Environmental, Health, and Safety

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1 Environmental, Health, and No.: BCF Page: 1 of 26 Site Representative Manager, Environ, Health & VP and Gen. Mgr., Freeport REVISION HISTORY Date Revision Details of Change Number Added Periodic Inspection Requirements in Section 8.1 Added Attachment 13 Periodic Inspection Check List

2 Environmental, Health, and No.: BCF Page: 2 of 26 Site Representative Manager, Environ, Health & VP and Gen. Mgr., Freeport 1 PURPOSE to establish minimum standard work practices and procedures for isolating Hazardous Energy Sources and otherwise disabling machines or equipment to prevent unexpected or unintentional energizing, startup, or release of stored energy that could cause personal injury or equipment damage 2 DEFINITIONS 2.1 Acceptance An acceptance signature on a Master Isolation Procedure is acknowledgement by the person signing that: The equipment specified on the isolation procedure is the equipment to be worked on. The MIP signed has the same number as the isolation tags used to isolate the equipment to be worked on. This shall be verified by auditing two or more isolation tags used for the isolation of the equipment. The owner has communicated all information needed about the isolation, lockout, and/or tag-out. The isolation procedure has a current approval signature. 2.2 Affected Employee a person whose machine or equipment is to be serviced or maintained under lockout/tag-out or a person who is working in an area which such activities are being performed 2.3 Authorized Employee A person who locks out/tags out machines or equipment or otherwise performs work on equipment subject to this procedure authorized employee and the affected employee may be the same under certain circumstances. 2.4 Contracted Employee (i.e., contractors without their company supervision on site) An individual or group of individuals for whom BASF Corporation (BC) provides direct supervision in their day-to-day activities and direction as to how an activity is to be performed. 2.5 Contractor Employee (i.e., Nestor, daily and shutdown contractors with supervision on site) An individual engaged by or through a third party to perform services principally for the third party.

3 Environmental, Health, and No.: BCF Page: 3 of 26 Site Representative Manager, Environ, Health & VP and Gen. Mgr., Freeport 2.6 Danger Tag A tag that can be placed on equipment where the use or operation of the equipment may cause injury or equipment damage. Do not use a danger tag as an isolation tag. 2.7 De-Energized Isolated or disconnected from all energy sources and containing no residual or stored energy. 2.8 Energy Isolating Device A device that physically prevents the transmission or release of energy, including but not limited to the following: manually operated electrical circuit breakers disconnect switches radiation device lockout shutters (A radiation safety officer (RSO) for confined space entries must tag these out.) a positive shutoff actuated valve if all of the following conditions are met: It is a positive shutoff device and has no leak. Note: A process control valve cannot be used as an energy-isolating device, since it is not a positive shut-off device. The fail-safe position is the desired position. The valve is disabled. The energy source has an energy-isolating device (blocking device) and is tagged out. any similar device used to block or isolate energy(e.g., blinds, pancakes with an isolation tag attached) and air gaps (>12 ) The tube sheet/tubes of an exchanger can serve as an energy isolating device for a line break as long as verification of no leakage can be accomplished. They cannot be used for isolation for hot work or confined space without a variance granted by OM and Site Team Leader. Note: Push buttons, selector switches, and other circuit type devices are not energy isolating devices. 2.9 Four-Eyes Principle The use of (two) 2 or more individuals (equipment owner and individuals(s) performing the work) to assess tasks to ensure that all hazards are identified and eliminated/controlled through safe work practices, use of PPE, communication/ awareness, etc.

4 Environmental, Health, and No.: BCF Page: 4 of 26 Site Representative Manager, Environ, Health & VP and Gen. Mgr., Freeport 2.10 Hazardous Energy Source Any source of electrical, mechanical, hydraulic, pneumatic, kinetic, chemical, thermal, radiation, or other energy, including stored, inertial, or residual energy that if unexpectedly or unintentionally released, could cause injury to personnel, or if introduced into a process could be hazardous Individual Release The initialing off on the Work Crew Accountability Form or MIP that the individual is no longer working behind the hazardous energy isolation Isolation The process of preparing and positioning of equipment or components of equipment in order to segregate them from Hazardous Energy Sources. Energy isolation must be performed in accordance with equipment specific hazardous energy control procedures and must achieve a Zero Energy State Locking/Lockout The placement of lockout device(s) on an energy isolating device, in accordance with an established equipment specific hazardous energy control procedure to ensure that the energy isolating device and the equipment are controlled to a Zero Energy State and cannot be operated until the lockout device is removed Lockout Device A device that holds an energy isolating device in a safe position and prevents the energizing of a machine or equipment until the lockout device is removed Master Isolation Procedure Hazardous energy source control procedure that one may use for control of multiple isolation points/devices. Since the Master Isolation Procedure relies primarily upon administrative means to control the release of potential hazardous energy, additional steps for verification of Zero Energy State are required to ensure that protection comparable to lockout is maintained during work this procedure covers. There must also be a mechanism to achieve personal acceptance of the lockout/tag-out by each authorized employee (WCAF).

