ASBESTOS AWARENESS PROGRAM

NOTE: All regulation references are to 29 CFR 1926.1101 unless otherwise stated.

Purpose
The purpose of this program is to inform employees, and interested persons, that this
company is complying with OSHA's asbestos standard, Title 29 Code of Federal
Regulations 1926.1101 by ensuring that:

1. No employee is to be exposed to an airborne concentration of asbestos in excess

of 0.1 f/cc (fibers per cubic centimeter of air) as an eight-hour time-weighted
average (TWA).

2. No employee is to be exposed to an airborne concentration of asbestos in excess

of 1.0 f/cc (excursion limit) as averaged over a sampling period of 30 minutes.

We conduct an initial exposure assessment of all work performed by this company, in

regard to any “presumed asbestos containing materials” (PACM), that may be located on
our jobsites. This assessment is performed during the pre-bid process, and during any
pre-construction meetings, prior to any actual work being performed. We rely heavily upon
statements and documentation given to us by owners, or other controlling parties, for
whom work is being performed. If asbestos is present at any job site, we require the
owner to supply us with the proper owner notification records. These records shall include
documentation regarding areas that contain asbestos, and shall include results of the
most current testing that has been performed. The testing results shall include a summary
of all areas that contain asbestos, including the percentage of asbestos containing
materials present, and a map of all areas, designating affected areas.

We do not self-perform any monitoring for asbestos containing materials. All testing and
monitoring shall be performed by outside qualified contractors, to be hired by the owner or
any other party we perform work for. We will not contract out any asbestos abatement
activities. If asbestos abatement activities are to take place, the qualified asbestos
abatement contractor shall, through the owner, report to us the work performed, method
used, results of all tests, and shall comply with all governmental regulations regarding the
abatement of asbestos containing materials. All asbestos removal operations must be
conducted within regulated areas. These regulated areas shall comply with 29
1926.1101(e)(2) - (5).

We understand that the communication of asbestos hazards is vital to prevent

overexposure and that we have specific duties under the asbestos rule to communicate
those hazards through written notifications, signs, labels and employee information and
training.
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On multi-employer worksites, we will: (1) inform other employers on the site of the nature
of our work, (2) relay information of the existence of regulated areas (if any), and take
correct measures, within our control, to ensure employees of other employers are not
exposed to asbestos.

This program applies to all construction work where any of our employees or sub-
contractors, may be occupationally exposed to asbestos. All work related to construction,
alteration, or repair, including painting and decorating, is included.

Initial Exposure Assessment

Whenever asbestos containing materials have been found to exist on a job site,
notification to all employees will be made. We will notify employees in writing, personally,
or by posting at a central location, the areas that are affected, (including a graphic
representation of affected areas) and what percentage of asbestos is contained in these
materials. We will also notify all employees of any monitoring results as soon as possible,
following receipt of those results. Monitoring will always be performed by other qualified
parties.

The initial exposure assessment will indicate if this job is likely to exceed the PEL,
(permissible exposure limit). If this is the case, then the owner shall be directly responsible
to properly abate the affected areas, and provide all testing and monitoring results to our
company before we can perform any work in those affected areas. It is the responsibility of
the owner to properly post (with warning signs) any affected areas clearly and
conspicuously.

Asbestos Exposure
All employees receive training that whenever they encounter any material that may
contain asbestos related material, they are to immediately stop work. The suspect
material is not to be disturbed in any manner, and all associated trades are to be
advised of the location of the possibly containing asbestos material. The area is to
be clearly marked and labeled. The material will then be tested by a recognized and
certified company to ascertain if there are any asbestos containing material. No
work in that area is to continue until we receive written notification of the contents
of the questionable material. If the material contains asbestos, a qualified and
certified asbestos abatement contractor is to be contracted by the owner for
removal of the asbestos containing material.

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Objective Data
Where we rely on objective data that demonstrates that products made from or containing
asbestos or the activity involving such products or material are not capable of releasing
fibers of asbestos in concentrations at or above the permissible exposure limit and/or
excursion limit under the expected conditions of processing, use, or handling to satisfy the
requirements of 29 CFR 1926.1101(f), we establish and maintain an accurate record of
objective data reasonably relied upon in support of the exemption. The record includes at
least the following information:

1. The product qualifying for exemption.

2. The source of the objective data.
3. The testing protocol, results of testing, and/or analysis of the material for
the release of asbestos.
4. A description of the operation exempted and how the data support the
exemption.
5. Other data relevant to the operations, materials, processing, or employee
exposures covered by the exemption.

We maintain this record for the duration of this company’s reliance upon such
objective data.

Training Records
All employee training records are maintained at our office, and may be reviewed upon
request. In regards to this section of our safety program, training for asbestos awareness
is only performed. We do not train employees or sub-contractors on abatement
procedures. Our company policy is to perform initial assessments of our jobsites to
determine if asbestos is present. If asbestos is present we will not disturb existing
asbestos. Our policy is to advise the owner or other controlling party, and to have them
contract directly with a qualified testing contractor, and abate the hazard if so needed. If
asbestos is present, and has not been disturbed, we will inform employees and other
contractors on site (that are under our control) of the presence of asbestos. Such
notification will be based upon assessments and testing performed by the owner and
given to us. These records will be made available, and given to all affected parties.

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Records of Required Notifications

Where the owner has communicated and received information concerning the
identification, location and quantity of ACM (Asbestos Containing Material) and PACM
(“presumed Asbestos Containing Material”), we ensure that written records of such
notifications and their content are maintained by the owner, and a copy is given to us.

Demarcation

Any regulated area, where asbestos abatement procedures are to be conducted shall be
demarcated in a manner that prohibits any of our employees, or sub-contractors (under
our control) from entering the area, and protects persons outside the area from exposure
to airborne asbestos. When critical barriers or negative pressure enclosures are used,
they may demarcate the regulated area. Warning signs shall be posted, by the owner (or
their qualified representative) in accordance with the requirements of 29 CFR
1926.1101(k)(7).

Access

Access to regulated areas is restricted to authorized persons only.

Prohibited Activities

We prohibit our employees, and all sub-contractors (under our control) from entering a
regulated area.

Communication of Hazards

The existence of any PACM (“presumed asbestos containing materials”) or ACM

(asbestos containing materials) shall be communicated to all employees, and sub-
contractors, as soon as possible, after they have been discovered.

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