Wyandotte Site Function: Ecology, Health & Safety Procedure No.: WYN Page: 1 of 25

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1 Procedure No.: WYN Page: 1 of 25 Preparer: Owner: Approver: EHS Hub Team Leader, Occupational Safety/Industrial Hygiene EHS Hub Team Leader, Occupational Safety/Industrial Hygiene EHS Hub Manager Revision History Revision Date Revision Number 07/08 0 6/11/ //15/16 5 Details of Change Original standard from updates to 2008 Corporate Confined Space Standard Minor revision removed site requirement to maintain a list of confined spaces Site standard revised based on 2011 changes to Corporate Safe Work Standard (refer to Safety and Health Alert dated June 6, 2011 for specific changes). Safe work permit also revised based on 2010 management review and stakeholder dialogue. Changes align with Corporate Confined Standard as well as include guidelines for Riding an Elevator Car. Added roles and responsibilities along with hazard assessment and evaluation tools. Clarifies monitoring requirements for BASF personnel and contractors, including initial and continuous monitoring using direct reading personal monitoring equipment.

2 Procedure No.: WYN Page: 2 of PURPOSE To establish minimum standard work practices and procedures for entering and working within Confined Spaces, Wyandotte site personnel, Contractor Employees and Contracted Employees. On the Wyandotte site all identified confined spaces are to be treated and classified as Permit-required Confined Spaces (PRCS), as referenced in the Federal and state plan standards (29 CFR and MIOSHA Part 90 and 490); regardless of the fact that the space may not meet the regulatory definition of a PRCS In addition, the BASF Wyandotte site does not allow for Alternate Entry Procedures (c) (5) spaces and permit space reclassification (c) (7) which are not recognized by BASF Corporate policy. 2. DEFINITIONS 2.1. Attendant An individual stationed outside one or more Confined Spaces who monitors the Authorized Entrant(s) and who performs all Attendants duties required by the site Confined Space Entry program Authorized Entrant An individual who is authorized, by the site s Confined Space Entry program, to enter into a Confined Space Bodily Enter For the purpose of a Confined Space evaluation, means that a potential Authorized Entrant's entire body (including head, torso, and all extremities) can pass through an opening and fit within the space in question and perform the assigned work Contractor/Agency A company which will be either placing or bringing Contractor(s), Temporary Employee(s) or Contractor Employee(s) onto a BC site Contracted Employee A Contracted Employee is an individual or group of individuals for whom BC provides direct supervision in their day-to-day activities and direction as to how an activity is to be performed Contractor Employee An individual engaged by or through a third party to perform services principally for the third party and for whom BC does not provide direct supervision in their day-today activities and direction as to how an activity is to be performed.

3 Procedure No.: WYN Page: 3 of Confined Space A space, (such as tanks, vessels, silos, storage bins, hoppers, vaults, pits, ditches and sewers) that: 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 Limited or Restricted Means of Entry or Exit The inability to walk upright through a space entrance and or has significant obstructions within the space that would impede an entrant s ability to exit the space Entry The action by which a person passes through an opening into a Confined Space. Entry includes ensuing work activities in that space and is considered to have occurred as soon as any part of the entrant s body breaks the plane of an opening into the space Entry Supervisor The person (such as supervisor, resource personnel, operations owner or crew leader) responsible for determining if acceptable Entry conditions are present at a Confined Space, authorizing Entry, and overseeing Entry operations. NOTE: An Entry Supervisor also may serve as an Attendant or as an Authorized Entrant, as long as that person is trained and equipped as required for each role he or she fills. Also, the duties of Entry Supervisor may be passed from one individual to another during the course of an entry operation Explosive Atmosphere A range of concentrations of gases, dusts, or fibers with air that can support ignition. The range of concentrations is material-specific. The range for a material can vary based on pressure, temperature, and oxygen content Hazardous Atmosphere An atmosphere that may expose personnel to the risk of death, incapacitation, and impairment of the ability to self-rescue, injury, or acute illness from one or more of the following causes: Flammable gas, vapor or mist in any detectable concentration using a calibrated combustible gas indicator operating in the percent range of sensitivity. Airborne combustible dust at a concentration that meets or exceeds its lower flammable limit. This concentration may be approximated as a condition in which the dust obscures vision at a distance of 5 feet (1.52 m) or less. Atmospheric oxygen concentration below 19.5 percent or above 21.0 percent.

