Elevated Walking/Working Surfaces (Fall Protection) Supersedes: 10/12 (Rev.04) Preparer: Owner: Approver: EHS Team Member EHS Team Member EHS Manager

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1 Procedure No.: PA Page: 1 of 31 Preparer: Owner: Approver: EHS Team Member EHS Team Member EHS Manager Document Revision Change Table Revision Number Revision Description Revised By Revision Date 02 Changed Header and Footer VB 05/08 03 Added Hagemeyer Store Technician Responsibilities TF 10/ Added approved tie off point to Attachment A AFG 10/11 Reviewed No changes TD 01/12 Modified title, added definition steps 2.5, 2.9, 2.10, 2.11, 2.14, TD 10/ , 2.20, 2.21, 2.23, 2.25, 2.26, and Added exemption under SCOPE, added/modified steps 4.1, 4.2, A, E, F, G, H, I, 4.2.2, 4.2.3, 4.3.2, 4.3.4, 4.3.5, 4.3.6, 4.3.7, 4.3.8, 4.3.9, , , , , 4.5.3, 4.6, 4.7, 4.7.1, 4.7.2, and attachments. Reviewed. No Changes TF 07/14 Updated to Corporate Fall Protection Requirements and Advisory 244. Sections: 2. - Definitions 4.1 WWS General Requirements Fall Hazard Assessment 4.3 Duty to Provide Fall Protection 4.4/5 Guardrails/Handrails/Stair rails 4.6 Fixed ladders/portable ladders/mobile ladders & platforms DLS / LP 08/ /8 Roof Work 4.10 Scaffolds 4.11 Steel construction work 4.12 Rig-hoisted platforms 4.13 Powered platforms 4.14 Holes in WWS 4.15 Repair of elevated WWS 4.17 PFA s & Suspension Trauma 4.18 Training

2 Procedure No.: PA Page: 2 of PURPOSE The purpose of this document is to establish minimum work practices and requirements that protect workers from falls and other related hazards associated with elevated work for BASF Corporation (BC) personnel, Contractor Employees, and Contracted Employees at the Port Arthur facility. 2. DEFINITIONS 2.1. Aerial Lift A power platform (JLG, Scissor Lift, etc.) or a vehicle mounted work platform used to elevate personnel to above ground work locations articulating boom platforms, vertical towers, and extension boom platforms Anchorage Point A secure point of attachment for lifelines, lanyards, or deceleration devices Body Belt A strap with a means both for securing it about the waist, and for attaching it to a lanyard, lifeline, or deceleration device. Body belts are not to be used as a part of fall restraint system Body Harness A fall restraint device component consisting of a harness system designed to spread shock load over the shoulders, thighs and seat area Cage An enclosure mounted on the side rails of a fixed ladder or fastened to a structure behind the fixed ladder that is designed to surround the climbing space of the ladder. A cage is also called a cage guard or basket guard Certified Anchorage Points Certified Anchorage Points capable of supporting a safety factor of 2 shall be designed and installed under the supervision of a Qualified Person. For the purposes of procedure, a Qualified Person is a licensed professional (civil and or structural) engineer in the state of Texas.

3 Procedure No.: PA Page: 3 of DEFINITIONS cont d 2.7. Competent Person One who is capable of identifying existing and predictable hazards in the surroundings or work conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them. Duties requiring a Competent Person for Fall Protection include: Documented, periodic, inspections of Fall Protection Equipment shall be by a competent person at the frequency specified by the manufacturer, or not to exceed twelve (12) months Provide hands-on Training for Fall Protection Provide Equipment Use Procedures 2.8. Connectors A device used to couple (connect) parts of the fall protection system together (e.g., lanyard, SRL, vertical lifeline) 2.9. Controlled Access Zones Those areas that are barricaded to: protect people from falling objects, to protect people from getting too close to leading edge work. The barricade shall be erected not less than 6 feet nor more than 25 feet from those areas Dangerous Equipment Equipment (machinery, electrical equipment, etc.), that as a result of form or function, may be hazardous to employees who fall onto or into such equipment Designated Area A distinct portion of a warning line in which people may perform work without additional fall protection Fall Hazard Any condition on a walking-working surface that exposes a person to a risk of harm from falling on the same level or to a lower level.

4 Procedure No.: PA Page: 4 of DEFINITIONS cont d Fall Protection System A system used to protect an employee from fall hazards. Such systems include guardrail systems, safety net systems, personal fall arrest systems, positioning device systems, warning line systems, controlled access zones, safety monitoring systems and covers Fixed Ladder A ladder with rails or individual rungs that is permanently attached to a structure, building, or equipment Floor Hole An opening measuring less than 12 inches but more than 1 inch in its least dimension, in any floor, platform, pavement, or yard through which materials but not persons may fall Floor Openings An opening measuring 12 inches or more in its least dimension, in any floor, platform, pavement, or yard through which a person may fall Grab Bar An individual horizontal or vertical handhold installed to provide access above the height of a ladder Guardrail System Barrier erected along an unprotected or exposed side, edge, or other walking-working surface to prevent personnel from falling to lower levels Handrail A rail used to provide employees with a handhold for support Hoist area Any elevated access opening to a walking-working surface through which equipment or materials are loaded or received Hole A gap or open space in a floor, roof, horizontal walking-working surface, or similar surface that is at least two (2) inches (5 cm) in its least dimension.

