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DISCLAIMER

This Safety Handbook is provided to inform and acquaint all employees with Hogan & Associates Construction (“the Company”) and with the Company’s policies, procedures, and practices with regards to safety.

The Company may change any of its policies, procedures, or other matters described in this Safety Handbook or elsewhere with or without notice, at the sole option of the Company, without prior consultation with or agreement by any employee.

Neither this Handbook, any other document, or other policies or procedures shall be construed as constituting a promise from or contract of any kind with the Company, either express or implied, regarding any of the matters addressed in any such handbook or policies.

 
SAFETY MISSION
  • HOGAN VALUES HUMAN LIFE OVER PROFIT.
  • WE INVEST TIME, MONEY, AND OTHER RESOURCES TO SUPPORT THAT VALUE.
  • WE EXPECT EACH OF OUR EMPLOYEES AND SUBCONTRACTORS TO SIMILARLY THINK AND WORK TO SUPPORT THAT VALUE.
 
 
SAFETY HANDBOOK PURPOSE

You will see from the Table of Contents this Safety Handbook covers an array of topics—each designed to help you stay safer on the job.

Read it, study it, review it.

What we cannot include in this Safety Handbook, however, is what it takes to make you think about safety in all you do. Neither Hogan nor OSHA can articulate rules and procedures to cover every circumstance you will encounter on our job sites. Instead, you must preemptively think your way safely through every one of those circumstances you will experience. You must make your safety and the safety of those around you not just your priority, but your reason for being.

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JARED MORGAN, VICE PRESIDENT, SAFETY (801-910-7011)
  1. Oversees the safety of the company and directs training, inspections, and policy
  2. Studies all the State and Federal OSHA requirements in order to be certain Fineline trainings, inspections, and policies are in line with those standards
  3. Maintains all safety records and assures Fineline is in compliance with all such record-keeping regulations
  4. Handles worker compensation claims and light-duty assignments for employees who may be injured at our fabrication facility
JOHN ROUTSON, SAFETY ASSISTANT (385-441-2603) (updated 12/2021)
  1. Working with Jared Morgan, handles the day-to-day safety efforts of the company
  2. Makes certain all safety equipment needed in place (AED, trauma kit, first-aid kit, safety and employment posters)
  3. Responsible to see all safety equipment is present, in proper working condition, and used properly throughout the job duration
  4. Issues and inspects fall protection equipment for the company
  5. Performs site safety inspections
  6. Performs random drug testing
  7. Tracks on-line safety training
  8. Does hands-on safety training
  9. Responsible for self-performing work crew safety training
PROJECT DIRECTORS
  1. Project Directors are the executives over each of our projects. In addition to bringing their considerable construction experience expertise to each job, they bring their safety experience as well.
  2. While regularly visiting and inspecting each job site they oversee, they are also doing informal safety observations.
PROJECT MANAGERS
  1. Project Managers are responsible for the safety of each job they manage.
  2. Working with Jared Morgan, the Safety Assistant, and the Superintendents, they work to reduce risk exposure in general on all their jobs.
SUPERINTENDENTS (updated 12/2021)
  1. Directly responsible for the safety of the job they supervise—they are the point-person for jobsite safety
  2. Work with other team leaders at the beginning of the job to ascertain what special safety requirements there may be for that job
  3. Work with the jobsite foremen to be certain they are maintaining and training to a high safety standard for their respective areas
  4. Assure the Hogan Drug and Alcohol Policy is strictly adhered to
  5. Hold daily production and safety meetings with ALL Hogan employees
  6. Perform a weekly safety inspection of their site
  7. Maintain daily safety logs
  8. Hold a weekly safety meeting with their subcontractors
  9. Responsible to see all safety equipment is present, in proper working condition, and used properly
  10. Work with each of the subcontractors as they come on site to be certain they maintain the same high Hogan safety standards—as per their contract
  11. Oversee the safety of any injured worker and manage the reporting of the accident or injury of any Hogan employee should an accident or injury occur
TEAM MANAGERS (updated 12/2021)
  1. Directly responsible for the safety of the teams they supervise
  2. Work with other team leaders at the beginning of the job to ascertain what special safety requirements there may be for that job
  3. For the teams that the Team Managers supervise, make sure all on-site Hogan employees attend the Daily Production and Safety meeting every morning with the Project Superintendent.
  4. Perform a weekly safety inspection of their site (yard and steel fabrication teams only)
  5. The Shop & Yard Manager will do a Daily Production & Safety meeting for the yard crew each morning.
FOREMEN
  1. Responsible for the safety of their respective areas of construction
  2. Have both the responsibility and the authority to train and call out safety violations for those working in their areas
  3. Authorized to stop any procedure until a way is found to do it safely.
  4. Responsible for the training and oversight of new-hires—starting them on the road to having safety foremost in their minds as they work on Hogan projects.
  5. Assist the Superintendent(s) in handling all safety issues and procedures for their respective areas.
ALL FIELD EMPLOYEES
  1. Follow all safety rules and procedures
  2. Report any injuries to his or her Foreman or Superintendent
  3. Participate in all required training, including videos on hoganuniversity.com, reading materials, and hands-on training
  4. Report unsafe conditions and equipment to his or her Foreman or Superintendent

IN THE END, IT IS EACH INDIVIDUAL’S RESPONSIBILITY TO STAY SAFE.

All the training, all the inspections, all the safety meetings, all the safety gear, all the safety incentives cease to work if the individual does not care about his or her personal safety and the safety of those around them.

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Back injuries constitute:

  • 41% of ergonomic injury cases
  • $50 billion spent each year
  • 24% of all missed work days
  • The second most common reason for a doctor’s visit
 

A full 80% of adults have experienced a back injury and—incredibly—having a back injury statistically reduces a person’s life expectancy.

Fortunately, it’s not hard to pinpoint the major cause of these disruptive back injuries. These activities account for 80% of lower-back injuries:

  • Lifting
  • Placing
  • Carrying
  • Holding
  • Raising
  • Lowering

Knowing the importance, and knowing the primary cause of back injuries, we can now put in place practices—and attitudes—to help prevent them.

LIFT WITH YOUR LEGS AND NOT WITH YOUR BACK

You’ve heard it since you were a teen. And it turns out this common adage is true, and constitutes the number one rule for back safety.

  • Legs apart
  • Rear end low and well away from the load
  • Knees bent
  • Strong grip on load
  • Lift with your legs
  • Keep you back straight
  • Use your tummy muscles
  • Lift smoothly, without jerks or twisting
  • Keep the load close to your body and in your “power zone” (see drawing on next page)
  • Turn with your feet, not your waist
  • Keep spin in its natural, gentle-S shape
  • Reverse the process to set the load down
LIFTING HAZARDS

Before lifting we need to assess the situation. Among them are:

  • Uneven ground
  • Potholes
  • Dangerous slopes
  • Inadequate clearance
  • Electrical hazards
  • Soft ground
  • Defective equipment
  • Tripping hazards
  • Clutter or housekeeping obstacles
  • Hidden obstacles

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SAFETY POLICIES

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Hogan Construction recognizes alcohol and drug abuse as a potential health and safety issue and encourages employees to seek help.

A CONSCIENTIOUS EFFORT TO SEEK SUCH HELP BY ITSELF WILL NOT JEOPARDIZE ANY EMPLOYEE’S JOB.

 
—SUMMARY—

This summary section is for your convenience. It does cover the primary principles of the Commercial Driver Drug and Alcohol Policy. Your reading assignment and associated quiz will cover this summary section.

The content of the details section will still apply to your employment at Hogan and your use of company vehicles.

However, if you abide by the policy to:

  • Not use drugs (recreational drugs or performance-altering prescription drugs without a doctor’s supervision and/or without the knowledge of your supervisor) on or off the job, while driving or otherwise not use or possess alcohol while on the job or while in or using company vehicles
  • Not come to work or drive impaired
  • Not have on your person or in a company vehicle any impairing substances,

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you will likely never require the content of the DETAILS section.

 
 
PROHIBITIONS

ALCOHOL CONCENTRATION

Covered employees are prohibited from reporting for duty or remaining on duty when their ability to perform assigned functions is adversely affected by alcohol or when their blood alcohol concentration is 0.02 or greater. No Supervisor having actual knowledge an employee has an alcohol concentration of 0.02 or greater shall permit the employee to perform or continue to perform safety-sensitive functions, including driving a company vehicle.

ALCOHOL POSSESSION

No employee shall be on duty or operate a commercial motor vehicle while the employee possesses alcohol, unless the alcohol is manifested and transported as part of a shipment or is being taken into evidence. No Supervisor having actual knowledge that an employee possesses unmanifested alcohol shall permit the employee to perform or continue to perform safety-sensitive functions.

ON-DUTY USE

No employee shall use alcohol while performing safety-sensitive functions. No Supervisor having actual knowledge that an employee is using alcohol while performing safety-sensitive functions shall permit the driver to perform or continue to perform safety-sensitive functions.

PRE-DUTY USE

No employee shall perform safety-sensitive functions within four hours after using alcohol. No Supervisor having actual knowledge an employee has used alcohol within four hours shall permit the driver to perform or continue to perform safety-sensitive functions.

USE FOLLOWING an ACCIDENT

No employee required to take a post-accident alcohol test shall use alcohol for eight hours following the accident, or until he or she undergoes a post-accident alcohol test, whichever occurs first.

 
 
TESTING

We do drug testing at the beginning of employment, and then we randomly drug test all employees at the rate of 20% of the average staff count on an annualized basis. And we will target employees for drug testing if we have suspicions of substance abuse.

We will also drug test any employee involved (directly or indirectly) in an on-the-job incident requiring more than first aid, or for which there was extensive property damage, within 32 hours of the incident. If an employee is subject to one of these post-accident drug or alcohol tests, he or she must not consume alcohol until the test is done.

CONSEQUENT DISCIPLINARY ACTION

Any employee who violates this company commercial vehicle drug-abuse policy will be subject to disciplinary action, including termination of employment.

