Safety Playbook

OSHA JOB SITE VISIT PROTOCOL

REPORTING INCIDENTS

STEPS 1. The Construction Manager politely introduces himself/herself to the OSHA inspector and asks them for their credentials. Then request they wait until the VP/DM arrives to the job site. Please refrain from talking about the inspection until Century representation arrives. OSHA will wait up to an hour for the VP/DM to arrive once the safety issue/concern is remediated. a | If the OSHA inspector requests a contact phone number, only provide the National Director of Safety’s contact – DO NOT GIVE YOUR PERSONAL PHONE NUMBER. b | During an OSHA inspection, STOP all work on site c | In the event of an injury, no demonstrations are to be conducted 2. Notification steps within 1 – 2 hours: a | Contact your immediate supervisor and VP of Construction/DM, before contacting the DP/RP. b | Call your 3rd party Safety Consultant. a. We have 3 companies (Pike/Customized Safety and Quality Solutions/Quality Built/Safety Compliance) b. Please contact your division leadership for detailed contact information. c | Corporate Contact a. CCS & CMP – Call National Director of Safety Note: At the time of inspection, no documents are to be given to the OSHA inspector. Do not sign any documents presented by the inspector. Forward all requests for signatures to National Director of Safety. 3. Take pictures of everything the OSHA inspector takes pictures of, so we have the same information. 4. Once the inspection process is complete and Notice of Violations are provided, the Division Safety Officer & VP of Construction/DM send a brief email with the results of the inspections and any issues (if any) with subject line “OSHA Inspection”. Those to receive the email are: a | Division President & Regional President b | National Director of Safety c | Regional Counsel 5. The OSHA inspector usually gives a form or a follow-up email asking for information/proof of inspections, etc. Be sure you coordinate with the DSO/VP/DM along with your office administrator (if applicable) in assembling required info (ie, SiteDocs documentation, 3rd party audits, etc.) 6 . Any responses to OSHA must be reviewed by your VP/DM, our 3rd party Safety consultant, Regional General Counsel, and the National Director of Safety before submission 7. Once OSHA has received all the information, an acknowledgment is provided by letter or email, asking for a follow-up meeting, or letting us know of an issue closure. 8. If a meeting is needed, the Vice President of Construction/DM will invite all applicable parties to attend (3rd party consultant, Regional Counsel, etc.)

All Site Managers are responsible to adhere to the policies Century has in place in case of an accident or tragedy on the job site. • Refer to your OSHA pocket card for step-by-step instructions - A digital version can be found on MyCentury on the corporate safety page • If you receive a call from the National Director of Safety, HR team, or Legal team, please follow their instructions • The trade partners/suppliers are responsible for getting in touch with OSHA in the event of an accident that needs to be reported - It is a best practice for the Site Manager to be present for the call • Immediately contact the National Director of Safety – the Site Manager is NOT responsible for contacting OSHA - Fill out the Safety Incident Report Form (can be found on Century Toolbox) - Report the accident on SiteDocs

WHAT TO DO IF OSHA VISITS This document can be found on myCentury, under the “ Corporate Safety ” link. 1. INTRODUCE yourself to the OSHA

c. CALL your 3rd party safety consultant – contact information is found on MyCentury d. CALL , Director of Safety, Chelsey Fishman, who contacts applicable departments. Cell: (303) 619-2205 Office: (303) 416-8091 (Don’t give documents to the OSHA inspector during inspection.) 3. TAKE PICTURES of everything the OSHA inspector takes pictures of, so we have the same information. 4. Once the inspection is complete and Notice of Violations are provided, Chelsey will send a brief email with the results of the inspections and issues (if any) with subject line “OSHA Inspection” to: a. Division President & Regional President 5. The OSHA inspector usually gives a form or a follow-up email asking for information/ proof of inspections, etc. Be sure you COORDINATE with your DSO/VP along with the Director of Safety, your office administrator (if applicable) in assembling required info (i.e., SiteDocs documentation, 3rd party audits, etc.). b. Regional Counsel c. Risk Management

inspector and ask them to please wait for the VP of Construction/Division Manager to meet on site (They will wait up to an hour for someone to meet them once the safety issue/concern is remediated). This applies ONLY if the investigation is on Century. a. During an OSHA inspection, STOP all work on site b. In the event of an injury, no demonstrations are to be conducted 2. Notification steps within 1 – 2 hours: a. CONTACT your immediate supervisor and VP of Construction. b. The VP of Construction contacts the DP who contacts the Regional President.

6. Any responses to OSHA must be REVIEWED by your VP/DSO, our 3rd party Safety consultant, Regional General Counsel, and Director of Safety BEFORE submission. 7. Once OSHA has received all the information, an acknowledgment is provided by letter or email, asking for a follow-up meeting or letting us know of an issue closure. 8. If a meeting is needed, Chelsey will INVITE all applicable parties to attend (3rd party consultant, Regional Counsel, etc.).

30 | OSHA Job Site Visit Protocol | SAFETY PLAYBOOK

SAFETY PLAYBOOK | Reporting Incidents | 31