5 Procedure No.: PA Page: 5 of DEFINITIONS cont d Ladder safety system A system designed to eliminate or reduce the possibility of falling from a ladder. A ladder safety system usually consists of a carrier, safety sleeve, lanyard, connector, and a body harness. Cages and wells are not ladder safety systems Lanyard A fall restraint device component consisting of a flexible line that secures the wearer of a harness to a vertical or horizontal lifeline or a fixed anchorage Leading Edge The edge of a floor, roof or form work for a floor or other walking/working surface, (such as the deck) which changes location as additional floor, roof, decking or form work sections are placed, formed or constructed. A leading edge is considered to be an "unprotected side and edge" during periods when it is not actively and continuously under construction Lifeline A component consisting of a flexible line for connection to an anchorage at one end to hang vertically (vertical lifeline), or for connection to anchorages at both ends to stretch horizontally (horizontal lifeline), and which serves as a means for connecting other components of a Personal Fall Arrest System to the anchorage Low Pitched Roof A roof having a slope less than or equal to four in twelve. (One foot vertical for every three feet horizontal.) Lower Level Those areas or surfaces to which an employee can fall. Such areas include but or not limited to ground levels, floors, platforms, ramps, runways, tanks, equipment or structures Maximum intended load The total load (weight and force) of a person, equipment, vehicle, tools, materials, and other loads the employer reasonably anticipates being applied to a walking-working surface at any time Mechanical Equipment Includes all motor or human propelled wheeled equipment used for roof work, except wheelbarrows or mop carts.

6 Procedure No.: PA Page: 6 of DEFINITIONS cont d Mobile Means manually propelled or movable Mobile ladder stand (ladder stand) A mobile, fixed-height, self-supporting ladder that usually consist of wheels or casters on a rigid base and steps leading to a top step. It may also have handrails and is designed for use by one employee at a time Mobile ladder stand platform A mobile, fixed-height, self-supporting unit having one or more standing platforms that are provided for means of access and egress Motion-Stopping-Safety (MSS) System A fall restraint system providing fall protection by using the following equipment singly or in combination: guardrails, scaffolds or platforms with guardrails, safety nets, and harness systems Opening A gap or open space in a wall, partition, vertical walking-working surface, or a similar surface that is at least 30 inches (76 cm) high and at least 18 inches (46 cm) wide, through which an employee can fall to a lower level Personal Fall Arrest System A system used to arrest an employee in a fall from a working level. It consists of an anchorage, connectors, a body harness, and may include a lanyard, deceleration device, lifeline, or suitable combinations of these Personal fall protection system A system (including all components) used to provide protection from falling or to safely arrest a person s fall if one occurs. It consists of an anchorage, connectors, a body harness, and may include a lanyard(s), deceleration device, lifeline, or suitable combination of these. Examples of personal fall protection systems include personal fall arrest systems, positioning systems, and travel restraint systems Platform A walking-working surface that is elevated above the surrounding area.

7 Procedure No.: PA Page: 7 of DEFINITIONS cont d Qualified Person A person who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training and experience, successfully demonstrates the ability to solve/resolve problems relating to the subject matter, the work, or the project Runway An elevated walking-working surface, such as a catwalk, foot walk along shafting, or an elevated walkway between buildings Safety Net System A net placed below workers to catch them in the event a worker falls Safety Monitoring System A safety system in which a competent person is responsible for recognizing and warning employees of fall hazards. The competent person shall: Be competent in the recognition of fall hazards Be capable of warning workers of fall hazard dangers and in detecting unsafe work practices Be on the same walking/working surfaces of the workers, and can see them Be close enough to work operations to communicate orally with workers and has no other duties to distract from the monitoring function Self-retracting lanyard (SRL) personal fall limiter (PFL) A deceleration device containing a drum wound line that can slowly retract from, or retract onto, the drum under slight tension during normal movement by a person; device automatically locks the drum and arrests the fall at onset of descent SRL= drum attaches to anchorage point; safety hook attaches to harness D-ring PFL= drum attaches to the harness D-ring; safety hook attaches to the anchorage point Steep Roof A roof having a slope greater then a 4 in 12 vertical to horizontal Suspension Trauma Also known as harness hang syndrome (HHS), is an effect which occurs when the human body is held upright without any movement for a period of time. If the person is strapped into a harness or tied to an upright object they could eventually faint and could lead to a fatality.

8 Procedure No.: PA Page: 8 of DEFINITIONS cont d Through ladder A type of fixed ladder that allows the employee to step through the side rails at the top of the ladder to reach a walking-working surface, such as a landing Unprotected Sides and Edges Any side or edge of a walking/working surface (except at entrance and another point of access) where there is no wall, guardrail system, or stair rail system to protect employees from falling to a lower level Warning Line System This system consists of a temporary rope, wire, or chain and supporting stanchion erected not less than six feet from the edge of a roof and flagged at no more than six foot intervals with high visibility material. This is to warn employees that they are approaching an unprotected roof side or edge, and which designates an area in which the roof work may take place without the use of guardrails, Body Harness, or Safety Net systems to protect employees in the area Walking/Working Surfaces Any surface, whether horizontal or vertical, on which a person walks or works, including but not limited to floors, grating, roofs, ramps, bridges, runways, formwork, and concrete reinforcing steel, but does not include fixed ladders, vehicles, or trailers on which personnel must be located to perform their work duties Well A permanent, complete enclosure around a fixed ladder. 3. SCOPE This procedure applies to personnel (employees and contractors) working under the following conditions: In work areas where there is a danger of falling from a distance of four feet or greater. The distance will be based on the elevation where the employee is standing or sitting. Work from any aerial lift device; Work on roofs; In work areas, not protected by guardrails, less than 4 feet above or next to dangerous equipment and surroundings. Work performed at a height of 4 feet or greater on portable, non-caged ladders. Exceptions: Truck drivers accessing the top of their trailers for inspection/verification purposes only, per DOT requirements, are exempt from the fall protection requirements of this standard.