 
 
REFUSAL TO SUBMIT

Refusal to test or submit to an alcohol or drug test means that a driver:

  • Fails to appear for any test (except a pre-employment test) within a reasonable time, as determined by the employer and consistent with dot agency regulations, after being directed to do so by Hogan
  • Fails to remain at the testing site until the testing process is complete. However, an employee who leaves the testing site before the testing process commences for a pre-employment test is not deemed to have refused to test
  • Fails to provide a urine specimen for any drug test required by the employer and DOT regulations
  • In the case of a directly observed or monitored collection in a drug test, fails to permit the observation or monitoring of your provision of a specimen
  • Fails to provide a sufficient amount of urine when directed, unless it has been determined through a required medical evaluation, that there was an adequate medical explanation for the failure
  • Fails to undergo a medical evaluation as directed by the MRO as part of the verification process or as directed by the DFR concerning the evaluation of shy bladder procedures
  • Fails to cooperate with any part of the testing process
  • Fails or declines to take a second test the employer or collector has directed the driver to take, or
  • Is reported by the MRO as having a verified adulterated or substituted test result, or
  • Possesses or wears a prosthetic or other device that could be used to interfere with the collection process
  • For an observed collection, fail to follow the observer’s instructions to raise your clothing above the waist, lower clothing and underpants, and to turn around to permit the observer to determine if you have any type of prosthetic or other device that could be used to interfere with the collection process.

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No employee shall refuse to submit to a post-accident, random, reasonable suspicion, or a follow-up alcohol or controlled substance test required under Title 49 code of Federal Regulations. No Supervisor shall permit an employee who refuses to submit to such tests to perform or continue to perform safety-sensitive functions.

The following are examples that may constitute a refusal to be tested for alcohol and/or controlled substances:

  • ALCOHOL TESTING Refusal by an employee to:
    • Sign the breath alcohol form
    • Provide adequate breath without a valid medical explanation.
    • Cooperate with the testing process in a way that prevents the completion of the test.
  • CONTROLLED SUBSTANCES Refusal by an employee to:
    • Provide a urine sample
    • Provide an adequate urine sample without a valid medical explanation
    • Cooperate with the testing process in a way that prevents the completion of the test.
 
 
CONTROLLED SUBSTANCE USE

No employee shall report for duty or remain on duty requiring the performance of safety-sensitive functions when the employee uses any controlled substance, except when the use is pursuant to the instructions of a physician who has advised the employee that the substance does not adversely affect the employee’s ability to safely operate a commercial motor vehicle.

No Supervisor having actual knowledge that an employee has used a controlled substance shall permit the driver to perform or continue to perform safety-sensitive functions.

PRESCRIPTION MEDICATIONS

Drivers taking legally prescribed medications issued by a licensed health care professional familiar with the driver’s work-related responsibilities must report such use to their immediate supervisor or dispatcher, and may be required to present written evidence from the health care professional which describes the effects such medications may have on the driver’s ability to perform his or her tasks.

At the sole discretion of the alcohol and drug program administrator, a driver may be temporarily removed, with pay, from a safety-sensitive position if deemed appropriate. After review of all relevant information and on a case-by-case basis, a driver on a prescription medication that presents a safety issue may also be permanently or temporarily removed from his or her position.

Alcohol and controlled substances testing conducted under this policy shall meet or exceed the procedures found in Title 49 code of Federal regulations, part 40. A copy of this title shall be maintained by the Program Administrator and shall be made available to any employee upon request.

 
 
POSSESSION

No employee shall have illegal drugs and/or alcohol in their possession while on Company premises, or while operating Company equipment, or while on Company time.

 
—DETAILS—
 
 
POLICY STATEMENT

This policy states the position of Hogan & Associates Construction (hereafter referred to as the Company) regarding the use of alcohol and drugs in our workplaces or on Company premises while conducting Company business. Employees are expected and required to report to work on time and in suitable mental and physical condition for work. It is our intent and obligation to provide a healthy and safe drug- and alcohol-free environment.

The unlawful manufacture, distribution, possession, or use of a controlled substance and/or alcohol on company premises, in Company vehicles, or while conducting Company business off Company premises is prohibited. Violation of this policy will result in termination of employment.

 
 
DEFINITIONS

EMPLOYEE This policy applies to all employees in the service of the Company for compensation who are required to hold and maintain a Commercial Drivers License  (CDL) as a condition of employment or who receives a reimbursement in part or whole for securing a CDL or who operates a commercial motor vehicle including full-time, part-time, casual, intermittent or occasional drivers shall be subject to random testing conducted pursuant to Federal law and regulations of Title 49 code of Federal Regulations, Part 383. All Company employees are subject to pre-employment, random, reasonable suspicion, post-accident, return-to-duty, and follow-up testing conducted pursuant to such law and regulations and this policy.

PROSPECTIVE EMPLOYEE Any person who has made application for employment with the Company, who is subject to the CDL requirements of Title 49 code of Federal Regulations, Part 383, and/or any person who has been offered a position with the company. Applicants who are offered a position with the company are subject to pre-employment controlled substances testing as a condition of employment.

COMMERCIAL MOTOR VEHICLE A motor vehicle or a combination of motor vehicles used in commerce to transport passengers or property if the motor vehicle:

  • Has a gross combination weight of 26,001 or more pounds inclusive of a towed unit with a gross vehicle weight rating of more than 10,000 pounds, or
  • Has a gross vehicle weight of 26,001 or more pounds, or
  • Is designed to transport 16 or more passengers, including the driver, or
  • Is of any size and is used in the transportation of hazardous materials which require placards.

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Employees who operate commercial motor vehicles as defined above are required to have a current Commercial Driver’s License (CDL).

SAFETY SENSITIVE FUNCTIONS All time from the time a driver begins work or is required to be in readiness to work until the time he or she is relieved from work and all responsibility for performing work. Safety-sensitive functions shall include:

  • All time at an employer or shipper plant, terminal, facility, or other property, waiting to be dispatched, unless the driver has been relieved from duty by the employer
  • All time inspecting, servicing, or conditioning any commercial motor vehicle at any time
  • All time spent at the driving controls of a commercial motor vehicle in operation
  • All time, other than driving time, in or upon any commercial motor vehicle except time spent resting in a sleeper berth
  • All time loading or unloading a vehicle, supervising, or assisting in loading or unloading, attending a vehicle being loaded or unloaded, remaining in readiness to operate the vehicle, or in giving or receiving receipts for shipments loaded or unloaded, and
  • All time repairing, obtaining assistance, or remaining in attendance upon a disabled vehicle.
 
 
ALCOHOL TESTING DEFINITIONS

ALCOHOL The intoxicating agent in beverage alcohol, ethyl alcohol, or other low molecular weight alcohols including methyl and isopropyl alcohol.

ALCOHOL USE The consumption of any beverage, mixture, or preparation, including any medication containing alcohol.

ALCOHOL CONCENTRATION (OR CONTENT) The alcohol in a volume breath expressed in terms of grams of alcohol per 210 liters of breath as indicated by a DOT-approved breath testing device.

SCREENING ALCOHOL TEST An analytic procedure to determine whether an employee may have a prohibited concentration of alcohol in a breath specimen.

CONFIRMATION ALCOHOL TEST A second test, following a screening test with a result of 0.02 or greater that provides quantitative data of alcohol concentration using a DOT-approved alcohol testing device.

 
 
DRUG TESTING DEFINITIONS

ILLEGAL DRUGS A controlled substance included in Schedule I or II as defined by Section 802(6) of Title 21 of the United States Code. The possession of which is unlawful under Chapter 13 of the Title. The term “illegal drugs” does not mean the use of a controlled substance pursuant to a valid prescription or other use authorized by law.

DRUG TEST An analysis of a urine sample for the presence of “illegal drugs” provided by an employee or prospective employee.

INITIAL DRUG TEST (also known as a screening drug test) is a test used to differentiate a negative specimen from one that requires further testing for drugs or drug metabolites.

CONFIRMATION DRUG TEST A second analytical procedure to identify the presence of a specific drug or metabolite that is independent of the screening test and that uses a different technique and chemical principle from that of the screening test in order to ensure reliability and accuracy.

VERIFIED NEGATIVE DRUG TEST A drug test result that was negative on an initial FDA-approved immunoassay test (screening drug test), and reviewed and verified by the medical review officer (MRO) in accordance with this plan and the mandatory guidelines under Title 49 Code of Federal Regulations Part 40 – procedures for transportation workplace drug and alcohol testing programs.

VERIFIED POSITIVE DRUG TEST A test result that was positive on an initial FDA-approved immunoassay test (screening drug test), confirmed by a gas chromatography or mass spectrometry assay, (or other confirmatory test approved by the Department of Health and Human Services) (confirmation drug test) and reviewed and verified by the MRO in accordance with this plan and the mandatory guidelines under Title 49 of the Code of Federal Regulations Part 40. The screening drug test and confirmation drug test cutoff levels for the illegal drugs are:

DRUGSCREENING CUTOFFCONFIRMATION CUTOFF
Confirmation Cutoff Cannabinoids as Carboxy-THC (Marijuana) – whether or not applicant/employee has a Medical Cannabis Card issued by the laws of the State of Utah; see 26-61a-111(a) Utah Code Annotated.-THC (Marijuana)50 ng/ml15 ng/ml
Cocaine metabolites as benzoylecgoine (Cocaine, Crack)150 ng/ml100 ng/ml
Phencyclidine. (PCP, Angel Dust)25 ng/ml25 ng/ml
Opiates (Codeine, Morphine)10 ng/ml10 ng/ml
Amphetamines (Amphetamines & Methamphetamine)500 ng/ml250 ng/ml

SPLIT URINE SAMPLE A portion of the urine sample provided by the donor at the time of collection, poured into a separate specimen bottle, sealed in the presence of the donor, and shipped to the primary laboratory. If the primary sample tested positive for the presence of drugs(s) defined in F-Verified Positive Drug Test, the donor can request analysis of the “split sample” if he or she notifies the medical review officer within 72 hours of notification of a positive drug test.

 
 
REQUIRED TESTS

The Company intends to test employees and/or prospective employees for the presence of drugs and/or alcohol, in accordance with the provisions of this policy. An employee who refuses to be tested when so required will be subject to the full range of disciplinary action, including dismissal. Attempts to alter or substitute a urine specimen provided will be deemed a refusal to take the drug test when required. Drug and alcohol tests shall be given under the following circumstances:

PRE-EMPLOYEE TESTING Prior to the first time an employee performs a safety sensitive function for the Company, the employee shall undergo testing for the five drugs described in the above section.

