Lock Out Tag Out and Line Breaking

Transcription

1 Title: Lock Out Tag Out and Line Breaking Site Function: Ecology and Safety Procedure No.: MC Page: 1 of 22 McIntosh Site Preparer: B. Lax Owner: M. Ware Approver: J. Slinkard SE HUB EHS Team Member EHS Team Leader Site Director 1. PURPOSE The protection of personnel from any safety hazards caused by accidental activation of equipment. This procedure establishes the minimum standard work practices and procedures for initial safe opening and ensuing work on flanges, pipes, and equipment which contained or may have contained hazardous material, thermal hazards (hot or cold) or been under pressure. Additionally, it established the minimum requirements for the lockout/tagout (LOTO) of energy isolating devices. It shall be used to ensure that machines or equipment are isolated from all potentially hazardous sources of energy and locked/tagged out before employees perform any servicing or maintenance activities where the unexpected start up or release of stored energy could cause injury. 2. DEFINITIONS 2.1 Affected Employee A person whose machine or equipment is to be serviced or maintained under lockout/tagout or; who is working in an area where such activities are being performed. 2.2 Authorized Employee A person who locks out / tags out machines or equipment or performs work on equipment subject to this procedure. The Authorized Employee and the Affected Employee may be the same under certain circumstances. 2.3 Capable of Being Locked Out An energy isolating device is capable of being locked out if it has a hasp or other means of attachment to which, or through which, a lock can be affixed, or it has a locking mechanism built into it. Other energy isolating devices are capable of being locked out, if lock out can be achieved without the need to dismantle, rebuild, or replace the energy isolating device or permanently alter its energy control capability. 2.4 Confined Space: A space (such as tanks, vessels, silos, storage bins, hoppers, vaults, pits, ditches, and sewers) that:

2 Procedure No.: MC Page: 2 of 22 Is large enough and so configured that a person can bodily enter and perform assigned work; and Has limited or restricted means of entry or exit; and Is not designed for continuous employee occupancy 2.5 Electrical Tag See Attachment # 1. This tag is used by Qualified Electricians and hung on electrical equipment to signify electrical Work is being performed. 2.6 Energized Electrical Work Work performed on exposed live parts (involving either direct contact or contact by means of tools or materials) or near enough to them for employees to be exposed to any hazard they present. This work shall only be performed by Qualified Electricians. 2.7 Energy Source Any source of electrical, mechanical, hydraulic, pneumatic, chemical, thermal, nuclear or other energy. 2.8 Owning/Operating Department The unit or department that operates or is responsible for the daily operation of the process, area or facility where work is being conducted. 2.9 Isolation Verification A final field check to confirm that the specified equipment has been properly isolated and/or de-energized. Isolation verifications may be performed by the Permit Issuer. The person performing the isolation verification shall sign the LOTO sheet, upon completing the Isolation verification. Signature indicates: the applicable work matches the Safe Work Permit the conditions in the field are safe for the Work Crew to perform their work (e.g. 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. The try to operate step is a requirement, and is an attempt to start or operate equipment that has been locked/tagged out. The purpose of the try to operate step is to verify that isolation and de-energization of the equipment is effective. It should be noted that if equipment is computer controlled, trying to operate a local field switch cannot serve as the sole means to Try To Operate.

3 Procedure No.: MC Page: 3 of 22 all isolation points for hazardous energy sources have been locked or tagged as identified on the LOTO Sheet, including use of One Plus methods if applicable no other hazardous energy sources are attached to the equipment to be worked inside the boundaries defined by the tag out (e.g. all purge hoses and steam hoses used for preparation are disconnected), unless otherwise noted on the permit and/or LOTO Sheet the LOTO Sheets 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 Hazardous Energy Source Any electrical, mechanical, hydraulic, kinetic, pneumatic, chemical, thermal, or other energy (e.g., radiation), including stored or residual energy, that if unexpectedly or inadvertently released, could cause injury to personnel, or if introduced into a process could be hazardous. A hazardous energy source includes anything that may cause injuries due to the accidental activation of equipment, such as, but not limited to: Being caught in, on, or between power driven mechanical components of equipment. Being struck by a moving piece of equipment. Contact with electrical hazards. Contact with hazardous materials/chemicals. Contact with temperature extremes or cryogenic fluids. Contact with any pressures. Exposure to harmful radiation or infectious materials. Exposure to harmful noise. Exposure to residual or stored energy Hot Tap A procedure used in the repair, maintenance, and service activities which involves welding on a piece of process equipment which cannot be isolated, depressurized, or cleared; for the purpose of installing connections or appurtenances Hot Work An activity that falls into one of the following categories:

