NU-SAF-102 — PPE PROGRAM & WRITTEN HAZARD ASSESSMENT

Tier 2/3/4 — Procedure + Field Card + Hazard Assessment Certification · Rev 1.0 DRAFT — goes live the day Adam signs §5 · Owner: Field Supervisor Parent: NU-SAF-100 §5 element 3. Governing standards: 29 CFR 1926 Subpart E (1926.95–.106) for the equipment; 29 CFR 1910.132(d)(2) for the written certification (§1 explains why both). Field-card layer: Card 05-A line 8 is the daily gate; NU-SAF-102-C (§7) is the truck card. This document is the program behind both.

THE GATE

The baseline five — hard hat · hi-vis · safety glasses · safety-toe boots · gloves — go on before the gate at the yard and stay on inside the cones. Every man, every site, every day (Card 05-A line 8). The task add-ons in the §4 table go on before the task starts, not after the first close call. And the program itself has one record that matters: the signed certification in §5. Unsigned, Nova has no PPE program on the day an auditor asks.

Two records back this gate. Daily: the Card 05-A morning gate plus the PPE line on the JSA (the form the Work Order Ready Gate labels JHA — same form). Program: the signed §5 certification, filed where the office can produce it in under a minute.

1. WHY TWO STANDARDS ARE CITED (read this before an audit, not during one)

The equipment rules are construction rules. 29 CFR 1926 Subpart E: 1926.95 (provision, condition, and who pays), 1926.96 (foot), 1926.100 (head), 1926.101 (hearing), 1926.102 (eye and face), 1926.97 (electrical protective equipment — the dielectric gloves).
The written certification lives in general industry: 1910.132(d)(2). It requires a written document that identifies the workplace evaluated, names the person certifying, carries the date of the assessment, and identifies itself as a certification of hazard assessment. The construction standard requires the assessment thinking (PPE selected for the hazards of the work, 1926.95(a)) but never wrote the certification wording down.
Auditors do not care about that distinction. ISNetworld, Avetta, Congruex Unify, and insurance underwriters ask for "the signed hazard assessment certification" by name, and the answer "that's a 1910 requirement" loses the prequal. So Nova writes it, signs it, and files it. §4 is the assessment. §5 is the certification. Together they are the document the audit wants.

Why it matters beyond audits: the assessment is the one page that says, task by task, what a Nova hand wears before he starts. A new hire shouldn't have to learn that from a burn or a chipped tooth.

2. THE BASELINE FIVE

Card 05-A line 8, quoted exactly, because the field card and this program must never drift apart:

PPE on before the gate: hard hat · hi-vis · safety glasses · safety-toe boots · gloves.

That line is the whole daily standard. What each item means:

Item	The standard	Cite
Hard hat	Worn wherever there is possible danger of head injury from impact, falling or flying objects, or electrical contact — which is every Nova work area. Not backwards under a bore rig mast, not riding the dashboard.	1926.100(a)
Hi-vis	Class per road exposure, per NU-SAF-105 §6.3: Class 2 minimum, all workers, all sites, always. Class 3 for night work, anything above 45 mph, and every flagger. NU-SAF-105 owns the class rules — this row just makes hi-vis one of the five.	NU-SAF-105 §6.3 · 1926.201(a) (flaggers)
Safety glasses	On from the gate, not from the first spark. Machines, mud, marking paint, and stone chips do not announce themselves. Men who wear prescription glasses get over-the-glass (OTG) safety glasses or prescription safety eyewear — Nova stocks OTG as the default (1926.102(a)(2)). Street glasses are not safety glasses.	1926.102(a)(1) · 1926.102(a)(2)
Safety-toe boots	Protective footwear meeting the consensus standard, every man below the neck of the excavation trade's number-one crush zone: his own feet.	1926.96
Gloves	Construction carries no numbered glove standard — hand protection rides on the general provision (1926.95(a); 1910.138 is the general-industry analog). Nova's rule is simpler: gloves on for every hands-on task. Rod handling, rigging, lids, pipe, tools.	1926.95(a)

The five are the floor, not the ceiling. §4 adds task PPE on top. Nothing in §4 ever subtracts from the five.

