FOX Corporation requires that all work operations be conducted safely, and in accordance with established environmental, health and safety procedures and applicable regulatory requirements.
1.0 SCOPE
The prevention of injury or illness is a primary factor in all FOX Corporation (FOX) work activities. An effective safety program also requires the total participation from all levels of the organization.
2.0 Responsibilities
Within FOX, the ultimate responsibility and authority for establishing effective health and safety policies rests with the Chief Operating Office. As FOX is a multi-divisional organization, senior executives responsible for establishing and maintaining health and safety policy within their respective operating divisions include:
- Eric Shanks, FOX Sports
- Robert Wade, FOX Entertainment
- Jack Abernethy, FOX Television Stations
- Suzanne Scott, FOX News Media
- Gary Ehrlich, FOX Studio Operations
FOX’s Environmental, Health and Safety Department (EHS) has been established and is responsible for supporting the needs of the above-mentioned executives within FOX and is tasked implementing necessary policy and program-related requirements on their behalf.
In addition to required Environmental, Health and Safety (EHS) Program responsibilities discussed in EHS001, EHS Policy, the Injury and Illness Prevention Program (IIPP) responsibilities described below are necessary to ensure the effectiveness of the procedure.
2.1 Department Heads and Management
Department Heads and Management-level personnel will:
- Identify health and safety hazards through job safety assessments and routine inspections, and take action to control the hazards.
- Develop work area-specific safety procedures as needed.
- Know and implement all applicable safe work practices.
- Ensure all personnel are trained in the safe performance of their applicable work activities.
- Provide FOX’s job-specific safety training to employees.
- Ensure appropriate refresher training for employees is provided where required.
- Require employees to comply with applicable rules, policies, procedures, and guidelines.
- Provide and enforce the use and maintenance of safety devices and personal protective equipment as needed.
- Ensure employees are qualified and able to perform the required duties.
- Ensure employees report work-related injuries and illnesses in accordance with established procedures and state law.
- Investigate every incident, accident, injury, or illness promptly and thoroughly to determine the cause and take the necessary action to prevent reoccurrence.
- Provide timely and necessary information to the Workers’ Compensation Department to satisfy the requirements for claims management.
Department Heads and Management-level personnel are responsible for promoting a positive attitude toward safety and health practices, identifying budget requirements, and developing departmental safety programs in compliance with the requirements of the IIPP.
2.2 Employees
Every FOX employee is responsible for complying with all company safety policies and procedures. Each employee is responsible for the following:
- Comply with all rules, policies, procedures, and guidelines applicable to their jobs, actions, and conduct.
- Take every reasonable precaution to protect the health, life, and safety of themselves and other employees and facilities.
- Do not remove, displace, damage, or destroy any safety device, notice, or warning furnished for use in any place of employment or interfere in any way
with the use of it by any other person. - Know and implement health and safety requirements of their work assignment.
- Use and maintain the protective equipment provided and assigned for use.
- Report safety-related problems or concerns to their supervisor, department head, and/or the EHS Department.
- Report work-related injuries and illnesses promptly to their immediate supervisor.
- Attend training sessions.
- Only perform tasks for which they are adequately trained.
2.3 Environmental, Health and Safety Department
The EHS Department is responsible for the management, development, implementation, and ongoing administration of the IIPP. The EHS Department will perform the following actions in support of the IIPP:
- Assist department heads in their management of the IIPP.
- Provide consultation on matters of workplace health and safety, including guidance for controlling workplace health and safety hazards.
- Monitor worksite environments to determine and assess employee exposure to unsafe or unhealthy conditions.
- Interpret applicable safety regulations and recommend appropriate compliance strategies.
- Provide audits, training, safety team participation, and required services in support of the IIPP.
- Provide periodic summaries of accident information to departmental units for review and support of safety program development.
- Work with the department heads and safety teams to conduct reviews of employee accident reports and act on pertinent safety matters.
- Maintain the IIPP and associated safety programs to address specific hazards.
- The EHS Department will publish and periodically review and revise this policy.