4 Procedure No.: MC Page: 4 of Flame- or Spark-Producing Hot Work means an operation that can produce enough heat from flame, spark, or other means, such as friction, with sufficient energy to ignite combustibles or flammables. This includes electric arc and gas welding, grinding, cutting, burning, brazing, soldering, and similar spark-producing or heat-producing operations Non-rated Electrical Equipment Hot Work includes the use of portable electric equipment and electronic devices in Electrically Classified areas and that are not Listed or Labeled for use in the Electrically Classified Area Vehicle Access Hot Work includes the operation of electric, gas, diesel, or internal combustion engines in Electrically Classified Areas, unless the equipment has been approved for use in the area by a nationally recognized testing lab. For example, powered industrial trucks may be manufactured for use in specific Electrically Classified Areas Interdepartmental LOTO Line Breaking or isolation work activity on a pipeline or equipment which is shared with another operating unit or Owning Department. The Safe Work Permit is issued by the unit/department initiating the work activity Issuing Shift The work shift personnel on duty on the shift during which the Safe Work Permit is issued to the Work Crew Line Breaking The actual opening/separation/removal of equipment containing or having previously contained a Hazardous Material/Energy source. Equipment includes, but is not limited to all types of flanges, pumps, manways/hatches, screwed pipe, fittings, exchanger tube plugs, valves, tubing, hoses, sanitary connections, or other types of connections/openings in process or utility service One-Plus Isolation System utilizing a mechanism of physical protection to make equipment inoperative. This is intended to prevent unexpected or inadvertent operation of an Energy Isolation Device Qualified Electrician

5 Procedure No.: MC Page: 5 of 22 An individual who has received training meeting the requirements of 29 CFR 1910 Subpart S - Electrical, as determined by the BASF McIntosh site electrical maintenance supervision Person who has completed formal program of training (either classroom or on the job) and qualification and is familiar with the: Hazards of electricity. Skills and techniques needed to distinguish exposed parts from other parts of electrical equipment. Skills and techniques needed to determine the nominal voltage of exposed live parts. Clearance/approach distances required and the corresponding voltages to which the qualified person will be exposed. Applicable electric codes. Hazardous area classification and its application to electrical installations. Safety-related electrical work practices pertaining to their respective job assignments. Electrical requirements included in operating and maintenance procedures (including lock, tag, and try). Use, care, and limitations of personal protective equipment Radiation Work activity involving the isolation, repair, or removal of any radioactive equipment on site such as nuclear gauges shall be performed in accordance with the site Radiation Policy (MC ) Owner Lock and Tag See Attachment # 2. This tag is used by the Owning Department (usually Operations) to isolate equipment for Servicing/Maintenance. The lock will be an Abus type lock and shall only be used for LOTO purposes Safe Work Permit This permit is issued for Lock Out/Tag Out and Line Breaking jobs at the McIntosh Site that falls within the scope of this procedure. Refer to McIntosh Site Safety Procedure MCC , Safe Work Permit, for more information Servicing/Maintenance Work place activities such as constructing, installing, setting up, adjusting, inspecting, modifying, and maintaining and/or servicing machines or equipment. These activities include lubrication, cleaning or unjamming of machines or equipment and making adjustments or tool changes, where personnel may be exposed to the unexpected energization or startup of the equipment or release of hazardous energy.

6 Procedure No.: MC Page: 6 of Lockout/Tag Out (LOTO) Sheet See Attachment # 3. A sheet that is issued as part of Safe Work Permit when lock out/tag out or Line Breaking work is involved. This sheet identifies the energy isolation devices that are used to safely perform that work activity Try To Operate An attempt to start or operate equipment that has been locked/tagged out, for the purpose of verifying that isolation and de-energization of the equipment is effective. The Try step shall also apply to One Plus isolation to ensure the Energy Isolation Device cannot be inadvertently opened. The position of owner locked/tagged valves shall not be changed for the purpose of trying to operate. It should also be noted that if equipment is controlled by DCS systems, trying to operate a local field switch cannot serve as the sole means to Try To Operate such equipment. The Owning Department must address these situations on a case-by-case basis to verify proper isolation Work Crew The individuals assigned to a particular job. For the purpose of this procedure, a Work Crew may be comprised of workers from more than one company provided each company involved and the Owning Department agree to the arrangement. A Safe Work Permit shall be issued for each Work Crew Maintenance Lock and Tag See Attachment # 4. This tag is used only by Work Crew personnel to indicate that a crew is working on the tagged out and locked out equipment. Installation and removal of this Maintenance tag is restricted to Work Crew supervision or work crew member. These Maintenance tags must be signed and dated prior to installation. The Maintenance tag shall not normally be placed on any equipment which does not have an Owner tag/lock. Sub-contractors shall use another lock color, provided it is different from the owning/operating department locks and tags. The color-coded lock guidelines include the use of green locks by BASF and KBR maintenance, black locks by KBR for capital work, and blue locks by BASF I&E personnel Permit Acceptor Person responsible for obtaining approval to do work.

