Safety is built into every job we take

Effective Date: January 1, 2024  |  Last Updated: June 1, 2025  |  Applies to: All field technicians, project managers, subcontractors, and operations personnel

1. Policy Statement

Commercial HVAC Company ("the Company") is committed to achieving and maintaining the highest practical standards of health and safety across all field operations. We conduct commercial HVAC installation, maintenance, repair, and replacement work in occupied commercial buildings, industrial facilities, multi-family residential properties, and public institutions throughout New York City.

Working in active commercial buildings — particularly in mechanical rooms, on rooftops, in confined spaces, and near high-voltage electrical systems — presents real occupational hazards. Our safety policy establishes the minimum standards of care we require of every person who performs work on our behalf or as part of our projects.

This policy is aligned with applicable standards from the Occupational Safety and Health Administration (OSHA), the New York City Department of Buildings (NYC DOB), the Environmental Protection Agency (EPA), and the NYC Fire Department (FDNY) where relevant to mechanical and HVAC operations.

2. Scope and Applicability

This Safety Policy applies to:

• All full-time and part-time employees of Commercial HVAC Company
• All field technicians, apprentices, and helpers working under our supervision
• Licensed subcontractors and specialty trade partners engaged for project work
• Project managers, estimators, and operations staff who visit active job sites
• Any vendor, supplier, or representative who enters a job site in connection with our work

This policy covers all work performed in connection with Commercial HVAC Company service agreements, including routine maintenance visits, emergency service calls, planned replacements, design-build projects, and warranty service — across all five NYC boroughs.

3. Roles and Responsibilities

Company Leadership

• Establish and communicate safety standards, expectations, and accountabilities
• Allocate appropriate resources for training, equipment, and PPE
• Ensure all field operations comply with OSHA 29 CFR 1926 (Construction) and 29 CFR 1910 (General Industry) standards as applicable
• Investigate serious incidents promptly and implement corrective actions
• Maintain valid general liability insurance, workers' compensation coverage, and all required NYC contractor certificates of insurance (COIs)

Project Managers and Supervisors

• Conduct or coordinate a pre-job safety briefing for every new work location
• Confirm that all tools, equipment, and materials are in safe working condition before a job begins
• Identify and communicate site-specific hazards to assigned technicians before work commences
• Stop work immediately if an unsafe condition is identified and cannot be immediately corrected
• Document and report all near-misses, injuries, or property damage within 24 hours
• Verify that any subcontractor assigned to a task holds appropriate certifications and safety qualifications

Field Technicians and All Site Personnel

• Follow all safety procedures, instructions, and site-specific rules without exception
• Use required PPE correctly at all times in areas or tasks where it is mandated
• Report any unsafe condition, tool failure, or near-miss to a supervisor immediately
• Never perform work they are not trained or certified to perform
• Refuse to proceed with work if doing so would create an unreasonable risk of injury, and communicate that refusal to a supervisor
• Maintain a clean and organized work area throughout the duration of any job

4. Personal Protective Equipment (PPE)

Required PPE varies by task and environment. The following are minimum standards for common HVAC field activities:

Standard Field PPE (All Sites)

• Safety-toed boots (ASTM F2413 compliant) at all times on active job sites
• Safety glasses or goggles when working with power tools, drilling, cutting, or near refrigerant
• Work gloves appropriate to the task (cut-resistant for sheet metal; insulated for electrical proximity; chemical-resistant for refrigerant)
• High-visibility vest or clothing when working in areas with vehicle or heavy equipment traffic

Task-Specific PPE

• Electrical work: Insulated gloves rated for the voltage involved, arc flash face shield where arc flash risk is present, and flame-resistant (FR) clothing for work in or near energized panels
• Rooftop and elevated work: Full-body harness with shock-absorbing lanyard whenever working within 6 feet of an unguarded edge above 6 feet in height, as per OSHA 1926.502
• Refrigerant handling: Chemical splash goggles, refrigerant-rated gloves, and a self-contained breathing apparatus (SCBA) or supplied air respirator when working in confined areas with potential refrigerant accumulation
• Confined space entry: Appropriate respiratory protection, gas detection equipment, and full PPE as specified in our Confined Space Entry Permit procedure
• Welding and brazing: Welding helmet, leather gloves, leather apron, and fire-resistant clothing; appropriate ventilation or local exhaust required
• Insulation and ductwork: Dust mask (at minimum N95 rated) and nitrile gloves when handling fiberglass or mineral wool insulation materials

PPE is provided by the Company at no cost to technicians. Technicians who arrive at a job site without required PPE will be sent to retrieve it before work may begin. No exceptions.

