Reviewed and Revised: June 11, 2026
29 CFR 1910 & 1926
Construction Safety Program
The safety policy of Rice Mohawk Steel (RMS) is not intended to supersede the requirements
of the standards. Employees should review the standards for particular requirements which
are applicable to their individual situation. Rice Mohawk Steel will allot a reasonable amount
of time during regular work hours for employees to review the regulations, standards and
RMS’s safety policy and attachments.
Rice Mohawk Steel will make adjustments to this program as required.
Rice Mohawk Steel will review and revise this policy as needed or annually in order to
maintain a comprehensive program.
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1910.1926
Construction Safety
Policy
Table of Contents
I. Objective
II. Policy
III. Applicability
IV. Implementation
V. Administration
VI. Training
VII. Reporting Injuries
VIII. Notifications
IX. Basic Safety Rules
X. Enforcement of Safety Policy
XI. Attachments
A. Job Safety Checklist
B. Safety Equipment Checklist
C. Safety Meeting Report
D. Employee Acknowledgment
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I. OBJECTIVE
The Safety Policy of RMS is designed to comply with the Standards of the Occupational Safety
and Health Administration, the Kahnawà:ke Department of Occupational Safety and Health
and, to comply with the Kahnawake Mohawk Self Insurance Division to maintain a safe and
injury/illness free workplace. A copy of the OSHA Safety and Health Standards 1910 and 1926
are available for all employees use and reference. These Standards shall be available in the
home office at all times and will be sent to the jobsite on request. Jobsites lasting more than 15
consecutive days will maintain a copy of the standards on site at all times.
Compliance with the following Safety Policy and all items contained therein is mandatory
for all employees of the company. The authorization and responsibility for enforcement has
been given primarily to the foreman of each jobsite as employee safety representative and
responsible person, unless otherwise noted.
II. POLICY
It is our policy that accident prevention be a prime concern of all employees. This includes
the safety and well being of our employees, subcontractors, clients and visitors, as well as
the prevention of wasteful, inefficient operations, and damage to property and equipment.
III. APPLICABILITY
This Safety Policy applies to all employees of Rice Mohawk Steel, regardless of position within
the company. The Safety Rules contained herein apply to all subcontractors and anyone who
is on a company project site.
Every employee is expected to comply with this Safety Policy, as well as the OSHA Safety and
Health Standard and where applicable the Act Respecting Occupational Health and Safety
(Quebec), Canada Occupational Health and Safety Regulations (SOR/86304) and all other
regulations and codes which may apply.
IV. IMPLEMENTATION
This Safety Policy supports the following fundamental means of maximum
employee involvement:
A. Management commitment to safety.
B. Effective job safety training for all categories of employees.
C. Weekly toolbox safety meetings at all jobsites.
D. Job hazard analysis provided for all employees.
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Responsible Person means: The person responsible at each jobsite for implementing the
RMS safety program.
The Responsible Person will meet at least once a month to evaluate all areas of safety and
make recommendations to the company president or other senior management official.
V. ADMINISTRATION
The Safety Policy will be carried out according to guidelines established and published in
this and other related procedures. Specific instructions and assistance will be provided by
the Responsible Person as requested. Each supervisor will be responsible for meeting all of
the requirements of the Safety Policy, and for maintaining an effective accident prevention
effort within his or her area of responsibility. Each supervisor must also ensure that all
accidents are thoroughly investigated and reported to the Responsible Person on the same
day of the occurrence.
VI. TRAINING
All new employees will be required to attend a safety orientation session prior to accessing
the work areas. This orientation will address jobsite hazards and prevention, task hazards,
specific trainings required by law and the OSH regulations. Some jobs may require both
OSHA and Canadian and Provincial regulations.
VII. REPORTING OF INJURIES
All employees will be held accountable for filling out a company “Notice of Injury Form" and
“Kahnawake MSI forms” immediately after an injury occurs or as soon as possible depending
on type or severity of injury even if medical treatment is not required. (Notice must be made
at or near the time of the injury and on the same day of the injury.) Employees must report the
injury to their supervisor, project manager, etc. A casual mentioning of the injury will not be
sufficient. Employees must let their supervisor know:
A. How they hurt themselves.
B. What they were doing at the time.
C. Who they were working with at the time.
D. When and where it happened.
E. Other pertinent information that will aid in the investigation of the incident.
Failure to report an injury immediately (meaning at or near the time of the injury and on
the same day of the injury) is a violation of the Safety Policy, and may result in immediate
termination.
