Environment, Health and Safety
Environment, Health and Safety (EHS) are integral considerations in all business operations at ALTUS. Our commitment to EHS is reflected by actions from executive management through field-level personnel. Being a relatively small company, ALTUS is able to quickly assess EHS practices and share experience and methods for improvement quickly and decisively.
Our EHS goals are to: For major projects ALTUS assigns a senior management level EHS officer with project oversight authority including discretion to stop work over any unacceptable site-specific hazards. ALTUS has enjoyed a long and successful relationship with our certified industrial hygienist (CIH), Cynthia Ellwood, PhD. In addition, Glenn Burge, ALTUS' senior EHS consulting advisor has extensive EHS and Environmental Management System (EMS) experience with a broad variety of Fortune 500 and smaller corporations. ALTUS draws on Cynthia and Glenn's depth of experience for a variety of projects, and we are pleased to have them as part of the ALTUS team. Our CIH and EHS/EMS staff are available at any time to provide field or customer support in assessing and mitigating EHS concerns. For a more detailed explanation of key EHS elements in place at ALTUS, please read on. The Nuts and Bolts of our EHS Program If you would like to download our EHS policy statement, please click on EHS Policy Statement (PDF)
Behavior-based Safety
ALTUS has a behavior-based program in place for communicating and assuring that all personnel understand their obligation to stop work that is unsafe. The program recognizes individuals for positive behavior and identifies leading indicators for unsafe conditions or actions in the work place. Information is gathered from the behavior-based safety program and is used to understand types of at-risk-behaviors, develop performance targets (including action plans and/or training) and address behaviors targeted for improvement.
Regulatory Compliance
ALTUS determines which existing regulations apply to specific operations and has procedures for monitoring compliance, determining any changes to regulations or new agency interpretations, or regulations that apply to the specific operations. ALTUS maintains a list of applicable regulations and periodically conducts on-site inspections of compliance, where applicable. ALTUS subcontractors are also required to comply with regulatory requirements, company policy and site-specific requirements.
Subcontractor Management
ALTUS has a process in place to provide verification that any subcontractor ALTUS hires, or is responsible for, is working to the same EHS level that ALTUS expects. This process would include, but is not limited to, communication of company programs, performing rigorous pre-qualification assessments and monitoring performance and performing regular EHS reviews and assessments.
Drug & Alcohol-free Workplace
ALTUS has a documented Substance Abuse Policy. If DOT regulations are applicable, the Policy will include necessary provisions for compliance with the regulations. The Policy includes any subcontractor working on company projects as well. The Policy includes necessary provisions for a non-DOT testing pool that will include all company personnel. ALTUS has a procedure for conducting drug and alcohol tests that includes pre-employment testing, post accident testing, random testing, reasonable suspicion testing, and return to duty testing. These provisions are made for subcontractors as well. ALTUS provides regulatory required training for supervisors and employee notification and/or training for the Substance Abuse Policy.
Emergency Response
All ALTUS technical staff and subcontractors are expected to know how to react in case of a serious accident or emergency situation. ALTUS has documented procedures or methods to ensure that Emergency Response Plans comply with all legal and company requirements to aid workers and subcontractors in the event of an emergency. ALTUS employees and subcontractors learn of the plan during their orientation on their first day at the work site. ALTUS also ensures that staff and subcontractors understand the plan and can demonstrate proficiency by conducting drill or training exercises. As part of the Health, Safety and Emergency Response Plan, ALTUS ensures that the site has appropriate first aid and appropriate medical case management arrangements, which includes knowledge of directions to the local hospital.
Health and Safety Plans (HASPs)
ALTUS staff develops a site-specific Health and Safety Plan (HASP) for all projects that could reasonably pose a threat to human health or the environment. The site HASP adequately describes the work being undertaken, the risks involved in performing the required tasks, the measures being taken to mitigate the risks, and the emergency response and reporting requirements. ALTUS has a formal written procedure that identifies personnel responsible for HASP development, implementation (including training), and assurance that the plan is current, valid and in compliance.
Continual Improvement
ALTUS has an EHS Program with a focus on continual performance improvement. ALTUS records incidents, near misses, observations, and routinely conducts inspections and reviews. ALTUS corrects any deficiencies noted in the incident reports, inspections and reviews. For significant issues, ALTUS tracks implementation of improvement opportunities. In addition, ALTUS also performs periodic reviews of subcontractors’ EHS programs. ALTUS occasionally sets and tracks performance targets for certain components critical to improvement.
