Company Safety
& Health Plan.

TK Improvement LLC will plan safe work, control hazards at their source and provide the equipment, supervision and instruction needed for each assignment. All workers must follow the applicable controls. The company will seek qualified outside assistance where its own knowledge or resources are insufficient.

President and program administration

Konstantin Ternavskiy, Owner and President, is responsible for administering this plan, budgeting for safety, selecting supervisors and competent persons, verifying subcontractor arrangements, reviewing incidents and authorizing corrective action. He may perform a technical role only after the qualifications for that specific role are verified and recorded.

Job supervisor and designated specialists

The assigned job supervisor conducts the pre-job review, briefs workers, checks conditions during the shift, coordinates trades and occupants, and ensures hazards are corrected before work resumes. A competent person must be able to recognize existing and predictable hazards in the assigned subject and have authority to correct them promptly. A qualified person must have demonstrated the expertise needed for the specific technical problem. These roles are task-specific and are recorded in Form A.

Designate competent persons for the hazards actually present, including scaffolds and silica. Use qualified persons for scaffold design, engineered fall-protection systems and other tasks requiring that expertise. A worker’s OSHA course card, job title or experience in an unrelated trade is not sufficient by itself.

Workers and subcontractors

• Employees inspect their equipment, use the specified controls, keep others clear, report changing conditions and decline tasks for which they have not been trained.

• Subcontractors remain responsible for their employees and must coordinate their controls with the company. A contract cannot remove an employer’s OSHA duties.

• Visitors and occupants must remain outside work and drop zones. The supervisor explains safe access routes and coordinates restrictions with the property owner.

Applicable rules

Construction and remodeling are governed primarily by 29 CFR Part 1926. Hazard communication and respiratory protection incorporate specific Part 1910 requirements; injury records and severe-event reporting are addressed in Part 1904. Federal OSHA covers private-sector employers in Pennsylvania and Delaware. Requirements for actual tasks, manufacturer instructions and applicable state and local rules must also be met.

Basis and related sources [1] [2] [3] [4]

Before mobilization, the supervisor completes Form B with the crew and affected subcontractors. Break the work into steps and identify who could be harmed, including residents, children, neighbors and delivery workers. Revisit the assessment when the sequence, crew, weather, materials or building condition changes.

Before removing a window or door

• Check the building age, coatings, hidden utilities, condition of the opening, structural support, access height and drop zone. Confirm the lead and asbestos screening decision before disturbing suspect material.

• Choose the working platform and fall protection before removing a sash, frame, trim or temporary guard. Plan how the opening will be secured if installation cannot be completed that day.

• Confirm unit weight and dimensions, lifting devices, carrying route, crew positions and the manufacturer’s installation sequence. Arrange temporary support before releasing fasteners.

• Coordinate dust containment and ventilation with fall protection, scaffold ties and emergency egress; containment sheeting must not conceal hazards or obstruct exit routes.

Choose controls in order

First eliminate the hazard or change the method, such as prefabricating on the ground, ordering precut material or using a lift. Then use physical controls such as guardrails, shrouds, water delivery and barriers. Use work sequencing, restricted access and training to support those controls. Select PPE for the remaining exposure. PPE does not justify avoidable exposure.

Stop work procedure

Any worker may call “STOP WORK.” Stop the affected task, make equipment safe if that can be done without exposure, keep people out and notify the supervisor. If the supervisor is unavailable or the issue remains unresolved, contact the President. Do not wait for permission to move away from danger.

The supervisor records the hazard and correction on Form K, obtains the necessary competent or qualified review, checks the correction in the field and briefs the affected workers. Restart only after the supervisor authorizes it and any required technical approval is documented. Nobody may override a technical hold merely to meet a deadline.

Mandatory holds

Hold work for missing fall protection or rescue arrangements; unstable access or structure; unknown energized services; suspect asbestos; unassessed lead or silica work; uncontrolled airborne dust; missing required credentials; failed equipment; uncontrolled public access; or weather that prevents safe control of people or materials.

Basis and related sources [2] [3] [5]

Before a subcontractor starts, the President or assigned supervisor completes Form J. Obtain the scope, supervisor and emergency contact; the applicable registrations and insurance evidence; task training; relevant credentials; planned equipment; and the subcontractor’s work methods. Check the actual documents and expiration dates. This manual does not assert that any subcontractor has already been approved.

Coordination before mobilization

• Identify which employer will provide access equipment, fall-protection systems, opening covers, power, dust controls, housekeeping and emergency support.

• Exchange hazardous chemical information and SDS, exposure-related hazards, lead and asbestos survey information, and the locations of exclusion zones.

• Review shared scaffold capacity, anchorage use, simultaneous work, overhead work and the effect of one trade’s demolition or removal on another trade.

• Brief every crew on site rules, reporting, stop-work authority, emergency signals, assembly point and safe occupant access.

During work

The company supervisor coordinates daily with the subcontractor’s lead person and records interface hazards in the job assessment. Inspect the conditions under the company’s control, respond to hazards reported by others and use available authority to require corrections. Do not assume that a subcontractor’s certification or insurance makes the work safe.

OSHA’s multi-employer policy considers creating, exposing, correcting and controlling employers. More than one employer can have duties for the same condition. Each employer must assess its actual role; assigning responsibility on Form J does not eliminate a duty imposed by law.

Unacceptable conditions

Stop the affected activity and protect workers and occupants. Require a corrective method, supporting qualification or replacement equipment as appropriate. Document the correction and restart approval. Repeated or serious violations may result in removal of personnel, suspension of the work or termination of the subcontract consistent with contract terms.

Before leaving the property

The departing trade hands over any unfinished opening, energized system, temporary support, containment or other continuing hazard to the receiving supervisor. Record the person taking responsibility, required restrictions and next inspection. Never leave a homeowner responsible for an unguarded construction hazard.

Use the same screening and coordination process for lower-tier subcontractors. Worker classification must reflect the actual relationship; calling a person a subcontractor is not a substitute for determining the company’s employer obligations.