5. Hazard Identification and Risk Assessment

Before beginning any new job or task at an unfamiliar site, assigned project supervisors or lead technicians must conduct a verbal or written hazard review covering:

• Type of building and occupancy (occupied, partially occupied, after-hours only)
• Location and accessibility of the work area (rooftop, mechanical room, ceiling space, basement)
• Proximity to electrical hazards (panels, live circuits, exposed conductors)
• Presence of hazardous materials (asbestos-containing materials in older buildings, lead paint, PCB-containing equipment)
• Confined space classification of any enclosed work areas
• Structural risks (aging rooftop equipment curbs, compromised decking, skylights)
• Environmental conditions (extreme heat on rooftops in summer, ice and wind in winter)
• Building-specific emergency exit routes and muster points

For complex or elevated-risk projects, a written Job Hazard Analysis (JHA) may be required prior to mobilization. JHAs are retained in the project file and are available for client review upon request.

6. Lockout/Tagout (LOTO) Procedures

All work performed on or near energized HVAC equipment — including electrical disconnects, refrigerant circuits, gas lines, steam systems, and chilled water systems — requires compliance with our Lockout/Tagout (LOTO) procedure, consistent with OSHA standard 29 CFR 1910.147.

LOTO requirements include:

• Identify all energy sources (electrical, pneumatic, hydraulic, thermal, gravitational) associated with the equipment to be serviced
• Notify the building operator or facilities manager before isolating any system that may affect occupied space operations
• De-energize, isolate, and physically lock out each energy source using company-issued locks — each technician applies their own lock
• Release or restrain any stored energy (discharge capacitors, bleed pressure lines, block elevated components)
• Verify the equipment is in a zero-energy state before beginning work
• Remove locks only after all personnel are clear and tools are accounted for
• Never remove another technician's personal lock — only the technician who applied a lock may remove it

LOTO tags and locks are issued to each field technician and must be carried to every service call. Working on energized equipment without proper LOTO in place is a terminable violation of this policy.

7. Electrical Safety

Commercial HVAC systems operate at voltages ranging from standard 120V/240V residential circuits to 480V three-phase service commonly found in commercial and industrial buildings. Our technicians are trained to treat all electrical circuits as live until personally verified de-energized through LOTO.

• Only EPA-certified and appropriately licensed personnel perform electrical connections to HVAC equipment
• All electrical work is performed in compliance with the current National Electrical Code (NEC) and NYC Electrical Code requirements
• Arc flash hazard assessments are performed or referenced for any work in or near electrical panels rated 50V or above
• Portable electrical tools and extension cords used on job sites are inspected before each use and removed from service if damaged
• Ground Fault Circuit Interrupter (GFCI) protection is used for all 120V portable tools on outdoor or wet-location job sites

8. Rooftop and Elevated Work

A significant portion of commercial HVAC work in New York City takes place on rooftops — servicing rooftop units (RTUs), cooling towers, condensing units, exhaust fans, and related equipment. Rooftop conditions present unique hazards including unguarded edges, slippery surfaces, extreme temperatures, and heavy equipment proximity.

• All rooftop work is pre-authorized through the building manager or property management team before access
• Technicians assess rooftop conditions (surface integrity, drainage, obstructions, wind conditions) before beginning work
• Fall protection — full-body harness and shock-absorbing lanyard tied to an appropriate anchor point — is required for any work within 6 feet of an unguarded roof edge per OSHA 29 CFR 1926.502
• Roof openings and hatches are guarded or covered when not in active use by personnel
• Ladders used to access rooftops must extend at least 3 feet above the roof access point and be secured at the top
• Heavy equipment (replacement units, compressors, condensers) lifted to rooftops via crane or hoist is coordinated with a licensed rigger and requires a NYC DOB crane permit as applicable
• Rooftop work is suspended during lightning, high winds exceeding 25 mph, or ice conditions that cannot be safely mitigated

9. Refrigerant Handling and EPA Compliance

All refrigerant handling performed by or on behalf of Commercial HVAC Company must comply with EPA Section 608 of the Clean Air Act and applicable NYC local refrigerant regulations, including requirements related to refrigerant tracking, leak detection, and phase-down schedules for high-GWP refrigerants.

