Document Number: HSP 325 Current Rev: 07/23/2015 PSM 6...

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Document Number: HSP 325 PSM 6 Revised By: Jake A. Valenti Manager Approval: Hillary Garner Current Rev: 07/23/2015 Revision No.: 9 Page 1 of 28 HEALTH AND SAFETY PROGRAM 325 – CONTRACTOR SAFETY MANAGEMENT Printed controlled copy expires 24 hours after 2:19 PM on 8/10/2015. 1.0 PURPOSE Axiall, Plaquemine, has developed this document to ensure the site achieves desired safety performance by contractors, thus enhancing contractor employee protection. This document provides guidelines to assure that contractors and their tiers of subcontractors are meeting or exceeding Axiall’s expectations and requirements. 2.0 SCOPE This document applies to all contractor companies performing work at Axiall, Plaquemine, through contractual agreement, by service contract, purchase order, etc…, including, but not limited to contractor personnel performing maintenance, repair, turnaround, renovation or specialty work. 3.0 RESPONSIBILITIES 3.1 Procurement Department 3.1.1 Issue contracts for services to only those companies that have satisfied all contractor qualification requirements for Axiall, Plaquemine. 3.1.2 Issue contracts, purchase orders to contractors that have A or B company grade in ISNetworld. 3.1.3 Retain copies of all required contract documents for PSM audit purposes. 3.1.4 Inform all contractors that a condition of performing work at the Plaquemine Complex is to adhere to the site safety requirements. 3.2 Authorized Axiall Representative 3.2.1 Ensure contractor has acceptable ISNetworld company grade before requesting them to the site. 3.2.2 Invite contractor to attend the monthly contractor safety meeting held the first Wednesday of every month at 1:00pm in the Rebecca room of the H&S building. 3.2.3 Monitor contractor's work areas for compliance to all applicable regulations and Axiall health and safety policies and procedures. 3.2.4 Participate in inspections of Contractor work areas and ensure closure on inspection findings. 3.2.5 Obtain contact information for contractors’ home office, corporate health and safety contact, job superintendent and site health and safety representative. 3.2.6 Review all contractor chemical inventories and SDS and send all new chemicals through “New Chemical Approval” process. 3.2.7 Complete “Post Job Evaluation” for all jobs performed by a contractor. 3.2.8 Notify Health and Safety of any contractor incident as soon as possible.

Transcript of Document Number: HSP 325 Current Rev: 07/23/2015 PSM 6...

Document Number: HSP – 325

PSM – 6

Revised By: Jake A. Valenti

Manager Approval: Hillary Garner

Current Rev: 07/23/2015

Revision No.: 9

Page 1 of 28

HEALTH AND SAFETY PROGRAM 325 – CONTRACTOR SAFETY MANAGEMENT

Printed controlled copy expires 24 hours after 2:19 PM on 8/10/2015.

1.0 PURPOSE

Axiall, Plaquemine, has developed this document to ensure the site achieves desired safety

performance by contractors, thus enhancing contractor employee protection. This document

provides guidelines to assure that contractors and their tiers of subcontractors are meeting or

exceeding Axiall’s expectations and requirements.

2.0 SCOPE

This document applies to all contractor companies performing work at Axiall, Plaquemine,

through contractual agreement, by service contract, purchase order, etc…, including, but not

limited to contractor personnel performing maintenance, repair, turnaround, renovation or

specialty work.

3.0 RESPONSIBILITIES

3.1 Procurement Department

3.1.1 Issue contracts for services to only those companies that have satisfied all

contractor qualification requirements for Axiall, Plaquemine.

3.1.2 Issue contracts, purchase orders to contractors that have A or B company

grade in ISNetworld.

3.1.3 Retain copies of all required contract documents for PSM audit purposes.

3.1.4 Inform all contractors that a condition of performing work at the Plaquemine

Complex is to adhere to the site safety requirements.

3.2 Authorized Axiall Representative

3.2.1 Ensure contractor has acceptable ISNetworld company grade before

requesting them to the site.

3.2.2 Invite contractor to attend the monthly contractor safety meeting held the

first Wednesday of every month at 1:00pm in the Rebecca room of the H&S

building.

3.2.3 Monitor contractor's work areas for compliance to all applicable regulations

and Axiall health and safety policies and procedures.

3.2.4 Participate in inspections of Contractor work areas and ensure closure on

inspection findings.

3.2.5 Obtain contact information for contractors’ home office, corporate health and

safety contact, job superintendent and site health and safety representative.

3.2.6 Review all contractor chemical inventories and SDS and send all new

chemicals through “New Chemical Approval” process.

3.2.7 Complete “Post Job Evaluation” for all jobs performed by a contractor.

3.2.8 Notify Health and Safety of any contractor incident as soon as possible.

Document Number: HSP – 325

PSM – 6

Revised By: Jake A. Valenti

Manager Approval: Hillary Garner

Current Rev: 07/23/2015

Revision No.: 9

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HEALTH AND SAFETY PROGRAM 325 – CONTRACTOR SAFETY MANAGEMENT

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3.2.9 Send incident report/investigation report to Health and Safety upon receiving

the report.

