HEALTH AND SAFETY PROGRAM 317 CONTROL OF HAZARDOUS ENERGY

Transcription

1 Page 1 of PURPOSE Axiall, Plaquemine Complex, has developed this Program to minimize potential accidents and injuries, and to enhance employee protection. Personnel in or around equipment, machinery, or lines must be protected from injury due to unexpected activation, start-up, or release of stored energy. 2.0 SCOPE This Program covers the servicing and maintenance of machines and equipment in which the "unexpected" energization or start up of the machines or equipment, or release of stored energy could cause injury to employees. The need to lockout, tagout, and tryout is not limited to when the equipment or machinery is inspected, serviced, repaired, installed, or removed. 3.0 DEFINITIONS 3.1 Affected employee--an employee who works in an area where lockout/tagout/tryout procedures are used. An affected employee does not perform or implement the lockout/tagout/tryout procedure. An affected employee can become an authorized employee. 3.2 Authorized employee--an employee who performs servicing or maintenance or initiates lockout/tagout/tryout on equipment and machinery. Authorized employees have received required training. 3.3 Energy Source--Any electrical, mechanical, hydraulic, pneumatic, chemical, thermal, gravitational, or any other source of "static" or "dynamic" energy that could cause injury. 3.4 Energy Isolating Device--A physical device that prevents the transmission or release of energy, such as: Manually-operated electrical circuit breaker; Disconnect switches; A manually-operated switch; Slide gate; A line valve; Blocks, springs, or support bars; Blinds/pancakes/blank flanges; and Pipe plugs. NOTE: Push buttons, selector switches, limit switches, or other control-circuit type devices are not considered energy isolating.

2 Page 2 of Equipment Proprietor--An individual who maintains supervision and authority over an operating unit's equipment, machinery, or lines. 3.6 Isolation List-- A complete list of all system hazardous energy sources that must be addressed when isolating a system for maintenance inspection and repair. The list will include, but is not restricted to, electrical, hydraulic, pneumatic, all valves, lines to be disconnected, and areas where blinds are to be installed. 3.7 Lockout Device-- Any of the hardware used to isolate a hazardous energy source and render it inoperable. These devices may include, locks with proper identification, chains, hasps, blinds, cables, and tags. 3.8 Lock Removal Authorization Form -- The form used to notify management of the necessary removal of a lock in an employee s absence. 3.9 Tagout Device--A prominent warning. A tag securely attached to equipment or machinery that forbids operation and identifies the Equipment Proprietor or Maintenance Crew Leader who attached the lockout/tagout device and gives the details for locking out Blinds--A red handled plate installed in pipes to effectively block and isolate lines or equipment. A common blind is one which is used for multiple jobs at the same time Chains--Chains and locks are used to lock valves and hand wheels. The chain is placed through the hand wheel and around an immovable structure and then locked Gang Hasps--Scissor-like devices that accept numerous locks and are applied directly to the equipment being isolated Group Lock Box--A tamper-proof enclosure capable of accommodating gang hasps and locks that prevents physical access to a key(s) locked inside Locks--Locks are the primary method to isolate equipment and machinery out-ofservice.

3 Page 3 of Pipe Plugs--A plumber's stopper placed on the end of lines to effectively isolate hazardous energy Electrical Plug Locks--A device that encloses and locks over an electrical plug connected to equipment to protect against inadvertent energizing Valve Covers--An encapsulating device used to lock some valves controlled by hand wheels or handles. The valve is turned to the desired position and the handle or hand wheel is removed. The valve cover is placed over the valve stub and tightly locked Valve Lock--A device that locks out a valve found on lines, such as steam, water, and compressed air lines. This may consist of a chain and lock or a device that encapsulates the valve handle or wheel Long-term lockout - Any equipment that will be taken out of service and locked out for greater than a 6-month time period will be considered as a long-term lock out Long Term Lock Out Form A long-term lock out form will be used to document the equipment that will be locked out. The form will contain the equipment name, the equipment number (when applicable) a brief description of why the equipment is locked out, the date the equipment was locked out and the name of the person who locked out the equipment. Appropriate signatures are required on the form depending on the areas affected Long-term locks -Will be a black lock and keyed area specific. 4.0 RESPONSIBILITIES Axiall has provided a Control of Hazardous Energy Program for employees, and is responsible for training employees and for notifying contractors of its Control of Hazardous Energy Program. Specific responsibilities are listed below: 4.1 Health and Safety (H&S): Trains affected employees to an awareness level on control of hazardous energy.