RANDOM TEST A system of drug and/or alcohol testing imposed without individualized suspicion that a particular individual is using illegal drugs, and may either be:

  • Uniform unannounced testing of designated employees occupying a specific area, element, or position; or
  • A statistically random sampling of such employees based on a neutral criterion; and
  • The company shall ensure that random alcohol and drug tests conducted under this testing method are unannounced and the dates for testing are spread reasonably throughout the calendar year.
  • The minimum annual percentage rate for random drug testing shall be 50% of the average number of employees in positions requiring a CDL. The minimum annual percentage rate for random alcohol testing shall be 25% of the average number of employees in positions requiring a CDL.
  • An employee shall only be tested for alcohol while the employee is performing safety-sensitive functions, just before the employee is to perform safety-sensitive functions, or just after the employee has ceased performing such functions.

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REASONABLE SUSPICION TESTING Drug and/or alcohol testing when the Company has reason to believe that the employee has violated the prohibitions of this policy concerning drug and/or alcohol use.

Reasonable suspicion of drug and/or alcohol use shall be based on a specific event or observation indicating recent drug and/or alcohol use. The observation may include indications of the chronic and/or withdrawal effects of controlled substances or alcohol and any of the following:

  • Documentation of unsatisfactory work performance or on-the-job behavior
  • Evidence of the manufacture, distribution, dispensing, possession, or use of drugs/controlled substances, alcohol, or other prohibited substances
  • Occurrence of a serious or potentially serious accident or minor accident that may have been caused by human error, risky behavior, not following direction, etc.

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Signs of possible alcohol or drug use (not all-inclusive):

  • Abnormally dilated or constricted pupils
  • Glazed stare, redness of eyes
  • Flushed face
  • Change of speech (faster or slower)
  • Constant sniffing
  • Needle marks
  • Sudden weight loss
  • Increased absences
  • Increased appetite for sweets
  • Forgetfulness, performance faltering, poor concentration
  • Borrowing money from co-workers or other unusual display or need for money
  • Constant fatigue or hyperactivity
  • Smell of alcohol
  • Slurred speech
  • Difficulty walking
  • Dulled mental processes
  • Slowed reaction rate
  • Change in personality (paranoia)

REASONABLE CAUSE TESTING shall be obtained only after the covered employee’s supervisor or company official (trained in detecting the indicators of drug and/or alcohol use in accordance with Title 49 Code of Federal Regulations, Part 382.603) has reviewed all information, facts, and circumstances leading to and supporting the reasonable cause observation. A written record shall be made of the observations leading to the testing and signed by the supervisor or company official prior to testing. All employees tested under this provision shall be prohibited from performing any safety-sensitive functions until the Program Administrator reviews the results of the test

Alcohol testing is authorized under reasonable suspicion only if the observations required by this testing method are made during, just preceding, or just after the period of the workday that the employee is required to be in compliance with on-duty time. An employee may be directed by the Company to undergo reasonable suspicion testing only while the employee is performing safety- sensitive functions, just before the employee is to perform safety-sensitive functions, or just after the employee has ceased performing such functions. The Company shall not take any action under this section against an employee based solely on the employee’s behavior and appearance, with respect to alcohol use, in the absence of an alcohol test.

POST-ACCIDENT TESTING A post-accident test is an alcohol and/or controlled substances test administered to an employee following an accident involving a Company vehicle or any vehicle used in the performance of Company business under the following conditions:

  • The employee was performing safety sensitive functions with respect to the vehicle and the accident involved a loss of human life;
  • The accident involved serious injury, or major property damage to any vehicle involved the in incident and the Company driver receives a citation under state or local law for a moving traffic violation arising from the accident.

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Accident means an occurrence involving a Company vehicle or any vehicle used in the performance of Company business operating on a public road which results in:

  • A fatality
  • Bodily injury to a person who, as a result of the injury, immediately receives medical treatment away from the scene of the accident or
  • One or more motor vehicles incurring disabling damage as a result of the accident, requiring the vehicle (any vehicles involved) to be transported away from the scene by a tow truck or other vehicle.

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RETURN TO DUTY TESTING Drug and/or alcohol testing required before the employee returns to duty requiring the performance of a safety-sensitive function after engaging in conduct prohibited by this policy. An alcohol test conducted under return-to-duty testing shall have a result indicating an alcohol concentration of less than 0.02 grams of alcohol per 210 liters of breath. DOT requires all DOT follow-up (or return ability of a driver to safely operate a commercial motor vehicle, or a warning label on a medication (prescription or over the counter medication), warns of possible impairment, must be reported to the employee’s supervisor.

FOLLOW-UP TESTING Testing required following a determination that an employee is in need of assistance in resolving problems associated with alcohol misuse and/or illegal drugs. The company shall ensure that the employee is subject to unannounced follow-up testing as directed by the substance abuse professional. dot requires that all dot follow-up (or return-to-duty) tests be collected under direct observation.

Use of a prescription drug, where the prescribing physician advises that it could impair the ability of a driver to safely operate a commercial motor vehicle, or a warning label on a medication (prescription or over the counter medication), warns of possible impairment, must be reported to the employee’s supervisor.

 
 
PROHIBITIONS

ALCOHOL CONCENTRATION

Covered employees are prohibited from reporting for duty or remaining on duty when their ability to perform assigned functions is adversely affected by alcohol or when their blood alcohol concentration is 0.02 or greater. No Supervisor having actual knowledge an employee has an alcohol concentration of 0.02 or greater shall permit the employee to perform or continue to perform safety-sensitive functions.

ALCOHOL POSSESSION

No employee shall be on duty or operate a commercial motor vehicle while the employee possesses alcohol, unless the alcohol is manifested and transported as part of a shipment or is being taken into evidence. No Supervisor having actual knowledge that an employee possesses unmanifested alcohol shall permit the employee to perform or continue to perform safety-sensitive functions.

ON-DUTY USE

No employee shall use alcohol while performing safety-sensitive functions. No Supervisor having actual knowledge an employee is using alcohol while performing safety-sensitive functions shall permit the driver to perform or continue to perform safety-sensitive functions.

PRE-DUTY USE

No employee shall perform safety-sensitive functions within four hours after using alcohol. No Supervisor having actual knowledge an employee has used alcohol within four hours shall permit the driver to perform or continue to perform safety-sensitive functions.

USE FOLLOWING an ACCIDENT

No employee required to take a post-accident alcohol test under title 49 code of Federal Regulations, part 382.303, shall use alcohol for eight hours following the accident, or until he/she undergoes a post-accident alcohol test, whichever occurs first.

 
 
REFUSAL TO SUBMIT TO A REQUIRED ALCOHOL OR CONTROLLED SUBSTANCES TEST

Refusal to test or submit to an alcohol or drug test means a driver:

  • Fails to appear for any test (except a pre-employment test) within a reasonable time, as determined by the employer and consistent with DOT agency regulations, after being directed to do so by Hogan
  • Fails to remain at the testing site until the testing process is complete. Provided, that an employee who leaves the testing site before the testing process commences (see 49 CFR 40.63©) for a pre- employment test is not deemed to have refused to test
  • Fails to provide a urine specimen for any drug test required by the employer and DOT regulations;
  • In the case of a directly observed or monitored collection in a drug test, fail to permit the observation or monitoring of your provision of a specimen
  • Fails to provide a sufficient amount of urine when directed, unless it has been determined through a required medical evaluation, that there was an adequate medical explanation for the failure
  • Fails to undergo a medical evaluation as directed by the MRO as part of the verification process or as directed by the DER concerning the evaluation of the shy bladder procedures
  • Fails to cooperate with any part of the testing process
  • Fails or declines to take a second test the employer or collector has directed the driver to take; or
  • Is reported by the MRO as having a verified adulterated or substituted test result, or
  • Possesses or wears a prosthetic or other device that could be used to interfere with the collection process
  • For an observed collection, fail to follow the observer’s instructions to raise your clothing above the waist, lower clothing and underpants, and to turn around to permit the observer to determine if you have any type of prosthetic or other device that could be used to interfere with the collection process.

 

No employee shall refuse to submit to a post-accident, random, reasonable suspicion, or a follow-up alcohol or controlled substance test required under title 49 code of Federal Regulations. No Supervisor shall permit an employee who refuses to submit to such tests to perform or continue to perform safety-sensitive functions.

The following are examples that may constitute a refusal to be tested for alcohol and/or controlled substances:

  • Alcohol testing, refusal by an employee to:
    • Sign the breath alcohol form
    • Provide adequate breath without a valid medical explanation.
    • Cooperate with the testing process in a way that prevents the completion of the test.
  • Controlled substances, refusal by an employee to:
    • Provide a urine sample
    • Provide an adequate urine sample without a valid medical explanation
    • Cooperate with the testing process in a way that prevents the completion of the test.
 
 
CONTROLLED SUBSTANCE USE

No employee shall report for duty or remain on duty requiring the performance of safety-sensitive functions when the employee uses any controlled substance, except when the use is pursuant to the instructions of a physician who has advised the employee that the substance does not adversely affect the employee’s ability to safely operate a commercial motor vehicle.

No Supervisor having actual knowledge that an employee has used a controlled substance shall permit the driver to perform or continue to perform safety-sensitive functions.

Prescription medications. Drivers taking legally prescribed medications issued by a licensed health care professional familiar with the driver’s work-related responsibilities must report such use to their immediate supervisor or dispatcher, and may be required to present written evidence from the health care professional which describes the effects such medications may have on the driver’s ability to perform his or her tasks.

At the sole discretion of the alcohol and drug program administrator, a driver may be temporarily removed, with pay, from a safety-sensitive position if deemed appropriate. After review of all relevant information and on a case-by-case basis, a driver on a prescription medication that presents a safety issue may also be permanently or temporarily removed from his or her position.

Alcohol and controlled substances testing conducted under this policy shall meet or exceed the procedures found in title 49 code of Federal regulations, part 40. A copy of this title shall be maintained by the Program Administrator and shall be made available to any employee upon request.

 
 
POSSESSION

No employee shall have illegal drugs and/or alcohol in their possession while on Company premises, or while operating Company equipment.