4 Procedure No.: WYN Page: 4 of 25 Atmospheric concentration of any substance that could result in employee exposure in excess of its occupational exposure limit. Any other atmospheric condition that is immediately dangerous to life or health. Note: Refer to attachment # 1 - BASF Exposure Assessment Occupational Exposure Limit Reference Value Determination in establishing acceptable occupational exposure limits in Section 6 Related Documents Immediately Dangerous to Life or Health ( IDLH ) Any condition that poses an immediate or delayed threat to life or that would cause irreversible adverse health effects or that would interfere with an individual s ability to escape unaided from a permit required space. An example is an oxygen deficient atmosphere containing less than 19.5 percent oxygen by volume. (Refer to the NIOSH Pocket Guide to Chemical Hazards for IDLH limits for toxic chemicals which is available from NIOSH.) Operating/Owing Department The BASF unit or department that operates or is responsible for the daily operation of the process, area, or facility where work is being conducted Monitoring The process by which the hazards the entrants may encounter in the space, are identified and evaluated using direct-reading instruments of other equipment Permit Revalidation The process of reviewing the work conditions specified on an existing permit(s), with a Permit Acceptor or a member of the work crew, to ensure the scope, conditions and safety precautions listed on the existing permit have not changed Permit System The site's written procedure for preparing and issuing permits for Entry and for returning the permit space to service following termination of Entry Rescue Service Personnel designated to rescue persons from Confined Spaces Retrieval System Equipment including (retrieval line, chest or full-body harness, wristlets if appropriate and a lifting device or anchor) used for non-entry rescue of persons from permit spaces.

5 Procedure No.: WYN Page: 5 of SCOPE This procedure applies to BASF Wyandotte Facility located in Wyandotte, MI. On the Wyandotte site all identified confined spaces are to be treated and classified as Permitrequired Confined Spaces, as referenced in the Federal and state plan standards (29 CFR and MIOSHA Part 90 and 490); regardless of the fact that the space may not meet the regulatory definition of a PRCS. In addition, the BASF Wyandotte site does not allow for Alternate Entry Procedures (c) (5) spaces and permit space reclassification (c) (7) which are not recognized by BASF Corporate policy. However under special circumstances and with approval from the Wyandotte EHS group and the owning group the Wyandotte site will consider alternate entry procedure outlined in MIOSHA Part 90/490. This Wyandotte Site Confined Space Entry procedure does not apply to: Construction related work activities regulated by 29 CFR 1926 subpart P Excavations or MIOSHA Construction Safety Part 9 Excavation, Trenching & Shoring. All elevator work at the Wyandotte site will require a confined space permit if the space meets the definition of a confined space and has one or more of the characteristics of a hazardous atmosphere as described under 2.12 of this procedure. 4. PROCEDURE 4.1. General Requirements/Information Each Operating/Owning Department at the Wyandotte site shall evaluate the workplace to determine if any spaces meet the definition of confined space as defined in Section 2 and Section This assessment is not required to be documented Evaluation Each Confined Space must be evaluated to determine the potential for hazards according to the intended service or use, not after a given hazard(s) has been eliminated or controlled. If any of the following apply, these Confined Spaces may only be entered by the issuance of a Confined Space Entry Permit. Does the confined space contain or have the potential to contain a Hazardous Atmosphere (such as, previously contained flammable, combustible, acidic, caustic, or toxic materials) or where oxygen enriched or deficient atmospheres or noxious odors may exist. Does the confined space contain a material that has the potential for engulfing an entrant? Does the confined space have an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller crosssection? Does the confined space contain any other recognized serious safety or health hazards; such as ionizing radiation, electric shock, temperature, or moving parts

6 Procedure No.: WYN Page: 6 of 25 Each group on the Wyandotte site is encouraged to have a written confined space evaluation as part of their unit addendum to the Wyandotte site program that includes how and which spaces have been identified as confined spaces. Refer to WYN B for an example of an evaluation tool. In addition each unit/group is required to maintain a list of confined spaces specific for their area. Any changes will require a review by the EHS group Confined Space Identification Each Operating/Owning Department shall inform exposed personnel, by posting danger signs or by other equally effective means, of the existence and location of the danger posed by the location s Permitted-required Confined Spaces. Other acceptable means of informing exposed employees of the existence and location of the dangers posed by the permit spaces, include but are not limited to; computer based training (CBT), unit safety meetings, or similar communication means Authorization Only properly trained and authorized personnel may enter confined spaces. Confined spaces will only be entered using an approved confined space permit which follows the following procedure: If the initial evaluation of the space was yes to any question in Section of the evaluation, then a Confined Space Entry Permit is required. If the initial evaluation was no to ALL of the questions in the Section, of the evaluation, then entry may be authorized through a Safe Work Permit process, provided that initial air monitoring of the space is conducted using properly calibrated and maintained direct-reading instruments or equipment. If it is necessary to enter the space to eliminate or determine a hazard via monitoring or inspection, a confined space entry permit and requirements of this procedure are required Permit System Each facility shall establish a written site program for confined space entry that includes: Identification, communication and training of Confined Spaces, Issuance, use, and cancellation of Confined Space permits. Authorization and cancellation for entry into Confined Spaces. And the other elements required by this standard. Other elements of a written program include, but are not limited to, the following; the roles and responsibilities for entry supervisors, entrants and attendants for the permitting process. Refer to the Roles and Responsibilities section of this procedure for specific duties of the various

