Written Safety Program & IIPP

Safety is a core value at OnyxFM, not a priority that shifts with the schedule. We comply with all applicable Cal/OSHA and federal OSHA standards, provide training and supervision for safe work, investigate every incident and near-miss, and hold every level of the company accountable for safe work practices.

No employee will ever be disciplined or retaliated against for reporting a hazard, refusing unsafe work, or raising a safety concern in good faith.

The OnyxFM Safety Program Administrator is responsible for implementing and maintaining this program. Contact: safety@onyxfm.io.

• Supervisors enforce safe work practices, conduct site inspections, deliver toolbox talks, and correct hazards.
• Employees follow safe practices, use required PPE, and report hazards immediately.
• Subcontractors maintain their own compliant safety programs, follow this program on our sites, and provide proof of training and insurance before mobilizing.

We ensure compliance through new-hire safety orientation, recognition of safe behavior, retraining for unsafe work, and progressive discipline for willful or repeated violations. Safety performance is a factor in performance reviews for all field and supervisory personnel.

Our Hazard Communication Program tracks chemical inventories, maintains Safety Data Sheets (SDS), and labels every container. Employees are trained on chemical hazards and required PPE before working with any product. Chemical mixing is prohibited unless directed by product instructions.

We identify hazards through initial site assessments, scheduled inspections, employee reports, and incident investigations. All inspections are documented with hazards found and corrective actions taken.

Hazards are corrected based on severity:

• Imminent hazards: work stops immediately and personnel are removed until the hazard is corrected.
• Serious hazards: corrected or controlled before work continues.
• Other hazards: corrected on a documented schedule with interim protections.

When hazards cannot be corrected by OnyxFM (for example, building infrastructure issues), they are reported in writing to the client and our personnel are restricted from the area until resolved.

Every service line follows tailored safety rules, including:

• Janitorial: wet-floor signage, slip-resistant footwear, proper dilution ratios, safe lifting, and sharps/biohazard handling.
• Post-construction: GC orientation, verification of utilities, hard hats, eye protection, high-visibility vests, HEPA vacuums, and N95+ respirators for dust.
• Maintenance & repair: qualified-only electrical work, tool inspections, GFCI protection, and hot-work permits.
• Ladders & work at height: pre-use inspections, three points of contact, 4:1 ladder angle, fall protection above six feet, and authorized operators only for lifts.
• Grounds & exterior: PPE for powered equipment, exclusion zones, heat illness prevention, and fuel safety.
• Vehicle & driving: authorized drivers, seat belts, hands-free-only phone use, pre-trip inspections, and secured, segregated chemical loads.

Per 8 CCR §3314, servicing or maintenance of equipment that could unexpectedly energize follows notification, shutdown, isolation of all energy sources, personal lock/tag application, release of stored energy, and verification of zero-energy state before work begins. Only trained, authorized employees perform lockout/tagout.

OnyxFM provides required PPE at no cost to employees. Minimum PPE is determined by task hazard assessment. Required PPE by task area includes:

For outdoor and indoor work at or above 82°F, we comply with 8 CCR §3395 and §3396. We provide fresh, cool drinking water, shade or cool-down areas, high-heat procedures at 95°F+, acclimatization observation for new employees and heat waves, and emergency response training for supervisors.

Employees exposed to blood or other potentially infectious materials are covered by an Exposure Control Plan per 8 CCR §5193. We follow universal precautions, use disposable nitrile gloves and EPA-registered disinfectants, never pick up sharps by hand, and offer Hepatitis B vaccination at no cost to employees with occupational exposure.

We maintain open, two-way safety communication through new-hire orientation, documented toolbox talks, safety alerts, and anonymous hazard reporting at safety@onyxfm.io. Safety information is provided in a language and format employees understand.

Safety training is provided before the first field assignment, for new job assignments, whenever new hazards are introduced, and for supervisors on the hazards employees may face. Core curriculum covers this IIPP, HazCom, PPE, slips/trips/falls, safe lifting, ladder safety, chemical safety, bloodborne pathogens, heat illness prevention, and emergency procedures.

Per California SB 553 (Labor Code §6401.9), OnyxFM maintains a Workplace Violence Prevention Plan. Employees are trained to recognize, avoid, and report workplace violence hazards, including those specific to occupied client facilities and after-hours settings. All threats and incidents are logged, investigated, and reported to a supervisor immediately.

On client sites, employees follow the facility's emergency action plan. In any life-threatening emergency, employees call 911 first, then notify the supervisor. First-aid kits are maintained in company vehicles and at fixed sites. Fire, earthquake, active threat, and severe weather responses follow site emergency plans and instructions from emergency personnel.

All injuries, illnesses, and near-misses are reported to a supervisor the same day. Supervisors complete an incident report within 24 hours, and the Program Administrator investigates root causes and assigns corrective actions. Serious injuries or illnesses are reported to Cal/OSHA immediately, and in no event longer than 8 hours after we know or should have known of the incident.

We maintain inspection records, training documentation, Cal/OSHA Form 300 logs and annual 300A summaries, incident reports, SDS and chemical inventories, and workplace violence incident logs. Records are kept in accordance with applicable retention requirements.

Before working on any OnyxFM-managed site, subcontractors must provide proof of workers' compensation insurance, a copy of their written IIPP or signed adoption of this program, and proof of required training and certifications. Subcontractors observed working unsafely will be stopped and may be removed from the project.

This program is reviewed at least annually by the Program Administrator, and additionally after any serious incident, Cal/OSHA citation, or significant change in services. Revisions are communicated to all employees.

Effective date: August 11, 2026. Review cycle: annually, and after any serious incident or significant operational change.