3.0 Procedure
3.1 Compliance with EHS Policies
All employees are responsible for using safe practices; following all directives, policies, and procedures; and assisting in maintaining a safe work environment. Management is responsible for ensuring that all health and safety policies and procedures are clearly communicated and understood by all employees. Managers and supervisors are expected to enforce the rules fairly and uniformly. Ensuring that all employees comply with the rules and maintain a safe work environment includes the following:
- Evaluate the safety performance of all employees.
- Recognize employees who perform safe and healthful work practices.
- Provide training to employees whose safety performance is deficient.
- Discipline employees for failure to comply with safe and healthful work practices.
Any employee who knowingly or negligently violates safety rules or practices, or engages in behavior that could result in property damage, personal injury, or injury to others, may be disciplined up to and including termination.
3.2 Identification of Hazards
The on-going identification of potential hazards is critical to the prevention of workplace accidents. Hazard identification and control are also directly related to other IIPP components such as training and inspections.
3.2.1 Safety Programs for Specific Hazards
Where necessary, Department Heads will develop activity-specific health and safety requirements. Individual departments may need to develop operational safety procedures for particularly hazardous tasks performed by their employees.
3.2.2 Work Site Inspections
All personnel are responsible for inspection of their work site(s) to identify potential hazards. These identified hazards will then be corrected using the appropriate hazard mitigation methods. Any hazards that require assistance in correcting shall be reported to the work supervisor for resolution. Under no
circumstances will work be performed under unsafe conditions.
Employees play a key role in identifying hazards. Employees are encouraged to report problems or concerns to their supervisor. If the concern is not addressed at that level, employees can report to their Department Head, and/or the EHS Department.
Hazard notification can be made using the Fox Employee Hotline, which may be used anonymously, as a mechanism for submitting this information.
The Employee Hotline Number is 866.369.2225.
It is unlawful for an employee to be disciplined or retaliated against for making a legitimate oral or written complaint to his or her supervisor, Department Head, the EHS Department, or any governmental agency having regulatory responsibility for occupational health and safety.
3.2.3 Department-Initiated Inspections
Conducting routine inspections is an important part of hazard identification and ensuring that employees work in a safe environment. Supervisors, or their designees, must perform routine evaluations of their operations for health and safety hazards and maintain a file of these inspections.
Hazards noted during the inspections shall be corrected as soon as feasible. Inspections shall be conducted in accordance with the following frequency:
- Monthly – all potentially hazardous areas (shops, warehouses, docks, etc.) to detect and correct any identified hazardous conditions(s).
- Quarterly – all office areas to detect and correct any identified hazardous condition(s).
- As required by a supplemental safety program.
Additional safety inspections must be conducted whenever new equipment or changes in procedures are introduced into the workplace that presents new hazards. A safety review may be needed when an accident occurs, to identify and correct hazards that may have contributed to the accident.
3.2.4 Periodic Inspections
Periodic inspections to identify and evaluate workplace hazards are performed by competent. The EHS Department will assist FOX-management in the performance of periodic inspections to identify and evaluate hazards as follows:
- When the IIPP was initially established.
- When new substances, processes, procedures, or equipment that presents potential new hazards are introduced into the workplace.
- When new, previously unidentified hazards are recognized.
- When occupational injuries and illnesses occur.
- When regular, full-time, or freelance employees are hired and/or reassigned to processes, operations, and/or tasks for which a hazard evaluation has not yet been conducted.
- Whenever workplace conditions warrant an inspection.
3.2.5 EHS Department Surveys and Audits
EHS personnel will perform facility work-area inspections on a periodic basis and eventually, conduct full-scale department audits on a annual basis. EHS personnel will communicate the results of surveys and audits with appropriate department officials. Supervisors must take action to correct hazards identified by EHS Department personnel. Additionally, from time to time or as deemed necessary, FOX may retain the services of insurance providers or third party consulting firms to assess unique hazards at its work locations.
3.3 Hazard Correction
Unsafe or unhealthy work conditions, practices, or procedures shall be corrected in a timely manner based on the severity of the hazards. Hazards shall be corrected as follows:
3.3.1 Imminent Danger Hazards
Imminent dangers are those safety hazards that pose an immediate threat to personal safety and may cause personal injury, illness, death, and/or significant damage to property. Employees recognizing an imminent danger have the authority to take any or all of the following measures, as necessary:
- Stop the operation (if under their immediate control).