Basis and related sources [5] [6]

The supervisor verifies training before assignment and observes the worker demonstrate the required method. Instruction must match the actual tools, hazards and language needs of the crew. Use an interpreter or translated materials when needed and confirm understanding through questions and practical demonstration.

Ongoing instruction

Company policy requires a brief task discussion at the start of each workday, a documented toolbox talk at least weekly during active work, and retraining whenever conditions change or unsafe performance shows a knowledge gap. These frequencies are company policy and do not replace specific regulatory training requirements.

An OSHA 10-hour or 30-hour Outreach card can support general awareness; it does not establish competence for every task or replace required task training. No such card or training history is represented by this plan.

Records and feedback

Use Form F for the topic, trainer, date, language, participants, practical assessment and follow-up. Fall-protection certification must identify each trained employee, training date and trainer or employer signature; record the adequacy-review date if relying on prior training. Invite worker suggestions and report the outcome of hazard corrections.

Basis and related sources [3] [7] [8] [9] [10]

The supervisor records task PPE in Form B. The company provides required PPE at no cost except where a specific OSHA payment exception applies, verifies proper fit for each worker, and replaces damaged or unsuitable equipment. Worker-owned PPE must meet the same requirements.

Selection for residential work

• Eyes and face: use safety eyewear with side protection for cutting, drilling, fastening and debris. Add appropriate goggles for dust or splash and a face shield for flying fragments or glass work; a shield supplements eye protection.

• Hands and arms: select cut-resistant gloves and sleeves for glass and sharp metal; select chemical-resistant gloves from the SDS and manufacturer’s compatibility information. Avoid loose gloves where rotating equipment can entangle them.

• Head and feet: provide suitable head protection where impact, falling objects or electrical hazards exist. Use protective footwear selected for impact, puncture, slip and electrical hazards; ordinary shoes are unsuitable for active construction work.

• Hearing: use quieter equipment and isolate noise sources. Provide suitable hearing protection for noisy cutting, grinding and powered fastening; instruct workers in fit and use.

• Body and visibility: wear close-fitting clothing and secure hair and jewelry. Use high-visibility clothing around vehicles and equipment. Provide knee protection for prolonged flooring work and clothing suited to weather and contaminants.

Noise assessment

Evaluate exposure when loud operations occur, several tools run together or duration increases. Construction Table D-2 permits 90 dBA for 8 hours and 100 dBA for 2 hours, with combined exposures evaluated together. Apply feasible engineering or administrative controls and a continuing hearing conservation program when required by 1926.52. Company policy requires hearing protection for high-noise tasks while assessment is pending; that precaution is not proof that exposure is acceptable.

Use and care

The worker checks PPE before use, reports poor fit or damage, cleans it as instructed and stores it away from chemicals and sunlight. The supervisor confirms that combined items do not interfere with each other: eyewear must not compromise a respirator seal, and clothing must not prevent a harness from fitting.

Respirators are addressed in Section 16. A disposable dust mask used because the task requires respiratory protection is a respirator and triggers the applicable program requirements.

Basis and related sources [11] [12] [10]

Plan access and edge protection before the crew removes windows, doors, railings, siding or flooring. Check that the supporting surface is sound. Never stand on a sill, loose framing, a bucket or an unapproved makeshift platform to gain height.

OSHA triggers for this work

Residential construction generally requires fall protection at 6 feet or more above a lower level. At a wall opening, protection is required when its outside bottom edge is at least 6 feet above the lower level and its inside bottom edge is less than 39 inches above the working surface. Apply the task-specific rules for holes and dangerous equipment; protect trip and step-through hazards even below a fall-height trigger. Scaffold and ladder requirements are addressed separately.

Company work method

• Use a properly designed work platform and collective protection, such as guardrails, where feasible. If a guard must be removed to receive a unit, establish the alternate protection before removing it.

• Measure the drop on both sides of the opening. Interior work can expose a worker to an exterior fall. Insect screens, taped plastic and a new unit resting loosely in the opening are not fall protection.

• Secure temporary covers against movement, mark them clearly and confirm their load capacity. Do not use thin scrap sheet material or unfastened plywood as a cover.

• Secure tools and materials, maintain a drop zone and keep residents and workers away from the area below. Coordinate any lifting operation with the installers’ fall-protection method.

System criteria

Subpart M guardrail top edges are generally 42 inches plus or minus 3 inches, with intermediate protection and required strength. A typical hole cover must support at least twice the maximum load expected at one time, be secured and be marked. Use a designed system that satisfies the full standard; these dimensions alone do not establish compliance.

No routine exception for difficult work

The company does not authorize unprotected work because a job is short, a ladder is inconvenient or an anchor is absent. A residential alternative fall-protection plan under 1926.502(k) is a narrow, site-specific exception requiring a demonstrated infeasibility or greater hazard and qualified-person development. This company manual and Form D are not that exception plan. Stop and obtain a separate compliant plan if such an exception is proposed.

Basis and related sources [13] [14] [15]

Before personal fall arrest is used, the supervisor and the appropriate competent or qualified person complete Form D. Prefer prevention of a fall when a properly designed restraint system or guarded platform is feasible. A harness alone provides no protection.

System selection

• Use a full-body harness, compatible locking connectors and a suitable energy-absorbing lanyard or self-retracting device selected for the worker, task, anchorage location and edge exposure. Follow all manufacturer limits.

• Fall-arrest anchorages must support at least 5,000 pounds per attached employee or be part of a complete system designed, installed and used under a qualified person with a safety factor of at least two. Never assume trim, a window frame, plumbing, a gutter or a guardrail is an anchor.

• Plan free fall, deceleration, harness movement, worker height, swing fall and clearance to obstacles. The standard limits free fall to 6 feet and prohibits contact with a lower level; manufacturer requirements may be more restrictive. A standard lanyard may be unsuitable at a low window opening.

• Inspect before each use. Remove defective or impact-loaded equipment from service and quarantine it for competent review and any required manufacturer action. Never return it on appearance alone.

Practical rescue arrangements

Specify who can reach the suspended worker, the rated rescue or access equipment, where it will be kept, how rescuers remain protected, and how EMS will enter. Check actual access and communication before work. Calling 911 is part of the emergency response; it is not, by itself, a demonstrated method of prompt retrieval from suspension.

