 of 3
APPENDIX K – WHMIS PROGRAM
Policy Statement

Workplace Hazardous Materials Information System (WHMIS) is a systematic approach to educate workers to hazardous materials found around them, the proper procedure for use/handling of these materials, and first aid requirements and prevention. The goal of this legislation is to reduce illness and injuries caused by hazardous materials.

All employees and sub-contractors are to actively participate in the WHMIS program. The program is to ensure that workers receive the fullest knowledge and protection in the handling of products, which could be harmful to their health.

Workers will understand how to use hazardous materials safely, the procedures for safe use, and handling, storage and precautions of hazardous materials before use. They are also responsible for reporting containers with missing, illegible/destroyed, or wiped-out labels or applying a workplace label. Workers that use or work in proximity to hazardous materials are required to have training from their Employer in:

SDSs must be made accessible to all personnel, close to their work areas and readily available during the work shift. SDSs must also be made available to First Aid Attendant(s) and other emergency personnel on site.

Employer Responsibilities

All employers must ensure that a worker's exposure to any harmful substance does not exceed occupational exposure limits. If a harmful substance does not have an established exposure limit, employers must ensure that worker exposure is kept as low as reasonably practicable. WHMIS employer responsibilities are in 3 main categories:

  1. Labels
    • Ensure that hazardous products received at the workplace are properly labelled.
    • Ensure workplace labels are used in the workplace.
  2. Safety Data Sheets
    • Ensure that up to date SDS are readily available for workers.
    • Ensure that the SDS arrives when materials are received.
    • Obtain SDS information prior to allowing the materials in the workplace.
  3. Worker Education
    • The hazard classifications/symbols and the safe use of hazardous materials.
    • How to read, use and understand labels and SDS.
  4. Risk Control
    • Ensure workers are trained in WHMIS.
    • Verify hazard assessments for use, handling, and storage.
    • Evaluate hazardous products to deduce if substitution for a safer/healthier product is practical.
    • Verify appropriate emergency/spill control measures are implemented.
WHMIS Labels

WHMIS has established standards for manufacturers, suppliers, and employers to identify hazardous materials using labels. It is mandatory that hazardous materials are packaged with visually prominent WHMIS Labels that meet regulation.

On-Site supervisors are to:

  1. Ensure that workers who work with or in proximity to hazardous materials are instructed in the content, purpose, and significance of supplier and workplace labels and other identifiers.
  2. Ensure that a controlled product or the container of a controlled product has the proper label applied at the time of entry into the workplace.
  3. Ensure that no controlled product is used or handled in the workplace without the proper label.
  4. Take measures to ensure that supplier labels are not removed, defaced or altered in the workplace.
  5. Develop and apply Workplace Labels to hazardous materials or container of hazardous materials whenever:
    • The employer produces a controlled product in the workplace. (Not applicable to our scope of work).
    • An existing supplier label becomes illegible, or is accidentally removed
    • When a controlled product is decanted (transferred from its original container to any other container)
Inventory

Management will establish an inventory of WHMIS hazardous materials. The inventory will be reviewed as often as necessary to ensure that it is maintained and up-to-date.

Purchasing
  1. At the time of ordering any new materials, the supplier must be requested to identify which products, if any, are covered by hazardous materials legislation.
  2. Where multiple products that are used for the same purpose are available, the least hazardous material will be obtained if practical.
  3. Suppliers are required to provide us with SDS prior to the material arrival.
  4. All WHMIS controlled hazardous materials ordered may only be accepted if accompanied with applicable labeling and SDSs.
Risk Controls

Management and foremen are responsible for monitoring storage, handling and use of hazardous materials on their sites as part of their daily supervision, and during regular inspections. Monitoring will consider the physical and health hazards of the product, quantities, work processes, location of use, based on WHMIS and other workplace information. Management, in cooperation with suppliers and supervisors, will develop work procedures that ensure worker health and safety.

Control measures may include:

  1. Elimination, where the hazardous product will be replaced with a non-hazardous one, or the job redesigned to avoid the use of such hazardous products, if applicable.
  2. Substitution such as replacing the material with a less harmful alternative.
  3. Engineering controls such as ventilation, process modification or isolation of the hazard source.
  4. Administrative controls such as work procedures, storage arrangements, maintenance and shift scheduling.
  5. Personal Protective Equipment such as substance specific gloves and goggles, as required by the product's SDS.
Safety Data Sheets

WHMIS requires manufactures, suppliers, and employers to disclose the nature of materials found in their products using Safety Data Sheets (SDS).

It is mandatory that hazardous materials are supplied with an SDS that includes all information specified by the hazardous products legislation:

  1. Obtain up-to-date supplier Safety Data Sheet before product is used or handled.
  2. Ensure that supplier SDS is not more than 3 years old.
  3. Develop an employer SDS if the controlled product is produced in the workplace.
  4. Update SDS:
    • Within 90 days of receiving new information about product.
    • At least every 3 years.
  5. Make sure SDS are "Readily Available" to:
    • All workers who work with or in proximity to hazardous materials during each work shift.
    • Occupational Safety and Health Committee or Worker Health and Safety representative.
    • First Aid attendants and other personnel involved in emergency response.
  6. Ensure workers are informed regarding:
    • Content required on SDS and their location.
    • The purpose and significance of the information.
Worker Education

Instruction on the WHMIS programs, Labels, and SDS, is to start with an employee's orientation and be substantiated with a formal review of WHMIS with all employees a minimum of once per year. When new conditions or hazardous materials enter the work site, specific instruction are to be given to all site employees at the next toolbox meeting that includes, as a minimum, identification of the product, hazard symbols, safe handling and first aid procedures, and the addition of the SDS to site records.

Worker Responsibilities

Workers have a responsibility to themselves and other fellow workers to conduct work in accordance to standards, regulations, guidelines established by WorkSafeBC, WHMIS product labels and SDS, and our Company.