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VIII. NOTIFICATIONS
A. In Case of Serious Injury or Death
After the injured has been taken to the hospital, the supervisor shall notify the main
office and the Responsible Person as soon as possible. Statements from witnesses shall
be taken. Statements are to be signed by witnesses and should include the time and
date. Photographs of the area where the incident occurred and any other relevant items
are to be taken. The Responsible Person will assist in the investigation. The completed
accident report form will be sent to the main office.
B. In Case of Inspection by OSHA/KDOSH;
The supervisor must notify the Responsible Person that an OSHA/KDOSH Compliance
Officer is on the jobsite. It is the responsibility of all employees to make the inspector’s
visit on the jobsite as pleasant and timely as possible.
IX. BASIC SAFETY RULES
A. Compliance with all applicable Kahnawà:ke or provincial, federal, client and
company safety rules and regulations is a condition of employment.
B. All injuries, regardless of how minor, must be reported to your supervisor and the
Responsible Person immediately. An employee who fails to fill out a "Notice Of Injury
Form" can be issued a safety violation notice and may be subject to termination,
in accordance with company policy. In the event of an accident involving personal
injury or damage to property, all persons involved in any way may be required to
submit to drug and blood alcohol content testing.
C. Hard hats will be worn by all employees on the project site at all times. The bill of
the hard hat will be worn in front at all times. Alterations or modifications of the hat
or liner are prohibited. Crane operators, when in an enclosed cab, have the option
of not wearing a hard hat due to the possibility of obstruction of view.
D. Safety glasses will be worn as the minimumrequired eye protection at all times.
Additional eye and face protection such as monogoggles and face shields are
required for such operations as grinding, jack hammering, utilizing compressed air
or handling chemicals, acids and caustics. Burning goggles for cutting, burning or
brazing and welding hoods for welding, etc., are required.
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E. Fall Protection Requirements
1. In general, full body harnesses and lanyards shall be worn and secured any
time there is a fall hazard of more than four (4) feet in general industry and six
(6) feet in construction industry.
2. Lifelines shall be erected to provide fall protection where work is required in
areas where permanent protection is not in place. Horizontal lifelines shall be a
minimum of 2inch diameter wire rope. Vertical lifelines shall be 3/4 inch manila
rope or equivalent and shall be used in conjunction with an approved rope
A. Clothing must provide adequate protection to the body. Shirts must have at least a
tee sleeve. Shirts with sleeves and long pants will be worn at all times. No shorts are
to be worn on projects. All employees, except welders and burners, must tuck shirt
tails inside trousers. Burners and welders will not be permitted to wear polyester
or nylon clothing. Sturdy work boots with rigid, slip resistant soles are required. No
clogs, tennis shoes or loafers are permitted. Steeltoed tennis shoes with the ANSI
label are the only alternative to the leather work boot.
G. All personnel will be required to attend safety meetings as stipulated by project
requirements in order to meet OSHA Safety Standards.
H. Firearms, alcoholic beverages or illegal drugs are not allowed on company
property, in company vehicles or on any RMS jobsite at any time. When drugs are
prescribed by a physician, the Responsible Person should be informed. The use
or possession of illegal drugs or alcoholic beverages on the jobsite will result in
immediate termination. In addition, Incivility and Sexual harassment of any type
towards another person is strictly prohibited and is cause for immediate dismissal
of employment.
I. Housekeeping shall be an integral part of every job. Supervisors and employees are
responsible for keeping their work areas clean and hazardfree. Clean up is required
when a job is finished at the end of the day.
J. Burning and cutting equipment shall be checked daily before being used. Flash
back arresters shall be installed at the regulators on both oxygen and gas bottles.
All gas shall be shut off and hoses disconnected from bottles and manifolds at the
end of the work day. Caps shall be replaced on bottles when gauges are removed.
When gauges are removed and caps replaced, the oxygen and gas bottles shall be
separated into storage areas no less than 20 feet apart with a “No Fire or Smoking"
sign posted and a fire extinguisher readily available. Makeshift field repairs will not
be allowed.
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K. Drinking water containers are to be used for drinking water and ice only.
Tampering with or placing items such as drinks in the water cooler will result in
immediatetermination. The "common drinking cup" is not allowed. Only disposable
cups will be used.