 
 
CONSEQUENCES FOR DRIVERS HAVING VIOLATED SUBPART B OF THE FEDERAL REGULATIONS

REMOVAL from a SAFETY-SENSITIVE FUNCTION

No employee shall perform safety-sensitive functions, including driving a commercial motor vehicle, if the employee has engaged in conduct prohibited by this policy; title 49 code of Federal Regulations, part 382, subpart B – prohibitions; or an alcohol or controlled substance rule of another DOT agency.

REQUIRED EVALUATION & TESTING

No employee who has engaged in conduct prohibited by this policy shall perform safety-sensitive functions, including driving a commercial motor vehicle, unless the employee has met the requirements of title 49 code of Federal Regulations, part 382.605

OTHER ALCOHOL-RELATED CONDUCT

No employee tested under this policy who is found to have an alcohol concentration of 0.02 or greater but less that 0.04 shall perform or continue to perform safety-sensitive functions for the Company, including driving a commercial motor vehicle, nor shall the Company permit the employee to perform or continue to perform safety-sensitive functions, until the start of the employee’s next regularly scheduled duty period, but not less than 24 hours following the administration of the test. Except as provided in this section, the Company shall not take any action under this section against an employee solely on test results showing an alcohol concentration less that 0.04.

COMPANY ACTION

Upon receipt of a verified or confirmed positive drug or alcohol test result which indicates a violation of this policy, or upon the refusal of an employee or prospective employee to provide a sample, the Company may use that test result or refusal as the basis for disciplinary or rehabilitative actions, which may include the following:

  • Evaluation by a substance abuse professional to determine what assistance, if any, the employee needs in resolving problems associated with alcohol misuse and controlled substances use
  • A requirement that the employee enroll in a company approved employee assistance program which may include additional drug and alcohol testing, as a condition of continued employment
  • Suspension of the employee with or without pay for a period of time
  • Termination of employment
  • Refusal to hire a prospective employee. or
  • Other disciplinary measures in conformance with the Company’s usual policies and procedures.

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The Company shall not permit an employee who has engaged in conduct prohibited by Title 49 code of Federal Regulations, part 382, subpart B and this policy to perform safety-sensitive functions until he or she has been evaluated by a substance abuse professional and has completed a return to duty alcohol and/or drug test with negative results.

 
 
CONFIRMED POSITIVE DRUG TEST RESULTS

The responsibilities of the medical review officer (MRO) with respect to a confirmed positive drug test result are to review and interpret the drug test result. In carrying out this responsibility, the MRO shall examine alternate medical explanations for any positive test result. This action may include conducting a medical interview and review of the individual’s medical history, or review of any other relevant biomedical factors. The MRO shall contact the individual directly, on a confidential basis, to determine whether the employee wishes to discuss the test result.

The MRO shall talk directly with the individual before verifying a test as positive to discuss the test results with him or her. If, after making all reasonable efforts and documenting them, the MRO is unable to contact the individual directly, the MRO shall contact the Company Program Administrator who shall direct the individual to contact the MRO as soon as possible. If the individual provides a legitimate explanation for the confirmed positive drug test, verified by the MRO, the MRO declares the test to be negative.

Following the verification of a positive test result, the medical review officer shall notify the individual that he or she has 72 hours from the time of notification to request a test of the split urine sample. If the individual requests an analysis of the split sample within 72 hours of having been informed of a verified positive test, the MRO shall direct, in writing, the laboratory to provide the split specimen to another DHHS-certified laboratory for analysis. Note a request to test the split specimen does not defer the reporting of the verified positive test result to the Program Administrator.

 
 
REFERRAL, EVALUATION AND TREATMENT

Each covered employee who has a positive controlled substance test or a blood alcohol concentration test of 0.04 or greater shall be referred to a Substance Abuse Professional (SAP). The SAP shall determine what assistance, if any, the employee needs in resolving problems associated with alcohol misuse and controlled substance use.

 
 
RELEASE OF ALCOHOL AND CONTROLLED SUBSTANCES TEST INFORMATION

An employee is entitled, upon written request, to obtain copies of any records pertaining to the employee’s use of alcohol or controlled substances, including any records pertaining to his or her alcohol or controlled substances test. The Company shall promptly provide the records requested by the employee.

The Company shall make available copies of all results for employer alcohol and/or controlled substances testing conducted under this part and any other information pertaining to the employer’s alcohol misuse and/or controlled substances use prevention program, when requested by the secretary of transportation, any DOT agency, or any state or local officials with regulatory authority over the employer or any of its employees.

 
 
RETENTION OF RECORDS

The Company shall maintain records of the alcohol misuse and controlled substances use prevention programs as provided in this section. The records shall be maintained in a secure location with controlled access. The Company shall maintain the records in accordance with the following schedule:

FIVE YEARS:

  • Records of employee alcohol test results with results indicating an alcohol concentration of 0.02 or greater.
  • Records of employee verified positive controlled substances test results.
  • Documentation of refusals to take required alcohol and/or controlled substances test.
  • Calibration documentation (breath alcohol testing devices, if applicable).
  • Employee evaluation and referrals by DOT substance abuse professionals.

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TWO YEARS:

  • Records relating to the alcohol and controlled substances collection process.

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ONE YEAR:

  • Records of negative and canceled controlled substances test results (as defined in part 40) and alcohol test results with a concentration of less than 0.02.

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—SUMMARY—
 

This summary section is for your convenience. It does cover the primary principles of the Drug- and Alcohol-free Work Place Policy. Your reading assignment and associated quiz will cover this summary section.

The content of the details section will still apply to your employment at Hogan. However, if you abide by the policy to:

  • not use drugs (recreational drugs or performance-altering prescription drugs without a doctor’s supervision and/or without the knowledge of your supervisor)
  • not use or possess alcohol while on the job
  • not come to work impaired
  • not have on your person any impairing substances,

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you will likely never require the content of the details section.

 
 
DRUG USE

Illegal drug use, including prescription drug abuse, is not tolerated—zero tolerance on and off the job.

 
 
DRUG-USE TESTING

We do drug testing at the beginning of employment, and then we randomly drug test all employees at the rate of 20% of the average staff count on an annualized basis. And we will target employees for drug testing if we have suspicions of substance abuse.

We will also drug test any employee involved (directly or indirectly) in an on-the-job incident requiring more than first aid, or for which there was extensive property damage, within 32 hours of the incident. If an employee is subject to one of these post-accident drug or alcohol tests, he or she must not consume alcohol until the test is done.

The drug test results we get back from the lab are the employee’s results—the employee is responsible for the results. No amount of excuses will make it otherwise.

An employee claiming he or she was at a party where pot was being smoked but he or she didn’t smoke other than as second-hand smoke, is a cute story, but the test results are the test results; there is no second chance. And, in this example, if true, that employee should have found a different party to attend, because now it’s probably gonna cost him or her their job.

 
 
CONSEQUENT DISCIPLINARY ACTION

Any employee who violates this company drug-abuse policy will be subject to disciplinary action, including termination of employment, possible loss of company benefits, and refusal to hire in the case of pre-employment tests.

 
 
INSPECTIONS

Hogan & Associates Construction reserves the right to inspect—with or without notice—all persons, packages, automobiles, and any other items that come or are brought onto the company premises or job site locations. In addition, all rooms, desks, lockers, machines, computers, and other company-purchased items remain the property of Hogan & Associates Construction; and Hogan & Associates Construction reserves the right to inspect them with or without notice.

 
 
ALCOHOL USE

While an employee is free to responsibly use alcohol when not working, such use must be responsibly done and not result in any impairment of ability on the job. If there is any day-after impairment, we maintain the right to render disciplinary action, including termination of employment. And just as for illegal substances, we do not tolerate any alcohol use on the job at all. Period. Zero tolerance.

These rules and protections also apply to all the subcontractors on the site.

 
 
PRESCRIPTION AND OVER-THE-COUNTER DRUG USE

Use of prescribed medicines must be reported to the employee’s supervisor prior to any work being done. The failure to report the use of a prescription drug, where a licensed health care practitioner, the pharmacist, or label indicates it may impair the employee’s ability to safely perform their job will be a violation of this policy. Employees who use prescribed medicine must have a current or unexpired prescription that was prescribed within a year of the date of the collection of the test. The prescription must be the employee’s prescription.

Prescription or over-the-counter medications with warnings should not be taken during or before work. An employee undergoing prescribed medical treatment with any drug which may alter his or her physical or mental ability must report this treatment to Hogan & Associates job site superintendent. The Safety Department will determine whether a temporary change in the employee’s job assignment during the period of treatment is warranted.

—DETAILS—
 
 
Definitions

ADULTERANT Any foreign substance added to a test specimen.

ADULTERATE The replacing, adding foreign substances to, or tampering with a specimen in any way with the intent to alter true test results.

ALCOHOL The intoxicating agent in beverage-alcohol, ethyl alcohol, or other low molecular weight alcohol, including methyl and isopropyl alcohol.

ALCOHOL TESTING Being tested by a qualified alcohol testing technician, using a dot-approved alcohol testing device or a dot-approved initial screening device.

CDL Commercial Driver’s License

CMV Commercial Motor Vehicle

COMPANY PREMISES In addition to all Hogan offices, properties, project sites, company vehicles, and equipment, “company premises” also includes any place or vehicle where employees are doing work for or representing Hogan in any way.

CONTROLLED SUBSTANCES For the purposes of this program, controlled substances are equivalent to prescription drugs and illegal drugs, both of which include, but are not limited to Cocaine, Cannabinoids (marijuana), Opiates, Amphetamines, Phencyclidine (pcp), Barbiturates (Phenobarbital, Secobarbital), Benzodiazepines (Librium, Valium), Propoxyphene (Darvon), Methadone and Methaqualone. Testing for these substances has been upheld in court for Federally-mandated drug-testing programs. Other substances may be tested for as needed.

DHHS The Department of Health and Human Services or any designee of the Secretary, Department of Health and Human Services.

DOT Department of Transportation

DPC Drug Program Coordinator (Jared Morgan, 801-951-7000)

METABOLITE Metabolic waste product that is more or less toxic to the organism producing it. As drugs are eliminated from the body through metabolism by making the substances more excretable, some metabolites have their own pharmacological activities, which can either be similar to or different from the original drug.

POSITIVE ALCOHOL TEST Test levels on both the screening test and the confirmation test produces a result of .04 or greater.