4 Page 4 of Trains authorized employees on the proper use of hazardous energy control procedures Orients contractors to Axiall's Control of Hazardous Energy Program Ensures that Annual Lockout/Tagout/Try Inspections are conducted. (Appendix C) Maintains audit records Audit contractors compliance. 4.2 Equipment Proprietors: Learn, understand, and follow Axiall's Control of Hazardous Energy Program Initiate hazardous energy control procedures utilizing red proprietor locks and tags Provide specific energy isolating details that are unique to the job or area to the Maintenance Crew Leader Ensure the equipment and machinery is effectively isolated and enforces the hazardous energy control procedure Ensure personnel safety by reviewing drawings, consulting people with system knowledge, and by testing hazardous energy isolation Develop corrective action plans covering deficiencies found during the H&S Control of Hazardous Energy Procedure audits. 4.3 Maintenance Crew Leaders: Learn, understand, and follow Axiall's Control of Hazardous Energy Program Issue individual (blue) locks to all authorized maintenance crew personnel.

5 Page 5 of Consult with Department Supervision or Equipment Proprietor to identify proper energy isolating devices for equipment and machinery Verify and control the equipment proprietor's isolation by attaching a Crew (yellow) lock to all isolation points. In those areas where it is found that a lock cannot be attached, a work request will be made to have the isolation point modified to accept a lockout device. (See section 5.1, Equipment or Machinery Upgrade.) 4.4 Authorized Employees: Learn, understand, and follow Axiall's Control of Hazardous Energy Program Inform affected employees of all lockouts and tagouts in their immediate area Use proper hazardous energy control procedures. 4.5 Affected Employees: Learn, understand, and follow the Axiall Control of Hazardous Energy Program Do not use or attempt to use locked and tagged equipment or machinery. 4.6 Contractors: 5.0 PROCEDURE Contractors are required to meet or exceed this Axiall Program. 5.1 Equipment or Machinery Upgrade It is Axiall's Policy that all process equipment and machinery be able to accept a lockout device. If process equipment or machinery cannot accept a lockout device, whenever replacement or major repair, renovation or modification of machine or equipment is performed, and whenever new machines or equipment are installed, energy isolating devices for such machine or equipment shall be designed to accept a lockout device. 5.2 Lock Identification Proprietor Lock

6 Page 6 of 35 The Proprietor Lock is utilized as the initial isolation by the equipment owner. The Proprietor Lock is not used for individual protection and work cannot be performed on equipment without the addition of an Individual Lock. Additional requirements are: Keyed alike; Each unit s lock set is keyed differently; The Do Not Operate Tag is affixed to the gang hasp of this lock; and Lock has a red band; and Is not to be used as the only isolation device Crew Lock The Crew Lock is utilized by Maintenance to take control of the isolated equipment. The Crew Lock is not used for individual protection and work cannot be performed on equipment without the addition of an Individual Lock. Additional requirements are: Each set is keyed differently; Has crew identification consisting of crew name and company name; and Are maintained by a Maintenance Crew Leader or designee; and Lock has a yellow band Individual Lock The Individual Lock is utilized by an employee for their personal protection. It is the only lock that provides true employee protection and work cannot be performed without it. Additional requirements are: Individual locks have only one key and are held by the person to whom the lock and key is assigned. Each lock is keyed differently; Must have employee identification consisting of employee name and company name; and Maintained by an individual in a crew; and Lock has a blue band Lock Box, Group Lock The Group Lock Box is utilized to control multiple isolation points with a