If an employee demonstrates an unwillingness to follow established standards, and, after being given clear instructions, ignores requests by Management or Supervisor to follow the working standards, the employee will then be subject to our disciplinary action policy as explained in Element 5 of this OH&S Program. Worker's responsibilities are:

  1. Know and understand:
    • The content information that should appear on supplier labels and workplace labels, including the requirements for information on the availability of SDS.
    • The significance for worker health and safety of information on the WHMIS Programs and other written or symbolic means of identification.
    • Procedures for the safe use, storage, handling, and disposal of hazardous materials; procedures to be followed when fugitive emissions are present, or in an emergency which involves hazardous materials.
  2. Handle hazardous materials in accordance with the WHMIS standards as identified on Labels and SDS and our Company's Safe Work Procedures.
  3. Follow our supervisor's and site Safety Coordinator directions to avoid removing, defacing or altering the WHMIS labels.
  4. Inform the Supervisor or Site Safety Coordinator of the presence of the WHMIS Labels or SDS and other identifiers, which are illegible or have been accidentally removed.
  5. Wear the appropriate personal protective equipment.
CANWIDE STEEL
OHS PROGRAM
Appendix L
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
APPX LCreated: Apr/2025Last rev: ---Rev. 2.21 of 7
APPENDIX L – COMMUNICABLE DISEASE PREVENTION PROGRAM
Policy Statement

A communicable disease is an illness caused by an infectious agent or its toxic product that can be transmitted in a workplace from one person to another. Examples of communicable diseases that may circulate in a workplace include COVID-19, norovirus, and seasonal influenza.

Symptoms differ depending on the disease, but are likely to include fever or chills, coughing, diarrhea and fatigue. A person can also be carrying the disease, spreading it among others in the workplace or at home, without showing any symptoms.

Exposure to communicable diseases may occur:

Responsibilities

The Prime Contractor is responsible for:

The Employer is responsible for:

Supervisors are responsible for:

Workers are responsible for:

Risk Identification, Assessment and Control

Routes of Exposure

Exposure to communicable diseases can occur through:

Breathing-in fine droplets in the air

If somebody coughs or sneezes, fine droplets escape their mouth/nose which are airborne for a short period of time before falling to the ground, typically within two meters. Anybody close enough may become exposed by breathing in these droplets. Social distancing (maintaining 2 meters of distance from other people) can reduce the risk of this occurring.

Direct Close Contact

Close contact refers to physical contact with another person, for example shaking hands or hugging. When people cough or sneeze droplets may settle on their skin, clothing, and/or their hands. People who are carriers of communicable disease may transmit the virus from their hands or clothing to others during close contact. The virus then has the potential to enter the body by rubbing eyes, eating with hands, chewing nails, etc.

Air-borne

Droplets in the air that result from coughing or sneezing are typically large enough to land on the ground within 2 meters. However, some droplets may be small and travel further, or land on other airborne particles such as dust, and travel for longer distances.

Vehicle-borne

The term vehicle refers to objects or materials that becomes contaminated with the disease. The object may contact the person's body, be ingested (eaten or drunk), or be introduced internally during surgery or medical treatment. Examples of vehicles that can transmit diseases include water, food, cooking or eating utensils, clothing, hand tools, and contaminated medical/first aid supplies or tools.

Vector-borne

Transmission to humans and other animals by blood-feeding living organisms, typically insects, such as mosquitoes, ticks, and fleas. The living organism carries the disease on its body, or as an infection host -the insect being infected- itself.

Risk Assessment

The level of risk of certain communicable diseases, may increase from time to time or on a seasonal basis. This may occur at a local or regional level, or within a certain workplace.

Management will monitor and review communicable disease-related information issued by the regional medical health officer or the provincial health officer if related to our industry, region, or workplace. This includes orders, guidance, notices, and recommendations issued by a medical health officer or the provincial health officer.

The below factors will increase the risk of contracting Communicable diseases.

Exposure Control

Controlling the hazardous exposure follows the following hierarchy:

  1. Elimination
  2. Engineering Controls
  3. Administrative Controls
  4. PPE

Elimination:

The below policies will be implemented with the purpose of eliminating the possibility of transmission. The below policies and practices may not always be practicable.

Engineering controls:

The below engineering controls will be implemented with the purpose of reducing the risk by reducing the possibility of transmission. The below policies and practices may not always be practicable.

Administrative controls:

If we are a prime contractor, we will:

As an employer, we will:

Frequent Hand washing is one of the best ways to minimize the risk of infection. Proper hand washing helps prevent the transfer of infectious material from the hands to other parts of the body—particularly the eyes, nose, and mouth - or to other surfaces that are touched. Hand washing stations will be listed on the site safety plans and reviewed in site orientations.

Workers are advised to wash hands immediately:

Use soap and warm running water (when available). If water is unavailable, use a waterless hand cleanser/sanitizer that has at least 70% alcohol. Follow the manufacturer's instructions on how to use the cleanser.

Cough/Sneeze Best Practices

Any person coughing or sneezing must follow the below practices:

Additional Practices

In addition to the above controls, the below practices will reduce the possibility of contracting any communicable diseases. However, these practices may not be practicable at all times:

If operating a Mobile Elevated Work Platform (MEWP) such as scissor or boom lifts.

If workers show symptoms of communicable diseases.

If workers are showing symptoms of communicable disease before coming to work, they should stay home.

If they develop severe symptoms while at work, they will be advised to leave the workplace, and head home, or to their family doctors. Workers should only return to the workplace once they have recovered from symptoms, especially in the case of fever. Workers should inform their manager or supervisor if they are ill.

Mild symptoms such as mild cough or running nose may not require leaving site. Follow other practices such as coughing in elbows, regular handwash, wearing a mask, etc.

