ACTV JAPAN INDUSTRIAL HEALTH AND SAFETY INSTRUCTION 1. Industrial Health and Safety Instruction
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1 ACTV JAPAN INDUSTRIAL HEALTH AND SAFETY INSTRUCTION 1 Industrial Health and Safety Instruction
2 ACTV JAPAN INDUSTRIAL HEALTH AND SAFETY INSTRUCTION 2 ACTV JAPAN takes employee, contractor and intern safety very seriously. Film production produces numerous hazards and safety issues that need to be recognized to prevent loss of equipment, time, and life. Because of the hazardous nature of production sets and hazardous locations throughout the world, safety and hazard prevention is a key priority for ACTV JAPAN and its partners.
3 ACTV JAPAN INDUSTRIAL HEALTH AND SAFETY INSTRUCTION 3 This instruction outlines the occupational and industrial, environmental safety, fire protection and health program of ACTV JAPAN. SUMMARY OF CHANGES: First Draft 1. Purpose Responsibilities Guidance Sources Applicability Training Risk Management Reporting Procedures Emergency Arrangements Communication of Information Safety Procedures Work Refusal Process Attachment 1 GLOSSARY OF REFERENCES.. 19
4 ACTV JAPAN INDUSTRIAL HEALTH AND SAFETY INSTRUCTION 4 1. PURPOSE. The purpose of this instruction is to outline ACTV JAPAN s Health and Safety policies for employees, contractors and interns Scope. This instruction applies to all ACTV JAPAN employees, contractors and interns, and to all areas within ACTV JAPAN LTD except where otherwise prescribed or specified, or in instances where ACTV JAPAN LTD is under contractual obligation where in contractor safety standards will be adhered to. In the event contractor does not have specified safety standards, this instruction will be specified in its place Program performance. Program performance will be rated under three (3) specific measurements: 2. RESPONSIBILITIES Occupational illness and injury resulting in lost productivity or life Health and Safety violations from outside agencies Internal risk assessment and risk management evaluations ACTV JAPAN LTD Registrar: The Registrar is responsible for safety management of ACTV JAPAN. If the Registrar is not competent in this area, the Registrar should appoint a Health and Safety Representative trained to manage the program The Registrar is responsible for appointing a Health and Safety Representative to review, implement and enforce this Instruction. The appointed Representative does not need to be an employee of ACTV JAPAN, the Registrar can appoint him/herself. Multiple Representatives may be appointed The Registrar is responsible for the development of a Health and Safety training program. This responsibility may be delegated The Registrar is responsible for providing financial and other resources for effective implementation of this Instruction The Registrar is responsible for complying with this Instruction.
5 ACTV JAPAN INDUSTRIAL HEALTH AND SAFETY INSTRUCTION ACTV JAPAN Health and Safety Representative: The Health and Safety Representative is responsible for the effective implementation of this Instruction The Health and Safety Representative is responsible for the update/upkeep of this Instruction The Health and Safety Representative is responsible for acting as a liaison between ACTV JAPAN and outside safety and health agencies The Health and Safety Representative is responsible for ensuring that production sets and locations adhere to outside agency health and safety instructions, documents and protocols The Health and Safety Representative is responsible for the documentation and record keeping of employee, contractor and intern safety, fire protection and health training The Health and Safety Representative is responsible for attending safety and health training/refresher courses The Health and Safety Representative is responsible for the Operational Risk Management (ORM) and Risk Assessment program The Health and Safety Representative is responsible for complying with this Instruction ACTV JAPAN Employees: ACTV JAPAN employees are responsible for the safety and well being of contractors and interns whilst contracted by ACTV JAPAN ACTV JAPAN employees are responsible for attending safety and health training/refresher courses ACTV JAPAN employees are responsible for assessing risk before during and after production to ensure sets/locations meet or exceed prescribed safety requirements as outlined in this instruction or superseding protocol ACTV JAPAN employees are responsible for reporting any accidents, mishaps or hazards to the appropriate authorities.