POSITIVE DRUG TEST When the test levels on both the screening test and the confirmation test which are recognized as positive by the U.S. Department of Health and Human Services in it’s Mandatory Guidelines for Federal Workplace Drug Testing Program, or standardized cutoff levels at a DHHS certified lab.

PRESCRIBED MEDICINE Prescription drug under the care of a licensed health care practitioner that may impair the employee’s ability to safely perform their duties.

UTAH DRUG and ALCOHOL TESTING ACT (Private sector) Utah Code Annotated 34-38-1.

ZERO TOLERANCE Any positive result from drug or alcohol testing will be subject to immediate disciplinary action.

 
 
Purpose

In keeping with Hogan & Associates Construction’s concern for the health and safety of our work force, in keeping with the intent of the federal Drug-Free Workplace Act, Hogan & Associates Construction has instituted a drug-free work place policy.

Employees of Hogan & Associates Construction are our most valuable resource and for that reason their health and safety is our number one concern. Any drug or alcohol use that impairs the health and well being of our employees or threatens our business will not be tolerated. The use of and abuse of controlled substances and alcohol on or off duty, is not consistent with the law abiding behavior expected of all employees. Employees who abuse controlled substances or alcohol on or off duty tend to be less productive, less reliable, and prone to greater absenteeism. This in turn can result in increased costs, delays, and risks to the company’s business. Drug use and alcohol use in the work place puts the health and safety of the abuser and all other workers around them at increased risk. Employees have the right to work in a drug-free environment. In addition, drug and alcohol abuse inflicts a terrible toll on the nation’s productive resources and the health and well being of American workers.

 
 
Certification of Policy

This policy certifies Hogan & Associates Construction’s intent to maintain a drug-free work place. The manufacture, distribution, sale, possession, or use of a controlled substance and/or alcohol in the work place is prohibited. Posters notifying potential employees and current employees of substance abuse testing will be kept in conspicuous locations on the job and in Hogan’s main office.

 
 
Application to Commercial Driver’s License holders

Additionally, the U.S. Department of Transportation (DOT) has regulations which govern the use of drugs and alcohol by employees who hold a Commercial Driver’s License (CDL) and drive a Commercial Motor Vehicle (CMV). Hogan employees who fall under these conditions will be subject to the “Hogan & Associates DOT Drug and Alcohol policy.”

 
 
Questions

If you have questions regarding terms used in this policy, please refer to the “Definition Section”, above. Other questions regarding this policy can be directed to Jared Morgan, Hogan & Associates Construction’s Drug Program Coordinator (DPC).

 
 
Confidentiality

To protect confidentiality and to comply with the law, all records relating to drug and alcohol testing will be maintained in a confidential file in a secure location with controlled access.

 
 
Zero Tolerance Policy

Hogan & Associates Construction has a zero-tolerance level program and is committed to maintaining a safe work place free from the influence of drugs and/or alcohol. The Drug-Free Work Place Act specifically requires Hogan & Associates Construction to notify each employee that as a condition of employment each employee (including all Worker’s Compensation covered employees) must comply with the company’s Drug-Free Work Place Policy. Any employee who violates this company policy will be subject to disciplinary action, including termination of employment, possible loss of company benefits, and refusal to hire in the case of pre-employment tests. All employees are hereby notified that Hogan & Associates Construction reserves the right to the following:

  1. Inspect with or without notice, all persons, packages, automobiles, and any other items that come or are brought onto the company premises. In addition all desks, lockers, rooms machines, computers, and other company purchased items remain the property of Hogan & Associates Construction; and Hogan & Associates Construction reserves the right to inspect them with or without notice.
  2. Require drug and alcohol testing of:
    • Any employee at any time on a random basis. Random testing shall be conducted, at a minimum, on 20% of the average staff on an annualized basis.
    • Potential hires applying for employment with Hogan & Associates, new employees (part- or full-time) within three weeks of hire date, and re-hires who have not worked for Hogan for six months or longer, within three weeks of re-hire date. (A statement that substance abuse testing is required will be posted on vacancy announcements for all positions which require testing.)
    • Any employee involved (directly or indirectly) in an on-the-job incident requiring more than first aid or extensive property damage within 32 hours of the incident. If an employee is subject to a post accident drug or alcohol test, he or she must not consume alcohol before the test is done.
    • Any employee who gives, for any reason, reasonable suspicion that he or she may be under the influence of drugs or alcohol. In such a situation, supervisors will fill out the “Observed behavior—Reasonable Suspicion Record” form (on Procore and in the “Forms” section herein) before the test, and within 48 hours of the incident, and turn it in to the company’s DPC. For reasonable suspicion, the employee will not be allowed to return to work until after the results are provided. Employees will be compensated for lost time if the results are negative. If the results are positive the termination date will be the date and time of the test. In post-accident and reasonable cause situations when alcohol is suspected, a quantitative enzyme diagnostic (QED) or other alcohol screen may be given in addition to the drug test. Such alcohol tests should be performed immediately and must be performed within eight hours of the incident. For employees who must follow dot guidelines, please refer to the Module available in the Centerville office for drug and alcohol testing options and for types of drugs tested. All testing will be done not only for the presence of drugs and alcohol, but also the presence of a metabolite.
  3. Allow specimens to be collected and analyzed by DHHS-certified, professional laboratories for the following controlled substances:
    • Cocaine
    • Cannabinoids (marijuana) – whether or not applicant/employee has a Medical Cannabis Card issued by the laws of the State of Utah; see 26-61a-111(4) Utah Code Annotated
    • Opiates/synthetic
    • Phencyclidine (PCP)
    • Barbiturates (Phenobarbital, Butalbital, etc.)
    • Any and all suspected adulterant products and validity testing
    • Bath salts or other stimulants
    • Any and all other controlled substances
    • Propoxyphene (Darvon)
    • Methadone
    • Amphetamnes
    • Benzodiazepines (Librium, Valium, etc.)
 
 
Prohibitions

Hogan & Associates Construction’s Drug-Free Work Place Policy prohibits employees from engaging in any of the following activities:

  • ALCOHOL Use, possession, manufacture, distribution, dispensation, or sale of alcohol on company premises or while on company business, or while in company supplied vehicles, during working hours.
  • CONTROLLED SUBSTANCES Unauthorized use or possession, or any manufacture, distribution, dispensation, or sale of a controlled substance on company premises or while on company business or while in company supplied vehicles.
  • Storing in a locker, desk, automobile, or other repository on company premises any controlled substance.
  • Being under the influence of a controlled substance or alcohol on company premises or while on company business, or while in company supplied vehicles. It is against Company policy for any employee to operate any vehicle or equipment while under the influence of any drug or alcohol which renders the employee incapable of safely and adequately operating the vehicle or equipment. Presence of a listed prohibited drug or its metabolite in the body of an employee will constitute a violation of this policy.
  • Any possession, use, manufacture, distribution, dispensation, or sale of controlled substances off company premises that adversely affects the individual’s work performance, his own or other’s safety at work, or the company’s regard or reputation in the community.
    Failure to adhere to the requirements of any drug treatment or counseling program in which the employee is enrolled.
  • Failure to notify the company of any conviction under criminal drug statutes for a work place offense within five days of the conviction.
  • Use of alcohol while on company premises, or to report to work under the influence of alcohol. An employee is considered to be in violation of this policy when he or she reports to work and cannot pass an alcohol screening that has a cut-off level of .04 percent.
  • Refusal to sign a statement to abide by this Drug-Free Work Place Policy.
  • Refusal to be tested when required as outlined in this policy. Employees will be given three hours from the time of notification to provide a specimen. Any situation where an employee “can’t go” within that three hour time period will be considered and treated as a refusal to be tested unless the donor can provide a medical explanation to the MRO within five days.
  • Adulterate specimens by the use of adulterant products, dilution, substitution, or any other method. The company reserves the right to re-collect diluted specimens.
 
 
Authorized Use Of Prescribed Medicine

Use of prescribed medicine must be reported to the employee’s supervisor prior to any work being done. The failure to report the use of a prescription drug, where a licensed health care practitioner, the pharmacist, or label indicates it may impair the employee’s ability to safely perform their job will be a violation of this policy. Employees who use prescribed medicine must have a current or unexpired prescription that was prescribed within a year of the date of the collection of the test. The prescription must be the employee's prescription.

Prescription or over-the-counter medications with warnings should not be taken during or before work. An employee undergoing prescribed medical treatment with any drug which may alter his or her physical or mental ability must report this treatment to Hogan & Associates job site superintendent. The Safety Department will determine whether a temporary change in the employee’s job assignment during the period of treatment is warranted.

 
 
Drug Abuse Treatment Programs

Recognition and confession of drug abuse is vital for successful rehabilitation. Whenever feasible, Hogan & Associates Construction will assist employees in overcoming drug abuse by providing information on treatment, counseling, and education programs. However, the decision to seek diagnosis and to apply for and attend such programs is primarily the individual employee’s responsibility. Employees will be solely responsible to pay all costs related to enrolling and participating in such programs.

When employees confess drug problems and request assistance from Hogan & Associates Construction, the company will treat all such requests as confidential and will recommend various treatment, counseling, or educational programs to the employee.

Employees who voluntarily request the company’s assistance in dealing with a drug problem may do so without jeopardizing their continued employment, provided they strictly adhere to the terms of their treatment, counseling, or educational program. Such a request must be made at least 24 hours prior to the notification of an upcoming drug test.

At a minimum, such program terms must include:
a) The immediate cessation of any use of drugs
b) Regular attendance and active participation in the recommended program
c) Periodic unannounced testing during enrollment in the program
d) Passing a return to duty test before returning to job duties.

Hogan & Associates Construction reserves the right to give follow up tests as often as deemed necessary while he or she is enrolled in the program. Upon graduation of the program, the employee may be given follow up tests on an unannounced basis at the discretion of company officers, for the following two years.

However, once an employee is notified of an upcoming test, he or she will be required to take the test. Once such notice has been given, “last minute” confessions will not be tolerated and last minute voluntary requests for assistance from employees will not prevent disciplinary action for violation of Hogan Associates Construction’s Drug-Free Work Place Policy.

 
 
Disciplinary Actions For Violation

A violation of Hogan Associates Construction’s Drug-Free Work Place Policy may result in disciplinary action of termination or refusal to hire, at the company’s sole discretion. Employment termination includes loss of all company benefits.

