Supersedes: 1/17 (Rev.16) Preparer: Owner: Approver: EHS Team Member EHS Team Member EHS Manager. Revision Description Revised By Revision Date

Transcription

1 Procedure No.: PA Page: 1 of 28 Port Arthur, TX. Reviewed: 05/18 Effective: 05/18 Preparer: Owner: Approver: EHS Team Member EHS Team Member EHS Manager Document Revision Change Table Revision Number Revision Description Revised By Revision Date Added information with respect to decontamination, 2.5 AFG/TAD 11/16/ Definition AND Section F. Modified step C to include purpose of safety harness on permit when one is required. Modified step 3, Scope, under the heading of this procedure TAD 1/23/ does not apply to, the 3 rd bullet to say a permit is required for certain deliveries and pickups. 11 Modified step 4.1.9, to include cross area permitting for TAD 6/2013 Operations Day Technicians 2.8 Define non-intrusive work DLS 3/ WAL activities defined WAL header includes activities Changed Day Technicians to Production Specialists MD 8/ WAL activities further defined. Added reference to EHS Requirement Occupational Safety MD 01/ and Industrial Hygiene N-R-OSA-001-EN-M per RCMS 002 Advisory Training requirements for Safe Work Permit Issuers DLS 7/20/16 16 Attachment A Latest Safe Work Permit revision DLS 1/ minor activities 2.13 reference to maintenance issued permits 3. maintenance exemptions hazard identification/co-signing by maintenance permit-issuer qualifications 4.2.1,.5 #work crew / vehicle ID rqmnt change 2.13 to reference maintenance issued permits hr. shift scenario for permitting , 21 revalidation / # work crew / vehicle ID requirement change Fall Hazard Assessment / PTP rqmnt Hotwork Gas monitor / Toxic instrument cal requirements Permit authorization requirements 4.4. Record retention / reviews, audits, program review 6.0 Related Documents change for new corps std. Attachment A: Safe Work Permit Form changes Linked Active Work Permit Inspection Tool LP 05/18

2 Procedure No.: PA Page: 2 of PURPOSE To provide safety precautions for work activities on the Port Arthur Site by: Ensuring clear communications about the work to be accomplished. Providing approval from the operating/owning department. Identifying and communicating hazards related to the identified task. Providing protective measures to address the identified hazards. Providing specific communications on lockout/tagout of hazardous energy sources. Determining other permit requirements (Confined Space Permit, Excavation Permit, etc.) are an essential aid to make sure that tasks with special risks can be planned and carried out safely. Because many tasks are performed by workers other than those who operate the plant, clear and formal agreements are necessary. Prior to the start of a particular work activity, a risk assessment or review of the hazards must be carried out. 2. DEFINITIONS 2.1. Contingent Employee A non-basf employee for whom BASF provides supervision of his or her day-today activities and direction as to how an activity is to be performed Contractor/Agency A company which will be either placing or bringing Contractors, Temporary Employees or Contractor Employees onto a BC site 2.3. Contractor Employee A non-basf employee for whom BASF does not provide supervision of his or her day-to-day activities or direction as to how an activity is to be performed. Note: In this procedure, a Contractor also means subcontractor Daily Support Team (DST) The Daily Support Team (DST) is composed of the following positions: General Manager, Ops Director, Operation Managers, Operation Engineers, Operation Coordinators, Production Leaders, Production Specialists, Furnace Mechanic, TES Director, Maintenance Manager, TES Manager, TAR Planning Manager, Reliability Engineer, Cogen/Boiler Specialist, IE Maintenance Coordinator, Mechanical Maintenance Coordinator, High Voltage Engineer, Planning Supervisor, Contractor Coordinator, Analyzer Specialist, IE Engineer, Stationary Equipment Engineer, Maint/Operations Planners, Technology Director, Manager Process Technology, Furnace Engineer, Furnace Specialist, Site Safety Specialist and Site Environmental Specialists.