Only people trained and equipped for the planned rescue may perform it. Do not create a second casualty by climbing to an unprotected edge, cutting a loaded line or improvising a rope system. If the planned method cannot be delivered promptly, choose another work method before exposure.

During and after a fall

Raise the alarm, call 911, stop nearby work, protect the area and activate the planned rescue. Provide first aid only within training and follow emergency responders’ instructions. Remove affected equipment and anchors from use, preserve evidence, notify the President and reassess the work method before restarting.

Workers must demonstrate correct harness fitting, connection, movement through the task and recognition of inadequate clearance. Review rescue arrangements whenever the work position or access changes.

Basis and related sources [14] [9]

Select a ladder for the height, total load, surface and electrical environment. For handling a large window, sustained two-handed work or significant sideways force, the supervisor must choose a platform or lift that permits control of the task. A helper holding a ladder does not correct an unsuitable work method.

Inspection and setup

• A competent person inspects ladders periodically and after an event that may affect safe use; company policy also requires a user check before each use. Check rails, steps, feet, locks, ropes, labels and contamination. Tag and remove defective ladders.

• Set a non-self-supporting ladder so the horizontal base distance is approximately one-quarter of its working length. Secure it against displacement and use sound, level footing; do not raise it with blocks or debris.

• For upper-level access, extend side rails at least 3 feet above the landing. If that is not possible, secure the top to a rigid support and provide a suitable grasping device. Arrange safe step-off and access.

• Open stepladders fully and lock spreaders. Do not use the top or top step as a step. Do not use a closed stepladder as a leaning ladder unless designed for that configuration.

Safe use

Face the ladder and maintain secure hand contact while climbing. Company policy requires three points of contact during climbing and prohibits carrying a window, door or other load that prevents a secure grip. Hoist tools or use a suitable belt. Keep the body between the rails; climb down and reposition rather than overreach.

Keep the top and bottom clear and protect ladder locations from doors, traffic and vehicles. Do not move or extend an occupied ladder. Use nonconductive rails where contact with exposed energized parts is possible, while also controlling the electrical hazard. A fiberglass ladder does not make electrical contact safe.

Temporary stairs and changes in level

Provide a stairway or ladder where a required access break in elevation is 19 inches or more and no other permitted access is provided. Stairs with four or more risers or a rise over 30 inches, whichever is less, require at least one handrail and a stairrail along each unprotected side. Keep treads and landings stable, lit and clear; check the full stair requirements before use.

Portable ladders have their own OSHA requirements. Do not apply the scaffold threshold or assume that a harness must be attached to the ladder. Any additional fall-protection arrangement must be properly designed for the actual task.

Basis and related sources [16] [7] [17]

Use manufactured scaffolds and platforms suitable for the building, ground and intended loads. A qualified person designs the scaffold; a competent person directs erection, alteration, movement and dismantling by trained workers. Record the assigned persons and the configuration before use.

Scaffold controls

Under 1926.451, scaffold fall protection is generally required more than 10 feet above a lower level, with the required system depending on scaffold type. Company policy is to use compatible guardrails on supported work platforms at 6 feet or more where feasible and to assess lower heights. Ladder-jack scaffolds require personal fall arrest at the regulatory trigger; do not assume a plank between ladders is a complete system.

• Check footing, base plates, bracing, ties, planking, platform access, capacity and falling-object protection. Scaffold components must support required loads; do not overload a platform with windows, siding or debris.

• Inspect by a competent person before each work shift and after an event affecting integrity. Tag unsafe equipment and prevent access. Recheck ties when siding or trim is removed.

• Keep platforms clear. Do not stand on rails or place ladders or boxes on platforms to gain height. Use proper access rather than climbing cross braces.

• Stop for storms, excessive wind, ice, unstable ground or unsafe power-line proximity. Screens and containment increase wind loads and require a suitability review.

Mobile scaffolds and pump jacks

Follow the applicable 1926.452 provisions and manufacturer instructions for the exact configuration, including stability, bracing, load and access. Lock casters when stationary. Company policy prohibits riding a mobile scaffold while it is moved. Pump-jack work requires a separate setup review, appropriate bracing, platform protection and manufacturer instructions; improvised poles or mixed components are not permitted.

Boom lifts and scissor lifts

Authorize only trained operators familiar with the unit. Inspect controls, emergency lowering, guardrails, ground conditions and overhead hazards. Use required fall protection attached only to an approved anchorage; remain inside the platform and never tie off to an adjacent structure. Follow the equipment-specific rule and manufacturer instructions: boom lifts and scissor lifts do not have identical requirements. Establish a ground person, exclusion zone and emergency lowering procedure.

Basis and related sources [18] [19] [20] [8]

Only trained and authorized workers may use powered equipment. The supervisor confirms the tool, blade, fastener and work support are suitable for the material. Read the manufacturer instructions and inspect rented equipment before accepting it.

Inspection and isolation

Before use, check guards, switches, handles, cords, batteries, blades, bits, hoses and safety devices. Keep guards functional; never wedge a guard open. Tag defective tools and remove them from use. Unplug, remove the battery or isolate the air supply and release stored pressure before changing accessories, clearing jams or servicing. A trigger lock is not energy isolation.

Saws and cutting

• Support long pieces and offcuts to avoid pinching the blade or dropping material. Clamp small workpieces; keep hands out of the cut path and use the manufacturer’s push devices where appropriate.

• Maintain required guarding and anti-kickback equipment on table saws. Position the operator away from the kickback path and keep helpers clear. Let the blade stop before reaching near it.

• Use the correct rated blade or abrasive wheel, guard and speed. Do not use a cracked wheel or a toothed saw blade on a grinder not designed for it.

• Use dust extraction or wet methods suited to the material. Before cutting older finishes, flooring, masonry or fiber-cement, complete the applicable lead, asbestos or silica assessment.