Rehire

In order to qualify for rehire, the terminated employee must provide the DCP with a signed statement from a counselor, education, or rehabilitation center (hereafter called “rehab”) verifying enrollment in a rehab program. The statement must include a signed release by the terminated employee allowing the DCP to check up and receive all information regarding his or her enrollment and progression in the program. Approval of rehab programs will be at the sole discretion of the DCP. The terminated worker will be responsible to pay all costs related to the program.

Only with the DCP’s approval and following the minimal time frame of at least one week from the date of the positive result are terminated employees eligible for rehire. Rehire is not guaranteed by enrollment in a rehab program. If the individual is rehired, his or her employment will be contingent upon his or her active involvement, strict attendance, and complete adherence to the guidelines of his or her program. Further, the worker’s rehab schedule must not conflict with his or her work schedule and Hogan will not compensate workers for their rehab time. Upon rehire, a drug screen will be required before returning to work and monthly “follow up” tests will be required for up to two years with the employee paying for the tests. If, while enrolled in such programs or anytime following graduation from such programs, another positive test result is received, immediate termination will follow, and the individual will not be eligible for rehire for a minimum of one year.

Positive post-accident testing

In the case of positive post accident drug or alcohol testing, and when it is determined that termination of employment is necessary, the termination date will be the date and time of the incident. A positive post-accident result may constitute a loss in worker’s compensation benefits.

When an employee receives written notification of a positive result he or she will have two days to contest or explain the result to Hogan. Contesting the result means he or she requests that the same specimen be retested at a different DHHS-certified lab. The employee will be responsible to cover all related costs unless he or she can prove that the first lab made a mistake.

Condition for retaining benefits

Employees who have worked for Hogan & Associates for more than one year and whose employment is terminated due to a positive result, may retain his or her benefits if he or she enrolls in an approved treatment, counseling, or educational program within two weeks of the termination date and follows the guidelines outlined in this section. A violation of program guidelines will result in the loss of benefits as well as rehire eligibility as outlined above.
Any employee testing under dot or OCIP will be subject to the guideline outlined in their respective programs. Please refer to the dot and OCIP handbooks available in the Centerville office.

 
 
Employee Education and Supervisor Training
Employee Education

Hogan & Associates Construction shall provide at least one hour of employee substance abuse education training per year. Hogan & Associates Construction shall retain records, to include attendee’s signatures, dates, and training topics, to document employee participation in education.

Supervisor Training

Hogan & Associates Construction shall provide at least 2 hours of substance abuse training per year. Supervisors shall receive training to encompass at least 60 minutes on alcohol misuse and at least 60 minutes on drug use. Training shall incorporate physical, behavioral, speech, and performance indicators of probable alcohol misuse and use of drugs. Hogan & Associates Construction shall retain records, to include attendee’s signatures, dates, and training topics, to document supervisory participation in training.

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— COMMUNICATIONS —
 
ACCIDENT REPORTING

Accident reporting information is posted on the Safety Posters in the job trailer.

 
 
DAILY LOGS

Daily logs are a way to document important conversations with subcontractors, owners, architects, and Hogan employees. In addition, it is a way to document manpower, deliveries, inspections, visitors, etc. We encourage our Site Superintendents to do their daily logs daily. The template for Daily Logs can be found in Procore under Project Management.

 
 
PROCORE

For safety purposes, we track the following in Procore.

  • Weekly site inspections
  • Daily production and safety meetings (with Fineline employees)
  • Daily logs
  • Weekly subcontractor safety meetings.
 
 
SAFETY DATA SHEETS (updated 12/2021)

Modern construction uses a great many chemicals, including:

  • Concrete curing compounds
  • Polymer bonding agents
  • Polymer modified mortar for repair and maintenance

 

Each chemical has a Safety Data Sheet, or SDS, which actually consists of sixteen sheets covering several topics, including first aid instructions for when a person comes in contact with the chemical.

For example, if one of our employees gets a chemical in his or her eye or swallows a chemical, and we call 911, the ambulance will come and the paramedics are going to ask for the sds sheets. Fineline employees and subcontractors can access the SDS sheets by clicking on the QR code located on Hogan’s safety poster which is located in the project trailer.

Remember they are there. Look for them when you visit the job trailer.

The safety data sheets include an array of important information about the chemical, including first aid and the safe handling and storage of the chemical.

 
 
— INSPECTIONS —
 
SITE SAFETY INSPECTIONS

Site safety inspections are to be performed by the Superintendent or Foreman weekly. The inspection form is in Procore and in the Forms section of this book. Superintendents and Foreman should make time to immediately fix issues identified during site inspections.

In addition, Jared Morgan and the Safety Assistant visit each project and perform a safety inspection, with photo documentation, at least monthly, more frequently if the project is a large one (e.g., weekly for a full high school build). The results of the inspection are recorded in Procore and sent to the Superintendent. Follow-up on cited issues is required, including photo proof of issue correction.

 
 
— SAFETY MEETINGS —
 
DAILY PRODUCTION AND SAFETY MEETINGS (updated 03/2022)

Daily production and safety meetings must be conducted with all Fineline employees on each project first thing in the morning. These meetings are typically held at the start of each work day and last five to ten minutes. The Superintendent is responsible for these meetings. The meetings cover tasks to be worked on that day by each employee, hazards associated with those tasks, and what will be done to remediate those hazards.

Every Fineline employee assigned to a project is required to attend, participate in, and sign their name on the Daily Production and Safety Meeting attendance sheet.

Daily Production and Safety Meeting documents are held in Procore for the duration of the project.

(A separate Subcontractor Safety meeting is held weekly for the Foreman of each of the trades.)
The Meeting should cover the following:

  • Work assignments or tasks for each employee for that day.
  • Project hazards anticipated for the day (and beyond) and procedures for minimizing the risk to employees and project
  • Report on any hazardous materials that will be entering the site that day (and beyond)
  • Review of any safety violations that may have occurred on the project during the previous day(s)
  • Review of any accidents or near hits that may have occurred on the project during the previous day(s)
  • Weekly have each employee check his or her MY CERTIFICATIONS (Fineline ADP Portal) and report any training requirement about to expire
  • Any other safety topics the Superintendent deems appropriate to review or highlight.
 

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[UPDATED DECEMBER 12, 2020]

JOBSITE SAFETY ANALYSIS

Before the start of each job, the Superintendent, Jared Morgan (VP over safety), or our Safety Assistant meet to evaluate the job requirements and identify any special safety issues the job may entail. These include:

  • Large steel erection requirements (steel transportation and storage on site before installation, lifting methods and schedules, special placement requirements that may require specific safety processes)
  • Large excavation requirements (hauling-traffic patterns and timing, collapse-prevention needs, etc.)
    Fall-protection needs (perimeter and interior leading edges, holes, upper-level access)
  • Confined spaces
  • Site security (reducing “attractive hazards,” preventing purposeful and inadvertent entrance by non-workers, theft protection)
  • Site natural conditions (potential geological and geographical issues, worker transportation patterns and parking)
  • Demolition needs (large-component deconstruction, swppp, hauling traffic patterns and timing, dangerous and regulated materials removal)
  • Construction methods and schedules (reducing weak steel or concrete structure durations, managing caustic or dangerous materials, special safety equipment that may be needed to complete each task)
  • Live-site considerations (isolating construction from business or education processes and populations, emergency evacuation needs, continuous fire and emergency medical access)

 

In addition to identifying these construction requirements, the safety team identifies the nearest emergency medical clinic and posts that location on the jobsite safety poster.

 
 
JOBSITE SAFETY EQUIPMENT

At the start of each project, we equip the site with the following safety and emergency items:

OSHA | ANSI FIRST AID CABINET

  • Adhesive Bandage 1×3 (100)
  • Adhesive Bandage 3×¾ (100)
  • Fabric Bandage 1×3 (50)
  • Knuckle Bandage (20)
  • Fingertip Bandage (20)
  • Non Sterile Pad 2×3  (8)
  • Tape Roll (1)
  • Triangular Bandage (1)
  • Trauma Pad (2)
  • Bandage Compress (1)
  • Eye Cup (1)
  • Gauze Pads (20)
  • Gauze Rolls (3)
  • Examination Gloves (8)
  • Instant Cold Compress (1)
  • Tweezers (1)
  • Scissor (1)
  • Burn Cream (10)
  • Burn Spray 3 oz. (1)
  • Antibiotic Ointment (10)
  • Antiseptic Spray 3 oz. (1)
  • Alcohol Pads (60)
  • PVP Iodine Pads ()
  • Antiseptic Towelettes (30)
  • Sting Relief Pad (10)
  • First Aid Guide (1)
  • Cotton Tip Applicators (100)
  • Elastic Bandage 3-in (Ace Type) (1)
  • Aspirin Tablets (100)
  • Pain Relief Tablets (100)
  • Antacid Tablets ()
  • Hand Sanitizers (25)
  • Eye Wash 4 oz. (1)
  • Eye Pad (2)
  • Splints / Tongue Depressors (4)
  • Filtration Masks (6)

OSHA | ANSI TRAUMA KIT

My-Medic.jpg
  • Bandage 1×3¼ (2)
  • Bandage 2×4 (2)
  • Bauze Roll 3×12½ (1)
  • Liquid Skin rgram (1)
  • Secure Strips (3) (1)
  • Ibuprofen 800mg (2)
  • Tylenol 1000mg (1)
  • Benadryl 50 mg (1)
  • Pepto Bismol (1)
  • Burnshield Burn Jel 3½ml (1)
  • Lip Guard (1)
  • Sunscreen (1)
  • P.A.W.S. Wipes (1)
  • Oral Pain Relief (1)
  • Triple Antibiotic (1)
  • Hydrocortisone (1)
  • Sting & Bite Relief (1)
  • Saljet Bullet (1)
  • Paracord 20ft (1)
  • Whistle (1)
  • SuperSkin (2)
  • Tweezers (1)
  • EMT Shears (1)
  • Nitrile Gloves (2)

OTHER SAFETY EQUIPMENT

  • Automatic External Defibrillator (AED)
  • Ear Plugs
  • Eye-wash Stations
  • Hard Hats (loaners)
  • N95 Respirators
  • Safety Glasses (clear loaners, also clear and shaded to replace previously issued glasses)
  • Safety Vest (loaners)
  • Work Gloves (to replace previously issued gloves)
JOB OFFICE DOCUMENTATION
  • HazCom or SDS Binder
  • Safety Handbook (Effective June 2021, we will no longer be providing a hard copy of Hogan’s safety handbook at each Hogan project. A current version of Hogan’s safety handbook can be found in Hogan University under "Library" or "Library & Forms.")
 