7 Procedure No.: MC Page: 7 of Eyes Principle The use of 2 or more individuals (equipment operator/owner and individuals(s) performing the work) to assess tasks in order to ensure that all hazards are identified and eliminated or controlled through safe work practices, use of PPE, communication and awareness, etc. 3. SCOPE AND APPLICATION Unless exempt as specified below, this procedure applies to all McIntosh Site LOTO work involving isolating equipment from Hazardous Energy Sources for Servicing/Maintenance, Line Breaking, and other work where there is the potential for exposure to a Hazardous Energy Source. The specific procedures relating to LOTO work involving isolation of equipment do not apply to the following activities listed below. However, all PPE requirements for specific linebreaking activities must remain in accordance with Section 4.3 of this procedure and the site PPE procedure MC , Activities performed, in accordance with a written job procedure, job hazard analysis (JHA), etc., by Operating/Owning Department personnel where the work is routine, repetitive and integral to the use of the equipment and within the exclusive control of the individual(s) performing the work (e.g., filter or strainer cleaning, hose connection or disconnection, vessel inspections for level gauging, and process sampling). Work on cord and plug connected electrical equipment for which exposure to the hazards of unexpected energization or start-up of the equipment is controlled by unplugging the equipment from the energy source and by the plug being under the exclusive control of the person performing the Servicing/Maintenance. 4. PROCEDURE 4.1 General Procedure Requirements A Safe Work Permit and a LOTO Sheet shall be issued to perform activities requiring isolation of Hazardous Energy Sources. A. Refer to MCC , Safe Work Permit, for specific requirements related to issuance of Safe Work Permits. B. Refer to section 4.3 for specific requirements related to Line Breaking A flow chart of the general steps of this procedure is included as Attachment # The equipment shall be prepared by the Owning Department, by isolating Hazardous Energy Sources and/or decontaminating/purging equipment. Unit

8 Procedure No.: MC Page: 8 of 22 specific procedures (e.g. JHAs, SOPs) shall be used for shutting down, isolating, blocking and securing equipment. Generic isolation procedures (Attachment # 5) may be used for less complicated equipment provided they address the hazards and necessary steps for proper isolation. The Permit Issuer must be a different individual than the Permit Acceptor performing LOTO and Line Breaking activities. Unit procedures, in conjunction with the LOTO Sheet, must address the following: A. Identification of the covered equipment or group of equipment B. A list of the specific types and magnitudes of Hazardous Energy Sources C. Steps for safely shutting down, isolating, blocking, positioning and/or otherwise securing the equipment D. Identification of the safe position for each energy isolation device E. Specific steps necessary for safely releasing any stored or contained Hazardous Energy Sources F. Specific methods (i.e. Locks, One Plus/Tag Plus, etc.) and isolation location(s) necessary for each energy isolation device G. Methods to confirm Isolation Verification H. Steps necessary to safely return the piece of equipment to service Isolation of Hazardous Energy Sources A. All Hazardous Energy Source isolation devices shall be owner tagged at a minimum. Owning Department locks shall be an Abus lock type (See attachment 2). Owner tags and Abus locks shall only be used to isolate equipment for activities covered under the scope of this procedure. Owner tags and Abus locks shall not be used to isolate equipment that will be abandoned in place or for other activities that do not involve Servicing/Maintenance. NOTICE tags shall be used for such purposes. B. Whenever equipment is to be isolated for Servicing/Maintenance, a drawing showing the location of each isolation device must be generated. A hand drawing, ISO drawing or P&ID may be used. This drawing should be used in conjunction with the LOTO Sheet to ensure all isolation points for hazardous energy sources are identified. C. Each electrical energy source shall be locked out and tagged with an owner lock/tag if it is capable of being locked. If the electrical energy isolation device is not lockable, the One-Plus isolation method shall be used regardless if the isolation device is prone to inadvertent operation or not. D. When electrical leads are disconnected from an energy source, a SWP must be issued by operations personnel prior to performing work. Once disconnected by a qualified electrician, an electrical tag must be placed at the point closest to the work activity. The completed SWP that was issued for dropping the electrical leads must accompany any SWP s