3 Procedure No.: PA Page: 3 of DEFINITIONS cont d 2.5. Decontamination This is the process of physically removing or neutralizing chemical contaminants from personnel and/or equipment. Proper decontamination will prevent contact of contaminants with personnel and equipment. Contaminated clothing / PPE must be properly bagged, tagged, labeled and disposed of in approved containers Eyes Principle The use of 2 or more individuals reviewing a job or task together in the field to ensure that all hazards are identified and eliminated/controlled through safe work practices, use of PPE, communication/awareness, etc. At a minimum this includes a Permit Issuer and individual(s) conducting the work Hot Work Work involving welding, torch cutting, burning, brazing, grinding or the use of open flames, in areas other than maintenance shops or designated fabrication areas designed and maintained for such work, is considered Hot Work. In addition, the use of any spark producing tool or equipment (jack hammers, grinders, drills, etc.), the use of any non-rated electrical equipment, and Vehicle Access in electrically classified hazardous areas is also considered Hot Work Intrusive Work Work that is performed where hazardous energy sources could be released by the performance of the work or anytime there is potential to affect the sealing surface of live process equipment/components. This includes jobs that involve Control of Hazardous Energy, Line Breaking, Hot Work/Vehicle Entry, and Confined Space Entry Learning Objectives Specific knowledge, skill, or attitudes the training participant is intended to have learned at the conclusion of the training program. As a minimum, the learning objectives will include applicable regulatory training elements Minor Activities Tasks that have very low risk; do not require a 4-eyes field review or a procedure; do not involve protection of hazardous energy sources for the specific work to be done. Examples include: visitor walkthroughs, visual inspections, vehicle entry into non-classified areas, copy machine repair, etc Non-Intrusive Work Work being performed that does not involve Hazardous Energy Control, Line Breaking, Excavation, Critical Lift, High Energy Hot Work or Confined Space Entry.

4 Procedure No.: PA Page: 4 of DEFINITIONS cont d Owning/Operating Department Approval A final field check to confirm the permit requirements are met. The Permit Issuer shall sign the Safe Work Permit upon completing the Owning/Operating Department Approval. Approval indicates: the applicable work on the schedule matches the Safe Work Permit the conditions in the field are safe for the Work Crew to perform their work (i.e., valves did not leak through by checking low point bleeds, verifying bleed valves are not plugged, etc.) all Hazardous Energy Source devices have been physically tested and found to be de-energized (i.e., hit the start button ) no other Hazardous Energy Sources are attached to the equipment to be worked inside the boundaries defined by the tag out; example, all purge hoses and steam hoses used for preparation are disconnected, unless otherwise noted on the permit and/or MIP the MIP and other paperwork are filled out and accurate with all applicable spaces initialed or checked off the immediate area around the equipment to be worked has been checked with the appropriate gas testing equipment for hydrocarbons and/or for toxicity as needed. NOTE: If any of the above requirements are not satisfactory, the permit shall not be signed or issued Owning/Operating Department The BASF unit or department that operates or is responsible for the daily operation of the process, area or facility where work is being conducted. Plant the Cracker or C4 complex Section Hot, Cold, Utilities, BD, InAlk, OCU, OSBL Area Furnaces, Quench, Steam, Raw Water, Charge Gas, Refrig, Pygas/Distillation, BD, InAlk, OCU Reference PA-P-ME-407 in documentum for Maintenance-issued permitsareas of responsibility Permit Acceptor The person who signs the safe work permit that is responsible for doing the work or leading others who will perform the work that required a safe work permit. This person is responsible for transferring job specific information to the work crew.

5 Procedure No.: PA Page: 5 of DEFINITIONS cont d Permit Extension The process used to extend an existing Safe Work Permit up to 2 hours past its indicated end time, using section VIII Permit Issuer Personnel that have been trained, qualified and authorized to issue permits on behalf of the Operating/Owning Department Safe Work Permit (SWP) A form that provides written authorization to perform work that describes tasks, associated hazards, and appropriate control measures Servicing Group Any personnel involved in activities that are outside the scope of routine production or utility operations. The terms Service Group and work crew are used synonymously for the purpose of this procedure Tie-Point Tag An identification tag, pink with black numbers that is placed within one foot of where Hot Work is to take place Re-issuing Means to void the previous permit for work and issue a new permit Revalidation The process of reusing an existing SWP to authorize work by reviewing the work conditions specified on an existing permit, with a Permit Acceptor, to ensure the scope, conditions, and safety precautions listed on existing permit have not changed. Revalidation must include the required signatures and approvals at the time of revalidation WCAF Work Crew Accountability Form A form that is attached to all serving several purposes: The administrative control to account for every individual working in the unit(s) who is not signed in on the Work Authorization Log (WAL) or is an approved member of the Daily Support Team (DST). The administrative control for every individual working behind a hazardous energy isolation. The verification that every individual worker has read and understands the conditions of the permit(s).