6 ACTV JAPAN INDUSTRIAL HEALTH AND SAFETY INSTRUCTION ACTV JAPAN employees are responsible for complying with this Instruction ACTV JAPAN Contractors: ACTV JAPAN contractors are responsible for attending safety and health training/refresher courses ACTV JAPAN contractors are responsible for assessing risk before during and after production to ensure sets/locations meet or exceed prescribed safety requirements as outlined in this instruction or superseding protocol ACTV JAPAN contractors are responsible for reporting any accidents, mishaps or hazards to the appropriate authorities ACTV JAPAN contractors are responsible for complying with this Instruction ACTV JAPAN Interns: 3. GUIDANCE ACTV JAPAN interns are responsible for attending safety and health training/refresher courses ACTV JAPAN interns are responsible for assisting in assessing risk before during and after production to ensure sets/locations meet or exceed prescribed safety requirements as outlined in this instruction or superseding protocol ACTV JAPAN interns are responsible for reporting any accidents, mishaps or hazards to the appropriate authorities ACTV JAPAN interns are responsible for complying with this Instruction Guidance for this Instruction is provided by the Occupational Health and Safety Act (UNITED STATES), the Health and Safety at Work Act (UNITED KINGDOM), the Industrial Safety and Health Law (JAPAN) and the Safety Guidelines for Film and Television in Ontario (CANADA).
7 ACTV JAPAN INDUSTRIAL HEALTH AND SAFETY INSTRUCTION 7 4. SOURCES Regulatory Federal and International Standards. ACTV JAPAN complies with the intent of standards of the host government. For example, while producing in Japan the governing act is the Industrial Health and Safety Law. The host nations health and safety standards take precedence over this instruction unless this instruction is more stringent Territories with absence of written standards. In the event ACTV JAPAN is producing in territories with no written health and safety standards, this instruction will be the governing instruction using Occupational Health and Safety Act as a reference. 5. ACTV JAPAN HEALTH AND SAFETY INSTRUCTION APPLICABILITY Unique Situations. Under certain circumstances deemed unique, this instruction may not be applicable. Great care has been given to provide guidance under normal operating procedures, however in a unique situation this instruction should be applied as far and as practically as possible. 6. SAFETY, FIRE PROTECTION AND HEALTH ON THE JOB TRAINING ACTV JAPAN provides On the Job safety, fire protection and health training as well as written material for employee, contractor and intern review. This is to ensure safety and health competence from ACTV JAPAN employees, contractors and interns Training will be a bi annual event. New employees, contractors and interns will receive training before they are permitted to work on set/on production DELETED 6.3. Production safety training. On set production training safety will be included with On the Job safety, fire protection and health training On the Job training outline: Hazards of the job tasks and safety procedures to be followed Hazards of the work areas to include physical and chemical Applicable standards and guidance that apply to job and workplace.
8 ACTV JAPAN INDUSTRIAL HEALTH AND SAFETY INSTRUCTION Personal protective equipment needed and how, when and where to use it Location and use of emergency and fire protection equipment Emergency procedures that apply to job and workplace, including evacuation procedures, fire reporting procedures, and location of fire alarms and extinguishers Reporting unsafe equipment, conditions or procedures to Production Managers immediately Location, submission procedures Mishap reporting procedures Emergency telephone numbers Location and required review of appropriate safety bulletin boards Location of medical facilities and procedures for obtaining treatment Requirements for documentation and notification of occupational injury or illness DELETED Individual responsibilities for ensuring own safety Required use of safety belts and/or safety harnesses Personal rights and responsibilities under applicable guidance DELETED Any occupational medical examination required Confined space requirements Manual lifting guidance Jewelry safety Principles of risk management.
9 ACTV JAPAN INDUSTRIAL HEALTH AND SAFETY INSTRUCTION Potential hazards associated with the surrounding local area if production activities require travel. 7. OPERATIONAL RISK MANAGEMENT AND ASSESSMENTS 7.1. Risk management. Risk is an inevitable and unavoidable fact of life. There will always be a certain amount of risk involved during every production. ACTV JAPAN s goal is not to eliminate risk, but to reduce necessary risk to the smallest factor possible while accepting no unnecessary risk. ACTV JAPAN does this by incorporating Operational Risk Management and Risk Assessments into the production pipeline Operational Risk Management (ORM). Operational risk management is a decision making process to systematically evaluate possible courses of action, identify risks and benefits, and determine the best course of action for any given situation. ORM enables ACTV JAPAN s employees, contractors, and interns to maximize operational capabilities while limiting all dimensions of risk by applying a simple, systematic process appropriate for all personnel and functions during all stages of production ORM Principles Accept no unnecessary risk. Unnecessary risk comes without a commensurate return in terms of real benefits or available opportunities. All ACTV JAPAN productions and daily routines involve risk. The most logical choices for accomplishing a production are those that meet all production requirements while exposing personnel and resources to the lowest acceptable risk Make risk decisions at the appropriate level. Making risk decisions at the appropriate level establishes clear accountability. Those accountable for the success or failure of the production must be included in the risk decision process Accept risk when benefits outweigh the costs. All potential benefits should be compared to all potential costs. The process of weighing risks against opportunities and benefits helps to maximize production capability. Even high risk endeavors may be undertaken when there is a well founded basis to believe that the sum of the benefits exceeds the sum of the costs.