5 Environmental, Health, and No.: BCF Page: 5 of 26 Site Representative Manager, Environ, Health & VP and Gen. Mgr., Freeport 2.16 ONE-PLUS System using a mechanism of physical protection to make equipment inoperative; intended to prevent unintentional operation of an energy isolation device when lockout cannot be or is not used. All quarter-turn piping valves that do not have a locking mechanism will use one plus to secure them. Some examples include but are not limited to: removing an isolating circuit element taking off the valve handle chaining the valve handle using a lock using tie wraps to secure a valve in the proper position taping or securing non-lockable electrical breaker devices securing equipment shafts that could be rotated while being worked on stationing a stand-by person at the equipment energy isolation device 2.17 Operating /Owning Department The BASF unit or department that operates or is responsible for the daily operation of the process, area, or facility where work is taking place. Under certain documented circumstances, individuals, departments, or companies who would not normally be considered members of the operating/owning department (i.e., service and maintenance personnel) may be authorized to perform work under the permitting exemption described in this section. The following circumstances must be met to consider such individuals as operating/owning department personnel: They must be trained and qualified to perform the subject activities. They must have a level of knowledge and experience with the operation/process (equipment, hazards, and controls) that is equal to any existing operating/owning department personnel. They are specifically authorized by the OM/SM in writing (individually/department/company as appropriate) as a member of the operating/owning department for the specific tasks they are to perform Permit Issuer Personnel who have been trained, qualified, and authorized to issue or modify permits on behalf of the operating/owning department Primary Isolating Device An isolating device that is intended to withstand the rated pressure of the equipment.

6 Environmental, Health, and No.: BCF Page: 6 of 26 Site Representative Manager, Environ, Health & VP and Gen. Mgr., Freeport 2.20 Prior Contents Includes the previous chemical contents in the equipment before clearing and any chemical agents (i.e., soda blasting, soaps, etc.) used for cleaning Qualified Electrician 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 live 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 his/her respective job assignments electrical requirements included in operating and maintenance procedures (including lock, tag, and try) use, care, and limitations of personal protective equipment (PPE) Note: The person authorizing the election to work on site will verify this. If done by contractor service, the contractor is responsible. If brought for a specific job, the person authorizing his/her use is responsible to verify his/her qualifications. No certifications are required Release A release signature on a master isolation procedure by the person who accepted the MIP who certifies that all personnel in his/her work group have stopped work, signed off WCAF, and are clear of the equipment on which they were permitted to work Tag-out The placement of an isolation tag on an energy-isolating device, in accordance with an established procedure, to indicate that the energy isolating device and the equipment being controlled may not be operated until the isolation tag is removed in accordance with established procedures.

7 Environmental, Health, and No.: BCF Page: 7 of 26 Site Representative Manager, Environ, Health & VP and Gen. Mgr., Freeport 2.24 Isolation Tag An Isolation tag and a means of attachment (tie-wrap), which is securely fastened to an energy isolating device in accordance with an established procedure, to indicate that the energy isolating device and the equipment being controlled may not be operated until the tag-out device is removed in accordance with established procedures Verification Means to ensure that isolation has been achieved for each type of hazardous energy source. Examples may include sampling with chemical indicating tubes, photo-ionization detectors or combustible gas indicators, measuring ph of wash water, checking voltage, checking equipment for potential rotation (ensure any other energy source such as wind on fans could cause them to rotate, etc.), attempting to operate a valve or switch, successful purge/flush, etc Work Crew Accountability Form (WCAF) A form that is attached to all safe work permits serving two purposes. This form is the administrative control to account for every individual working in the unit/block who has not signed on the accountability log (AL) and is the administrative control to account for every individual working behind hazardous energy isolation Zero Energy State The point where all potential hazardous energy sources have been verified to be deenergized. 3 SCOPE The requirements of this procedure apply to the BASF Freeport plant site. 3.1 This procedure applies to all activities where the potential exists for exposure to hazardous energy sources, unless specifically exempt below. 3.2 This procedure does not apply to the following: 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 the unplugging of the equipment from the hazardous energy source if the plug is under the exclusive control of the employee performing the service or maintenance.