- Notify affected employees.
- Report the danger to the immediate supervisor having jurisdiction over the area.
- Report the danger to the EHS Department.
3.3.2 Other Identified Hazards and Employee Complaints
Any safety hazard identified must be reported to an area supervisor immediately who must then take steps to ensure the condition is abated in a timely manner. An attempt should be made, whenever possible, to isolate the hazard until it can be corrected. For example, barriers should be positioned,
equipment locked out, or employees relocated to a safe area. After identifying potential hazards, action must be taken to control the hazard. Hazard mitigation techniques to be considered include:
- Material substitution.
- Process selection.
- Use of engineering controls, such as ventilation, isolation.
- Administrative controls, when allowed, which can include assignment of work/rest rotations.
- Use of personal protective equipment (PPE).
- Use of air monitoring.
- Erection of scaffolding, guard rails.
- Medical surveillance.
- Training of personnel.
- Immunizations.
3.4 Personnel Training
Prior to performance of work, supervisors will ensure that personnel have the proper qualifications and training to perform the assigned tasks safely, and are familiar with the general and job-specific health and safety practices appropriate to the work. Training and instruction shall be provided as follows:
- Explanation of the IIPP emergency action plans and fire prevention plan, and measures for reporting any unsafe conditions, work practices, injuries, and when additional instruction is needed.
- Uses of appropriate clothing, including gloves, footwear, and personal protective equipment.
- Information about chemical hazards to which employees could be exposed and other hazard communication program information.
- Provisions for medical services and first aid, including emergency procedures.
- Annual refresher training regarding established safety rules/policies/procedures, and any other areas listed in supplemental safety programs.
- Retraining whenever new equipment, substances, or processes are introduced into the workplace that may create new hazards. Hazards that have been reported to department heads should be addressed in a training session.
- To all workers given new job assignments for which training was not previously provided.
- Whenever management is made aware of a new or previously unrecognized hazard.
- To supervisors to familiarize them with the health and safety hazards to which workers under their immediate direction and control may be exposed.
- To all workers with respect to hazards specific to each employee’s job assignment.
Refresher or supplemental training to ensure employee’ skill sets are at the level necessary to perform their work efficiently and safety training must be documented with training records retained in department files. Department heads/supervisors shall require employees to take all appropriate training.
Training documentation shall include the date and time, name of trainer and trainee, topics covered, and trainee signature.
Training includes not only trade-specific training (e.g., hazardous noise exposure), but also must incorporate the qualifications required by regulations (e.g., respirator protection training and fit testing), and additional training needed such as use and care of PPE, requirements for tasks such as confined space entry, and the hazards of the tasks and materials used.
3.5 Communication
Every employee and supervisor at FOX must ensure that an open line of communication regarding safety-related issues is maintained. This can be accomplished through both department-specific and company-wide safety programs and policies. The following system of communication is designed to facilitate a continuous flow of health and safety information between management and staff in a form that is readily understandable and consists of one or more of the following:
- New employee orientation including a discussion of health and safety policies and procedures.
- IIPP review.
- Workplace safety and health training programs.
- Effective communication of health and safety concerns between employees and supervisors, including translation where appropriate.
3.5.1 Safety Meetings
Some departments and activities will require the performance of routine safety meetings with its employees. These meetings should last no less than 5 minutes and address information pertaining to workplace safety policies and procedures. Employees who have construction-related job responsibilities are required to attend safety or tailgate meetings every 10 working days. The foreman or department head are responsible for ensuring that these meetings are conducted and documented.
3.5.2 Employee Hotline
Every employee at FOX has the ability to report safety concerns, anonymously if necessary, via the Employee Hotline at 866.369.2225. This service can be accessed 24 hours a day, and each call will be assigned to the EHS Department to implement the investigation process.
3.5.3 Intranet
The EHS Department will distribute EHS-related procedures and information via FOX’s Intranet/internet site.
3.5.4 Signs/Postings/Barricades
Areas where hazards have been identified shall be posted when unprotected personnel could enter. Accident prevention signs include “Hard Hat Area” and “No Smoking.” Barricades are also to be used to protect personnel, as in re-routing vehicle or foot traffic. When barricades are used, they shall be used in
conjunction with the appropriate hazard signs.