10 ACTV JAPAN INDUSTRIAL HEALTH AND SAFETY INSTRUCTION Integrate ORM into operations and planning at all levels. To effectively apply risk management, ACTV JAPAN Production Managers, employees, contractors and interns must dedicate time and resources to integrate ORM principles into planning and operational processes. Risk assessments of productions are most supportive when they are done as a normal way of managing a production, not an add on process performed by people not otherwise involved ORM Process Identify the Hazards. Step one of the process involves application of appropriate hazard identification techniques in order to identify hazards associated with the operation or activity. Hazard can be defined as any real or potential condition that can cause production accident, mishap or damage Assess the Risk. The assessment step involves the application of quantitative or qualitative measures to determine the probability and severity of ill effects potentially resulting from exposure to a hazard Analyze Risk Control Measures. Step three involves the evaluation of specific strategies and controls that reduce or eliminate risk. Effective mitigation measures reduce one of the three components (probability, severity or exposure) of risk Make Control Decisions. Decisions are made at the appropriate level and are based upon analysis of overall costs and benefits. Decision makers choose the most supportive risk controls consistent with ORM principles Implement Risk Controls. Once control measures have been selected, an implementation strategy must be developed and carried out Supervise and Review. Risk management is a process that continues throughout the life cycle of the system, production, or activity. ACTV JAPAN employees, contractors and interns at every level must fulfill their respective roles in ensuring controls are sustained over time. Once controls are in place, the process must be periodically reevaluated to ensure their effectiveness and production supportiveness. 8. ACCIDENT, MISHAP AND HAZARD REPORTING PROCEDURES Reporting procedures. If an accident or mishap occurs during a production under the commision of ACTV JAPAN, the Production Manager must be notified as soon as possible as to the nature and severity of the accident or mishap. This information will
11 ACTV JAPAN INDUSTRIAL HEALTH AND SAFETY INSTRUCTION 11 then be relayed to the Health and Safety Representative for evaluation, analyzation, documentation and archiving/distribution. The Health and Safety Representative along with the Production Manager and Registrar (if not also the Health and Safety Representative) will determine if an investigation is warranted into the accident or mishap Other reporting procedures. In the event the accident, mishap or hazard requires outside agency intervention, the host government s Health and Safety Act will determine the reporting procedures along with this instruction. In the event the host government does not have a written Health and Safety Act, the Occupational Health and Safety Act will dictate reporting procedures along with this instruction Emergency, disaster and catastrophe reporting procedures. In the event of an accident or mishap during an emergency, disaster, or catastrophe or reporting an emergency, disaster or catastrophe, the host nation emergency procedures and protocol will be used along with this instruction to dictate reporting procedures. If the host nation has no written emergency procedures and/or protocols, the Occupational Health and Safety Act along with this instruction will be used in lieu of Hazard reporting procedures. Production hazards must be reported to the Production Manager immediately after discovery. 9. FIRST AID AND EMERGENCY ARRANGEMENTS ACTV JAPAN shall provide First Aid supplies, consisting of a First Aid kit, (This First Aid kit will follow host government Occupational Safety and Health guidelines, in the event the host government has no written guidelines the Occupational Health and Safety Act will be the governing instruction along with this instruction) at its expense for use during production hours. The kit is not a substitute for an actual medical facility and in the event of an emergency a medical facility will be used If an ACTV JAPAN commissioned production is an area or territory with no access to a medical facility within a ten (10) kilometer zone (measured outward in circle from production location), ACTV JAPAN will provide an individual who is trained in the administration of first aid Large scale productions (productions consisting of over 200 employees, contractors and/or interns in one production location), ACTV JAPAN will arrange for on location medical services.