8 Environmental, Health, and No.: BCF Page: 8 of 26 Site Representative Manager, Environ, Health & VP and Gen. Mgr., Freeport The plug is under the exclusive control of the employee if: It is physically in the possession of the employee. It is within arm s reach and in the line of site of the employee. The employee has affixed a lockout/tag-out device on the plug Activities on equipment where the energy source is not a hazardous energy source. Note: Electrical energy 50 VAC/VDC or below is not considered hazardous energy Operation and maintenance of electric power generation, control, transformation, transmission, and/or distribution lines/equipment. These tasks require specific training, work practices, and employee protection from these special hazards presented by working with energized electrical equipment not identified in this procedure Hot taps that site-developed procedures cover (Refer to BC Hot Work & BC Hot Tap Procedure.) The following procedures/processes may be exempt from a site s/unit s hazardous energy source control program if a risk assessment has been documented and approved by BASF management identifying the risks and control measures necessary to protect personnel: Activities performed by operating/owning department personnel where the work is routine, repetitive, and integral to the use of the equipment for production and under the exclusive control of the individual(s) performing the work. Exclusive control means within ten (10) feet. One example of such an activity could be changing a filter on a filter pot with integrated isolation and proper draining. (See the attached Permit vs. Procedure Flow Chart, Sec ) Note: Lab instrument servicing, maintenance and repair can qualify for this exemption by following manufacturers recommended installation, maintenance, and servicing procedures as long as the work is performed by the operating owning department. The isolation sources

9 Environmental, Health, and No.: BCF Page: 9 of 26 Site Representative Manager, Environ, Health & VP and Gen. Mgr., Freeport 4 PROCEDURE must be under the control of the servicing personnel where applicable for control of hazardous energy Routine electrical tasks involving specific equipment that must be performed in an energized state, and are conducted by a qualified electrician Removal of a plug/blind flange from a bleed valve and the operation of a bleed valve may be exempt from site s/unit s hazardous energy source control program if they are in compliance with the following items and only performed by the operating/owning department: PPE grid identifies proper PPE for bleed removal and/or bleed operation for each potential exposure condition and they are followed during each task Personnel are instructed in and use of proper defensive positioning techniques during tasks Personnel maintain direct control of bleed during the plug removal or bleed operation Loading and unloading operations performed by PST, Logistics, or the operating/owning department may be exempt from site s/unit s hazardous energy source control program if they are using a BASF manager approved TJA that covers all steps necessary to ensure that personnel are not exposed to hazardous energy during the process of loading and/or unloading Gas bottles that supply lab instruments, cutting torches, or other equipment and the person replacing the bottle can isolate the energy. 4.1 Equipment Shutdown, Preparation, and Isolation Authorization to Prepare and Approve Hazardous Energy Isolations Each department manager must designate in writing the personnel who are approved to prepare and/or approve hazardous energy isolation procedures. The employee must be knowledgeable of the system, energy sources, and other hazards associated with the equipment being isolated.

10 Environmental, Health, and No.: BCF Page: 10 of 26 Site Representative Manager, Environ, Health & VP and Gen. Mgr., Freeport Control of Work Involving Hazardous Energy Sources Personnel, excluding operating/owning department personnel when proper criteria are met ( ), shall not perform activities involving the control of hazardous energy sources without prior written authorization in the form of a safe work permit issued by a permit issuer. The applicable equipment-specific hazardous energy control procedure(s) shall, at a minimum, be referenced on the permit. To meet the requirements of the four eyes concept, the permit issuer and the permit accepter cannot be the same person Zero Energy State Verification Perform all activities, to the extent possible, under a zero energy state that has been verified, at a minimum, by operating/owning department personnel. For permitted work, verification of zero energy state shall be documented on the permit. When zero energy state verification is not possible, use proper PPE and/or additional administrative/engineering controls to minimize exposure to hazards Communication Before the performance of activities subject to this procedure, the operating/owning department shall notify all affected employees of the work activities and any potential hazards/consequences associated with the work. In addition, all affected employees shall be notified before placing equipment back into service New and Replacement Equipment Whenever replacement, major repair, renovation, modification of a machine or equipment is performed, and whenever new machines or equipment are installed, energy isolating devices for such equipment shall be designed to accept a lockout device. All new and replacement quarter-turn piping valves shall be designed to accept a locking mechanism Equipment Specific Hazardous Energy Control Procedures All activities subject to the requirements of this procedure shall be performed by the owning/operating department using written equipment specific hazardous energy control procedures. These procedures shall be prepared for each piece of equipment or for each group for similar equipment (i.e., equipment with similar energy source type/magnitude and similar isolation requirements).

