Policy #2 INJURY & ILLNESS PREVENTION PROGRAM Version 2.2

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1 INTRODUCTION Searles Valley Minerals is committed to safely operating all facilities/operations to keep accidents, injuries and illnesses to a minimum. It is our policy to provide all employees with a safe and healthful work environment. Searles Valley Minerals will comply with the California Occupational Safety and Health Administration (Cal-OSHA) regulations and; the commitment established by the Responsible Care Initiative of the American Chemistry Council. REQUIREMENTS The Injury and Illness Prevention Program (IIPP), as specified by Cal-OSHA, requires Searles Valley Minerals to establish, implement and maintain the following: Management commitment and identification of individuals with authority and responsibility for the program. A system of communication, regarding safety and health issues, pertaining to employees. A system for assuring employee compliance with safe work practices. Scheduled inspections/evaluation system. Procedures to investigate all occupational injury and illness including serious incidents. Procedures for correcting unsafe or unhealthy working conditions. Assure proper safety and health training and instruction to all employees. Establish procedures for the identification and evaluation of work place hazards. Recordkeeping and documentation. RESPONSIBILITY AND AUTHORITY Avinash Puri, President of Searles Valley Minerals Inc., holds the overall authority and responsibility for implementing and executing of this Injury and Illness Prevention (IIPP) Program for Searles Valley Minerals. John Bradley, Safety Manager, holds the responsibility for administering and maintaining this IIPP Program. Facility and departmental managers and supervisors are responsible for implementing and Revised August 3, 2017 Page 1 of 9

2 maintaining the IIPP Program in their specific work area or facility and for answering any worker s questions about the IIPP program. Authority, roles, and responsibilities, in support of the Searles Valley Minerals IIPP and in commitment to the Searles Valley Minerals Safety and Health Program, are defined for all levels of the organization. Additionally, each employee within the organization has a defined responsibility to safety and the environment, and is granted the authority to stop any work that does not comply with the tenants of operational excellence and the requirements of the Searles Valley Minerals Safety and Health Program. A copy of this IIPP Program is available to all employees from each manager or supervisor. This program is available within the Searles Valley Minerals Computer Network Safety Policies and Procedures Book on the "S" drive as document [#2] in the [safety] directory under the subdirectory [policies]. COMMUNICATION All managers and supervisors are responsible for communicating with their employees, about occupational safety and health, in a manner that is understandable by all. Searles Valley Minerals encourages all employees to report all unsafe or unhealthful hazards and conditions without fear of reprisal. To ensure this occurs, Searles Valley Minerals has the following practices implemented: Management Team Meetings and Department staff meetings discuss safety first. New employee safety orientation is held with all new employees, during which IIPP is discussed. Safety Meetings are held weekly for maintenance groups, twice monthly for operations and production groups (this includes one formal and one tailgate or follow-up meeting), and monthly for office and administrative groups. All required safety training is completed on an annual basis. Safety Committee Meetings are held in each facility usually on a monthly basis. The minutes of these meetings are posted and reviewed with the respective crews by their committee safety representative. All committee members receive a copy of the minutes even if they were unable to attend the meeting. All employees are encouraged to bring all unsafe or unhealthy acts and conditions to the immediate attention of their supervisor. Revised August 3, 2017 Page 2 of 9

3 Safety suggestions are encouraged at each facility to receive new ideas and provide feedback on improvements. An Employee Communications and Reporting Policy is in place to correct and identify unsafe conditions in our facilities. Additionally, a formal practice is provided to facilitate solutions for situations in which an employee refuses to do an assigned task for safety reasons. COMPLIANCE Employees are responsible for compliance with established safe and healthful work practices. To ensure this occurs, Searles Valley Minerals has the following management practices in place: Employees are informed about the provisions of our Injury and Illness Prevention Program. All levels of employees are encouraged to participate in our safety efforts. Opportunities to do this are provided by the employee safety participation program, the safety committees/teams, and the planned inspection programs. All supervisors and managers are evaluated annually on the safety performance in their areas of responsibility. All employees are observed periodically through the Employee Observation Programs by trained observers and are given feedback on both safe behavior and at risk behavior. Recognition is given to those employees who perform safe and healthful work practices. Special training is provided or counseling given to those employees who have a deficient safety performance. Failure to comply with safe and healthful work practices will result in disciplinary action. INSPECTIONS & HAZARD ASSESSMENT Searles Valley Minerals has programs that inspect the operations to identify and evaluate workplace hazards: A fully trained safety and health staff is a resource to all management and hourly Revised August 3, 2017 Page 3 of 9

