Fall Protection Guidelines. Individual Unit Function: Safety Procedure No.: SOP-0111 Page: 1 of 13. Preparer: Owner: Approver: Safety Safety Safety

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Procedure No.: SOP-0111 Page: 1 of 13 MIDGA Reviewed: 09/187/1 Effective: 09/17/17 Supersedes: Ver. 1.0 7 1. PURPOSE These guidelines are to provide minimum standards for work on corrugated roofing, structural steel, flat roofs, outside handrails, on ladders, on scaffolding, in overhead buckets, pole climbing, stack climbing, and surfaces 4 or more feet above ground or another surface. 2. DEFINITIONS 2.1. Aerial Lift A power platform or a vehicle mounted work platform used to elevate personnel to above ground work locations. This includes articulating boom platforms, vertical towers, and extensible boom platforms. 2.2. Anchorage Point A secure point of attachment for Lifelines, lanyards or deceleration devices. 2.3. Body Harness A fall restraint device component consisting of a harness system designed to spread shock load over the shoulders, thighs and seat area. 2.4. Competent Person One who is capable of identifying existing and predictable hazards in the surroundings or work conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them. 2.5. Fall Protection System A system used to protect personnel from fall hazards. Such systems may include Guardrail Systems, Safety Net Systems, Personal Fall Arrest Systems, Warning Line Systems, Safety Monitoring Systems or covers. 2.6. Guardrail System A barrier erected to prevent personnel from falling to lower levels.

Procedure No.: SOP-0111 Page: 2 of 13 2. DEFINITIONS cont d. 2.7. Floor Hole An opening measuring less than 12 inches but more than 1 inch in its least dimension, in any floor, platform, pavement, or yard through which materials but not persons may fall. 2.8. Lanyard A flexible line or rope, wire rope, or strap which generally has a connector at each end for connecting the Body Harness to a deceleration device, Lifeline, or anchorage. 2.9. Leading Edge The edge of a floor, roof or form work for a floor or other walking/working surface, (such as a deck) which changes location as additional floor, roof, decking or form work sections are placed, formed or constructed. A Leading Edge is considered to be an "unprotected side and edge" during periods when it is not actively and continuously under construction. 2.10. Lifeline A component consisting of a flexible line for connection to an anchorage at one end to hang vertically (vertical Lifeline), or for connection to anchorages at both ends to stretch horizontally (horizontal Lifeline), and which serves as a means for connecting other components of a Personal Fall Arrest System to the anchorage. 2.11. Low Pitched Roof A roof having a slope less than or equal to a 4 in 12 vertical to horizontal. 2.12. Lower Level Those areas or surfaces to which an employee can fall. Such areas include, but not limited to; ground levels, floors, platforms, ramps, runways, tanks, equipment, or structures. 2.13. Mechanical Equipment All motor or human propelled wheeled equipment used for roof work, except wheelbarrows or mop carts. 2.14. Personal Fall Arrest System

Procedure No.: SOP-0111 Page: 3 of 13 A system used to arrest personnel in a fall from a working level. It consists of an anchorage, connectors, a Body Harness, and may include a Lanyard, deceleration device, Lifeline, or suitable combinations of these. 2. DEFINITIONS cont d. 2.15. Qualified person A person who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training and experience, successfully demonstrated the ability to solve/resolve problems relating to the subject matter, the work, or the project. For the purposes of this standard, a Qualified Person is a licensed professional (civil and or structural) engineer in the state in which the respective BASF site is located. 2.16. Safety Net System A net placed below workers to catch them in the event a worker falls. 2.17. Safety Monitoring System A safety system in which a Competent Person is responsible for recognizing and warning personnel of fall hazards. The Competent Person shall: Be competent in the recognition of fall hazards. Be capable of warning workers of fall hazard dangers and in detecting unsafe work practices. Be on the same walking/working surface and in visual sighting distance of the employees being monitored. Be close enough to work operations to communicate orally with workers and has no other duties to distract from monitoring function. 2.18. Steep Roof A roof having a slope greater than a 4 in 12 vertical to horizontal. 2.19. Suspension Trauma Also known as harness hang syndrome (HHS), is an effect which occurs when the human body is held upright without any movement for a period of time. If the person is strapped into a harness or tied to an upright object they could eventually faint and could lead to a fatality. 2.20. Unprotected Sides and Edges