7 Procedure No.: WYN Page: 7 of 25 jobs associated with confined space entry, including entrant, attendant, entry supervisor, owning department and maintenance department. Multi-Employer Coordination BASF is responsible for ensuring that any confined space work done onsite is properly managed as part of the confined space entry work permit process. Prior to work being started, a pre-planning meeting will be held to evaluate the qualifications of all parties involved. In addition, BASF will require a Pre-Task Plan (PTP) prior to any confined space work being initiated. BASF personnel will issue confined space permits for all work performed by BASF owned facilities on the Wyandotte site. Note: A 3 rd party contractor may also issue their own permit to manage the confined space for their personnel. In those situations where a contractor issues their own permit then they are required to also conduct initial air monitoring on their permit. Prior to BASF personnel issuing a confined space permit, a Safe Work Permit will also be issued by the Process Owner; including, documentation of air monitoring results. Due to different work activities in the space, separate Safe Work Permits will be required for each work activity and/or company. The Process Owner is responsible for coordinating entry operations with the Contractor(s), when both BASF and/or multiple Contractor personnel will be working in or near Confined Spaces simultaneously as Authorized Entrants. This coordination is necessary so that employees of one employer do not endanger the employees of any other employer Employee Participation Within the BASF Wyandotte site, all Wyandotte s stakeholders and contractors will be involved in the development and implementation of the Confined Space standard. Where contractors are performing work on the Wyandotte site, they will follow both the BASF Wyandotte Site procedure, as well as, the BASF Corporate Confined Space Standards without exception. Information and input on the Wyandotte standard may include any of the following information, including but not limited to, the following: Safety meetings Rescue service drill critiques Employee suggestion programs Accident/incident report investigation follow-up and Training sessions.

8 Procedure No.: WYN Page: 8 of Confined Space Preparation Cleaning and Decontamination Prior to entry, all Confined Spaces that may have contained a hazardous material or hazardous atmosphere should be cleaned of prior contents by washing, steaming, neutralizing, purging or other effective means to eliminate or minimize the hazard within the space. Work within Confined Spaces that contain contaminated equipment shall be decontaminated in accordance with the Wyandotte Contaminated Equipment procedure in WYN If product or other material remains in the vessel after cleaning, careful review of the situation by the Owning/Operations department and the maintenance group is required to identify special provisions (e.g., re-cleaning, increased/improved monitoring, additional ventilation, upgrades to or additional PPE requirements). Air monitoring can also be conducted by Operations/Owning personnel who have received training in the following areas: span gas checking, calibration, testing equipment use and data interpretation Isolation Techniques The Confined Space shall be completely protected against the release of hazardous energy and material into the space. Every effort should be made to isolate the confined space as close to the vessel as reasonably possible. In the event this cannot be achieved, adjoining piping and equipment must be controlled by using techniques defined in the Wyandotte Control of Hazardous Energy procedure, WYN , including the need to verify that all spaces are free of hazards to the same degree as the space being entered. A line shall be deemed isolated if one or more of the following steps are taken to isolate the Confined Space from potential sources of hazardous materials: A blank or blind has been inserted in the line. Blanks must be of construction and thickness to sustain the maximum line pressure. The line has a double block and bleed where the two block valves are closed, the bleed, in between, is opened and locks/ tags are applied. Lines are disconnected and misaligned from the Confined Space. The block valves in a line to the jackets, coils, reboilers and similar items which in themselves are not open to the confined space in which work is to be performed are closed and tag out applied. The only exception, to not isolate the block valves, would be the use of external cooling water on vessel jackets or coils during hot weather. Lines going to jackets, coils, re-boilers are closed or locked and tagged. Given the fact that the jackets and coils will not leak into the space. At the Wyandotte site all adjoining piping and hazardous energy sources shall be de-energized and isolated in accordance with the Corporate Control of Hazardous Energy Procedure, BC and the Wyandotte Control of Hazardous Energy Procedure contained in WYN

9 Procedure No.: WYN Page: 9 of 25 Note: If the confined space contains internal power driven mechanisms, such as agitators, all switch gear and other power sources shall be locked, tagged, tried and verified. Look for stored inertial energy of rotating equipment, as well as, hydraulic and pneumatic energy sources Preparation and Isolation Requirements Site or Unit spaces that do not meet the definition of a confined spaces, as defined in Section 2.7, are exempt from the Program requirements. Confined Spaces which do not contain a hazard or potential hazard capable of causing physical harm or for which adherence to a requirement would increase the hazard (e.g., blowing air in a dusty environment) may be also be exempted from one or more of the Program requirements. Exemptions must be documented in writing. 1. Exemptions must be reviewed and signed off by the following individuals or groups :Process Owner (or Staff-level designee), 2. Maintenance Team Leader (or designee), and 3. EHS Safety Coordinator (or designee). Note: Standing Confined Space exemptions must be identified and a list maintained by Operations/Owning Unit Atmospheric Conditions A. Oxygen Where the level of oxygen is between 19.5% and 21% and the integrity of the atmosphere cannot be guaranteed, an air-line respirator or self-contained breathing apparatus ("SCBA") shall be used. Where the level of oxygen is found to be below 19.5% and corrective actions do not alleviate the situation, a SCBA or pressure-demand air-line respirator with an emergency egress bottle shall be used. Except for rescue, entry into inert atmospheres or atmospheres less than 16% oxygen requires authorization of facility manager or designee and EHS hub representative or designee. B. Enriched Oxygen Atmospheres found to have enriched oxygen supplies (greater than 21%) require appropriate action to reduce the level to 21%. Note: Excess oxygen can extend the flammable range of gases and vapors and can also make combustible materials ignite and burn rapidly.