9 Procedure No.: MC Page: 9 of 22 that will be issued to perform subsequent work on the equipment associated with that energy source. E. Isolation devices for non-electrical hazardous energy sources shall be locked and tagged by the owner. Each valve must have its own lock and tag. One-Plus Isolation shall be used for isolation devices per the following criteria: E.1 Each quarter-turn valve on a hazardous energy source, which cannot be positively locked/tagged to prevent inadvertent operation, shall use one of the following methods: Remove handle Chain or cable Valve cover or locking arm Cable lock Valve gags Tie wrap (minimum tensile strength of 120 lb) F. Each chain-actuated valve, regardless of valve type, shall have the chains secured out of the way or the chains secured together at a height of 7 feet or more. G. For railroad track isolation, the blue flag or de-rail switch shall be owner tagged and locked. H. Work on electrically traced lines, including insulation work, must ensure that the electrical tracing is locked out and verified as de-energized by a qualified electrician. The electrician shall sign the LOTO Sheet upon verification. I. During installation of electrical tracing, the circuit breaker shall be locked by the installing contractor until the tracing is turned over to the Owning Department. J. Steam lancing of electrically traced lines requires the following precautions: Circuits must be identified, locked and tagged out, and verified deenergized by a qualified electrician A Safe Work Permit must be issued to the person(s) who will perform the lancing; Insulation must be removed to verify tracing is not damaged; K. Use of automatically actuated valves for isolation requires: Determine if the valve is a fail open valve or a fail closed valve. o Fail open valves cannot be used as an isolation point unless the actuator is removed from the valve. o If the valve is a fail closed valve, all energy sources (electrical, air supply, air reservoirs, springs, hand jacks, etc.) that could

10 Procedure No.: MC Page: 10 of 22 o operate the valve must be identified, isolated, and locked/tagged. For air actuated valves, the air should be disconnected from the valve, and a Do Not Operate tag used to ensure the air is not inadvertently reconnected Isolation of nuclear devices shall be performed in accordance with the site Radiation Policy (MC ) Equipment isolation/decontamination may take several days and be performed by more than one shift. However, upon completion of isolation the LOTO Sheet shall be signed by the individual who performed the isolation. This signature indicates the equipment was prepared for the permitted activity including being isolated, tagged/locked, decontaminated, and Tried To Operate to verify proper isolation. The posting of warning signs, using barricade tape, placement of splash pans, etc. should be considered as part of the preparation in accordance with written procedures or Owning Department supervision s instruction. A. Equipment interlocks, where applicable, must be verified that they are not engaged such that they prevent the isolation. B. Attempts to verify a local field switch on equipment controlled automatically or remotely (such as by DCS systems) cannot serve as the sole means to verify isolation. An additional isolation verification method, which verifies that the equipment will not start as a result of a signal from the computer, must also be performed. When verifying equipment with a variable frequency drive, ensure the VFD is considered during the verification step. Verification of isolation when interlocks are involved can be performed by one of the methods listed below: B.1 Installation of an engineering control (e.g. local disconnect) B.2 Following an equipment-specific isolation and verification procedure In accordance with MCC (Safe Work Permits) isolation verification can be performed one shift prior to the issuance of the Safe Work Permit The 4-eyes principle shall be employed to ensure that all necessary precautions have been taken before the lock/tag is removed. The Permit Issuer and the Permit Acceptor shall meet at the specific work location to review the job and the requirements of the Safe Work Permit.

11 Procedure No.: MC Page: 11 of 22 At a minimum this field review shall confirm the following, as applicable to the work: A. All line break locations have been identified and all line break precautions taken as identified in section 4.3 B. Bleeders nearest each line break are open and unplugged C. Pressure has been removed or controlled to the extent that it no longer poses a hazard to personnel. D. All purges are off E. All piping/equipment is cooled to the extent that it no longer poses a hazard to personnel. F. Any associated Start/Stop switch has been tried. Note: If a local field switch is used to Try To Operate the equipment, the off switch shall be activated immediately following the try. This is to help prevent startup of the equipment once the Servicing/Maintenance is complete and the switch gear is energized by the Owning Department. G. Equipment has been verified as de-energized and is ready for work H. The job scope is mutually agreed upon and documented as such on SWP I. If the work involves entry into a Confined Space, a rescue plan has been established and retrieval equipment is in place. This must be verified by the ERT prior to entry The Safe Work Permit issuer shall complete the approval portion of the applicable LOTO Sheet. Use of Safe Work permits/loto sheets for Confined Space Entries will be as follows: A Safe Work permit and LOTO sheet will be completed for placement of blinds during isolation of the Confined Space. Once blinds are in place, a Safe Work permit and LOTO sheet will be completed for the Confined Space Entry, siting the blinds as the isolation points. The bottom of the tags from the blinds should be placed in the lockbox. o Maintenance Work Crew members as well as a member of operations will place tags on the blinds. Anyone going in the vessel is also required to place a tag on each blind. (It is not a requirement for the bottom portion of these tags to be placed in the lockbox. Only the bottom portion of the operators tag is required in the lockbox.) The location and tag number for each blind installed must be documented by the operator on the LOTO sheet. o As a part of the LOTO sheet, the valve used to supply gas for the air horn will be tagged open. The tag will specify that the gas is to be used exclusively for the air horn.