6 Procedure No.: PA Page: 6 of DEFINITIONS cont d Work Authorization Log WAL (Attachment B) A sign-in roster located in the control room, for all non-operations personnel (not part of the Daily Support Team) authorizing non-permitted (minor) activities in the operating/process areas of the plant. Non-permitted activities include: plant walks/tours, engineering measurements, verifying P&ID s, sample pick-ups, PSSR s, Bid walks, Audits, LDAR inspections (not any repairs or carbon canister monitoring), entry into analyzer houses by analyzer and PM techs, entry into sub stations and/or RIE buildings by high voltage electricians, or any non-intrusive work in the control room. Additionally, the following activities can be authorized through the WAL in electrically non-classified areas: refueling, insect spraying, vacuum truck for septic and port-a-potties. The Daily Support Team includes the following members: Site Leadership Team, Operation Engineers, Operation Coordinators and Environmental, Health and Safety Specialists Written Operation Procedures Written step by step instructions that describe how to carry out specific tasks. These procedures can be in different forms such as: Task Job Analysis (TJA), Job Safety Analysis (JSA), Standard Operation Procedures (SOP), Work Job Instructions (WJI), etc and must specify safety considerations. 3. SCOPE This procedure applies to the following tasks at the BASF Port Arthur plant site: Non-intrusive and intrusive work by maintenance, contract maintenance or other BASF servicing group in any process area, packaging areas, off-site areas, or laboratories. Non-intrusive and intrusive work by contractors anywhere on the plant site. This procedure does not apply to: Equipment preparation by Owning/Operating Department personnel for servicing and/or maintenance that is done in accordance with a written job procedure. Owning/Operating Department personnel working within their assigned process unit and who are following standard operating procedures for routine activities. Vendors or contractors performing janitorial services, office machine maintenance (i.e., photo-copier, fax, etc.), bottled water service, soft drink and snack machine service, or making deliveries/pickups in areas where a vehicle entry permit is not required (permits will be required if delivery is connected to any process equipment or if the transferring of any type of hazardous chemical takes place from one piece of equipment to another).

7 Procedure No.: PA Page: 7 of SCOPE cont d Routine maintenance work performed by BASF or contract maintenance employees in Maintenance/I&E shops. Routine building maintenance performed by BASF or contract maintenance employees in control room buildings, offices, and administrative buildings (i.e., changing light bulbs or HVAC filters). Work done on third party property (i.e., Entergy, CenterPoint Energy, etc.) Work-site visits by vendors or contractors, walk-throughs, P&ID reviews, or housekeeping/safety inspections. Authorized activities that are permitted to be written on the WAL (Attachment B). Daily Support Team (DST) activities that are permitted by this procedure. BASF maintenance personnel will not require permitting by the owning/operating process department for daily rounds, PM s, troubleshooting, coordination of contractor employees, and hazard identification, but will need to sign on/off the WAL for unit accountability purposes. 4. PROCEDURE 4.1. General Requirements The 4-eyes principle is required for the issuance of a safe work permit. It is acceptable for the Permit Issuer to radio a qualified Permit Issuer who may already be in the field to complete the 4-eyes review along with the person conducting the work. NOTE: The maximum time between job review and start of work shall not exceed 2 hours All information written on the Safe Work Permit shall be printed and legible Permit Acceptor must understand the spoken and written language in which the permit is written A Safe Work Permit shall be issued prior to the initiation of any work activity covered in the scope of this procedure Multiple jobs performed by a single craft can be performed under a single Safe Work Permit as long as ALL of the following apply: The work is non-intrusive with the exception of being under a single MIP; and The jobs are limited to one specific area of the plant, i.e. Refrig, Pygas, Quench, BD, etc.; and

8 Procedure No.: PA Page: 8 of General Requirements cont d cont d Each job included in the single SWP has had the 4-eyes principle applied; and The job hazards are the same for each specific job location within the area (Example: Multiple scaffolds being built in one area of the plant) Multiple crafts used to perform a single job can be under a single Safe Work Permit as long as ALL of the following apply: The work is non-intrusive with the exception of being under a single MIP; and Only one job is being performed on the permit; and The job hazards are the same for each craft performing the work. (Examples: Crane operator and maintenance crew removing a PSV; millwright and electrician removing a pump or motor; main work crew with a supporting work crew) A section wide or plant wide permit can be written under a single Safe Work Permit as long as ALL of the following apply: The same work is being performed in all areas by a single crew; and The work is non-intrusive; and The work hazards and required PPE are the same for each section; and The single permit has to be signed by a qualified permit issuer from each affected area; and The job will take no longer than 15 minutes in each affected area. (Examples: Delivering water coolers, the mosquito truck, vacuuming out the port-o-lets, etc.) A non-intrusive type Safe Work Permit may be issued across plant areas by an Operations Day Technician for project work only. Before this permit is issued, the Operations Day Technician will contact the area Operations Technician to ensure no hazards exist in the area of the work to be permitted.