7 Page 7 of 35 limited use of Proprietor, Crew and Individual Locks required. Additional requirements are: Each lock is keyed alike; The key for lock box, group locks is placed in the lock box; Are maintained by the Tool Room or individual units; and The lock box, locks and keys are checked out as a kit. All spare keys to these locks will be maintained by the H&S Department; and Lock has a green band. 5.3 Preparation for Lockout The Equipment Proprietor will know the type and magnitude of energy that the process equipment or machinery utilizes, as well as the hazards, and ways to control the energy The Equipment Proprietor will determine the process equipment or machinery to be locked out; identify all energy isolating devices; and provide an isolation list with necessary work permits to Maintenance The equipment will also be inspected by the Equipment Proprietor to identify all potential energy sources in consultation with the Maintenance Crew Leader and/or the work crew Tagging a control power on-off selector switch only is not safe and will not be considered as meeting these requirements. The control breaker/panel must be locked out Shut down equipment or machinery by normal shutdown procedures The Equipment Proprietor will turn the main power switch, or appropriate energy isolating devices, to the "off" position so that the process equipment or machinery is isolated from its energy source. Rotating flywheels, chucks, and blades will be allowed to stop and pneumatic or hydraulic systems will be depressurized. Portions of steam and chemical lines will be blocked, drained or blanked as appropriate I/E/HVAC I/E/HVAC performs a number of routine minor preventative maintenance checks on certain low hazard/low risk job tasks where the technician maintains direct control of the isolation devices. Examples of these tasks include, testing pressure transmitters or DP cells,

8 Page 8 of 35 cleaning and flushing ph or conductivity probes, testing level transmitters process analyzers HVAC Performing these tasks may be accomplished without installing lockout/tagout devices by either the area proprietor or the instrument technician as long as the technician is within reach of, and maintains direct control of the isolation devices at all times. In the event the technician must leave the work area unattended, all isolation devices shall be locked out, or the equipment returned to normal operations. During routine preventive maintenance, a qualified technician isolating equipment for their sole protection may lock the equipment with their individual (blue) lock without the additional proprietor (red) and crew leader (yellow) locks. Custodianship shall remain with the Instrument or Analyzer Technician until the work permit is turned in to the Equipment Proprietor. Custodianship then reverts back to the Equipment Proprietor. If continued lockout is required, then the Equipment Proprietor must lockout using the red lock Each piece of process equipment or machinery associated with the process will be examined for sources of potential energy, such as residual pressure or rotating parts. Each source will be blocked, removed, or otherwise stabilized to eliminate potential energy Once all pressurized systems have been depressurized, rotating parts have stopped, and any other potential energy sources stabilized, the energy isolation devices or switch will be locked out and tried out by the Equipment Proprietor. The Equipment Proprietor will: Affix a proprietor (red) lock; and Complete information on the Proprietor Do Not Operate Tag: o Equipment Proprietor's name; o Date; o Explanation of lockout.

9 Page 9 of 35 The shackle of the lock must be placed through the eyelet of the tag when affixing the tag to the lockout device. (See Appendix A - Lockout Tag) Issue a complete isolation list to the Maintenance Crew Leader After verifying that all energy sources have been isolated, the Maintenance Crew Leader will then affix a crew (yellow) lock with proper identification that lists the Maintenance Crew name and company name The Maintenance Crew Leader will, after assuring that all employees are clear of the process equipment or machinery, operate or "tryout" the start button, circuit breaker, or other device to make certain the equipment will not operate. Operating controls will be returned to the neutral or "off" position after the test Custodianship of the instrument pressure device or on-stream analyzer system shall be transferred from the Equipment Proprietor to the Instrument or Analyzer Technician upon approval of the work permit. The boundary of the custodianship shall be the manifold or valve where the Instrument or Analyzer Technician is in direct control. Custodianship shall remain with the Instrument or Analyzer Technician until the work permit is signed off as complete by the Equipment Proprietor. Custodianship then reverts back to the Equipment Proprietor.

10 Page 10 of Lockout/Tagout/Try Procedure Sequence Each member of each work crew will then affix an individual (blue) lock with proper employee identification, which list the employee's name and company name, on the gang hasp at each isolation point Isolation points will be verified by each of the work crews leader The equipment is now locked, tagged, and tried out Failure to lockout and tagout equipment or machinery, or any other devices during a planned outage, emergency breakdown, or necessary normal repairs, including improper use, is cause for disciplinary action Unauthorized removal of, tampering with, or ignoring any isolation device without proper authorization is cause for disciplinary action Lock Box In situations where multiple lockout devices are required for a single job, a lock box can be utilized to accomplish control of hazardous energy. The following procedure will be adhered to: A group lock box kit may be obtained from the tool room The group lock box will be placed at the work site or designated area The Equipment Proprietor will take steps following proper lockout/tagout/tryout procedures and attach the group locks (green) and Danger Do Not Operate tags on all appropriate equipment energy isolating devices The key for the group lock box locks will be placed in the group lock box.