10 Procedure No.: WYN Page: 10 of 25 C. Flammable Gases/Vapors Confined Spaces containing detectable flammable gases/vapors using a properly calibrated and maintained combustible gas indicator operating in the percent range of sensitivity shall not be entered. D. Generation of Flammable Gases/Vapors If work activities to be performed in a Confined Space are expected to generate flammable gases/vapors, continuous ventilation and representative continuous Monitoring are required. If flammable gases/vapors are detected, immediate corrective action must be taken to reduce their concentrations (e.g., increased ventilation and reduced rate of vapor generation). If the combustible gas readings reach 5% of the Lower Explosive Limit (LEL), work must cease and the Authorized Entrants must exit the Confined Space immediately. E. IDLH When entry is made into an IDLH atmosphere or into a space that could quickly develop an IDLH atmosphere (if ventilation fails or for other reasons), the Rescue Service shall stand by at the Confined Space. F. Toxic Substances The level of a toxic substance in the Confined Space should be maintained below the applicable Occupational Exposure Limit (OEL) at all times during the Entry. In those situations where the concentration cannot be maintained below the applicable OEL, appropriate respiratory personal protective equipment shall be used by all Authorized Entrants according to the site/unit Respiratory Protection Program requirements. Note: Concentrations of contaminants may be toxic at levels much lower than flammable gas detection; therefore, the requirements for appropriate PPE for these conditions must also be evaluated and implemented. G. Combustible Dust Confined Spaces containing airborne combustible dust at a concentration that meet or exceed the Lower Flammable Limit (LFL) or obscures vision at a distance of five feet or less shall not be entered. If work activities performed in a Confined Space generate combustible dust at a concentration that obscures vision at a distance of five feet, work activities must cease and immediate

11 Procedure No.: WYN Page: 11 of 25 corrective action must be taken to reduce their concentration (e.g., increase ventilation and/or reduce rate of dust generation). H. Physical Hazards Heat, humidity, and cold stress hazards during Confined Space entry shall be controlled to prevent adverse health effects to authorized entrants. I. Radiation Hazards Radioactive devices must be mechanically locked out in the closed/off position by a qualified nuclear gauge operator and checked/verified by a Radiation Safety Officer (RSO) or authorized designee prior to entry into the vessel. J. Other Introduced Hazards When hazardous energy sources are introduced into a Confined Space, the hazardous source shall be controlled or eliminated before entering the confined space (i.e., Hyrdoblasting equipment, heat treating activities, or introduced atmospheric hazards during cleaning). 4.3 Monitoring Requirements Before Permit Issuance Each confined space shall be initially monitored for oxygen content prior to entry; in addition monitoring for Lower Explosion Limit (LEL) and or toxics is required for spaces that contained a Hazardous Atmosphere. Monitoring shall be performed reflective of entry conditions. Monitoring for atmospheric conditions shall be conducted as close to Entry time as possible and at no time shall it exceed two hours prior to entry. If the space is unoccupied due to work breaks or delays, Monitoring shall be performed as close to re-entry time as possible and at no time shall it exceed two hours prior to re-entry. Various levels or sections of the Confined Space shall be checked to account for oxygen displacement by gases heavier or lighter than air Periodic and Continuous Monitoring The atmosphere in the Confined Space shall be monitored continuously during the Entry activities for oxygen when a confined space has had an Atmospheric Hazard or if one may be introduced into the space. The atmosphere in the Confined Space that had an Atmospheric Hazard or if one could be introduced into the space shall be monitored continuously during the Entry activities for flammable gases/vapors

12 Procedure No.: WYN Page: 12 of 25 when work activities to be performed in a Confined Space are expected to generate flammable gases/vapors or when the Confined Space has contained flammable gases/vapors. In situations where continuous Monitoring is technically infeasible, pre-determined periodic Monitoring shall be conducted as appropriate. Personal direct-reading monitoring shall be conducted for workers inside the confined space, including BASF and contractor employees. Monitoring parameters should be determined by the Confined Space Entry Supervisor in collaboration with an EHS representative as necessary. Confined Spaces that contain toxic gases/vapors/mists shall be evaluated to determine the appropriate sampling frequency that will accurately assess the atmospheric exposure Sequence The atmosphere of all Confined Spaces shall be tested in the following order: a. oxygen content, b. flammable gases/vapors, c. toxic gases/vapors/mists and observation for combustible dusts Maintenance and Calibration Monitoring instruments are to be maintained properly and performance tested ( Bump Test or Function Test ) before each day s use, at a minimum. Performance testing shall include verification of proper instrument response against a known concentration of test gas for each oxygen gas, flammable gas/vapor and toxic gas/vapor/mist of concern. Periodic instrument calibration should be performed according to manufacturer s recommendation Instrument Tolerances Acceptable instrument performance testing and subsequent Monitoring results may allow for normal acceptable instrument deviations as determined by the instrument manufacturer. 4.4 Confined Space Permit Content The Confined Space Entry permit system shall, at a minimum, include the following information: Identification of the Confined Space and purpose of Entry, Date and authorized duration of Entry, List of Authorized Entrants and Attendants, Name of individual currently serving as Entry Supervisor, Signature/initials of Entry Supervisor who originally authorized Entry, Communication method between attendant and entrants Name or initial of tester

