Environmental Health & Safety (EH & S)

C.D. Lyon Construction, Inc. has instituted and administered a comprehensive and continuous occupational injury and illness prevention program.
Our program includes a detailed process safety manual, DOT compliant drug/alcohol testing, and behavior based safety processes. Our experience modifier rating (EMR) has consistently been below industry average since the company started more than twenty-five years ago.

We believe the health and safety of an individual employee takes precedence over all other concerns. In support of this commitment, the company provides measures to control workplace hazards through communications, periodic inspections, incident investigation, mitigation, compliance audits
and employee training. Under all circumstances, it is the intent of C.D. Lyon to comply with all applicable federal, state and local regulations and to
provide a safe and healthful work environment for our employees.

PROCESS SAFETY MANUAL

To help us achieve an injury-free workplace, we have developed a Process Safety Manual, an integrated plan to manage and improve company safety performance. As part of this process, we hire employees and contractors with an exemplary safety attitude. We do this knowing we must cooperate
and work as a team to obtain the desired results.

Our core plan is divided into five sections (Foreword, Injury and Illness Prevention Program, Code of Safe Practices, Safety Standards, and General
Safety Policies).

Foreword

Includes an overview of program contents, introduction and scope, and a policy statement endorsing the system as appropriate for the company.

Injury and Illness Prevention Program (IIPP)

An IIPP is an element required by California Code of Regulation 3203 for all employers. It consists of seven established criteria (responsibilities, compliance/disciplinary policy, communication, identification of workplace hazards, accident reporting and investigating, employee training and record keeping). The IIPP is the main part of the administrative portion of our manual.

Code of Safe Practices (Tailgate Safety-Meeting Topics)

The written code of safe practices section of our program are not necessarily required by any regulatory body, however much of the contents reflect
current laws and such is used to complement independent study or assist in tailgate safety meetings. We hold daily tailgate safety meetings on every project.

Safety Standards (procedures)

Safety standards included in section 4.00 of our core Process Safety Manual includes written job procedures developed to be utilized in most of the daily activities of the company. Most of the written job procedures are regulatory required and reference applicable federal and/or state laws within
the text of the documents.

General Safety Guidelines

The General Safety Guidelines section of our core plan encompass all other written safety material that is not necessarily a daily function of the business, however deemed important to the success of our company. Within this section you will find general information relating to a multitude of safety requirements.

DRUG AND ALCOHOL PROGRAM

In addition to our core safety plan C.D. Lyon manages three drug and alcohol testing programs. We believe keeping drugs and alcohol off the job
sites is a major contributor to our exemplary compliance efforts.

Our drug and alcohol plans comply with U.S. Department of Transportation (DOT) Pipeline & Hazardous Materials Safety Administration (PHMSA)
and the Federal Motor Carrier Safety Administration (FMCSA). We also have the ability to test for drugs that are not normally part of a DOT plan.

All of our drug and alcohol testing plans include a provision for:

Pre-Placement,

Reasonable Suspicion,

Post Accident, and

Random testing

BEHAVIOR BASED SAFETY (BBS) PROCESSES

Behavior Based Safety (BBS) is an established method of using positive reinforcement to change unsafe individual behaviors. C.D. Lyon was following BBS principles well before it became an industry standard.

The process starts with a behavioral hazard analysis to identify “at-risk” behaviors. These are determined by using:

Job Site Observations (JSO)s
Job Hazard Analysis (JSA)s
Safety Communication Systems (SCS)s, and a
Data Tracking System (DTS)s for Incident / injury / near miss analysis
Our BBS System is an employee-based plan that strives for continuous improvement. We analyze all tasks and hazards to identify critical safety behaviors before each job.

Our BBS Principles:

· Behavior is the cause of most accidents

· Consequences motivate behavior

· What gets measured gets done

· Feedback is essential to improvement

· Quality is built-in early in the process

· Conversations change organizations

BBS Process Tools

Job specific safe work plans, Job Site Observations (JSO)s, and Safety Communication Systems (SCS) in conjunction with task specific job safety
analysis (JSA) are used to implement and document the BBS process. Safe work plans are developed as a stand alone document while JSAs are documented utilizing established company protocol.

Data Management

BBS observation data is managed and collected in an electronic data tracking system (DTS) database which assists our company in concentrating
effort towards the most effective risk reduction methods

ENVIRONMENTAL COMPLIANCE

It is C.D. Lyon’s policy to comply with applicable environmental laws and regulations. Our operations will be governed by sound planning, use of appropriate control mechanisms and proper employee training. No business objective shall be pursued at the expense of environmental compliance.

To communicate this value we use a systematic audit process which results in remedial actions. Our facilities remain environmentally sound and in compliance with all applicable environmental laws and regulations.