11 Page 11 of The Equipment Proprietor will install a proprietor (red) lock and Do Not Operate on the group lock box so that it cannot be opened without removing the lock Using the isolation list, the Maintenance Supervisor in charge of the job or his designee who is familiar with the area will verify that the proprietor has properly isolated all possible energy sources and locked and tagged each device. He will then affix a Maintenance Do Not Operate Tag at each lock box lock (green) location All maintenance crew personnel will then install locks with proper identification on the group lock box as described in the lockout/tagout/tryout procedure It is the responsibility of each Crew Leader who performs lockout using a single lock box to review isolation lists, as well as physical equipment to ensure that the sources of hazardous energy, which apply, have been controlled by lock box locks. All authorized employees may verify lockouts and lockout procedures have been properly implemented After use, group lock boxes must be returned to the Tool Room or unit-designated area for proper inventory and maintenance. 5.5 Equipment Testing If lockout devices must be temporarily removed to test equipment, the following actions will be taken: Clear the process equipment and machinery of all tools and materials Employees not involved in testing will move away from the area Maintenance personnel will remove their individual (blue) locks Maintenance Crew Leaders will remove their crew (yellow) locks The Equipment Proprietor will remove the proprietor (Red) lock and Do Not Operate tag.

12 Page 12 of The Equipment Proprietor, with consultation from the Maintenance Crew Leader, will energize and proceed with testing The Equipment Proprietor will de-energize and repeat lockout/tagout/tryout procedure sequence as necessary. 5.6 Restoring Equipment and Machinery to Normal Operation When all work has been completed and maintenance locks removed, the Equipment Proprietor will be notified by the Maintenance Crew Leader. The Equipment Proprietor will remove the proprietor (red) lock and proprietor lockout tag and re-energize the circuit Maintenance Crew: Remove all tools and other equipment used to service the equipment and ensure that appropriate parts are all properly replaced Only after all individual blue locks of a maintenance crew have been removed and the crew's work completed will the (yellow) Maintenance Crew lock be removed Reinstall all guards that have been removed Check the area to make sure that all employees are clear The Equipment Proprietor will then be notified that the maintenance crew's work is completed Equipment Proprietors: Notify affected employees of completion of the job Remove proprietor (red) lock, tag, and lockout device Inspect equipment to ensure proper operation. 5.7 Absent Employee Lock Removal All equipment and machinery will be restored to "normal operation" by the Equipment Proprietor. If an individual is no longer on plant premises, then Department Supervision will:

13 Page 13 of Verify that the individual who engaged the lockout device is not at the plant Make every possible effort to contact the owner(s) of the lock to notify him/her of the lock removal Upon contacting the maintenance crew leader, both department supervision and the maintenance crew leader must mutually agree to the safe removal of this lock In such instances of removal, a Lock Removal Authorization form must be completed by operations supervision. The Authorization form will be sent to H&S within 24 hours. (See Appendix A) The Maintenance Crew Leader will take the Authorization form to the main gate so that they can void the employees PIN number. This will ensure that the owner of the lock knows of the lock removal before resuming work at the plant. 5.8 Transfer of Authority When work will be continued to the on coming shift The proprietor lock and tag will remain. All individual (blue) and crew (yellow) locks will be removed prior to leaving the plant. Maintenance personnel for the on coming shift will repeat the required lockout/tagout/tryout sequence and apply their respective crew (yellow) and individual (blue) locks When work will not be continued to the on coming shift The proprietor lock and tag will remain All individual (blue) will be removed prior to leaving the plant The crew (yellow) lock and orange tag will remain if the work is not complete The Maintenance Supervisor in charge of the work or his designee who is familiar with the job will also make a notation in the comment section of the work permit stating

14 Page 14 of Long Term Lockout that the work is not complete before returning the permit to unit operations. Long-term lockout - Any equipment that will be taken out of service and locked out for greater than a 6-month time period will be considered as a long-term lock out Procedure Prior to locking out equipment a long-term lock out form will be filled out Each Department Manager will designate a responsible person for filing long term lock out forms and maintaining locks and tags Before locking out any electrical equipment for long term, consult with your I&E department The equipment will be locked out using a long-term lockout (black) lock A designated long-term lockout tag will be affixed to the isolation point(s) Training Prior to putting back in service a Management of Change (class 2) must be followed The training for this procedure will be done via a monthly safety meeting module Cord and Plug Connected Equipment or Machinery Cord and plug connected equipment may be de-energized by unplugging the equipment from the energy source so long as the authorized employee performing the maintenance or servicing is in visual contact of the plug If the plug is not under exclusive control of the authorized employee, the plug must be locked and tagged following the lockout/tagout/tryout procedures.