12 Procedure No.: MC Page: 12 of The Work Crew member shall then sign and date the Safe Work Permit and the Work Crew Accountability section of the LOTO Sheet after they understand the type, magnitude, and hazards related to the energy being isolated and accept the equipment isolation points and the controls applied. Note that the LOTO Sheet can be signed after the job is walked as described in section The Work Crew member who signed the permit or another designated Work Crew representative shall then walk the job, review the permit, and hang their locks/tags at the locations specified on the LOTO Sheet or place them on the lockbox. It is the responsibility of the work crew representative to communicate the requirements of the permit to the remaining work crew members. A. All work Crew members shall also hang their locks/tags at the locations specified on the LOTO Sheet or place them on the lockbox. B. Maintenance tag and locks shall be hung after an Owner Lock and Tag has been hung. Individually keyed locks and tags shall be used by the Work Crew. C. A signed tag shall accompany all locks for the purpose of identifying the person who applied the lock. If the Work Crew representative has any questions after walking the job, they must return to the issuer of the Safe Work Permit and seek clarification. Note: Only Work Crew members shall remove their respective locks/tags and only after the entire crew has signed off the job via the Work Crew LOTO record When the equipment is turned over to the Work Crew, the LOTO Sheet number will be recorded in Section III of the Safe Work Permit The isolation points should ensure that the equipment to be worked on is isolated from all potentially hazardous sources of energy. Each Work Crew member must understand the job and the safety measures employed. A. Each work crew member must walk the job, evaluate the isolation points, and confirm that all necessary isolation points have been identified and properly locked out/tagged out. If needed, work crew members should consult with their work crew representative and/or the permit issuer for assistance. B. Any work crew member has the right to perform the Try to Operate Step. Prior to Trying any equipment, the work crew member must notify their work crew representative who will notify the permit issuer.

13 Procedure No.: MC Page: 13 of The Owning Department retains the top copy of the LOTO Sheet and the bottom copy is retained by the Work Crew Upon completion of work activity, end of shift, or revoking of the permit for any reason, the LOTO Sheet, along with the associated Safe Work Permit, (including sign off initials) shall be returned to the Owning Department If the job is not complete, but the Work Crew is finished for the shift, the Work Crew representative shall turn in the unsigned LOTO Sheet to the Owning Department. If the Work Crew locks are pulled, re-verification of energy isolation (lock out/tag out) must be performed again when the Work Crew returns at a later time to continue the job even if it is the same individual. No Work Crew representative shall depend upon isolation verification of another Work Crew representative even if the Work Crew locks were left in place Once the job is completed by the Work Crew, all Work Crew members that hung their locks/tags shall pull their locks and tags and a Work Crew representative (Work Crew member or supervision) shall complete the LOTO Sheet by signing off Work Crew Accountability record section of the LOTO Sheet and turn it into the Owning Department. The Safe Work Permit, complete with Work Crew members signed off the job, shall be signed and returned to the Owning Department For completed jobs, after verification that the Work Crew has cleared their tags, locks and tools; and returned their Safe Work Permit and LOTO Sheet (complete with Work Crew members initials indicating that they signed off the job), the Owning Department shall: verify the equipment is safe to be cleared, remove the Owning Department lock and tags, verify the tag numbers against the LOTO Sheet and then complete the LOTO Sheet. All Affected Employees shall then be informed before the equipment is placed back into service If for some reason the Work Crew tag and lock is not cleared and the crew left the site: During normal work hours (Monday through Friday dayshift) The appropriate Work Crew representative of the area shall be contacted by Owning Department. The Work Crew representative shall be responsible for clearing the Work Crew Maintenance tag(s) and lock(s) after ascertaining that such action is safe and proper. During other times the on-duty Owning Department supervisor shall first attempt to call out the regular appropriate Work Crew representative or on-call maintenance person. If unsuccessful, the incident commander (IC) will assist with clearing the Work Crew tags and/or locks. In any case, the 4-eyes principle shall be employed to ensure that all necessary precautions have been taken before the lock/tag is removed.