3.2.10 Send following HSP’s to site contractor representative as applicable. Any

procedures sent to the contractor must be stamped/marked as “Date: Good

for Duration of Job.” 3.2.10.1.1 HSP – 103 “Plant Entry Requirements”

3.2.10.1.2 HSP – 106 “ General Safety Rules”

3.2.10.1.3 HSP – 200 “Safe Work Permitting”

3.2.10.1.4 HSP – 202 “Confined Space Entry Permitting”

3.2.10.1.5 HSP – 307 “Line Breaking”

3.2.10.1.6 HSP – 317 “Control of Hazardous Energy”

3.2.10.1.7 HSP – 318 “Excavation Safety”

3.2.10.1.8 HSP – 319 “Fall Protection”

3.2.10.1.9 HSP – 325 “Contractor Safety Management”

3.2.10.1.10 HSP- 302 “Signs, Signals, &Barricades”

3.2.10.1.11 HSP – Any other applicable HSP’s

3.3 Health & Safety Department (H&S)

3.3.1 Monitor ISNetworld grades for all connected contractors; work with ISN and

the contractor to maintain an acceptable grade.

3.3.2 Evaluate contractor health and safety requirements to ensure full compliance

with requirements of this policy during the qualification process. This will be

accomplished within ISNetworld.

3.3.3 Review annually contractor's (Evergreen) safety performance and verify

implementation through field inspections and surveillance.

3.3.4 Make Axiall Health and Safety Procedures available via ISNetworld.

3.3.5 Track any post-job evaluation action items to completion.

3.4 Operations Supervision

3.4.1 Axiall operations and maintenance supervision will meet as often as

necessary with contractor employers to discuss safe work practices and

contractor safety performance.

3.5 Security

3.5.1 Ensure contractor company has A or B ISNetworld company grade; if not

deny gate entry.

3.5.2 Ensure that contractors wear temporary badge and appropriate safety

equipment (e.g. hard hat, safety glasses, and NIOSH approved acid gas escape

respirator (Honeywell (model 7902) preferred) prior to entry into the facility.

3.5.3 Ensure that all contractors have proper safety orientations prior to entering

plant for work.

Document Number: HSP – 325

PSM – 6

Revised By: Jake A. Valenti

Manager Approval: Hillary Garner

Current Rev: 07/23/2015

Revision No.: 9

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3.5.4 Provide site-specific orientation for contractor personnel prior to allowing

work on site for emergency jobs via Health & Safety approval

3.5.5 Ensure that all contractor employees use the turnstiles or scanners when

entering and leaving the complex.

3.5.6 Periodically inspect vehicles upon entering and exiting the plant per Axiall’s

security plan.

3.6 Contractors and Subcontractors

3.6.1 Submit all qualification forms and subsequent documentation including the

health and safety program associated with pre-qualification process for the

contractor and any sub-contractors to be used to ISNetworld – all

subcontractors shall have their own ISNetworld account.

3.6.2 Ensure all employees and subcontractor employees complete the ARSC

Basic Plus safety orientation and Axiall site-specific orientation prior to

beginning work on site.

3.6.3 Immediately report injuries, illnesses or other significant safety issues to

Authorized Axiall Representative.

3.6.4 Conduct and document weekly safety inspections of the work site.

3.6.5 Conduct weekly safety meetings for all employees.

3.6.6 Turn in an incident investigation report to Authorized Axiall Representative

within twenty-four (24) hours following any incident, injury or near miss.

3.6.7 Conduct daily tailgate safety meetings.

3.6.8 Comply with all applicable federal regulations and Axiall safety policies and

procedures.

3.6.9 Participate in scheduled third-party or Axiall internal process safety

management (PSM) audits for contractors; this will include providing

requested documentation and following action items to closure.

3.6.10 Submit hours worked and acknowledge Axiall Health & Safety procedure

changes via Monthly Contractor Report sent via email by the H&S

department.

3.6.11 Attend post-job evaluation with Axiall representative, when invited.

4.0 CONTRACTOR TIERS

4.1 Requirements of Tiered Contractor Companies

*ALL ENTRY REQUIREMENTS OF AXIALL HSP-103 APPLY.

Document Number: HSP – 325

PSM – 6

Revised By: Jake A. Valenti

Manager Approval: Hillary Garner

Current Rev: 07/23/2015

Revision No.: 9

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4.1.1 Tier 1 – Visitors/Deliveries/Vendors – these companies/individuals do

not perform work either on or adjacent to process equipment.

4.1.1.1.1 These companies or individuals do not require subscription

to ISNetworld.