9 Procedure No.: PA Page: 9 of General Requirements cont d The Owning/Operating Department shall issue. Process unit owning/operating permit issuers should request assistance from maintenance personnel, including project coordinators, to provide information concerning hazard identification and general work details to effectively assess and permit work as needed. Permit countersigning by BASF maintenance will be required when requested by other owning/operating permit issuers to ensure effective communication of hazards and potential consequences to unit operations The Permit Issuer must be trained and successfully complete quizzes and hands on demonstration as qualification for the area being permitted. Operations, TES, Maintenance department supervision determines, through its training program, when a person is qualified and then authorized to issue. Permit-issuing departments will maintain a list of designated, qualified permit-issuers A Safe Work permit or revalidation must be issued by the shift on duty The Safe Work Permit shall be reviewed in its entirety with the Work Crew representative signing the permit The Work Crew representative will then review the Safe Work Permit with the Work Crew members performing the work permitted Each work crew member will then print their name on the Work Crew Accountability Form and initial on and off the job as job assignment dictates If any conditions change that are listed on the permit, then the Permit Acceptor must communicate the changes to the Permit Issuer Once a permit is authorized, the original copy shall remain with the Permit Issuer and the field copy shall be posted at the work site for the duration of the job. All permits must be in duplicate. A. For a single permit issued for multiple jobs or crafts, the permit will be posted at a central location in the job area and all work crew members will know the posted location. B. For permits issued only as Vehicle Entry permits, the field copy must remain on the vehicle that is permitted.

10 Procedure No.: PA Page: 10 of General Requirements cont d cont d C. If Vehicle Entry is a portion of the overall job, the permit may remain at the job site rather than in the vehicle are valid for up to one operations shift. A Safe Work Permit may be extended for 2 hours by the out-going Owning/Operating Department for jobs that are not complete. A. If the work must continue beyond the initial shift, the Permit Acceptor must return the field copy permit to the Owning/Operating Department to be extended by the Permit Issuer. B. The Owning/Operating Department must visit the job site to verify the original conditions of the permits are valid before extension of the Safe Work Permit. Section VIII will be used for extension. C. The Owning/Operating Department will match the Control Room copy with the field copy and obtain signatures and record the time and date of revalidation. D. Based on the Safe Work Permit requirements, an additional LEL and O 2 check may be required. If so, record the LEL and O 2 results in the revalidation section and permit the work to continue. E. All Work Crew members must be informed of the extension. F. Work that will extend beyond 2 hours will require the permit to be reissued or revalidated (unless the issuer and acceptor have not changed; i.e. both working up to a 16-hour shift) Revalidation of will allow work to continue through multiple shifts (using attachment C) under the original Safe Work Permit as long as the following conditions are met: The original SWP revalidation by the oncoming shift takes place within the 2-hour extension period or at the restart of the work if no extension was needed/granted; and The job scope has not changed and the original permit conditions have been verified to still be applicable; and The Permit Acceptor agrees the conditions are acceptable; and

11 Procedure No.: PA Page: 11 of General Requirements cont d cont d The Safe Work Permit Revalidation (Attachment C) form is completed The process for Revalidation is as follows: A. At the beginning of shift or restart of work, the Permit Acceptor and Permit Issuer will review the permitted work allowed by the original SWP and determine the current status of work activity. If the job is determined as not complete and work will need to continue past the extension period, the revalidation process will begin. B. The Permit Acceptor will return the field copy of the Safe Work Permit and the current Revalidation Permit, if applicable, to the Permit Issuer. C. The Permit Issuer will physically verify that all conditions of the original permit are still met and that no new hazards have been introduced on the equipment being worked or in the general area the work is being performed. D. If all conditions are acceptable between the Permit Issuer and the Permit Acceptor, the job/work will be authorized to continue under permit revalidation. All required information on the Revalidation Permit will be filled out, signed and dated by the Permit Issuer and the Permit Acceptor. E. The Permit Acceptor has the responsibility to review the Safe Work Permit and the Safe Work Revalidation Form with the work crew members and have them sign onto the WCAF. F. The original field copy of the SWP and the current copy of the Revalidation Permit will be posted at the job site.