12 ACTV JAPAN INDUSTRIAL HEALTH AND SAFETY INSTRUCTION COMMUNICATION OF ESSENTIAL SAFETY AND HEALTH INFORMATION ACTV JAPAN deploys two (2) methods of essential safety and health information communication and distribution: Primary delivery method. The primary delivery method of essential safety and health information is through electronic distribution. This includes such methods as electronic mail, cellular communication, electronically distributed attached files and electronic social media Alternate delivery method. The alternate delivery method of essential safety and health information is through voice and written handout/pamphlet during production meetings and production calls. 11. SAFETY PROCEDURES AND PROTOCOLS Production safety. As outlined in the preface of this instruction, ACTV JAPAN takes safety very seriously. It is imperative that all production team members at all levels are familiar with government health and safety regulations and this instruction Pre production operational risk management and safety assessments. ACTV JAPAN includes initial safety evaluations of a production as part of the production pipeline. During pre production planning the following assessments will be completed: Location hazards. To include such items but not limited to industrial hazards, liability hazards, environmental hazards, social hazards and any unique situation deemed a hazard Equipment hazards. To include such items but not limited to lighting kits, specifically halogen lighting systems and support equipment, props and set design hazards, electrical power systems, motorized vehicle hazards, common industrial tool hazards and any unique situation deemed a hazard Personnel hazards. To include such items but not limited to diseases and illness in hostile environments, political and ideological civil uprising and revolts, dangerous wildlife hazards, on location industrial hazards, extreme weather, geological and acts of nature hazards and any unique situation deemed a hazard Explosive, chemical and fire hazards. To include planned or unplanned explosions, open flames, pyrotechnics, corrosive and/or
13 ACTV JAPAN INDUSTRIAL HEALTH AND SAFETY INSTRUCTION 13 dangerous chemicals hazards and any unique situation deemed a hazard Production operational risk management and safety assessments. ACTV JAPAN includes real time safety evaluations of a production as part of the production pipeline. Production is the pre production plan put into action. This includes the safety plan developed through pre production operational risk management assessments In the event of an unidentified safety hazard being identified during the production stage, the production will be stopped and the Production Manager will be notified immediately as to the nature and severity of the hazard. Production will not resume until the Production Manager has cleared the hazard and the production has been deemed safe In the event of an unidentified safety hazard being identified during the production stage which requires outside agency intervention, the outside agency involved will be the deciding authority on when production will resume. However, the Production Manager maintains authority to keep production halted at his/her discretion In the event of an unidentified safety hazard being identified during the production stage which requires outside agency intervention in territories with no such agency, the Production manager will assume authority until such agency intervenes Post production operational risk management and safety assessments. ACTV JAPAN includes post production safety data evaluations of a production as part of the production pipeline. Post production is the production data analyzed, archived and/or distributed. This includes any safety data collected during real time production operational risk management assessments Any accidents, mishaps, or hazards documented during production will be distributed to the Health and Safety Representative for analyzation, evaluation, documentation and archiving/distribution If an outside agency is involved with a production accident, mishap or hazard, the Health and Safety Representative will follow up with involved agency to acquire their collected data. This data will be to the extent of any applicable Privacy Acts The Health and Safety Representative will distribute a Health and Safety Report to the Production Manager in the event an accident, mishap
14 ACTV JAPAN INDUSTRIAL HEALTH AND SAFETY INSTRUCTION 14 or hazard occurs I.A.W. para.10 of this instruction Production safety procedures. This section outlines specific production safety procedures for use during production Pre production teams will develop a safety plan using ORM to be executed during production Production teams will execute the pre production safety plan in addition to the following safety procedures: Electrical Safety The Gaffer/Lighting Director, Generator operator and/or Production Manager are in charge of all temporary power distribution systems for film or video production. They should be consulted prior to the use of any electrical system Only trained and authorized technicians will attempt on location repairs of electrical equipment Production team members will stay clear of lighting fixtures and lamps Production team members will take care not to walk on or drive over electrical cables whether they are in use or not. Loose cables will be secured in such a manner as to not cause a production industrial hazard The use of emergency lighting equipment will be directed by the pre production ORM assessment and by the host government Health and Safety Act During extreme weather, the Gaffer/Lighting Director, Generator operator and/or Production Manager will determine shutdown of electrical equipment unless specific guidance is given under host government s Health and Safety Acts Light stands and fixtures will be secured either by straps or sandbags to prevent tip overs of fixtures Electrical Safety Qualifications.
15 ACTV JAPAN INDUSTRIAL HEALTH AND SAFETY INSTRUCTION Electrical Safety Qualifications are outlined in the host government s Health and Safety Act. In the event that the host government has no written Health and Safety Act, the Occupational Health and Safety Act along with this instruction will act in lieu of Transportation Safety All transportation vehicles used will comply with host government transportation regulations and authorities Exemption from Productions in territories with no government transportation regulations or authority, or areas out of the jurisdiction of government agencies, such as private property, where ACTV JAPAN under commision or contract has authority over the safety and health of employees, contractors and interns, will be exempt from compliance of If vehicle is equipped with driver and passenger emergency restraint systems and/or other safety features, restraint systems/safety features will be used per method of instruction provided by manufacturer. There is no exemption granted to this instruction Fire Safety. Does not include planned pyrotechnics, explosions or open flames. Planned pyrotechnics safety instruction is governed by host government Health and Safety Acts Fire safety is governed by host government Health and Safety Acts. If producing in a territory with no written Health and Safety Act, the Occupational Health and Safety Act along with this instruction will act in lieu of Production locations will have on hand, at the bare minimum, one (1) approved Fire Extinguisher within 25 feet of production location. Most urban environments already satisfy this requirement however, use proper ORM assessment procedures when in doubt.