 
SIGNAGE

The following signage will be available for all employees to see:

  • Safety Poster
  • eVerify Posters
  • Required Training (via the Fineline Workforce Now portal)
  • Site Management Contact and Site Location Information (for 911 calls)
  • Minor and Major First Aid Instructions
  • EEO|AA Poster
  • Minimum Wage Poster
  • Blomquist-Hale Counseling Services Poster
  • Emergency Egress
 
 
JOBSITE SECURITY (updated 03/2022)

At the beginning of each project, as well as during the project, the Superintendent and the Project Manager should review the project requirements and the surrounding community to determine what type of site security requirements should be imposed.

Each project will be fenced and gated. All the gates on the project must be locked each evening.

In addition, depending on the management review described, security cameras, and/or security guards may be used. Additional evening and weekend gate checks may also be scheduled.

 
 
GOOD NEIGHBOR ACTIONS

At the beginning of each project the assigned Superintendent is to contact neighboring businesses and residents, giving them contact information and letting them know that if there are any security or safety (or behavioral) concerns that arise during the project, they should contact him or her.

 
 
SIGNAGE

The following signage will be available for all employees to see:

  • Safety Poster
  • eVerify Posters
  • Required Training (via the Fineline Workforce Now portal)
  • Site Management Contact and Site Location Information (for 911 calls)
  • Minor and Major First Aid Instructions
  • EEO|AA Poster
  • Minimum Wage Poster
  • Blomquist-Hale Counseling Services Poster
  • Emergency Egress

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Establishing workplace-safety committees is one way management can encourage employees to participate in implementing and monitoring the company’s safety program.

Typical responsibilities of workplace-safety committees include:

  • Developing safe work practices.
  • Crafting written safety programs.
  • Leading safety training.
  • Conducting workplace inspections and safety audits.
  • Reviewing incidents, near misses, accident investigation reports, claim summaries and loss analyses to prevent reoccurrences of similar incidents.
  • Establishing dispute resolution procedures.
  • Proposing and creating safety checklists.
  • Promoting employees’ interests in health and safety issues.
  • Providing a forum in which labor and management can discuss health and safety issues and collaborate on solutions.

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Hogan Construction’s safety committee was established to help reduce the risk of workplace injuries and illnesses and ensure compliance with federal and state health and safety regulations. In addition, this is an opportunity for many classes of employees to collaborate on safety issues and also to be part of the solution.

Hogan’s safety committee meets monthly and is comprised of Project Managers, Project Superintendents, Project Foreman and Team Leaders. Committee members will serve for one year.

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[See also TRAINING SECTION.]

TRAINING MATRIX & JOB CLASSIFICATIONS

READING MATRIX

In addition to money and time spent creating and providing safety training, as well as purchasing and maintaining safety equipment, we give financial incentives to workers to encourage on-going safety training (see TRAINING SECTION; see also the TRAINING MATRIX in this section).

On-going safety training is for all field employees up to and including Superintendents.

The consequence of doing the assigned readings and courses is a much greater likelihood of being safe on the job, of going home each evening to your family and friends with your heart still beating and all your body parts attached and functioning. Plenty of incentive!

But the consequence of doing the assigned readings and courses per the schedule in the Matrix is some nice extra money. You are going to do the reading and courses anyway, you may as well do them on time and get nicely rewarded for your efforts.

The consequence of not doing all the assigned readings and all the courses (as assigned to your job classification per the Matrix) is that you won’t be eligible for pay raises until you are current on all the assigned readings and all the courses.

The Individual Safety Incentive Programs are:

  • New-hire and Foremen Safety Incentive Program
  • Quarterly Safety Incentive Program for all field employees (with some modifications for new-hires during their first year with Hogan)
  • Yearly “Seasoned Employee Annual Safety Award” (SEAS) Program for all field employees (with some modifications for new-hires during their first year with Hogan)
  • Field Leadership Quarterly Safety Incentive Program (Superintendents, Foremen, Team Managers, Team Leaders)
 
 
1. NEW-HIRES: FIRST THREE MONTHS

New-hires are the most likely to be injured during work—76% of all our injuries happen to those with less than one year on the job! So we have a safety incentive program just for new hires.

To help our new-hires understand the importance of and the how of construction safety, we take them through several online courses before we send them to the field to start work. We also require they read the entire Safety Handbook during their first 90 days with Hogan—and pay them for the time it takes to do that reading and give them bonuses if they do the reading on time.

The readings—and awards—are broken into three periods (updated 01/2023):

 
 
2. QUARTERLY SAFETY INCENTIVE FOR ALL FIELD EMPLOYEES

Awarded if a field employee completes each quarter’s Safety Handbook reading assignments and associated quizzes plus the required training coursework for that quarter (per his or her job classification) by the last day of each quarter.

Q1 – Due by March 31
Q2 – Due by June 30
Q3 – Due by September 30
Q4 – Due by December 31

At our discretion, each quarter we may offer a gift to field employees who successfully finish the Safety Handbook reading and quiz assignments, as well as the required training coursework for that quarter. Gifts range from cash to clothing to company store credits. So it doubly pays to train: your own safety and nice gifts.

Field employees are personally responsible to complete the Safety Handbook reading assignments and quizzes plus the required training coursework. Once you complete a training or reading, a notification will be sent to HR for filing in your employee record and to Payroll so you can be paid for the time you spent training (see the page 48 Matrix for payment amounts).

We encourage field employees to complete their required trainings and readings each month to avoid the end-of-quarter deadline panic of trying to cram three months’ work into a couple of evenings.

If the employee forfeits this award by not finishing the training for that quarter on time, the employee is still required to do the training sometime before the end of the year. The employee will be compensated for the reading and course time regardless of when the training is completed during the year.

If an employee does not complete the training for the year, he or she won’t be eligible for any pay raises until the employee becomes current on all the assigned readings and all the courses.
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HINT #1: You can readily use a snow day or sick day to do much of your training for the quarter. That way you will still be paid for at least some of that day.

HINT #2: You can train ahead. For example, if you had a snow day in February, you could use the entire eight hours to do training not due until quarters two, three, or four.

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NEW-HIRE modifications to the quarterly safety incentive

New-hires are eligible for the Quarterly Safety Incentive per the column to the left, with these modifications:

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Safety Handbook Reading and Quizzes

Any new-hire with a start date in the first month of a quarter (January, April, July, or October) will need to read both period-one (“Introduction” through “Other Policies”) and period-two (“Aerial Lifts” through “Rebar Caps”) readings (see previous page) to be eligible for the Quarterly Safety Incentive at the end of that quarter.

Any new-hire with a start date in the second month of a quarter (February, May, August, or November) will need to read only period-one (“Introduction” through “Other Policies”) readings to be eligible for the Quarterly Safety Incentive at the end of that quarter.

Any new-hire with a start date in the third month of a quarter (March, June, September, or December) will not be eligible for that quarter’s Quarterly Safety Incentive. These new-hires will need to have finished all three period-one, -two, and -three reading assignments to be eligible for the Quarterly Safety Incentive award for the quarter after their start date quarter.

All three types of new-hires (first-month, second-month, and third-month) will need to have done all of the new-hire readings (the complete Safety Handbook) to be eligible for any subsequent quarter’s Quarterly Safety Incentives (until they begin the regular reading schedule as described in the next sub-section).

 
EXAMPLE new-hire READING FOR
QUARTERLY SAFETY INCENTIVE AWARD

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when do NEW-HIREs begin the sAMe reading schedule as everyone else

New-hires will have read the entire Safety Handbook and passed all the sectional quizzes during their first three months at Hogan. Consequently, they are not required to do the monthly reading assignments everyone else does until:

  • First-, second-, and third-quarter start dates: These new-hires will start to reread the Safety Handbook on the following January 1, per the schedule in the Matrix.
  • Fourth-quarter start dates: These new-hires will start to reread the Safety Handbook not on the following January 1, but starting with the January after that, one year out, and per the schedule in the Matrix.

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(See the example new-hire year transition to regular reading schedule graphic below.)

They are, however, still eligible for the Quarterly Safety Incentive awards if they do the required coursework beginning with the month following their hire date (see new-hire coursework section, right column).

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EXAMPLE new-hire YEAR transition to regular reading scheduleD

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New-hire Coursework

New-hires complete specific new-hire courses before starting in the field. They are paid for their time spent doing this training, though there are no financial incentives otherwise. (These courses are New-hire, EEO, Powered Industrial Trucks, Back Safety, and Silica. In addition, Iron Workers do Working from Heights and Steel Erection.)

Beginning with the first full month following their hire date, they are expected to complete the monthly coursework assigned for their respective job classifications (per the Matrix) just like seasoned employees (again, see illustration, below).

They receive pay compensation for this coursework per the Matrix.

There will be some months and may be a quarter when there will be no coursework scheduled.

PRORATED AWARD

As stated above, new-hires will be eligible for the Quarterly Safety Incentive awards if they complete their assigned coursework on time. Partial quarters, due to variability of when they start with Hogan, will have the quarterly incentive award prorated to match their personal training schedule (one-third or two-thirds of the total, again depending on when their start date).

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EXAMPLE new-hire coursework start date
(start regular courses the first full month in the field)

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3. Yearly safety incentive for ALL FIELD EMPLOYEES

The “Seasoned Employee Annual Safety Award” or the SEAS Award is given at the end of each calendar year to field employees based on completing each month’s assigned coursework and Safety Handbook reading assignments.

The SEAS awards grow in value the more years the employee has been with Hogan.
The award levels, based on years with Hogan, are:

  • Years 1 through 3: $100 each year.
  • Years 4 and 5: $150 each year.
  • Starting in your sixth year with Hogan, you get $300. Each year and every year thereafter—if you complete your monthly assigned Safety Training Courses and Safety Handbook Modules. (We do reserve the right to change the reading in future years to keep things fresh and interesting.)

