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August 25, 2019 Attn: Maureen Rischitelli - CFO Hawthorne Assisted Living 100 Hawthorne Blvd Leesburg, FL 34748-8639 RE: Site Safety Inspection date August 6, 2019

Dear Maureen, Thank you and all participating managers in their respective departments for assisting with the inspection. The following recommendations have been compiled in efforts to improve employee health and safety in the workplace and the overall safety of the tenants that live at Hawthorne. During inspection there were several unsafe conditions and regulatory non-compliant observations noted for your immediate attention. The boat marina and the maintenance shop being two primary areas for immediate attention. *Upon completion please submit electrician’s safety inspection report along with repairs and upgrade documentation to Debra Coad – Sr. Account Manager, BKS Partners Additionally, you will find recommendations for making repairs from a general and property liability perspective. I hope you find this information helpful implementing safety initiatives for each department. Should you have questions, feel free to contact me. I am here for you! Thank you, “Safety” Cindy McClellan, Sr. Risk Mitigation Manager cindy.mcclellan@bks-partners.com Cell# (239)872-2129

Disclaimer - Baldwin Krystyn Sherman assists employers in evaluating workplace safety exposures. Surveys and related services may not reveal every hazard, exposure and/or violation of safety practices at the workplace. Inspection and consultations by Baldwin Krystyn Sherman do not result in any warranty that the workplace, operations, machinery, appliances or equipment are safe or in compliance with applicable regulations. Any recommendations and related services are not and should not be

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construed as legal advice or be used as a substitute for legal advice. Employee protection is ultimately the responsibility of the employer.

Cc: Chris Johnson, General Manager, Hawthorne Debra Coad – Sr. Account Manager, BKS Partners Bill Taulbee –– Advisor, BKS Partners Pat Kerby – Risk Director, BKS Partners

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Maintenance Area

Housekeeping Violations Shop floor has excessive unsafe work conditions. (slip, trip and fall hazards) Organize shop with ergonomic work benches, chemical cabinets and shelving for efficient workflow. Conduct pushing, pulling and lifting safety training. 29 CFR1915.81 https://www.osha.gov/laws-regs/regulations/standardnumber/1915/1915.81

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Electrical hazard - shop fan has exposed wiring. Tag out of service.

Maintenance shop exposures – Loss control systems are needed in the shop to eliminate hazards. Clean (degrease), organize and inventory maintenance shop to eliminate unsafe work exposures and cost efficiency. 11 tips for effective workplace housekeeping https://www.safetyandhealthmagazine.com/articles/12470-tips-for-effective-workplace-housekeeping?page=2&sf55549587=1

Top 10 most common OSHA safety violations

1. personal protective equipment (PPE) 2. electrical hazards 3. machine guarding 4. hazard communication 5. flexible, extension cords 6. fall protection 7. lockout and tagout on energized equipment 8. a blocked or obstructed portable fire extinguisher 9. welding and compressed gasses 10. documented training records.

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Shop Mezzanine level

Fire escape obstruction - Fire code violation and hazardous condition from items being stored on the steps. A 5gal bucket of flammable oil is stored under the stairs. Refrain from using storage under stairs per NFPA code.

Clear mezzanine level free of combustible dust and oil saturated on the floor. Clean and organize using shelving to prevent slip, trips and fall hazards.

Refrain from storing flammables on the mezzanine level.

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Chemical Storage building

Emergency eyewash safety shower violation - The emergency eyewash safety shower is obstructed from use. The safety shower should be inspected monthly to ensure safe operation per regulatory standards. https://www.ishn.com/articles/104523-the-12-most-common-causes-of-emergency-eyewash-shower-noncompliance

Properly dispose chemicals no longer used that are stored in the chemical building.

Chemical bldg. - The exhaust fan is not operable. Proper exhaust ventilation is required to minimize high level chemical off gassing exposures from excessive heat when entering the building.

Chemical bldg. – Store personal protective equipment, PPE respiratory protection, chemical gloves and eye protection away from chemical contaminants. Conduct PPE chemical use training.