13 Procedure No.: WYN Page: 13 of 25 List of the hazards and the isolation and control methods, Acceptable Entry conditions, Identification of Rescue Service and method of communication, Entry equipment required, Monitoring documentation (documented on Wyandotte Safe Work Permit) stated in Section 4.5. of this standard, Other permits required, and An area for additional information/comments 4.5 Documentation Results of air monitoring that indicate the atmosphere the Authorized Entrants actually entered, including oxygen concentration below 19.5% and flammable gases/vapors and toxic materials above zero ppm are considered IH exposure records subject to recordkeeping requirements. Refer to BASF Records Retention Policy BC037 and BASF Exposure Assessment Work Process BWP-008 in Section 6 related documents. Any Confined Space Entry Permit which indicates that personnel actually entered a contaminated atmosphere, must be kept for 30 years as a record of exposure in accordance with the OSHA 29 CFR (MIOSHA Part 470, Employee Medical Records and Trade Secrets standard). This includes initial entries made by person(s) performing the atmospheric testing. These permits must be kept even if PPE was worn to prevent actual exposure to personnel. Examples of contaminated atmospheres include: Atmospheres containing less than 19.5% oxygen: Atmospheres with a flammable gas/vapor reading greater than zero (0); and Atmospheres with a toxic substance (s) reading greater than zero (0). The Equipment Owner is responsible for reviewing the permits to determine if any should be kept as exposure records per the above described criteria. Applicable permits should be forwarded to the Wyandotte EHS Department for retention. Results and corrections from the annual program review shall be documented and retained until the next review. Results and corrective actions shall be documented from the debriefing at permit close out. The following must be documented on the Confined Space Entry permit: Monitoring instrument calibration verification and equipment identification. Verification of daily performance testing ( Bump Test ). Confined Space atmosphere monitoring results, including the time of the tests and the tester's initials.

14 Procedure No.: WYN Page: 14 of 25 The frequency of documentation for all Monitoring which shall be determined before each Entry. 4.6 Permit Issuance and Duration A Confined Space Entry permit shall be valid only for the time and specific location identified on the permit. Any personnel changes concerning Attendants and Authorized Entrants shall be documented on the permit by an Entry Supervisor. Communications (visual, audio, verbal or signal line) shall be maintained between all individuals involved in the Entry and the Attendant. Where exists, any requirement for special procedures or instructions, shall be noted on the Confined Space Entry permit. These instructions must be compiled prior to the issuance of the Confined Space Entry permit. Any deviations or exceptions to the requirements defined in both the Wyandotte Site Confined or the BASF Corporate Confined Space Standard must be agreed upon by the Process Owner (Operations/Owning group), the Maintenance Team Leader (or designee) and the EHS Safety Coordinator (or designee). If the Confined Space contains internal power driven mechanisms such as agitators, all switch gear and other power sources shall be "locked, tagged and tried" in conformity with the Wyandotte Control of Hazardous Energy Procedure, WYN Radioactive devices such as level detectors shall be secured to prevent exposure during the Entry in conformity with the Wyandotte Radiation Safety Procedure, WYN When a portable ladder or stairs are required to enter a Confined Space, the equipment shall be inspected, suitable for the type of space, and, readily available for exit to anyone in the space. All electrical equipment used inside a Confined Space shall be consistent with the Wyandotte Site Hot Work Procedure, WYN for the area classification in a safe condition and grounded or double insulated. Lighting shall be "approved" low voltage units or extension cords equipped with a functional ground fault circuit interrupter. All temporary lighting shall be equipped with guards to prevent contact with the bulb. 4.7 Confined Space Permit Revalidation If a change in Entry supervision occurs, the on-coming Entry Supervisor must revalidate or reissue the Confined Space Entry permit and inform representative personnel involved in the Entry of the change in supervision. Permit Revalidation includes the review, agreement of permit conditions and signatures of the permit acceptor and Entry Supervisor. Permit Revalidation is not allowed under the following situations: There has been an isolation modification Changes in work scope