14 Procedure No.: MC Page: 14 of 22 Prior to resuming any work on the equipment by the initial Work Crew, they shall be informed by the Owning Department that their previously applied locks and tags were removed The Owning Department shall file the LOTO Sheet with the Safe Work Permit if the job is complete. If the job is incomplete, the LOTO Sheet shall be retained for re-issuing on any subsequent shift. The bottom copy of the LOTO Sheet should be filed/retained with the Owning Department (top) copy. 4.2 Completing LOTO Sheet The LOTO Sheet is used to document and communicate the means to safely isolate and secure equipment to be serviced and safely return equipment back to service. The LOTO Sheet is initiated by the Owning Department. The LOTO Sheet may be filled out as the equipment is being prepared which may take more than one shift or day All applicable information shall be completed on the LOTO Sheet (hazardous energy type, magnitude, item LOTO, reason for LOTO, Tag number, etc.) The system or equipment covered by the job must be clearly identified A description of the work to be done shall be specified in the Reason for LOTO line item of the LOTO Sheet The date in the upper portion of the LOTO Sheet is to reflect the initial date that the job first started Any special instructions, hazards, or precautions associated with the equipment that has been prepared for Servicing/Maintenance shall be noted in the Special Instruction section The signature and date under Steps to Safety Isolate and Secure Equipment, in the last section on the LOTO Sheet, is used to record and indicate that the equipment preparation by the Owning Department is complete. The signature means that individual reviewed the equipment, and to the extent reasonable, the equipment was properly prepared for Servicing/Maintenance including isolated, tagged, locked out, tried and/or decontaminated, as needed. Only qualified personnel trained to operate the equipment shall perform this task All Work Crew members shall sign the Work Crew LOTO Record on the back of the LOTO sheet once they understand the isolation measures being employed and agree the job is safe to perform.

15 Procedure No.: MC Page: 15 of If more than one LOTO Sheet is required because of the number of tags/locks required, or if more signature lines for the work crew are needed, additional LOTO Sheets shall be attached to the first sheet and noted in the upper right corner of the LOTO Sheet (e.g. Page 1 of 2, etc.) Once the job is finished and all Work Crew members have signed off the Work Crew LOTO Record which is on the back of the LOTO Sheet, indicating they are no longer working on the job task in question, the Work Crew representative shall complete the Job Complete by Work Crew section of the LOTO Sheet. The signature and date in the last section on the LOTO sheet (under Steps to Safety Return Equipment back to Service ) shall be provided by the Owning Department after they ve verified and performed each step in that section. 4.3 Minimum Line Breaking Isolation Guidelines Every effort must be made to thoroughly drain, purge, vent, etc., closed systems such as piping and tanks prior to performing line breaking operations. It is recognized that the absolute elimination of all chemicals and/or hazardous energy sources cannot be guaranteed due to things such as leaking valves, pluggage, etc. Also, in some cases a nitrogen or steam purge may be added to the equipment to inert the atmosphere to make the overall job safer. These conditions must be communicated to the Work Crew via the Safe Work Permit or LOTO Sheet and appropriate safety precautions such as personal protective equipment (PPE) shall be prescribed. Note: Opening of a bleed valve does not constitute an initial break The minimum protective equipment in any Line Breaking situation shall be: Chemical, thermal and/or other appropriately protective gloves per the site s PPE hazard assessment. Full-face protection (face shield or full-faced respirator) if there is potential for splashing, spraying, or drippage on the face. Chemical goggles are required for eye irritants. In addition to the minimum protection stated above, protection for Line Breaking involving equipment that contains or previously contained corrosives, skin absorbable materials, sensitizers or materials that could pose a significant thermal hazard shall be: Chemical goggles and face shield (unless wearing a full faced respirator, fully encapsulating suit, hood or other PPE that provides equivalent protection). Chemical/thermal resistant boots Appropriate type of chemical/thermal resistant clothing that is specifically protective for the chemical of potential exposure

16 Procedure No.: MC Page: 16 of 22 When activities have the potential to drip, spray or pour downward onto individuals performing the work, additional measures may include the taping of glove/clothing openings, use of hooded clothing or other measures to ensure materials do not come into contact with the skin. PPE may not be downgraded until Line Breaking activities have been properly terminated per section Despite the precautions taken to remove the contents, personnel involved in the line breaking operation shall assume the equipment contains hazardous energy sources, which will be released when opening the equipment, and take the following precautions: A. The use of defensive positioning in order to avoid a spray or release when attempting the line break B. Breaking of flanges on the opposite side of the piping from the employee C. The use of required PPE until the line break has been completed and until the atmosphere can be verified free of hazardous contaminants D. Use of barricades and/or barrier tape to restrict access when work is elevated or over grated platforms. E. Use of splash or drain pans, as needed, to protect personnel and equipment below; and F. Coordination and communication with all groups or personnel involved in or potentially affected by the line breaking. G. De-pressurization of lines or equipment and absence of material has been accomplished, when possible, by opening vents and drains. Where present, pressure gauges should be checked for pressure readings and bleeds should be opened and cleared Owning Department personnel who perform routine Line Breaking activities which are exempt (by way of a written procedure or a job hazard analysis) from the issuance of a Safe Work Permit, must still perform/verify the precautions identified in as applicable to the activity Any relaxing of line breaking precautions (e.g. downgrading of PPE) must be approved by the Permit Issuer and documented on the Safe Work Permit only after the equipment has been verified free of hazardous energy sources by one of the following means: Testing (i.e., neutral ph of flush water) The creation of a minimum ½ air gap between flanges Establishing a purge out an open drain valve adjacent to the planned line break Atmospheric monitoring for flammable, and/or toxic gas or vapor