L. All tools whether company or personal, must be in good working condition.
Defective tools will not be used. Usage of personal tools on the jobsite must be
approved by the Responsible Person. Examples of defective tools include chisels
with mushroomed heads, hammers with loose or split handles, guards missing on
saws or grinders, etc.
M. All extension cords, drop cords, and electrical tools shall be checked, properly
grounded with ground fault interrupters (GFI’s). Cords and equipment that do not
meet requirements shall be immediately tagged and removed from service until
repairs have been made.
N. “Horseplay" on the jobsite is strictly prohibited. Running on the jobsite is allowed
only in extreme emergencies.
O. Glass containers or bottles of any kind are not permitted on jobsites.
P. The jobsite speed limit is 10 MPH or 15 Km/hr unless otherwise posted. No employee
is permitted to ride in the bed of a truck standing up or sitting on the outside edges
of a truck. Employees must be sitting down inside the truck or truck bed when the
vehicle is in motion. Riding as a passenger on equipment is prohibited unless the
equipment has the safe capacity for transporting personnel.
Q. Adequate precautions must be taken to protect employees and equipment
from hot work such as welding or burning. Fire extinguishing equipment shall
be no further than 50 feet away from all hot work. Notify the Responsible Person
immediately of used fire extinguishers that need to be returned for recharging. Use
of welding blinds is required in high traffic areas.
R. All scaffolding and work platforms must be built and maintained in accordance
with OSHA specifications. All ladders must be in safe condition without broken rungs
or split side rails. Damaged ladders shall be removed from service. Ladders shall be
secured at the top and bottom and extend three (3) feet past the working surface.
Metal ladders around electrical work are prohibited. A step ladder shall never be
used as an extension ladder. A step ladder must only be used when fully opened
with braces locked.
S. Crowfoot connections on air hoses shall be wired to prevent accidental
disconnection. Compressed air shall not be used to dust off hands, face or clothing.
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T. Report all unsafe conditions and near misses to Responsible Person so corrective
action can be taken.
U. All floor openings or excavations shall be barricaded on all sides to ensure
employees are aware of the hazards. Floor holes shall be covered, with the covers
secured and clearly marked.
V. Warning signs, barricades, and tags will be used to the fullest extent and shall be
obeyed.
W. Scaffold Tag System
1. Green tags are to be placed on 100 percent complete scaffolds with all braces,
locks and hand, mid, and toe rails in place before use.
2. Yellow tags indicate incomplete scaffolds. If scaffold is missing a hand, mid, or
toe board, it must have a yellow tag and employees on it must be tied off at
all times.
3. Red tags indicate scaffolds that are in the process of either being erected or
disassembled. These scaffolds are not to be used at any time.
4. Scaffold tags should be placed in a highly visible location on the scaffolds for
all employees to see.
X. All OSHA Safety Standards will be followed for job processes requiring respiratory
protection. *SEE RESPIRATORY PROTECTION PROGRAM.
Y. All OSHA Safety Standards will be followed during excavation. *SEE EXCAVATION
PROGRAM.
Z. All OSHA Safety Standards concerning confined space entry will be followed. *SEE
CONFINED SPACE PROGRAM.
AA. All OSHA Safety Standards will be followed for job processes requiring fall protection.
*SEE FALL PROTECTION PROGRAM.
AB. All Safety Standards concerning lockout/tagout of energized equipment will be
adhered to in accordance with 29 CFR 1910 General Industry Subpart J, standard
number 1910.147, 29 CFR 1926 Construction Industry Subpart K, standard number
1926.417 and Canadian standard CSA Z46013 as applicable.
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X. ENFORCEMENT OF SAFETY POLICY
Safety violation notice(s) shall be issued to any employee, subcontractor, or anyone on the
jobsite violating the safety rules or regulations by the Responsible Person .
A. Any violation of safety rules can result in suspension or immediate termination.
B. Any employee receiving three (3) written general violations within a six (6) month
period shall be terminated.
C. Issuance of a safety violation notice for failure to use fall protection or for failure to
report a job injury (at the time of the injury) may result in immediate termination, in
accordance with company policy.
It is understood that Rice Mohawk Steel is not restricting itself to the above rules and
regulations. Additional rules and regulations as dictated by the job will be issued and posted
as needed.