15 Procedure No.: WYN Page: 15 of 25 A new hazardous energy source is introduced Change in Company performing work Significant time gap as defined by site At the Wyandotte site the permit shall not be valid for longer than one shift of personnel performing the Entry activities (maximum 16 hours). Upon assignment of a new (different shift) Entry Supervisor the permit must be re-validated or reissued and the Permit Acceptor must be informed of the changes. 4.8 Confined Space Permit Closeout and Debrief Upon completion or discontinuation of the Entry, the Confined Space Entry permit shall be returned to an Entry Supervisor for debriefing and closeout. Any issues affecting safe entry conditions identified, including hazards encountered during an Entry will be noted on the debriefing section at the bottom of the Confined Space permit, so that appropriate revisions to the site program can be made as soon as feasible. Authorized Entrants, Entry Supervisor, and Authorized Attendant shall be debriefed concerning the program and any hazards created or confronted during Entry at the end of any Entry operation. The debriefing activities shall be documented on the confined space permit. Completed Confined Space Entry permits shall be retained for the period necessary to facilitate the program review stated in Section 4.13, but should not be kept no longer than one year. Permits do not have to be retained after the review but documentation of the review results and corrective measures is required. 4.9 Duties and Responsibilities Entrant The Authorized Entrant Responsibilities include but are not limited to: Knowing the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure; Properly use equipment as required by this procedure, such as, PPE, lighting, and ventilation; Communicate with the attendant as necessary to enable the attendant to monitor entrant status and to enable the Attendant to alert Entrants of the need to evacuate the space; Alert the Attendant whenever: (1) the Authorized Entrant recognizes any warning sign or symptom of exposure to a dangerous situation, or (2) the entrant detects a prohibited condition; Exit from the Confined Space as quickly as possible whenever: (1) an order to evacuate is given by the attendant or the entry supervisor, or (2) the entrant recognizes any warning sign or symptom of exposure to a dangerous situation or (3) the

16 Procedure No.: WYN Page: 16 of 25 Authorized entrant detects a prohibited condition, or (4) and evacuation alarm is activated Attendant When personnel are working within a Confined Space, a trained Attendant shall be immediately outside the space. The Attendant may monitor more than one Confined Space provided that the Monitoring of these spaces is performed without compromising the safety of any Authorized Entrant in all the Confined Spaces being monitored by the Attendant. The Attendant responsibilities include but are not limited to: Knowledge of the hazards that may be faced during Entry, including information on the mode, signs, symptoms, and consequences of the exposure; Awareness of possible behavioral effects of hazard exposure in Authorized Entrants; Maintaining an accurate count of Authorized Entrants in the Confined Space; Remaining outside the permit space during entry operations until relieved by another Attendant; Communicating with Authorized Entrants as necessary to monitor entrant status and alert Entrants of the need to evacuate the space Summoning rescue and other emergency services Monitoring Confined Space activities and order Authorized Entrants to evacuate the permit space immediately under any of the following conditions: o o o If the attendant detects a prohibited condition; Behavioral effects of Authorized Entrant hazard exposure Situation outside the Confined Space which could endanger Authorized Entrants such as activation of emergency alarm; or o Attendant cannot effectively and safely perform all required duties. Taking the following actions when unauthorized persons approach an Entry in progress: o Warn unauthorized persons to stay away o Advise unauthorized persons to exit immediately if they have entered the Confined Space; and o Inform Authorized Entrants and Entry Supervisor if unauthorized persons have entered the Confined Space; Performing non-entry rescues as specified by rescue procedure; and Performing no duties that might interfere with primary duty to monitor and protect Authorized Entrants.

17 Procedure No.: WYN Page: 17 of 25 Summon rescue and other emergency services as soon as the attendant determines that authorized entrants may need assistance to escape from permit escape hazards Entry Supervisor The Operating/Owning Entry Supervisor shall authorize entry into the Confined Space by signing the Confined Space Permit. Determine whenever responsibility for a permit space entry operation is transferred and at intervals dictated by the hazards and operations performed within the space that entry operations remain consistent with terms of the entry permit and that acceptable entry conditions are maintained. Prior to authorization of the Confined Space Entry permit, the Entry Supervisor and representative personnel involved in the Entry shall: Personally inspect the Confined Space preparation. Know the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure. Verify, by checking that the appropriate entries have been made on the Confined Space permit, that all tests specified by the permit have been conducted and that all procedures and equipment specified by the permit are in place before signing the Confined Space permit and allowing entry to begin. Provide an opportunity for the Authorized Entrant or their Authorized representative to observe pre-entry and periodic Monitoring of the atmosphere. Review precautions taken. Verify that rescue services are available and that the means for summoning them are operable. Throughout all permit space activities, the Entry Supervisor shall ensure the following: Ensure the permit is located at the work site. Review procedures to be followed and instructions for all personnel involved in the assignment. Re-evaluate the Confined Space in the presence of any Authorized Entrant or their representative upon request by either if they have reason to believe that the initial evaluation may not have been adequate. Remove unauthorized individuals who enter or who attempt to enter the Confined Space during entry operations. Terminate the entry and cancels the Confined Space Entry permit when hazards or conditions warrant.