12 Procedure No.: PA Page: 12 of General Requirements cont d Following the completion of the job or the end of the shift, a Work Crew representative must return the Safe Work Permit to the Owning/Operating Department and: A. Match the copies of the permit and mark the permit job completed section as applicable. B. Print name as the permit returnee in the designated section of the permit closeout section If an emergency alarm is sounded or an emergency condition occurs in the unit where the work is being performed, all are considered void, and all work is stopped for evacuation and emergency response. NOTE: Permits are not cancelled for scheduled alarm tests must be re-validated (using section VIII) following an All Clear by the Owning/Operating Department supervision or their designee. Owning/Operating department must authorize entry and 4-eyes the job before permit acceptors are allowed to resume work Completed will be reviewed by the Owning/Operating Department supervision for accuracy and then retained in accordance with 4.4. of this procedure Completing the Sections of the Safe Work Permit Section I - Work Description A. This section is to identify who will be permitted to work and the specific location (area or equipment identification) in the unit or department. B. The description of the work should be detailed and specify the task(s) required to complete the work. C. The Work Company and the Emergency Contact Person shall be identified in this section. D. The Emergency contact number is a Contractor s emergency number. The intent of this phone number is so BASF can contact a representative of the contract company in the event of an incident.

13 Procedure No.: PA Page: 13 of Completing the Sections of the Permit cont d Section I Check All That Apply A. Any task box with an asterisk requires additional permits or associated paper work that must accompany or applies to the Safe Work Permit. B. More than one task box can be selected for a single task. For example, pulling a pump could include marking the Lock Out / Tag Out and Line Breaking boxes. C. General Work should be selected for activities such as, but not limited to; painting, insulating, scaffold erection, pulling wires, etc. where there is no other task type applicable. D. Line Breaking and Lock Out/Tag Out should be selected anytime a task involves isolating an energy source or breaking into process lines. E. Hot Work has three sub-categories for the intention of the Safe Work Permit. When Hot Work is required, the Hot Work box and additional sub-categories will be selected in section IV on the permit as applicable for the task. For Example, a welding job would require the Hot Work box to be checked as well as the Welding/Cutting/Brazing, Vehicle Entry for the welding machine or welding rig, and Low Energy Ignition Source for non-classified electrical tools. F. Unclassified electrical equipment used in classified areas must be marked as Hot Work Low Energy Ignition Source. G. For confined space work, the Confined Space box must be selected on the Safe Work Permit. When a safe Work Permit that is designated as a Confined Space permit, the Safe Work Permit must be attached to the Confined Space permit at the conclusion of the task and retained with the Confined Space permit by the Owning/Operating Department for one year.

14 Procedure No.: PA Page: 14 of Completing the sections of the Safe Work Permit cont d Section I Check All That Apply cont d H. Critical Lift, Excavation, and Hot Tap will be selected when applicable. Those also require additional paperwork that must accompany the Safe Work Permit. I. The Chemical Compliance must be selected when work is related to those specific chemicals Section II - Hazards / Communication A. This section of the permit is to communicate information on the health and physical hazards of chemicals previously contained in the equipment, as well as those used to clean out equipment if applicable. B. Information on the health and physical hazards associated with any chemicals that the acceptor may be using as part of the job tasks. C. The location of applicable Safety Data Sheets is identified. D. Location of safety shower/eyewash and fire extinguishers, and evacuation/rendezvous points are communicated. E. If electrical tools will be used for the task, determine if they are rated for the area where the work will take place. F. If personnel will or may be exposed to process liquid contaminates or residual process vessel cleaning material, the material MUST be analyzed PRIOR to letting personnel working in the contaminated area. If the results of the testing identify contaminates are present, personnel MUST be dressed in the proper PPE and in this section it MUST be noted that decontamination is required. The Shift Supervisor, Maintenance Supervisor and Safety must be notified of the situation and must develop a plan for the work. Personnel MUST be made aware of how PPE and Tools will be decontaminated to prevent exposure to the identified material.

15 Procedure No.: PA Page: 15 of Completing the sections of the Safe Work permit cont d Section II - Hazards / Communication cont d The highest level of potential contamination MUST NOT require more than washing of tools, removal, and then proper disposal of PPE. If before removing PPE washing will be required, then personnel will NOT be allowed to work until the hazard is further washed/cleaned/neutralized and/or removed. G. Indicate that a Fall Hazard Assessment has been conducted during the permitting process and that Potential for dropped objects has been identified and mitigated. H. Indicate that a PTP (Pre-Task Plan) has been written by the permit acceptor. A PTP may be a Job or Task Safety Analysis: a written plan indicating that service personnel have assessed and planned the details of their job tasks for safety Section III Isolation / Lock Out/Tag Out / Owning/Operating Department Approval A. Hazardous energy sources shall be isolated, locked out and/or tagged out and the Owning/Operating Department Approval shall be in accordance with the site s Control of Hazardous Energy procedure (PA ). B. If there are no hazardous energy sources, N/A may be selected and the remainder of this section skipped. C. If applicable, complete this section on the permit and record the MIP number(s) Section IV Hot Work Requirements A. All Hot Work activities shall be in accordance with the site s Hot Work procedure (PA ). B. Hot Work may not be permitted if the fire protection system is inoperable without EHS approval. If there is no fire protection system where the Hot Work is to take place, select N/A.