If you show severe symptoms on site and need to leave, follow this procedure:

  1. Put on non-medical face mask, respirator or surgical mask if you have one available.
  2. Put on your gloves if available.
  3. Proceed to the main gate, in an outdoor environment. Keep two meters (6 ft) away from any person and don't touch any surfaces. Cover your mouth if you had to speak to someone.
  4. Once at the gate, don't leave site. Call your supervisor who in turn will call the site safety coordinator and notify them.
  5. Supervisor will provide you with a non-medical face mask, a respirator or surgical mask, if available, and send you home.
  6. As much as possible, notify supervisor of any person they had close contact with on site in the past few days.
  7. See your family doctor and follow their directions.
  8. If needed, supervisor will notify persons the worker came in close contact with as per step f. and advice to monitor health closely.
PPE
Worker Training

Our workers will receive training in the following:

Training will be done periodically through toolbox meetings. Any feedback from workers will be recorded and documents updated as needed.

Health Monitoring

Our workers will promptly report any symptoms of communicable disease to their manager or supervisor and the first aid attendant. When a worker reports symptoms to the company or Supervisor after leaving site the Company will immediately notify the Contractor in charge of the site to ensure proper measures can be taken to protect the health and welfare of other worker who will have had contract with this worker.

Record Keeping

Records will be kept of the following:

Our company will keep records of instruction and training provided to workers regarding communicable diseases, and of any disease reported.

Review

We will review the exposure control plan every month and update it as necessary, in consultation with our joint health and safety committee or worker health and safety representative.

The plan will also be updated when new related information is issued by health officers.

CANWIDE STEEL
OHS PROGRAM
Appendix M
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
APPX MCreated: Apr/2025Last rev: ---Rev. --1 of 1
APPENDIX M – MUSCULOSKELETAL INJURY (MSI)

It is a common and costly problem that affects many workers and workplaces. MSI can result from overexertion, repetitive motion, awkward posture, vibration, or contact stress. MSI can cause pain, disability, and reduced quality of life for workers, as well as increased absenteeism, turnover, and compensation costs for employers.

The factors in the workplace that may expose workers to a risk of musculoskeletal injury (MSI) will be identified and assessed, including:

We will use a hierarchy of controls that starts with engineering. If engineering controls are not practicable, we will use administrative controls. Our final choice will be personal protective equipment. Temporary control measures will be implemented if/when permanent control measures are not yet implemented.

The Risk assessment will be performed by someone who understands the work process, the MSI risk factors, and the principles of risk assessment and control. For documenting purposes, the WSBC form for "Musculoskeletal Injury Risk Assessment" can be used for the assessment, designation of controls and control of actions required.

Workers will be instructed on how to identify the risk factors related to their work, such as the early signs and symptoms of an MSI and how they can affect their health. We will also educate workers on ways to reduce the risk of MSI. The training will include work procedures, mechanical aids and personal protective equipment, if applicable.

The effectiveness of the measures taken to comply with the Ergonomics (MSI) Requirements will be reviewed at least annually, and will include interviewing workers, identifying changes in the number and severity of signs and symptoms of MSI, observing a reduction in the number of risk factors or in the severity of risk factors, comparing the exposure to risk factors before and after controls are implemented.

CANWIDE STEEL
OHS PROGRAM
Appendix N
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
APPX NCreated: Apr/2025Last rev: ---Rev. --1 of 12
APPENDIX N – CONFINED SPACE ENTRY PROGRAM
Policy Statement

We have taken rigorous steps to establish a system for identifying confined spaces, evaluating the potential hazards associated with these spaces and developing appropriate entry and rescue procedures.

The objectives of this program are as follows:

  1. Prevent employee injury, illness or death resulting from confined space hazards.
  2. Identify potential confined spaces prior to entry and determine the potential hazards associated with each.
  3. Develop techniques to control confined space hazards, including preparation for emergency rescue and contingency plans.
Responsibilities

Administration

Our Company has assigned overall responsibility for administration of the confined space entry program to management, who will enlist the assistance of confined space experts/consultants as required.

Supervision

At the time of entry, we will assign responsibility for supervision to a person who is adequately trained to supervise the job before any worker enters a confined space.

The responsible supervisor will ensure that:

Instruction

Each person who is assigned duties or responsibilities related to entry into a confined space will be adequately instructed and trained in:

  1. General recognition of confined space hazards and the hazards of each specific space.
  2. The precautions identified in written procedures which are required to properly perform their duties.
  3. How to perform their work duties in a safe and healthy manner.
  4. How to perform any assigned roles in confined space entry.

Co-ordination

Coordination is of critical importance and considered one of the key measures contributing to a successful safety program. We take coordination very seriously for all work activities, not just confined space entry.

Prior to entry to the confined space and commencement of the scope of work, the entry supervisor must ensure that all workers and other trades in nearby areas which may be affected by the work activities in the confined space are notified and are aware of the confined space entry.

If the results of the work inside the confined space pose a serious hazard to outside workers, then other means of controlling the work activities must be used such as erecting barriers, restricting working times either for workers inside the confined space or outside or using alternate control measures such as additional fans for venting.

Whatever the situation, it is imperative that constant communications be established and maintained with the entry supervisor or designate and the adjacent workers who are potentially affected.

All work activities which are not routine must be planned well ahead of the scheduled start date of those activities.

Management will coordinate with the supervisor that any specialized equipment, such as specific filters for respirators, can be obtained early on.

This lead-time is required to ensure that workers affected by the scope of work inside the confined space can be trained on any new equipment or procedures that will be required for the duration of work within the confined space.

Under no circumstances will any work be conducted in a confined space without the authorization of the Supervisor.

Sub-contractors

Sub-contractors have the responsibility to ensure that they have reviewed the requirements in Part 9 of the OH&SR and the requirements within this section prior to commencing any work in confined spaces. This includes conducting hazard assessments and preparing entry procedures and permits for their workers.

Contractors are also responsible to ensure that all workers who will be entering confined spaces have adequate training, supervision, and PPE prior to entry. Check to ensure the site requirements are met.