15 Page 15 of If work is suspended for a period of time, (such as during breaks, lunch, or overnight), the plug must be locked and tagged following lockout/tagout/tryout procedures Isolation of Process lines and Blinding Procedure Isolation of process lines is accomplished to effectively isolate lines or process equipment to allow smaller areas to be purged, gas freed, and worked, instead of complete systems. When lines or equipment are being prepared for hot work, confined space entry, or when required by the equipment proprietor, the line or equipment must be isolated by utilizing single valve blocking and blinding, valve blocking and line or spool removal, or valve blocking and plugging all attached piping. Isolation of lines using double block and bleed should only be used when no other method can be used and requires Manager approval. Prior to attempting process line isolation, lockout/tagout of applicable valves is required Isolation of Process Lines: The Equipment Proprietor will provide an isolation list with necessary work permits to maintenance The Equipment Proprietor will check equipment and issue proper safe work permits for isolation of process lines to commence The Equipment Proprietor will assure maintenance crew personnel that there are no open lights, fires, or other sources of ignition within a safe distance downwind of the line or equipment to be opened Proper protective clothing and equipment will be worn according to the Axiall Personal Protection Equipment program HSP Lines and equipment will be depressurized and then opened very slowly to assure that there is no holdup of gas or liquid and that block valves and blinds are holding Lines and equipment will be prepared in accordance with the Axiall First Flange/Line Breaking program HSP prior to line breaking.

16 Page 16 of Precautions will be taken to minimize spillage The bleed valve that is utilized for purposes of de-pressuring and draining the system must be locked in the open position and be included on the isolation list. The bleed valve near the line break should also be locked in the open position if piping intersects the line between the low point drain valve and the line break (unless this is the same bleed valve). The intent is to provide an indication of a leaking valve Blinding: The Equipment Proprietor will determine the exact location where the process lines are to be blinded The Equipment Proprietor will consult his isolation list for locations requiring blinding and lockout procedures Blinding tags will be filled out by the Equipment Proprietor and Maintenance Crew Leader as described in the lockout/tagout/tryout procedure sequence. The entry location will then be placed on the Blinding Tag by the Equipment Proprietor If an isolation location will require a blind to be installed in the line, the Equipment Proprietor responsible for the line or equipment will provide a Blind Tag and a nylon tie, to be used at the location where the blind is to be installed The nylon tie must be: non-reusable; self-locking; and minimum unlocking strength of 50 lbs The maintenance crew who installs the blind will attach the Blind Tag securely to the blind handle The Equipment Proprietor who verifies that the blind has been correctly installed will complete all entries, remove the bottom portion of the blind tag and sign in the appropriate location on the isolation list.

17 Page 17 of The preferred placement for blinds will be at the flange closest to the vessel, tank or equipment. Blinds may be installed at flanges farther from the vessel if the first location is not practical Blinds may be installed on the side of blocked valves that is most consistent with pressure testing requirements When spool pieces are removed, open lines may be effectively plugged or blind flanged before work on that equipment is allowed Blinds will only be installed or removed at the request of the Equipment Proprietor Blinding locations will be documented on an isolation list that has been approved by the Equipment Proprietor The Equipment Proprietor is responsible for assuring that line or equipment preparation procedures are used before the installation or removal of blinds Managing Common Blinds The equipment proprietor will ensure that a locking mechanism is used on the blind and all locks are installed to make sure that the common blind is not removed until all jobs are complete. (Ref HSP for removal) Restoration of Process Lines and/or Blind Removal Procedures After maintenance has been accomplished to the Equipment Proprietor or designee's satisfaction, maintenance will return equipment to production When maintenance has removed the blind and restored the process lines to their original condition, they will then remove the Blind Tag and return it to the Equipment Proprietor or their designee The Equipment Proprietor will verify that the process line has been restored correctly. He will then sign the appropriate place on the isolation list and/or blind list