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Chemical storage building – Clean, organize and inventory chemicals in use. Properly dispose of old chemicals no longer in use. Ensure employee’s exposed to chemicals receive Hazard Communication standard (29 CFR 1910.1200) training with signature of acknowledgment obtained. Conduct annual refresher thereafter, and when employees are exposed to a new chemical. Follow manufacture requirements for all personal protective equipment, PPE and respiratory protection requirements. On a good note the chemicals access is key controlled.

Fuel Tank

Move recycling to Universal waste collection area

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Clean, and prep tank to paint with rust inhibitor. Re-label tank and conduct monthly inspections as required by EPA permit requirements.

Replace weather cracked hoses.

The secondary protective berm is inadequate to contain a spill from the tank.

Refrain from storing flammables around the fuel tank. Put a protective cover over the fire extinguisher.

Fuel tank storage - Clean, and prep tank to paint with rust inhibitor. Re-label tank and conduct monthly inspections as required by EPA permit requirements. Refrain from storing items inside and outside fuel storage containment area.

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Maintenance bone yard area

Environmental Health & Safety violations and loss exposures – Clean, organize and inventory assets and properly dispose of non-assets. Refrain from storing chemicals outside of buildings to prevent chemicals leaching into the ground water and adjacent retention areas. Develop a chemical (oils and paints) and scrap material waste removal system. Include a systematic schedule to remove all waste at a minimum quarterly basis. Fill in uneven surfaces preventing trip and fall injuries and landscape area post clean up. Additionally, yard waste has flying projectile potential during hurricane season causing unnecessary damages to nearby properties.

Remove wood pallets, stone pile, and misc debris. Empty dumpster for use. Fill in uneven surfaces and landscape area. Store equipment out of the weather. Install hose reels to prevent trip and fall hazards and maintain a neat appearance.

PVC pipe stored on top of the shed

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Shop – Waste Oil Management System

Used Oil is stored outside the building overhang subject to adverse weather conditions and spills to the storm water drain adjacent to the shop. It is recommended that a formal used oil assessment be conducted to develop Best Management Practices, BMP’s in accordance with EPA guidelines. Develop a plan to minimize used oil storage by scheduling a routine pick up program. Provide employee training and develop procedures for cleaning oil spills immediately preventing slips and falls and housekeeping issues. Additionally, include employee materials handling, back injury prevention and personal protective equipment, PPE training. Relocate all flammable oils to a single use building with secondary containment and spill response kits. Develop a designated area with written smoking policy.

PART 279—STANDARDS FOR THE MANAGEMENT OF USED OIL https://www.ecfr.gov/cgi-bin/text-idx?SID=c359ffd33144647ce4c1842d68ee6acf&mc=true&node=se40.29.279_122&rgn=div8

Ashtray receptacle by the oil tank

Install hose reels to prevent trip and falls.

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Poor housekeeping practices. Degrease and implement spill prevention controls and procedures.

OSHA violation and unsafe work practice to lift employees in the man basket without proper PPE and fall restraint training. Single operator lifts are designed for one operator reducing human error risk.

Examples of single operator boom lift designed to elevate people is highly recommended.

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Install brace supports under the AC unit Rust inside electrical panel shows signs of water

intrusion

Universal Waste Management

https://www.epa.gov/hw/universal-waste

Fluorescent bulbs in maintenance shop

Universal Waste Management – Fluorescent bulbs were observed in the shop and in the sales office. Recycled cans are stored in the behind the fuel tank. Determine a designated area for universal waste to be accumulated in a safe manner for scheduled disposal. See link for more info - EPA requirements for safe management practices and properly disposal of batteries, pesticides, mercury-containing equipment and florescent lamps. https://www.epa.gov/hw/universal-waste

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Boat Marina Electrical Violations and unsafe conditions

Electrical cord is damaged and repaired with tape

Light gauge extension cord running under the dock

Unapproved shore power connects – unsafe and non-compliant cords running under dock

End of electrical cord is burnt into

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Unsafe walkway conditions from algae mold growth -The walkway deck not under shelter is weather damaged accumulating standing water resulting in tenant slip and fall hazards.