Procedure No.: SOP-0111 Page: 4 of 13 Any side or edge (except at entrances to points of access) of a walking/working surface, e.g., floor, roof, ramp, or runway where there is no wall or Guardrail System at least 39 inches (1.0 m) high. 2.21. Warning Line System A barrier (wire, rope or chain and supporting stanchions) erected on a roof to warn employees that they are approaching an unprotected roof side or edge, and which designates an area in which the roof work may take place without the use of guardrails, Body Harness, or Safety Net systems to protect employees in the area. 2. DEFINITIONS cont d. 2.22. Walking/Working Surfaces Any surface, whether horizontal or vertical, on which a person walks or works, including but not limited to floors, grating, roofs, ramps, bridges, runways, formwork, and concrete reinforcing steel, but does not include fixed ladders, vehicles, or trailers on which personnel must be located to perform their work duties. 3. SCOPE These guidelines apply to all employees and contractors of BASF MIDGA Operations. 4. PROCEDURE 4.1 PERSONAL FALL ARREST SYSTEM FALL PROTECTION GUIDELINES A safety harness (or other approved fall protection device or system) must be worn and tied-off when working on the following: Sloping roofs Flat roofs without handrails within six feet of the edge or roof opening Any suspended platform or stage Any scaffold with incomplete handrail or decking Ladders near the edge of roofs and floor openings In the area of roof or floor openings When placing and tying reinforcing steel in walls, piers, or columns When removing floor planks from the last panel in a temporary floor In areas exposed to protruding reinforcing steel When assembling and disassembling scaffolding

Procedure No.: SOP-0111 Page: 5 of 13 When working in aerial lifts When working on a ladder and feet of worker surpass the 6 foot point. Fall protection is mandatory at 6 feet or higher (in the absence of handrails). Manufacturers recommendations for inspection, use, and equipment life will be observed for all fall protection equipment. Any damaged equipment will be repaired in accordance with the manufacturer or discarded. In addition to pre-use inspections, fall protection will be certified annually by a qualified person. 4.2 CORRUGATED ROOFING For work on corrugated roofing, fall protection will be required at all times. The fall protection system selected should protect against falls from the edge of the roof as well as falls through the roof. Any of several methods can be used for achieving the required protection, the specific method used will be job and location dependent and determined by the supervisor and crew. Remember: Any anchorage point or lifeline must support a 5000 pound fall force per person anchored to it or shall be designed, installed and used as part of a complete Personal Fall Arrest System which maintains a safety factor of at least two, under the supervision of a Qualified Person. 4.3 STRUCTURAL STEEL For employees working on structural steel, fall protection will be required whenever employees are working more than 6 feet off the ground. It is the responsibility of the project engineer and the supervisor/crew to determine the method that best protects employees. 4.4 FLAT ROOF BUILDINGS If work is required within 6 feet of the edge of a flat roof, or if other unusual conditions are present, then fall protection will be required. 4.5 PLATFORMS, OPEN-SIDED FLOORS, AND RUNWAY AREAS (OPEN LOADING BAYS, PORTABLE RUNWAYS BETWEEN PLATFORMS AND PLATFORMS/WALKWAYS NEXT TO RAILROAD BAYS.)

Procedure No.: SOP-0111 Page: 6 of 13 Every open-sided floor, runway, or platform 4 ft. or more above an adjacent floor or ground level shall be guarded by a standard railing on all sides. The railing shall be equipped with a toeboard when there is potential for falling materials coming from the guarded level. A standard railing shall consist of a top rail, intermediate rail, and posts and shall be a vertical height of 42" from upper surface to top rail to the floor, platform, runway, or ramp level. The intermediate rail shall be approximately halfway between top rail and surface. Pipe railings shall be at least 1.5 in. normal diameters with posts spaced not more than 8 ft. on centers (Note: See BASF Midga Structural Standards - Standard Guardrail and Handrail Details - Drawing #Midstds1000, MidStdS1001). If, for any reason, rails are removed, protection shall be provided to prevent a person from falling to a lower level. For a surface greater than 6 ft. above ground level or to a lower level, Personal Fall Protection shall be worn. The rails shall be replaced immediately after work requiring their removal has been completed. Never rig a system that would allow you to free-fall more than a distance of six feet. (For example, if you are 6 feet tall, using a six foot lanyard with shock absorbing function, and are anchored above your head, your feet will end up about 15 feet from where they started in a 6 foot free fall.) You may need to use an anchor/connector that will allow less than 6 feet free fall to prevent you from hitting an obstacle or surface. Here s two ways to limit free-fall: Use a retractable lanyard between the lifeline and your harness. Reduce the amount of slack in your lanyard by raising your tie-off point. Your tie-off to the lifeline or anchor must always be level with or higher than the connection to your harness. 4.6 SLURRY CARS - PORTABLE FALL PROTECTION When work is being performed on top of slurry cars, such as loading, unloading or maintenance work, any access way through the handrail on top of the slurry car that is not protected by a fold down ramp shall be guarded by placing a portable handrail across the open access way. 4.7 WORK OUTSIDE OF HANDRAILS