11 Environmental, Health, and No.: BCF Page: 11 of 26 Site Representative Manager, Environ, Health & VP and Gen. Mgr., Freeport The format and structure of the procedures are not mandated. Examples of acceptable procedures may include operating procedures, written job instructions, total job analyses, maintenance procedures, master isolation procedures, or equipment drawings, depending upon the complexity of the equipment. A checklist or equipment drawing can be used to supplement a generic procedure if it provides the required information Exemption Equipment-specific energy control procedures are not required if all of the following eight conditions are met: The equipment has no potential for stored or residual energy or reaccumulation of stored energy after shut down that could endanger employees. Equipment has a single hazardous energy source that one can readily identify and isolate. The isolation and locking out of the hazardous energy source will completely de-energize and deactivate the equipment. The equipment is isolated from the hazardous energy source and locked out during service/maintenance. A single lockout device will achieve a locked out condition. The lockout device is under the exclusive control of the authorized employee performing the service or maintenance. The service/maintenance does not create hazards for other employees. The site/unit has had no incidents involving the unexpected activation or re-energization of the equipment during service/maintenance Specifications for Equipment-Specific Hazardous Energy Control Procedures Written equipment specific hazardous energy control procedures shall, at a minimum, include the following elements: identification of the covered equipment or group of equipment a list of the specific types and magnitudes of hazardous energy sources specific steps, with proper sequence if necessary, for safely shutting down, isolating, blocking, positioning, and/or otherwise securing the equipment identification of the safe position for energy isolation devices

12 Environmental, Health, and No.: BCF Page: 12 of 26 Site Representative Manager, Environ, Health & VP and Gen. Mgr., Freeport specific steps necessary for safely releasing any stored or contained hazardous energy sources specific methods (i.e., lockout devices, one- plus/tag plus, etc.) and isolation location(s) necessary for achieving zero energy state isolation specific steps and methods for verification must include when the sequence of returning equipment to service has impact on safety the sequence Owning/operating department lockout devices and tags shall be the first tags applied in the procedure and the last removed Guidelines for Equipment-Specific Hazardous Energy Control Procedures When writing equipment specific hazardous energy control procedures use the following when applicable: Electrical power sources must be shut down. Process, utility, and feed and/or discharge sources must be drained, de-pressured, purged, flushed, or cleaned as much as possible to effectively remove the potential for injury. Additional precautions could include the blinding or physical disconnection of lines and/or lockout of valves. Hydraulic pressure sources must either be completely de-pressured, or adequate blocking devices must be placed to prevent unintentional movement of the equipment. Inertial energy identification and verification steps must be taken. Proper Isolation of systems with remote start capabilities, including the ability of such systems to have multiple methods for energizing equipment (i.e., field start/stop and DCS), must be in place. Capacitors shall be fully discharged or removed. On equipment and controls that operate on circuits in excess of the 480 volt rating, lockout shall be accomplished by disconnect and/or breakers opened, racked out, and tagged. A qualified electrician shall verify. If re-accumulation of stored energy can occur, verification of isolation will continue until work is complete or until such re-accumulation hazards no longer exist. Reference BCF Confined Space Entry and BCF Line Breaking.

13 Environmental, Health, and No.: BCF Page: 13 of 26 Site Representative Manager, Environ, Health & VP and Gen. Mgr., Freeport Electrical Lockout additional requirements A lock must be used as a one-plus on electrical energy isolating device by operating/owning department and any work crew that has the potential to touch an un-insulated conductor or a moving part that would be driven by an electrical motor. One lock per crew/safe work permit. An Isolation tag must be hung on the lock to indicate who hung the lock and who is authorized to remove the lock. The lock does not need to be a specific color or unique key. The lock and tag do not need to be listed on the MIP Considerations for Verifications Equipment interlocks, where applicable, must be verified that they are not preventing or interfering with the proper verification of Isolation. If work is being performed on mechanical parts only (gearbox, seal, belt, fan, etc.), verification of electrical isolation must be by a means that provides a direct indication of power that is not affected by an interlock or shutdown. A light, screen, display, or voltage reading directly off the power source that have written approval by an Authorized Qualified Electrical Person (See #10.) are acceptable examples, but 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. If work is being performed on electrically operated devices in such a manner that failure to de-energize the circuit could put workers into contact with exposed, live circuits (unwire motor, switch gear parts, switch replacement, etc.), a qualified electrical person shall test voltage to verify that the power is de-energized. Other methods may be necessary to determine if energy sources have been isolated. 4.2 Permission to Work Work Authorization (See attached Permit vs. Procedure Flow Chart, Sec ) The safe work permit must include an isolation procedure for the equipment to be worked on. The isolation procedure can be a drawing, P&ID, or descriptive text and must: Be approved by an authorized employee