18 Page 18 of Common Blind Removal Provisional comments may be needed on Safe Work Permits and Isolation Lists until all jobs are complete and the blind is removed Isolation List Each operating unit will have isolation lists for confined space entries. Isolation list for other pieces of process equipment and machinery will be developed prior to the issuance of a Safe Work Permit. A copy of the isolation list must be attached to the permit. (Appendix B for Example) An isolation list will provide: A mechanism for recording relevant information on isolation practices; and A record that can be utilized during unit turnarounds and start-up as a means of "checking-off" as process lines are isolated or restored Isolation lists will consist of the following information: Entity/Equipment name Equipment number Electrical devices/switches to be isolated Valves to be isolated Process lines or spools to be removed Flange location where blinds will be installed All blinds installed (date and operator); All blinds removed (date and operator) Remarks and/or special precautions Bleed valves Tanks Under Construction

19 Page 19 of Tanks under construction that are not connected to process lines or other operating equipment are generally exempted from the rules governing lockout/tagout/tryout procedures Each case must be reviewed on an individual basis by Department Supervision Job-Made Slip Blinds Job-made slip blinds or Pancake blinds are to be cut from the appropriate material in the size desired. Blinds must be the correct diameter and flange rating and of sufficient thickness to withstand the pressures which may be encountered Specific attention should be given to cutting the blind handle as this will serve as a distinguishing characteristic of a blind versus a typical orifice plate Handles are to be painted red in color to provide a second means of identification Pipe Plugs Pipe plugs are alternative isolating devices for piping. Pipe plug procedures will follow the same requirements as blinds Pipe plugs will not be used without approval of the Unit Management Pipe plugs or plumbers/stoppers used in maintenance work should be of the appropriate pressure rating for the intended job. Pressures are usually stamped on the plug Work will not be performed in front of a line containing a pipe plug Always clean inside the pipe prior to inserting a plug A mandatory in-line gauge is required to assure appropriate pressure is not exceeded Working On Or Near Energized Equipment Due to the maintenance constraints and the need for operating continuity, it is sometimes necessary to perform tests and/or minor repairs to energized

20 Page 20 of 35 equipment and machinery. This procedure is designed to allow this type of work with a minimum danger to person and equipment. This procedure is not intended to replace the lockout/tagout/tryout procedure and should never be used when that procedure may be applied. This procedure will be employed when it is necessary for maintenance to perform tests; inspections and/or trouble shoot process equipment and machinery in a way that may expose them to the danger of coming into contact with hazardous energy sources It is the primary responsibility of Operations Supervision with consultation from the Maintenance Crew Leader as to the necessity of employing this procedure Operations Supervision must consider the possible impact on production and equipment should mishaps occur during the course of the work. Department Supervision will take all possible precautions as dictated by the nature of the work The Maintenance Crew Leader's first consideration will be the safety and qualifications of the personnel performing the work and secondly the safety of the equipment involved. A very deliberate approach in outlining the work to be performed and in enforcing all applicable safety precautions must be taken Procedure: When work will be conducted on or near energized equipment a Safe Work Permit must be issued by the Equipment Proprietor to the individual performing the work. The Safe Work Permit must clearly state that work will be done on energized equipment and list any special requirements, including PPE and standby When the work to be performed necessitates that an explosionproof seal be broken in a classified area, that area will be tested for combustible mixtures before a safe work permit is issued When electrical testing requires that a technician work with a potential greater than 120 volts to ground, they will be accompanied by an observer who will not take part in the actual work, but will serve as a standby The standby will be required to wear the same personal protective equipment as the person performing the work.

21 Page 21 of The standby need not be an electrical technician, but anyone who is briefed beforehand as to the proper emergency procedures as detailed by the electrician At a minimum the emergency procedures will include the electrician wearing a non-conductive tag line if there are no options for remotely shutting off the power The individual performing the work will employ all applicable safety precautions as dictated by the nature of the work. An individual working in an enclosure containing greater that 120 volts to ground will be required to wear goggles or face shield and rubber gloves rated at a voltage greater than the phase to phase potential available If the work area must be left unattended at any time, it is the responsibility of the person performing the work to secure all exposed energized equipment parts and to lock all associated switches before leaving. If the equipment cannot be secured, the area must be barricaded with Red Barricade Tape and posted with a sign stating Danger Live Electrical Equipment Authorized Personnel Only During routine preventive maintenance, a qualified electrician isolating electrical equipment for their sole protection may lock the equipment with their individual (blue) lock without the additional proprietor (red) and crew leader (yellow) locks When the work is completed, the person performing the work will notify the Equipment Proprietor in person Plugged Line Safety Procedure Note: This section is a subpart of this program and addresses uncommon tasks that are completed on irregular basis. It identifies the more hazardous materials and the basic steps to follow when dealing with each Operating Department personnel will prepare equipment to reduce risk of unnecessary exposure to personnel performing the job.