Procedure No.: SOP-0111 Page: 7 of 13 Work outside of handrails is performed due to equipment failure. In the areas where maintenance is to be performed, especially routinely, walkways with the proper handrails should be provided. In those instances where work outside of handrails must be performed on a non-routine basis and can not be performed from the level below, Personal Fall Protection must be provided. Also, when any personnel are in the process of removing or replacing handrails, opening or closing swing out handrails, or opening or closing elevated swing out doors, fall protection shall be worn, unless the task can be performed from the surface below. 4.8 LADDERS Ladder guidelines will comply with MSHA regulations which include: 56.11003 Ladders shall be of substantial construction and maintained in good condition. Note: Ladders should be inspected before and after each use. Any ladder determined defective or not meeting the standards of MSHA/OSHA shall be identified with a tag and arrangements for repairs or replacement made. Ladders to be replaced should be destroyed and not discarded. 54.11004 Portable rigid ladders shall be provided with suitable bases and placed securely when used. Note: Extension ladders should be secured at the top when possible and extend at least three feet above the top landing. Extension ladders should be positioned 75 degrees from the horizontal. 56.11005 Fixed ladders shall be anchored securely and installed to provide at least three (3) inches of toe clearance. 56.11006 Fixed ladders shall project at least three (3) feet above top landings, or substantial handhold shall be provided above the landings. 56.11007 Wooden components of ladders shall not be painted except with a transparent finish. 56.11011 Persons using ladders shall face the ladders and have both hands free when ascending and descending. Note: The top and last step of a portable ladder shall not be used as standing or sitting platforms. In addition, employees working off ladders where a fall greater than six (6) feet could result must wear a safety harness and attach the lanyard to another structure when possible. Tool pouches or other means should be used to transport materials to leave both hands free for ascending and descending the ladder. 56.11025 Fixed ladders, except on mobile equipment shall be offset and have substantial railed landings at least every 30 feet unless backguards or equivalent protection, such as safety harnesses and safety lines are provided. Note: Fixed ladders should be provided with cages when the total length of the ladder exceeds 20 feet unless equivalent fall protection is provided.

Procedure No.: SOP-0111 Page: 8 of 13 56.11026 Fixed ladders 70 degrees to 90 degrees from the horizontal and 30 feet or more in length shall have backguards, cages or equivalent protection, starting at a point not more than seven feet from the bottom of the ladder. Note: Standard 56.11026 is referring to ladders measured from the ground. Ladders which are located on elevated areas, such as on walkways at dust collectors, where the fall potential is greater than twenty (20) feet will require a backguard or equivalent protection even if the ladder is less than 20 feet in length. Finally, backguards, ladder cages, or other protection should also be evaluated on a case-by-case basis and provided if other hazards require their use. 4.9 WORKING FROM LADDERS/UNRAILED PORTABLE PLATFORMS Personal fall protection is required when working from a ladder/platform 6 feet or more above the surface the ladder/platform rests on or within 6 feet of a handrail. 4.10 SCAFFOLDING Scaffolding design shall comply with the following MSHA guidelines: 56.11027 Scaffolds and working platforms shall be made of substantial construction and provided with handrails and maintained in good condition. Floorboards shall be laid properly and the scaffolds and working platforms shall not be overloaded. Working platforms shall be provided with toe-boards when necessary. Note: In addition to the MSHA guideline, the scaffold should be adequately secured to prevent it from tipping over. It should also be placed on stable ground to prevent settling. Floorboards should be secure and toe-boards provided if work materials (tools, metal, etc.) could fall from the scaffold. Safety harnesses must also be worn while working from a scaffold when handrails cannot be provided. 4.11 SHINGLE ROOFS Work on shingle roofs can be considered to be similar to work on corrugated roofing. Fall protection must be provided, however the type of protection is to be chosen based on the nature and specific needs of each job. 4.12 OVERHEAD BUCKETS All employees working in elevated buckets will wear a safety harness with the lanyard attached to the boom. This includes work in manlifts, cranes, and hydralifts. 4.13 POLE CLIMBING