3. TASK ADD-ONS (what goes on top of the five, and when)

Add-on	When	The standard
Dielectric gloves + insulating mat	Operator, hands on the controls, every pilot bore. NU-SAF-110 §2 owns this gate and §2.1 owns the care rules (daily inspect + air test, 6-month electrical retest, leather protectors — 29 CFR 1926.97). Not restated here; go read it.	NU-SAF-110 · 1926.97
Hearing protection	In the rig zone whenever a drill rig, hydrovac blower, missile, or breaker is running, and any time you have to raise your voice at arm's length. Plugs or muffs — worn, not pocketed. A full hearing conservation program (monitoring, audiograms) is NU-SAF-113 — on the register gap list, not built; until it exists, the rule is: loud task = protection on.	1926.101 · 1926.52
Face shield over safety glasses	Cutting, grinding, and sawcutting — asphalt, concrete, pipe, steel. The shield is add-on armor, not a substitute: glasses stay on underneath. Silica dust controls for sawcutting are NU-SAF-111's job (register gap list, not built) — flagged in §9 item 7.	1926.102(a)(1)
Waders / rubber boots	Mud work — bore pits, hydrovac spoil, standing water, fluid returns. Wet feet in July are a nuisance; wet feet in January are the end of the workday. Safety-toe still applies where crush hazard exists — rubber safety-toe, not box-store rain boots.	1926.95(a)
Heat-resistant gloves	Hands near the fusion heater plate — it runs hot enough to brand you through a work glove. `[Adam: confirm heat-rated gloves are actually in the fusion kit — see §9]`	1926.95(a)
Chemical-resistant gloves + splash goggles when the SDS calls for them	Handling drilling-fluid additives, solvents and degreasers, fuel, pipe lube — anything with a warning label. The SDS says which glove; the HazCom program that houses the SDS binder is NU-SAF-101 (DRAFT 8/1/26, pending Adam sign-off — SDS binder rides each truck per its §4).	1926.95(a)

4. THE WRITTEN HAZARD ASSESSMENT — BY TASK (Tier 4 · NU-SAF-102-F)

This table IS the hazard assessment. The §5 block certifies it. Baseline five is assumed on every row — the columns list what the task adds and where the governing rules live. Re-assess per §5.2.

#	Task	Hazards found	PPE beyond the five	Governing docs
1	HDD drilling (rig zone)	Rotating drill string, high-pressure fluid, pinch and crush at the vise, noise, mud splash, utility strike / energization	Hearing protection in the rig zone. Operator on pilot: dielectric gloves + mat per NU-SAF-110 §2. Goggles over glasses when charging the hopper with bentonite or additives (dust)	NU-SAF-110 · NU-FLD-220 · HDD Operator book Card 2
2	Locating	Live traffic exposure, uneven ground, sun and heat	None beyond the five — hi-vis class per road per NU-SAF-105 §6.3. Heat rules per NU-SAF-112	NU-SAF-105 · NU-SAF-112
3	Potholing / hand-dig / hydrovac	High-pressure water and air, flying spoil and stone, blower noise, mud, buried utility contact	Face shield over glasses on the wand. Hearing protection at the hydrovac. Waders/rubber boots in mud	NU-FLD-200 ch. 4 · Day 1–2 book Cards 4 & 7
4	Mini-ex trenching	Struck-by and swing radius, cave-in, spoil at the edge, noise	Hearing protection when a breaker runs; otherwise none beyond the five — the controls are distance and spotters (NU-SAF-116 §4 exclusion zone) and protective systems (NU-SAF-107), not equipment on the body	NU-SAF-107 · NU-SAF-116
5	Missile shots	Pneumatic tool noise, air-hose whip, pit work, mud	Hearing protection while the missile runs. Waders/rubber in wet pits	NU-FLD-200
6	Traffic zones (all road work)	Struck-by from live traffic — the one hazard that kills without touching a machine	Hi-vis class stepped up per exposure: Class 3 night / above 45 mph / flaggers. All other rules are NU-SAF-105's	NU-SAF-105 §§4–6
7	Fusion / couplers	Contact burns from the heater plate, pinch at the clamps, solvent wipes	Heat-resistant gloves at the plate. Chemical-resistant gloves for solvent wipe-down	`[Adam: fusion kit contents — confirm]`
8	Loading / towing	Crush and pinch at the hitch, strap recoil, dropped ramps and rod boxes, feet under steel	None beyond the five — gloves and safety-toes are the working items; the controls are procedure and hands-out-of-the-bight per NU-FLT-310	NU-FLT-310
9	Vault / handhole work (topside only)	Smashed fingers on lids, wet ground, and the hazard that owns its own SOP: the atmosphere below the lid	Waders/rubber when wet. Lid work with a hook, not fingers. Entry PPE is not listed because entry is not permitted — NU-SAF-109 governs, and until its §9 program items close, nobody enters	NU-SAF-109
10	Sawcutting / grinding / breaking pavement	Flying fragments, blade contact, noise, silica dust	Face shield over glasses. Hearing protection. Silica controls per NU-SAF-111 when built — until then, flag on the JSA `[Adam: see §9]`	NU-SAF-111 (gap)

Chemicals on Nova trucks and rigs, assessed once here: bentonite and drilling-fluid additives, diesel/gasoline, hydraulic oil, engine oil and grease, pipe lube, marking paint, two-cycle mix, solvents/degreasers. Contact PPE per §3 last row; the SDS binder and labeling program is NU-SAF-101 (DRAFT 8/1/26, pending Adam sign-off — SDS binder rides each truck per its §4).