9 Procedure No.: PA Page: 9 of PROCEDURE 4.1. General Requirements Walking-Working Surfaces (WWS) Surface Conditions All surface conditions must be kept in clean, dry, slip-free, orderly, and sanitary condition. When wet processes are used, drainage must be maintained and to the extent feasible, dry standing places, such as false floors, platforms, and mats must be provided. Surfaces must be maintained free of hazards such as sharp or protruding objects, loose boards, loose grating, corrosion, holes, leaks, spills, snow and ice Loads Walking-working surfaces must be able to support the maximum intended load for the surface. Maximum safe load limits of floors within building structures, in pounds per square foot, shall be conspicuously posted in all storage areas, except on floors or slab grades Access and Egress Safe access and egress to and from walking-working surfaces must be provided Inspection, Maintenance, and Repair Walking-working surfaces must be inspected, regularly and as necessary, and maintained in a safe condition. Hazardous conditions on walking-working surfaces must be repaired before next use. If correction or repair cannot be made immediately, the hazard must be guarded to prevent use or protect personnel until the hazard is corrected or repaired. When structural integrity is involved, a qualified person must perform or supervise the correction or repair. When removing grating and creating a fall through hazard to a lower level greater than four (4) feet (1.2 m), workers shall be protected from falling through the opening. Grating shall not be walked on until it has been fastened in place. Temporary floor openings shall be guarded to prevent exposure to the opening.

10 Procedure No.: PA Page: 10 of PROCEDURE cont d 4.2. Fall Hazard Assessment All elevated work activities must be assessed for potential fall hazards. The assessment should include, but is not limited to, whether the elevated working surfaces (ladder, roof, scaffold, etc ) pose a fall hazard and the need for Personal Fall Arrest Systems and anchorage to ensure the worker does not fall and contact the ground or lower obstructions. Overhead work should be evaluated to ensure falling object protection is adequate. Consideration for dropping tools, equipment, stacking tools or equipment near the edge of an elevated platform, etc. are addressed in PA Falling Object Prevention. Ladders (permanent or temporary scaffold ladders) should be provided with an offset/platform for every 24 vertical section. If this is not possible, installation of fall protection (personal fall arrest systems, ladder safety systems) is required. Fall hazard assessment is required during the issuance of a Safe Work Permit. The total fall distance from the working surface to the lower level or obstructions and the selected personal fall protection components must be evaluated to ensure the person will not contact the lower level or obstructions in the event of a fall. Prompt rescue for a person in the event of a fall must be provided. The evaluation of rescue personnel, ladders, suspension trauma straps equipped on body harness, descending devices or other rescue equipment needs to be evaluated since there may be an instance in which a person cannot self-rescue (e.g., unconscious or seriously injured). NOTE: Use self-retracting lanyards (SRL) or personal fall limiters (PFL) when the Total fall distance is fewer than eighteen (18) feet. Traditional six (6) foot (1.8 m) lanyards may not be the appropriate deceleration device of choice if the lower level is fewer than eighteen (18) feet Duty to Provide Fall Protection and Falling Object Protection Fall protection for working on and/or inspections of rolling stock (railcars, tank trucks, flat bed trailers, etc.) is not exempt from fall protection when fixed or portable fall protection systems are installed and are available or when fall protection is technologically or economically feasible. The expectation is that rolling stock can be positioned or spotted at a fall protection system, or portable units can be purchased to protect working on rolling stock Guardrails systems, safety net systems or personal fall protection systems shall protect walking-working surfaces with unprotected sides or edges that are four (4) feet (1.2m) or more to a lower level Protection from Falling Objects are addressed in PA Falling Object Prevention.

11 Procedure No.: PA Page: 11 of PROCEDURE cont d 4.4. Guardrail Systems For construction details refer to N-S-CL 506 (Angle guardrails) N-S-CL 507 (pipe guardrails) Top rail height 42 inches (107 cm) plus or minus 3 inches (8 cm) above the walkingworking surface. Mid-rail height midway between the top rail and the walking-working surface. Where intermediate vertical members are used in place of mid-rails, the vertical members may not be greater than 19 inches (48 cm) apart. Where screens and Mesh are used in lieu of mid-rails, shall extend from the walking working surface to the top rail and along the entire opening. Guardrail systems must be capable of withstanding a force of 200 pounds (890N) applied downward and outward; 150 pound (667N) for mid-rails, screens, mesh, and other equivalent intermediate members. Openings in guardrail systems used as a point of access shall be equipped with a self-closing gate that slides or swings away from the opening and is equipped with a top and mid-rail or equivalent intermediate member meeting the requirements of this section or an offset that prevents a person from walking or falling into the opening 4.5. Handrails and Stair Rail Systems Handrails are used on walls as a handhold when no leading-edge fall hazards exist. Measure the required height of inches (76-97 cm) from the leading edge of the stair tread to the top surface of the handrail. The previous height of inches (76-86 cm) for installations prior to January 17, 2017, is grandfathered into new requirements Use stair rail systems when a leading-edge fall hazard exists. Measure the height requirement of not fewer than 42 inches (107 cm) from the leading edge of the stair tread to the top surface of the top rail. The previous height of not fewer than 30 inches (76 cm) prior to January 17, 2017, is grandfathered into new requirements. For existing stair rails systems installed before January 17, 2017, the top rail of a stair rail system may serve as a handrail only when the height of the stair rail system is between 36 and 38 inches (91-97 cm) measured at the leading edge of the stair tread to the top surface of the top rail. Stair rail systems installed after January 17, 2017, require a stair rail height of 42 inches (107 cm) with separate hand rails at heights of 30 and 38 inches 91 and 97 cm). The handrail and stair rail must be a smooth surface, have a minimum figure clearance of 2.25 inches (5.7 cm) and not have a projection hazard at the end of the handrail or stair rail system.