4.1.1.1.2 Examples of these companies or individuals are: a

visitor of an Axiall employee or contractor employee, hot

shot delivery, training rep, Sales, Entergy & gas suppliers.

4.1.1.1.3 Valid visitor orientation required for entry (12AXLV).

4.1.2 Tier 2 – Non-Operational Contractors – these companies may perform

work either adjacent to process equipment or adjacent to the property

battery limits, but for no reason perform hands-on work on process

equipment.

4.1.2.1.1 These companies do require subscription to ISNetworld.

4.1.2.1.1.1 Exemption to ISNetworld is allowed by written approval from

H&S dept. – safety and insurance review still required.

4.1.2.1.2 Their work could require safe work permits from

operations. However, they would not perform any work on

process equipment.

4.1.2.1.3 Companies performing work inside laboratories are not

required to subscribe to ISNetworld; this excludes

construction or renovation to the building.

4.1.2.1.4 Examples of service companies are: Tire repairs,

windshield replacement, fencing, equipment rental,

engineering contractors, PSM consultants, landscaping,

and chemical service companies.

4.1.2.1.5 Valid Basic Orientation Plus/Refresher and Axiall site-

specific required for entry (12AXLPLQ).

4.1.3 Tier 3 – Operational Contractors – Operational Contractors – These

companies perform maintenance or repair, turnaround, major

renovation or specialty work either on or adjacent to process

equipment; this tier consists of nested and job-specific contractors.

4.1.3.1.1 These companies require subscription to ISNetworld.

4.1.3.1.2 Examples of service companies are: work on piping,

vessels, or other equipment, work on DCS, fire

maintenance provider, turnaround services.

4.1.3.1.3 Safe Work permits are required for most of their work.

4.1.3.1.4 Required to review and accept policies annually via

ISNetworld.

4.1.3.1.5 Valid Basic Orientation Plus/Refresher and Axiall site

specific orientation required for entry (12AXLPLQ).

5.0 PROCEDURE

5.1 Qualification

5.1.1 The following information will be utilized to measure a Contractor’s and

Document Number: HSP – 325

PSM – 6

Revised By: Jake A. Valenti

Manager Approval: Hillary Garner

Current Rev: 07/23/2015

Revision No.: 9

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sub- contractor’s prior safety performance. Contractors and sub-contractors

that do not adequately meet an acceptable level of achievement will not be

allowed to perform work at Axiall, Plaquemine.

5.2 Required Qualification Submittals

5.2.1 Prior to or as part of the bid evaluation process all prospective contractors

shall submit the following information to their ISNetworld account for

review and acceptance by Axiall:

5.2.1.1 Answer the Management System Questionnaire (MSQ) within the

ISN account

5.2.1.2 OSHA 300 and 300A logs covering the past three years and the

current year to date for the company and local/regional office.

5.2.1.3 Workers Compensation Insurance Experience Modification Rate

(EMR) documentation from the contractor’s workers comp carrier for

the past three years.

5.2.1.4 A current copy of their Health and Safety Manual

5.3 Other Data

5.3.1 In addition, a review may be conducted of audit reports from former clients,

the Greater Baton Rouge Industry Alliance (GBRIA), and previous Axiall

projects.

5.4 Selection

5.4.1 Submittal Review

5.4.1.1 A complete review of the MSQ will be conducted by ISN

Review and Verification Service (RAVS) to ensure the

company meets our minimum criteria.

5.4.1.2 The three year average of the local/regional office incident

rate may not exceed the national average in the applicable

NAISC code, as published by the Bureau of Labor Statistics

(BLS).

5.4.1.3 The contractor’s EMR rate may not exceed 1.0 to be a

qualified contractor at Axiall, without an approved variance.

5.4.2 Pre-Bid Meetings

Based upon the size and scope of the project a pre-bid meeting may be

conducted and made available to all prospective contractors. During the pre-

bid meeting an Axiall representative will discuss the health and safety

Document Number: HSP – 325

PSM – 6

Revised By: Jake A. Valenti

Manager Approval: Hillary Garner

Current Rev: 07/23/2015

Revision No.: 9

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requirements of this Contract and any unique expectations, based upon the

project scope.

5.4.3 Contract Language

To ensure Contractors are made aware of Axiall’s health and safety

requirements the contract language shall contain details of special issues

expected of contractors when working within the Plaquemine Complex (see

appendices).

5.5 Re-Qualification

5.5.1 Contractors must re-qualify annually or prior to issuing a new contract.

5.5.1.1 Re-Qualification includes:

5.5.1.1.1 Updated OSHA 300 logs

5.5.1.1.2 Update EMR documentation

5.5.1.1.3 Annual Sign off of Plaquemine Site Health and Safety

Manual

5.5.1.1.4 Same OSHA TRIR and EMR requirements as original

qualification.