18 Procedure No.: WYN Page: 18 of Duties of Contractors The confined space entry contractor is responsible for maintaining a confined space entry program that complies with both BASF and MIOSHA requirements. The contractor provides their Confined Space Entry written program to BASF upon pre-qualification request and periodically upon request, thereafter. The contractor attest that their confined space employees comply with the BASF permit-required Confined Space program and have the training necessary to comply with MIOSHA and BASF requirements. Obtains the necessary permits (Safe Work/Hot Work, Confined Space) prior to conducting work. Obtains necessary information from BASF regarding permit space hazards. Coordinates entry operations with BASF personnel. Informs BASF of any hazards created or observed in a Confined Space. In addition to the above duties, the following information is also required to be provided to BASF by contractors performing or involved with Confined Space work on-site: Copies of Permit-required Confined Spaces (PRCS) training records to Site or Unit operations prior to commencing entry activities. Each contractor performing Permit-Required Confined Space (PRCS) work is required to perform independent atmospheric testing of the permit space using properly calibrated and functionally tested direct reading instrumentation for the anticipated hazards within the space. If respiratory protection is mandatory for entry operations, the contractor is required to provide or have available on-site, copies of the respirator medical determination, fit testing and annual respirator training for all affected personnel Welding in a Confined Space Welding/Cutting in Confined Spaces shall be in compliance with the Wyandotte Site Hot Work Procedure, WYN and the Wyandotte Site Personal Protective Equipment (PPE) Standard, WYN Welding activities in Confined Spaces must include but are not limited to be the following provisions: Gas cylinders and welding machines shall be left on the outside during welding or cutting operations When welding equipment is unattended, electrodes shall be removed from holders and located to prevent accidental contact and the machine disconnected from the power source. Local exhaust or general ventilation to maintain toxic fumes, gases, or dust below the OEL specified in attachment #1 BASF Exposure Assessment Occupational Exposure Limit Reference Value Determination in establishing acceptable occupational exposure limits. In situations where

19 Procedure No.: WYN Page: 19 of 25 local exhaust or general ventilation is not sufficient or feasible, approved airline respiratory protection must be provided. Mechanical ventilation shall be used when the following spaces have o an area less than 10,000 cubic feet per welder o ceiling height less than 16 feet o an internal configuration that prohibits or obstructs cross ventilation General ventilation rate of 2,000 cubic feet per minute per welder, except where local exhaust hoods and/or booths are used or when NIOSH approved air-line respiratory protection is used. Local exhaust control ventilation rates. Freely movable hoods intended to be placed by the welder as near as practicable to the work being welded and provided with a rate of air-flow sufficient to maintain a velocity in the direction of the hood of 100 linear feet (30 m) per minute in the zone of welding when the hood is at its most remote distance from the point of welding. The rates of ventilation required to accomplish this control velocity using a 3-inch (7.6 cm) wide flanged suction opening are shown in the following table: Welding Zone Minimum Air flow (CFM) Duct Diameter, inches 4 to 6 inches from arc or torch to 8 inches from arc or torch to 10 inches from arc or torch to 12 inches fom arc or torch Rescue Retrieval Systems A Retrieval System shall be used whenever an Authorized Entrant enters a Confined Space unless the retrieval equipment would increase the overall risk of Entry or would not contribute to the rescue of the Entrant. The Retrieval System shall consist of a chest or full body harness with a retrieval line in good condition attached to the Entrant at any point which presents a profile small enough for the successful removal of the Entrant to a fixed point or mechanical device outside the Confined Space. When a Retrieval System is used a chest or full body harness shall be donned by the Entrant before entering any Confined Space where Entry is through a man way or other restricted opening. A mechanical device shall be used for vertical type Confined Spaces more than five feet deep. Wristlets may be used in lieu of a chest or full body harness if the use of the chest or full body harness is infeasible or creates a greater hazard.

20 Procedure No.: WYN Page: 20 of Rescue Services Non-entry methods of rescue will be used first. Attendants are trained to perform non-entry rescue; however, prior to initiating non-entry rescue techniques, the Attendant will activate the Site s Confined Space Rescue Team or other site qualified rescue service providing rescue services for the entry. In no case will a person attempt non-entry rescue without training according to the requirements of this program. Rescue Services shall be available either on-site or from off-site which provide appropriate response times and training for rescue workers. Refer to Appendix F of OSHA 29 CFR in Section 6, Related Documents for reference. If off-site Rescue Services is being considered, the employer must contact the service to plan and coordinate service response capability prior to authorizing entry. On the other hand, if the service becomes unavailable, they must notify the employer and the entry cancelled. Rescue Services personnel shall be trained and certified in first aid/cpr and at least one member shall be available at the facility during the Entry with direct means of communication (e.g., radio and telephone) to facilitate a quick response to the Entry location. Non-Entry rescue shall be used whenever possible. When non-entry rescue is not possible due to the space configuration or obstructions, all rescue equipment which would be used in an Entry rescue shall be readily available, at or near the Confined Space Entry area, to reduce the response time. Any Entry into an atmosphere which may be hazardous to retrieve a downed person shall require the use of a supplied-air respirator (SAR) with an emergency egress bottle or a SCBA Rescue Team Organization The site rescue team may be comprised of maintenance, production and site services personnel. The Rescue Team Roster is posted on the Wyandotte site Intranet and should also be posted within each respective unit at a location that is accessible by personnel who issue Confined Space Entry permits Rescue Team Notification Members of the rescue team must be notified that a Confined Space entry is taking place before the entry permit is authorized. A minimum of two rescue team members must be on-site and available for timely response for all Confined Space entries. Any member of the rescue team may be contacted. Solicitation of rescue team members for planned off-shift entries must be performed during the day-shift prior to the off-shift entry. The contracted rescue team member is responsible for advising the Entry Supervisor (Permit Issuer) if more than two members are needed for that entry.