14 Environmental, Health, and No.: BCF Page: 14 of 26 Site Representative Manager, Environ, Health & VP and Gen. Mgr., Freeport Be included in the safe work permit or MIP Identify the equipment Identify specific types and magnitude(s) of energy potential included in isolation Specific steps with proper sequence for safely shutting down, isolating, blocking, positioning, and/or otherwise securing the equipment Show/identify each energy isolation point and indicate the method of isolation to be used at each point, i.e., valve open/closed, pancake, double block and bleed, etc. Specific steps necessary for safely releasing any stored or contained hazardous energy sources. Identify the verification method required to ensure that isolation has been achieved for each type of energy source, i.e., valve(s) open/closed, blinds/pancakes in place, MCC off, start/stop switch (es) off, LEL/O 2 checks, CO or NO 2 checks, etc. Include specific steps and sequences necessary to safely return the piece of equipment to service. Include RSO sign-off for nuclear device isolation for CSE. Include the date, approval signature, and master isolation procedure number (if applicable). Attach it to the safe work permit if not using a MIP. If a MIP or SWP is not used, the isolation procedure must be placed in a designated location Worker or Crew Leader Responsibilities Before Work When the equipment has been properly isolated per department procedures, the person performing the work, or the crew leader, will for himself and/or his crew determine that the provisions of the site/department procedures have been properly applied and: Attach an isolation tag to each energy isolation device on the equipment to be worked on, or sign Acceptance on the respective master isolation procedure(s). Obtain a safe work permit before performing any work Changes Made to MIP after Work has Begun When work is in progress, and changes need to be made to the isolation procedure, the following steps must be taken: Remove employees from any work covered by the isolation procedure. Have employees sign off (release) the existing master isolation procedure and WCAF portion of the SWP if one is in effect.

15 Environmental, Health, and No.: BCF Page: 15 of 26 Site Representative Manager, Environ, Health & VP and Gen. Mgr., Freeport Change the isolation and revise the isolation procedure documentation, safe work permit, and/or master isolation procedure. Communicate the changes to affected workers. Have employees sign on (acceptance of) the WCAF portion of the SWP/MIP, if one is in effect, before resuming work Test/Position of Equipment For situations in which lockout/tag-out devices must be temporarily removed from the lockout device and the machine or equipment energized to test or position the machine, equipment, or component, the following sequence of actions will be followed: Approval must be obtained from representatives the operating/owning department and authorized employees. Machines or equipment must be cleared of non-essential tools and materials and assurance made that components are operationally intact. Have employees sign off (release) the existing master isolation procedure and WCAF portion of the SWP, if one is in effect. Testing shall be performed in the sequence: Remove the work crew tags first. Then remove the operating/owning department tags. The operating/owning department will then restore all valves, switches, etc., to their normal operating positions and perform the test. Equipment/machines must be de-energized, and energy control measures previously in place must be restored before servicing activities may resume. After test, energy(s) that were re-energized must be verified again and signed off as verified on next revision. Energy(s) that were not touched may be just carried down with ditto marks under verified columns. Have employees sign on (acceptance of) the WCAF portion of the SWP/MIP, if one is in effect before resuming work Removal of Tags after Completion of Work All tags shall be removed by the person(s) who applied them or the designated representative upon completion of work. After verification that all work is completed and MIP is signed off, all operating/owning department tags shall be removed by an authorized employee from the operating/owning department. In the case in which a tag has not been removed and the MIP has not been signed off by the person who applied it or the owner cannot be identified, the operating/owning department operations team leader may remove the tag only

16 Environmental, Health, and No.: BCF Page: 16 of 26 Site Representative Manager, Environ, Health & VP and Gen. Mgr., Freeport upon positive verification that the employee responsible for the lockout/tagout is not available and that the removal will not create an unsafe condition. All affected employees shall be informed before equipment is placed back into service. 4.3 Lockout Devices Lockout devices must have positive identification as to ownership by department or individual and shall not be used for any other purpose. This will be met by attaching an isolation tag to each lockout device If an energy-isolating device is designed for a lockout device, the isolation tag will be attached at that point One-plus is the minimum tagging/tag-out requirement for an energy isolating device that has the potential for unexpected or unintentional operation. All quarter-turn piping valves must use one-plus for isolation if they do not have a locking mechanism An isolation tag shall be attached to the energy isolating device. Where the tag cannot be placed directly on the energy isolating device, it must be located as close as safely possible to the device in a position that would be immediately obvious to anyone attempting to operate the device. 4.4 Isolation Tags Isolation tags are to be used, as applicable, with lockout devices and one-plus restraint methods to ensure the integrity of the isolation One-plus must be used with the isolation device if the energy isolating device has the potential for unintentional operation. All quarter- turn piping valves without a locking mechanism must use one-plus Isolation tags must be the only tag used for controlling energy and shall not be used for any other purpose. Note: A printer version of this tag is available for use with automated red tag programs Isolation tags must be placed directly on lockout devices or on energy isolating devices.