5.5.1.1.5 Contractor updated Health and Safety Manual (if requested)

5.6 Pre-Job Start

5.6.1 Kick-Off Meetings

5.6.1.1 Following contract award a pre-construction meeting (kick-off)

will be held with the Contractor's management. The site

supervisor must attend the pre-construction meeting. Applicable

health and safety issues shall be discussed during the pre-

construction meeting.

5.6.1.2 During the pre-construction meeting an Axiall Safety

Representatives will be assigned to the project for coordination

with the Contractor.

5.6.1.3 All required submittals shall be received and approved prior to the

Contractor being released to proceed with mobilization and construction.

5.6.2 Orientation

All Contractor employees are required to attend Axiall Site-Specific

Orientation at an Alliance Safety Council or other ARSC council prior to

beginning work on-site. See Axiall HSP-103 “Plant Entry Requirements” for

Document Number: HSP – 325

PSM – 6

Revised By: Jake A. Valenti

Manager Approval: Hillary Garner

Current Rev: 07/23/2015

Revision No.: 9

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specific details.

5.7 Work in Progress

5.7.1 Evaluation

Throughout the duration of the project, the authorized Axiall representative

for the contractor will perform occasional informal inspections and as

warranted, a formal inspection of the contract job. Findings from these visits

will be tracked by the Authorized Axiall Representative to ensure mitigation

or elimination.

5.8 Post Evaluation

5.8.1 Following completion of a project completed by a contractor the authorized

Axiall representative will conduct a Post Job Evaluation of the Contractors

performance with the contractor (See Appendix B).

5.8.2 Service contracts will be reviewed on an annual basis.

6.0 RECORDKEEPING

6.1 Contractor Audits

6.1.1 Copies of all formal audits and inspections of a Contractors performance

shall be maintained in the Safety department & ISNetworld.

6.1.2 Axiall Health and Safety procedures shall be reviewed with both nested and

non-nested contractors annually. Nested contractors’ records will be

reviewed internally annually by Axiall. Non-nested may be reviewed

internally or by third party annually

6.2 Post Job Evaluation Form

6.2.1 The completed Post Job Evaluation Form will be maintained in the Project

files maintained by Engineering & ISNetworld.

7.0 PROGRAM REVIEW

7.1 This Program will be reviewed periodically. HS&S will ensure this review is

performed. The purpose is to assess compliance and to evaluate program effectiveness.

7.2 Following the review, the program will be revised to include any necessary changes.

Review results will be documented. All employees will be informed of any changes

Document Number: HSP – 325

PSM – 6

Revised By: Jake A. Valenti

Manager Approval: Hillary Garner

Current Rev: 07/23/2015

Revision No.: 9

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made in the plan.

7.3 Department Managers will be informed of review results.

8.0 REFERENCES

8.1 29 CFR 1910.119 (h) - Process Safety Management

9.0 APPENDICES

Appendix A - Statement of Contractor Health and Safety Requirements and Policies

Appendix B - Post Job Evaluation

Printed controlled copy expires 24 hours after 2:19 PM on 8/10/2015.

APPENDIX A

STATEMENT OF CONTRACTOR

HEALTH AND SAFETY

REQUIREMENTS AND POLICIES

STATEMENT OF CONTRACTOR HEALTH AND

SAFETY REQUIREMENTS AND POLICIES

Axiall Corporation requires that Contractors take all reasonable precautions in the performance

of their work to protect the health and safety of their employees and of personnel in the

surrounding work areas. The special safety requirements listed herein shall not relieve the

Contractor from complying with the Occupational Safety and Health Act (OSHA) or any other

regulatory or contractual requirement, and are noted only to highlight special areas of concern.

1.0 Pre-Construction

1.1. Following contract award a pre-construction meeting (kick-off) will be held with the

Contractor's management. Applicable health and safety issues will be discussed

during the pre-construction meeting.

1.2. During the pre-construction meeting an authorized Axiall representative will be

assigned to the project for coordination with the Contractor. All required submittals

contained herein would go to the assigned representative, unless noted otherwise.

1.3. All required submittals would be received and approved prior to the Contractor being

released to proceed with mobilization and construction.

2.0 Safety Program

2.1. In the qualification process and anytime requested thereafter, the Contractor will

submit, for Axiall review and acceptance, a written Safety Program consistent with

OSHA regulations, Axiall safety requirements and specific to the tasks to be

performed. The Program at a minimum will contain the following:

2.2. Safety Policy Statement, signed by the principal officer of the company, which

describes the organization’s health and safety goals.

2.3. Name, qualifications and duties of the Safety Representative

2.4. Hazard Communication Program

2.5. Respiratory Protection Program

2.6. Fall Protection Plan

2.7. Training Program including; Employee orientation, hazard communication, personal

protective equipment, confined space entry, and control of hazardous energy.