16 ACTV JAPAN INDUSTRIAL HEALTH AND SAFETY INSTRUCTION Equipment Safety Boom Poles. Boom pole operators will take care not to introduce hazards to a production through use of boom poles. Boom poles will be used and operated under provided instruction from manufacturer. Horseplay will not be tolerated under any circumstance and is grounds for immediate dismissal from production and forfeiting of compensation for the duration of dismissal. The Production Manager determines acts of horseplay Halogen Lighting Systems. Halogen Lighting Systems introduce many hazards to a production in the form of electrical, extreme heat, fire and industrial. These lighting systems will be operated under provided instruction from manufacturer and by trained and competent individuals. Horseplay will not be tolerated under any circumstance and is grounds for immediate dismissal from production and forfeiting of compensation for the duration of dismissal. The Production Manager determines acts of horseplay Halogen Lighting Systems will be secured either through a secure restraint system and/or sandbagging Halogen Lighting Systems will only be handled, adjusted, repaired or otherwise manipulated by using approved personal protection equipment (PPE) to prevent injury to handler Halogen Lighting Systems safety features will be present and functional according to manufacturer's instruction during the use of the system Camera Systems. Though technology has allowed for compact, light modern camera systems, there may be instances where heavy camera systems must be used as part of the production. These heavy camera systems introduce hazards to personal health and safety. Horseplay will not be tolerated under any circumstance and is grounds for immediate dismissal from production and forfeiting of compensation for the duration of dismissal. The Production Manager determines acts of horseplay Camera Systems will be used, rigged and/or
17 ACTV JAPAN INDUSTRIAL HEALTH AND SAFETY INSTRUCTION THE WORK REFUSAL PROCESS. otherwise manipulated by trained individuals and per the provided instruction from the manufacturer Equipment Connection Systems. Equipment Connection systems include data cables, power cords, XLR cables, B/N and Coax cables, computer cables and any other cable that physically connects one piece of equipment to another or power source. These connection systems introduce specific industrial hazards. Horseplay will not be tolerated under any circumstance and is grounds for immediate dismissal from production and forfeiting of compensation for the duration of dismissal. The Production Manager determines acts of horseplay Connection system cables will be taped, bundled, strapped, covered or otherwise secured in a manner to prevent tripping hazards Connection system cable locking connectors will be engaged per manufacturer's instruction Common Industrial Tool Systems. Common industrial tool systems include any tool that is not unique to a specific purpose or one time use. This includes common screwdrivers to powered lift trucks and pallet jacks. These tools present numerous hazards to a production including personal health and safety hazards, industrial hazards, fire hazards, explosive hazards and chemical hazards. Horseplay will not be tolerated under any circumstance and is grounds for immediate dismissal from production and forfeiting of compensation for the duration of dismissal. The Production Manager determines acts of horseplay All Industrial Tool System safety procedures are governed by the host governments Health and Safety Act. In the event ACTV JAPAN is producing in a territory without a written Health and Safety Act, the Occupational Health and Safety Act along with this instruction will be used in lieu of Contractor or intern work refusal process. The work refusal process is governed by their sponsor governments work refusal process. Unless otherwise specified in writing,
18 ACTV JAPAN INDUSTRIAL HEALTH AND SAFETY INSTRUCTION 18 while contractor or intern is engaged in work refusal, they agree to forfeit compensation until disengaged from work refusal Salaried employees of ACTV JAPAN LTD work refusal process is governed by Industrial Safety and Health Law (JAPAN). Kristofor K. Morich Procedures and Policies, ACTV JAPAN John R. Lipartito Managing Director, ACTV JAPAN Jim A. Ballard Production Manager, ACTV JAPAN Yoshio Numai General Manager and Registrar, ACTV JAPAN
19 ACTV JAPAN INDUSTRIAL HEALTH AND SAFETY INSTRUCTION 19 Attachment 1 GLOSSARY OF REFERENCES Occupational Health and Safety Administration (OSHA) Health and Safety at Work Act (HSWA) Industrial Safety and Health Law (ISHL) Safety Guidelines for Film and Television in Ontario
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