4 employees. Management and hourly employees participate in the planned inspection program. Hazards are classified by a risk assessment, with the most serious hazards requiring immediate correction. Management routinely reviews their operations for hazards and unsafe action. There is an Employee Communications and Reporting Policy. There is an industrial hygiene sampling program to monitor our employees exposure to known health hazards. There are number of specialized inspections to identify hazards that need correction. Process hazard assessments are conducted and reviewed periodically as required by Process Safety Management. These hazard assessments are conducted when a new substance, process, procedure or equipment is introduced in the work place. As part of the Searles Valley Minerals Accident/Incident Investigation Procedure, all hazards that may have contributed to an incident are corrected. The safety department formally audits the operations for hazards and compliance with our safety procedures. There is a periodic external third party audit of the facility. Insurance carriers review risk yearly. ACCIDENT/INCIDENT INVESTIGATION Searles Valley Minerals has an Accident/Incident and Reporting/Investigation Procedure. This procedure addresses the following: Requiring that all accidents and incidents be reported to supervisor immediately. Requiring an investigation to determine the causal factors of the accident or incident. More detailed investigations may be completed based on the risk assessment rating. Documenting the findings and actions recommended and taken. Revised August 3, 2017 Page 4 of 9

5 Determining the reason(s) why the cause existed. Taking the necessary corrective action to prevent recurrence of the accident or incident. Following-up to ensure that the corrective action was taken and that this corrective action was the solution to the cause. CORRECTION OF USAFE/UNHEALTHY CONDITIONS Based on potential severity, unsafe and unhealthy work conditions, work practices, and work procedures are corrected in a timely manner. Hazards observed or discovered in the work area are evaluated according to their risk and hazard potential. When an imminent hazard exists, which cannot be immediately addressed without endangering employees and/or property, Searles Valley Minerals will remove all employees from the area, except those who are necessary to correct the condition. Employees who are required to correct the hazardous condition shall be provided with the proper protective equipment and the training necessary to handle the hazard. SAFETY TRAINING AND INSTRUCTION All employees, managers, and supervisors will have training and instruction on general and jobspecific safety and health practices. A Safety Training Policy has been established to standardize the training subjects and when they are provided. Examples of required training topics include: Hearing Conservation. Eye Protection. Lockout. Confined Space. HAZWOPER. Hazard Communication and Hazardous Material Management. Fire Extinguisher Use. Injury Management. Revised August 3, 2017 Page 5 of 9

6 Forklift Operation. Scaffold Use. Blood Born Pathogens. Crane/Rigging Training. Fall Protection. Respirator Training. Ergonomics. All training is documented. All new employees go through a full day of New Hire Safety Orientation. This is followed up with days to week of further specific safety training at the facility where the employee will be assigned. Training and instruction is given to all affected employees whenever new substances, processes, standards or equipment are introduced into the work environment and represent a new hazard in the work place. All employees must receive training and instruction concerning the specific hazards of their job assignment or when ever the employer is made aware of a new or unrecognized hazard. All supervisors must receive specific training and instruction to familiarize themselves with the specific safety and health hazards that their employees may be exposed to in their daily job functions. All employees assigned to new jobs, or transferring to a new job assignment, must be given specific instructions on how to safely accomplish the job. GENERAL WORKPLACE SAFETY AND HEALTH PRACTICES General Workplace Safety and Health Practices include but are not limited to the following: Revised August 3, 2017 Page 6 of 9

7 Implementation and maintenance of the injury and illness prevention program. Emergency action and fire prevention plan. Provisions for both emergency and non-emergency medical services. Prevention of musculoskeletal disorders, including proper workstation use and lifting techniques. Proper housekeeping, such as keeping stairways and aisles clear, work areas neat and orderly, and promptly cleaning up spills. Prohibiting horseplay and other acts that tend to adversely influence safety. Proper storage to prevent stacking of materials in an unstable manner and storing materials against doors, in exits, in front of electrical panels, or blocking fire extinguishers. Proper reporting of hazards and accident to supervisors. Hazard communication, including employee awareness of potential chemical hazards and proper labeling of containers. Proper storage and handling of toxic and hazardous substances including prohibiting eating or storing food and beverages in areas where they could be contaminated. DOCUMENTATION Records are kept according to the following guidelines: Inspections 3 years Training 3 years Incident Investigations 5 years SAFETY, SECURITY, HEALTH & ENVIRONMENTAL (SSHE) COMMITTEES Searles Valley Minerals has a Safety (SSHE) Council. All Facilities and Departments have Safety (SSHE) Committees. SSHE Committees meet Monthly. SSHE Committees Minutes are provided. The SSHE Council and SSHE Committees Review Incidents. Revised August 3, 2017 Page 7 of 9

8 Searles Valley Minerals has established resources for the supervisors responsible for the safety and health of their employees located in Trona, California. A Safety Policies and Standards Manual is available on line for the supervisor use as a resource tool, a training aid and a guide to the continued safe operation of our facilities. Avinash Puri President Searles Valley Minerals Revised August 3, 2017 Page 8 of 9

9 ASSOCIATED DOCUMENTS None REFERENCES None DEFINITIONS None Policy #2 REVISION & CHANGE HISTORY LOG Document Title: Injury & Illness Prevention Program Document Owner: Safety Manager Version No: Reason For Change: Date: 1.0 Original Version April 20, Standard Review and Revision January 21, Standard Review and Revision July 10, Significant additions to the Responsibility and Authority section made Updated Names and Responsibilities November 17, Updated Names and Responsibilities September 5, Updated Names and Responsibilities September 9, Standard Review and Revision 2. Updated Names and Responsibilities August 3, 2017 Revised August 3, 2017 Page 9 of 9