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NOTE: You can qualify for the SEAS Award—doing all of the yearly training—even if you missed the deadline for any of the quarterly training incentives. For example, if you are a master procrastinator (a bad thing), you can do all of your year’s training in December and qualify for the annual SEAS Award, though you would have missed out on those awesome $100 quarterly awards.

NEW-HIREs

New-hires can also receive the SEAS award, though it will be prorated to match the number of quarters they have been participating in the regular employee coursework.

 
 
4. Field leadership QUARTERLY SAFETY INCENTIVE (updated 03/2022)

Superintendents and their Foreman will receive $200 each quarter if they do the following:

SUPERINTENDENTS & FOREMEN

  • Daily Production and Safety Meetings first thing in the morning
  • Weekly Subcontractor Safety Meetings
  • Weekly site inspections
  • Daily logs

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The following Hogan crews will hold their own Daily Production & Safety meetings first thing each morning and will be awarded $200 for holding these meetings:

  • Steel fabrication facility
  • Surveyors
  • Yard

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TEAM MANAGERS & TEAM LEADERS:

Team Managers and Team Leaders will also receive $100 each quarter if they ensure their employees attend the jobsite Daily Production & Safety meetings first thing each morning.

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ACCIDENTS

If there is an accident involving a subcontractor on a Hogan project, the site Superintendent or site Foreman is responsible to complete the “Subcontractor Accident Investigation” form (found in Procore in “Forms”).

In addition, contact Jared Morgan at 801-910-7011 immediately. He will decide if it is necessary to report the incident to OSHA. In Utah, employers are required to notify UOSH within 8 hours of occurrence of any fatality; disabling, significant, or serious injuries; or illnesses to workers. For Idaho and Wyoming, employers are required to notify OSHA within 8 hours for any fatalities, and 24 hours for inpatient hospitalizations, amputations, or losses of an eye.

UTAH UOSH: 801-530-6901
IDAHO OSHA: 208-321-2960
WYOMING OSHA: 307-777-7786

Tools, equipment, materials, or other evidence that might pertain to the cause of such accidents shall not be removed or destroyed until authorized by osha. You are also required to investigate all incidents of worker injuries and occupational illnesses.

Jared Morgan, Hogan’s VP over safety will be responsible to contact OSHA.

If a subcontractor is injured on a Hogan project, Hogan’s VP of Safety will be responsible to contact OSHA if it meets this definition:

“Employers are required to notify the respective OSHA state office within eight hours of occurrence of any fatality, or within 24 hours of any inpatient hospitalizations, amputations, or losses of an eye.”

 
Aerial Lifts

All personnel using aerial lifts must be trained and tied off as required by OSHA.

 
 
CLOTHING REQUIREMENTS for SUBCONTRACTORS

The following applies to all subcontractors on the jobsite. If subcontractor employees don’t comply, they may be sent home.

  • A minimum of T-shirt length sleeves on shirts.
  • Full-length trousers without large holes—short pants are not permitted.
  • Appropriate shoes for the work to be done. Most of the time this means sturdy work boots. Tennis shoes or flip flops are not permitted.

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For work inside the building of a Hogan project, when there isn’t any overhead work, ceiling grids are in, and the finishes are going in, the hard hat requirement may be lifted. Even though the hard hat requirement may be lifted at this stage of the project, subcontractors are still required to wear high-viz shirts or vests, safety glasses, work gloves, long pants, and a quality pair of boots. Our subcontractors will coordinate with the project Superintendent when the hard hat requirement may be lifted.

  • When subcontractors perform work outside the building, those crews must wear their hard hats at all times.
 
 
Competent Person

A competent person is defined as a person who has the ability and has been adequately trained to recognize hazards and has the authority to correct them or to stop work until they are corrected. Each subcontractor will have the responsibility to select, train, and authorize competent persons appropriate for their scope of work as required by OSHA. This includes but is not limited to trenching and excavations, scaffolding, steel erection, fall protection, roof fall protection, etc.

 
 
Emergency Plans

A loud horn is stored in each Hogan job office near the posted emergency information. In the event of an emergency where evacuation is necessary, the Superintendent or designated worker will sound the horn in sets of three until the project is completely evacuated. When the horn is sounded the subcontractor’s supervisor or foreman in charge will be responsible to account for all his or her company’s employees, and to report their status to the Hogan Superintendent.

All subcontractors are responsible to inform their employees of the emergency horn, and to train their employees on evacuation and other emergency plans.

 
 
Hazardous Communications Program (HazCom)

All subcontractors are responsible to have an OSHA-compliant HazCom program for themselves and any subcontractors under them. HazCom should be discussed at the preconstruction meeting(s), and each week during the safety and coordination meeting with the site superintendent (see “Safety Meetings” below).

 
 
Housekeeping

Continual housekeeping on the site is a process that must be maintained by everyone. Each subcontractor is responsible for the removal of debris and excess materials that result from their work. Those who do not clean up their debris may be charged the cost of having it cleaned up for them.

 
 
Ladder Safety

One of the most dangerous hazards on a construction site is also unsurprisingly one of the most common violations. It occurs when workers stand on the top or second-to-the-top rungs of an A-frame ladder. DO NOT make this dangerous mistake! OSHA requires, all employees who use ladders to be properly trained with documentation available upon request. This training is available on Hogan University.

 
 
Required Programs for Masons, Steel Erectors, Anyone with Work on the Roof

Due to the high risk of falls, Hogan requires site-specific safety plans from all:

  • Steel erectors
  • Anyone with work on the roof
  • Masons.

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Your safety plan is required when you turn in the "Subcontractor's Safety Form".

 
 
Safety Contract

In order to maintain a safety culture where all operations are conducted as safely and efficiently as possible, we have each subcontractor sign a Subcontractor Safety Contract wherein Hogan assigns the responsibility, authority, and accountability for all safety-related issues to the management and supervisory personnel of each subcontractor within their individual area of operation. The Subcontract Agreement places responsibility upon subcontractors to insure their sub-subcontractors and their individual employees perform their work in a safe manner and according to Hogan and OSHA policies.

As provided in the Agreement, payment may be withheld from the subcontractor, subcontractor employees may be expelled from the site, or other discipline may be assessed for safety noncompliance.

Payment will not be released until all pages of the Subcontractor Safety Contract are filled out, sent to Hogan, and approved. Due to the high liability, past incidents, and past OSHA citations involving these Masons, Steel Erectors, and Roofing subcontractors, the Subcontractor Safety Contract requires site-specific safety plans from them.

Our Project Assistants store the Safety Subcontracts in Procore where the jobsite Superintendent and jobsite Foreman can access them if needed. To find them, do the following in Procore.

  1. Go to the appropriate job in Procore
  2. Click on “Project Tools”
  3. Click on “Documents”
  4. Click on “Subcontractor Safety Acknowledgment”
 
 
Safety MEETINGS

While they are on the project working the job, all subcontractors are required to attend a weekly safety meeting with the Hogan superintendent and the other subcontractors on the project. The first agenda item should be safety. Use this meeting to coordinate, plan for, and communicate safety issues on the project. In addition to the weekly meeting with Hogan, each subcontractor is responsible to hold weekly safety meetings with their own crews to pass on information from Hogan as well as address trade-specific safety.

The template used for the weekly subcontractor safety meeting is found in Procore under “Forms” and in the Forms section of this book.

 
 
SAFETY PROGRAM

Each subcontractor is required to have a formal safety program in place and available for review upon request. At a minimum, this safety program should meet and enforce all OSHA standards.

 
 
SAFETY TRAINING

Each subcontractor should know when safety training is required for the activities of their employees and subcontractors under them. Each subcontractor is responsible to provide the training and to keep appropriate documentation available for review.

 
 
SILICA DUST

Subcontractors must take appropriate measures to control the dust from mason block cutting, concrete grinding, or wherever a silica dust hazard exists, so their employees and others are not exposed.

 
 
SUBCONTRACTOR DISCIPLINE

In the event a sub-contractor is found not following safety rules, the Superintendent may issue the “Sub-contractor OSHA Violation Warning”. If the problem continues, proper authorities should be notified so proper corrective action is taken. Superintendents should record dates and names and details of all verbal and written warnings.

The “OSHA Violation Subcontractor” form is in the “Forms” section of this Handbook as well as in Procore in “Forms”.

 
 
SUBSTANCE ABUSE

Drug or alcohol abuse is not tolerated. Subcontractors will be responsible for the investigation, testing, and if necessary, the discipline of their employees who are suspected of drug or alcohol abuse, possession of, or under its influence while on project grounds. If a subcontractor supervisor cannot be found, Hogan superintendents have the authority to dismiss workers from the site.

 
 
WORKERS COMPENSATION AND GENERAL LIABILITY INSURANCE REQUIRED

Subcontractors will not be allowed to start work on site until proof of worker’s compensation and general liability insurance has been submitted and approved by Hogan.

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Courses

Hogan provides a variety of training courses for employees, and we expect—and incent—our employees to avail themselves of this training. (See safety incentives on page 44.) The trainings vary per job title and are repeated yearly, every third year, or every fifth year as shown in the table.

Most of these courses are available on www.hoganuniversity.com so you can do them at your convenience. You will be paid your hourly rate for your time as shown in the online time pay compensation column.

Some courses include a hands-on component carried out at our Centerville Construction Training Site—a steel structure that simulates an actual building site, complete with manhole and underground, confined spaces training capability.

Readings

Employees are also required to complete monthly Safety Handbook readings and pass the readings’ associated quizzes. Both the readings and quizzes (or "assessments") can be accessed from your Workforce Now ADP portal home page. These readings are repeated yearly and you are paid the amount shown in the reading time pay compensation column.

Responsibility

You are personally responsible for noting the monthly and quarterly training and monthly reading requirements and accomplishing them.

Reporting

All Hogan University online training and reading quizzes will automatically send a completion certificate to HR for filing in your employee record.

Documentation

After you complete your safety training you will receive a “certification” card. Keep the card with you as you work. You may be checked by Hogan or Utah UOSH inspectors to make sure you have been properly trained.

You should check it yourself at the beginning of each month to be certain none of your training is about to expire. You may need to do some training before shown on this standardized schedule in order to stay current, and then repeat the training as shown on this schedule to be in sync with the company .

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