12 Procedure No.: PA Page: 12 of PROCEDURE cont d 4.5. Handrails and Stair Rail Systems cont d Stairways shall be designed in accordance to N-S-CL 510: Structural Steel Stair Details Ladders (Fixed, Portable and Mobile) Fixed ladders comply with N-S-CL 509: Structural Steel Ladder and Cage Details. All ladders shall be used in accordance with the manufacturer s recommendations. All ladders shall be inspected prior to each shift of use for proper working conditions and that it is free from visible defects. Any ladder with structural or other defects shall be tagged Do Not Use or similar wording and taken out of service until repaired or replaced. Sites shall identify safe use practices for working from portable ladders in accordance with (c) portable ladders. Ladders shall only be used for the purpose for which they were designed. Use and placement of portable ladders shall comply with (c). Mobile ladder stands and platforms shall be used in accordance with (e). Mobile ladder stands that are four (4) feet or higher require handrails. When the top step height is above ten (10) feet, handrails on three sides are required. Workers should stay positioned on the ladder within one (1) foot (0.03 m) of the side rails Fall Protection for Roof Work Determine appropriate Fall Protection systems in Attachment B for roof work. Fall Protection is required if working less than six (6) feet (1.8 m) from the unguarded roof edge Steep Roof Work Each employee on a steep roof with unprotected sides and edges 6 feet or more above lower levels shall be protected from falling by guardrail systems with toe boards, safety net systems, or personal fall arrest systems.

13 Procedure No.: PA Page: 13 of PROCEDURE cont d 4.7. Fall Protection for Roof Work cont d Low-pitched Roof Work Personnel engaged in roofing work on a low pitched roof with Unprotected Sides and Edges 6 feet or more above lower levels shall be protected from falling by any of the following: Guardrail System with toe board, Safety Net systems, Personal Fall Arrest Systems Combination of Warning Line System and Guardrail System Warning Line System and Safety Net System, Warning Line System and Personal Fall Arrest System, or Warning Line System and Safety Monitoring System. A Designated Area may be used when performing infrequent and temporary work greater than six (6) feet (1.8 m) from an unprotected edge. This Designated area must be delineated by a warning line (rope, wire chain or tape that meets the following: has a breaking strength of 200 pounds (890 N) lowest point including sag is not fewer than 34 inches (86cm) and not more than 39 inches (99 cm) visible from a distance of 25 feet (7.6 m) away erected as close to the work area and not fewer than six (6) feet (1.8 m) from the roof edge If work is >15 from the roof, the warning line is not required. Or, on flat roofs 50 ft or less in width, the use of a Safety Monitoring System without a Warning Line System is permitted. Exception: Employees engaged in servicing and maintenance roof mounted equipment may do so without fall protection provided the following: The roof is flat, and Walkways and equipment being serviced are 6 feet or more from the roof edge, and Employees are trained and instructed to stay within the clearly marked walkway.

14 Procedure No.: PA Page: 14 of PROCEDURE cont d 4.7. Fall Protection for Roof Work cont d Leading Edge Work A. Personnel engaged in leading edgework must be protected by the use of guardrails, safety nets or personal fall arrest systems. B. When zones are used to control access where leading edge and other operations are taking place, the controlled access zone must be defined with a control line or other means to restrict access. Lines must consist of rope, wires, tapes or equivalent materials, and must be flagged at not more than six-foot intervals with high visibility materials Roof skylights Skylights shall be guarded by a standard skylight screen or a fixed standard railing on all exposed sides to protect workers from falling through to a lower level Warning Line System When used, must be erected around all sides of the roof work area. The wire, rope or chain shall be rigged and supported in such a way that its lowest point (including sag) is not less than 34 inches from the walking/working surface and its highest point no more than 39 inches from the walking/working surface. The warning line stanchion supports must be able to withstand at least 16 pounds of force, 30 inches above the roof surface without tipping. Minimal tension strength of the rope, wire or chain must be 500 pounds after being attached to the stanchion. The line shall be attached at each stanchion in such a way that pulling on one section of the line between stanchions will not result in slack being taken up in adjacent sections before the stanchion tips over. If Mechanical Equipment is not being used, the warning line must not be less than 6 feet from the roof edge. If Mechanical Equipment is being used, the warning line must not be less than 6 feet from the roof edge which is parallel to the direction of Mechanical Equipment operation and no less than 10 feet from the roof edge which is perpendicular to the direction of the Mechanical Equipment operation.