Nailers and pneumatic tools

Company policy requires a full sequential trigger for nail guns where that option is available for the task. Keep hands away from the fastening path and the opposite face of thin material. Never carry a tool by its trigger, aim it at anyone, bypass the contact safety or clear a jam while connected. Secure hose connections and use the correct pressure and fittings. Treat an injection injury as an emergency.

Other equipment

Powder-actuated tools require tool-specific training, authorization, daily functional checks and a separate site review of the substrate and exclusion area. Do not use them in explosive or flammable conditions. Keep knives sharp, cut away from the body, cover stored blades and use a dedicated sharps container.

Charge batteries with the specified charger in a protected, ventilated location away from combustible waste. Remove damaged, swollen or overheating batteries from service. Do not use compressed air to clean lead or silica dust from people, clothing or work areas.

Basis and related sources [21] [22] [23]

Before drilling, cutting or removing trim, locate hidden wiring and services, check accessible spaces and review owner information. Assume an unknown wire is energized. Stop for damaged service equipment, exposed conductors, water near electricity or any need to work close to an overhead line.

Temporary power

OSHA requires GFCI protection or a compliant assured equipment grounding conductor program for covered construction power use. Company policy selects GFCI protection for all 120-volt, single-phase, 15- and 20-amp receptacles supplying portable tools on company jobs, including use of existing residential outlets. Test the GFCI before each day’s use and after relocation according to its instructions. Do not substitute an unimplemented grounding program.

• Use grounded or approved double-insulated tools and intact cords rated for the load and conditions. Never remove a ground pin, use a damaged plug or make taped makeshift repairs.

• Protect cords from traffic, sharp edges, doors, standing water and hot surfaces. Keep connections dry and use listed covers and equipment suitable for outdoor exposure.

• Use a qualified electrical worker for electrical diagnosis, circuit repair or generator bonding and grounding decisions. Never backfeed a home through a receptacle.

Deenergizing and securing circuits

Identify every energy source, including backfeed and stored energy. An authorized qualified electrical worker deenergizes the circuit, secures and tags controls as required by 1926.417, and verifies absence of voltage with appropriate equipment before exposure. The supervisor coordinates all affected trades and occupants. Only the authorized person may release the isolation after the area is checked and affected people are notified.

Company employees do not perform energized electrical repair under this plan. When safe isolation cannot be confirmed, stop and obtain a qualified electrician. Work-specific electrical procedures are required before any expanded electrical scope is authorized.

Overhead lines and generators

Identify line voltage and applicable equipment clearance before positioning ladders, scaffold, lifts or long siding and trim. Company policy uses a minimum 10-foot exclusion zone for ordinary work near lines up to 50 kV, with greater separation where required; stop when voltage is unknown. Have the utility arrange protection or deenergization if the required clearance cannot be maintained.

Use fuel-powered generators outdoors, positioned so exhaust cannot enter doors, windows, crawlspaces or air intakes. Never operate them in a house or attached garage, even with doors open.

Basis and related sources [24] [25] [26] [18]

This section, Section 13 and the completed Form E make up the company’s silica exposure control plan for the tasks selected at each job. It must be implemented before cutting, drilling, grinding or demolishing concrete, mortar, brick, tile, stone or fiber-cement. No exposure data or completed assessment is supplied by this manual.

Select the compliance method

The silica action level is 25 micrograms per cubic meter and the permissible exposure limit is 50 micrograms per cubic meter, each as an 8-hour time-weighted average. For a listed task, fully and properly apply OSHA Table 1, including its equipment, work practices and respirator requirements. Otherwise use the alternative exposure-control route with representative monitoring or valid objective data and necessary controls. Visible dust is not a reliable measure of exposure.

Company control procedure

• Plan lower-dust methods first: order precut material, use suitable shears, or move cutting to a controlled outdoor station away from residents, air intakes and other crews.

• List each task, material, tool, duration, location, dust control and respiratory requirement on Form E. Attach the actual Table 1 row or exposure-assessment basis; a generic shop vacuum or a wet blade alone is not a complete determination.

• Set barriers and signs around dust-generating work. Keep nonessential workers away and coordinate exposure from other trades. Maintain ventilation without pushing contamination into occupied areas.

• Use HEPA vacuuming or wet cleanup. Company policy prohibits dry sweeping, dry brushing and compressed-air cleanup of silica dust. Handle settled dust, slurry and vacuum bags so they do not dry out or become airborne.

• Check water flow, shrouds, hoses, airflow, filters and dust collection throughout the task. If control fails, stop, isolate the area, repair the cause and reassess before resuming.

Administration and health follow-up

Designate a silica competent person to implement the plan through frequent and regular inspections. Review its effectiveness at least annually and whenever tasks change. Keep it readily available to workers and authorized representatives. Train workers on health effects, tasks, controls, the competent person and medical surveillance.

Provide silica medical surveillance at no cost when a worker must use a respirator under the silica standard on 30 or more days in a year. Track any day of required use. The initial examination is generally due within 30 days of assignment and periodic examinations at least every three years, subject to the standard and clinician recommendations. Required respirator use also requires Section 16 controls.

Basis and related sources [27] [28] [29]

These are starting configurations for common company work, not a replacement for the complete Table 1 row. The supervisor and silica competent person verify equipment, duration and setting before release. If combined Table 1 tasks exceed four hours in a shift, use the more-than-four-hour respirator column for each task.

Fiber cement siding

For Table 1 item (iii), use a handheld saw with a blade 8 inches or less outdoors, with a commercially available dust collection system providing at least the tool maker’s specified airflow and filtration of at least 99 percent. Maintain and use the system as instructed. When all conditions are met, Table 1 specifies no respirator for either duration column. Indoor cutting or a larger blade does not qualify under that row.

Masonry and tile cutting

A stationary masonry saw under item (i) uses integrated water delivery continuously feeding the blade; Table 1 specifies no respirator for either duration column when fully implemented. A handheld power saw under item (ii) also uses integrated water delivery: outdoors, no respirator is specified for 4 hours or less and APF 10 is specified for more than 4 hours; indoors or enclosed, APF 10 applies for either duration. Provide the required indoor exhaust.

