Idle Time: Small Habits, Big Impact

Purpose Keeley Construction is committed to improving safety, sustainability, and operational efficiency across all projects and facilities. The Closed Loop PPE Recycling Program provides a structured process to collect, clean, inspect, and reuse certain PPE items rather than immediately disposing of them. Through this program, PPE items are collected, transported to a recycling partner, laundered, inspected for quality, and returned for reuse when appropriate. The goal is to reduce waste, extend the life of PPE, and support Keeley’s sustainability initiatives. The program supplements existing PPE purchasing practices and does not replace the need to maintain adequate PPE inventory on site. Scope This policy applies to: Keeley Construction offices and job sites participating in the PPE recycling program Team members and supervisors responsible for PPE usage Safety and operations personnel overseeing jobsite compliance Facilities participating in PPE collection and distribution The program currently includes PPE types such as: High impact gloves Dipped gloves Insulated gloves Leather gloves Safety vests These items are collected, sorted, cleaned, inspected, and paired for reuse when possible. Program Overview The PPE recycling process consists of three primary steps: 1. Collection Used PPE is deposited into designated 55-gallon collection drums located at approved facilities or job sites. These drums are labeled and provided as part of the recycling program. Only approved PPE items may be placed in these containers. 2. Processing and Laundering Collected PPE is transported to the recycling partner’s facility where items are: Sorted and evaluated Laundered and sanitized according to manufacturer guidelines Metal detected and inspected for quality control Items that meet safety and quality standards are prepared for redistribution. Items that fail inspection are removed and documented as scrap. 3. Return and Reporting Clean PPE is returned to Keeley facilities along with processing reports documenting: PPE items recovered Scrap quantities Sustainability metrics These reports help track waste reduction and provide visibility into PPE lifecycle management. Safety and Compliance Requirements To maintain compliance with the recycling service agreement: Only non-hazardous PPE may be placed in collection containers. PPE contaminated with hazardous materials, regulated chemicals, or biohazards is strictly prohibited. Any excluded materials remain the responsibility of the facility generating the waste. Team members must follow all OSHA and company safety procedures when handling used PPE. Site Responsibilities Each participating site is responsible for: Maintaining proper PPE inventory levels Ensuring only approved items enter recycling containers Keeping collection areas organized and accessible Coordinating collection schedules with the recycling provider Supporting program tracking and reporting This program is intended to reduce PPE replacement costs and waste, but it does not eliminate the need to purchase new PPE when items are damaged or unsafe. Sustainability Impact By participating in the PPE recycling program, Keeley facilities can: Reduce PPE waste sent to landfills Extending the lifespan of PPE equipment Support broader sustainability and environmental goals The program supports responsible resource management and contributes to waste reduction initiatives across operations.

1.0 – Definition 2.0 – Policy 2.1 – Time & Material Projects 2.2 – Lump Sum Projects 3.0 – Mailing Instructions and Address Information 1.0 – Definitions Any surplus construction materials or structural components that are deemed to be scrap, that can be collected and taken to a recycling facility for compensation. Any used and or removed construction materials or structural components that are taken out during demolition that can be collected and taken to a recycling facility for compensation. 2.0 – Policy It is the general policy of Keeley to act with honesty and integrity when accounting for surplus and scrap materials. At no time shall materials be willfully and purposely recycled. Scrap materials are the property of the client or the company and should be treated as such. 2.1 – Time & Material Projects On a Time & Material (T&M) project the client owns all scrap materials when the materials have been originally purchased by them. In this case it is the client’s sole responsibility to collect (or provide a collection receptacle), transport, and collect any applicable compensation. Should the Client turn the scrap materials over to Keeley a written notice of this action is required before taking ownership of the materials. In this case, please refer to section 2.2. 2.2 – Lump Sum Projects On a lump sum project where the original construction materials are purchased by the company, Keeley owns all of the scrap materials that may arise. In this case care shall be taken to collect all scrap materials throughout the construction process. The items shall then be transported to a recycling facility that will pay out the compensation in form of a check. This check shall be made payable to Keeley Construction. This check shall then be promptly mailed to the Ewing Keeley office. 3.0 – Mailing Instructions Please send the scrap compensation checks in the US Mail or via UPS to the following address. After mailing the check please follow up with an email to jridler@keeleyconstruction.com with any tracking information and to let him know to be on the lookout. Keeley Construction Attn: Josh Ridler 500 S Ewing Ave Unit G St. Louis, MO 63103