15 Procedure No.: PA Page: 15 of PROCEDURE cont d 4.7. Fall Protection for Roof Work cont d Safety Nets If Safety Nets are used, manufacturer s recommendations (i.e. installation, maintenance, inspection requirements, etc ) shall be followed and the manufacturer s written recommendations must be kept at the job site and made available for review upon request. In addition, the requirements of 29 CFR 1926 subpart M must be followed Working from Portable Ladders Work from portable ladders shall be assessed to identify and eliminate fall hazards. If the Portable Ladder cannot be repositioned to stay within 1 ft of the side rails, other working surfaces such as a platform ladder, scaffold, etc should be considered to eliminate the fall potential Working from Scaffolds Scaffolds used must meet the requirements of 29 CFR 1926 subpart L, and PA Scaffolds Steel Erection Employees engaged in steel erection activities shall comply with the requirements of this procedure except when compliance with the maximum 6 foot free fall distance is not practicable. In such cases, appropriate engineering and administrative controls and /or Personal Fall Arrest Systems shall be utilized as necessary to limit the free fall distance to as close to 6 feet as possible. Steel erection activities must comply with 29 CFR 1926 subpart R for fall prevention requirements Rig Hoisted Personnel Platforms Rig hoisted personnel platforms use is permissible when other elevated working surfaces would be more hazardous or is not possible because of structural design or worksite conditions. When allowed, shall comply with 29 CFR Hoisting Personnel.

16 Procedure No.: PA Page: 16 of PROCEDURE cont d Powered Platforms, Man Lifts, Aerial Lifts, and Vehicle-Mounted Work Platforms use must comply with 29 CFR 1910 subpart F: Personnel occupying aerial lifts are required to wear a Body Harness and be anchored to the designated anchor point in the basket at all times. If an aerial lift is not equipment with a manufactured Anchorage Point, appropriate measures shall be taken with the manufacturer to have one installed before using the aerial lift. Anchoring to an adjacent pole, structure or equipment while working from an aerial lift is prohibited. The anchor point shall be in a location in the basket that will not allow the occupant to be thrown out of the basket. Personnel working in aerial lifts shall not stand on the rails of the basket. Scissor lifts are excluded from personal fall protection because the work platform is properly guarded and the lift does not have an articulating boom. Reference PA (Powered Mobile Platforms) for additional requirements Covering for Floor Holes, roofs and other elevated walking/working surfaces Holes in floors, roofs, and other walking/working surfaces shall be covered to provide personnel protection. Covers shall be capable of supporting, at least 2 times the maximum intended load. Covers shall be secured when installed to prevent accidental displacement. All covers, except cast iron manhole covers or steel grates used on streets or roadways, must be marked with the word HOLE or COVER to provide warning of the hazard Maintenance and Repair of Elevated Walking/Working Surfaces The employer shall ensure through regular and periodic inspections and maintenance that Walking/Working surfaces are in a safe condition for employee use. Periodic inspections of elevated walking/working surfaces are documented by Vallen. The inspection frequency was determined by the Maintenance group. All hazardous conditions shall be corrected, repaired or guarded to prevent employee exposure until repairs are made. Guarding may be in the form of an adequate cover or Guardrail System capable of withstanding a force of 200 lbs applied within 2 inches of the top edge.

17 Procedure No.: PA Page: 17 of PROCEDURE cont d Maintenance and Repair of Elevated Walking/Working Surfaces cont d Where the structural integrity of the Walking/Working surface is compromised, a Qualified Person must perform or supervise the maintenance or repair of that surface. When removing grating and creating a Floor Opening with a potential to fall 4 feet or greater, workers shall be protected from falling through the opening. Temporary Floor Openings shall have a standard railing or shall be constantly attended by someone. Grating shall not be walked on until it has been fastened in place. If the Floor Opening is 4 feet or greater and remains open, it shall be barricaded with adequate guardrails. If a permanent structure is modified such that it results in an incomplete structure and fall hazard, either a hard barricade shall be erected or a designated monitor shall be placed in the area to ensure that no individual enters the exposed area without adequate fall protection Other Requirements Whenever specific construction, maintenance or operations activities that are not addressed in this procedure are conducted, the requirements of 29 CFR or 29 CFR shall be met Personal Fall Arrest Systems A Personal Fall Arrest System with continuous attachment shall be used by personnel in work areas that are not protected by Guardrail Systems where there is a danger of falling a distance of 4 feet (1.2 m) or greater. Personal Fall Arrest Systems including Body Harnesses, Lanyards, and associated equipment, must meet the requirements of 29 CFR , or 29 CFR , or ANSI Z standards Personal Fall Protection Systems A. The primary personal fall arrest system shall be a body harness equipped with a front and back D-ring. a duel Personal Fall limiter PFL, and suspension trauma straps. Or equipped with a shock absorbing Y- lanyard. When a shock absorbing Y-Lanyard is not used, 2 single Lanyards with built-in shock absorbers may be used. When 2 single Lanyards are used, do not secure both Lanyards at the same time except for the time it takes to unhook one Lanyard and attach the other. Lanyards shall be equipped with self-closing and self-locking snap hooks.

18 Procedure No.: PA Page: 18 of PROCEDURE cont d Personal Fall Arrest Systems cont d Personal Fall Protection Systems cont d NOTE: PFL eliminates as much as twelve (12) feet (3.6 m) of the total fall distance a person can experience during a fall. Calculating a six-foot (1.8 m) lanyard or a six-foot (1.8 m) worker height is not necessary. SRLs reduce total fall distances and do not require shock absorbers. Body belts are not allowed as fall protection. B. When selecting a body harness size, consult the manufacturer s size chart for worker height and combined weight for person and tools. C. When fall protection systems are required, body harness and lanyards should not be the fall protection system of choice when loading flammables so the employee can move freely in case of a fire. This should also be applied to loading highly hazardous chemicals (e.g., inhalation hazards, acid/gases) so employee can move freely in the case of a chemical release. D. The lanyard anchorage point must be such that personnel can fall no more than 6 feet or contact any lower level. If using a shock absorbing lanyard, the minimum tie off point is 10 feet above the closest obstruction beneath the work. E. If a lanyard may come in contact with hot surfaces, an insulated cover shall be placed on the lanyard or on the hot surface for protection. F. When vertical lifelines are used, each person shall be provided with a separate lifeline. G. Attaching lanyards to sharp edges is prohibited. H. Before an insulated process line is used as an anchor point, it must be approved by the Owning/Operating department and meet the tie off requirements of attachment A.