Incident and Injury Free
ALTUS strives to deliver an incident and injury free workplace for workers and subcontractors. ALTUS trains its employees on how the company’s EHS program will lead to an incident and injury free workplace and the benefits of this to both the client and the company. Employees and subcontractors are informed of how they are progressing toward an incident and injury free workplace, and certain actions where improvement must be made in order to achieve that result are highlighted. ALTUS also maintains a 12-month rolling recordable incident rate (RIR). All hours worked are measured and recorded, injuries are accurately categorized per Federal and State occupational, safety and health regulations, and injury categorization is consistent with Worker’s Compensation claims. Any recordable injuries are investigated and explanations, recommendation or actions are made as a result of the injury.
Incident Reporting
ALTUS personnel and subcontractors must immediately notify the company of any incidents resulting in personal injury, spills or releases, security issues, loss or damage to property, or near-misses. Company personnel and subcontractors are made aware of, and understand, the requirements of immediate and effective notification and reporting.
Risk Management
ALTUS expects its employees to review, understand and control their risks at the project level. To that end, project safety reviews are conducted at the beginning of a project to understand the full range of risks. For small projects that are repetitive, such as service stations, a template is used. However, every site has unique risks that must be considered (security, subsurface conditions, etc.) and adequately controlled. Once the project safety review has been completed, a site-specific HASP is developed. As part of the HASP, ALTUS completes a Job Safety Analysis (JSA) for key tasks and plans for any changes. Each JSA is reviewed and signed off on by each person performing the task being analyzed. Each Risk Assessment (RA) ensures that the hazards, their elimination, substitution, control and mitigation are properly covered. Each worksite is inspected by an ALTUS employee before the RA is completed.
Training
All ALTUS employees and subcontractors must have an understanding of their job. They should know how to do their job safely and know how to react in case of an emergency. All employees learn of the basic EHS aspects of their job during their orientation training. Supervisors never allow a worker to advance to the next stage of their job without having an understanding of the EHS aspects.
ALTUS maintains a training matrix for all employees that includ all regulatory-required training and defines the intervals at which retraining is required. Some of the training might included a testing component, depending on the subject matter, to assure competence of all personnel. Records of training, including class rosters, qualifications of trainers, training agendas, and competence tests are kept in the corporate office. ALTUS also determines if site-specific training is required (i.e., local contractor safety councils, etc.).
Weapons-free Workplace
All ALTUS projects and worksites are free from weapons. Every ALTUS employee, subcontractor or their employees working on an ALTUS-related project should ensure that they do not bring weapons onto the worksite. Weapons include, but are not limited to, guns, large knives and explosives. Any employee found to be carrying weapons, after being informed of the policy, may face disciplinary action of up to and including immediate removal from the work site. ALTUS communicates this policy to all employees and subcontractors prior to doing work on a project.
Control of Work
ALTUS ensures the safety of the workforce in potentially high-hazard activity by a Control of Work (COW) process. All identified roles within the COW policy and associated procedures have defined accountabilities; in addition, all personnel involved in the COW process are appropriately trained and competent to carry out their roles. All planning and scheduling of work identifies individual tasks and their interaction, and all tasks are risk assessed according to ALTUS’ Risk Assessment policy. Prior to conducting any work that involves confined space entry, work on energy systems, ground disturbance, hot work or other hazardous activities, a permit must be obtained. The scope of work, hazards, controls, and mitigations of a job are clearly communicated in writing and signed off by all individuals involved in the task. The work site is left in a safe condition on completion or interruption of the work. All internal and external lessons learned that impact the COW process will be captured, incorporated and shared. The COW policy and associated procedures make it clear to everyone that they have the obligation and authority to stop unsafe work.
Driving Standard
ALTUS has a written safe driving practice/procedure for all operations associated with project sites. ALTUS monitors the hours worked and miles driven, when appropriate, and ensures that the limits of employees are not exceeded. Safe driving in wintry conditions is especially emphasized.
Fitness for Duty
ALTUS has a Fitness-For-Duty program, which includes assessment of the physical capability of employees to perform specific tasks. The program includes a physical agility-testing component, in addition to an assessment by a medical doctor about the condition of an employee to work using a respirator. ALTUS recognizes specific factors affecting employee fitness for work including physical exertion requiring a reasonable degree of stamina, shift work, absence from home, adverse weather, smoke, heat and cold exposure, transportation, emergency situations, claustrophobia, limited privacy and mental health of the employee. These factors are considered and mitigated in the assessment of an employee’s fitness for duty.