Unsafe condition from roof leaking rain water

Life saving device is damaged

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Unsafe condition Slip and fall hazard -Standing water accumulates in front of the gangway entrance to the interior of the marina.

Unsafe condition -Rust and jagged edges of the metal table mount has potential of causing a foot injury

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Utilities

The desk work area is located inside the pump room. Noise dosimetry testing data should be collected to verify if a hearing conservation program is needed to protect employees hearing from long term accumulative noise injury.

Unsafe condition - The emergency eyewash and safety shower is obstructed by an uncoiled water hose – trip & fall hazard. Conduct documented inspection of the shower monthly per regulatory requirements. See link for more info. Emergency Shower and Eye Wash Station Requirements https://www.grainger.com/content/qt-emergency-shower-eye-wash-stn-req-120

Chlorine distribution room

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Cummins Onan Diesel Generator 100kw– prep and paint exterior.

Diesel tank preventive maintenance -Rain water accumulates around the tank causing damage. Prep and paint tank with rust inhibitor and label.

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Remove damaged service cables no longer in use. Paint bollard safety yellow.

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Base of the tower… TRI-CO Communications services the tower. Currently employee James, is climbing the tower to conduct inspection of loose bolts and wiring. It is recommended that inspecting the tower is added to the service agreement to transfer risk to an experienced properly trained technician.

Top half of the tower…

Communications tower - TRI-CO Communications services the tower. Currently employee James is climbing the tower to conduct inspections. OSHA has specific training requirements for tower climbers, written safety plan, Job Hazard Analysis, JHA, emergency action plan, and fall protection 100 percent tie-off level training annually. It is recommended that inspecting the tower is added to the service agreement to transfer risk to an experienced properly trained technician. https://www.fcc.gov/document/fcc-osha-tower-climber-safety-guide

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Identify the Hydro pneumatic tank with a label

Repair holes in vinyl siding. The wood around the window shows signs of water damage around the window

Protective cover is missing on the electrical receptacle in the IT room

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Fire Station

The handrail is not firmly secured to the sidewalk

Fire hazard -Cigerette butts are littering the ground between the fire statiosn and the marina. Establish controls for managing a designated smoking area.

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Water leak around ice machine

Slip and fall hazard around the ice machine

Water accumulating from the downspout is causing a slip and fall hazardous condition entering the storage room

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Electrical – install electrical receptacles with GFI and eliminate the permanent use of surge protector

Respiratory exposure – have ducts cleaned

Code violaiton -Electrical panel is obstructed Code violation – blanks are missing from the

breaker that has been removed

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The safety handrail is too low and does not have a midrail OSHA Railing requirements for standard Railing (noted as “Guard” in building codes): 42 inch minimum height. Required if 48 inches or greater drop from walking surface — top rail, intermediate rail and posts. Intermediate rail at “about halfway up” or 21”

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Administration building

Unsafe condition- Not pictured-the exit steps from the General Managers office does not have a landing.

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Designated smoking area away from the building Place watertight protective cover over receptacle

to prevent building water damage

Sales Office

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Exit doors -Keep both doors clear of obstruction for emergency’s

Install electrical receptacle to service area

Chemical exposure -properly store all chemicals out of the office area

Paint

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Unsafe condition -relocate bulbs to the universal waste collection site

Code violation – obstructing an exit with a waste can

Trip and fall hazard – items are obstructing path

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Exterior of the Sales office

Wasp nest Water damage to the exterior door and wall

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Clubhouse

Respiratory exposure - Mold & bacteria exposure/electrical issue - Ceiling tiles are stained from obvious leaks

Mold in the walls There is water in the ceiling light cover

exposed to an electrical source.

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Clubhouse Storage facility

Genie Lift and pallet jack – Conduct documented lift and materials handling safety training for all users.

Gym – cords trip and fall hazards. Chemicals in bottles are not labeled

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Slip & Fall Hazard – algae build up. Recommend either rerouting the downspout underground to the drain and/or installing a guard rail to prevent access to this area from the sidewalk.

Post signage DO NOT FEED Alligators! Monitor area frequently and have animal control relocate if need be

Handrail

alligator