When entering confined spaces, subcontractors are responsible to identify and implement proper controls for safe operation and submit the hazard assessment and entry procedures to us prior to entry.

General Requirements

Initial Determination

Our Company will:

  1. Identify all confined spaces that may exist on any site.
  2. Appoint a competent individual to identify and assess the hazards the worker(s) is likely to be exposed to while in the confined space and perform appropriate atmospheric testing and confined space inspections.
  3. Determine whether each confined space requires entry by a worker, either in scheduled work activities or as a result of foreseeable system failures or other emergencies.

Prohibited Entry

For confined spaces that will not require entry, we will ensure that each point of access to the confined space is secured against entry or identified by a sign or other effective means which indicates the nature of the hazard and the prohibition of entry, and that workers are instructed not to enter.

For sites under control by a different company, or when it's not applicable for our company to post signs or secure access, workers are to be made aware of the above point in a way that will make them able to identify all confined spaces at the workplace, understand the hazards of these spaces and any prohibition of entry.

Control of Hazards

Our Company will ensure that all confined space hazards are eliminated or minimized, and that work is performed in a safe manner. For confined spaces which do not have an entry procedure, one will be developed by our Company Representative in conjunction with a qualified person prior to any entry into the confined space.

Confined Space Entry Program

Our Company has prepared and implemented a written confined space entry program which includes:

  1. An assignment of responsibilities.
  2. The procedure for identifying confined spaces or groups of similar spaces on site and the procedure for completing a hazard assessment on those spaces.
  3. Written safe work procedures for entry into and working in the confined space, that address, where applicable:
    • Identification and entry permits.
    • Lockout and isolation.
    • Verification and testing.
    • Cleaning, purging, neutralizing or venting.
    • Ventilation.
    • Standby persons.
    • Rescue.
    • Lifelines, harnesses and lifting equipment.
    • Personal protective equipment and other precautions.
    • Coordination of work activities.
Hazard Assessment and Entry Procedures

Qualifications

The hazard assessment and written confined space entry procedures will be prepared:

Identification of Access Points

When a confined space requires entry by a worker, each point of access which is not secured against entry will be identified by a sign or other effective means which indicates the hazard and prohibits entry by unauthorized workers.

Hazard Assessment

A hazard assessment has been completed on all confined spaces considered non-prohibited entry. For spaces not yet identified or which are currently classified as prohibited entry, a hazard assessment will be completed by a qualified person.

It is possible that the work activities required in a confined space may not be consistent with those that were assumed during the original hazard assessment. In these cases, a hazard assessment will be conducted for the work activity to be performed inside a confined space.

This hazard assessment will:

  1. Consider the conditions which may exist prior to entry due to the confined space's design, location, or use, or which may develop during work activity inside the space, and
  2. The potential for oxygen enrichment and deficiency, flammable gas, vapour or mist, combustible dust, other hazardous atmospheres, harmful substances requiring lockout and isolation, engulfment and entrapment, and other hazardous conditions.

Procedures

Written procedures specifying the means to eliminate or minimize all hazards likely to prevail have been developed based on the hazard assessment. The procedures should address:

  1. Identification and entry permits
  2. Lockout and isolation
  3. Verification and testing
  4. Cleaning, purging, venting, or neutralizing
  5. Ventilation
  6. Standby persons
  7. Rescue
  8. Lifelines, harnesses and lifting equipment.
  9. PPE and other precautions
  10. Coordination of work activities
When Permits are Required

An entry permit verifies that all required procedures have been reviewed with those entering the space and that all other precautions, such as emergency rescue, have been arranged and are understood. By posting a permit, workers are informed of the hazards of the space and what control measures are in place.

The permit also serves as a record of atmospheric testing and then entry and exit of designated workers. The permit also names the entry supervisor who is responsible for every aspect of the entry. The permit also acts as a final checklist for precautions required and taken with regards to safe entry to the confined space named on the permit.

An entry permit will be completed and signed by the entry supervisor before a worker enters a confined space with a high hazard atmosphere.

An entry permit will be posted at each designated point of entry to a confined space, except when:

Contents of a Permit

Confined Space Entry Permit and Atmospheric Test Record details the information which is required for safe entry to a confined space on our site.

Updating the Information

Once issued, the information on an entry permit will only be altered by:

  1. The responsible supervisor who signed the permit to update it in accordance with points 2 or 3 below,
  2. The standby worker is to update the list of workers inside the confined space, or
  3. The tester records test results.

Entry permits will be reviewed and updated as necessary to ensure the ongoing safety of the workers inside the space.

The permit will be re-authorized and signed by the responsible supervisor:

  1. If there is a change in the work crew,
  2. After each shift change, or
  3. After a change of the responsible supervisor.

Every worker affected will be informed of an alteration of an entry permit regarding a change in the required precautions or work activity.

Emergency situations may invalidate your permit, check with site management.

Record of Permit

Upon completion of the scope of work, return the entry permit to our Company Representative for finalization. The entry permit will be kept for one (1) year from the date the permit expires.

Lockout and Isolation

Lockout

Prior to entry to a confined space for any reason, all machinery which is inside the space or adjacent to it must be locked/tagged out. Adjacent machinery does not require locking out if it does not, in any way, affect the confined space during normal operation. This lockout applies to conveyance equipment or any other equipment that causes any material to enter the confined space. All material conveyance equipment that transports material to or from the space will be free of material and the equipment will be locked out. Lockout is in accordance with the applicable lockout procedure and must be verified by the entry supervisor prior to accessing the confined space. Each worker entering the space will apply his/her personal lock to the locking device. Entry supervisors must ensure that workers are only entering confined spaces that have been locked out as detailed in the lockout procedure for the machinery within that space and that the lockout has been verified by the entry supervisor prior to entry.

Isolation

Before a worker enters a confined space, adjacent piping which contains or has contained a harmful substance will be controlled as detailed in the entry procedure for that space.