Anchor drilling

For handheld or stand-mounted drills under item (vii), use a commercially available shroud or cowling and dust collector with at least the manufacturer’s specified airflow, at least 99 percent filtration and a filter-cleaning mechanism. Clean holes with a HEPA vacuum. Table 1 specifies no respirator for either duration column when fully implemented.

Grinding and removal work

Do not treat mortar removal, general grinding, floor grinding and chipping as interchangeable. Each has a different Table 1 entry and may require different airflow, wet controls or respiratory protection. Before grinding a floor, assess old coatings and adhesives for asbestos and lead as well as silica. Attach the applicable complete entry and method to Form E; otherwise hold the task for exposure assessment.

When Table 1 cannot be followed

Obtain a competent exposure assessment using representative personal air monitoring or objective data that match the material, method and conditions. Under the scheduled-monitoring option, repeat within six months for exposures at or above the action level and at or below the PEL, and within three months above the PEL. Provide written assessment results within five working days. Reassess changed conditions and use the standard’s criteria for ending monitoring.

APF means assigned protection factor. Selecting an APF does not by itself select a safe respirator; the written respiratory program and the actual contaminant must be considered.

Basis and related sources [27] [28] [29]

Before disturbing paint, record the building’s construction date and all affected components. For pre-1978 housing or child-occupied facilities, determine RRP coverage before pricing, advertising or performing covered work. If age or coating status is unknown, treat the work as potentially covered until an acceptable determination is documented.

Coverage and credentials

Window replacement and demolition of painted surfaces do not qualify for the minor repair area exemption. Other minor work may qualify only if all conditions are satisfied, including no more than 6 square feet of disturbed interior paint per room or 20 square feet on the exterior. Do not split a project to evade coverage or rely on a homeowner’s waiver.

For Pennsylvania work, verify the company’s applicable EPA firm certification and the assigned certified renovator’s current training credentials. For Delaware work, verify Delaware Division of Public Health certification for the firm and the relevant individual; do not assume EPA firm certification alone authorizes work in Delaware. Store actual certificates in the job file. This plan confers none of those credentials.

Prework information and Delaware requirements

Provide the required Renovate Right information before covered work and document receipt or authorized delivery procedures. Under the federal rule, distribution is no more than 60 days before the renovation; mailing has additional timing requirements. Review owner, tenant and child-occupied-facility notices as applicable.

For Delaware, use the current DPH forms and requirements. Its published RRP notification form requires receipt five business days before the work start date and an updated notice for a changed start date. Complete the required Occupant Protection Plan and retain it on site; observe its distribution requirements, including advance delivery for restricted practices. Verify the current process with DPH before the job; Form G is an internal tracking sheet, not the state filing.

Testing and scope

An allowable lead-free determination must cover all affected surfaces and be made using an authorized method by the appropriate certified person. A casual test by an untrained worker is not sufficient. Preserve the report and component locations. OSHA worker-exposure duties still require separate assessment; RRP exemptions or results are not a blanket OSHA exemption.

Lead abatement and renovations subject to HUD or other additional rules require separate scope and credential review. Do not market ordinary renovation as certified lead abatement. Use appropriately authorized specialists when that work is needed.

Basis and related sources [30] [31] [32] [33] [34] [35]

Containment and completion

The assigned certified renovator directs covered RRP work and documents worker instruction. Under federal RRP, the renovator is physically present for sign posting, containment setup and cleaning, and available on site or by phone throughout renovation. Establish occupant separation and safe passage. Interior floor protection generally extends 6 feet and exterior ground protection 10 feet, or farther to contain debris; approved vertical containment provisions may apply. Protect doors, windows and HVAC and prevent migration to adjacent property.

Prohibit open-flame paint removal. High-speed paint-removal equipment requires compliant shrouds or containment with HEPA extraction; heat guns must operate below 1,100 degrees Fahrenheit. Company policy favors wet hand methods and controlled component removal where practical. Protect workers from sharp edges and falls while preserving containment.

Contain waste, clean with the prescribed HEPA and wet methods, and prevent dust tracking. The certified renovator performs the applicable visual inspection and interior cleaning verification, or required dust clearance is performed by an authorized person. Record results and release the area only after the applicable completion criteria are met. Follow Delaware’s program for Delaware jobs.

OSHA lead controls

OSHA 1926.62 protects workers and applies separately from RRP. Its action level is 30 micrograms per cubic meter and its PEL is 50 micrograms per cubic meter as an 8-hour average, with adjustment for longer workdays. An initial exposure determination is required when lead exposure may occur.

Specified lead tasks, including manual scraping, sanding, demolition of lead-painted structures and heat-gun use, require interim protections until an assessment establishes actual exposure. Higher-exposure tasks have higher presumed protection levels. Before such work, the President must obtain competent exposure advice and implement the required respirator, protective clothing, changing facilities, handwashing, training and initial biological monitoring. Do not start by issuing an unselected dust mask.

Where required, implement a task-specific written lead compliance program, engineering and work-practice controls, monitoring and medical removal protection. Update the program at least annually. Provide initial biological monitoring for exposure at or above the action level on any day; a continuing medical surveillance program applies for such exposure on more than 30 days in 12 months. Provide the required initial and annual worker training.

Hygiene and records

Keep food, drink, tobacco and cosmetics out of contaminated areas. Wash hands and face before breaks; use clean eating areas and prevent contaminated clothing from entering vehicles or homes. Store medical information confidentially. Preserve RRP records for at least three years and provide federal post-renovation compliance information with the final invoice or within 30 days, whichever is earlier. Preserve employee exposure and medical records under their longer rules.

Basis and related sources [36] [37] [38] [39] [40] [62]

Required respirator use is prohibited until this program is implemented for the actual task. The President appoints an administrator qualified by training or experience and records the appointment on Form A. The administrator completes Form L and any additional written procedures needed for the selected equipment and exposures.

Before first required use

• Evaluate the contaminant, exposure and oxygen conditions. Select a NIOSH-approved respirator with the appropriate filter or cartridge, protection factor and use limits. A particulate filter does not protect against solvent vapor or carbon monoxide.