2.8. Name, qualifications of excavation competent person (if applicable)

2.9. Name and training certification of First Aid designee

2.10. Process by which the Project will be internally inspected for health and safety

deficiencies

2.11. Safety meeting program

2.12. Disciplinary action program

2.13. Analysis of hazards anticipated with job tasks.

2.14. List of critical lifts to be performed during the project

2.15. Emergency response plan

2.16. Axiall Safety will promptly review the Program.

3.0 Hazard Communication

3.1. Axiall maintains Safety Data Sheets (SDS) for hazardous chemicals used on site.

SDSs are available to contractor personnel upon request. Request may be made in

any control room or to your Axiall representative.

3.1.1. The Contractor and all tier contractors will comply with OSHA 29CFR

1910.1200 Hazard Communication and Axiall requirements, which include:

3.1.2. Developing and implementing a written hazard communication program for

the site (To be included in the Safety Program).

3.1.3. Training employees in handling all hazardous materials.

3.1.4. Maintaining a list of all hazardous materials present in the workplace.

3.1.5. Maintaining Safety Data Sheets for each hazardous material onsite.

3.2. The Contractor will submit a copy of the hazardous material inventory and all

associated SDS to authorized Axiall representative for review and acceptance, prior to

the materials being brought onsite. The authorized Axiall representative will review

all SDS and send all new chemicals through the new chemical approval process.

4.0 Safety Representative

4.1. The Contractor will assign a Safety Representative to each project. The safety

representative will be on site full time when the project crew size is 25 or greater or

otherwise requested by the Axiall Representative. The safety representative

responsibilities will include, as a minimum, the following:

4.2. Authority to take immediate action to correct safety violations and, if necessary, stop

work;

4.3. Conduct weekly safety meetings with project employees;

4.4. Conduct weekly safety inspections and document findings;

4.5. Conduct daily tailgate safety meetings.

5.0 Medical First Aid

5.1. When the contract work force exceeds five (5) personnel, the Contractor will

provide at least one (1) employee trained in Basic First Aid and CPR to be

onsite during project work hours.

5.2. The Contractor will maintain a first aid kit of adequate size for the number of

employees working on the project.

5.3. Axiall maintains a Medical Emergency Response Team (MERT) available on all

shifts. In the event of a medical emergency, notify Axiall personnel for assistance

from the MERT. (See Section 28. Emergency Response for notification methods)

6.0 Orientations

6.1. Before beginning work on site, each Contract and/or sub-tier contract employee will

attend:

6.1.1. A general safety orientation presented by any member of ARSC (Association

of Reciprocal Safety Councils) located throughout the Gulf Coast area. The

Safety Council of Baton Rouge is a member of ARSC. The card will read

“ARSC”.

6.1.2. An Axiall General Plant and specific production-units orientation. The

orientation is conducted Monday thru Friday at 6:30 am to 4:00 pm at the

Alliance Safety Council. The card will read “12AXLPLQ” on the back.

6.2 A proof of the ARSC Orientation and the plant and unit specific (12AXLPLQ)

must be presented at the main security center prior to coming on site.

7.0 Training

7.1. OSHA requires training for all personnel working within an industrial facility.

7.2. The Contractor will ensure that required safety training is carried out before

personnel start work and continues throughout all phases of the work.

7.3. Additional training for specific tasks may also be required. The Contractor will

be responsible to ensure employees meet all required regulatory training.

7.4. Contractors must provide copies of certifications upon request for all work

requiring certifications per regulations such as crane operators or welders to

Axiall representative.

8.0 Communication Requirements

8.1. In order to ensure the safety and well being of all personnel entering this Axiall

complex it is important that contractors are capable of comprehending all plant

warning signs as well as verbal and written instructions. For this reason, personnel

must posses a minimum level of proficiency in the English language to be allowed

access into the plant. This minimum level will be gauged by requiring successful

completion of all orientation documentation and tests without assistance or

“coaching” from others.

9.0 Contractor Evaluation

9.1. Throughout the duration of the project, Axiall will perform occasional inspections of

the contract job. Findings from these visits will be presented to the Contractor for

corrective action. In addition a report regarding the observations and correction of

deficiencies will be placed in the contract file for use in future evaluation of the

Contractor.

10.0 Inspections

10.1. The Contractor will conduct weekly or more frequent if regulatory, safety

inspections of the work site and document findings.

10.2. Prompt action is required by the Contractor to correct noted unsafe practices or

unsafe conditions.

11.0 Safety Violations

11.1. In the event of violations or unsafe practices involving imminent danger to

personnel, immediate action will be taken to stop work and correct the hazardous

situation. If violations continue or corrective actions are not taken after a reasonable

period of time, Axiall's option of terminating the contract will be enforced.

11.2. Violation of safety requirements by Contractor employees will result in

appropriate disciplinary action. Axiall may determine it to be necessary for an

employee to be ejected from the plant premises and have their badge and orientation

card removed.

12.0 Reporting Injuries

12.1. The Contractor will, within 1 hour, verbally notify their Axiall Project Contact

and the Safety Department of all injuries, illnesses, or near-miss incidents. The

Contractor will investigate each injury, illness or incident. The Contractor will

submit written documentation of the incident and investigation to the authorized

Axiall representative within twenty-four hours of the injury or incident.