22 Page 22 of The section of line containing the pluggage shall be isolated to ensure that no hazardous energy is present Personal protective equipment must be used to protect personnel performing the work. Applicable Departmental Hazard Assessments and/or Operating Procedures should be referenced for PPE requirements. The The contained pressure must be released in some controlled, safe fashion. methods authorized to release confined pressure are: a Bleeders - This is the most preferred method. Bleeders can be plugged but may be cleared using pressure, vacuum, or rodding (with caution) b opposite side ofthe line. Flanges - Red Barricade Tape the work area. Break flanges on c Drill Hole in Pipe - If there are no bleeders or flanges to release the contained pressure, a small pilot hole must be drilled to the center of the pipe. (An air-operated drill must be used for flammable materials.) Once the contained pressure has been released, the pipe may be cut using cold methods at the location of the drilled pilot hole. This method can be used only with permission from the Department Manager and Maintenance Manager. HSP-201 Hot Tap Permit must be followed d This requirement also applies to long sections of plugged flanged piping that has been removed from its normal location. Multiple cuts require multiple pilot holes Permits must specifically describe the work to be done, equipment to be used, necessary personal protective equipment, special exposure precautions, and any other items deemed necessary by the operating supervisor. The Safe Work Permit must be clearly posted at the job site The scope of work can be changed only after a thorough supervisory review and a new permit is issued The work area must be barricaded to keep unprotected personnel out of the area All personnel performing work must know the location of the nearest safety shower and eyewash. When safety showers are either not available or not functioning properly, the job shall be delayed until this condition is corrected All lines shall be treated as they are liquid full and under pressure until the ends are broken and it has been determined that the line is not plugged nor does it contain any hazardous energy or material.

23 Page 23 of The Operations and Maintenance Supervisors will verbally review the safety considerations regarding that job as the last item prior to the start of the job. This safety reminder shall include the job specific PPE relevant to the job If the scope of work must be changed, plant or contract personnel must discuss the proposed method with their plant supervisor and gain approval. A new permit should then be requested and issued from Operations. 6.0 TRAINING 6.1 All technicians will receive annual control of hazardous energy awareness training for all authorized and affected employees. Affected employees will be instructed in the purpose and use of the hazardous energy control procedure. 6.2 Axiall provides additional detailed instructions to authorized employees on: The types and magnitude of hazardous energy at Axiall Plaquemine Complex; The potential hazards of process equipment and machinery which can store potentially hazardous energy; The methods and means necessary for energy isolation and control; and Proper use of hazardous energy control procedures. 6.3 All new employees will receive appropriate lockout/ tagout/tryout training prior to performance of any process equipment or machinery-related tasks. 6.4 Employees will reexamine procedures for hazardous energy control for any updated procedures or whenever changes in job assignment or process equipment and machinery occur. 6.5 Retraining will be conducted whenever a periodic inspection reveals that employees are not fully aware of or are not following established procedures, or if regulatory requirements change. 7.0 RECORD KEEPING 7.1 Training records will be kept on each employee. 7.2 Isolation list records will be kept for one week upon work completion.

24 Page 24 of PROGRAM REVIEW AND ANNUAL INSPECTIONS 8.1 Program Review This Axiall Control of Hazardous Energy Program will be reviewed at least every three years. H&S will ensure this review is performed. The purpose is to assess compliance, to ensure that all necessary employees are included, and to evaluate program effectiveness Following the review, the Control of Hazardous Energy Program will be revised to include any necessary changes. Review results will be documented. All employees will be informed of any changes made in the plan Safety Involvement Team will develop corrective action plans and schedules to address any deficiencies documented during reviews Corrective action plans will be submitted to H&S. 8.2 Annual Lockout/Tagout/Try Inspections 9.0 REFERENCES Annual LO/TO inspections will be conducted to ensure compliance with OSHA s LO/TO Standard. (Appendix C) The inspection will be conducted by authorized employees not involved in the energy control procedure being inspected All LO/TO documentation will be forward to H&S The inspection shall include a review of: All employee work practices involving activities and application of the hazardous energy control procedures; Equipment and machinery energy isolating devices; and Isolation lists. American National Standards Institute (1982). "Safety Requirements for the Lock Out/Tag Out of Energy Sources." ANSI Z244.1, New York, NY.