19 Procedure No.: PA Page: 19 of PROCEDURE cont d Personal Fall Arrest Systems cont d Personal Fall Protection Systems cont d I. Unless specifically designed and approved by the manufacturer for such use, a Lanyard shall not be tied back to itself. J. Writing or marking on Lanyard and Body Harness webbing is prohibited. K. Lanyards and harnesses should be of the same manufacturer L. Personal Fall Protection systems and components subject to impact loading shall be immediately removed from service and shall not be used again until inspected by a Qualified person and determined to be undamaged and suitable for reuse. Full body harnesses and lanyards may not be placed back in service regardless of inspection. M. Fall Protection systems shall not be used to lower or lift tools or equipment Personal Fall Arrest Systems Performance Criteria A. Horizontal Lifelines need to be engineered by a Qualified person or manufacturer due to the complexity of line tension, horizontal and perpendicular forces on line and anchors. B. Shock absorbing lanyards and Self-Retracting Lanyards SRLs come in many varieties. Make sure the proper device is recommended for the application. C. A SRL/PFL is the recommended lanyard because it minimizes free fall, allows vertical mobility, and allows limited horizontal mobility from a fixed point. When used in a fixed overhead position, limit the horizontal movement (fewer than 30 degrees) to prevent swing fall hazards in the event of a fall. Connectors for horizontal movement to a SRL/PFL must be compatible with the anchorage point(s). Never keep the cable extracted when not in use.

20 Procedure No.: PA Page: 20 of PROCEDURE cont d Personal Fall Arrest Systems cont d Personal Fall Arrest Systems Performance Criteria cont d D. When vertical life lines are used, each person shall be provided with a separate lifeline and should not require the person to continuously hold, push or pull any part of the system while climbing. Connections between the carrier or lifeline and the attachment to the front D-ring shall not exceed nine (9) inches (23 cm). Vertical lifelines should operate without the use of hands when ascending or descending. E. Ladder Climbing Devices should not require the person to continuously hold, push, or pull any part of the system while climbing. Connections between the carrier or lifeline and the attachment to the front D-ring shall not exceed nine (9) inches (23 cm). Mountings for ridged or flexible carriers shall be attached to the manufacturer s recommendations Anchorage Points Anchorage points used for attachment of personal fall arrest equipment shall meet the requirements in Attachment A. The anchorage shall be capable of supporting 5,000 pounds per worker attached and shall be designed, installed and used as part of a complete Personal Fall Arrest System which maintains a safety factor of at least two, under the supervision of a Qualified Person. Insulated lines may not be used as anchorage points unless it meets the requirements of Attachment A and authority granted by the owner of the insulated line. Conduit, cable trays, grating, and handrails shall not be used as anchoring points Suspension Trauma Preventing Suspension Trauma should be part of the elevated work assessment and plans should be in place to ensure prompt rescue. Suspension Trauma straps or similar accessories should be a part of the Body Harness assembly.

21 Procedure No.: PA Page: 21 of PROCEDURE cont d Personal Fall Arrest Systems cont d Inspections A. Prior to Use Personal fall arrest systems shall be inspected by the user prior to each use for wear, damage, and other deterioration. Body harnesses and lanyards shall be inspected by the user for cuts, burns, excessive wear, loose splices, defective hardware, and distorted thimbles. B. Quarterly Inspections Personal fall arrest systems shall also be inspected quarterly by a competent person knowledgeable and trained in inspecting the systems. Upon completion of the inspection, each harness shall be tagged with a color coded tag indicating that it has been inspected for that quarter. The following colors shall be used: o Red = first quarter o White = second quarter o Blue = third quarter o Yellow = fourth quarter Documentation of inspections shall be maintained by the Vallen Store Technicians o Equipment in service keep current year plus three (3). o Equipment out from service keep one (1) year after removed from service Defective Components Defective components shall be removed from service. Personal Fall Arrest Systems and components subject to a fall shall be immediately removed from service. o Body Harness and Lanyards shall be removed from service and destroyed. o Retrieval devices and other components that are reusable shall be certified by a qualified manufacturing representative before placing back in service.

22 Procedure No.: PA Page: 22 of PROCEDURE cont d Training All BASF personnel, Contract Employees and Contractor employees who might be exposed to fall hazards shall be trained such that each of these employees will be able to recognize the hazards of falling and the procedures to be followed to minimize these hazards. Fall Protection training must be developed by a Qualified person and delivered in a manner that is understood. Contractor training is the responsibility of the contract company Training shall include as necessary The requirements of this procedure; Types of fall hazards in the workplace; The correct procedures for erecting, maintaining, disassembling, and inspecting the Fall Protection systems used; The use and operation of Guardrail Systems, Personal Fall Arrest Systems, Safety Net systems, Warning Line Systems, Safety Monitoring Systems, Controlled Access Zones, and any other protection which may be used; The role of each employee in the safety monitoring system when this system is used; The correct procedure for the handling and storage of equipment and materials and the erection of overhead protection; and The role of employees in fall protection plans. Proper storage of personal fall protection equipment when not in use Retraining must be conducted when: There is reason to believe that any affected employee who has already been trained does not have the understanding and skill required to be able to recognize fall hazards and the procedures to be followed to minimize these hazards. Changes in the workplace or types of Fall Protection Systems/equipment that make previous training obsolete.