17 Environmental, Health, and No.: BCF Page: 17 of 26 Site Representative Manager, Environ, Health & VP and Gen. Mgr., Freeport Isolation tags must include: equipment number/identification: Note: This can be achieved by reference to MIP or listing on the tag. The reason for tagging. Name, date, and department of person attaching the tag. Person/position authorized to remove the tag All isolation tags must be attached with a fastener that is non-reusable, attachable by hand, self-locking, and non-releasable with a minimum unlocking strength of fifty (50) pounds The isolation tags must be capable of withstanding inadvertent or accidental removal and be capable of tolerating the environment and time period in which they will be used Isolation tag information must be legible and able to withstand environmental conditions In-use isolation tags must be updated if they are no longer legible but do not have renewal requirements based on time Equipment owners are responsible for assuring that all isolation tags are removed from equipment before that equipment is physically removed for maintenance, demolition, etc Isolation tags must be disposed of, after removal, in a trash/waste container or another location designated by the unit by the person(s) removing the tag(s) Any isolation tag that is found on the ground or dislodged from where it was hung must be immediately investigated to prove that it is not part of an active isolation. If the tag was part of an active isolation, it must be re-attached and a near-miss incident report created to track and address the issue. 4.5 Master Isolation Procedure (MIP) System A master isolation procedure (MIP) can be used to control the lockout and/or tag-out of multiple isolation points as long as it will afford both the authorized and affected employees protection comparable to that of individual lockout

18 Environmental, Health, and No.: BCF Page: 18 of 26 Site Representative Manager, Environ, Health & VP and Gen. Mgr., Freeport devices All hazardous energy sources must be isolated as per the requirements of this procedure before implementing and authorizing work under the protection of an MIP The person completing, and authorizing work under a MIP must verify that all hazardous energy sources are properly isolated and that verification methods have been performed An approved isolation procedure shall be on or attached to the respective MIP(s) The MIP number shall be written on all isolation tags used for the isolation. The unique number on the top of the MIP form must be used and another number or name not substituted for it Safe work permits must reference the number of the MIP(s) controlling the isolation for the respective job(s). The person doing the work, or crew leader, will sign acceptance on the MIP to indicate that he/she is performing work under the protection of the MIP Lockout devices or isolation tags on equipment or on energy isolating devices referring to a MIP number cannot be removed until the respective MIP has been checked, and all personnel have signed off the MIP Individual authorized employees must be given the opportunity to personally verify isolations if they choose Approval of all MIPs must be by an authorized person, department, or company by OM/SM of the area Additional sheets must be attached to the original MIP if more sign-on locations are needed. Attachment F must be used, and the header must be filled out If a MIP is not used for isolation, every worker associated with the job/task must attach his/her personal tag to every energy isolating device Verification of energy isolation (zero energy) is separated into 3 sections to aid in multiple departments performing parts of the overall energy isolation verification. (Non-electrical isolation verification, Electrical isolation verification,

19 Environmental, Health, and No.: BCF Page: 19 of 26 Site Representative Manager, Environ, Health & VP and Gen. Mgr., Freeport Power Distribution isolation verification) Verification of an MIP may be carried out by three separate entities or just one depending on the isolation energy sources and verification methods. 4.6 Work Crew Accountability All workers are required to be in control of the hazardous energy sources. The work crew accountability form (WCAF) serves as the administrative control to ensure the safety for every individual working behind hazardous energy sources. If the permit acceptor and signer of the MIP is the same person, he/she is not required to sign on the WCAF The WCAF will be a part of safe work permits that involve hazardous energy isolation and/or line breaking activities. Additional WCAF sheet(s) may be attached if needed The WCAF must reference all associated MIPs or energy isolations if the WCAF is on a separate sheet from the permit The permit acceptor will be responsible for ensuring that all affected workers sign on and off the WCAF The permit acceptor may not sign off (release) the MIP if all affected workers have not signed off the WCAF If an authorized worker forgets to sign off the WCAF or MIP and is not available, all reasonable efforts must be made to contact that specific worker. If that specific worker cannot be located, the owning department may initial off the worker after a thorough physical inspection of the work-site/equipment has been performed, and it has been determined that the equipment can be safely operated. If a worker has been initialed off the WCAF by the owning department, that specific worker or his/her supervision must be informed before he/she resumes work. 4.7 Job Completion Upon job completion, tags must be removed. If a MIP is in use, the "Release" section must be signed and the job status box checked complete If the job is not complete, tags can be left in place. If a MIP is in use, the "Release" section must be signed and the job status box checked Incomplete.