12.2. A Contractor’s Monthly Report must be submitted to the Axiall Safety

Department for each month in which the Contractor performed work on site. The

report should detail only Contractor numbers for personnel on an Axiall project.

This will be sent to you electronically from our H&S department.

13.0 Control of Hazardous Energy Sources

13.1. The Contractor will be responsible to ensure that the project and associated

personnel comply with the requirements of OSHA 29CFR 1910.147 and the Axiall

Health and Safety Manual procedure for the control of hazardous energy sources,

HSP-317, “Control of Hazardous Energy.”

13.2. For lockout/tagout, the contractor will provide personal blue locks for each

employee involved in lockout with the company’s name and employee’s name. Also

yellow locks for supervisors must be provided with the same information.

14.0 Confined Space Entry

14.1. The Contractor will be responsible to ensure that the project and associated

personnel comply with the requirements of OSHA 29CFR 1910.146 and Axiall’s

Health and Safety Manual procedure, HSP-202 “Confined Space Entries” for entry

into confined spaces.

14.2. A confined space entry permit issued by Axiall Operations is required prior to

entry into any confined space.

14.3. Excavations greater than 4 feet in depth will be considered a confined space.

15.0 Excavations

15.1. All excavation work will be conducted in accordance with OSHA 29CFR 1926

Subpart P “Excavations” and the Axiall’s Health and Safety Manual procedure, HSP

318 “Excavation Safety”.

15.2. All excavations must be inspected daily and when conditions change by a

“Competent Person” prior to entry, by personnel. The name and qualifications of

this competent person must be submitted to Axiall for review and acceptance.

15.3. An Excavation Permit must be obtained and reviewed prior to the start of

excavation activities at Axiall.

16.0 Permits

16.1. To provide for maximum personnel safety, any Contract work performed in the

plant must be “permitted” by the Supervision in charge of the area involved. The

following permits are utilized to communicate safety requirements for activities:

16.2. Safe Work Permit

16.2.1. Required for all work performed on site. Issued by Department Supervision

responsible for the unit in which work will be performed.

16.3. Hot Work

16.3.1. Required for all activities within an operating unit which may produce sparks

or flames. Contained within the Safe Work Permit. Issued by Department

Supervision responsible for the unit in which work will be performed.

16.4. Vehicle Entry

16.4.1. Required for all vehicles and other internal combustion engine equipment

taken into an operating unit. Contained within the Safe Work Permit. Issued

by Department Supervision responsible for the unit in which work will be

performed.

16.5. Confined space entry permit

16.5.1. Required for entry into any confined space. Issued by Department

Supervision responsible for the unit in which work will be performed.

16.6. Excavation permit

16.6.1. Required for all excavation work performed on site. Issued by Engineering

Department.

17.0 Protective Clothing

17.1. Contractor personnel will wear hard hats, industrial quality work shoes, and safety

glasses with side shields while within the plant site, except in offices, gang shacks,

and control rooms. Signs or permits for specific exposure areas may prescribe

additional personal protective equipment. Always follow these instructions. Safety

glasses, including all components (frames, lenses, and side shields) will conform to

ANSI Standard Z87.1. Slip-on, flimsy plastic side shields are not permitted.

17.2. All personnel, as determined by the activities to be performed, will wear

appropriate clothing. Shirts with sleeves, over the shoulders, and long pants are

required at a minimum. Flame retardant clothing (FRC) is required in all process

units and where otherwise noted by the requirements of a safe work permit.

17.3. All employees will have (on their person) an emergency escape respirator for

chlorine gas at all times while on site. The escape respirator must be maintained

sealed in a clear plastic bag for protection from deterioration.

17.4. Before any employee starts work requiring use of respiratory protective

equipment, the Contractor will comply with OSHA Section 29CFR 1910.134

17.5. No one whose work involves wearing a tight fitting respirator will be allowed in

the area with facial hair that would prevent a positive face to full-face mask seal.

This includes beards, sideburns, or an elongated mustache.

18.0 Fall Protection

18.1. Employees working on elevated surfaces four (4) feet or more above a lower

level will be protected from falling.

18.2. Fall protection systems must comply with the requirements of OSHA 29CFR

1926 Subpart M - “Fall Protection”.

18.3. Personnel fall arrest systems will consist of a full-body harness with shock

absorbing lanyard. All snap hooks will be the locking type. The use of body belts for

fall arrest is prohibited.

19.0 Housekeeping

19.1. Housekeeping is to be an ongoing process throughout the day and not performed

only at the completion of the day's work.

19.2. During the course of construction, alteration, or repairs, all debris will be kept

cleared from work areas, passageways, and stairs in and around buildings or other

structures.