Procedure No.: SOP-0111 Page: 9 of 13 Pole climbing will not be performed by BASF employees without approval of the superintendent in charge. Special protection will be developed based on individual needs of the job. 4.14 STACK CLIMBING The stack at 11F calciner will be climbed using the fall protection system provided on the ladder. 4.15 MANBASKETS When hoisting personnel in manbaskets: 1. Basket must be lowered under power, no freefall. 2. Hoist must be equipped with an anti-tier blocking device. 3. Personnel must be secured by a safety harness hooked to the cable above wedge socket. 4. Hook must be equipped with a safety clip. 5. Manlifts are not to be used as an anchorage point when working outside the basket. 4.16 USE OF HYDRALIFTS If the use of this equipment is being considered for fall protection, EHS review is required. Whatever method is chosen, a rescue plan in the event of a fall shall be in place. 4.17 Anchorage Points Anchorage points used for attachment of personal fall arrest equipment shall be designed and or approved by a Qualified Person. The anchorage shall be capable of supporting 5,000 pounds per worker attached or shall be designed, installed and used as part of a complete

Procedure No.: SOP-0111 Page: 10 of 13 5. RESPONSIBILITIES 6. RELATED DOCUMENTS Attachment A Personal Fall Arrest System which maintains a safety factor of at least two, under the supervision of a Qualified Person. Conduit, cable trays, grating, and handrails shall not be used as anchoring points. Section Revision Revised By Date Revised 4.16 Added Section WJK 3/30/12 4.17 Added Section EM 8/8/13 4.2 Added condition EM 8/8/13 Attachment A Added Attachment EM 8/8/13 All SOP Review KH 9/17/17

Procedure No.: SOP-0111 Page: 11 of 13 ATTACHMENT A Typical tie-off attachments for one worker MAXIMUM ALLOWABLE SPANS FOR BEAMS USED AS FALL PROTECTION BEAMS Depth MAXIMUM DEPTH WIDTH ALLOWABLE SPAN (in) (in) (ft) 4 4 10 6 4 8 6 6 19 8 4 9. 10 4 10 12 4 11 Width CHANNELS Depth DEPTH (in.) MAXIMUM ALLOWABLE SPAN (ft) 6 6 8 9 9 10 10 11

Procedure No.: SOP-0111 Page: 12 of 13 TEES Depth Width MAXIMUM DEPTH WIDTH ALLOWABLE SPAN (in) (in) (ft) 4 4 6 5 4 10 6 4 15 BEAM TABLES ARE BASED ON THE FOLLOWING: 1. Personnel use shock-absorbing Lanyards (meeting ANSI Z359.1) which limit the load distributed to the Body Harness to 900 lbs. 2. One worker is tied to a beam within a given span at any time. 3. Table is not for Lifeline (cable) anchorage. 4. Spans > 20 ft. shall not be approved by a Qualified Person. IF ANY OF THE ABOVE CONDITIONS CANNOT BE MET, ALTERNATIVE ANCHORAGE POINTS AND FALL PROTECTION SYSTEMS MUST BE APPROVED BY A QUALIFIED PERSON. MAXIMUM ALLOWABLE SPANS FOR PIPES USED AS FALL PROTECTION PIPES NOMINAL PIPE DIAMETER (in) MAXIMUM ALLOWABLE SPAN (ft) Nominal Pipe Diameter < 3 not allowed 3 10 4 16 PIPE TABLE IS BASED ON THE FOLLOWING: 1. Personnel use shock-absorbing Lanyards (meeting ANSI Z359.1) which limit the load distributed to the Body Harness to 900 lbs. 2. One worker is tied to a pipe within a given span at any time. 3. Carbon steel pipes. 4. Continuously welded pipe i.e. no flanges or fittings within the tie-off span. 5. Nominal pipe diameter based on un-insulated lines. 6. Table is not for Lifeline (cable) anchorage. 7. Spans > 20 ft. shall not be approved by a Qualified Person.

Procedure No.: SOP-0111 Page: 13 of 13 IF ANY OF THE ABOVE CONDITIONS CANNOT BE MET, ALTERNATIVE ANCHORAGE POINTS AND FALL PROTECTION SYSTEMS MUST BE APPROVED BY A QUALIFIED PERSON.