20 Environmental, Health, and No.: BCF Page: 20 of 26 Site Representative Manager, Environ, Health & VP and Gen. Mgr., Freeport 5 OTHER TAGS 5.1 Danger Tags (See the Attachments section for tag design.) Danger tags are used to convey information on hazards where the use or improper operation of equipment may cause personal/environmental injury or equipment damage. They should be used for notification and securing of damaged equipment, air mover valve position, and/or transmission/security of any other condition that could pose a safety risk to anyone Danger tags must indicate the: name, date, and department of person attaching the tag reason for tagging person/position authorized to remove the tag Equipment with a danger tag attached must follow all instructions on the tag Only the authorized person or position designated on the tag is authorized to remove the tag. If he/she is not available, the operations team leader may authorize removal after it has been determined that it is safe to do so Danger tags must remain legible at all times, but there are no renewal requirements based upon time. 5.2 Process Information Tags (See the Attachments section for tag design.) Process Information tags are used to convey process information. They can show material status, equipment out of service, or any specific instructions needing to be communicated at a given position in the process. A comment section is provided for more detail info. Check boxes are provided near the edge of tag to allow for holepunching for long-term tagging. No time based renewal requirements apply to this tag. 5.3 Relief Device Removal Tags (Pink) (See the Attachments section for tag design.) The relief valve removal tag(s) are used to indicate that a piece of equipment (i.e., pressure relief device) has been properly cleared and isolated and is ready to be removed. No relief device shall be removed unless it has a relief device removal tag attached.

21 Environmental, Health, and No.: BCF Page: 21 of 26 Site Representative Manager, Environ, Health & VP and Gen. Mgr., Freeport The relief device removal tag(s) shall be hung after the verification of isolation has been completed for that piece of equipment. The relief device removal tag(s) shall specifically identify the piece of equipment that will be removed (i.e., relief valve number). The equipment numbers shall match at all three places: o the equipment to be removed o the relief device removal tag o the equipment number description on the safe work permit An authorized safe work permit writer shall hang the relief device removal tag and may hang it during the Four Eyes process of permitting. The relief device removal tag(s) shall be returned to the control room with the safe work permit. This tag may be removed by the permitted crew removing the piece of equipment or any authorized permit writer. 6 VIOLATIONS Violations of tagging and/or hazardous energy control procedures must result in disciplinary action up to and including termination of employment. 7 TRAINING 7.1 General Each department shall provide training to ensure that the purpose and function of this procedure is understood and that adequate knowledge and skills are developed and maintained for the safe application and removal of energy isolation techniques. 7.2 Training Content BASF and contracted employees performing work as authorized employees shall receive training on the following: content of this standard (SS#12) recognition of applicable hazardous energy sources and their hazards type and magnitude of energy sources in the workplace use of adequate methods and means to control these sources and the limitations of a tag-out system

22 Environmental, Health, and No.: BCF Page: 22 of 26 Site Representative Manager, Environ, Health & VP and Gen. Mgr., Freeport that tags are essentially warning devices affixed to energy isolating devices and do not provide the physical restraint that a lock provides on those devices that when a tag is attached to an energy isolating device, it is not to be removed without authorization of the person responsible for it and it is never to be bypassed, ignored, or otherwise defeated that tags must be legible and understandable by all employees that tags may evoke a false sense of security, and their meaning needs to be understood as part of the overall hazardous energy control program use of equipment specific hazardous energy control procedures the requirements for issuing a permit and the necessary means to safeguard against the hazards posed during these activities BASF and contracted affected employees shall receive training in: the purpose and use of the site energy control program and how it may affect their specific work operation. the limitations of a tag-out system (See for details.) BASF and Contracted Not Directly Involved in the Site s Hazardous Energy Control Program: 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. 7.3 Training Frequency for Affected Employees and Authorized Employees Training shall be delivered in accordance with the EHS curriculum assignment process. Retraining of an employee is required whenever: o There is a change in job assignment affecting the level of participation in the program (i.e., an employee changes from an affected employee to an authorized Employee). o Deviations or inadequacies in an individual s performance of an applicable procedure indicate that lack of knowledge is a cause. o An applicable equipment specific hazardous energy isolation procedure has been changed because of equipment or process changes or when a new hazard is introduced.

23 Environmental, Health, and No.: BCF Page: 23 of 26 Site Representative Manager, Environ, Health & VP and Gen. Mgr., Freeport 7.4 Documentation for BASF and Contracted Employees Training will be documented including: o each trainee's name o date(s) of attendance, o means to verify understanding o learning objectives for the course Documentation shall be maintained according to BC037, Record Retention Policy, and the applicable record retention schedule. 7.5 Contractor Employees Refer to BC , Contractor EHS Qualification and Oversight, for requirements. 8 Management System Review 8.1 Site Review of Program Site shall review the effectiveness of the site s program at least annually to ensure that the management systems are properly implemented and that the elements adequately control exposures to hazardous energy sources. As a minimum, the following management system elements shall be included in the review: a review of the site safety standard to ensure that all currently required corporate requirements are included a review of incidents on site that involve the failure to control hazardous energy sources since last annual review A representative number of equipment specific hazardous energy isolation procedures shall be reviewed annually Each unit needs to determine the number of Equipment Specific Isolation Procedures that need to be reviewed on an annual basis based on the number of equipment specific isolations preformed in a year. For example, a unit performs 100 isolations in a year, they determine 10% of these isolations would accurately represent the 100 equipment specific isolations. Therefore, the unit should have 10 Periodic Inspections performed annually Each unit will need to complete the periodic inspections for the Equipment Specific Isolation Procedures using the Control of Hazardous Energy Periodic Inspection Check List (Attachment 13).