25 Page 25 of 35 American Petroleum Institute (February, 1983). "Safe Maintenance Practices in Refineries," API Publication No. 2007, Washington, D.C. National Institute for Occupational Safety and Health (September, 1983). "Guidelines for Controlling Hazardous Energy During Maintenance and Servicing," DHHS (NIOSH) Publication No , Cincinnati, OH. Occupational Safety and Health Administration's 29 CFR (September 1, 1989). "The Control of Hazardous Energy (Lockout/Tagout)." Occupational Safety and health Administration's 29 CFR (August 6, 1990). "Training." Occupational Safety and health Administration's 29 CFR (August 6, 1990). "Selection and Use of Work Practices."

26 Page 26 of APPENDICES Appendix A - Lock Removal Authorization Form Appendix B - Equipment Isolation List (Example) Appendix C - Annual Lockout/Tagout/Try Inspection Appendix D Long Term Lockout Form

27 Page 27 of 35 Appendix A Lock Removal Authorization Form

28 Page 28 of 35 LOCK REMOVAL AUTHORIZATION FORM Refer to the Control of Hazardous Energy Program in the Safety Program and Procedures Manual. Policy: It is the policy of Axiall Plaquemine Complex that no action will be taken to remove an isolation device belonging to another individual without this form being completed which is the written approval of management. USE THIS FORM FOR EACH INDIVIDUAL(S ) LOCK(S) REMOVED LOCK IDENTIFICATION Employee's Name Location of Lock(s) Company Reason for Removal: Equipment and Area Inspected by: Servicing/Repairs Verified Complete by: Production Supervision Maintenance Supervision APPROVAL Date Date Notify the Main Guard Gate that an isolation device has been removed and give employee's name. The guard will void the employee's PIN number to prevent him/her from entering the plant until they have been made aware that their isolation device (lock) has been removed. Note: This form must be sent to the Health & Safety Department within 24 hours. Revised 8/31/98

29 Page 29 of 35 Appendix B Equipment Isolation List Example

30 Equipment Name: Description of Task: EQUIPMENT ISOLATION LIST Equipment Number: Work Order Number: Energy Isolation Points: (electrical devices and switches, valves, blinds installed, double blocks and bleeds, spools removed, etc.) Date of Isolation Tech. Initials Removed EXAMPLE SPECIAL PRECAUTIONS / COMMENTS

31 Appendix C ANNUAL LOCKOUT/TAGOUT/TRY INSPECTION

32 ANNUAL LOCKOUT/TAGOUT/TRY INSPECTION (To be completed at a time when a Lockout Activity is in progress) UNIT Equipment DATE LOCKOUT ACTIVITY IN PROGRESS: EMPLOYEE(S) INTERVIEWED: 1) 2) 3) 4) 5) 6) 7) 8) 9) 10) 11) Is the equipment isolation log for the lockout/tagout/try activities posted where all employees can check it. Have all lockouts been tried? Are lockout devices installed properly? Is any equipment locked out, but is not listed on the equipment isolation log? Is any equipment on equipment isolation log not locked out? Are all affected employees and/or contractors in the area aware of the lockout activities in progress and the specific equipment that is locked out? Are employees familiar with Axiall s lockout/tagout/try policy and procedures? Are contractors familiar with the lockout/tagout/try policy and procedures? If chains/locks are being used as interim lockouts for valves, are the chains tightly wrapped in such a way as to prevent operation of the valve? Are all lockout devices in good condition? Are all electrical breakers capable of being locked out? AUDITED BY: REMARKS: Deficiencies must be reported to management for mitigation. File audits in unit and route copy to Health and Safety.

33 Appendix D Long Term LockOut

34 Long Term Lock Out Form Date of Long Term Lock Out: Unit or Area Equipment that is involved in the lock out: Reason for the Lock Out: Tag Number Anticipated return to service date. Employee performing the lock out. Is an MOC established for this lockout? Yes No Have all affected employees been notified (I&E, Maintenance, Shifts ) Yes No If no was checked please state the reason. Manager (or designee)

35 Signature