5. CERTIFICATION OF HAZARD ASSESSMENT (this signature is what the audit wants)

CERTIFICATION OF HAZARD ASSESSMENT — 29 CFR 1910.132(d)(2)

Workplace evaluated: Nova Underground field operations — all crews, all job sites, and the equipment yard; the tasks listed in §4 of this document (HDD drilling, locating, potholing/hand-dig/hydrovac, mini-ex trenching, missile shots, traffic zones, fusion/couplers, loading/towing, vault/handhole topside work, sawcutting/grinding). Finding: the hazards identified in §4 require the personal protective equipment listed in §§2–4 of this document. Person certifying that the evaluation has been performed: Adam Pelewski, Owner, Nova Underground. Date(s) of the hazard assessment: August 1, 2026. This document is the certification of hazard assessment required by 29 CFR 1910.132(d)(2).

Signature: [Adam: sign] Date: [Adam: date]

5.1 Where it lives

Signed original scanned into the app (Softr, with the NU-GOV-000 register); a copy in the prequal answer set so ISN/Avetta/Unify uploads never wait on a hunt. The office produces it on request in under a minute — that is the test.

5.2 When it gets re-done

Re-assess §4 and re-sign §5 whenever any of these happen — and once a year regardless, with the NU-SAF-100 §11 annual program review and signature refresh:

A new task type — the Dirt Work Division's pool digs and any new service line get a row before the first crew mobilizes.
New equipment class — a larger rig, a new attachment, anything that changes the hazard picture.
An incident or near-miss that PPE touched — the NU-SAF-121 record triggers the review; the review answers "was the §4 row wrong, or was it not followed?"
Annual review — new date, new signature. An assessment dated three ownership-of-hazards ago convinces nobody.

6. PROVISION, REPLACEMENT & PAYMENT (the rule that keeps PPE on bodies)

Nova provides the PPE. All of it. NU-SAF-100 §1 commitment 5 already commits to this: "We fund it." OSHA's payment rule (1926.95(d)) carries exceptions — non-specialty safety-toe footwear worn off-site, prescription safety eyewear, everyday clothing. Nova does not use the exceptions. One rule is enforceable; a rule with footnotes is a negotiation. [Adam: decide the boot mechanism — company-bought, allowance, or reimbursement with a cap — see §9]
Damaged or worn out = swapped the same day, no cost to the man, no questions that sound like blame. A cracked hard hat, a shredded glove, a vest gone gray — turn it in, take a new one. The swap gets a line in Daily Truck Log Section C (the same section Card 05-A already uses for anything the morning gate can't check).
Why the no-cost rule is absolute: the moment replacement costs a man money or an argument, he tapes the glove and wears the cracked hat, and the program is dead everywhere except the binder.
Spares ride on the truck. The Card 05-A safety loadout already counts 2 spare vests. Spare glasses, gloves, and earplugs per truck: [Adam: fill quantities — see §9].
Sizing is provision. PPE that doesn't fit is PPE that comes off. New hires get sized during the Day 1–2 book window, not handed the leftovers bin.
Every employee is trained before his first field day — when PPE is required, which PPE per his §4 task rows, how to put it on and fit it, its limitations, and its care — inside the Day 1–2 book window (NU-PPL-405). Retrained when his task PPE changes, new PPE arrives, or misuse is observed. (1910.132(f) analog — same audit logic as §1.)
Care: every man inspects his own PPE — that duty is already assigned in NU-SAF-100 §3 (Operator/Driver/Locator/Laborer row). Dielectric glove care is NU-SAF-110 §2.1 and is not restated here. No painting, drilling, or "customizing" hard hats — modifications void the rating.

7. NU-SAF-102-C — PPE FIELD CARD (Tier 3 — print, laminate, truck)

THE FIVE, before the gate, every day (Card 05-A line 8): hard hat · hi-vis · safety glasses · safety-toe boots · gloves

ADD BEFORE THE TASK: 1. Pilot bore, on the controls → dielectric gloves + mat (NU-SAF-110 — inspected, air-tested, in test date). 2. Rig, hydrovac, missile, breaker, or saw running → hearing protection. 3. Cutting or grinding anything → face shield OVER the glasses. 4. Mud, pits, standing water → waders / rubber boots. 5. Fusion heater plate → heat-rated gloves. 6. Additives, solvents, fuel, pipe lube → chemical-resistant gloves + splash goggles when the SDS calls for them. 7. Night, above 45 mph, or flagging → Class 3 hi-vis (NU-SAF-105 §6.3).