24 Environmental, Health, and No.: BCF Page: 24 of 26 Site Representative Manager, Environ, Health & VP and Gen. Mgr., Freeport Completed Checklist, Control of Hazardous Energy Documentation, and Action Plan to correct Deficiencies found need to be retained for Current year plus 2 or duration of the Audit period whichever comes first An authorized employee who is not currently using the procedures under review must perform the review. The audit shall include: a comparison of the procedure(s) with existing equipment design and layout at least one each on line breaking and electrical energy sources a comparison of the procedure(s) with actual implementation practices interviews with authorized employees who use the procedure(s) that include: o a discussion of with each authorized employee regarding his/her responsibilities under the procedure(s) A discussion of any limitations of the isolation methods specified by the procedure(s) certification that the review has been performed with documentation of the following: o name of inspector and employees included in the inspection o o date of inspection equipment-specific hazardous energy control procedure inspected and the machine or equipment on which the energy control procedure was being used findings and corrective action, where applicable, of any deviations or deficiencies identified during the review The review shall be documented and reported to MAT. Note: For an example, see the Safe Work Practices Management Review Checklist located as an attachment in the related documents section of corporate standard BC Unit Review Requirements Notify site safety of all incidents involving the failure to control hazardous energy sources. Site must be notified of these incidents to meet annual review requirements. 8.3 Action Item Tracking Corrective actions resulting from the reviews shall be tracked to completion using a tracking system and must be communicated to all authorized and affected employees.

25 Environmental, Health, and No.: BCF Page: 25 of 26 Site Representative Manager, Environ, Health & VP and Gen. Mgr., Freeport 9 RESPONSIBILITIES 9.1 Site Manager The Site Manager has responsibility for ensuring the implementation of this procedure. 9.2 /Industrial Hygiene Team Leader The Team Leader of the Site Team has the primary responsibility for issuing, reviewing, administering, and/or interpreting this procedure. 9.3 Operations and Service Managers Implement the requirements of this procedure. Ensure that the requirements are being followed in their areas of responsibility. Ensure that training is provided as per requirements. Ensure that identified deficiencies are corrected and forwarded to site for review. Authorize, in writing, personnel, departments, and companies who can prepare and approve equipment isolation procedures in their areas. Verify that they have training on this and other applicable BASF safety standards and have procedures to comply with them. Verify that they are trained and qualified to perform the subject activities Verify that they have a level of knowledge and experience with the operation/process (equipment, hazards, and controls) that is equal to any existing operating/owning department personnel. 9.4 Permit Writer Ensure that all applicable requirements in this standard are met before issuing a SWP. When issuing a SWP to a designated owner/operator, verify that he/she has procedures to meet the requirements of this standard, just as if he/she were the normal owner/operator. (i.e., MIP, TJA, SOP, that addresses all aspects of this standard) 9.5 Employees Prepare and approve isolation procedures if authorized. Isolate and verify isolations of equipment per procedure/requirements. Assign/issue MIPs. Communicate the following to the MIP acceptor:: o positive I.D. of equipment o isolation and method(s) used

26 Environmental, Health, and No.: BCF Page: 26 of 26 Site Representative Manager, Environ, Health & VP and Gen. Mgr., Freeport o o verification (testing) methods used any known potential hazards, safety precautions, and requirements for the job 10 RELATED DOCUMENTS OSHA 29 CFR (control of hazardous energy) OSHA 29 CFR (electrical safety references) BC Lock, Tag, and Try BCF Line Breaking BCF Confined Space Entry BCF Safe Work Procedures 11 ATTACHMENTS Attachment 1 - Master Isolation Plan (MIP) Attachment 2 - MIP Additional Sign-on Sheet Attachment 3 Control of Hazardous Energy Sources Review Checklist Attachment 4 Work Crew Accountability Form (WCAF) Attachment 5 - Isolation Tag Attachment 6 - Danger Tag PVC Attachment 7 - Process Information Tag PVC Attachment 8 - Blind Installed Tag PVC Attachment 9 - Permit vs. Procedure Flow Chart Attachment 10 - Sample TJA for LOTO Exemption Attachment 11 - TJA Exemption Criteria Attachment 12 - Relief Device Removal Tag Attachment 13 Periodic Inspection Check List