17 Procedure No.: MC Page: 17 of 22 Monitoring for respirable atmosphere when working on lines containing asphyxiants Other methods approved by the site appropriate for the Hazardous Material/Energy Source If a system or piece of equipment is closed and then subsequently reopened after it has undergone a line break but not put back into service, the subsequent reopening is considered a new line break and must adhere to all the requirements of the initial line break Lines in flammable/combustible service which cannot be verified as free of materials by use of a bleeder or other equivalent means shall be opened via a non-sparking means (e.g. cold cutting or drilling a hole with pneumatic or other appropriate tools) to obtain an adequate sniff. Hot Work permits, for work on the line shall not be issued until the line is verified free of materials Testing must be performed using a properly calibrated direct reading instrument or indicator on lines or equipment which may have contained flammable and/or toxic liquids or gases before and intermittently during the Line Breaking activities as appropriate for the operations. Testing parameters are stated on the permit No hot work is permitted that could have an adverse impact on Line Breaking activities performed on equipment in flammable or combustible service For work activity involving single isolation points and flammable, toxic or asphyxiant chemicals with poor warning properties, periodic or continuous monitoring should be considered as a special precaution Demolition/removal of piping and equipment, which previously contained chemicals, shall be performed using the following practices: A. Equipment shall be isolated, prepped, and cleaned following the requirements previously discussed in this section. B. All valves should be placed in the open position and all flanges broken apart to minimize the potential for trapped materials. C. Where possible, individual components (e.g. valves, instruments, gaskets, etc.) shall be removed and handled separately. This is to minimize the potential for chemicals to remain entrapped during handling and transport of the equipment. D. For equipment that previously contained skin absorbable chemicals (e.g. aniline, nitrobenzene), openings through which trapped materials can

18 Procedure No.: MC Page: 18 of Interdepartmental LOTO escape must be bagged and taped prior to moving. Clear bags must be used so that any leaked chemicals can be observed The basic LOTO procedure with a few additional steps added shall be followed for LOTO of equipment (pipelines) that is shared by more than one Owning Department The originating unit is ultimately responsible for the Equipment Preparation of the entire system. The unit originating the work shall fill out the Safe Work Permit and LOTO Sheet and shall retain ownership of the entire line/equipment until the work is complete Preparing the line/equipment, such as by washing, purging and/or depressurizing, shall be coordinated between the units involved. The originating unit shall direct this activity Piping or equipment to be locked and tagged shall be done under the direction of the originating unit, but the other Owning Departments shall install locks and tags on the equipment located in their own area. Representatives of the originating unit shall go to the other unit(s) to mutually hang the Owner locks and tags Tag numbers shall be communicated to the originating unit to place on the LOTO Sheet. Once these tags are placed, only the originating unit can authorize their removal The originating unit shall initiate and issue the LOTO Sheet for the work involved. Bottom copy of Work Crew copy of the LOTO Sheet shall be issued to the Work Crew as usual. In addition, a separate Work Crew copy of the LOTO Sheet shall be physically issued to the other unit(s) involved. In other words, the other unit(s) shall be treated as a separate Work Crew, thus providing positive communication Upon completion of the work activity, the Work Crew and the subsequent unit(s) shall sign off on their Work Crew copy in the Work Crew LOTO record section and return their Work Crew copy to the originating unit. Telephone/radio contact alone is not sufficient. When all copies have finally been released, the clearing of the locks and Owner tags shall begin. The originating unit shall then clear all locks and Owner tags. The other Owning Departments shall provide assistance in removal of the locks and tags in their area. Representatives of both units are expected to be physically present for the removal of the locks/tags in the subsequent unit(s).