19.3. The spillage of oil or any other foreign substance onto the ground or into plant

sumps, trenches or ditches is strictly prohibited. Any spill or release must be

immediately reported to the unit or authorized Axiall representative. Contractor will

provide metal containers for the collection and separation of waste, trash, and other

refuse.

20.0 Signs, Barriers and Flagging

20.1. The Contractor will furnish, erect, maintain, and dismantle all barriers required for

its work.

20.2. As a minimum, flagging will be installed around the perimeter of the jobsite and

storage areas. Signs will meet OSHA specifications and will identify all hazards.

20.3. Barricades or flagging are required:

20.3.1. Around all work areas

20.3.2. Around crane swing area and counterweight swing radius of all equipment

20.3.3. To define outer limits of high noise areas.

20.3.4. To define areas of overhead work

20.3.5. Around excavations

20.3.6. For road closures

20.4. Provide flashing yellow lights if barricades on road closures are left overnight.

Notify the authorized Axiall representative at least 48 hours before closing off any

road.

21.0 Construction Equipment

21.1. Contractor and all subcontractors will comply with all provisions of OSHA and

Axiall’s Health and Safety Manual in the operation, control, and inspection of major

equipment. In addition, Axiall reserves the right to inspect major equipment prior to

use on site to determine if there are obvious defects that would prevent operation of

the equipment on site.

21.2. Rigging from the buckets or booms of backhoes, front end loaders, dozers, etc., to

lay pipe, erect steel, pick and carry, etc., will not be permitted unless a properly

installed and tested lifting eye or lug has been attached to the bucket or boom by the

manufacturer, and lifting capacities and configurations are specified in the

manufacturer's operating manual.

21.3. All vehicles or construction equipment having the view to the rear obstructed will

be equipped with audible backup alarms. In congested areas, a flagman may also be

required.

21.4. Before conducting any work from a platform suspended from a crane the

Contractor will submit details of its proposed work platform and rigging method for

Axiall approval. All Cranes used in the hoisting of personnel must be equipped with

anti-two-block devices.

21.5. Prior to using cranes for any work, the Contractor will present to the authorized

Axiall representative a copy of the Annual Inspection Certificate. Cranes will be

restricted to 90% of the capacity shown on the manufacturer's capacity chart when

operating in the stability or tipping portion of the chart. When operating in the

structural integrity area of the chart, the capacity shown on the chart is acceptable.

21.6. Prior to making a critical lift, the Contractor will submit a rigging preplan to the

authorized Axiall representative for review and acceptance. Submittal will be made

no later than 5 working days before the lift is scheduled to be made. The rigging

preplan will include:

21.6.1. Manufacturer, model, and capacity of the crane(s)

21.6.2. Capacity charts

21.6.3. Working radius

21.6.4. Boom length

21.6.5. Weight of load including rigging

21.6.6. How the weight was determined

21.6.7. Size and capacity of rigging hardware (slings, shackles, etc)

21.6.8. Drawing showing the rig and load layout and extent of movement.

21.7. A lift will be considered critical when any of the following conditions exist:

21.7.1. The load exceeds 75% of the crane capacity as the crane is configured to

perform the lift.

21.7.2. Lifts involving more than one crane to handle a common load.

21.7.3. The crane or lifting device is used in an application that deviates from the

manufacturer's recommendations including, but not limited to:

21.7.3.1. Boom configuration not per boom make-up chart

21.7.3.2. Moving a crane with longer boom than recommended

21.7.3.3. Exceeding capacities for restrictions shown on the load chart

21.7.3.4. Lifts are made over process equipment.

22.0 Motor Vehicle Operation

22.1. Observe the speed limits and all posted traffic signs. Maximum plant speed is 15

mph.

22.2. All vehicles must be equipped with seat belts which will be used by both the

driver and passengers while operating the vehicle on Axiall property.

22.3. Equipment will not be fueled while the engine is running. This includes engine

driven equipment such as air compressors, welding rigs, etc.

22.4. Motor vehicles are to be driven to the side of the road and shut down immediately

upon sounding of the plant emergency alarm system. Vehicles' occupants will

evacuate on foot in a cross wind manner to the nearest shelter location. Do not

attempt to restart vehicles until the "All Clear" has been sounded.

22.5. Drivers will sound the vehicle horn prior to backing up unless vehicle is equipped

with a back up alarm.

22.6. Vehicles must not be left running unattended.

22.7. Vehicles may carry only the maximum number of persons it was designed to

accommodate. Passengers may only be transported if they are riding in the cab of

pickup trucks that have adequate seat belts for the number of passengers.

23.0 Electrical

23.1. Contractor will provide ground fault circuit interrupter protection for all cord sets,

receptacles, and electrical tools including connections to generators and equipment

connected by cord and plug for use by employees.

23.2. All Contractor equipment must be maintained outside the minimum clearance

distances for overhead lines, as listed in Table 1 of ASME/ANSI B30.5-1989 “Mobile

and Locomotive Cranes”.