• Obtain a confidential medical evaluation by a physician or other licensed health care professional before fit testing or required use. Follow the written limitations and any required follow-up.

• For tight-fitting respirators, complete an accepted fit test for the exact make, model, style and size before use, at least annually and when changes may affect fit. No facial hair or other condition may interfere with the seal.

• Train workers in use, limits, inspection, seal checks, emergency exit, care and storage. Repeat training at least annually and when needed. A user seal check is required each time a tight-fitting respirator is donned; it does not replace fit testing.

Task procedures

Specify who uses each respirator and for which tasks, how workers enter and leave the area, how filters and cartridges are changed, and how the equipment is cleaned, disinfected, inspected and stored. Establish a cartridge change schedule based on objective information where required; odor alone is not an acceptable schedule.

Stop and leave the exposure area for breathing difficulty, breakthrough, leakage, damaged equipment or a control failure. Report the condition and do not reenter until it is assessed and corrected. Never use an air-purifying respirator in an oxygen-deficient, unknown or immediately dangerous atmosphere. Such conditions are outside this plan’s authorized work.

Voluntary use

The administrator must first determine that voluntary use is safe and that protection is not required by the exposure or company rule. Provide OSHA Appendix D information. Voluntary filtering-facepiece use has a limited written-program exception; voluntary use of other respirators requires the applicable medical, maintenance and written-program elements. Do not label required use “voluntary” to bypass controls.

Evaluation and records

The administrator observes actual use and consults workers to correct fit or performance problems. Keep the written program, training records, medical clearance documentation and fit-test records, with medical information restricted. Maintain fit-test records until the next test and retain medical records under applicable requirements.

Basis and related sources [10] [41] [42]

This section and the completed chemical inventory in Form H constitute the company’s written hazard communication program. The President administers it; the job supervisor maintains the site copy and introduces new products only after review. It covers employees exposed to hazardous chemicals during normal work or foreseeable emergencies.

Inventory and access

List the exact product identifier, manufacturer, work location and SDS location for sealants, foams, adhesives, primers, paints, solvents, fuels, cleaners and other hazardous products. Obtain the current SDS before use and update the list when products change. Do not assume a household-branded product is exempt when construction exposure is more frequent or prolonged than ordinary consumer use.

Keep SDS immediately accessible during every shift, in a labeled binder or a reliable electronic system with a practical offline backup. Workers must be able to retrieve them without asking an unavailable manager. Record the site location and access method in Form H and show the crew.

Labels and use

Keep manufacturer labels legible. Label workplace containers with the product identity and hazard information under an approved workplace system; observe the limited immediate-use exception. Never use a beverage bottle or an unlabeled container. Explain pictograms, signal words, hazard statements, protective measures and emergency information to exposed workers.

• Before use, review the product’s ventilation, incompatibility, storage, skin and eye protection, first aid and spill instructions. Prefer a less hazardous product where suitable.

• Evaluate vapor and sensitization hazards from spray products, two-component foams, epoxy systems and isocyanate-containing products. Ordinary dust controls are not a vapor-control plan.

• Separate incompatible chemicals, close containers, control ignition and protect containers from heat and damage. Keep only needed quantities at the work area.

Nonroutine tasks and other employers

Before a new process, spill response, adhesive removal or work on an unknown pipe or container, the supervisor briefs the affected workers on hazards and controls. Exchange chemical lists, SDS access, labeling systems and protective measures with subcontractors before their employees may be exposed.

Only trained workers may handle a small incidental spill within the product procedure and their equipment capability. Unknown, large, reactive or airborne releases require evacuation and emergency assistance. This plan does not authorize hazardous-material emergency response.

Basis and related sources [43] [44]

Residential remodeling can encounter asbestos in resilient flooring, backing, mastics, siding, roofing, pipe insulation, textured coatings and other materials. Appearance or a homeowner’s statement cannot establish that a suspect material is asbestos-free.

Required screening

Ask the owner for surveys, laboratory reports and known hazardous-material information. Identify every material affected by removal, drilling or cutting. OSHA presumes certain older thermal insulation and surfacing materials to contain asbestos and imposes specific presumptions for older resilient flooring; age alone does not rule out asbestos in other materials.

Before disturbing suspect material, stop and obtain a determination from an appropriately qualified or licensed asbestos professional using proper sampling and laboratory methods. Employees must not pull samples, sand suspect flooring, break siding shingles or sweep unknown debris under this manual.

If suspect material is found

• Stop the affected operation. Keep occupants and other trades out and avoid tracking dust or debris.

• Do not dry sweep, use compressed air, vacuum with an ordinary vacuum or continue demolition to “finish the opening.”

• Notify the supervisor and property owner, document the location and arrange competent assessment and any required specialist control or removal.

• Resume only after the affected scope has been assessed, appropriate work is completed, and the company has received the documentation needed for safe reentry and follow-on work.

Limits of authorized work

This manual does not authorize asbestos abatement or disturbance. Such work requires a separate compliant program, qualified personnel, applicable licenses and notifications, exposure controls and training. If the company later adds asbestos work, the President must complete that program before contracting for or performing it.

Other concealed hazards

Stop for unknown chemical containers, strong unexplained odors, sewage, extensive mold, animal waste, damaged fuel lines or suspected contaminated soil. Identify the source and obtain specialist advice where required. Do not combine cleaning products or apply a chemical treatment to an unknown material.

For water-damaged framing or floors, assess structural stability before entry or material storage. Isolate any damaged wiring. For biological contamination, establish suitable hygiene and protective measures before cleanup; this manual is not a remediation or hazardous-waste response plan.

Basis and related sources [45] [43]

Plan every large window or door movement before unloading. The supervisor confirms weight, dimensions, center of gravity, unit condition, carry route and installation position. There is no universal safe one-person weight limit; consider grip, size, reach, stairs, repetition, wind and individual capability.

Preparation

• Use a suitable cart, dolly, glass rack, vacuum lifter or other rated aid where practical. Inspect lifting cups and devices, confirm capacity for the surface and orientation, and follow the manufacturer’s limits.

• Use a coordinated team when the task cannot be safely controlled by one person. Assign one person to call the move; agree on lift, lower, stop and emergency commands.