16 Procedure No.: PA Page: 16 of Completing the sections of the Safe Work permit cont d Section IV Hot Work Requirements cont d C. Record name of LEL attendant(s) for Low Energy and Vehicle Entry hotwork permits; Record name of Fire Guard(s) (Fire Watch) for High Energy hotwork permits. D. All Hot Work on process equipment/piping requires a Tie-Point Tag. Record the Tie-Point Tag number in section IV on the Safe Work Permit. E. Select the appropriate fire protection measures for the Hot Work. Selecting more than one measure is permitted based on the amount of protection necessary. F. Vehicle Entry shall be marked any time motorized equipment is required to be operated in a process area; vehicle type and location/route must be completed. More than one vehicle or mobile equipment may be permitted on one Safe Work Permit as long as all of the equipment is identified on the permit and will travel and stay in the same work location. G. See section Section VII Approvals: for authorization by signature requirements Section V Combustible / LEL Information A. Based on the site s Hot Work procedure, designate if monitoring is to be continuous or periodic and select the appropriate option on the Safe Work Permit. B. All columns of the table are required to be completed by the technician conducting the atmospheric testing. C. Identify gas monitor used by recording ID#, that it has been bumptested on shift of use, and calibration date / by whom any time a gas meter is used in issuing a permit, including hotwork or linebreaks.

17 Procedure No.: PA Page: 17 of Completing the sections of the Safe Work permit cont d Section V Combustible / LEL Information cont d D. Reference PA (butadiene compliance) & PA (benzene compliance). Record PID ID# and calibration date / by whom any time a meter is used to issue a permit Section VI Work Environment and Personal Protective Equipment A. Some tasks require standby personnel. If applicable, identify if BASF or the Work Crew will provide this requirement. B. If purging or ventilation is required, specify the type of ventilation requirements necessary for the work. C. Standard PPE includes a hard hat, safety glasses and protected toe footwear. This section is to identify additional PPE requirements. Based on site PPE grids, select the appropriate PPE and ensure the work crew understands the required PPE. If a safety harness is required, its purpose being retrieval or fall protection must be annotated on the permit. D. If barricades are required, select the type of barricade required for the task Section VII Approvals A. The Safe Work Permit is not valid until both the Owning/Operating Department and a Work Crew Representative sign the permit. General Work permits may be authorized by anyone trained and qualified for the area being permitted. Low Energy Ignition Source (including vehicle entry) Hot Work permits may be authorized by anyone trained and qualified for the area being permitted; authorization by signature in section IV - Operations approval-low Energy in section IV. Confined Space permits require an additional permit and authorization by signature of the Shift Supervisor.

18 Procedure No.: PA Page: 18 of Completing the sections of the Safe Work Permit cont d Section VII Approvals cont d High Energy Hot Work (welding, grinding, spark-producing) require authorization by signature in section IV of a top-level outside or higher process technician (as determined by Production Leaders and/or Shift Supervisor). B. The Owning/Operating Department approval indicates that the permit is accurate and the precautions are safe for work to proceed. C. The Work Crew Representative may be the foreman or crew leader. Nevertheless, this person s approval indicates they are aware of all requirements of the permit and will pass on this information to all members of the Work Crew prior to starting work. D. All Work Crew Members shall print their name on the WCAF and initial on and off as job status dictates Section VIII Revalidation after Plant Upset/Emergency or Extension A. must be revalidated after a plant upset or emergency condition cancelled the permit. The permit acceptor must return the field copy of the permit to the Owning/Operating Department. The Owning/Operating Department must visit the job site to verify the original conditions of the permits are valid before revalidating the Safe Work Permit. The Owning/Operating Department will match the Control room copy with the field copy and obtain signatures and record the time and date of revalidation. Based on the Safe Work Permit requirements, an additional LEL and O 2 check may be required. If so, record the LEL and O 2 results in the revalidation section and permit the work to continue.