23.3. All electrical equipment and lines will be considered energized until Axiall

electrical authorities verify that it is not.

23.4. All portable equipment shall be ground while in use (i.e. portable generators, etc..

and other equipment, such as during fuel transfers.

24.0 Tool Inspection

24.1. All Contractor-furnished portable tools and equipment (including personal

protective equipment) will be pre-inspected by qualified Contractor personnel.

Equipment will be maintained in safe working order and is subject to Axiall

inspection at any time while on the plant site. Tools and equipment found to be

defective will be tagged and removed from site daily and not returned until all

deficiencies are repaired. Axiall retains the right to prohibit, or restrict, the use of

tools and equipment determined to be in unsafe working condition.

25.0 Fire Protection

25.1. Smoking of tobacco products or use of electronic smoking devices, as defined in

HSP-109, will be permitted only in areas designated by Axiall. Smoking by a

Contractor employee in any non-designated area will be considered cause for

immediate discharge from the plant premises.

25.2. Storage and use of flammable materials will be subject to Axiall approval. Only

safety cabinets and cans that meet OSHA requirements will be used for storing and

dispensing flammable liquids.

25.3. The Contractor will provide a trained and dedicated fire watch for all hot work

activities, as required by the Hot Work Permit.

25.4. Contractor will furnish a sufficient number of fire extinguishers to protect its

work area. Extinguishers will be inspected and sealed.

25.5. Plant fire extinguishers are for emergency use only and may not be removed from

their storage location for fire watch use.

25.6. Oily rags will be kept in fireproof metal containers with self- closing lids, or an

approved equivalent container.

25.7. Any plastic, tarpaulin, or other material used to construct a hut, tent, or similar

protective structure, will be flame retardant.

26.0 Emergency Response

26.1. Axiall has an extensive system for emergency response. Contractors are trained

in the plant emergency response system during General Site Orientation.

26.2. It is Axiall’s policy that in the event of an emergency all personnel should

immediately take shelter and await further direction. It is critical that Contractors

identify their nearest shelter location to be utilized during an emergency.

26.3. The Contractor must designate a competent employee to serve as their Monitor.

During an emergency, the Monitor will take role of their employees and report to the

Main Security Office for accountability purposes.

26.4. To report an emergency condition dial “333" from any in-plant phone from a

“non-plant” phone line dial 685-2500.

27.0 Drug and Alcohol Free

27.1. It is Axiall’s position that all contract employees be drug and alcohol free while

they are on our property and/or equipment and in any way performing a service for

Axiall.

27.2. It is imperative that your employees be drug and alcohol free to insure the

efficient operation of our facilities, as well as conform to the law, and most

importantly, provide for safety and protection of all employees as well as the general

public.

27.3. It is required that each contractor inform his employees of our position regarding

controlled substances, and the contractor’s responsibility to enforce this with his own

employees.

27.4. When a contractor is involved in any of the following, an alcohol and drug test is

required within 24 hours:

27.4.1. OSHA recordable

27.4.2. Vehicle incident

27.4.3. Near Miss where the behavior of the employee or employees contributed to

the incident.

28.0 Drummed and Containerized Material

28.1. All contractors will be charged with the responsibility of handling all drummed and

other containerized material including: receiving, storing, and disposing of all

material received in drums as part of your work. Contractors will be responsible for

labeling and handling the containers in accordance with all applicable laws and

regulations. The contractor additionally will be responsible for clean-up and disposal

of any material that is spilled.

29.0 Temporary Buildings and/or Tents

29.1. All temporary buildings, including but not limited to blast resistant modules or

otherwise known as a c-can, tents, sheds, etc. that are intended to be occupied when

on Axiall property shall be reviewed by the Emergency Response Supervisor and a

Louisiana State Fire Marshals’ Request for Exemption shall be completed and

submitted the Louisiana State Fire Marshal by the Emergency Response Supervisor

before the building can be mobilized.

29.1.1. The Request for exemption (highlighted fields) shall be completed by the

building owner and the form submitted to the Emergency Response Supervisor for

payment request and submission to the Louisiana State Fire Marshals’ office for

approval.

29.1.1.1. No building (i.e. tent, trailer, shack, c-can, etc…) shall not be

mobilized to Axiall without the Request for Exemption being sent to the

Fire Marshal for review AND granted.

29.1.2. See Appendix C for the Request for Exemption, Interpretive Memorandums

2000-11, Exemption Request Form for Temporary Construction Buildings at Job

Site, 2002-01, for temporary buildings, and 2002-02, for tents and canopies in

industrial facilities.

APPENDIX B

POST JOB EVALUATION

Appendix B

*This form can be completed electronically in ISNetworld. **For login access to ISNetworld: Jake Valenti (225) 685-2617 [email protected]

APPENDIX C

Louisiana State Fire Marshals’

Request for Exemption – (2000-11)

and

Interpretive Memos (2002-01 & 2002-02)