23 Procedure No.: PA Page: 23 of RESPONSIBILITIES 5.1. Port Arthur Site Leadership Team Has primary responsibility for implementation of this procedure Environmental, Health, and Safety Manager Has primary responsibility for the initiation, re-issuance, administration, and/or interpretation of this procedure Port Arthur Site Employees and Contractors Have primary responsibility for adherence to procedure including identifying deficiencies in the procedure, and identifying, reporting and correcting activities not in compliance with the procedure. 6. RELATED DOCUMENTS N-ID-OSA-027 Walking/Working Surfaces (WWS) (Fall Protection) and Falling Object Protection 29 CFR 1926 Subpart L: Scaffolds 29 CFR 1926 Subpart M: Fall Protection (Safety Nets) 29 CFR 1926 Subpart R: Steel Erection 29 CFR : Hoisting Personnel 29 CFR (b)(c)(e): all ladders, portable ladders, mobile ladder stands 29 CFR 1910 Subpart D, Walking and Working Surfaces 29 CFR 1910 Subpart F, Powered Platforms, Manlifts, Vehicle mounted platforms 29 CFR : Personal Fall Protection Systems 29 CFR : Fall Protection 29 CFR , Duty for Fall Protection 29 CFR , Fall Protection Systems criteria and practices 29 CFR , Training Requirements ANSI Z Safety Req. for PFA Systems, Subsystems and Components N-S-CL 506: Guardrail Construction Standard N-S-CL 509: Structural Steel Ladder and Cage Details N-S-CL 510 Structural Steel Stair details PA : Scaffolds PA : Falling Object Prevention PA : Powered Mobile Platforms Attachment A: Structural Beams as Anchorages Attachment B: Fall Protection Systems Grid Attachment C: Required Clearance Illustration Attachment D: Port Arthur Fall Hazard Assessment

24 Procedure No.: PA Page: 24 of 31 ATTACHMENT A Typical tie-off attachments for one worker MAXIMUM ALLOWABLE SPANS FOR BEAMS USED AS FALL PROTECTION BEAMS Depth MAXIMUM DEPTH WIDTH ALLOWABLE SPAN (in) (in) (ft) Width CHANNELS Depth DEPTH (in.) MAXIMUM ALLOWABLE SPAN (ft) TEES Depth Width MAXIMUM DEPTH WIDTH ALLOWABLE SPAN (in) (in) (ft) BEAM TABLES ARE BASED ON THE FOLLOWING: 1. Personnel use shock-absorbing Lanyards (meeting ANSI Z359.1) which limit the load distributed to the Body Harness to 900 lbs. 2. One worker is tied to a beam within a given span at any time. 3. Table is not for Lifeline (cable) anchorage. 4. Spans > 20 ft. shall not be approved by a Qualified Person. IF ANY OF THE ABOVE CONDITIONS CANNOT BE MET, ALTERNATIVE ANCHORAGE POINTS AND FALL PROTECTION SYSTEMS MUST BE APPROVED BY A QUALIFIED PERSON.

25 Procedure No.: PA Page: 25 of 31 MAXIMUM ALLOWABLE SPANS FOR PIPES USED AS FALL PROTECTION PIPES NOMINAL PIPE DIAMETER (in) MAXIMUM ALLOWABLE SPAN (ft) Nominal Pipe Diameter < 3 not allowed PIPE TABLE IS BASED ON THE FOLLOWING: 1. Personnel use shock-absorbing Lanyards (meeting ANSI Z359.1) which limit the load distributed to the Body Harness to 900 lbs. 2. One worker is tied to a pipe within a given span at any time. 3. Carbon steel pipes. 4. Continuously welded pipe i.e. no flanges or fittings within the tie-off span. 5. Nominal pipe diameter based on un-insulated lines. 6. Table is not for Lifeline (cable) anchorage. 7. Spans > 20 ft. shall not be approved by a Qualified Person. IF ANY OF THE ABOVE CONDITIONS CANNOT BE MET, ALTERNATIVE ANCHORAGE POINTS AND FALL PROTECTION SYSTEMS MUST BE APPROVED BY A QUALIFIED PERSON.

26 Procedure No.: PA Page: 26 of 31 Anchorage Points Anchorages used for attachment of personal fall arrest equipment shall be independent of any anchorage being used to support or suspend platforms and capable of supporting at least 5,000 lbs. per employee, and be rigged such that an employee can neither free fall more than 6 feet, nor contact any lower level. Below are some general guidelines and calculated equipment to meet this requirement. Anchorage Points Minimum Sizes and Conditions 1. Pipe 2" carbon steel and 3" or greater of any metal pipe may be used if in good condition. Span (between pipe supports) must not be greater than 20 feet for any size pipe. 2. Structural Steel Span must be 20 feet or less. The pipe length must be continuous for at least two supports on either side of the attachment. Do not tie off to electrical conduit of any size or cable tray. Do not tie off to insulated pipe of any size unless permission is received from the owner. Do not tie off to non-insulated, high temperature pipe without a heat guard on the lanyard. Handrails or guardrails are not to be used as anchor points. 3. Ladder Cages Connecting to the side rail of the ladder where a rung is attached meets the 5,000 pound requirement 4. Lifelines 3/8" diameter, silicon-tin-bronze cable, alloy 13, 7 strand per ASTM B /8" Diameter galvanized steel Space-lay. Lifeline cables that are part of a climbing protection device are acceptable. 5. Lanyards Shall have self closing, self locking snap hooks, and have a minimum breaking strength of 5000 pounds. NOTE: When securing to an anchorage point, the user must take into consideration the deflection of the pipe or cable, (which could be up to 24" for 2" pipe), and for the amount of lanyard that would be lengthened from the shock absorber unstitching, plus an individual's leg length. Also check the anchorage point for corrosion. If the above conditions cannot be met for an anchorage point, contact the EHS Department for assistance to determine which anchorage points can be used.