19 Procedure No.: PA Page: 19 of 28 B. For SWP extensions, follow steps , A through F. 4.2 Completing the sections of the Safe Work Permit cont d Section IX Closeout A. The permit acceptor must get each individual worker to initial off the WCAF and then sign and return the Safe Work Permit(s) at the end of the day/shift or when the work is completed. B. The Owning/Operating Department shall verify all individual workers have initialed off the WCAF and then complete the Closeout section on the permit by: Identifying job status; Recording if the area is cleaned, if locks/tags are removed and that the affected personnel are notified. C. Any qualified member of the Owning/Operating Department may accept the permit from the Work Crew representative. Record the time and sign the permit Contractor Employee Safety Orientation Contractor Employees must attend an EHS orientation before being allowed to conduct work on BASF property. The Port Arthur site uses the local Industrial Safety Training Council (ISTC) to conduct and evaluate knowledge competence of the required site specific EHS training; the site s Safe Work permitting process is included in this training. All contractors requesting site access to perform on-site work activities must complete this training/orientation before receiving a Port Arthur Contractor gate access badge Recordkeeping and Inspection program All, along with their associated revalidation forms, if applicable, MIP s, excavation permits, etc., issued to a Work Crew shall be filed for no more than one year, and may be destroyed after 30 days, providing that (1) Review/critique and (2) Field audit results (including corrective measures) are retained until the Annual Program Review is completed If a Confined Space Permits is issued, the Owning/Operating Department must retain the associated Safe Work Permit with the Confined Space Permit.

20 Procedure No.: PA Page: 20 of Recordkeeping and Inspection Program cont d The Safe Work Program (Annual Program Review) shall be reviewed at least annually to ensure that the management system is properly implemented and the elements adequately control the covered activities. As a minimum, the following elements shall be included in the review: Ensure alignment of the site/unit procedure to the corporate procedure requirements. Review incident reports involving safe work permitting issues. Review/critique and Field audit findings from the previous year. Interviews with Permit Issuers, persons performing work and other affected employees including Contractor Employee(s) where applicable, to ensure they understand their roles and responsibilities. Document the annual review and retain it for 3 years. Review/critique: frequent inspection of permits for quality and consistency; performed by operations supervision or designee(s) Field audits are to be conducted monthly, reviewing work in progress, and must check to ensure that: Hazards have been identified Control measures are adequate and still in place Workers have been informed of hazards and control measures Permit documentation is in order involved in incidents must be retained and electronically added to the incident report. A field audit conducted in accordance with the requirements of Control of Hazardous Energy Sources can be used to help meet the requirements of periodic inspections under N-ID-OSA 014 / PA : Control of Hazardous Energy Sources. Document and keep field audits for the annual review. See Attachment: Active Work Permit Inspection Tool for additional help with conducting field audits.

21 Procedure No.: PA Page: 21 of Recordkeeping and Inspection Program cont d Training BASF and Contract Employees Involved in Safe Work Activities Permit Issuers and personnel performing Service/Maintenance Work shall receive training on how to recognize the applicability of situations that require a Safe Work Permit and the requirements for issuing a permit. Permit Issuers shall be trained on the applicable safety and health practices and be able to prescribe the necessary means to safeguard against the hazards posed during Service/Maintenance Work. The operating/owning department manager designates in writing qualified and responsible personnel who are authorized to issue safe work permits on their behalf for work performed in their respective unit/department(s). Communicate/post to all department personnel. Training shall be completed at the times specified according to the EHS curriculum assignment process. Retraining of employees is required whenever: Deviations or inadequacies of an applicable procedure indicate that lack of knowledge is a cause. Equipment or procedures have been added or revised Personnel not directly involved in Service/Maintenance work will receive awareness training for this and other safe work practices in accordance with the EHS curriculum assignment process Training Documentation for BASF and Contract Employees Document training including each of the following: trainee s name, date(s) of attendance, means used to verify understanding, learning objective(s) for the course. Maintain documentation according to BC037: Records Management Policy and the applicable record retention schedule Work Authorization Log WAL (Attachment B) The WAL is a roster for all non-operations personnel performing non-permitted activities in the operating/processing areas of the Port Arthur Site.