21 Procedure No.: WYN Page: 21 of 25 Requests for additional rescue team members may be made by Operations/Owning or maintenance performing the entry. The Entry Supervisor (Permit Issuer) is responsible for contacting all necessary rescue team members to establish a rescue team for that entry Rescue Team Communication A method of summoning rescue (i.e., radios, pagers, cell phones, etc.) must be established prior to commencement of entry operations and noted on the Rescue section of the confined space permit. The Confined Space entry attendant will contact the rescue team via the established method in the event that a rescue may be necessary. Drills to practice summoning Confined Space rescue services and also to evaluate response time shall be conducted annually or more frequently to ensure adequate response time is maintained Rescue Team Equipment Rescue equipment is contained in the Rescue Team trailer. The equipment is maintained by members of the Confined Space Rescue team. An equipment list is maintained by the Wyandotte Site Confined Space Rescue Team. Inventory and inspection of rescue equipment is the responsibility of the Rescue Team. Annual inspection is to be conducted on all Rescue Equipment Training The following provisions applies to Wyandotte Site BASF personnel directly and indirectly involved in Confined Space Entry operations Persons Directly Involved in Confined Space Entry Operations Confined Space Permit issuers, Authorized Entrants, Attendants, testers or other personnel whose job may require involvement in the Entry of Confined Spaces shall receive and understand training in: Confined Space and hazard identification, evaluation techniques, appropriate control methods, proper use of all associated equipment to successfully effect Entry, and their specific roles/responsibilities under the program A combination of Computer Based Training (CBT) and hands on training will be used to ensure all employees involved in confined space entry work are properly trained.

22 Procedure No.: WYN Page: 22 of Persons Not Directly Involved in Confined Space Entry Operations Personnel not directly involved in Confined Space Entry operations who may be exposed to the hazards of Confined Spaces shall receive awareness training to prevent unauthorized Entry. Acceptable Confined space awareness training can be a combination of Computer Based Training (CBT) and/or specific training given during safety meetings Rescue Service Training Rescue Service shall receive the same training as Authorized Entrants plus: training in rescue techniques and equipment, the use of personal protective equipment, blood-borne pathogens, first aid, and CPR Each member of the Rescue Service shall receive basic training in first aid and CPR, and at least one member of the service shall maintain current certification. Attendants shall also receive training in non-entry rescue techniques. In addition the Wyandotte site rescue team s members will perform simulated rescue operations from representative types of permit spaces to fulfill the annual rescue team requirements Training Frequency Training shall be delivered in accordance with the EHS curriculum assignment process. Personnel shall be retrained whenever deviations or inadequacies to the Confined Space Entry procedure are identified. Each member of the Rescue Service shall practice in a Confined Space entry or non-entry rescue drill, as applicable. Drills shall be conducted on representative spaces or in spaces that are worst-case or most restrictive with respect to internal configuration, elevation, and portal size. The rescue drill shall be conducted at least once every 12 months with field evaluation to verify competency. At the Wyandotte site, rescue drills will simulate the types of spaces likely to be encountered Documentation Training shall be documented including date of the training, trainees' names, means used to verify understanding, and learning objectives for the course Training documentation shall be maintained according to BC037 Record Retention Policy and the applicable record retention schedule.

23 Procedure No.: WYN Page: 23 of Contractor Employee Contractor Employee whose work involves or may be affected by Confined Space Entry shall be informed of the site procedure and how the requirements will be applied. Contractor Employees shall be trained in accordance with BC Contractor Selection Oversight and Safety for training requirements. Refer to BASF BC Contractor Selection Oversight and Safety in Section 6 Related Documents Confined Space Management System Review At the Wyandotte site the Confined Space management review will be led by the Site EHS group to review the effectiveness of Confined Space Entry practices at least annually. The review will include unit and site services personnel and will include a review of documentation provided by each group. In addition, where possible work-in-progress reviews may be conducted using field audit books or a confined space audit form as referenced in Section 6 of this standard. As a minimum, the following elements of the Confined Space Entry management system shall be included in the review: Review the site procedure and permit to ensure all currently required elements are included. A review of all incidents and other nonconformance reports that involved Confined Space Entry activities and have occurred since the last Confined Space Entry management system review. The review should verify root causes have been properly identified and appropriate corrective actions have been implemented. A review of the completed permits to determine if the effectiveness, completeness and accuracy of the permit system according Section Inspection of at least one Confined Space Entry job-in-progress to verify site practices comply with the site procedure. The inspection shall include verification of the training personnel involved in this job-inprogress have received. Interviews with a representative number of Permit Issuers, persons performing Confined Space Entry, and other affected employees, including Contractor and Contracted Employees where applicable, to verify they understand their role/responsibility. A review of applicable equipment, instrument maintenance and calibration records per the requirements of the standard. Copies of all Confined Space Entry Permits and associated paperwork (Safe Work Permit, Pre-Task Plans) generated and issued by Wyandotte Site Operations/Owning Units made during the calendar year (January to December) under review will be forwarded to the Wyandotte Site EHS Department for evaluation by the end of February of the year following the review.

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