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ATTACHMENT A
JOB SAFETY CHECKLIST
The following Job Safety Checklist has been condensed and edited from the Occupational
Safety and Health Act, Part 1926, Construction Safety and Health Regulations.
A. Safety Rules
_________ Hard hats and safety glasses worn.
_________ Shirts with sleeves worn.
_________ Work shoes worn.
_________ Subcontractors' personnel hold safety meetings as indicated by project requirements in
accordance with OSHA Safety Standards.
_________ Work areas safe and clean.
_________ Safety monogoggles/face shields worn when circumstances warrant.
_________ Electrical cords and equipment properly grounded with GFI's in place and checked by a
competent person.
_________ No use of alcoholic beverages or controlled substances.
_________ Subcontractors provide fall protection for their employees in accordance with OSHA Safety
Standards.
_________ All scaffolds built to specifications as established by OSHA.
_________ Excavation/trenches sloped or shored as established by OSHA.
_________ Drug testing of employees involved in accident(s) resulting in personal injury or property damage.
B. Recordkeeping
_________ OSHA/ KDOSH poster "Safety and Health Protection on the Job" posted.
_________ OSHA/KDOSH " 300 Log or Occupational Injuries and Illnesses” posted during the month of
February only.
_________ Hard hat sign posted in a conspicuous manner.
_________ Weekly safety meeting signin logs maintained in a folder with a copy forwarded to the main office
weekly.
C. Housekeeping and Sanitation
_________ General neatness.
_________ Regular disposal of trash.
_________ Passageways, driveways, and walkways clear.
_________ Adequate lighting.
_________ Oil and grease removed.
_________ Waste containers provided and used.
_________ Adequate supply of drinking water.
_________ Sanitary facilities adequate and clean.
_________ Adequate ventilation.
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D. First Aid
_________ First aid stations with supplies and equipment. The expiration dates of supplies checked
monthly. Expired supplies discarded.
_________ Trained first aid personnel.
_________ Injuries promptly and properly reported.
E. Personal Protective Equipment
_________ Hard hats.
_________ Safety Boots/Shoes.
_________ Hearing protection.
_________ Eye and face protection.
_________ Respiratory protection.
_________ Fall protection.
F. Fire Protection
_________ Fire extinguishers charged and identified.
_________ No Smoking signs posted when required.
_________ Flammable and combustible material storage area.
_________ Fuel containers labeled.
G. Hand and Power Tools
_________ Tools inspected.
_________ Power tools properly guarded.
H. Welding & Cutting
_________ Compressed gas cylinders secured in vertical position.
_________ Hoses inspected.
_________ Cylinders, caps, valves, couplings, regulators, and hoses free of oil and grease.
_________ Caps on cylinders in storage in place.
_________ Flash back arresters in place.
_________ Welding screens in place.
_________ Fuel and oxygen cylinders separated in storage.
I. Electrical
_________ All portable tools and cords properly grounded [Ground Fault Circuit Interrupters (GFCI’s)
properly installed].
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_________ Daily visual inspection of caps, ends and cords for deformed or missing pins,
insulation damage and internal damage.
_________ Tests of cords, tools and equipment for continuity and correct attachment of the
equipment grounding connector (GFCI) to the proper terminal made every month
and:
1. Prior to first use.
2. Prior to return to service after repairs.
3. Prior to return to service after incident that may have caused damage to
cord or equipment.
_________ Cords and equipment not meeting requirements immediately tagged and removed from service
until repairs have been made.
J. Ladders
_________ Inspected at regular intervals.
_________ No broken or missing rungs or steps.
_________ No broken or split side rail.
_________ Extend at least 36 inches above landing and be secured.
_________ Side rails of 2 x 4 up to 16 feet, or 3 x 6 over 16 feet.
K. Scaffolding
_________ Inspected at regular intervals.
_________ Footings are a sound ridge and capable of carrying maximum intended load.
_________ Tied into building vertically and horizontally at 14 foot intervals.
_________ Properly cross braced.
_________ Proper guardrails and toe boards.
_________ Scaffold planks capable of supporting at least four (4) times the maximum intended load.
_________ No unstable objects such as concrete blocks, boxes, etc., used as scaffold foundations.
_________ Use of OSHA/KDOSH Scaffold Tagging Program.
L. Guardrails, Handrails and Covers
_________ Guardrails, handrails and covers installed wherever there is danger of employees or materials
falling through floors, roots or wall openings and shall be guarded on all exposed sides.