22 Procedure No.: PA Page: 22 of 28 The WAL is located in the control room. All information must be printed and legible. 4.5 Work Authorization Log WAL (Attachment B) cont d All personnel not listed as part of the Daily Operations Team or the Daily Support Team will be required to sign in prior to going into the operating areas to perform non-permitted work. Sign in on the WAL allows access to all operating areas of the facility. BASF Authorization must be a member of the Owning/Operating Department. Personnel signed in shall sign out when work is completed, prior to leaving the operating areas. If an emergency occurs, personnel must get authorization from Owning/Operating Department to return to work Daily Support Team (DST) Members of the Daily Support Team (DST), listed in the Definitions section of this procedure, can enter the plant without a permit or using the Work Authorization Log (WAL) to perform visual inspections, audits or to follow field work. The access control protocol is that the DST members will make verbal contact with a member of the On-Shift Operations Team and swipe in/out on the card readers located at the Northeast corner of the control room upon entering and leaving the plant boundary limits. Under no circumstances will physical work be performed without the proper work permits. 5. RESPONSIBILITIES 5.1. Daily Support Team (DST) Have primary responsibilities to obtain verbal confirmation from the On-Shift Operations Team and to swipe in/out on the card readers located at the Northeast corner of the control room upon entering and leaving the plant boundary limits Site Leadership Team Has primary responsibility for the implementation of this procedure Environmental, Health, and Safety Manager Has primary responsibility for the initiation, re-issuance, administration, and/or interpretation of this procedure.

23 Procedure No.: PA Page: 23 of Site Employees and Contractors Have primary responsibilities for adherence to the procedure including the identification of deficiencies in the procedure, and identifying, reporting and correcting activities not in compliance with this procedure RELATED DOCUMENTS Attachment A Safe Work Permit Form Attachment B Work Authorization Log Attachment C Safe Work Revalidation Form Active Work Permit Inspection Tool Port Arthur EHS Procedure PA Control of Hazardous Energy PA Hot Work Permits PA Confined Space Entry PA Line Breaking PA Hot Tap PA Respiratory Protection PA Personal Protective Equipment Requirement: G-R-OSA 001 Occupational Safety N-ID-OSA 024 Safe Work

24 PA Effective 04/2018 Work Permit Attachment A Approved by: EHS Manager

25 PA Work Permit Attachment A Effective 04/2018 Approved by: EHS Manager

26 PA Safe Work Permit Attachment B WORK AUTHORIZATION LOG Activities include which can be authorized by this are limited to: plant walks/tours, engineering measurements, verifying P&ID s, sample pick-ups, PSSR s, Bid walks, Audits, and LDAR inspections (not any repairs or carbon canister monitoring), entry into analyzer houses by analyzer and PM techs, entry into sub stations and/or RIE buildings by high voltage electricians, or any non-intrusive work in the control room. Additionally the following activities can be authorized through the WAL in electrically non-classified areas: refueling, insect spraying, vacuum truck for septic and port-a-potties. DATE: All information must be printed and legible Name Company Job Description BASF Authorization Time In Time Out Emergency Contact # Note: Hazard communication and emergency information must be given when necessary. Effective: 08/2015 Approved by: EHS Manager

27 PA Safe Work Permit Attachment C PERMIT REVALIDATION FORM Safe Work Revalidation Hot Work Revalidation Confined Space Revalidation Permit may be revalidated at the beginning of each shift. To re-validate an existing permit, the Permit Issuer will verify that all conditions on the permit are still applicable. If all conditions are acceptable between the Permit Issuer and the Permit Acceptor the job/work will be authorized under permit revalidation. The Permit Acceptor has the responsibility to review the Permit with the crew and ensure all conditions are followed throughout the work/job activity. Original Permit # Date/Time From: To: Check box if permitted work activity requires hazardous energy isolation. MIP# Benzene Atmospheric Testing: Meter Number: Calibration Date: Butadiene Atmospheric Testing: Meter Number: Calibration Date: LEL Atmospheric Testing: Meter Number: Calibration Date: Fire Watch: Vehicle Type: Vehicle ID: Time LEL % O2 % Benzene PPM Butadiene PPM Other Toxic Technician Initials Confined Space Approval (Shift Coordinator): High Energy Hot Work Approver: I have inspected each requirement on this permit and have determined conditions to be safe for the execution of the designated work. Owner Approval: As Work Crew Representative, I agree the conditions to be safe for the permitted work and understand my responsibility to inform others of the information on this permit. Work Crew Rep: (print name) (print name) Effective: 03/2015 Approved by: EHS Manager

28 WORK CREW MEMBERS (Print full name) On Off On Off On Off Before any Isolation Tag(s) or lock(s) can be removed from equipment, the Owner/Operator shall ensure all Service personnel on this permit are signed (initial) off. If not, the equipment Owner/Operator must follow the requirements of PA Control of Hazardous Energy procedure for Tag/Lock removal. Crew Leader or permit acceptor is accountable for: a. Reviewing all the requirements of this permit with each member of the service work group b. Posting permit at job site c. Returning completed permit field copy back to originator. Worker is accountable for: a. Reading and understanding the requirements of this permit b. Recording their job status as on or off the job Effective 04/2018 Approved by: EHS Manager