• All technicians who handle refrigerants hold current EPA Section 608 certification at the appropriate level (Universal, Type I, II, or III) for the equipment they service
• Refrigerant recovery equipment is used to capture and contain refrigerant before any system opening — intentional venting of refrigerants is strictly prohibited by federal law and company policy
• Recovered refrigerant is stored in labeled, DOT-compliant recovery cylinders and transferred to an approved reclaimer
• Refrigerant logs are maintained for each project documenting the type, quantity recovered, quantity charged, and cylinder tracking numbers
• For systems with refrigerant charges of 50 pounds or more, leak inspection schedules and records are maintained in accordance with EPA regulations
• Technicians working in enclosed mechanical rooms with refrigerant systems are trained to recognize refrigerant leak symptoms and are equipped with refrigerant detection capability
• We actively support client transitions away from R-22 (phased out since January 1, 2020) and high-GWP refrigerants toward lower-GWP alternatives in compliance with AIM Act schedules

10. Confined Space Entry

Certain HVAC work environments — including large air handling unit (AHU) interiors, mechanical plenums, utility tunnels, and some equipment vaults — may meet the OSHA definition of a Permit-Required Confined Space (PRCS) under 29 CFR 1910.146.

• All potential confined space locations are evaluated and classified before entry is attempted
• Permit-Required Confined Space entry requires a written entry permit, an attendant stationed outside the space, atmospheric testing (oxygen level, combustible gases, toxic vapors), and rescue provisions
• Atmospheric testing is performed with a calibrated multi-gas detector before entry and continuously monitored during work inside the space
• Non-permit confined spaces are evaluated each time access is required to confirm conditions have not changed
• Technicians do not enter any confined space alone — a second qualified person must be present at the entry point throughout the work period
• Emergency rescue plans are established before entry and communicated to all involved personnel

11. Heat Stress and Cold Weather Precautions

HVAC technicians frequently work in thermally extreme environments — both on New York City rooftops in summer heat and in unheated mechanical spaces in winter. Heat stroke and hypothermia are serious occupational hazards that require proactive management.

Heat Stress Prevention

• Technicians are encouraged to hydrate frequently (minimum 8 oz of water every 20 minutes during heavy exertion in heat)
• Work-rest cycles are adjusted during heat advisories or when heat index exceeds 91°F
• Supervisors are trained to recognize early signs of heat exhaustion and heat stroke
• Shaded rest areas are identified at each rooftop or outdoor job site when available
• Work on sun-exposed rooftops during peak heat hours (11am–3pm) is scheduled to minimize unnecessary exposure during hot weather months

Cold Weather Precautions

• Appropriate insulating and wind-resistant outerwear is required for outdoor and rooftop work below 40°F
• Tools and equipment are inspected for cold-weather performance issues (battery-powered tools may require heated storage or warm-up periods)
• Ice or snow on rooftop surfaces must be cleared from work paths before accessing equipment
• Work involving refrigerant or pressurized systems in cold weather accounts for pressure-temperature relationship changes in refrigerant circuits

12. Manual Lifting and Rigging

Commercial HVAC equipment — including compressors, fan coil units, packaged rooftop units, condensing units, and air handling equipment — frequently involves heavy, bulky components that present serious injury risk if handled improperly.

• Manual lifting limit for a single technician is 50 lbs without mechanical assistance — heavier items require team lifting or mechanical lifting aids
• Proper lifting technique (bend at the knees, keep the load close, avoid twisting) is trained and reinforced
• Mechanical lifting aids (hand trucks, dollies, engine hoists, material lifts) are used for equipment too heavy or awkward for manual carrying
• Crane lifts, boom lifts, and rigging operations for rooftop equipment replacement are performed by or under the direct supervision of a NYC Licensed Rigger
• All rigging equipment (slings, shackles, hooks, chains) is rated, tagged, and inspected before each lift
• Building structural loading must be confirmed as adequate before staging heavy equipment on roof decks or upper floors

13. Emergency Procedures

All personnel working on a job site must be aware of the following before work begins:

• Emergency contact: Call 911 for any life-threatening injury, fire, or hazardous gas release. Do not delay emergency services to notify management first.
• Building emergency exits: Identify at least two exit routes from the work area before beginning work
• First aid: Each field vehicle is equipped with a first aid kit. Technicians are trained in basic first aid and encouraged to hold current CPR/AED certification
• Refrigerant release: In the event of a large refrigerant release in an enclosed space, evacuate immediately, ventilate if safely possible, and contact emergency services if exposure symptoms are present
• Gas leak: Do not operate any electrical switches. Evacuate the area immediately, close the gas supply valve if safely accessible, and call Consolidated Edison (Con Ed) emergency line and 911
• Fire: Evacuate and call 911. Do not use elevators. Notify building management and the building fire safety director immediately
• Electrical shock: Do not touch the victim if they are still in contact with the energy source. De-energize the circuit from the breaker or disconnect if safely reachable. Call 911 immediately.

After any emergency involving injury, property damage, or significant near-miss, work at the site is suspended until management has reviewed the situation and confirmed it is safe to resume.