Damaged PPE = swap it today, free, Truck Log Section C. Taped-up PPE is failed PPE.

8. PROOF & RECORDS (what has to exist when this is done right)

Every gate names its record. A gate that produces no record is a suggestion.

Record	Who	When	Where it goes
Signed §5 certification (current date)	Owner	On issue + every §5.2 trigger + annually	App + prequal answer set
PPE line on the JSA — task add-ons named for the day's work	Crew Lead	Before ground break, daily	JSA form
Card 05-A morning gate (the five, on, before rolling)	Crew Lead	Every morning	Card 05-A routine / ROLLING photo per NU-GOV-004
PPE swap (item, man, reason)	Crew Lead	Same day as the swap	Daily Truck Log Section C
Dielectric glove daily test + 6-month retest dates	Operator / Office	Per NU-SAF-110 §10	JSA + app (NU-SAF-124 matrix when built)
New-hire PPE issue + sizing + training sign-off	Office	Day 1–2 window	Training record / app (NU-SAF-124 when built)

Accountability tie-in (NU-PPL-403): PPE is already citable — Card 05-A line 8 makes the five part of the morning gate, and NU-SAF-105 §6.3 prices a vest miss at 1 point. Proposed rows, pending Adam ratifying into 403: any baseline-five item missing inside the cones = Class A (1 pt); working a §3 gated task without its add-on = Class B; the dielectric-glove and strike-protection misses stay Class B/C per the NU-SAF-110 §10 proposal (not duplicated here). Points land on the man who skipped it AND the Crew Lead who watched him work that way.

DONE WHEN

The §5 certification is signed, dated, in the app, and the office can produce it in under a minute.
Every truck carries the §7 card laminated and the spare-PPE stock at the [Adam: fill] quantities.
Every JSA written this month names the day's task add-ons, not just "PPE required."
A new hire can recite the five and point to the §4 row for his task by the end of the Day 1–2 book window.
The 403 rows in §8 are ratified, so enforcement is real and not implied.
The PPE toolbox talks run off the existing 52-week schedule (HANDOFF folder, 07_Toolbox_Talks_52wk.csv) — that schedule already exists; this document is the program behind those talks, and nobody rebuilds it.

NEVER

Never inside the cones without the five. Visitors, inspectors, and owners included — spare vests are on the truck for exactly this.
Never cut or grind without the face shield over the glasses. The shield alone is not eye protection; the glasses alone are not face protection.
Never touch the pilot-bore controls without dielectric gloves in test date (NU-SAF-110 — that gate lives there and is not softened here).
Never tape, glue, paint, or drill PPE. Modified PPE is failed PPE. Swap it.
Never charge a man for PPE, replacement included. Not from a paycheck, not "you lost it, you buy it."
Never write "PPE required" on a JSA without saying which. The §4 table exists so the JSA line can be specific.
Never let the certification go stale past its annual date. An expired certification reads as no program at all on audit day.

9. WHAT THIS DOCUMENT NEEDS FROM ADAM

Sign §5. This is the audit item — the single signature every prequal and every post-incident records request asks for by name. Two minutes, and it closes a P1 row on the NU-GOV-000 gap list.
Decide the boot mechanism (§6): company-bought, allowance, or capped reimbursement. NU-SAF-100 already committed Nova to paying; this is only the how.
Fill the spare-PPE stock per truck (§6): glasses, gloves, earplugs — quantities, and who restocks them on the supply run.
Inventory check: face shields, muffs/plugs, heat-rated fusion gloves, chemical gloves, waders — on the trucks today, or on an order? [Adam: fill what exists]
Ratify the §8 point rows into NU-PPL-403 so the enforcement column is 403 law, not this document's proposal.
Dielectric glove class: already open as NU-SAF-110 §11 item 2 — closing it there completes this document's §4 row 1. Not a new item, just the same one, flagged twice on purpose.
Sawcutting interim rule (§4 row 10): until NU-SAF-111 exists, decide the silica interim (who cuts, with what dust control). One sentence from you and the row stops being a gap.
Ratify Card 05-A v1.0 (NU-GOV-006). Its line 8 wording is load-bearing in this document's §2 — any future change to that line revs this document.

NU-SAF-102 · Rev 1.0 DRAFT · Nova Underground · Parent: NU-SAF-100 §5 element 3 · Governing: 29 CFR 1926.95–.106 + 29 CFR 1910.132(d)(2) certification · Field-card layer: Card 05-A line 8 + NU-SAF-102-C · Uncontrolled when printed.