• Clear and light the route, remove trip hazards, protect sharp edges and keep occupants clear. Plan a stable set-down location before lifting.

• Inspect glass for cracks, damaged edges and loose parts. Use suitable cut-resistant gloves and sleeves, eye protection and protective footwear; add face protection where fragments may strike.

Moving and installing

Keep the load close where possible, avoid twisting, and use controlled steps. Keep fingers out of pinch points and never place a body part beneath an unsupported unit. Do not carry a large panel while climbing a ladder. Do not attempt to catch falling glass.

Store units on suitable padded racks or supports, restrained against tipping and protected from impact. Do not lean unsecured panels against walls or leave them across an exit. Secure racks and loads during transport and unload from stable ground.

At the opening, establish temporary support and restraint before removing packaging, old fasteners or lifting aids. Confirm the manufacturer’s fastening sequence and that the unit is secured before releasing its support. Keep installers protected from falls throughout the handoff. Pause when wind prevents reliable control of a panel.

Mechanical lifting

Inspect rigging before each shift and as needed during use; use labeled equipment within rated capacity and remove defective items. Never lift people with material-handling devices or stand under suspended loads. Crane, hoist or powered industrial-truck operations require their applicable equipment-specific requirements and trained personnel before use.

Breakage and repetitive work

Isolate broken glass immediately. Use tools, rigid puncture-resistant containers and suitable PPE to collect fragments; never pick them up with bare hands. Plan material staging and task rotation to reduce repeated awkward lifts, overhead reach, kneeling and forceful gripping.

Basis and related sources [46] [47]

Before removing walls, floors, framing, stairs, decks or large openings, determine what supports the building and what services are present. Do not assume a wall is non-load-bearing because it is thin or because a homeowner says it can be removed.

Survey and sequence

Where demolition work is involved, 1926.850 requires an engineering survey by a competent person before work to determine structural conditions and the potential for unplanned collapse, with written evidence retained. Arrange qualified structural design where load paths, lintels, temporary shoring or opening changes require it.

• Document the removal sequence, temporary supports, waste route and limits on loading floors and platforms. Install specified support before cutting structural members.

• Locate and control electrical, gas, water and other services; have the appropriate trade isolate them. Verify that hidden services cannot be struck by a saw, drill or fastener.

• Assess lead, asbestos and silica before destructive work. Keep occupants outside dust and collapse zones and maintain a safe exit.

• Do not remove braces, scaffold ties, guardrails or supports without approval and a safe replacement method. Protect newly exposed floor and wall openings immediately.

Trade-specific controls

For siding, secure panels and offcuts, protect against sharp edges and account for wind. Select the access and dust-control method before work moves around the building. For flooring, investigate old adhesive and backing before scraping or grinding, control blade access, ventilation and trip transitions, and avoid overloading floors with material stacks.

For carpentry and trim, support long stock, check for nails and hidden fasteners and stabilize workpieces before cutting. Maintain temporary doors, barriers and security without trapping occupants or blocking escape.

Work requiring a separate program

Trenching or excavation, permit-required confined-space entry, major structural demolition, asbestos work, lead abatement, energized electrical work, crane operations and specialized hot work are not released by this manual alone. The President must obtain the task-specific plan, equipment, qualifications, permits and training required before such work is accepted or started.

Attics and crawlspaces require a pre-entry evaluation for access, structure, electricity, heat and hazardous atmospheres. If a space may be permit-required, stop; no employee enters or attempts rescue until the applicable construction confined-space procedures are established.

Basis and related sources [48] [25] [45]

Daily site condition

Keep stairs, exits, platforms and work areas free of offcuts, cords, packaging and loose fasteners. Remove or bend protruding nails. Provide stable containers for sharp scrap and glass; separate hazardous waste. Clean during the work and before leaving, rather than allowing hazards to accumulate until the final cleanup.

Secure material stacks against tipping or sliding and keep floor loads within capacity. Maintain adequate lighting. Route cords and hoses away from paths, protect changes in floor level and prevent sheeting from becoming a slip hazard. Use the contaminant-specific cleaning method; ordinary sweeping is not appropriate for lead or silica dust.

Occupied homes

Agree with the owner on work zones, temporary access, pets, children and daily shutdown. Maintain barriers and signs, secure tools and chemicals, and keep residents out of unfinished openings and unstable areas. Check each day that required exits, smoke detection and emergency access remain available. Do not leave a building unsecured or an opening exposed overnight.

Sanitation

Provide potable drinking water, sanitary drinking arrangements, usable toilet facilities and handwashing appropriate to the work. Do not assume the homeowner’s facilities are available without arranging access. Provide the changing, washing and clean eating arrangements required by lead or other exposure rules.

Heat and cold

Company policy requires accessible cool drinking water, rest breaks and a cool or shaded recovery area when heat exposure is present. The supervisor considers humidity, direct sun, workload, protective clothing and indoor heat. Schedule heavy work for cooler hours, increase breaks as conditions worsen and use a buddy system. Gradually acclimatize new or returning workers; do not assign a full strenuous heat exposure on the first day.

Train workers to report symptoms promptly. Confusion, collapse or other suspected heat stroke requires 911 and immediate cooling while help arrives. For cold, provide warm breaks, dry layers and traction; stop for loss of dexterity, unsafe footing or symptoms that impair safe work.

Weather and exhaust

Stop elevated work, glass handling and material lifting when wind, lightning, heavy rain, snow or ice prevents safe control. Reinspect equipment and supports after severe weather. Keep combustion engines outdoors and exhaust away from occupied areas. Never rely on open windows to make indoor fuel-powered equipment safe.

Basis and related sources [49] [50] [51] [52] [22]

Complete Form I for each job, post it where workers can reach it and review it before starting. Verify the exact address, unit, access route, phone coverage, assembly point, nearest appropriate medical facility and emergency access. Do not copy the company office address onto a job’s emergency form unless work is at that address.