27 Procedure No.: PA Page: 27 of 31 Protection From Fall Hazards unprotected sides and edges >4 from lower level Guardrail System Safety Net Attachment B Fall Protection Systems Personal Fall Protection X X X Covers Travel Restraint Ladder Safety Systems hoist area X X X X 1 Holes X X X X Dock Boards * runway/sidewalks >4 from lower level dangerous equipment with no guard/cover X X Openings X X X X Pits <10 X 2 Fixed Ladders X X Stairways X 3 Scaffolds X X 4 Roof Work X X X X 5 X X X Powered Platforms, Man Lifts Vehicle- Mounted Work Platforms * not required if solely used by mobile equipment and personnel are not exposed to fall hazards > 10 ft. and dockboards are covered in their fall protection training. 1 when railing is removed 2 limit access within 6 (1.8 m) of edge, use floor markings, warning lines 3 stair rail system for open edges when stairs have at least 4 risers. Follow Table D2 of for stairway handrail requirements. 4 when a scaffold railing or decking is not in accordance with 29 CFR 1926, Subpart L 5 cover or guard skylights or openings X X

28 Procedure No.: PA Page: 28 of 31 Attachment C Required Clearance Illustration Traditional 6 Shock Absorbing Lanyard Class A SRL/PFL A = 6' B = 3.5' AB = 9.5' C = 6' + 3" Safety Margin Min clearance req'd (MCR = 18.5') Class B SRL/PFL Class A Class B MAD - 2' MAD = 4.5' + 39" Safety Margin MCR = 5'3" MCR = 7'9"

29 Procedure No.: PA Page: 29 of 31 If a person is working at a height of less than 18.5 Consider replacing the 6 shock absorbing lanyard with a SRL/PFL.

30 PA Attachment D FALL HAZARD ASSESSMENT Page 1 of 2 Assessment is used to identify Fall Hazards or when use of personal fall protection is necessary. ASSESSMENT PERFORMED BY: DATE: SCAFFOLD OR ELEVATED WORK LOCATION: HOW OFTEN WILL TASK BE PERFORMED? DAILY MONTHLY WEEKLY ANNUALLY IDENTIFY POTENTIAL HAZARDS OF TASK(S) ELEVATED WORK PLATFORM CONFINED SPACE STAIRWAYS EXCAVATION INADEQUATE ANCHORAGE POINT WALL OPENING FLOOR OPENING LADDERS (FIXED OR PORTABLE) IMPALEMENT HAZARDS STRUCTURAL WORK SCAFFOLD ERECTION/DISMANTLE LEADING EDGE WORK ROOF WORK PROXIMITY TO DANGEROUS EQUIPMENT OTHER: DESCRIBE THE HAZARDS: INCLUDE DIMENSIONS, LOCATIONS, ELEVATIONS, LEVELS, ETC. IDENTIFY FALL PROTECTION SYSTEMS TO BE USED GUARD RAIL ANCHORAGE POINTS INSTALLED CONTROL ZONE W/ MONITOR MONITOR FALL RESTRAINT BEAM SLIDERS SAFETY NET PROCEDURES SELF-RETRACTING LIFELINES (YO-YO) CATCH PLATFORM WORK PLATFORM ENGINEERED LIFELINES SCAFFOLD SELF PROPELLED ELEVATED PLATFORM DESCRIBE FALL PROTECTION & MEANS FOR PREVENTING CONTACT WITH A LOWER LEVEL DROPPED OBJECT PROTECTION BARRICADING CATCH NETTING COVERS ON FLOOR HOLES (MARKED) SIGNS SCREENS/NETTING ON SCAFFOLDS TOOL LANYARDS IDENTIFY METHOD USED TO DETERMINE ADEQUACY OF ANCHORAGE POINTS PROFESSIONAL ENGINEER MANUFACTURER S DATA EXISTING ENGINEERING/DESIGN DOCUMENTS OTHER: DESCRIBE & IDENTIFY LOCATIONS OF ANCHORAGE POINTS Effective: 08/08/2018 Approved by: EHS Manager

31 PA Attachment D FALL HAZARD ASSESSMENT (cont.) Page 2 of 2 Assessment is used to identify Fall Hazards or when use of personal fall protection is necessary STEPS TO TAKE FOR IMMEDIATE RESCUE: DEPLOY & USE SUSPENSION TRAUMA STRAPS NOTIFY OPERATIONS VIA RADIO OTHER EMPLOYEE IN AREA TO NOTIFY OPERATIONS USE OF NEARBY LADDER; LOCATION: OTHER; DESCRIBE: NAME OF SAFETY ATTENDANT FOR UNGUARDED ELEVATED WORK: NAME DATE SHIFT COMPANY ASSESSMENT PERFORMED BY SIGNATURE: UPDATES/REVISIONS TO FALL HAZARD ASSESSMENT RESPONSIBLE PERSON: DATE: SHIFT: RESPONSIBLE PERSON: DATE: SHIFT: RESPONSIBLE PERSON: DATE: SHIFT: RESPONSIBLE PERSON: DATE: SHIFT: REVISIONS: REVISIONS: REVISIONS: REVISIONS: Effective: 08/08/2018 Approved by: EHS Manager