_________ Posts at least 2 x 4 stock and spaced no more than eight (8) feet apart.
_________ Top rail 42 inches above the floor and of 1 x 4 stock.
_________ Intermediate rail 21 inches above the floor and of 1 x 4 stock.
_________ Guardrail assemblies around floor openings equipped with toe boards. Toe boards at least four
(4) inches above the floor level with no more than 1/4 inch clearance above the floor level, when
there are employees below or when conditions dictate.
_________ Hole covers permanently attached to the floor or structure and identified with a hole cover sign
stenciled with the word “Danger”. Hole covers for holes two (2) inches or greater in diameter
made of at least 3/4 inch plywood or heavier.
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M. Material Hoists
_________ Inspected at regular intervals.
_________ Operating rules posted at operators station.
_________ "No Rider" signs prominently posted at all stations.
_________ All entrances properly protected.
_________ All entrance bars and gates painted with diagonal contrasting stripes.
_________ Experienced operators.
_________ Current crane certification inspection sticker and papers on the rig.
N. Motor Vehicles
_________ Lights, brakes, tires, horn, etc., inspected at regular intervals.
_________ No overloaded vehicles.
_________ Trash trucks have covers.
_________ No riding on the edge of pickup truck beds.
_________ No riding on concrete trucks, loaders, backhoes, etc.
_________ Functioning back up alarms on loaders, tractors, backhoes, etc.
_________ Fire extinguishers installed and readily available.
_________ Seat belts worn at all times.
O. Material Storage and Handling
_________ Material at least two (2) feet from edge of excavation site.
_________ Proper temperature and moisture levels for safe storage of materials to prevent
deterioration or volatile hazards within the storage area.
_________ Inventory maintained and inspected frequently.
_________ Proper protective gear worn when handling chemicals.
P. Concrete, Concrete Forms and Shoring
_________ Full body harnesses as positioning devices for employees tying rebar greater than six feet above
adjacent working surface have
_________ Automatic shut off switches on trowel machines.
_________ No riding on concrete buckets or flying forms.
_________ All forms properly shored.
_________ Single post shores braced horizontally.
Q. Use of Cranes and Derricks
_________ Prohibition of the use of cranes or derricks to hoist employees on a personal platform except in
the situation where no safe alternative is possible.
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ATTACHMENT B
SAFETY EQUIPMENT CHECKLIST
The following is a list of Safety Equipment that should be on the job, if required, or available
from the Responsible person at all times. Equipment should be checked at intervals in
accordance with the applicable OSHA Safety Standards by the Superintendent to ensure that
all required equipment is present and in good condition.
_________ Safety goggles, shields, and glasses.
_________ Hearing protection.
_________ Respirators.
_________ Hard hats.
_________ Fire extinguishers (properly charged).
_________ First aid kit (check list inside kit).
_________ Stretcher or stroke litter (tool room).
_________ Welding masks and goggles.
_________ Storage racks for compressed gases.
_________ Guards on all power tools.
_________ Trash barrels.
_________ OSHA/KDOSH forms posted.
_________ Company "Safety Policy" packet posted.
_________ Company "Hazardous Communication Program" packet posted.
_________ Emergency vehicle (vehicle designated to carry injured to hospital).
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ATTACHMENT C
SAFETY (Toolbox) MEETING REPORT
A safety meeting report is signed to indicate attendance. The form has room for employees
to sign after attending their weekly safety meeting. This form shall be filled out for each
jobsite safety meeting that is held. After completion of the form, make a copy to maintain
at each jobsite and return the signed original copy to the main office.
Safety Meeting Date:________________________________________
Topic:_____________________________________________________
Safety Meeting Conducted
By:_______________________________________________________
Employee Name (printed) Employee Signature Job Title
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ATTACHMENT D
EMPLOYEE ACKNOWLEDGMENT
I state that I have attended the safety orientation, and have read and received a copy of the
Rice Mohawk Steel safety rules and regulations.
I further state that I understand these rules and acknowledge that compliance with the
safety rules and regulations is a condition of employment. If I violate the safety rules or
fail to report an injury to my supervisor immediately, I understand that I am subject to
termination, in accordance with company policy.
__________________________________________
EMPLOYEE SIGNATURE
__________________________________________
DATE
__________________________________________
RESPONSIBLE PERSON SIGNATURE
__________________________________________
DATE
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