Alarm and evacuation

The company alarm is a clear repeated verbal warning, “EMERGENCY - EVACUATE,” supplemented by phone or another signal agreed at the briefing. Stop work; shut equipment down only if safe. Use the nearest safe exit and go to the assembly point. The supervisor accounts for employees, subcontractors and known visitors and reports missing persons to responders. Nobody reenters until authorized.

Medical emergency

Call 911 for serious injury, severe bleeding, electric shock, suspected heat stroke, breathing difficulty or other urgent conditions. Give the address, access instructions, nature of injury and hazards. Send a person to guide responders without leaving an injured person alone where assistance is available. Do not move the casualty unless remaining there is dangerous.

Arrange prompt medical attention before work. Where a medical facility is not reasonably accessible, provide a person with verifiable current first-aid certification at the site. Company policy requires a designated trained first-aid/CPR responder for every active crew. Confirm coverage if that person leaves. Maintain suitable first-aid supplies, checked before dispatch and at least weekly on the job; provide immediate flushing facilities where corrosives may contact eyes or skin.

Fire and hazardous release

Evacuate, call 911 and keep others away. Only trained, authorized personnel may use an extinguisher on an incipient fire with a safe exit available; employees are not assigned structural firefighting. Provide at least a 2A extinguisher per 3,000 square feet or major fraction, with no more than 100 feet travel, and at least one 2A on each floor, adjacent to a stairway in multistory buildings. Add protection for fuel and other special hazards. Inspect and maintain clear access.

For a gas odor, evacuate without operating switches, tools or other ignition sources in the area. Call emergency services and the utility from a safe location. For an unknown chemical release or suspected carbon monoxide, evacuate and obtain emergency assistance; do not reenter to retrieve tools.

Rescue limits

Use the preplanned fall rescue in Section 7. Do not enter a confined space, energized area, unstable structure or contaminated atmosphere to attempt an unprotected rescue. Medical treatment and emergency calls take priority over paperwork or waiting for management approval.

Basis and related sources [53] [54] [55]

Immediate internal response

Workers report injuries, illnesses, exposures, property damage and near misses to the supervisor as soon as practicable after urgent care. Reporting must not be discouraged by a rule, bonus or discipline. The supervisor provides assistance, informs the President, controls continuing hazards and starts Form K. Preserve facts and photographs when safe; do not delay treatment to investigate.

Severe events reported to OSHA

The President, or a designated backup if unavailable, reports a work-related fatality within 8 hours and an inpatient hospitalization, amputation or loss of an eye within 24 hours. A fatality is reportable if it occurs within 30 days of the incident; the other listed outcomes if they occur within 24 hours. When the employer learns later, the applicable reporting clock starts on learning of the reportable event or its work relationship.

Use 1-800-321-6742, OSHA’s online severe-injury reporting application, or the nearest OSHA Area Office. If that office is closed, use the national number or online method, not voicemail or email. Inpatient admission for care or treatment is distinct from observation alone. Consult the full reporting rule for specific exceptions; do not delay a required report while investigating blame.

Routine records

Determine Part 1904 coverage each year. The partial small-employer exemption generally applies only if the entire company had 10 or fewer employees throughout the previous calendar year, unless OSHA or BLS requires records. It does not remove severe-event reporting duties. Do not presume eligibility because a single crew is small.

When records are required, maintain OSHA 300, 301 and 300A or permitted equivalents; enter recordable cases within seven calendar days of receiving the information. Review, certify and post the annual 300A summary from February 1 through April 30, and retain the required records for five years following the covered year. Separately check whether electronic submission is required for the establishment.

Other records and follow-up

Notify the workers’ compensation carrier and applicable agencies within their actual requirements. The company’s carrier, policy and claim contacts must be entered from verified records; they are not supplied here. Track restrictions and return-to-work decisions through appropriate medical channels.

Retain exposure records generally at least 30 years and employee medical records generally for employment plus 30 years under 1910.1020, subject to its exceptions and any longer specific rule. Restrict medical access, provide legally required employee access, and preserve records subject to an investigation or claim. Do not include diagnoses in public jobsite logs.

Basis and related sources [56] [57] [58] [59] [60] [61] [63]

Inspection routine

OSHA requires frequent and regular inspections by designated competent persons. Company policy requires a documented pre-job review, daily work-area checks using Form C, and a weekly management review during active work. Perform extra checks after weather, relocation, an incident, a crew change or a change in method. Equipment-specific frequencies still apply, including scaffold inspections before each shift.

Inspect conditions while the operation is running as well as before work. Observe whether dust capture works, guards remain in place, occupants stay out and fall protection permits the actual movement. A completed checklist does not override an observed hazard.

Correct and verify

Classify an imminent danger or missing critical control as a stop-work item. Isolate it immediately and record responsibility and the required correction. For other hazards, set a realistic deadline and interim protection; affected work may continue only if workers are protected. The supervisor verifies the field correction, records evidence and closes the item. Use Form K and attach photographs or technical records where useful.

Fair accountability

Explain the rule and provide the training, tools and supervision needed to comply. Investigate whether a failure arose from unclear instructions, unavailable equipment, unrealistic scheduling or a deliberate act. Correct the underlying cause as well as the individual behavior.

Depending on severity and circumstances, company responses may include coaching, documented warning, retraining and reassessment, removal from a hazardous task, suspension or termination consistent with applicable law. Serious intentional violations may justify immediate removal. Apply the process consistently to workers and supervisors. Subcontractor violations are handled through site control and the contract.

No discipline is permitted solely for reporting an injury, illness, hazard or near miss, seeking medical attention, participating in an inspection or exercising protected rights. A good-faith stop-work report is not a violation.

Program review and record control

The President reviews unresolved findings, incidents, worker suggestions, training gaps and subcontractor performance at least quarterly during active operations and reviews this manual annually. Record changes on the adoption page, brief affected personnel and replace obsolete copies.

Company policy retains ordinary job assessments, inspections, training and corrective-action records for at least five years unless a longer legal, contractual, insurance or claim hold applies. Keep the latest required training certification and observe longer RRP, exposure and medical retention requirements. Blank forms must never be backdated or completed for work that was not actually reviewed.

Basis and related sources [2] [9] [56] [61] [64]