3.6 Accidents
Accidents and Incidents involving FOX personnel must be reported to and investigated by the EHS Department in accordance with EHS102, Incident Reporting and Investigation. Forms are mentioned by reference only. Key elements of EHS102 are summarized in this section.
3.6.1 Medical-related Incidents
Any on-the-job incident must be promptly reported in accordance with the following procedure:
- The supervisor of an injured employee must be notified immediately.
- Dial 9-1-1, (9-9-1-1 on the Fox Lot) for any medical emergency involving loss of consciousness or other serious condition.
- For non-emergency medical-related incidents, the employee’s supervisor must ensure that the injured employee receives medical attention as soon as possible. Specific procedures for each operating location should be developed as appropriate.
- For medical-related incidents that occur on the Fox Studios Lot during normal business hours, the employee must report to the Medical Department, located in Building 99, Room 220, immediately for evaluation. The Medical Department will determine if the employee requires off-site medical care.
- Supervisors are required to notify the EHS Department of the incident as soon as possible by calling 310-369-2671 or the Employee Hotline at 866-369-2225.
- The EHS Department will investigate the incident within 24 hours and notify the applicable Human Resources Business Partner, Risk Management and the Workers’ Compensation Department as necessary.
3.6.2 Non-Medical-Related Incidents and Near Misses
- Supervisors must be notified immediately.
- Supervisors are required to notify the EHS Department of the incident as soon as possible by calling 310-369-2671 or the Employee Hotline at 866-369-2225.
- The EHS department will investigate the incident within 24 hours.
- The supervisor and affected employee are required review the recommendations of corrective action with a focus on prevention of recurrence.
3.7 Investigation Procedure
Incidents and near misses require investigation to identify factors that might have caused or contributed to the occurrence and to prevent future incidents.
The investigation procedures, investigation leader, and investigation detail will be determined by the EHS Department and require participation by other FOX employees depending on the severity of the incident.
3.7.1 Incidents and Near Misses
Incidents are more severe than near misses and can result in significant injury or property damage.
The EHS Department will conduct investigation in accordance with the following:
- The EHS Department will document the investigation.
- The investigation must be conducted within twenty-four (24) hours after the incident occurs.
- As necessary, Department Heads may need to obtain additional information surrounding the incident in order to fully satisfy the investigation requirements/needs of the incident.
- Photographs of the incident scene must be taken as soon as possible after the incident. Statements from involved employees and witnesses must be collected using FOX’s Witness Statement Form.
3.7.2 Fatalities and Serious Injuries
The EHS Department must be notified immediately at any time a serious injury occurs. Serious injuries are medical-related accidents that involve the following:
- Serious injury or illness requiring inpatient hospitalization for a period in excess of 24 hours for other than medical observation.
- Employee loss of any member of the body or suffers any serious degree of permanent disfigurement.
3.8 Recordkeeping
Record keeping is required to comply with various occupational safety and health regulations and for company operations. These records include inspection reports, exposure reports, medical surveillance reports, training documentation, accident reports, summaries of investigations, and other records as
required by safety programs for specific hazards.
Based on content, Departments are required to maintain records for established time periods. The following are records for which retention is required or highly recommended. This is by no means a complete list, and any questions or concerns regarding recordkeeping should be addressed to the EHS Department at 310.369.2671 or via email at safety@fox.com.
- Workplace inspections.
- All safety and job specific training.
- Safety meetings.
- All departmental policies and standard operating procedures.
- Accident investigations.
- Equipment repair and maintenance records.
As a rule, 3 years is usually adequate for retention of records, with the following significant exceptions:
- Exposure records
– Copies of employee exposure records must be retained for 30 years following the exposure. - Medical records
– Employee medical information shall be retained for 30 years after the employee separates from FOX. Any medical records maintained by the department must be kept confidential, independent from other employee records, and in a secure place such as a locked filing cabinet.
An inquiry should be made before disposing documents to ensure that:
- The records are eligible for disposal according to federal, state, and local laws.
- No claims are pending that may require the retention of the records.
4.0 REFERENCES
EHS001, EHS Policy.
EHS102, Incident Reporting and Investigation.
5.0 ATTACHMENTS
None.