We will maintain records which identify the location of every isolation point. Every isolation point must be visually checked or otherwise verified to ensure that the confined space is effectively isolated before a worker enters the space. The application of required isolation for a confined space will be verified by the entry supervisor prior to entry. Follow WorkSafeBC OH&S Regulation 9.18 on the required method of isolation for adjacent piping.

Verification and Testing

Verifying all Precautions

Before a worker enters a confined space, pre-entry testing and inspection will be conducted to verify that the required precautions have been effective at controlling the identified hazards and that it is safe for a worker to enter. The entry supervisor will sign off on the entry permit that all testing has been verified and that the confined space is safe for entry.

Testing the Atmosphere

Before a worker enters a confined space, entry supervisors will ensure that the atmosphere in the confined space is tested using the appropriate testing medium and recommended flow rate. The pre-entry testing will be:

  1. Conducted as specified in the entry procedure ensuring all levels are tested.
  2. Completed not more than 20 minutes before a worker enters a confined space.
  3. Completed if all workers have vacated the confined space for more than 20 minutes as detailed in 2 above.
  4. Conducted as necessary to ensure the worker's continuing safety while a worker is inside a confined space with a moderate or high hazard atmosphere.

Whenever practicable, continuous monitoring of the atmosphere will be done. And it must be done if a worker enters a confined space with a moderate or high hazard atmosphere.

Procedures and Equipment

With regards to atmospheric testing inside confined spaces, our Company through the site management will ensure:

  1. Testing is carried out by an adequately trained worker.
  2. Test records show the date and time of the test, the initials of the tester and the levels or conditions found.
  3. Test results, other than continuous monitoring results, will be posted without delay at all points of entry to the confined space.
Cleaning, Purging, Neutralizing and Venting

When practicable, we will ensure that a confined space to be entered contains clean respirable air.

If a confined space is known, or has shown by pre-entry testing, to contain other than clean respirable air, the hazard will be controlled by cleaning, purging, neutralizing, or venting the space and the atmosphere will be retested before a worker enters the space to ensure that it lies within the guidelines and regulations.

Risk Control

If clean respirable air cannot be assured in a confined space before entry, we will ensure that:

  1. All workers entering the space wear appropriate personal protective equipment including respirators as determined by concentration of contaminants.
  2. The concentrations of flammable gases and vapors are maintained below 20% of the lower explosive limit.
  3. If flammable or explosive gases, vapors or liquids are present, all sources of ignition are eliminated or adequately controlled.
Ventilation

Continuous Ventilation

Every confined space will be ventilated continuously while a worker is inside the space, except in:

  1. An atmosphere intentionally neutralized in accordance with OH&S Regulation 9.29.
  2. A low hazard atmosphere controlled in accordance with OH&S Regulations 9.31(2).
  3. An emergency rescue if ventilation is not practical.

Low Hazard Atmospheres

Our Company will ensure that a minimum of 50 cubic feet per minute of clean respirable air is supplied for each worker inside a confined space with a low hazard atmosphere, except as permitted in OH&S Regulation 9.31(2).

Continuous ventilation is not required in a confined space which has a low hazard atmosphere, if:

  1. The atmosphere is continuously monitored and shown to contain clean respirable air.
  2. The space has an internal volume greater than 1.8 m³ (64 cu ft.) per occupant.
  3. The space is occupied for less than 15 minutes.
  4. The work inside the space generates no contaminants other than exhaled air.

Mechanical Ventilation

The requirement to have continuous mechanical ventilation within a confined space will be detailed in the entry procedure for each confined space. Under no circumstance will any worker enter a confined space that requires continuous mechanical ventilation unless that equipment is in place and working in accordance with manufacturer's guidelines and the requirements of the entry procedure.

General ventilation will be used for keeping the confined space safe for workers inside. It is important that regular inspection and maintenance be performed on these systems to ensure they are operating correctly and are moving the required amount of air through the confined space.

When using mechanical ventilation, it is important to ensure that the exhaust from the confined space is being blown in an area where there is no chance of contamination of other workers who will likely not have the required PPE to protect them from the hazard.

There may be a requirement to have Local Exhaust Ventilation (LEV) or Wet Dust Suppression (WDS) for specific types of work, such as welding or drilling/grinding/cutting bricks or concrete. This requirement will be detailed in the entry procedure. As with general ventilation it is imperative to ensure that the exhaust from the LEV is not blown onto unsuspecting workers or the intake of the general ventilation system.

Natural Ventilation

If natural ventilation is relied upon for the control of airborne contaminants in a confined space, the rate of airflow through the space will be monitored and will be sufficient to maintain concentrations of airborne contaminants below the applicable exposure limits.

Workers assigned to monitor the air flow through a space using natural ventilation must ensure they are aware of the protocols to follow if the air flow goes below the prescribed level detailed in the entry procedure.

Natural ventilation will not be used:

Ventilation Precautions

Physical Hazards

Spaces which can pose a physical hazard to workers entering them, will have specific details on controlling those hazards within the entry procedure for that space.

Written entry procedures must consider the following points for spaces which may contain a physical hazard to workers:

Personal Protective Equipment

Required PPE

Personnel who enter confined spaces will have the required PPE issued to them. Entry supervisors will ensure that workers are wearing the required PPE prior to entry and during their time they are in the confined space.

The entry procedure for the confined space will detail any specialized PPE that is required for entry. PPE such as safety footwear and hard hats will be the responsibility of the individual worker.

All PPE must be maintained and used in accordance with the manufacturer's instructions. Our supervisors and safety personnel must inspect this PPE regularly to ensure that it is in good condition and functions properly.

Respirators

If it is not possible to have clean, respirable air inside the confined space prior to entry or while workers are inside the space, then suitable respirators will be provided to each worker who may be required to enter a confined space.

Only qualified people will be permitted to use respirators within confined spaces on our site. All workers must complete a training program which includes fit testing, proper use, maintenance, and storage.