14. Incident Reporting

All work-related injuries, illnesses, near-misses, property damage events, and regulatory violations must be reported to the company's designated safety contact within 24 hours of occurrence. Serious injuries or incidents involving hospitalization must be reported immediately by phone.

• All incidents are documented using a standardized incident report form that captures the date, location, personnel involved, description of events, contributing factors, and corrective actions taken
• Near-miss reports are treated with the same seriousness as injury reports — many serious injuries are prevented by identifying near-miss events first
• OSHA 300 Log recordkeeping is maintained in compliance with 29 CFR 1904 requirements
• OSHA-reportable incidents (fatalities, hospitalizations, amputations, or loss of an eye) are reported to OSHA within the required timeframes (8 hours for fatalities, 24 hours for hospitalizations)
• Incident reports are reviewed by management to identify root causes and implement corrective measures to prevent recurrence
• No employee will face retaliation for reporting a safety concern, hazardous condition, near-miss, or injury in good faith

15. Training and Certifications

Competent, well-trained technicians are the foundation of a safe HVAC operation. Commercial HVAC Company maintains the following training and certification standards:

• EPA Section 608 Certification (Universal): Required for all technicians who handle refrigerants
• OSHA 10-Hour Construction Safety: Required for all field technicians; OSHA 30-Hour for supervisors and project managers
• First Aid / CPR / AED: Strongly encouraged for all field personnel; required for at least one person on any multi-person crew
• NYC DOB Site Safety Training (SST): Required for work on NYC construction sites that mandate SST card compliance under Local Law 196
• Confined Space Entry: All personnel who may enter permit-required confined spaces receive formal confined space entry training
• Fall Protection: Technicians who perform rooftop or elevated work receive documented fall protection training consistent with OSHA 1926.503
• Refrigerant Safety: Training on safe handling, leak response, and regulatory compliance for all refrigerant-certified technicians
• LOTO: All field technicians receive documented lockout/tagout training specific to the types of equipment they service

Training records are maintained in each employee's file and are available for client or regulatory review upon request. Certifications are renewed before expiration.

16. NYC Regulatory Compliance

Commercial HVAC work in New York City is subject to an extensive regulatory environment. Our operations comply with applicable requirements from:

• NYC Department of Buildings (DOB): Equipment replacement, new installations, and modifications requiring permits are filed and inspected through DOB. We hold and maintain all required NYC contractor registrations.
• NYC Fire Department (FDNY): Work involving fuel-fired equipment, refrigerant systems above certain charge thresholds, or systems in fire-rated assemblies may require FDNY permits or inspections. We coordinate as required.
• NYC Department of Environmental Protection (DEP): Cooling towers serving commercial buildings in NYC require DEP registration, water treatment plans, and inspection compliance under Local Law 77.
• Local Law 97 (NYC Climate Mobilization Act): We advise clients on HVAC system upgrades that support LL97 compliance for buildings over 25,000 square feet, including electrification pathways, VRF systems, and heat pump retrofits.
• Con Edison and PSEG Long Island: Electrical connections to utility service require proper work notification and compliance with utility interconnection standards where applicable.
• OSHA Federal and NY State PESH: We comply with OSHA federal standards and, where they apply, New York State Public Employee Safety and Health (PESH) program requirements.

17. Subcontractor Safety Requirements

When Commercial HVAC Company engages licensed subcontractors — including electricians, plumbers, riggers, insulation contractors, or other specialty trades — those subcontractors are required to:

• Hold all applicable New York State and NYC licenses and certifications for the work they perform
• Carry general liability insurance and workers' compensation coverage at levels consistent with our project requirements, and provide current certificates of insurance before mobilization
• Comply with all applicable OSHA, NYC DOB, and site-specific safety requirements
• Follow all active LOTO, confined space, and fall protection procedures in place on the job site
• Report any incident, near-miss, or safety concern to the Commercial HVAC Company project supervisor immediately

We reserve the right to remove from the job site any subcontractor personnel who fail to comply with safety requirements, and to terminate subcontract agreements for repeated or serious safety violations.

18. Policy Review and Updates

This Safety Policy is reviewed at least annually by Company leadership, and updated as needed in response to:

• Changes in OSHA, EPA, NYC DOB, or other applicable regulatory standards
• Findings from incident investigations or near-miss reviews
• Changes in the scope of work, service types, or geographic coverage of Company operations
• Feedback from field technicians, supervisors, or client safety teams

The most current version of this Safety Policy is published on this page. All employees, subcontractors, and relevant partners are notified of material updates. Questions about this policy or specific safety procedures should be directed to:

• Email: mail@commercialhvaccompany.com
• Mailing address: Commercial HVAC Company, Queens Village, NY 11428