19 Procedure No.: MC Page: 19 of When tags have been removed, the originating unit shall sign the LOTO Sheet as complete. 4.5 Recordkeeping All Safe Work Permits, along with the associated LOTO Sheets, Excavation permits, etc., issued to a Work Crew shall be filed for a minimum of 30 days. LOTO sheets associated with Confined Space entry must be retained along with the SWP and Confined Space Entry Permit for 1 year. 4.6 Program Review As part of the Site RCMS review process a management review of the effectiveness of the Lockout/Tagout program and Line Breaking practices shall be conducted and documented on an annual basis to ensure that the management system is properly implemented and the elements adequately control LOTO and Line Breaking activities. The review will be filed in EHS Activities application within the Lotus Notes EHS Portal. The review shall cover the following elements at a minimum: A. A comparison of the program with actual practices and corporate requirements. B. A review of incident reports involving hazardous energy source control activities, including line breaking activities that have occurred since the last annual review. C. Interviews with Permit Issuers, Authorized Employees, and other Affected Employees, including contractor employees where applicable regarding their roles and responsibilities. In addition, the following items related to line breaking practices must be reviewed: A. Inspection of at least one line breaking job, while in progress, to ensure that all applicable precautions indicated on the Safe Work Permit have been implemented in the field. B. Review of applicable maintenance and calibration records for monitoring equipment. C. Review of the Safe Work Permit and any associated paperwork (e.g. LOTO Sheet) for correctness. D. Verification of work practices in the field (as identified on the Safe Work Permit). 4.7 Review of Equipment-specific Hazardous Energy Control Procedures A representative number of equipment specific hazardous energy isolation procedures shall be reviewed annually. The review will be filed in EHS Activities. The review must be performed by an Authorized Employee who is not currently utilizing the procedures under review and shall include: A. A comparison of the procedure(s) and LOTO Sheets with existing equipment design and layout

20 Procedure No.: MC Page: 20 of 22 B. A comparison of the procedure(s) with actual implementation practices C. Review of the Safe Work Permit and any associated paperwork (e.g. LOTO Sheet) for correctness. D. Interviews with employees utilizing the procedure(s) that includes: A discussion with each employee regarding their responsibilities under the procedure(s) A discussion of any limitations of the isolation methods specified by the procedure(s) The review shall be documented with the results communicated to Affected Employees. The following minimum information must be documented: 4.8 Training A. Name of the person performing the review and the name of the employees included in the inspection; B. Date of the review; C. The identity of the equipment-specific hazardous energy control procedure and the machine or equipment on which the energy control procedure was being used. D. Findings of any deviations or deficiencies identified during the review and any associated corrective actions, which must be tracked in the Action Tracker system Owning Department personnel and Work Crew personnel associated with work performed in accordance with this procedure shall be trained to ensure the specific requirements are understood and followed. The content of the training shall include a review of the site procedure requirements including: A. Type and magnitude of hazardous energy sources that exist in the work place and means to isolate those hazardous energy sources. B. The limitations of a tagout system C. The importance of attempting to energize tagged or locked equipment D. Use of equipment specific hazardous energy control procedures E. The requirements for issuing a permit and the necessary means to safeguard against the hazards posed during these activities Personnel not directly involved in the hazardous energy control program will receive awareness training for this and other safe work practices in accordance with the EHS curriculum assignment process Training or retraining shall be provided at frequencies specified in Site Training matrix.

21 Procedure No.: MC Page: 21 of Training documentation shall include the trainee s names, date(s) of attendance, means used to verify understanding, and learning objective(s) for the course. 5. ROLES AND RESPONSIBILITIES 5.1 Owning Department Issue Safe Work Permits and LOTO Sheets in accordance with this procedure File completed permits and the associated LOTO Sheets, etc. in accordance with this procedure Ensure Authorized Employee(s) is available for the annual review of equipment specific hazardous energy control procedures Ensure that training is conducted in accordance with this procedure. 5.2 Work Crew Perform work activity as described in the procedure and in issued Safe Work Permits Assist Owning Department in performing periodic inspections as needed. 5.3 Site EHS Department Maintain, update, and interpret this procedure as needed Certify annually that this procedure is current and accurate. File record in EHS Activities application within the Lotus Notes EHS Portal Conduct annual program effectiveness review. File record in EHS Activities application within the Lotus Notes EHS Portal Ensure the annual review of equipment specific hazardous energy control procedures and line breaking activities is performed and documented in accordance with this procedure. 6. RELATED DOCUMENTS 6.1 Attachment 1, Electrical Tag 6.2 Attachment 2, Owner lock/tag 6.3 Attachment 3, LOTO Sheet 6.4 Attachment 4, Servicing/Maintenance lock and tag

22 Procedure No.: MC Page: 22 of Attachment 5, Generic Isolation Procedures 6.7 Attachment 6, LOTO and Line Break flow chart 6.8 McIntosh Safety Procedure MCC , Safe Work Permits 6.9 BASF Line Breaking Procedure, BC