Full Body Harness

A full body harness with shoulder D-rings will often be required inside a confined space as a means to retrieve and rescue a worker from inside the confined space. Entry Procedure will identify the conditions in which such harness will be used, and the rescue system required for the space.

Stand-by Worker

Low Hazard Atmosphere

If a worker enters a confined space which contains a low hazard atmosphere:

Moderate Hazard Atmosphere

If a worker enters a confined space which contains a moderate hazard atmosphere:

High Hazard Atmosphere, Engulfment or Entrapment

If a worker enters a confined space which contains a high hazard atmosphere, a risk of engulfment or entrapment or with any other recognized serious health or safety hazard:

Rescue

Rescue Services

Before any Confined Space Entry, rescue personnel must be identified, trained, and adequately equipped to perform rescue duties. Prior to any work commencing in confined spaces on our sites, the Fire Department in the local area must be contacted to determine if they provide confined space rescue services. If they do, then an agreement must be formulated and signed by the applicable managers detailing exactly what the rescue services consist of and what the expected response times will be.

A protocol must be agreed upon with regards to summoning rescue services. The procedure must be documented and posted on site and be available on all entry procedures and entry permits, if issued.

Summoning Rescue

The following information is required when contacting emergency services for a confined space rescue:

In the event that the local Fire Department does not provide confined space rescue services, we will ensure that sites which will have confined spaces have adequately trained personnel on site to effectively rescue workers within confined spaces should the need arise.

Equipment and Training

Every person assigned rescue duties will be properly equipped and adequately trained to carry out such duties. A practice drill will be conducted at least annually, and records of training and practice drills will be maintained by our site management. This requirement is for both internal and external rescue teams.

Our Company's Management, through site management, may request to review the personnel training and practice records of the local Fire Department with regards to confined space pursuant to the Applicable Workplace Health and Safety Regulation.

Notification of Confined Space Entry

Before a worker enters a confined space, our site superintendent will be notified of the confined space entry. This notification will be in the form of a letter stating as a minimum:

As well as the above points the letter will also include a copy of the hazard assessment, the entry procedure and the entry permit for the confined space. This letter will be sent out in such a time frame to allow at least one (1) week before the scheduled entry to the space.

We must be assured they understand the nature of the confined space entry and what will be required of them if we call for a rescue. A written response is required as it will become part of the entry documentation.

In the event that there are multiple spaces being entered simultaneously the same procedure as stated above will be followed with the exception that each space must be named along with the entry supervisor for that space and all applicable documentation must be sent for each space to the site management for review and response.

Contractor Responsibility

All contractors on our sites who must enter a confined space must have completed a hazard assessment and developed entry procedures specific to the confined space in question. This documentation must be reviewed by our site management prior to any entry.

Contractors are to ensure that all personnel who will enter the confined space will have adequate training in confined spaces. This training must be documented and be available for review at the request of our site management.

Summoning Rescue – Internal Rescue Team

If the situation inside the confined space is immediately dangerous to life or health the entry supervisor will notify the emergency rescue team to the confined space. The supervisor of the emergency rescue team will participate in all meetings that take place prior to the entry to the confined space.

The emergency rescue team lead will also review the entry procedure and be familiar with how to access the confined space and what equipment will be required to facilitate a rescue. The emergency rescue team will then have a crew talk no more than 24 hours before the scheduled entry to ensure all team members understand what is required of them in the event of an emergency requiring a confined space rescue.

Rescue Procedures

These procedures apply only to those situations where our Company's personnel are rescuing a worker who is in a confined space which has become immediately dangerous to life or health. If the worker's life or health are not in immediate danger, then wait for emergency services to attend.

Rescue procedures will apply and every possible effort to eliminate, control or reduce the risk to emergency personnel responding to emergency situations including the use of mechanical ventilation. These procedures, if applicable, will be detailed in the entry procedure.

Lifelines, Harnesses and Lifting Equipment

Lifelines, harnesses and lifting equipment are required when entering a confined space which contains a high hazard atmosphere, a risk of entrapment or engulfment or with any other recognized serious health or safety hazard. Workers will wear a harness of a type which will keep the worker in a position to permit rescue. This will be a harness which has D-rings on the shoulders.

The following points will be adhered to when this equipment is in use:

Harnesses, lifelines and lifting equipment will meet the requirements of standards acceptable under the Workplace Health and Safety Regulation. If one or more workers enter a confined space, provisions will be made to prevent the entanglement of lifelines and other equipment.

If rescue cannot be affected by the Stand-by worker(s) using harnesses, lifelines and lifting equipment and the situation warrants, then one or more member of the emergency rescue team will be stationed at the entrance to the confined space equipped and capable of entering the space and affecting a rescue.

CANWIDE STEEL
OHS PROGRAM
Appendix O
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
APPX OCreated: Apr/2025Last rev: ---Rev. 2.21 of 3
APPENDIX O – CRANE
Policy Statement

Management and Superintendents will plan and coordinate to ensure those who work around, in, or with cranes are experienced, certified, and physically fit according to guidelines outlined in the OH&S Regulation and industry best practices.

Processes critical to crane installation and operations include:

  1. Conducting a Pre-Crane Erection Meeting. This meeting will review the scope of work and ensure the applicable parties involved understand the expectations for erecting and use of the crane.
  2. Ensure a designated person will be submitting the Notice of Project for any tower crane activity such as erection, climbing, repositioning and dismantling, at least 2 weeks prior by accessing WSBC website.
  3. A professional engineer to certify that the crane foundations and underlying soil are adequate support for the tower crane with its maximum swing radius.
  4. A Crane Safety Plan must be developed and must include information such as no fly zones, loading and unloading areas, swing radius zones, multiple crane coordination, site specific hazards such as overhead lines and high voltage powerlines.
  5. Ensuring the applicable parties responsible for providing the required documents prior to erecting the crane submits the documents prior to the erection date. Refer to the Tower Crane or Self Erect Crane Checklist.
  6. Tower cranes shall be erected, jacked/de-jacked and dismantled under the immediate supervision of a qualified crane supervisor, designated by the employer, and reviewed with all parties involved.
  7. Tower cranes shall be erected, maintained, and used in accordance with the manufacturer's specifications, recommendations, and procedures. All modifications shall be approved by the manufacturer and engineered by a professional engineer. The crane plates and charts must reflect modifications.
  8. All personnel involved in crane erection or dismantlement must comply with their supervisor's instructions.
  9. Wire rope, rigging components, boom structures of the cranes must be inspected, and documentation kept on site. Annual certification by a professional engineer is required for all components of the crane.
  10. Conducting a Post-Crane Erection Meeting. Prior to operating the crane, the required documents as per the checklist must be readily available, reviewed and signed by applicable parties. This includes erector's report and site-specific procedures.
  11. Ensure WSBC is notified that a crane has been installed so an inspection of the crane can be done.
  12. Pre-shifts, weekly and monthly are recorded in the crane logbook.
  13. Supervisors of crane operators are responsible to ensure proper training, including the certification, orientation of the crane to the operator and a competency assessment for the operator completed.
  14. Proper inspections prior to, during, and after use are recorded in each crane's logbook.
  15. Ensure radio communications are in good working condition by doing a radio check. There must be a designated two-way radio system used for communications between the operator of a tower crane or a self-erecting tower crane and the riggers and signalers working with that operator. Multi-channel radios are not permitted for use to direct crane or hoist movement. Radio communication should always be concise and professional.
  16. An exclusion zone must be set up when crane maintenance or repair work is done that may pose a danger to those working in the area.
  17. When two cranes are working on either the same job site or adjacent sites, overlapping procedure is required if there is potential for contact with the other crane.
  18. Power Lines Regulations must be always adhered to and SJP for working around power lines must be established on site.
  19. All loads must travel in a safe manner and proper warning given by utilizing the crane horn system to warn others.
  20. Public road work requires personnel to comply with Municipal Requirements and the OH&S Regulation.
  21. Blind lifts require the crane operator to maintain constant communications with the rigger and any other workers assisting with the lift.
  22. Fall Protection Equipment and procedures may be required for work at heights.
  23. Crane operators must always comply with company policy. Safe work practices are a condition of employment for all crane operators and their riggers.
  24. An eye exam and physical fitness evaluation may be required on occasion.
  25. Crane operators are responsible for reporting any unsafe conditions to their supervisor as soon as possible.
Logbooks

Crane operators and riggers must complete their daily inspections and document findings in their logbooks. Any concerns found during the inspection must be reported to a supervisor immediately. Logbooks must be completed in full each day, and as soon as practicable.

The crane operator logbook and rigger logbook should be reviewed by the Supervisor/Safety manager prior to crane operation to ensure they are consistent with WorkSafeBC and site expectations.

These documents are reviewed weekly by the Supervisor to ensure that they are being completed correctly and consistently.

Crane Operation

Crane operators must be certified and qualified to operate the equipment.

Any person working as a crane operator on our work sites must be qualified to do so by demonstrating a good understanding of safe crane operating practices and procedures.

Rigging

Any person working as a rigger on our work sites must be qualified to do so by demonstrating a good understanding of safe rigging practices and general safety when working with cranes.

Riggers must complete the Rigger Qualification to confirm competencies and adhere to the following:

  1. Understand the different rigging methods and apply them correctly to each load lifted.
  2. Know the weight and center of gravity for each load lifted.
  3. Choke method on all loads, unless otherwise stated by the delivery agent, using chain or synthetic slings.
  4. Inspect all slings before use.
  5. Maintain the optimum lifting angle of 60° or greater is preferred. This angle is measured from the top of the load (where the sling is attached) to the sling leg.
  6. Double wrap slings if slippage is expected, avoid using excessive force on slings. When choking a load, do not beat down the sling.
  7. Wire rope slings are the preferred method for lifting reinforcing bars.
  8. Use tag lines if rotation of the load is anticipated. Workers retrieving tag lines may be exposed to a fall hazard in which fall protection systems such as fall restraint are required.
  9. Climbing forms is not permitted even when unhooking slings from lifting points.
  10. Secure all formwork before removing rigging. Slings are not to be unhooked from formwork until the formwork is secured.
  11. Store forms leaning against an A Frame or a wall or laid on the ground to prevent tip-over.
  12. Check the balance of the load.
  13. Never use forks unless deemed qualified and under direction of an experienced supervisor.
  14. Notify all personnel of overhead loads. Affected workers must be notified prior to the load flying over them.
  15. Remove all concrete from forms prior to them being flown.
Application

These guidelines are applicable to the following types of cranes:

CANWIDE STEEL
OHS PROGRAM
Appendix P
OCCUPATIONAL HEALTH AND SAFETY PROGRAM
APPX PCreated: Apr/2025Last rev: ---Rev. 1.01 of 8
APPENDIX P – RESPIRATORY PROTECTION PROGRAM
Policy Statement

Several construction activities in our operation may expose workers to hazardous levels of airborne contaminants, that if left uncontrolled, can have serious, short and long term effects on workers' health, and may eventually lead to cancer or other irreversible health conditions such as silicosis.

We will implement engineering controls when and where practicable in order to manage such exposure hazards, and in many cases, respiratory protection will be required in addition to such engineering controls.

This program has been written and implemented in order to ensure that:

  1. Respirators and cartridges are selected according to the hazards, made accessible and ready for use.
  2. Respirators used by our workers provide effective protection against airborne contaminants on our sites.
  3. Respirators are maintained, stored and in good operating condition as per manufacturer's instructions.
  4. Respiratory risks are assessed, controlled, and workers are protected from inhaling a hazardous atmosphere.
  5. Workers are instructed in respiratory hazards, and how to use their respirators effectively.

We are committed to ensuring that workers are not exposed to airborne concentrations in excess of their applicable exposure limits, as listed in the legislated regulations, and that exposure is reduced to as low as reasonably achievable, when required, by applying applicable engineering controls in addition to providing workers with respiratory protection.

All employees who are performing any work which may require the use of respirators are required to review the respirator program and comply with all requirements of this program as well as the regulatory requirements.

Employers on site are required to provide their own respiratory protection program applicable to their scope of work, and provide their workers with the proper equipment, fit testing and training identified in such program. Under no circumstances will any of our workers be allowed to work with any material, equipment or process that generates hazardous air contaminants without proper controls in place, which may include respiratory protection.

Respirators will NOT be used as primary control for airborne contaminants.

Responsibilities

Employer

Canwide Steel is responsible for:

Program Administrator

A designated person will be the administrator of this program, who may enlist the services of a qualified person, internal or external, to review this program at least annually. The program will also be reviewed when conditions change, new hazards introduced, or as a result of corrective actions resulting from accident investigations or from workplace or WorkSafeBC inspections. The program administrator will be responsible for:

Supervisors

Supervisors are responsible for ensuring that:

Worker – This section applies to ALL respirator users, including supervisors when using a respirator.

Workers/Respirator users are responsible for:

Person Selecting Respirators

For this Respiratory Protection Program, respirators have been selected by the program administrator, by enlisting the services of an external consultant, for assessment of respiratory hazards in the workplace. The person selecting respirators:

Respirator Fit Tester

These responsibilities apply to personnel performing fit testing, internal or external. For external fit testers, the program administrator will ensure competent fit testing providers are selected, and that they are aware of the requirements below as per CSA 94.4 and this respiratory protection program.

Risk Assessment

Breathing Hazards – When Respirators are Required

Below are respiratory hazards that would require the use of respiratory protection in our workplaces:

Within our operations, respiratory protection will be required when:

Note: the below situations are NOT applicable to our operations or work environment:

Respirator Selection

Respirators:

Filters/Canisters:

Workers are instructed on how to identify the correct filters by checking the labels, and by the color code of P100, being MAGENTA, as defined by NIOSH.

Filters will be available with the supervisor and workers are instructed on replacing their filters whenever breathing becomes difficult.

Training

Every respirator user will be trained on how to effectively use their respirators, as part of their fit testing. This training will include:

  1. Applicable respiratory hazards.
  2. Description of the selected respirator.
  3. Description of the selected filters, and how to identify.
  4. Pre-use inspection, and when to replace respirators and filters.
  5. The intended use and limitation of respirators.
  6. Proper donning, inspection, adjustment, seal-checking, doffing of their respirators
  7. Cleaning and storage.

This training should be repeated as often as necessary, at least annually, to ensure that employees remain familiar with the proper use of respirators. A record of this training must be kept on file.

Fit Testing

Fit Testing Records

Fit tests must be documented with records available on site, for each make, model, or size used by the respirator user. Records will show:

Procedures

Irritant smokes will be used. The instructions and challenges provided in CSA Z94.4 will be followed:

Use of Respirators

The basic pre-conditions and procedures for respirator use are:

  1. Workers must be clean-shaven where the respirator face piece seals to the skin.
  2. Each time the respirator is worn, the respirator user will perform a positive or negative seal check.
  3. Do not use any covering that passes between the sealing surface of a respirator and the worker's face.
  4. Other required personal protective devices and/or equipment must not interfere with the seal between the face piece and the face of the worker.
  5. When wearing a respirator, users experiencing any of the following will immediately leave the contaminated area and report to supervisor:
    • Nausea.
    • Dizziness.
    • Eye irritation.
    • Unusual odour or taste.
    • Excessive fatigue.
    • Difficulty breathing.
  6. Respirators will be inspected before and after every use for physical condition as well as general cleanliness.
  7. Users, who notice a resistance to breathing or the smell or taste of the contaminant within the respirator will leave the immediate work area and report to their supervisor at once. After an investigation rules out other reasons, such as failure of ventilation systems, the respirator shall be checked and new filters or cartridges installed.
  8. All users must review the respirator manufacturer's instructions.
  9. Any worker who reported any medical or health-related reasons they cannot use a respirator, will be assigned alternate tasks that do not require respiratory protection.
  10. No respirators will be shared between users.
  11. Respirators to be cleaned and stored following the instructions in this program.
Cleaning, Inspection, Maintenance, and Storage

Always check manufacturer's instructions on cleaning, storage and maintenance of respirators.

Cleaning Procedure

  1. Remove filters. Wipe them with a damp lint free cloth from the outside only. Never wash filters
  2. Wash the respirator in lukewarm water. Use only mild soap if needed.
  3. Dry by hand or place on a flat dry cloth or paper towel and let air dry. Do not dry in the sun, oven or any direct heat.

Inspect Respirator for:

Storage of Respirators

Store respirators, cartridges and respirator parts in a clean dry re-sealable plastic bag away from contaminants, heat, humidity or heavy tools that might physically damage the respirator. If respirator is wet, wipe with clean, dry, lint-free cloth before placing in the plastic bag.

Maintenance

Supervisors will ensure adequate stock of respirators and filters is available on site for replacement when needed. Workers are instructed to report to their supervisor any damaged or non-functioning respirators, requiring spare parts or replacement.

Workers are instructed to not repair or alter their respirator in any way, and report to supervisor when damaged for replacement.

Health Surveillance
Program Evaluation

This respiratory protection program will be reviewed and evaluated to ensure effectiveness in the following conditions:

  1. At least annually
  2. When new tasks are introduced that may involve respiratory hazards
  3. When new respiratory hazards are introduced in the workplace
  4. When there are reasons to doubt its effectiveness
  5. After incidents of exposure
  6. After any corrective action that result from an accident investigation, a workplace inspection, or a WorkSafeBC inspection.
Recordkeeping

Records will be kept of the following: