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Environmental, Health & Safety (EH&S) Manual

February 2007

Environmental Health and Safety Manual Policy No. 000

Policy Title: Table of Contents

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents Front Matter EHS Manual Revision Sheet EHS Manual Audit Sheet

Section 100 Policy Number EHS-101 Policy Number EHS-102 Policy Number EHS-103 Policy Number EHS-104

Section 200 Policy Number EHS-201 Policy Number EHS-202

Section 300 Policy Number EHS-301 Policy Number EHS-302 Policy Number EHS-304

Section 400 Policy Number EHS-401 Policy Number EHS-402

Section 500 Policy Number EHS-501 Policy Number EHS-502 Policy Number EHS-503 Policy Number EHS-504 Policy Number EHS-505 Policy Number EHS-506

Administrative Policy EHS Policy Medical Records General Site EHS Rules EHS Management of Change

Date / Revision 03/30/06 Rev 1 03/30/06 Rev 1 03/06/06 Rev 1 03/30/06 Rev 1

OSHA Inspections OSHA Inspection Process OSHA Inspection Procedure

03/30/06 Rev 1 03/30/06 Rev 1

Reporting and Recordkeeping OSHA Recordkeeping and Reporting 03/30/06 Rev 1 EHS Incident Reporting 03/30/06 Rev 1 EHS Monthly Reporting – Field Service 03/30/06 Rev 1

EHS Training and Auditing EHS Training Requirements EHS Auditing Process

03/30/06 Rev 1 03/30/06 Rev 1

Health and Safety Requirements Major Contractor Safety Control of Hazardous Energy Lockout/Tagout (LOTO) Personal Protective Equipment Respiratory Protection Hearing Protection and Conservation Hazard Communications

Page 1

03/30/06 Rev 1 06/20/06 Rev 2 03/30/06 Rev 1 03/30/06 Rev 1 03/30/06 Rev 1 03/30/06 Rev 1

Policy No:000

Section 500 Policy Number EHS-507 Policy Number EHS-508 Policy Number EHS-509 Policy Number EHS-510 Policy Number EHS-511 Policy Number EHS-512 Policy Number EHS-513 Policy Number EHS-514 Policy Number EHS-515 Policy Number EHS-516 Policy Number EHS-517 Policy Number EHS-518 Policy Number EHS-519 Policy Number EHS-520 Policy Number EHS-521 Policy Number EHS-522 Policy Number EHS-523 Policy Number EHS-524 Policy Number EHS-525

Section 600 Policy Number EHS-603 Policy Number EHS-604

Appendix Appendix A A.1 A.2 A.3 A.4 A.5 A.6 Appendix B

Table of Contents

Health and Safety Requirement Date / Revision Hazardous Waste Operations and Emergency Response (HAZWOPER) Emergency Response Fall Protection Powered Industrial Trucks Electrical Safety Fire Protection and Prevention Confined Space Entry Walking and Working Surfaces Ladders and Scaffolding Bloodborne Pathogens Compressed Gas Cylinders Hot Work Radiation Machine Guarding Tools Cranes and Rigging Means of Egress Driver Safety Housekeeping

03/30/06 Rev 1 03/30/06 Rev 1 03/30/06 Rev 1 03/30/06 Rev 1 03/30/06 Rev 1 03/30/06 Rev 1 03/30/06 Rev 1 03/30/06 Rev 1 03/30/06 Rev 1 03/30/06 Rev 1 03/30/06 Rev 1 03/30/06 Rev 1 03/30/06 Rev 1 03/30/06 Rev 1 03/30/06 Rev 1 03/30/06 Rev 1 03/30/06 Rev 1 03/30/06 Rev 1 03/30/06 Rev 1

Environmental Requirements Waste Management Toxic Substance Control Act

Title

03/30/06 Rev 1 03/30/06 Rev 1

Policy No.

Contractor Safety Forms Bid Solicitation/Contractor Qualification Form Contractor EHS Training Form Contractor EHS Rules Form Contractor Work Permit Weekly Safety Meeting Form Contractor Inspection Checklist

EHS 501

Medical Records Access Request Form

EHS 102

Page 2

Policy No:000

Appendix

Table of Contents

Title

Policy No.

Appendix C C.1 C.2

EHS Mgmt. of Change Forms Examples of Changes Change Management Record

EHS 104

Appendix D D.1 D.2

OSHA Inspection Procedure Forms Notice to OSHA Notice of Protest

EHS 202

Appendix E

Recordkeeping and Reporting Forms and Charts Recordability Flow Chart Recordability Checklist Recordability Guidance

EHS 301

EHS Incident Reporting EHS Incident Report Form EHS Incident Investigation Form Field Service EHS Monthly Report Form EHS Training Forms EHS Audit Tracking Form Lockout/Tagout Forms LOTO Index Facility Authorized Personnel List LOTO Audit Form LOTO Control Sheet Personal Protective Equipment Forms PPE Equipment Inventory Hazard Assessment Form Respiratory Protection Forms Respirator Specification Form Cartridge Change Out Schedule Respirator Cartridge Selection Chart Medical Evaluation Questionnaire Fit Test Protocol Fit Test Documentation Form Respirator Cleaning Procedure SCBA Inspection Form

EHS 302

E.1 E.2 E.3 Appendix F F.1 F.2 Appendix H Appendix I Appendix J Appendix K K.1 K.2 K.3 K.4 Appendix L L.1 L.2 Appendix M M.1 M.2 M.3 M.4 M.5 M.6 M.7 M.8

Page 3

EHS 304 EHS 401 EHS 402 EHS 502

EHS 503

EHS 504

Policy No:000

Appendix Appendix N N.1 N.2 Appendix O O.1 O.2 Appendix P P.1 P.2 P.3 Appendix Q Q.1 Q.2 Q.3 Appendix R R.1 R.2 R.3 Appendix S S.1 S.2

Table of Contents

Title

Policy No.

Hearing Conservation Forms Area/Personal Noise Monitoring Survey Record Hearing Conservation Program Audit Form Fall Protection Forms Fall Hazard Assessment Form Fall Protection Evaluation Form Powered Industrial Truck Forms Fork Truck Designation Sample Daily Fork Truck Maintenance Checklist Sample Fork Truck Training Evaluation Fire Protection and Prevention Forms Classes of fires and Appropriate Extinguishers Sample Fire Prevention Checklist Sample Fire Extinguisher Inventory Form Confined Space Entry Forms Example Confined Space Entry Permit Pre-Entry Checklist Confined Space Inventory Form Waste Management Forms Exemptions From Hazardous Waste Hazardous Waste Listings

Page 4

EHS 505

EHS 509

EHS 510

EHS 512

EHS 513

EHS 603

Environmental Health and Safety Manual Date: 9/24/2007

Title: Environmental Health and Safety Manual Revision Tracking Sheet

This sheet must be completed upon revision of any written S&W Energy Solutions EHS policy or procedure contained in the EHS manual. Policy or Procedure

Rev. #

Rev. Date

Revision Description

Revised By

Environmental Health and Safety Manual Date: 9/24/2007

Title: Environmental Health and Safety Manual Review Sign-Off Sheet

This sheet must be completed following the annual audit/review of the EHS manual. The sheet must be signed and dated by the person authorized to conduct the audit.

Audit Date

Audit Conducted By

____________

___________________________

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___________________________

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Environmental Health and Safety Manual Policy No. EHS-101

Policy Title: Environmental Health and Safety Policy

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2

Purpose and Scope.................................................................................................. 2 Policy ....................................................................................................................... 2

Page 1

Policy No:EHS-101

S&W EHS Policy

1 Purpose and Scope The purpose of this Policy is to state S&W Energy Solutions commitment to achieving environmental, health and safety (EHS) excellence. This commitment is the responsibility of management and employees in all functions. S&W Energy will strive to provide a safe and healthy working environment and to avoid adverse impact and injury to personnel and to the environment and the communities in which we do business.

2

Policy

The well being of our employees while on the job, as well as the preservation of our environment at our job-sites and surrounding community, has the highest priority at S&W Energy. While we must provide quality work at a fair price for our customers in order to survive as a business, we refuse to compromise health and safety or damage our natural surroundings in the process. We believe that productive, safe, and environmental-friendly work habits are one in the same. Many accidents happen when people are in a hurry to get something done, or when they settle into comfortable habits and become complacent. Mainstream thinking is “an accident will never happen to me or affect me”. None of us have the ability to predict when, where, or how an accident will happen. The tragedy is that most accidents would take but a few seconds to avoid. No matter how busy or experienced you feel you are, you MUST consistently take the extra time to do any task safely while simultaneously thinking to avoid negative environmental consequence. You must make safety a core value in your day to day routine. This EHS manual and its contents outline the minimum requirements for a safe and healthy work environment. Certain jobs will require additional protections. It is extremely important that you understand HOW each task is to be done in a safe manner. If you do not know, STOP and ASK before you commence your work. Your safety and well being, as well as the safety of those around you, can be a reality only through your constant and sincere effort. Simply talking or thinking about safety alone cannot and will not make safety a fact. You must believe in it, embrace it, and DO it. The S&W Energy Solutions’ EHS Policy includes very simple elements: • • • • •

Fostering a culture promoting compliance and encouragement of employees to raise their policy questions and concerns, and prohibiting retribution. Development and implementation of standards and procedures which will facilitate compliance by all S&W Energy Facilities, Sites, and personnel to this Policy and all applicable laws. Providing continuous education and training that will enable employees to understand the basic requirements of this Policy and applicable environmental, health and safety laws. Conducting internal and/or external EHS audits on a periodic basis to ensure compliance. Implementing a method for promptly reporting violations (and possible violations) of this Policy without the fear of retribution.

Page 2

Policy No:EHS-101

• • • • •

S&W EHS Policy

Establishing strict, but appropriate disciplinary actions to be taken with employees who violate this Policy. Adopting, embracing, supporting, and ensuring employees understand the philosophy that performance is never more important than compliance. Taking prompt remedial action when required. Promoting feedback and periodic evaluation to continually improve compliance with this Policy. Evaluating and providing rewards for employees whose actions promote the tenets of this Policy.

S&W Energy is committed to providing whatever it takes to ensure everyone works in the safest environment possible. Company management and employees must work as one to maintain a safe and healthy work atmosphere and to protect the workplace and surrounding community from negative environmental impact. This goal can only be achieved through a combined effort of working together. We at S&W Energy view safety, not as a priority, but as a core VALUE in our business philosophy. While priorities may change, values stay with us indefinitely.

Richard Wolf President – S&W Energy Solutions, Inc.

Signature ______________________________________

Date ________________

NOTE: All S&W Energy employees shall review the EHS Policy upon first day of employment and every year thereafter (annual requirement). The Policy shall be reviewed and signed by Management on an annual basis.

Page 3

Environmental Health and Safety Manual Policy No. EHS-102

Policy Title: Medical Records

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2

3 4 5 6 7 8 9

Purpose and Scope.................................................................................................. 2 Definitions ................................................................................................................ 2 2.1 Access – The right and opportunity to examine and copy................................. 2 2.2 Designated Representative............................................................................... 2 2.3 Employee Exposure Record ............................................................................. 2 2.4 Employee Medical Record ................................................................................ 2 2.5 Exposure (or Exposed) ..................................................................................... 3 2.6 Health Professional........................................................................................... 3 2.7 Record .............................................................................................................. 3 2.8 Specific Written Consent................................................................................... 3 2.9 Toxic Substance (Harmful Physical Agent) ....................................................... 3 2.10 Trade Secret ..................................................................................................... 4 Preservation of Records........................................................................................... 4 Access to Records ................................................................................................... 4 Trade Secrets........................................................................................................... 5 Training .................................................................................................................... 5 Auditing / Inspections ............................................................................................... 5 References............................................................................................................... 6 See Appendix B ....................................................................................................... 6

Page 1

Policy No:EHS-102

Medical Records

1 Purpose and Scope This procedure/policy provides information on employees’, and/or their designated representatives’, rights to gain access to relevant medical records and information. The procedure also includes the requirements and guidelines of S&W Energy to maintain files and records relevant to employee medical information. A physician or other health care professional in charge of medical or exposure records can carry out access to medical records on behalf of S&W Energy. Requirements in this procedure are not intended to affect existing legal and ethical obligations concerning confidentiality of employee medical information regarding patient/employee disclosure with medical-care relationship. This procedure/policy applies to any general industry employer who has access to employee exposure or medical records, or other similar analyses. The medical records referenced include work-related records in addition to medical records that are not mandated by specific occupational safety and health standards.

2

Definitions 2.1 Access – The right and opportunity to examine and copy. 2.2 2.3 •

Designated Representative – Any individual or organization to whom an employee gives written authorization to exercise a right of access. Employee Exposure Record – A record containing any of the following types of information: Environmental (workplace) monitoring or measuring of a toxic substance or harmful physical agent results; or



Biological monitoring results which directly assess the absorption of a toxic substance or harmful physical agent (not including alcohol or drugs); or



Material Safety Data Sheets (MSDS) indicating the material may pose a hazard to human health; or



A chemical inventory or any other record which reveals where and when used and identity of a toxic substance or harmful physical agent. Employee Medical Record – A record concerning the health status of an employee which is made or maintained by a physician, nurse, or other health care professional which includes, but not limited to, the following: medical and employment questionnaires or histories, results of medical examinations and laboratory tests (pre-employment, baseline, etc.), medical opinions and diagnoses, first aid records, treatments and prescription information, and medical complaints.

2.4

Page 2

Policy No:EHS-102

2.5

2.6 2.7 2.8 •

Medical Records

Exposure (or Exposed) – Any employee subjected to a toxic substance or harmful agent in the course of employment through any route of entry (inhalation, ingestion, skin absorption, etc.) and includes past exposure and potential exposure. It does not include situations where the employer can demonstrate that the toxic substance or harmful agent was not used or handled in the workplace at any given time. Health Professional – A physician, occupational health nurse, industrial hygienist, toxicologist, or epidemiologist, providing medical or other occupational health services to exposed employees. Record – Any item, collection, or grouping of information regardless of the form or process by which it is maintained (i.e., paper document, x-ray, microfilm, or automated data processing). Specific Written Consent – A written authorization containing the following information: The name and signature of the employee authorizing the release of medical information;



The date of the written authorization;



The name of the individual or organization that is authorized to release the medical information;



The name of the designated representative (individual or organization) that is authorized to receive the released information;



A general description of the purpose of the release of the medical information; and



A date or condition upon which the written authorization will expire (if less than one year). Toxic Substance (Harmful Physical Agent) – Any chemical substance, biological agent (bacteria, virus), or physical stress (noise, heat, cold, vibration, repetitive motion) which: Is listed in National Institute for Occupational Safety and Health (NIOSH) Registry of Toxic Effects of Chemical Substances; or

2.9 • •

Has yielded positive evidence of an acute or chronic health hazard in testing conducted by the employer; or



Is the subject of a material safety data sheet (MSDS) kept by or known to the employer indicating that the material may pose a hazard to human health.

Page 3

Policy No:EHS-102

Medical Records

2.10 Trade Secret – Any confidential formula, pattern, process, device, or information or compilation of information that is used in an employer’s business and that gives the employer an opportunity to obtain an advantage over competitors who do not know or use it.

3

Preservation of Records

Unless a specific occupational safety and health standard provides a different period of time, S&W Energy (and any other employer) shall assure preservation and retention of records as follows: The medical record for each employee shall be preserved and maintained for at least the duration of employment PLUS thirty (30) years. However, the following records need not be retained for any specific period: •

Health insurance claim records kept separately from S&W Energy’s medical program and its records; or



First aid records of one-time treatment and subsequent observations of minor scratches, cuts, burns, splinters, and the like which do not involve medical treatment, loss of consciousness, restriction of work or motion, or transfer to another job; or



The medical records of employees if they have worked less than one (1) year for S&W Energy if they are provided to the employee upon termination of employment.

The exposure record of each employee shall be preserved and maintained for at least thirty (30) years.

4

Access to Records

Whenever an employee or designated representative requests access to a medical record, exposure record, or analyses of exposure or medical records, S&W Energy shall assure that the access is provided in a reasonable time, place, and manner. If the record cannot be reasonably obtained within fifteen (15) working days, S&W Energy shall discuss with the employee or designated representative the reason for the delay and relay to them the earliest date when the record can be made available. S&W Energy shall ensure that a copy of the medical record is provided without cost to the employee and that it is given to the employee for such a period that allows time for a copy to be made (for their personal records). A designated representative may gain access to an employee’s medical records, exposure records, or analyses of exposure or medical records by specific written consent from the employee ONLY. A sample Medical Records Access Request Form is included in this procedure.

Page 4

Policy No:EHS-102

Medical Records

S&W Energy shall allow access to personnel medical records and information to OSHA or any other governing regulatory agency upon request, however, the proper written access must be provided prior to providing the records. Reference OSHA or other regulatory agency guidelines and requirements before permitting this access. If employer ever ceases to do business, the employer shall transfer all records referenced in this procedure to the successor employer. The successor employer shall receive and maintain these records. If employer ceases to do business and there is no successor employer, the employer shall notify the current employees of their rights to access records at least three (3) months prior to employer ceasing to do business.

5

Trade Secrets

S&W Energy may choose to delete information from an employee medical record upon request for access by the employee, designated representative, or physician, if the record contains trade secret information (i.e., manufacturing processes, chemical mixture data, etc.) as long as the requestor is notified of such action in advance. This is allowed only if S&W Energy can prove or support the claim that the information deleted is in fact a trade secret. Where a treating physician or health care professional determines that the trade secret information withheld or deleted is necessary to determine proper treatment or emergency care for the employee, S&W Energy shall immediately disclose the specific information despite the written confidentiality consents for disclosing trade secret information. However, upon disclosure of such information, S&W Energy may elect to have sequestering parties sign written confidentiality consents that information is to be used for treatment purposes only and not disclosed or used in any other fashion.

6

Training

All S&W Energy employees shall be trained on the requirements and guidelines of this procedure initially (upon first day of employment) and annually thereafter. The training shall cover the following:

7



The existence, location, and availability of records covered by this procedure;



The person responsible for maintaining and providing access to the records; and



Each employee’s rights of access of these records.

Auditing / Inspections

The Medical Records Access / Recordkeeping procedure shall be reviewed every 3 years. This procedure will be updated as necessary.

Page 5

Policy No:EHS-102

8

Medical Records

References 1. 29 CFR 1910.20 Access to Employee Exposure and Medical Records / OSHA Recordkeeping and Reporting Requirements

9

2. 29 CFR 1910.1020

Access to Employee Exposure and Medical Records

3. 29 CFR 1926.33

(Same as 29 CFR 1910.1020)

See Appendix B 1. Medical Records Access Request Form

Page 6

Environmental Health and Safety Manual Policy No. EHS-103

Policy Title: General Site EHS Rules

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

1. Table of Contents 1 2

Purpose and Scope.................................................................................................. 2 Policies..................................................................................................................... 2 2.1 General ............................................................................................................. 2 2.2 Conduct ............................................................................................................ 3 2.3 Asbestos & Other Fibers ................................................................................... 3 2.4 Barricades and Notice of Work Activity ............................................................. 3 2.5 Confined Space Entry ....................................................................................... 4 2.6 Cranes and Motorized Equipment..................................................................... 4 2.7 Defective Equipment......................................................................................... 4 2.8 Demolition ......................................................................................................... 4 2.9 Emergency Response....................................................................................... 4 2.10 Excavations....................................................................................................... 5 2.11 Fire Protection................................................................................................... 5 2.12 Hazard Communication Program (HAZCOM) ................................................... 5 2.13 Hazardous Substance / Waste Management.................................................... 6 2.14 Hot Work ........................................................................................................... 6 2.15 Housekeeping ................................................................................................... 6 2.16 Ladders and Scaffolding ................................................................................... 7 2.17 Lead Paint......................................................................................................... 7 2.18 Lockout / Tagout ............................................................................................... 8 2.19 Personal Protective Equipment (PPE) .............................................................. 8 2.20 Reporting EHS Incidents................................................................................... 8 3 Safety Meetings ....................................................................................................... 9 4 Training .................................................................................................................... 9 5 Auditing / Inspections ............................................................................................... 9

Page 1

Policy No:EHS-103

General Site EHS Rules

1 Purpose and Scope This policy provides general environmental, health and safety guidelines for all S&W Energy employees at any S&W Energy Facility or Job-Site. The list highlights the primary requirements of each site. The specific S&W Energy procedure or policy shall be reviewed to obtain all requirements for each area covered here. General Site EHS Rules also provides guidance pertaining to safety meetings (i.e., purpose and frequency). In addition to general EHS guidelines and rules, the Facility or Site shall generate any site-specific requirements that are not referenced here. They shall be attached to this procedure and indicated as “Facility or Site Specific”. The guidelines included in Section 2 of this procedure may be amended, upon approval from the S&W Energy EHS Manager, so that they reflect the requirements of the Site.

2

Policies

S&W Energy is committed to providing a safe and healthy work environment for all employees, both on-site and Contractor Workers, and is committed to avoiding adverse impact to the environment in performance of all site activities.

2.1 General • • • • • • • • •

Employees shall not work at any time when their ability is or may be impaired as a result of the use of legal prescription drugs. All individuals, employees, contractors, visitors, etc. must be seated in moving vehicles and seat belts worn while the vehicle is in motion. Fighting, horseplay, gambling, possession of firearms or other weapons, possession or use of alcohol or illegal or unauthorized drugs is prohibited. Except in “Designated Smoking Areas,” smoking is not permitted on Facility property. Eating and Drinking is only permitted in designated areas. All tools and equipment shall be inspected prior to use. Unsafe tools and equipment shall not be used. Employees will perform work in such a manner as to assure at all times maximum safety to self, fellow workers and the public and in accordance with all Federal, State, and Local requirements. Employees who do not either feel qualified for or physically able to perform will not attempt to work. Employees will perform work according to proper EHS practices and procedures as posted, instructed, and prescribed.

Page 2

Policy No:EHS-103

• • • •

General Site EHS Rules

Employees will obtain specific instructions and/or clarifications from their Supervisor before proceeding with work in situations where an EHS requirement or procedure is not completely understood. Employees will observe and adhere to all warning signs, signals, and notices. Employees shall not be permitted to wear loose or flapping clothing or have rags or other objects extending from pockets or belts when in the immediate proximity of machinery, motors, engines, or rotating equipment. Employees shall never operate any machine or rotating equipment unless all guards and safety devices are in place and in proper operating condition.

Immediately report every work-related Injury, Illness or Near Miss sustained at the Facility or Site to your Supervisor.

2.2 Conduct The following list is not a complete list but includes acts and behavior which are prohibited and for which an Employee may be removed or dismissed from the Facility: • • • • • • •

Use of obscene or abusive language; racial, gender, or ethnic slurs. Failure to follow specific instructions or specifications. Deliberately damaging, defacing, or misusing Facility or Site property or the property of others. Removing Facility or Site property from the premises without appropriate authorization. Gambling, bookmaking or selling lotteries on Facility or Site property. Immoral or indecent conduct; sexual harassment. Illegally possessing, selling, distributing or manufacturing drugs on Facility or Site property.

2.3 Asbestos & Other Fibers • • •

All fibrous materials must be accompanied by a MSDS and must be treated with care. Unless a Facility or Site is documented to be asbestos free, the Employee shall not disturb any fibrous material, but shall notify the Supervisor immediately if any is found. Any Employee or Contractor performing asbestos abatement must comply with requirements stipulated in Facility or Site procedures and any Federal, State, or local regulatory requirements.

2.4 Barricades and Notice of Work Activity •

Facility or Site personnel shall erect all necessary barricades and notices to safeguard all individuals, both Contractor Workers and site employees, during the conduct of the any work performed at the Facility or Site. Page 3

Policy No:EHS-103

• • • •

General Site EHS Rules

Barricades and notices are required around excavations, holes, or openings in floors, roofs, elevated platforms, around certain types of overhead work, and whenever necessary to warn people against falling objects or debris. Blinking lights must be used on protective barricades, where lighting is inadequate. The use of Caution Tape, yellow and black tape, means access to areas may be permitted only when it is safe to do so. Areas in which entry is not permitted will be taped-off with red and black barricade tape and have signs similar to: “Danger - Do Not Enter” posted. Employees shall not enter such areas.

2.5 Confined Space Entry • •

Employees must be qualified or trained to perform the work (have appropriate training per regulatory requirements) and briefed on the hazards of the confined space(s) prior to beginning work. Employees shall use S&W Energy Confined Space Entry procedures, unless another arrangement has been agreed upon.

No one will enter a PERMIT-REQUIRED CONFINED SPACE until a confined space entry permit has been issued and posted.

2.6 Cranes and Motorized Equipment • •

Employees must be properly trained to operate mobile equipment, complete and pass applicable examinations and certifications to qualify to operate equipment. (This may include DOT licensure). Only certified operators with valid certifications may operate cranes and other motorized equipment at the S&W Energy Facility or Site.

2.7 Defective Equipment •

The Employee shall ensure that all tools and equipment shall be inspected prior to use. Any defective equipment shall be tagged “OUT OF SERVICE” and removed until it has been repaired or discarded.

2.8 Demolition •

All demolition work shall be conducted in such a manner as established in accordance with the Engineering requirements.

2.9 Emergency Response •

All Employees and Contract Workers shall review and become familiar with the Facility’s or Site’s Emergency Response Plan and procedures before beginning assigned work.

Page 4

Policy No:EHS-103



• • • • •

All Employees shall be familiar with the Facility’s or Site’s spill notification and evacuation procedures as described in the Emergency Response Plan and know where to muster in an emergency. Also, the Employee shall be made aware of all emergency contacts and procedures for reporting fires. Spills must be properly managed to prevent harm or degradation of the environment, access to storm water or sanitary sewer drains, and to ensure worker safety. Evacuate the area if a spill involves hazardous, explosive, or flammable materials. Supervisors are required to know who is on their job, and be able to account for them at all times, especially after an evacuation. Supervisors must report missing personnel and their presumed location as quickly as possible. Approved First Aid supplies shall be made available to all employees, contractors, visitors, etc. in ample quantities at all times.

2.10 • •

• • • • • • •

Fire Protection

The reason for discharging a fire extinguisher shall be discussed with all Employees. After recharging, the extinguisher shall be returned to its original location. Employees shall not obstruct in any way access to fire extinguishers, fire hose stations or other fire apparatus, emergency eye wash stations and showers, spill response equipment or other safety related equipment. Employees shall know the location and correct operation of the nearest fire alarm and fire extinguisher. Employees shall know the location of designated fire exits and shall not block access to those exits. Employees shall not refuel equipment while it is running or when hot. Employees shall keep combustible and flammable materials away from hot surfaces and ignition sources. Employees will store flammable materials in approved cabinets. Reference the Site’s Fire Protection and Prevention procedure for detailed requirements and precautions.

2.12 •

Excavations

Prior to commencement of any excavation, the Employee shall notify the Shift Supervisor, or designee. Any Employee shall ensure that excavation areas are properly barricaded and have posted warning signs to ensure the safety of all individuals in the area.

2.11 •

General Site EHS Rules

Hazard Communication Program (HAZCOM)

Any HAZARDOUS MATERIALS brought on site must be accompanied by the associated MSDS. They shall be approved by the Facility or Site prior to bringing them on-site. The MSDS must be provided to the Facility

Page 5

Policy No:EHS-103

• •

General Site EHS Rules

Representative, or designee. All hazardous material must be in an approved container, including all flammable substances. All containers shall be properly labeled as to the contents and physical and health hazards at all times. Each Employee must be aware of the Facility or Site HAZCOM program that includes at a minimum: complete MSDS’s on hand at the work site for each chemical used, chemical inventory, adequate training for all personnel which covers: physical and health hazards of all products, proper handling of the products, and personal protective equipment.

A copy of the Facility or Site’s HAZCOM program and the Facility or Site MSDS inventory will be made available to any Employee or Contractor Worker upon request.

2.13 • •

• • •

Employees shall properly handle all hazardous and toxic substances and materials utilized in its work according to Site procedures and regulatory standards. Propane and compressed gas cylinders must be chained upright and on approved carriers when moved. Reference Hazardous Material Deliveries and Compressed Gas Cylinder Procedures for detailed requirements and guidelines. All Employees are responsible for the proper disposal of construction debris generated by their work at the Facility or Site. Enclosed disposal chutes are to be used whenever waste materials are to be dropped more than 10 feet. Employees will comply with requirements of S&W Energy’s Hazardous Material Handling and Waste Management procedures while on-site.

2.14 • •



Hot Work

Employees shall not perform hot work (welding, cutting, brazing, and burning operations) without obtaining a Hot Work Permit. All employees shall comply with S&W Energy’s Hot Work procedure and all its requirements.

2.15 •

Hazardous Substance / Waste Management

Housekeeping

Employees shall maintain all walkways and work areas clear of obstructions, tripping hazards, and debris. All oily rags must be disposed of in appropriate containers designed for oily wastes.

Page 6

Policy No:EHS-103

2.16 • • • • • • • • • •

• • • •



Ladders and Scaffolding

All ladders must be approved for use before being put into service. Each user must inspect ladders visually before using. If it is necessary to place a ladder in or over a doorway, barricade the door and/or post warning signs. Metal ladders must not be used for electrical welding, or near electric lines or services. Ladders must be tied off, with the user wearing a safety harness, if it is necessary to use a ladder on top of a scaffold or close to the edge of an elevated platform, roof, or floor opening. The top of the ladder must extend at least three (3) feet beyond the supporting object, when used as access to an elevated work area. Sound, rigid and suitable footing is required for all scaffolds and no unsuitable objects shall be used for support, such as barrels, boxes, bricks or concrete blocks. Guardrails and toe boards shall be installed in conformance with regulatory and engineering requirements and standards. Where persons are required to pass underneath, all scaffolds will be provided with ½” mesh screening between the tow board and guardrail. Scaffold and components shall be capable of supporting four times its intended load without failure. Personnel must wear properly tied-off safety harnesses on scaffold platforms not equipped with standard handrails or completed decking. Safety harnesses must be secured before stepping onto the scaffold, and must not be removed until personnel are clear of the scaffold. Harnesses must be tied off to independent lifelines or building structures – one lifeline per person. No one is allowed to ride a rolling scaffold while it is being moved. All tools and materials must either be removed or secured on the deck before moving. Pulling the scaffold along from overhead while on the scaffold is prohibited. Brick, tile, block or other similar materials may not be stacked higher than 24 inches on the scaffold deck. All scaffolds shall be erected and maintained in accordance with regulatory and engineering requirements and standards. Employees shall comply with S&W Energy’s Ladders and Scaffolding and Fall Protection Procedures.

2.17 •

General Site EHS Rules

Lead Paint

For operations comprising of the grinding, welding, or burning of lead painted surfaces a Supervisor must be notified prior to the start of work. If it is not known whether the surface has lead paint on it, the Facility Manager or designee shall be consulted. The area shall be posted that work is being conducted on lead painted surfaces.

Page 7

Policy No:EHS-103



Work practices such as using HEPA vacuum and exhaust ventilation will be applied.

2.18 • • •

• • • • • •



• •

Personal Protective Equipment (PPE)

Employees shall wear flame resistant or 100% cotton long sleeved shirts and long pants while involved in tasks with exposure to flames or electric arcs. Shirts with sleeves (long or short) will be worn at all other times. ANSI-approved hard hats shall be properly worn by all Employees and Contractor Workers and visitors throughout the Facility, except in office areas and in other designated areas. (Metal hard hats are prohibited.) ANSI-approved safety glasses with side shields shall be properly worn by all Employees and Contractor Workers and visitors throughout the Facility, except in office areas. Both chemical goggles and face shields shall be worn when working with or loading / unloading chemicals such as ammonia, sulfuric acid, caustic etc. ANSI approved safety shoes must be worn by all Employees and Contractors working on site. No sneakers or dress shoes will be allowed. Approved full body harnesses and lanyards shall be properly used when working in areas where a potential fall hazard exists. Approved hearing protection shall be properly used in designated areas. When in doubt of noise levels, hearing protection shall be used. Double hearing protection must be used when working in or around the turbines/generators when in operation with enclosures open. Respiratory protection will be properly used where administrative or engineering controls fail to reduce air contaminants to within OSHA prescribed limits. Employees shall comply with S&W Energy’s Respiratory Protection procedure, or equivalent procedure of their own. Other approved PPE such as face shields, protective clothing, gloves, etc. shall be used by Employees where the risk of injury or illness may be prevented by its use. All requirements as described in S&W Energy’s Personal Protective Equipment / Job Safety Analysis procedure shall be met.

2.20 •

Lockout / Tagout

Employees must get approval from the Shift Supervisor, or designee, BEFORE beginning work on Locked Out or Tagged Out equipment. All electrical wires and circuits are to be considered energized unless power is definitely disconnected and the applicable switches locked and tagged out. All Employees shall comply with S&W Energy’s Lockout / Tagout procedure.

2.19 •

General Site EHS Rules

Reporting EHS Incidents

Employees are responsible for reporting any work-related injury/illness or near misses (or environmental incidents) to the Facility Manager or Supervisor as soon as they become known.

Page 8

Policy No:EHS-103



3

General Site EHS Rules

The Facility Manager or Supervisor will complete all required paperwork per S&W Energy’s EHS Incident Reporting and OSHA Recordkeeping Procedures.

Safety Meetings

Supervisors at all work locations are responsible for conducting safety meetings with assigned personnel, including contractors and sub-contractors. These meetings may be brief 15-20 minute sessions or as long as 30-60 minutes. Meetings held for training purposes may require additional time. Meetings shall be held at a frequency established by the Facility or Site but at least monthly. ALL safety meetings shall be fully documented on a general form. The record shall indicate the time, date, and location of meeting, topics covered, duration, name of instructor (person presenting material), and all personnel attending. Records shall be kept for one year. In addition to the regular frequency of safety meetings, a safety meeting shall be conducted following an injury or near-miss to warn assigned personnel in an effort to prevent duplicate accidents or injuries.

4

Training

All Employees shall be trained on the guidelines of this procedure initially, prior to work at the Facility or Site. Refresher training is required any time there is a change to the Site’s general rules.

5

Auditing / Inspections

This procedure and policy shall be reviewed annually. Safety meeting records may be reviewed as part of this audit or inspection. The procedure / policy will be updated, as necessary.

Page 9

Environmental Health and Safety Manual Policy No. EHS-104

Policy Title: EHS Management of Change

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2

3 4 5 6

Purpose and Scope.................................................................................................. 2 Definitions ................................................................................................................ 3 2.1 Change ............................................................................................................. 3 2.2 Change Management Record (CMR) ............................................................... 3 2.3 Controlled Document ........................................................................................ 3 2.4 Design Review .................................................................................................. 3 2.5 Piping and Instrumentation Diagrams (P&ID) ................................................... 3 2.6 Replacement-in-Kind ........................................................................................ 3 2.7 RFC .................................................................................................................. 3 2.8 Temporary Change ........................................................................................... 4 Training .................................................................................................................... 4 Auditing / Inspections ............................................................................................... 4 References............................................................................................................... 4 See Appendix C ....................................................................................................... 4

Page 1

Policy No:EHS-104

EHS Management of Change

1 Purpose and Scope The purpose of this policy is to introduce the need to manage changes (normal, permanent, and/or temporary changes) to ensure that environmental, health and safety (EHS) factors has been included as part of the evaluation process. Facility or Site process, equipment, or operational changes must have appropriate review and authorization prior to implementation to ensure they do not introduce unacceptable risk or hazards. The EHS review portion of the Management of Change process is implemented at Facilities and Sites so as not to compromise the safety and health of employees (and the community) and to safeguard the surrounding areas from environmental catastrophes. Management of Change applies to all changes other than those classified as “replacement-in-kind”. Although maintenance crews typically conduct changes, all personnel must be aware of this policy as changes can be proposed by all employees. Everyone must understand the process and review required to implement a change and understand what constitutes a change. Many times what may appear to be a minor revision may have much larger implications. It may lead to injuries, accidents, permitting violations, etc., costing companies large sums of money and penalties, not to mention seriously injuring employees if not handled appropriately. Therefore, proper authorization and analysis is needed. A Facility or Site is required to have an overall Management of Change Procedure. EHS is only one part of the review and analysis of that process. This policy is not meant to replace any existing Management of Change procedure or process but to reemphasize the need for review of all changes and to ensure EHS is included as part of that review. Definitions and sample Request Forms are included with this policy as a tool to assist Facilities or Sites with implementing Management of Change procedures. It is NOT intended as a stand-alone procedure. The EHS Management of Change Policy should be incorporated into the Facility or Site’s overall Management of Change procedures. Prior to implementing ANY change, the proper analyses must be conducted and approved and the appropriate authorizations, most importantly for this policy EHS authorization, obtained (and all documented). NO CHANGE SHALL BE MADE OR IMPLEMENTED WITHOUT THESE REQUIREMENTS BEING MET.

All Facilities or Sites must have a formal system for identifying, assessing, authorizing, and implementing changes. Management of Change includes documentation and reviews that manage change by addressing the technical basis of the change, the impact on the environment, safety, and health, modification to operating procedures, necessary time periods involved, authorizations required, training of affected personnel, and updating process safety information.

Page 2

Policy No:EHS-104

2

EHS Management of Change

Definitions 2.1 Change All modifications to Facilities or Sites (buildings, structures, etc.), equipment, procedures, processes, operations, raw materials, and processing conditions other than “replacement in kind” are considered a change. Changes may include modifications of operation outside previously approved operating limits (EHS Procedure or Permit), process technology changes (rates, raw material, experiments, catalysts, etc.), or equipment changes (materials of construction, equipment specifications, piping arrangements, etc.). A list of typical modifications classified as changes (and subject to Management of Change) is included as a reference in the Attachment section of this policy document.

2.2 Change Management Record (CMR) A form used to document and control the progress of a modification from initiation through completion of the change. This is also referenced as a Change Request Form. Reference the Attachment section for an example form.

2.3 Controlled Document A document whose contents and distribution are “controlled” through the Management of Change process. Typically these documents include P&ID's, operational procedures, training manuals, permits, etc.

2.4 Design Review A review conducted by the appropriate personnel authorized to ensure the change has been engineered with the appropriate safety, health, and environmental considerations. This includes one of the authorizations required to implement a change.

2.5 Piping and Instrumentation Diagrams (P&ID) Flow charts or system diagrams of operational units that indicate specific information that can be used in training, troubleshooting, and safe operation auditing.

2.6 Replacement-in-Kind Replacement of an instrument, electrical, piping, equipment, apparatus or other component with an identical part or an equivalent approved and specified by the applicable Engineering standard. It also includes replacement of procedures or processes that are the same (i.e., updates). A list of typical modifications classified as Replacement-in-Kind (and NOT subject to Management of Change) is included as a reference in the Attachment section of this policy document.

2.7 RFC Request for Change.

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Policy No:EHS-104

EHS Management of Change

2.8 Temporary Change A change in piping or procedures for the purpose of accomplishing something not covered by typical operations will be considered a temporary change. It is removed as soon as the operation is completed.

3

Training

All S&W Energy employees (at a Facility or Site or Field personnel) shall be trained on the guidelines of this policy. Facility (or Site) Managers, technical staff, and supervisors must be trained in the overall Facility or Site Management of Change Procedure or process and in the detailed step-by-step procedures through which change is implemented. Training on this policy is included. Operators, craftsmen, and other personnel whose job function could involve them in implementing a change must be trained in the Facility or Site Management of Change Procedure or process, which includes this policy. Initial training is required and refresher training required every three years.

4

Auditing / Inspections

The EHS Management of Change Policy shall be reviewed every three years. The procedure will be updated as necessary. All documentation (Controlled Documents and Change Request Forms with supplemental information) shall be retained for the duration of the Policy. These records and documents may be reviewed during an audit or inspection.

5

References A. 29 CFR 1910.119, Process Safety Management B. Plant Guidelines for Technical Management of Chemical Process Safety

6

See Appendix C C.1

Examples of Changes and Replacement-in-Kind (2 Pages)

C.2

Example Change Request Form (2 Pages)

Page 4

Environmental Health and Safety Manual Policy No. EHS-201

Policy Title: OSHA Inspection Process

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2

Scope....................................................................................................................... 2 General Guidelines .................................................................................................. 2

Page 1

Policy No:EHS-201

1

OSHA Inspection Process

Scope

Workplace inspections by OSHA compliance officers may occur at any time. Ensuring full compliance with all applicable standards at all times will minimize any impact that an inspection may have. This policy outlines the basic OSHA inspection process and criteria.

2

General Guidelines

Under laws established by the Department of Labor, OSHA inspections proceed as follows: 1. Inspections can be initiated either by an employee complaint or the Labor Department's initiative. 2. Advance notice of a safety and health inspection without Labor Department authorization is prohibited. 3. Compliance officers must present credentials to the owner, operator, or agent in charge. If the inspection was the result of a complaint, the compliance officer must present a copy of the complaint prior to the conclusion of the inspection. 4. Compliance officers are entitled to enter without unreasonable delay. 5. A compliance officer may gain entrance by presenting credentials to any employee if minimum delay fails to produce the manager in charge. 6. Investigations and inspections must be conducted during regular working hours or at other reasonable times. 7. An authorized employee representative(s), as well as employer representatives, may accompany the compliance officer during the inspection. 8. In the absence of an authorized employee representative, the compliance officer may consult with a reasonable number of employees. 9. The compliance officer checks the place of employment, and all pertinent conditions, structures, machines, apparatus, devices, equipment and materials. 10. The inspection may include possible hazards reported before or during the inspection. 11. A citation will be issued for any violation. 12. If a condition poses imminent danger, the inspector has the authority to request that it be corrected immediately. If the situation is not abated, he/she can secure an injunction through the U.S. District Court, requiring immediate correction or suspension of the work until it is corrected. 13. The citation will detail the violation and the standard, which has been violated. A definite length of time for correction (abatement) will be set. 14. A copy of the citation must be posted at or near the place where the violation occurred. For our purposes, the bulletin board shall be acceptable. 15. An employee or his/her representative may appeal the time given for correction or the penalty and ask for more severe treatment.

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Policy No:EHS-201

OSHA Inspection Process

16. The employer may appeal the citation and proposed penalty providing it is appealed within 15 working days of the date of the citation or the right to appeal is lost. 17. When appealed, the “violations” is referred to the Solicitor’s office for review prior to legal action being taken or appeal to the Review Commission (Federal, not State programs). 18. The Review Commission is a three-person body independent of the Labor Department established for the specific purpose of hearing appeals. It should be noted that if the employee representative feels that the inspector was too easy on the contractor, he/she could also appeal the proposed penalty or the time of the abatement, asking for more severe treatment. If the employer does not file the Appeal within the stipulated fifteen days it loses the right of appeal. 19. When the Review Commission receives the Appeal from the Department of Labor, a notification of receipt will be sent to the Department of Labor, the employer, and the employee representatives setting time and place for hearing and appointing a hearing examiner. At all hearings there will be three parties--The Department of Labor, the employer, and the employee representatives. The hearing examiner will act as presiding officer and will issue a ruling. The examiner has the authority to subpoena records. It is optional at these hearings as to whether or not the parties are represented by legal counsel, and the President will make this decision. 20. The hearing examiner's ruling will be forwarded to the Review Commission which can concur in the rulings, modify, or vacate the rulings and can even increase the proposed penalty, based on the testimony at the hearing. 21. If the company wishes to contest the Review Commission's determination, our legal counsel will take the matter to the U.S. Court of Appeals.

Page 3

Environmental Health and Safety Manual Policy No. EHS-202

Policy Title: OSHA Inspection Procedure

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2 3

Scope....................................................................................................................... 2 General .................................................................................................................... 2 Procedure ................................................................................................................ 2 3.1 Procedures Prior to Arrival of a Compliance Officer.......................................... 2 3.2 Upon Arrival of a Compliance Officer................................................................ 3 3.3 At the Opening Conference............................................................................... 3 3.4 Employee Representation................................................................................. 4 3.5 Company Records ............................................................................................ 4 3.6 During the Inspection ........................................................................................ 5 3.7 Employee Interviews......................................................................................... 5 3.8 Closing Conference .......................................................................................... 6 3.9 After the Inspection ........................................................................................... 6 3.10 Upon Receiving a Citation................................................................................. 6 3.11 Citation Process................................................................................................ 6 4 See Appendix D ....................................................................................................... 7

Page 1

Policy No:EHS-202

OSHA Inspection Procedure

1 Scope This policy is an outline of the procedures required prior to, during, and after an inspection by OSHA compliance officers.

2 General The Occupational Safety and Health Act was enacted in 1970, with its purpose being "to assure so far as possible every man and woman in the nation safe and healthful working conditions and to preserve our human resources." The management of S&W Energy is in complete agreement with the purpose of the act and expects each project to comply with all regulations of the act. Administration and enforcement of OSHA are vested in the Secretary of Labor and Occupational Safety & Health Review Commission or with the State Labor Department in those states with approved programs. The act is enforced by job site inspections by OSHA Compliance Officers to determine if the regulations provided in the act are being complied with by employers. Violations of the act as determined by the compliance officers (COSH) during their inspections will result in financial penalties, up to $10,000.00 per violation. S&W Energy accepts the enforcement procedures as provided in the act, but realizes that if certain procedures are followed by the projects before, during, and after the inspections, the results of the inspections will be much more favorable to the Company. For this reason, the following procedures to be followed during an OSHA inspection have been established.

3

Procedure 3.1 Procedures Prior to Arrival of a Compliance Officer 1. The Project Manager (or designee) will designate the General Superintendent, Resident Engineer, and/or Safety Supervisor, to accompany the Compliance Officer during the inspection. This employee must be thoroughly familiar with the work S&W Energy is doing on the project, the work areas in which S&W Energy is involved, the equipment on the project belonging to or under the control of S&W Energy, and any subcontractors and their work on the project. He/she must also be thoroughly familiar with the S&W Energy EHS Manual and the safety program in effect on the project. 2. All records as required by OSHA (OSHA 300 Form, OSHA 101 Form, Crane Inspection Reports, etc.) are to be maintained and available. 3. A camera (preferably digital) will be located on the project and available. 4. The OSHA poster will be posted in a location readily observable by all employees where they normally report for work daily. 5. All safety activities on the project are to be documented; i.e., safety meetings (when held, who attended, topic covered, etc.), employee disciplinary measures taken for safety violations, correspondence to other contractors or the owner about unsafe conditions, etc.

Page 2

Policy No:EHS-202

OSHA Inspection Procedure

3.2 Upon Arrival of a Compliance Officer 1. The Project Manager or Safety Supervisor will verify the Compliance Officer's credentials, making sure the credentials are current. He/she will obtain a business card from each compliance officer, or record the name, address and phone number of each one. 2. He/she will determine why the Compliance Officer wants to inspect the project. The reason for the inspection will help in making the decision as to whether or not to require a search warrant. 3. DO NOT REQUEST SEARCH WARRANTS UNLESS INSTRUCTED TO DO SO. Search warrants will be requested only after consultation with S&W Energy Corporate Safety Department and/or agreement by the corporate legal staff. 4. If the Compliance Officer is at the project as the result of an employee complaint, the Project Manager or Safety Supervisor will ask for a copy of the complaint. 5. The Project Manager or Safety Supervisor will call the S&W Energy Manager of Safety immediately after obtaining the information in Nos. 1, 2 and 4 above, and before allowing the compliance officer to go to the work areas. 6. The Project Manager or Safety Supervisor will notify all project supervisors that the project is about to be inspected and the reasons for the inspection. 7. The Project Manager or Safety Supervisor will request an opening conference if the compliance officer does not call for one.

3.3 At the Opening Conference 1. The Project Manager, General Superintendent, Resident Engineer, and the Safety Supervisor (as applicable) are to be present. 2. Inform the subcontractors of the inspection and offer them the opportunity to be present. It is not mandatory that they attend; the choice is theirs. 3. Detailed notes must be taken of everything discussed. 4. If the inspection will disrupt an important meeting or critical phase of work, explain this to the compliance officer and arrange for the inspection to take place at a later time/date. 5. All publications and documents given by the compliance officer should be kept and marked with the name of the Compliance Officer and the date of its receipt. 6. The compliance officer's length of time with OSHA, education, prior work experience, and knowledge of project related work should be noted. 7. If more than one Compliance Officer is involved, it should be determined if they plan to make the inspection in one group or split into two (2) or more groups. If they want to divide into two (2) or more groups, it should be determined if it will present a problem for S&W Energy to provide a qualified employer representative for each group. If we are not in a position to provide an employer representative for each group, this should be discussed with the compliance officers. If they still insist on dividing into groups, the S&W Energy Manager of Safety should be contacted for direction.

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Policy No:EHS-202

OSHA Inspection Procedure

8. If the project involves many contractors, an agreement should be reached with the compliance officer that he/she will inspect S&W Energy in a short period of time, and will not involve us in a prolonged inspection (some project inspections have taken over a week) while he/she is inspecting us and every other contractor on the project simultaneously. 9. At all times prior to, during, and after the inspection, all S&W Energy employees should act in a cooperative, professional, businesslike manner, never entering into personal arguments with the Compliance Officer or volunteering information.

3.4 Employee Representation 1. One authorized representative of the employees shall be given the opportunity to accompany the Compliance Officer. If there is a safety committee, one member of the committee may be designated as the employee representative. 2. There need not be an employee representative for each inspection; however, where there is no authorized representative the compliance officer will probably talk to a number of employees about safety and health matters on the site. For this reason, we always prefer one employee representative to accompany the inspection team. 3. Employees interviewed during the inspection are not considered as part of the inspection for "walk around" purposes. Employees should be interviewed in private, and the Employee Representative should not be with the inspector during the interview. The name of the employee interviewed, the area he/she is working in, and any item/area he/she is obviously making comment on or reference to should be recorded.

3.5 Company Records 1. The Compliance Officer is allowed to look only at the OSHA records required to be kept by us: OSHA 300/300 A form, OSHA 301 form, Crane Inspection Records, etc. A copy of any of these records or any other records is not to be given to the Compliance Officer. 2. The Compliance Officer is not to look at any of our Company safety manuals. 3. The Compliance Officer is not to look at any safety inspection reports made by our Safety Engineering or Quality Control personnel, insurance carrier, etc., other than those reports required by OSHA. This includes not giving or letting the Compliance Officer look at any such reports made on subcontractor's activities. The officer may look at, but not have a copy of, safety committee minutes, check lists, or safety program plans. 4. Areas, which include, but are not limited to, our methods and operational procedures or our erection/form systems, quality control procedures, etc. should be identified as trade secrets. This will also include all negatives, prints or photographs, and environmental samples which should be labeled "Confidential Trade Secret" and normally not disclosed.

Page 4

Policy No:EHS-202

OSHA Inspection Procedure

3.6 During the Inspection 1. The Project Manager, General Superintendent, Resident Engineer, and/or Safety Supervisor (as applicable) should accompany the Compliance Officer at all times. They should never allow the Compliance Officer to have free and unlimited access to the project. 2. The inspection should be controlled. The Compliance Officer should be treated as would a guest in a house; he/she is there with our permission and will be expected to follow all instructions given him/her and will be required to conduct the inspection in such a manner that it does not disrupt the scheduled work. Remember that it is our project site - not OSHA's. The Compliance Officer is to be treated as any other visitor under our control while on our project. 3. Detailed notes of everything seen, discussed, and done by the Compliance Officer should be taken. 4. Photographs of everything the Compliance Officer photographs should be taken. If the equipment, work area, etc. can be photographed from a more favorable position (different angle, greater distance, etc.), photograph it from the different position. 5. No employee is to perform demonstrations for the Compliance Officer. Example - if a truck is idle and the Compliance Officer asks a person to operate it so he/she can see if the horn or back-up alarm is working, the request should be refused. The Compliance Officer should be allowed to see the work only as it is normally being done. 6. The Compliance Officer's questions should be answered to the best of a person's knowledge, but further information should not be offered. No evidence against oneself should be offered. 7. Orders, such as "clean up that trash", during the inspection to have conditions corrected that have not been noticed by the Compliance Officer should not be given. The immediate abatement of an alleged violation will not preclude a citation by the Compliance Officer, and may alert him/her to the condition. 8. If it is not fully understood what a Compliance Officer does or comments on, questions should be asked and all facts recorded, even if the inspection is interrupted.

3.7 Employee Interviews 1. Private interviews with S&W Energy employees by the Compliance Officer should not be allowed if they will be disruptive to the work process. If the compliance officer insists on having private interviews, it shall be done in accordance with the section on Employee Representation. 2. Record the names and employer of all personnel interviewed and, if we are present, the content of such interviews.

Page 5

Policy No:EHS-202

OSHA Inspection Procedure

3.8 Closing Conference 1. The Project Manager, General Superintendent, Resident Engineer, and the Safety Supervisor (as applicable) will be present. 2. There should be notes of everything discussed and records of what documents were distributed by the Compliance Officer. 3. No questions concerning the inspection should go unanswered. If the Compliance Officer feels that a violation exists on the project, abatement dates he/she plans to submit for each condition should be thoroughly discussed. If a condition cannot be corrected within the abatement date, it should be discussed with the Compliance Officer. 4. No estimate of abatement time needed to correct any alleged violations should be given. 5. Give the senior compliance.

3.9 After the Inspection 1. The Manager of Safety should be called to discuss the preliminary results of the inspection. 2. The Manager of Safety should immediately be sent copies of all notes and photographs taken. 3. The Manager of Safety shall call the S&W Energy Corporate Safety Department to discuss the preliminary results of the inspection.

3.10

Upon Receiving a Citation

1. The Manager of Safety should be notified immediately, as there will be only a limited period of time (15 working days) to make a decision as to how to best handle the citation. Date stamp the citation as of the date received and fax a copy to Corporate Safety 2. Make a copy for your record and send the original to corporate safety.

3.11

Citation Process

1. The Compliance Officer has the authority to request any condition that poses imminent danger be corrected immediately. If the situation is not abated, he can secure an injunction through the U.S. District Court requiring immediate correction, or suspension of the work until the condition is corrected. 2. The citation will detail the alleged violation(s) and the standard violated. A definite length of time for correction (abatement will be set and a monetary penalty proposed. 3. A copy of the citation must be posted at or near the place where the violation occurred. DO NOT POST THE PROPOSED PENALTY COLUMN. 4. The employer may appeal the citation and proposed penalty within 15 working days of the date the citation was received or he/she loses his/her right to appeal.

Page 6

Policy No:EHS-202

OSHA Inspection Procedure

5. The decision to appeal the citation and the method used will be made by Corporate Safety, Corporate Legal and the President. If it is appealed, the violation is referred to OSHA's Solicitor's office for review and submission to the Review Commission. The Review Commission is a three person body, independent of the Labor Department, established for the specific purpose of hearing Federal and State appeals. 6. When an appeal is submitted to the Review Commission a notification of receipt appointing a hearing examiner and scheduling a hearing, will be sent to the Department of Labor, the employer and the employee representatives. 7. The Department of Labor (OSHA), the employer, and the employee representatives (optional) will participate in the hearing. The hearing examiner, who has subpoena power, will act as presiding officer and will issue a ruling. This decision to be represented by Legal Counsel will be made by the President. 8. The hearing examiner's ruling is forwarded to the Review Commission. The Commission can concur, modify or vacate the ruling. 9. The decision to appeal the Review Commission decision will be made after review by Corporate Safety, Corporate Legal and the President.

4 See Appendix D D.1

Notice to OSHA (Federal Only) If, at the direction of S&W Energy Management, the decision is made to refuse access to the S&W Energy project area, Exhibit I is to be properly completed and presented to the Senior Compliance Officer attempting to gain access to the project. A copy is to be retained and forwarded to S&W Energy with the other required information.

D.2

Notice of Protest If S&W Energy is presented with an Inspection Warrant, the S&W Energy Manager of Safety should be contacted and a fax copy sent immediately. Exhibit II should be completed and presented to the Senior Compliance Officer serving the warrant after retaining a copy for our files. Then the inspection can proceed.

Page 7

Environmental Health and Safety Manual Policy No. EHS-301

Policy Title: OSHA Recordkeeping and Reporting

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2 3 4 5 6 7 8 9

Purpose and Scope.................................................................................................. 2 Definitions ................................................................................................................ 2 General Procedure................................................................................................... 6 Posting the OSHA 300A Log / Summary ................................................................. 7 Procedures for Incidents Involving Worker’s Compensation Claims ........................ 7 Training .................................................................................................................... 8 Auditing / Inspections ............................................................................................... 8 References............................................................................................................... 8 Forms....................................................................................................................... 8

Page 1

Policy No:EHS-301

OSHA Recordkeeping and Reporting

1 Purpose and Scope This procedure describes the notification, investigation, and reporting requirements that must be followed in the event of an occupational injury, illness or related accident. The procedure also outlines the reporting and recordkeeping requirements mandated by the Occupational Safety & Health Act (OSHA) and by insurance companies for worker’s compensation claims. The scope of this procedure covers work-related accidents, injuries and illnesses involving S&W Energy employees. Customers and affiliate labor of S&W Energy are subject to the same requirements under OSHA but are required to be filed under their parent company’s name and not under S&W Energy. NOTE: Procedure updated to reflect Recordkeeping changes taking effect on January 1, 2002.

This Procedure should be used with S&W Energy’s EHS Incident Reporting (and Follow-Up) Procedure to satisfy all regulatory and Company requirements pertaining to recordkeeping and reporting of EHS Incidents. Proper Forms to be completed when an EHS Incident occurs, per the two procedures include: EHS Incidents (Environmental and Permit Exceedances, Spills, Leaks, Explosions, Fires, Near Misses, etc.) 1. EHS Incident Report Form 2. EHS Incident Investigation Report Form EHS Incidents (Injuries & Illnesses) 1. EHS Incident Report Form 2. EHS Incident Investigation Report Form 3. First Report of Occupational Injury or Illness Form (OSHA 301 Equivalent) 4. OSHA 300 Log updated and maintained (if recordable) THE S&W ENERGY EHS MANAGER SHALL BE NOTIFIED OF AN INJURY/ILLNESS OR ACCIDENT AS SOON AS POSSIBLE

2

Definitions •

EHS Incident – An injury / illness, lost time accident, or fatality, including that of a contractor; a permit exceedance, a hazardous material spill; or other emergency such as fire, explosion, etc. Recordability of an EHS Incident may not always be

Page 2

Policy No:EHS-301

OSHA Recordkeeping and Reporting

determined at the time of occurrence or submittal of a report but may need to be classified after investigation is completed. •

First Aid – any one-time treatment and any follow-up visit (to doctor or clinic) for the purpose of observation of minor scratches, cuts, burns splinters and so forth, which do not ordinarily require medical care. Such one-time treatment, and follow-up visit for the purpose of observation, is considered first aid even though provided by a physician or registered professional personnel (registered Nurse or Physician’s Assistant). Reference the OSHA Recordability Checklist and Recordability Guidance Notes.



Incidence Rate (Injury & Illness (I&I) Rate) – A rate (number) calculated using the number of OSHA Recordable injuries and/or illnesses and total number of employee hours worked in relation to a common exposure base of 100 full-time workers. The common exposure base enables one to make an accurate interindustry comparison, trend analysis over time, or comparisons among firms regardless of size. The rate is typically taken over a 12 month rolling total, to take into account the Standard Factor discussed below. The I&I Rates of all applicable industries are accumulated and published through the Bureau of Labor Statistics as a measuring tool for occupational safety. The rate is calculated as: N / EH x 200,000 where: N = Number of injuries and/or illnesses or lost workdays; EH = Employee hours worked, combined, for all employees during calendar year or stated period; 200,000 = Standard Factor based on 100 full-time workers (working 40 hours per week, 50 weeks per year). If calculating the I&I rate over a period of less than 12 months, this factor will vary, totaling a standard number based on how weeks of the year you are calculating.



Log and Summary (OSHA No. 300 Log and 300A Summary) – The 300 Log is an OSHA recordkeeping form used to list OSHA Recordable (Occupational) injuries and/or illnesses, kept year to year (on a calendar year basis). The Log is used to record all Recordable injuries and illnesses and note their extent and severity. Following an injury report, an OSHA Recordable must be logged on the 300 Form within 7 days of the date of the Incident. Reports can be amended if further information proves the injury or illness not recordable or work-related. The 300 Log serves as the running list of annual Recordable injuries and illnesses. The 300A Summary is a separate form that totals all the work-related OSHA recordable injuries and illnesses, transferred from the OSHA 300 Log. 300A Summaries are required to be posted three months out of every year, required Page 3

Policy No:EHS-301

OSHA Recordkeeping and Reporting

from February 1 to April 30 for the preceding calendar year information. THE 300 AND 300A FORMS REPLACE THE OSHA 200 AND LOG SUMMARY, RESPECTIVELY. •

Lost Workdays – The number of days, consecutive or not, beyond the day of a work-place injury or onset of illness, that the employee was away from work or limited to restricted work activity because of occupational injury or illness. Do not count the day on which the injury or illness occurred. The count may end if it exceeds 180 days. They fall into two (2) categories: Lost Workdays Away From Work – The number of workdays, consecutive or not, on which the employee would have worked but could not because of occupational injury or illness. Lost Workdays (Restricted Work Activity) – The number of workdays, consecutive or not, which due to work-related injury or illness: (1) The employee was assigned another job on a temporary basis; or (2) the employee worked at a permanent job less than full time, differing from pre-injury or illness status; or (3) the employee worked at a permanently assigned job but could not perform all duties normally connected with it.



Medical Treatment – Treatment administered by physicians, by registered professional personnel or lay persons (i.e., non-medical personnel) in response to an injury or illness or employee. Medical treatment does not include first aid treatment (one-time treatment and subsequent observation or minor cuts, scratches, burns, splinters, and so forth, which do not ordinarily require medical care) even though provided by a physician or registered professional personnel. Reference the OSHA Checklist of Medical Treatment included in this procedure. The following are NOT considered Medical Treatment and, therefore, NOT Recordable: • • •



Visits to a doctor or health care professional solely for the observation or counseling; Diagnostic procedures, including administering prescription medications that are solely for diagnostic purposes; and Any procedure that can be labeled First Aid

Near Miss Incident – An event that COULD have resulted in an EHS Incident. These are important to record and report for preventative measures or to identify problem areas or issues.

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Policy No:EHS-301

OSHA Recordkeeping and Reporting



Occupational Illness – Any abnormal condition or disorder, other than one resulting from an occupational injury, caused by exposure to environmental factors associated with employment. It includes acute and chronic illnesses or diseases that may be caused by inhalation, absorption, ingestion, or direct contact of contaminants in the workplace.



Occupational Injury – Any injury such as a cut, fracture, sprain, amputation, etc., which results from a work accident or from an exposure involving a single incident in the work environment. (NOTE: Conditions resulting from animal bites, such as insect or snake bites, and from one-time exposure to chemicals are considered to be injuries).



OSHA 301 Form – A Form required By OSHA to be completed that records supplemental information for recordable injuries and illnesses. An equivalent Form may be used as long as it contains the same information as the OSHA 301 Form. In this procedure, the First Report of Occupational Injury / Illness Form may be used as the OSHA 301 Form. THE OSHA 301 REPLACES THE OSHA 101 FORM.



Posting – The 300A annual summary of occupational injuries and illnesses that is posted at each employer’s establishment from February 1st to April 30th, which includes data (I&I) for the previous calendar year. The posting includes the summary OSHA 300A Form. If company has “satellite” or field establishments, the posting can take place at headquarters but information at these remote locations must be accessible.



Recordable Cases – All work-related deaths and illnesses, and those workrelated injuries, which result in: Loss of consciousness, restriction of work motion. Transfer to another job, or require medical treatment beyond first aid. Reference the Recordability Flowchart and Checklist in this procedure for information on determining OSHA recordability.



Restriction of Work or Motion – Condition resulting from an employee’s job related injury or illness; the employee is physically or mentally unable to perform all or any part of his/her normal assignment during all or any part of the workday or shift.



Work Environment – Consists of the employer’s premises and other locations where employees are engaged in work related activities or are present as a condition of their employment. The work environment includes not only physical locations, but also the equipment or materials used by the employee during the course of his or her work.

Page 5

Policy No:EHS-301



3

OSHA Recordkeeping and Reporting

Workers’ Compensation Systems – State-run medical benefits program, set up by the individual states, to provide medical benefits and/or indemnity compensation to victims of work-related injuries and illnesses.

General Procedure

1. Whenever an injury/illness occurs at a site, the First Report of Occupational Injury/Illness Form (FROI) provided in this procedure must be completed. This form satisfies the requirement to record supplementary information of occupational injuries and illnesses and replaces the OSHA 301 Form. A. The form must be completed and reported to Headquarters within 48 hours of occurrence to ensure proper recording of any claim to proper worker’s compensation authorities. Insurance carriers withhold rights of denying claims if they are not reported in a prompt manner. If the FROI cannot reasonably be completed and sent within 24 to 48 hours, a call to Headquarters must be made for notification of the incident. B. Recordable Cases must be logged on the OSHA 300 Form within 6 calendar days of Incident or Case. Recordability must be determined within 7 calendar days. C. FROI (or OSHA 301 Logs / Records) shall be maintained on file for at least 5 years. 2. Recordable injuries/illnesses will be reported to the appropriate individuals according to S&W Energy EHS Incident Reporting (and Follow-Up) Procedures. In addition to the Form completed for the EHS Incident reporting, a copy of the First Report of Occupational Injury/Illness Form should be sent to each of these individuals. 3. Company insurance agencies shall be notified of a recordable injury/illness as soon as possible (this will be done by Headquarters personnel). Company insurance policies typically require that the insurer be given immediate notice of any accident or occurrence that may result in a liability under a policy. Failure to do so may result in loss of coverage and/or right of recovery under a policy. Further, Federal and State laws require proper and timely filing of workers’ compensation claims and other accident reports within 24 to 48 hours. 4. Upon receipt of information of injury or illness (of S&W Energy employee), S&W Energy will determine if the injury/illness is recordable using the OSHA Recordable Decision Flowchart and the OSHA Recordability Checklist, provided in this procedure, as a guide. If there is any question, contact the S&W Energy EHS Manager.

Because recordable injuries and illnesses need to be documented within certain time frames and because recordability is not always known at time of incident or receipt of incident report, all cases shall be considered recordable until determination has been made otherwise.

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Policy No:EHS-301

OSHA Recordkeeping and Reporting

5. In addition, an investigation will be conducted per S&W Energy EHS Incident Reporting (and Follow-Up) Procedure to identify corrective actions and determine how to prevent the injury/illness from recurring (for more serious cases).

4 •

• • • •

5 •





Posting the OSHA 300A Log / Summary All recordable injuries/illnesses will be recorded on the Facility or Site (location) OSHA 300 Log (Log). A copy of this Log is included in this Procedure or can be obtained from OSHA. Recordables must be logged on the Form no later than 7 calendar days after receiving information that a recordable case has occurred. The OSHA 300 Log is to be maintained on a calendar year basis. The Summary (Form 300A) must be posted in the workplace from February 1st until April 30th for the preceding calendar year. OSHA 300 Logs and 300A Summaries shall be maintained for at least 5 years. A SEPARATE OSHA 300A Summary must be posted for each employer at a given Facility or Site (location) other than S&W Energy. However, they are to be maintained by that employer and not by S&W Energy. An OSHA 300A Summary must be posted at each establishment for S&W Energy, unless provisions are made with Headquarters as to where the Log is to be posted. Under some circumstances, the Log can be posted at the employer’s headquarters site despite the fact that operations or work is carried on at a remote location. Contact the S&W Energy EHS Manager for specific guidance.

Procedures for Incidents Involving Worker’s Compensation Claims The Facility, Site, or Office Manager, Lead or Direct Supervisor (or designee) or Human Resources Manager is required to complete a Worker Compensation Board (WCB) Employer’s First Report of Injury/Illness Form for recordable injuries / illnesses. The First Report of Occupational Injury/Illness Form may be used for this requirement provided in this procedure and as referenced in Section 3. If this Form is not acceptable to the WCB, a separate Form supplied by the WCB must be obtained and completed. Contact the S&W Energy EHS Manager for more information. ALL REPORTS MUST BE SENT TO HEADQUARTERS (HQ) AND HQ WILL TRANSFER TO INSURANCE AUTHORITY. The Facility, Site, or Office Manager, or Lead or Direct Supervisor (or designee) or Human Resources Manager will send a copy of the First Report of Injury / Illness and the State Worker Compensation Board Employer’s First Report of Injury / Illness (if different) to the S&W Energy EHS Manager, as soon as possible. All claims, hospital bills, First Report of Occupational Injury/Illness Form, etc., shall be sent to: S&W Energy 1849 Kingwood Drive, Suite 103 Kingwood, Texas 77339 ATTN: Environmental, Health and Safety (EH&S)

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Policy No:EHS-301

• •

6

OSHA Recordkeeping and Reporting

A copy of the State Worker Compensation Board Employer’s First Report of Injury/Illness, or equivalent, will be sent to the State Worker’s Compensation Board. All forms must be kept on file for at least 5 years.

Training

All S&W Energy employees shall be trained on the requirements and guidelines of this procedure. EHS Incident Reporting (and Follow-Up) procedures will be given as part of this training. Training is required every three years or more frequently if program changes have occurred.

7

Auditing / Inspections

The OSHA Recordkeeping and Reporting Procedure shall be reviewed every three years. The procedure will be updated as necessary.

8

References

29 CFR 1904 Recording and Reporting Occupational Injuries and Illnesses under OSHA

9

Forms See Appendix E E.1 First Report of Occupational Injury/Illness (FROI) Form – OSHA 301 Equivalent E.2

OSHA Recordable Decision Flow Chart

E.3

OSHA Recordability Checklist

E.4

OSHA Recordability Guidance – Notes

Page 8

Environmental Health and Safety Manual Policy No. EHS-302

Policy Title: EHS Incident Reporting

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2 3 4 5 6 7 8 9

Purpose and Scope.................................................................................................. 2 Definitions ................................................................................................................ 2 Reporting EHS Incidents.......................................................................................... 3 Notification Responsibilities Involving Fatalities ....................................................... 4 EHS Incident / Near Miss Investigation & Follow-Up................................................ 4 Training .................................................................................................................... 6 Auditing / Inspections ............................................................................................... 6 References............................................................................................................... 6 Forms....................................................................................................................... 6

Page 1

Policy No:EHS-302

EHS Incident Reporting

1 Purpose and Scope This procedure provides the requirements and structure to report EHS Incidents and ensures that the appropriate individuals are notified of all EHS incidents that occur at a S&W Energy Facility, a job-site, or Headquarters / Regional Office as soon as possible. It also provides a systematic method of investigating the incident, identifying corrective actions to prevent reoccurrence, and outlines proper follow-up procedures of the Incident. This procedure outlines the method for and stresses the importance of communicating the details of incidents or near misses, along with the investigation results, to all S&W Energy employees to promote environmental, health and safety awareness and to prevent the incident from reoccurring.

This Procedure should be used with S&W Energy’s OSHA Recordkeeping and Reporting Procedure to satisfy all regulatory and Company requirements pertaining to recordkeeping and reporting of EHS Incidents. Proper Forms to be completed when an EHS Incident occurs, per the two procedures include: EHS Incidents (Environmental and Permit Exceedances, Spills, Leaks, Explosions, Fires, Near Misses, etc.) 1. EHS Incident Report Form 2. EHS Incident Investigation Report Form EHS Incidents (Injuries & Illnesses) 1. EHS Incident Report Form 2. EHS Incident Investigation Report Form 3. First Report of Occupational Injury or Illness Form (OSHA 301 Equivalent) 4. OSHA 300 Log updated and maintained (if recordable) THE S&W ENERGY EHS MANAGER SHALL BE NOTIFIED INJURY/ILLNESS OR ACCIDENT AS SOON AS POSSIBLE

2

OF

AN

Definitions •

EHS Incident - An injury/illness, lost time accident, or fatality, including that of a contractor; a permit exceedance; a hazardous material spill; or other emergency such as fire, explosion, etc. Recordability of an EHS Incident may not always be determined at time of occurrence or submittal of report but may need to be classified after investigation is completed.

Page 2

Policy No:EHS-302

• •

3

EHS Incident Reporting

Near Miss Incident - An event that COULD have resulted in an EHS Incident. These are important to record and report for preventative measures or to identify problem areas or issues Recordable Case – All work-related deaths and illnesses, and those workrelated injuries that result in: loss of consciousness, restriction of work or motion, transfer to another job, or require medical treatment beyond first aid. Reference the Recordability Flowchart and Checklist in the OSHA Recordkeeping and Reporting Procedure for information on determining OSHA recordability

Reporting EHS Incidents •

If an EHS Incident or near miss occurs at a S&W Energy Facility, job-site, or field service job, the Incident shall be reported to the Facility, Site Manager or Lead Supervisor as soon as possible. If an EHS Incident or near miss occurs in a S&W Energy Office (Headquarters or Regional Office), or while traveling on business, the Incident shall be reported to the Office Manager or employee Direct Supervisor as soon as possible.



The Facility or Site Manager, Lead Supervisor, Office Manager, or Direct Supervisor (or their designees) will complete an EHS Incident Report Form, provided in this procedure, based on the information of the EHS Incident or near miss at that time. (NOTE: Reports may need to be revised after first notification depending on results of any medical testing or further investigation into the Incident).



At a S&W Energy Facility, job-site, or during a field service job, the Facility or Site Manager, Lead Supervisor, or his/her designee, will notify the Customer / Owner of any EHS Incident or near miss as soon as possible. This can be done verbally or through written communication (i.e., memo, e-mail, etc.). Method of communication shall be identified on the EHS Incident Report Form.



Whether at a S&W Energy Facility, job-site, Headquarters / Regional Office, during field service job, or business-related travel, the Facility or Site Manager, Office Manager, Lead or Direct Supervisor (or their designee), shall notify the S&W Energy EHS Manager of any EHS Incident or near miss as soon as possible, but no later than 24 to 48 hours after occurrence.



The Facility or Site Manager, Lead Supervisor, Office Manager, or Direct Supervisor (or their designees) must also fax or e-mail a copy of the EHS Incident Report Form to the S&W Energy EHS Manager as soon as possible.



Outside agencies may also need to be notified in accordance with Federal, State and Local Regulations. Reference Site Emergency Response information or regulatory guidelines for contacts and proper procedures. (For O&M Facility, jobsite, or field service jobs, these notifications are typically made by the permit owner, which in most cases is the Customer). Page 3

Policy No:EHS-302



EHS Incident Reporting

A copy of the EHS Incident Report Form shall be kept on file for at least 5 years.

All EHS Incidents and near misses shall be reported, including those involving Contractors (at S&W Energy Facilities or job-sites or if subcontracted by S&W Energy).

4

Notification Responsibilities Involving Fatalities •

In addition to the requirements for reporting an EHS incident and/or near miss, the following steps should also be taken if a fatality should occur: A. A verbal report must be made to OSHA within eight (8) hours after the death of any employee from a work-related incident or any work-related incident that results in the hospitalization of three or more employees within 30 days from the incident date. B. The following information must be provided to OSHA in that verbal report:

1. The facility name; 2. The location of the Incident; 3. The time of the incident; 4. The number of fatalities or hospitalized employees; 5. The contact person; 6. The phone number; and 7. A brief description of the Incident. C. A Crisis Management Team or individual(s) may need to be engaged to deal with individual counseling issues surrounding a fatality or major catastrophe. OSHA will assist in this effort. • Upon notification of a fatality, S&W Energy Headquarters will notify Legal, Public Relations, and Human Resources. S&W Energy Headquarters will also assist in the fatality investigation, corrective action follow-up, and interfacing with regulatory agencies, as needed.

5

EHS Incident / Near Miss Investigation & Follow-Up •

All EHS Incidents and near misses shall be investigated. The investigation will vary according to the severity or potential severity of the incident. The Facility, Site, or Office Manager or Lead or Direct Supervisor will designate who is responsible for conducting and leading the Incident investigation. Page 4

Policy No:EHS-302

EHS Incident Reporting

As indicated by the severity of the Incident, steps to secure the Incident site must be initiated immediately to ensure the investigating party can conduct the proper investigation. •

The investigation shall be conducted as soon as practical after the Incident.



As part of the investigation, individual interviews should be conducted with individuals who were involved in the Incident or were witness of the Incident. Interviewing guidelines are as follows: The witnesses should be interviewed promptly, separately and privately. The interviewer should explain the purpose of the investigation to each individual. The interviewer should ask the witness to give their account of the events that occurred. The interviewer should avoid questions that give a yes or no answer. After the interview, the interviewer should document any concerns identified.

A. B. C. D. E. •

The investigation shall attempt to identify as many and practical corrective actions as possible, both immediate recovery actions and long term follow-up actions, to prevent the incident from reoccurring. All Corrective actions must have a responsible person assigned and tracked to closure. Management shall approve closure of all items identified by signing EHS Incident Investigation Report Form.



Each concern identified in the investigation must be addressed.



Upon completion of the investigation, the EHS Incident Investigation Report Form, provided in this procedure, will be completed by the Facility, Site, or Office Manager or Lead or Direct Supervisor, or designee, and sent to S&W Energy EHS Manager and Customer/Owner Headquarters, as applicable. The EHS Incident Investigation Report Form must be submitted to S&W Energy EHS Manager within one week from the Incident date.



A copy of the EHS Incident Investigation Report will be kept on file for at least 5 years.

EHS Incident Report Forms may need to be revised based on investigation results. Changes shall be made accordingly and as soon as possible. Amended reports and results shall be documented and filed.

Page 5

Policy No:EHS-302

6

EHS Incident Reporting

Training

All S&W Energy employees shall be trained on the requirements and guidelines of this procedure. Incident Investigation training shall be given as part of this training. Training is required every three years or more frequently if program changes have occurred.

7

Auditing / Inspections

The EHS Incident Reporting (and Follow-up) Procedure shall be reviewed every three years. Previous year’s reports may be reviewed during audit or inspection. This procedure will be updated as necessary.

8

References

29 CFR 1910.119

Process Safety Management

29 CFR 1910.120

Emergency Response Plans

9

Forms

See Appendix F F.1

EHS Incident Report Form (2 Pages)

F.2

EHS Incident Investigation Report Form

Page 6

Environmental Health and Safety Manual Policy No. EHS-304

Policy Title: EHS Monthly Reporting, Field Service

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2 3 4 5

Purpose and Scope.................................................................................................. 2 Policy and Guidelines............................................................................................... 2 Training .................................................................................................................... 4 Auditing / Inspections ............................................................................................... 4 Forms....................................................................................................................... 4

Page 1

Policy No:EHS-304

EHS Monthly Reporting, Field Service

1 Purpose and Scope This procedure provides guidance on S&W Energy’s requirement to report Environmental, Health and Safety information to Headquarters on a monthly basis. This requirement is applicable to S&W Energy’s Field Services Division.

Depending on customer requirements, a monthly report of ALL activity is required at most Field Service jobs and job-sites. This monthly report can be submitted as part of the general monthly report, as long as the required information is provided and all the customer requirements are met.

2

Policy and Guidelines Report Information and Schedule Each Field Service (FS) job and job-site is required to submit Environmental, Health and Safety information in the form of a report, provided in this procedure (Attachment Section). The report shall be completed and submitted on a monthly basis and must be provided to the S&W Energy EHS Manager, S&W Energy FS Manager and Supervisor, and the customer representative, at the end of each month. The monthly report can either be sent via fax, electronically, or mailed to headquarters as long as it is received by the indicated dates below. The S&W Energy EHS Manager will distribute to appropriate personnel at headquarters. Monthly reports are due to Headquarters no later than 7 days following the end of each month. If the report will be late or delayed for any reason, please contact S&W Energy Headquarters to notify of the delay in information. In the case of reporting injuries and illnesses on the monthly report, identify information in regards to S&W Energy employees ONLY. Although injuries and illnesses to other contractors and subcontractors are required to be reported as part of each contractor’s policy, they SHOULD NOT be rolled up on the S&W Energy’s monthly report. The monthly report is to provide information concerning S&W Energy employees. •

Other injuries on the same job-site may be noted and passed along to S&W Energy employees for informational and awareness reasons, but they are not required to be recorded.

All sections of the monthly report should be completed. If there is a section that does not apply to your employees or job-site, please indicate with “N/A” for Not Applicable. If there is no information to report although the category does apply to your Site, please indicate with “0”.

Page 2

Policy No:EHS-304

EHS Monthly Reporting, Field Service

Injuries and Illnesses If further clarification is required concerning recordable injuries and illnesses, days away from work, restricted work status, etc., please reference S&W Energy’s procedure on OSHA Recordkeeping and Reporting. ALL injuries and illnesses, including all other EHS Incidents, are to be reported as part of S&W Energy’s EHS Incident Reporting Procedure. The Incident Reporting process includes reporting injuries and illnesses that are NOT classified as recordable in addition to those that are. However, the monthly report requires recordable cases ONLY. Therefore, be advised that the number of injury and illness cases reported through the EHS Incident Reporting process may differ from the number recorded here. Environmental Exceedances Include air, water (either wastewater or stormwater), chemical spills, etc., in the appropriate categories on the report, if the incident pertains to, affects, or is the responsibility of a S&W Energy employee. Please specify as to the type of exceedance as indicated on the form. Every permit exceedance is classified as an EHS Incident, according to S&W Energy’s EHS Incident Reporting Procedure. Therefore, the number of exceedances reported on the quarterly report can be verified with the EHS Incident Reports filed. Only spills and releases that are classified as REPORTABLE should be included on the monthly report. To be considered reportable will depend on the material released or spilled, where the material is released or spilled, and the amount. State and local regulations differ in what they classify as reportable. Please consult local regulatory agencies to determine the criteria for reportable spills or releases. ALL spills or releases of chemicals or hazardous materials, including all other EHS Incidents, are to be reported as part of S&W Energy’s EHS Incident Reporting Procedure, if the incident pertains to, affects, or is the responsibility of a S&W Energy employee. The Incident Reporting process includes reporting spills and releases that are NOT classified as reportable in addition to those that are. However, the monthly report requires reportable spills and releases ONLY. Therefore, be advised that the number of spills and releases reported through the EHS Incident Reporting process may differ from the number recorded here.

Environmental permitting for Field Service jobs is typically in the name of the customer. For Environmental Exceedance reporting, consult with the customer for details on limits, responsibilities, state-specific rules, etc.

Page 3

Policy No:EHS-304

EHS Monthly Reporting, Field Service

Inspections Include the number of inspections (i.e., regulatory by an agency, conducted by a customer, conducted by S&W Energy, etc.) the Site has during each month. Agency inspections are also recorded as part of S&W Energy OSHA Inspection Procedure. These two numbers should correspond to one another. Distinguish between the type of inspection conducted, either health and/or safety related or environmental related. Violations / Citations / Fines Record the number of violations, citations, or notices of non-compliance issued to the Site and any associated fines imposed as result of those citations.

The S&W Energy EHS Manager will review all monthly reports. They will be assessed to determine any trends or patterns, to determine any problem areas, to note exceptional EHS performance, and to determine where EHS can be improved.

3

Training All S&W Energy Field Service Directors or Supervisors, or their designees shall be trained on the requirements of this procedure. Refresher training will be given if the procedure or report changes. It is the responsibility of the Site or Job Supervisor to track the information required in the monthly report, complete the report form, and send it to Headquarters by the timeline established in this procedure.

4

Auditing / Inspections The S&W Energy EHS Manager shall review the reports every month upon submittal. Monthly reports shall be maintained for the duration of the job and kept at Headquarters for the life of the project. This procedure will be updated as necessary.

5

Forms See Appendix H Field Services EHS Monthly Report Form

Page 4

Environmental Health and Safety Manual Policy No. EHS-401

Policy Title: EHS Training Requirements

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2 3 4 5 6 7 8 9 10

Purpose and Scope.................................................................................................. 2 Definitions ................................................................................................................ 2 Procedure ................................................................................................................ 2 Training Process ...................................................................................................... 3 Training Plans .......................................................................................................... 3 EHS Training Recordkeeping System...................................................................... 4 Training .................................................................................................................... 4 Auditing / Inspection................................................................................................. 4 References............................................................................................................... 5 Forms ................................................................................................................... 5

Page 1

Policy No:EHS-401

EHS Training Requirements

1 Purpose and Scope The purpose of this procedure is to establish regulatory required Environmental, Health & Safety (EHS) training for S&W Energy employees. It establishes EHS training that is mandatory based upon S&W Energy policy. Best Practice training, training which is not required either by regulation or by business policy but required under discretion of Manager or Facility as needed, is also identified. This procedure defines the frequency of all EHS Training. This procedure establishes a Recordkeeping System to record and track the training that has been conducted for each S&W Energy employee at any site. The scope of this procedure covers all field employees (personnel at O&M Facilities, field service technicians out on various job sites, etc.), in addition to office employees working at Headquarters or Regional Offices. Although some courses may be the same for field and office employees, the required EHS training for field employees is much more extensive, in purpose, scope, and content. The EHS Training Matrix included in this procedure identifies field employee EHS training with the office employee EHS training being a smaller subset of this Matrix. Training Plans are not required to be submitted by Headquarters and Regional Offices. Training will be set-up by the EHS Manager.

2

Definitions Qualified – A person with specific training, knowledge, and experience in the area for which the person has responsibility and the authority to control.

3

Procedure All new S&W Energy personnel must make every effort to complete the regulatory required and S&W Energy required EHS training as identified in the EHS Training Matrix within the first six months of employment. Efforts shall be made to attempt to obtain training records/certifications for new employees of S&W Energy or for employees who have transferred to S&W Energy from another company. These training records must be reviewed to ensure they meet EHS requirements, as outlined in this procedure. If no documentation can be obtained, employees must complete all initial EHS training required for their job position as identified in the EHS Training Matrix. EHS refresher training for other employees needs to occur on the frequency defined in the EHS Training Matrix. Training records must follow employees who transfer to other Facilities or Sites within the S&W Energy Business. S&W Energy has EHS Procedures that also need to be implemented through training. The regulatory training identified on the Training Matrix satisfies most of these requirements; however, additional procedural training may be required. Employees must review all EHS procedures.

Page 2

Policy No:EHS-401

4

EHS Training Requirements

Training Process

Each Facility or Site (including Headquarters / Regional Office(s)) needs to implement a process to ensure regulatory required and S&W Energy required EHS training is being completed in a timely manner. The process must include the following steps: •

• • • • •







A Training Plan must be created which includes the requirements identified in the EHS Training Matrix (use of the Matrix and the Annual EHS Training Tracking Form should be used to generate this Training Plan). The Training Plan development does not apply to Headquarters or Regional Offices. Training will be coordinated through EHS Manager. Employees must be scheduled for training taking into consideration shift work, vacations, illness, other training, etc. A system must be in place to notify employees in advance of the training. Training must be monitored to identify if courses need to be rescheduled for employees who did not attend, for new employees, or for employees who have changed positions, etc. The Training Plan must be maintained to include employee changes, rescheduling of courses, etc. Training records should attempt to be obtained for new employees transferring from another business or company; raining records compiled while at S&W Energy must follow employees who transfer to new positions within the business. Employee training must be recorded in a systematic format, where records can be readily and easily accessed and training status can easily be determined. An example Annual EHS Training Tracking Record is included in the Attachment Section of this procedure. A business-wide policy, which includes top-level management commitment, must be in place requiring that employees attend EHS regulatory required and S&W Energy required EHS training. The policy must include steps to be taken if employees arbitrarily miss regulatory required training. Any changes to the EHS Training Plan or additional information that needs to be included in the Training Plan shall be documented and filed with the Training Plan. Notify the appropriate individuals, as necessary.

Training can be given via several methods including using a live instructor (must be qualified), using videos from safety qualified vendors, or using computer-based or webbased training media (CDs, computer programs, etc.). Contact the EHS Manager, or designee, for more information on EHS training resources.

5

Training Plans

Training plans must be developed for each Facility or Site by the end of the third quarter of each calendar year (this is to coincide with budget planning). The Training Plan developed should comprise the training agenda for the following year. Consider the following when developing the annual Training Plan and developing a list of EHS training requirements for personnel:

Page 3

Policy No:EHS-401

• • • • • • •

EHS Training Requirements

Work activities currently in place that have training requirements; Anticipated changes in the work force responsibilities that may alter EHS training requirements; New equipment or processes that may trigger additional training requirements; Modified work methods or job responsibilities that will require new or modified training; Seasonal or non-routine work assignments subject to EHS regulatory requirements; Training programs that may help to reduce or eliminate workplace injuries or which the Facility or Site considers a Best Practice; and/or Results of EHS assessments or employee discussions.

Training Plans should be consistent with the EHS Training Matrix to ensure consistency and accuracy in entering this information into the designated EHS Training Tracking System (i.e., keep course name the same). Training Plans must be revised during the year to reflect any changes and/or revisions as well as any personnel changes. For example, if the Facility or Site Manager has left and a new Facility or Site Manager has been assigned, the Training Plan must be revised to include the EHS training requirements for the new Facility or Site Manager.

6

EHS Training Recordkeeping System

Each Facility or Site (including Headquarters / Regional Office(s)) must track S&W Energy employee EHS training continuously. Any certificates, test results, or other records obtained to validate proof of EHS training completed shall be kept in an EHS Training records file for the length of employment of individual.

7

Training

All S&W Energy employees shall be trained on the guidelines and requirements of this procedure. Initial training is required only.

8

Auditing / Inspection

Training records must be retained for the duration of any employee’s term of employment with the Company. They may be subject to review at any time to obtain the training status of an employee. The Facility or Site Manager, or designee, shall review the EHS Training Program on a quarterly basis to ensure EHS training is being completed and up-to-date. The EHS Training Procedure shall be reviewed every 3 years and updated accordingly.

Page 4

Policy No:EHS-401

9

EHS Training Requirements

References

29 CFR 1900 – to End

OSHA General Industry Standards

29 CFR 1926

OSHA Construction Standards

10

Forms

See Appendix I EHS Training Matrix (6 Pages)

Page 5

Environmental Health and Safety Manual Policy No. EHS-402

Policy Title: EHS Auditing Process

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2 3 4 5

Purpose and Scope.................................................................................................. 2 Audit of S&W Energy’s EHS Manual (Policies, Procedures, and Programs) ........... 2 EHS Audit or Assessment of the Facility (Walkthrough Audit) ................................. 2 Training .................................................................................................................... 4 Forms....................................................................................................................... 4

Page 1

Policy No:EHS-402

EHS Auditing Process

1 Purpose and Scope This procedure establishes the requirements for assessing S&W Energy’s Environmental, Health and Safety (EHS) policies and procedures provided in the EHS Manual. This includes review of the documentation, developed plans, and associated practices that accompany each policy and procedure. This procedure also provides guidance conducting entire Facility EHS assessments and audits (walk-through), done either internally or by a third party consultant.

2

Audit of S&W Energy’s EHS Manual (Policies, Procedures, and Programs)

Each EHS policy and procedure provided in the EHS Manual shall be assessed, audited, updated, and/or revised within the established timeframes provided in each policy and procedure. (Typically audit timeframes and frequencies are included in the Auditing Section of each policy or procedure). • • •

3

The audit / assessment shall take into account any regulatory or S&W Energy policy changes that may affect the procedure and require revisions or updates to the established requirements and guidelines. Changes shall be made as soon as possible (as soon as the change is known or becomes effective) and the revised procedure issued to all those who possess a copy of the EHS manual. The audit / assessment of the policy, procedure, or program shall be conducted by the S&W Energy EHS Manager, or designee. A schedule will be developed on an annual basis to identify the policies and procedures, which will be reviewed through the course of the year.

EHS Audit or Assessment of the Facility (Walkthrough Audit)

Each S&W Energy Facility shall have a complete EHS audit of their Facility completed on an annual basis. • • •



More frequent assessments may be conducted, as deemed necessary either by the customer or a regulatory agency, however, at a minimum, one compete EHS audit shall be conducted every year. The EHS Facility Audit shall consist of an assessment of the Facility practices and implemented programs covering all topics in S&W Energy EHS Manual. Use the EHS Manual’s Table of Contents as a guide. All findings (i.e., items found to be out of compliance or regulatory-based) shall be documented by the auditor or auditing team. If the audit is conducted by an outside third party or by a customer representative, the findings shall be discussed with the Facility Manager, or designee, prior to documenting as a finding. All findings shall be closed out as soon as possible. The Attachment section of this procedure contains a form that can be used to document the results of a Page 2

Policy No:EHS-402

EHS Auditing Process

Facility EHS Audit. A copy of this form, or equivalent, shall be submitted to the S&W Energy EHS Manager following the audit and the findings will be tracked to closure. The following items shall be included on the tracking form:





Audit Type – Self assessment or third party audit;



Finding Type – Regulatory, S&W Energy policy, or best practice;



EHS Category – Area or classified topics of finding, i.e., waste management, material handling, electrical safety, etc.;



Finding – Brief description of the finding;



Corrective Action – Brief description of corrective action to amend the finding;



Contact Name / Responsible Person – Individual to contact in case of a question / individual responsible for closing out the identified item or person implementing corrective action (this can be same person or different individual for each);



Finding Date – Date of the audit or finding;



Expected Completion Date – Date that the identified corrective action shall be implemented and the finding closed. DATE OF CLOSURE SHOULD NOT BE MORE THAN 30 DAYS FROM DATE OF FINDING UNLESS DISCUSSED WITH S&W ENERGY EHS MANAGER; and



Status – Either open or closed. THERE SHALL BE NO REGULATORY FINDINGS OPEN MORE THAN 30 DAYS, unless special provisions have been made.

The annual EHS Audit may be conducted by the Facility itself (employees at the Facility), by the S&W Energy EHS Manager, or designee, by a Customer or Owner Representative, or by a third party (consultant or regulatory agency). If an outside party conducts the audit, S&W Energy shall ensure that the audit covers all the to criteria outlined in the EHS Manual. THE AUDIT / ASSESSMENT MUST BE CONDUCTED BY A KNOWLEDGEABLE INDIVIDUAL OR GROUP OF INDIVIDUALS, QUALIFIED TO ASSESS EHS FOR S&W Energy. NOTE: If a Regulatory agency performs an audit, reference the requirements of S&W Energy Inspections Procedure.

Page 3

Policy No:EHS-402

EHS Auditing Process

An EHS Facility assessment or audit must be conducted on an annual basis. However, the ENTIRE audit dos NOT have to be completed at one time. If ALL of the EHS topics are audited through the course of the year, this satisfies the annual EHS audit requirement.



4

The EHS Facility audit or assessment results shall be maintained for the life of the Facility.

Training

All Facility Managers or Site Supervisors shall review the Auditing Protocol procedure and understand the requirements of EHS audits or assessments for their own Facility. No other training is required.

5

Forms

See Appendix J - Audit Findings Tracking Form

Page 4

Environmental Health & Safety Manual Policy No. EHS-501

Policy Title: Contractor Safety

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

1. Table of Contents 1 2

Purpose and Scope.................................................................................................. 2 Definitions ................................................................................................................ 2 2.1 Competent Person ............................................................................................ 2 2.2 Confined Space ................................................................................................ 2 2.3 Contractor ......................................................................................................... 3 2.4 Contractor Representative ................................................................................ 3 2.5 Contractor Supervisor ....................................................................................... 3 2.6 Contractor Worker............................................................................................. 3 2.7 EHS Incident ..................................................................................................... 3 2.8 Facility or Site ................................................................................................... 3 2.9 Facility (S&W Energy) Representative.............................................................. 3 2.10 Near Miss Incident ............................................................................................ 3 2.11 Sign-In Log (Facility or Site Sign-In Log) .......................................................... 3 2.12 Visitor ................................................................................................................ 4 3 Bid Solicitation.......................................................................................................... 4 3.1 Process ............................................................................................................. 4 4 Contractor Review and Selection ............................................................................. 5 5 Contractor Requirements – Prior to Commencement of Work ................................. 6 6 Inspections and Oversight........................................................................................ 7 7 Disciplinary Action(s)................................................................................................ 8 8 Contractor Injury or Illness / Report of Environmental Accident and Near Misses . 8 9 Visitors and Non-Major Contractors ......................................................................... 8 10 Recordkeeping ..................................................................................................... 9 11 Training ................................................................................................................ 9 12 Auditing / Inspections ......................................................................................... 10 13 References ......................................................................................................... 10 14 Attachments.......................................................... Error! Bookmark not defined.

Page 1

Policy No. EHS-501

Contractor Safety

1 Purpose and Scope The purpose of this procedure is to establish a method of ensuring only qualified Contractors are selected to perform work at S&W Energy Facilities or Sites. In addition, this procedure establishes guidelines and precautions taken for the safety of Contractors, or any other visitors, while on-site. The scope of this procedure covers Major Contractors performing high-risk operations at a S&W Energy Facility or Site or those Major Contractors who have been subcontracted by S&W Energy. Major Contractors performing high-risk operations include, but are not limited to: • • • • • • •

Contractors performing maintenance services using: Lock-out / Tag-out, Electrical Safety, Hot Work, or Respiratory Protection; Contractors who will work in Confined Spaces; Contractors using hazardous chemicals or materials, Contractors using heavy machinery (i.e., cranes, forklifts, etc.); Contractors working on scaffolds and ladders requiring fall protection; Contractors involved in demolition or excavations (trenching activities); and/or Contractors involved in management of hazardous waste or substances;

S&W Energy shall use discretion in their definition of Major Contractor, keeping in mind the type of work they will be involved in and the possible environmental, health and safety concerns associated with that work. Purpose here is to ensure that S&W Energy hires only qualified professionals to perform work activities to ensure a job well done while keeping safety a top priority. All other contractors and visitors on site do not need to be pre-qualified or go through the bid solicitation process. These may include food/cafeteria vendors, lawn care specialists, mail delivery employees, etc. However, they must use the Sign-In Log. If these “exempt” Contractors ever need to enter parts of the Facility or Site where work is being performed or may need to perform such activities as described above, S&W Energy shall verify their qualifications or have them escorted and assisted by a Facility Representative.

2 Definitions 2.1 Competent Person One who is qualified to perform a specified task as proven through training records, and/or by demonstrating the capability to identify existing and predictable hazards and the ability to take prompt, corrective measures to eliminate those hazards.

2.2 Confined Space Any space large enough and so configured that an employee can bodily enter and perform assigned work, but is not intended for continuous human occupancy, and has a limited means for entry or exit.

Page 2

Policy No. EHS-501

Contractor Safety

2.3 Contractor Any employee, group of employees, and/or organization working at a S&W Energy Facility or Site, under contract to perform work by S&W Energy. Contractor can be regular, temporary, or part-time worker.

2.4 Contractor Representative An individual designated by Contractor Company to sign paperwork and/or interface with S&W Energy, representing that Company.

2.5 Contractor Supervisor Any Contractor Worker in charge of work, regardless of title or classification.

2.6 Contractor Worker Every regular, temporary, or part-time Contractor employee, including subcontractors, working at a S&W Energy Facility or Site.

2.7 EHS Incident An injury/illness, lost time accident, or fatality, including that of a Contractor; a permit exceedance; hazardous material spill; or other emergency such as fire, explosion, bomb threat, etc. In case of an injury/illness, further investigation may be needed to classify as recordable or non-recordable (according to definition of OSHA).

2.8 Facility or Site The site or location, and all associated equipment, where S&W Energy is Operator or working as Contractor.

2.9 Facility (S&W Energy) Representative The designated Facility employee who is responsible for being a Contractor’s main point of contact while at the S&W Energy Facility or Site. The Facility Representative will conduct pre-job health and safety meetings to include review of work scope, Contractor’s responsibilities, and any Facility or Site specific health and safety concerns.

2.10

Near Miss Incident

An event which could have resulted in an EHS Incident.

2.11

Sign-In Log (Facility or Site Sign-In Log)

A book maintained for the purpose of recording Contractors and Visitors arriving and leaving the Facility or Site which includes: name, date, company, purpose of visit, time of check-in, and time of check-out.

Page 3

Policy No. EHS-501

2.12

Contractor Safety

Visitor

Any person who is not a regular, temporary, or part-time Contractor on S&W Energy Facility or Site property and whose stay is confined to office areas or who is escorted by a Facility Representative at all times.

3 Bid Solicitation Each time S&W Energy would like to obtain bids or quotes from a potential Contractor for work at a S&W Energy Facility or Site (or whether S&W Energy is subcontracting work at a customer site), a Bid Solicitation / Contractor Qualification Form must be completed by potential Contractor. The information provided on this Form, and any subsequent information, must be reviewed and approved by S&W Energy prior to any Contractor coming on-site to perform work. It is recommended that S&W Energy prequalify Contractors (i.e., go through this process well in advance of work commencing) so that there is no delay when trying to get qualified Contractors on-site for a specific job. The Contractor must submit certification that his/her Contractor Workers are properly trained to perform the work proposed, per regulatory or other required guidelines (Federal, State, and/or local). A Contractor Representative may verify this certification of his/her employees as a group or may verify each one individually. This certification shall be done on the Contractor EHS Training Tracking Certification Form, provided in this procedure. This Form shall be sent out with Bid Solicitation / Contractor Qualification Form. ONLY QUALIFIED CONTRACTORS WHO MEET BID SPECIFICATIONS AND EHS TRAINING REQUIREMENTS WILL BE CONSIDERED FOR WORK. In addition to basic safety and training information required of all Contractors, S&W Energy shall indicate on the Form any additional information that is required for submittal by the Contractor in order to be considered for the bid. This will be job- / sitespecific.

3.1 Process S&W Energy must send Bid Solicitation / Contractor Qualification Form to potential Contractors. S&W Energy may have to complete portions of the Form, indicating specific information that the potential Contractor must provide to be considered for the job. The EHS Training Tracking Certification Form shall also be sent to Contractor with the bid solicitation. Potential Contractor must complete the Form and send all information indicated to the S&W Energy contact, as designated on the Form or in cover letter. Contractor Representative before submittal must sign the Form. At a minimum, the Contractor must have a written HAZCOM Program and be able to provide this document upon request. A written HAZCOM program is a requirement of all employers, per OSHA regulation in regards to Hazard Communication. Page 4

Policy No. EHS-501

Contractor Safety

All hazardous chemicals and materials brought on-site by any Contractor must be accompanied by and MSDS. Chemicals and materials should be identified to the Facility or Site in advance and noted on the Qualification Form. The Contractor is required to use S&W Energy EHS procedures while performing work on-site, unless exceptions are made between customer, S&W Energy, and Contractor prior to commencement of work. If the potential Contractor wishes to use their own procedures, they must first ensure that the procedures meet all regulatory requirements and that they are at least as stringent as S&W Energy’s policies covering the same topic. Potential Contractor must submit any procedure they wish to use with the Bid Solicitation Form for review by S&W Energy. S&W Energy shall indicate the specific health and safety procedures to be used under the scope of work to be performed. Based on this information, the potential Contractor shall submit verification that Contractor Workers that will be supplied are properly trained and qualified to perform the specific work identified. The Contractor EHS Training Tracking Certification Form shall be completed accordingly and submitted. When contract bidding will not be performed, Contractors are still required to submit the Bid Solicitation / Contractor Qualification Form and any requested information in order to be allowed to perform work at the Facility. Any information submitted by a Contractor during bid solicitation must be maintained on file for at least one year. Annual qualification renewals are required.

4 Contractor Review and Selection The Bid Solicitation / Contractor Qualification Form and additional submittals will be reviewed by S&W Energy Representative, or designee as part of the selection process to evaluate the safety qualifications of the Contractor. The Safety record submitted by the Contractor shall be evaluated. Contractors with a poor safety record (check industry averages to compare) or inadequate safety programs may be disqualified from the bidding process or requested to upgrade their programs to qualify. Once the Contractor has been selected, S&W Energy will send to the Contractor the Contractor EHS Rules Form for the Facility or Site for review. These rules and guidelines shall comprise Contractor requirements in addition to general EHS rules and Facility or Site specific rules and guidelines, as provided in attachment in this procedure. This shall be provided on one Form for the each Facility or Site. Upon arrival at the Facility or Site, the Contractor must sign this Form, indicating they have read and fully understand the rules. By sending a copy in advance, it gives the Contractor or any Contractor Worker time to review site-specific information and ask any questions they may have prior to starting work and to avoid delays at check-in. Upon award of the contract, the Contractor will supply the Facility with all of the requested documentation (that was not previously supplied) as indicated on the Bid Solicitation / Contractor Qualification Form (i.e. MSDS, Certificate of Insurance, etc.).

Page 5

Policy No. EHS-501

Contractor Safety

5 Contractor Requirements – Prior to Commencement of Work All Contractors must sign in and sign out on the Facility or Site Sign-In Log upon arrival. This Log shall contain, at a minimum, the Contractor’s name, date, company, purpose of visit, time of check-in, and time of checkout. The Log shall be retained in the Facility or Site files for at least 3 years. Anytime a Contractor Worker or Visitor enters or leaves the Facility or Site, he/she must sign in and sign out on this Log. All first time Contractor Workers on-site and/or unescorted visitors must sign the Contractor EHS Rules Form at time of check-in. It is the responsibility of the Facility or Site to generate site-specific EHS requirements and add them to the general EHS rules (applicable to all Facilities and Sites) and Contractor Rules provided in this procedure to generate one Form, Contractor EHS Rules Form (reference Section 4.0 of this procedure). These signed Forms shall be retained by the Facility to verify annual approvals of Contractors. The signed Contractor EHS rules is valid for one year for each Contractor Worker who signs it. Each year, at the Contractor Worker’s first visit to the Facility, he/she must review and sign the Contractor EHS Rules Form. If the Contractor Worker, through his Company’s bid qualification process, has been approved as Contractor and has been on-site in the past year and previously signed the Form, he/ she does not need to sign again until the next year. OPTIONAL: S&W Energy may choose a number of methods that may assist in identifying valid and approved Contractor Workers on-site for any given year. One method is to generate or purchase color-coded stickers or badges to display on hard hats, signifying that the Contractor Worker has signed the Contractor EHS Rules Form and has been approved for work during that year. The next year, upon Contractor Worker’s first visit to the site and upon signing the Contractor EHS Rules Form for that year, a different color-coded sticker or badge can be issued, designating valid for that year. The Contractor Supervisor or Representative may sign one Contractor EHS Rules Form for all of the Contractor Workers under his supervision. However, each Contractor Worker MUST have read the rules and fully understand the contents. The Contractor Supervisor or Representative must indicate (by signing the Rules Form) that he/she is verifying for all Contractor Workers under his/her supervision. Each Contractor will be assigned a S&W Energy Facility or Site Representative. This S&W Energy Facility Representative, or designee, must conduct a pre-job safety meeting with the Contractor Representative / Supervisor (and his/her Contractor Workers) prior to the start of work activities. During this meeting, the S&W Energy Representative shall discuss: • •

The scope of work; Hazards associated with the job (i.e., any confined spaces and hazards associated with each);

Page 6

Policy No. EHS-501

• • •

Contractor Safety

Expectations of the Contractor Workers; Review of the Facility or Site Emergency Procedures (fire alarms, exits, routes of evacuation, emergency numbers and contacts, etc.); and Anything else that may be applicable to the job.

If the Contractor Workers are not present at this pre-job safety meeting, the Contractor Supervisor must relay this information to the Contractor Workers before beginning work. All Contractor Workers must receive and understand this information. NOTE: This safety orientation can be given through the use of a Facility or Site video, covering all the topics above and all the topics discussed on the Contractor EHS Rules Form. Contact S&W Energy EHS Manager for more information on videos. Each day, the Contractor Supervisor or Representative must report to the Control Room or other designated area assigned by the Facility, and complete a Daily Contractor Work Permit (for approval to begin work) from the Shift Supervisor. See sample Daily Work Permit provided in this procedure.

6 Inspections and Oversight The Contractor shall perform weekly safety meetings with his/her own employees, if onsite more than one week. The Contractor shall address any safety concern raised at these meetings immediately. The S&W Energy Representative shall be notified of any safety concern. Safety meeting information, agenda and attendants, shall be recorded by the Contractor (a sample Weekly Safety Meeting Form is provided in this Procedure). A copy of this form shall be given to the Facility Representative. If safety becomes a big concern at the site during the course of the work, frequency of safety meetings may increase, accordingly, to address issues. The Contractor shall perform safety inspections, at least weekly, of his/her Contractor Worker’s activities if the Contractor is on-site for longer than one week. The Contractor shall address safety concerns raised during these audits immediately. The S&W Energy Representative shall be notified of any safety concern. Inspections shall be documented (a sample Inspection Checklist is provided in this procedure). A copy of the checklist shall be shall be given to the S&W Energy Representative. In addition to the Contractor inspecting their own workers, the S&W Energy Representative, or designee, shall also monitor the Contractor Worker’s performance through inspections. Frequency of inspections will depend on the period of time that the Contractor is on-site. Inspections should be conducted as practical. They must be conducted for all Contractors who are on-site for more than one week. Inspections shall be documented (a sample Inspection Checklist is provided in this procedure). The Inspection checklist shall be shall be reviewed with Contractor Representative or Supervisor and kept on file. Contractor may request copy of Checklist.

Page 7

Policy No. EHS-501

Contractor Safety

Any discrepancies and assigned corrective actions must be indicated on the Checklist(s). The S&W Energy Representative will follow up to ensure that all corrective actions have been implemented. Violations of the EHS Rules observed by the S&W Energy Representative or another employee shall be documented. The notice will be completed by the S&W Energy Representative and reviewed with the Contractor Supervisor. Safety infractions will be re-evaluated to verify completion of corrective action(s). If there is a dispute about an infraction, the matter will be settled at the Facility or Site Manager’s discretion.

7 Disciplinary Action(s) Any blatant disregard for health and safety issues or repeated violations will require disciplinary action. Disciplinary action may include contract dismissal or work stoppage at the cost to the contract firm. The Facility or Site Manager, or designee, may bar or remove from the Facility or Site any Contractor Worker who violates any law or provision of this procedure, or other S&W Energy procedures, or who otherwise engages in conduct which is likely to cause personal injury, illness or property damage. The Contractor shall not re-assign any barred or removed Contractor Worker to perform work at the Facility or Site without the approval of the Facility or Site Manager, or designee. The Contractor shall be solely responsible for discipline of Contractor Workers.

8 Contractor Injury or Illness / Report of Environmental Accident and Near Misses The Contractor Supervisor is responsible for reporting all EHS Incidents (including any work related injury/illness, near miss, environmental accidents) to the S&W Energy Representative, or Shift Supervisor, as soon as they become known. After reporting the Incident to the S&W Energy Representative, the Contractor Supervisor, in conjunction with the Facility or Site Representative, will complete an EHS Incident Report Form (per S&W Energy procedures) and shall notify the appropriate individuals per the reporting procedure. The original Form shall remain with the Facility or Site and a copy given to the Contractor, if so desired upon request. All EHS Incidents, including near misses, need to be investigated and followed-up. Any corrective actions proposed as a result of Incident shall be tracked until closed (reference S&W Energy’s EHS Incident Reporting procedure).

9 Visitors and Non-Major Contractors All visitors and non-major contractors must sign in and out of the Sign-In Log and adhere to all Facility or Site Environment, Health and Safety rules.

Page 8

Policy No. EHS-501

Contractor Safety

Visitors and non-major contractors are not required to sign the Contractor EHS Rules Form if they will be escorted at all times by a S&W Energy Facility Representative or will remain within office areas for the duration of the visit. If not, they must sign the Form indicating they read and fully understand the rules as posted. Visitors and non-major contractors must wear proper Personal Protective Equipment (PPE), i.e., hard hats, safety glasses, ear plugs in required areas, etc., as warranted by the Facility or Site policies. Safety shoes are also required if exposed to hazards while on-site.

10 Recordkeeping The following Contractor Safety recordkeeping shall be maintained in the Facility or Site EHS Filing System for the period indicated: • • • • • • • •

Contractor Environmental, Health & Safety Rules Form Contractor Bid Solicitation / Qualification Form and Attachments Facility or Site Sign-In Log Contractor EHS Training Tracking Certification Form Daily Contractor Work Permit Contractor Health and Safety Inspection Checklist Record of Contractor Weekly Safety Meetings EHS Incident Report Form (pertaining to Contractor) and supporting documentation

3 years 2 years (updated annually) 1 year (kept up to date) 2 years (updated annually) 1 year 2 years 1 year 3 years

The Contractor Bid Solicitation / Qualification Form and Contractor EHS Training Tracking Certification Form shall be kept up to date and updated annually as part of Contractor re-certification.

11 Training Each Contractor will be required to either provide documentation or certify via the Contractor EHS Training Tracking Certification Form that their employees have been trained on the applicable regulatory requirements and standards, along with the hazards inherent to the nature of their work performed on-site. Contractor Representatives may certify this training for all of their employees. However, this must be indicated on the Certification Form. No individual will be allowed to perform work for S&W Energy as a Contractor unless this training certification is complete and accurate. Each Facility or Site will have the Contractor Workers review and sign the Contractor Environment, Health and Safety Rules Form on that Contractor Worker’s first visit to the site each year. All S&W Energy Facility or Site employees shall be trained on this procedure. Initial Training required only.

Page 9

Policy No. EHS-501

Contractor Safety

12 Auditing / Inspections The Contractor Safety Procedure shall be reviewed annually, including review of records and reports. This procedure will be updated as necessary.

13 References ANSI Standard for Eye and Face Protection (ANSI Z87.1) ANSI Standard for Protective Footwear (ANSI Z41) ANSI Standard for Protective Headgear for Industrial Workers (ANSI Z89.1, ANSI Z89.2) 26 CFR 1910.451

Scaffolding

29 CFR 1910.28

Scaffolding

29 CFR 1910.120

Hazardous Waste Operations and Emergency Response

29 CFR 1910.132 - 140

Personal Protective Equipment

29 CFR 1910.146

Permit-Required Confined Space

29 CFR 1910.147

The Control of Hazardous Energy (Lockout / Tagout)

29 CFR 1910.155-164

Fire Protection

29 CFR 1910.179

Overhead and Gantry Cranes

29 CFR 1910.180

Crawler, Locomotive and Truck Cranes

29 CFR 1910.269

Electric Power Generation, Transmission, and Distribution

29 CFR 1910.333

Electrical Safety

29 CFR 1910.1001

Asbestos

29 CFR 1910.1200

Hazard Communication

29 CFR 1926

OSHA Construction

14 Appendix A (Applicable Forms) 1. 2. 3. 4. 5. 6.

Bid Solicitation / Contractor Qualification Form (2 Pages) Contractor EHS Training Tracking Certification Form Contractor Environment, Health and Safety (EHS) Rules Form (6 pages) Daily Contractor Work Permit Sample Weekly Safety Meeting Form Sample Contractor Inspection Checklist (2 Pages)

Page 10

Environmental Health and Safety Manual Policy No. EHS-502

Policy Title: Control of Hazardous Energy (Lockout/Tagout)

Date: 6/20/2006

Revision: 2

Approval: Richard Wolf

Table of Contents 1 2 3 4

5 6 7 8 9

Purpose and Scope.................................................................................................. 2 Definitions ................................................................................................................ 2 Major Principles........................................................................................................ 5 Procedure ................................................................................................................ 6 4.1 Group Lockout Procedure ................................................................................. 6 4.2 Personal Lockout Procedure........................................................................... 13 4.3 Removal of Authorized Employee Locks and Tags When Off-Site ................. 14 4.4 Lost LOTO Tags ............................................................................................. 14 4.5 Shift Turnover ................................................................................................. 15 4.6 Equipment Specific Lockout / Tagout Procedures .......................................... 15 Contractors ............................................................................................................ 15 Training .................................................................................................................. 16 Auditing / Inspections ............................................................................................. 17 References............................................................................................................. 17 Forms..................................................................................................................... 17

Page 1

Policy No:EHS-502

Control of Hazardous Energy (Lockout/Tagout)

1 Purpose and Scope This procedure defines the minimum requirements for affixing appropriate lockout and tagout (LOTO) devices to de-energize, isolate, or otherwise disable machines or equipment to allow safe maintenance and servicing. Effective hazardous energy control procedures will protect employees during machine and equipment servicing and maintenance where the unexpected energization, start up or release of stored energy could occur and cause injury to employees or possible equipment damage. This procedure and incorporated practices are in compliance with all applicable Federal regulations. Strict adherence to this procedure ensures 100% compliance. The scope of this program applies to all systems, whether mechanical, electrical, pneumatic, or hydraulic and must be strictly adhered to by personnel employed by S&W Energy including all contractors and subcontractors. Upon S&W Energy’s approval, the customer or owner’s LOTO procedure may be substituted for S&W Energy’s policy if it is at least as stringent as S&W Energy’s policy and complies with all applicable regulations. This procedure DOES NOT apply to cord or plug-connected equipment for which exposures to hazards of energization are controlled by plugging / unplugging equipment from an energy source and the plug is under exclusive control of personnel performing the work. In cases where S&W Energy employees work on equipment locked out by others, S&W Energy shall be provided the capability to place their own lockout devices in parallel with those of others.

2

Definitions 1. Affected Employee - An employee whose job requires him/her to operate or use a machine or equipment on which servicing or maintenance is being performed under lockout or tagout, or whose job requires him/her to work in an area in which such servicing or maintenance is being performed. 2. Authorized Employee (AE) - A person who locks and tags out machines, equipment, or systems in order to perform servicing or maintenance on that machine or equipment. This person must complete the mandatory training to be qualified as an Authorized Employee. Only an Authorized Employee installs and removes his or her own locks and tag out devices as required by this program. An Authorized Employee is also any employee whose duties include performing maintenance and or servicing on a LOTO’ed system (including contractors). 3. Authorized Employee Locks - Personal locks used to enhance the safety of Authorized Employees performing servicing and/or maintenance of machines, equipment and/or systems. These locks will not be used for any other purpose. The locks shall be of one standardized color (colored band), different from Supervisor (CLA) and System Operation locks and singularly keyed. Each

Page 2

Policy No:EHS-502

Control of Hazardous Energy (Lockout/Tagout)

Authorized Employee shall retain the keys to individual personal locks. The use of an approved tag with the identity of the person applying the lock is required. 4. Authorized Employee Tags - Personal tags applied with the Authorized Employee’s Lock. The tag reads “Danger - Do Not Operate” and identifies the LOTO number, the tag number, and the Authorized Employee name. These tags will not be used for any other purpose. 5. Clearance – The formal state in which a system / equipment has been shutdown, de-energized, locked out, tagged, and thereby rendered inoperable, thus permitting maintenance and servicing work to safely proceed. No tagged isolation point energy control devices shall be operated while a Clearance is in effect. 6. Clearance and Lockout Authority (CLA) – See definition for Shift Supervisor/Lead Technician. For purposes of this procedure, CLA and shift Supervisor are interchangeable. 7. Device Under Test Tag - A Warning tag utilized for temporary testing of LOTO'ed equipment. The tag reads “Warning – Device Under Test”. 8. Double Block and Bleed - The closure of a line, duct, or pipe by closing and locking or tagging two in-line valves and by opening and locking or tagging a drain or vent valve in the line between the two closed valves. 9. Energy Isolating Device - A device that physically prevents the transmission or release of energy. Examples include circuit breakers, disconnect switches, valves and blank flanges. NOTE: Push buttons, selector switches, and other control circuit type devices are NOT considered energy isolating devices. 10. Lockbox - A container provided for the placement of the System Operation (Clearance) Lock Key(s) for a specific LOTO. The container shall be equipped to handle Authorized Employee locks and tags placed around the top of the container. 11. Lockout Device - A device that utilizes a positive means such as a keyed lock to hold an energy isolating device in a safe position to prevent the energization of a machine, equipment and/or system. Other lockout devices include blank flanges and bolted slip blinds. No combination locks may be used. 12. Lockout/Tagout (LOTO) - The placement of a lockout and tagout device on an energy isolating device, in accordance with this procedure, ensuring that the energy isolating device and the equipment being controlled cannot be operated until the lockout/tagout device is removed. 13. LOTO Control Sheet (LOTO Permit) – A form consisting of Tag Information, Authorized Employee, and Removal of Locks / Tags Information used to identify the current status of the LOTO. 14. LOTO Index - A form kept on file noting the sequential LOTO number, the equipment and scope of work, and the origination and closing dates of all LOTO's. This is a quick reference for open and closed LOTO’s. 15. Maintenance Work Order - An indexed order presented to the Shift Supervisor/Lead Technician by an Authorized Employee or Requestor prior to Page 3

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the initiation of the formal LOTO process. This order will describe in detail the scope of work and will be used to determine if a LOTO is required. 16. Requestor – The individual who originally requests a LOTO Permit for the purpose of performing work on a system or piece of equipment. The Requestor must be an Authorized Employee. 17. Shift Supervisor or Lead Technician (Clearance and Locking Authority, CLA) – An employee, designated by Facility Manager, in a supervisory capacity properly trained in LOTO and qualified to perform LOTO per this procedure and per regulatory requirements (facilities/sites may use varying titles for this position.). Depending on staffing and dual roles, this employee may designate an Authorized Employee to implement portions of this procedure. For purposes of this procedure, Shift Supervisor/Lead Technician and CLA are interchangeable. 18. Site Authorized Employee List – Each Facility or site shall generate a list of individuals authorized to conduct a LOTO. This list typically includes all permanent operations and maintenance employees (essentially all Authorized Employees). Shift Supervisors are usually noted as such on this list. 19. Supervisor Locks or CLA Locks - A set of locks that are specifically designated to be used only as the Lock Box locks. Locks must be a standardized color (colored band) different from Supervisor and System Operations locks and keyed individually (one key for one lock). The keys to Supervisor Locks are to be under the control of the Shift Supervisor / Lead Engineer. Supervisor Locks are not the Authorized Employee personal locks of each Supervisor. 20. System Operator (SO) - The employee designated by the Shift Supervisor/Lead Technician to operate an energy isolating device in order to apply System Operations locks and tags. The System Operator is trained as an Authorized Employee. SO also refers to Systems Operations, a part of the LOTO implemented by the System Operator (interchangeable). 21. System Operations Locks - The locks applied by the System Operator to deenergize equipment, machines and/or systems. These locks are padlocks of a standardized color (colored band) different from the Supervisor (CLA) and Authorized Employee locks. Each LOTO shall utilize padlocks that are either individually keyed or in sets that are commonly keyed. Duplicate keys to all sets of padlocks must be under the control of the Facility or Site Manager. SO locks are also referred to as Clearance Locks. 22. System Operations Tags - The tags applied by the System Operator when applying System Operations Locks to de-energize equipment, machines and/or systems. System Operations tags shall be different in color than the Authorized Employee Tags, read “Danger - Do Not Operate” and shall contain the following information: the LOTO number, the tag number, the date the tag was applied, identification of the individual applying the tag, the name of the energy isolating device, the position of the device and the signature of the Shift Supervisor.

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Control of Hazardous Energy (Lockout/Tagout)

23. Tagout - The placement of a System Operations Tag on an energy isolating device, in accordance with this procedure, ensuring that the energy isolating device and the equipment being controlled cannot be operated until the tagout device is removed. • •

• • • • •

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Tagout will be utilized along with the lockout device. Tags shall contain all of the information as identified, respectively. Tag information shall be written in a language that Authorized Employees working under the LOTO will understand. Pictorials should be included where it is uncertain if employees can clearly understand the significance and purpose of the tag. Tag material shall be substantial so as to prevent inadvertent or accidental removal of the tag. Approved tag materials include rigid vinyl, Seal Tag, or polyethylene plastic (Red Tag Material). Tag shall be attached by a one-piece, all environment tolerant, nylon cable tie or equivalent that is non-reusable, attachable by hand, self-locking, nonreleasable and has an unlocking strength of no less than 50 lbs. Tags shall be affixed such that it is clearly indicated that the operation or movement of the energy-isolating device from the “safe” or “off” position is prohibited. Only when a lock cannot be physically applied to an energy isolating device, can a tag, alone be used. The tag shall be fastened at the same point at which the lock would have been applied. Where a tag cannot be affixed directly to the energy-isolating device, the tag shall be located as close as possible to the device, so that it is immediately obvious to anyone attempting to operate the device.

Major Principles 1. It is mandatory that all persons comply with the restrictions and limitations of this procedure. Failure to follow and comply with this procedure will result in disciplinary action up to and including dismissal. 2. No individual shall attempt to start, energize, or use a piece of equipment that has been locked out and tagged out for servicing and maintenance activities, except as provided for in this procedure. 3. No individual shall attempt to remove a lockout device and tag, except as provided for in this procedure. 4. On all piping systems, double block and bleed shall be used whenever possible. 5. Additional personal protective equipment and special work instructions may be required depending on the hazards present. These requirements shall be reviewed by all employees involved in the job during a pre-job briefing before the start of work. 6. A check valve cannot be used as an energy isolation device. 7. A Systems Operations Tag, alone, can ONLY be utilized when a lockout device cannot be physically applied to an energy-isolating device. Page 5

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Control of Hazardous Energy (Lockout/Tagout)

8. Whenever an outside firm is contracted to work for S&W Energy, the S&W Energy LOTO Procedure shall be used. If the Contractor LOTO Program requires additional or more stringent protection from what this procedure provides, the Shift Supervisor or CLA and the Facility Manager, or their designee, shall develop an interface program acceptable to all parties and fully complies with all OSHA requirements. 9. This procedure does not apply to cord and plug operated equipment when it is unplugged and the plug is maintained within the exclusive control of the person performing work.

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Procedure

This procedure is based on the Group Lockout method, as referenced in and required by regulatory standards. However, under certain circumstances, Personal Lockout may be utilized.

4.1 Group Lockout Procedure Pre-planning of the LOTO shall be conducted by the Shift Supervisor/Lead Technician or the Requestor. When possible the Shift Supervisor/Lead Technician will be assisted by Authorized Employee(s) who know the equipment, machine or system to be LOTO’ed and/or will perform work on the equipment, machine or system to be LOTO’ed. As part of the LOTO planning, all sources of energy and other hazards associated with a machine, equipment or system shall be identified. Potential multiple sources of energy common to a single unit shall be checked. The machine, equipment or system shall be reviewed to identify all energy sources that need to be isolated and locked out. All necessary resources, such as, standard operating procedures, individual employee system knowledge, up-to-date equipment and system drawings, equipment manufacturer’s manuals, shall be used in making that determination. A. Initiating the LOTO All work requiring a Lockout/Tagout is to be reviewed with the Shift Supervisor/Lead Technician by the Authorized Employee. The Authorized Employee shall perform no work on equipment where a possible hazard exists to personnel or equipment without the equipment being properly isolated. A request for Clearance shall be initiated for all work covered by the scope of this procedure. 1. To request a LOTO, a Maintenance Work Order or a LOTO Request must be generated or completed. The Maintenance Work Order or LOTO Request shall indicate the date of the request, the name of the Authorized Employee (Requestor) requesting the LOTO, the machine, equipment and/or system for which the LOTO is requested, and the work to be performed.

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In some cases, one individual may function as both the Shift Supervisor/Lead Technician and a Requestor, depending on title and function.

B. Shift Supervisor/Lead Technician Review of Requested LOTO – Preparation of Systems Operations LOTO 1. The Shift Supervisor/Lead Technician shall review the Maintenance Work Order or Request and decide whether or not to grant the LOTO request. If the LOTO is to be granted, the Shift Supervisor/Lead Technician shall begin filling out the LOTO Control Sheet, first assigning the next number (sequentially) to the LOTO. This shall be documented on the LOTO Index and LOTO Control Sheet. 2. Upon approval of Request for LOTO, the Shift Supervisor/Lead Technician shall input information into the LOTO Index, which includes LOTO number, Date/Time Hung (Date/Time Cleared will be completed after the close of the LOTO), Description of Work, and signature. He/She must also complete the top of LOTO Control Sheet with LOTO number, Date/Time Opened, Equipment Description, Work Scope, and References. 3. The Shift Supervisor shall verify the scope of work for which the LOTO has been requested. This verification should include identification of all potential sources of hazardous energy and the appropriate energy isolation devices (isolation points required). NOTE: Pre-printed LOTO Forms should be developed to expedite Clearances that are frequently used or complicated. 4. The Shift Supervisor/Lead Technician shall designate a System Operator (SO) for the Systems Operations portion of the Group Lockout, as applicable. 5. The Shift Supervisor/Lead Technician shall complete required information for locking out the identified energy isolation points on the LOTO Control Sheet including the lock/tag number, the name and number of the energy isolating device, position of device after lock and tag applied. 6. The Shift Supervisor/Lead Technician, or designee, shall prepare the LOTO Tags and verify they coincide with listing on LOTO Control Sheet. The Shift Supervisor will provide the following information on the tag: the LOTO number, lock and tag number assigned (from LOTO Form), ID of equipment or device, position of device, and signature of Shift Supervisor. The remaining information will be provided by SO upon placement of lockout device.

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Control of Hazardous Energy (Lockout/Tagout)

7. Only after the required information on the LOTO Control Sheet, the LOTO Index and each tag has been completed can lockout/tagout devices be placed onto the energy isolation device. 8. The Shift Supervisor/Lead Technician will notify all affected employees of the machines, equipment or systems to be locked and tagged out for servicing or maintenance. C. Shutdown, Isolation, De-energizing and Placement of LOTO Devices – Systems Operations LOTO 1. Shut identified equipment off by normal operating procedures. 2. All sources of stored energy shall be dissipated. For instance, safely drain any hazardous material from piping or tanks or flush systems. Verify that all sources of stored energy cannot recharge (bleed off valve is open, grounded capacitor, etc.) Drains, vents, relief devices that may allow energy in any form to accumulate must be positioned to prevent such accumulation and then locked. 3. Designated isolation or blocking points such as valves, switches, and circuit breakers shall be operated or moved to specified safe position as indicated on the LOTO Control Sheet. 4. Each system, equipment or machine identified can now undergo LOTO. Each energy isolation point identified on the LOTO Control Sheet shall then be locked out and tagged out using the lockout/tagout device by the designated Systems Operator. 5. The System Operator shall have the original copy of the LOTO Control Sheet in his/her possession. Immediately after a lock and tag device is applied, the System Operator will sign and indicate the date and time on the tag (remaining information on tag completed). 6. The System Operator will also fill in the “Lock / Tag Hung By: Initials & Date” for that tag on the LOTO Control Sheet. D. Application of Systems Operations (Clearance) Locks 1. All isolation points identified on the LOTO Control Sheet shall be secured using Locks and Tags. Every effort shall be made to secure isolation point with a lock. •



When an energy-isolating device is capable of accepting a Lock, the Lock shall be used to secure the device. Assisting devices (i.e., chains, wedges, blocks, adapter, pins, self-locking fasteners, and other hardware) may be used as necessary. When an energy-isolating device cannot accept a Lock, a tag shall be used to secure the equipment. Tags alone shall only be used to secure energy isolating devices that physically cannot accept a Clearance Lock.

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Control of Hazardous Energy (Lockout/Tagout)



Locks shall be installed on the blocking point that provides the most positive isolation of the equipment, regardless of external control devices and remote operators. • Tags shall be utilized in conjunction with each Lock for identification purposes. E. Application of Tags 1. When a machine or piece of equipment is NOT capable of accepting a lock, Tags may be used as sole means for securing it. However, the following conditions must be met: • The Tag shall be located as close as safely possible to the device being tagged out, in a position that is immediately obvious to anyone attempting to operate the device. Examples of Visible Locations of Tag Attachment: Remotely controlled equipment – attached to control switch handles and to device itself. Manually operated equipment – hung on manual operating handle. Equipment within compartments – hung on the compartment door latch or on a screw eye, if provided, over the compartment door lock. Outdoor circuit breakers – hung on the equipment in a prominent location visible to those working on the equipment. Draw-out type circuit breakers – hung on the levering-in device when practical or on the cubicle door for all other cases. • •

The Tag shall be attached to the device being tagged with an approved Tag Attachment. Tag attachment criteria are outlined in Definition section under “Tagout”. Tags shall be attached at all isolation points and at remotely located control elements.

F. Verification 1. The System Operator shall verify the effectiveness of the locking device, by attempting to reposition the device immediately after it is applied. 2. The System Operator shall verify that all sources of stored energy have been dissipated (i.e. bleed-off valve open, etc.). 3. After ensuring that no personnel are exposed, the System Operator shall verify, as directly as possible, the effectiveness of the LOTO by Page 9

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operating the starting controls for the isolated equipment to make certain the equipment will not operate. For work that will expose employees to bare electrical circuits, the circuit must be checked with a multi-meter, or other appropriate equipment, to ensure the circuit is deenergized by an Authorized Employee trained and authorized to use this equipment. RETURN OPERATING CONTROLS TO THE “OFF” POSITION AFTER PERFORMING VERIFICATION TEST NOTE: In cases where the starting controls are operated from the control room, the System Operator shall request the Shift Supervisor/Lead Technician or Control Room Operator to attempt to start the applicable isolated equipment controls while verifying the equipment is in fact isolated. 4. The System Operator shall retain the lock keys or set of keys in his/her possession until he/she has locked and tagged all points designated on the LOTO Control Sheet and verified, as directly as possible, the correctness of the locks and tags. 5. When completed, the System Operator shall report and return the Clearance Lock key(s) and LOTO Control Sheet to the Shift Supervisor/Lead Technician. 6. Once the proper lockout and tagout has been implemented and verified, the Shift Supervisor/Lead Technician shall place the key(s) to the Clearance Locks in the Lockbox and secure the Lockbox with the Supervisor Lock. The key to the Supervisor Lock shall remain under Shift Supervisor/Lead Technician control. 7. The LOTO Control Sheet shall be retained by the Shift Supervisor.

G. Authorized Employee Lockout/Tagout (Work Performed Under Clearance) 1. The Shift Supervisor/Lead Technician, or designee, shall brief all Authorized Employees who will be performing work on the LOTO'ed equipment, machine and/or system. The briefing shall describe hazards associated with the job, work procedures involved, special precautions, energy source controls, and personal protective equipment required. 2. Each Authorized Employee assigned to perform work on the LOTO must sign onto the LOTO Control Sheet. Additional pages may be needed. 3. By signing onto the tagout, the Authorized Employee indicates that he/she as walked down the system and has initialed all tags on the tagout.

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Control of Hazardous Energy (Lockout/Tagout)

4. The Authorized Employee(s) shall walk down the LOTO to visually verify each energy isolation device for the correct device position. The System Operator shall accompany the Authorized Employee on the walk down if he/she is a contractor or is an on-site employee who is unfamiliar with the LOTO'ed machine, equipment and/or system. •

To verify that all energy-isolating devices are in the correct position, each Authorized Employee must initial each LOTO Tag.

NOTE: Each time an Authorized Employee removes his/her lockout device from the lockbox and signs off the LOTO, he/she MUST be offered the opportunity to walk down the LOTO upon re-signing onto the LOTO. 5. Following all AE’s adding their locks and tags and signing onto the LOTO, the Shift Supervisor/Lead Technician shall review the LOTO Control Sheet to ensure all information has been completed. H. Adding Locks and Tags to an Existing LOTO Locks and tags may need to be added to an existing LOTO. The addition of locks and tags must be approved by the Shift Supervisor/Lead Technician. Any locks and tags added to a LOTO become a part of that LOTO. The following steps shall be taken to add locks and tags to an existing LOTO: 1. The Shift Supervisor/Lead Technician will fill-out the LOTO Control Sheet identifying each Lock and Tag to be added to the LOTO. The added locks and tags shall begin with the next sequential number, if possible. 2. The Shift Supervisor/Lead Technician shall fill-out the additional LOTO Tags. 3. The Shift Supervisor/Lead Technician, or designee, will notify any affected persons of the additional devices to be LOTO'ed out of service. I. Temporary Removal of LOTO (Test Release) If it is necessary to temporarily remove LOTO devices for testing equipment, machines or systems the following steps must be taken: 1. The Authorized Employee requiring a test will make a request to the Shift Supervisor/Lead Technician and obtain his approval for the test. 2. The Shift Supervisor/Lead Technician will inform all employees who have signed onto the LOTO and who may be affected by the reenergization of the equipment, machine, and/or system that a test is scheduled to take place and to move to a safe location. 3. The Shift Supervisor/Lead Technician will fill out the Test Release Authorization section of the LOTO Control Sheet including the date

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and time of the test, Authorized By section, and the Authorized Employee requesting the test. If more that one test is required during the duration of the LOTO, annotate the test on the back of the LOTO Control Sheet. 4. Shift Supervisor will then review LOTO Control Sheet with the Authorized Employee requesting the test. 5. The Shift Supervisor/Lead Technician will consult with all Authorized Employees on this LOTO regarding the identified locks and tags. The Authorized Employees must agree that the LOTO’ed device may be operated without danger and that their work will stop while the identified locks and tags are removed. 6. The Authorized Employee shall then remove their lockout device and tag from the lockbox. 7. The Shift Supervisor/Lead Technician, or designee, will walk down the system to verify that the area is clear of personnel and equipment. 8. Energize and proceed with the positioning and testing. 9. At the conclusion of the testing, de-energize the equipment, machine, and/or system and reposition all affected energy isolation devices to their LOTO’ed position. Replace with the LOTO Locks and Tags. 10. Perform verification for those energy isolation points. 11. The test is now complete. Work can commence once again following the steps within this procedure. Each Authorized Employee will be briefed on the status of the LOTO (i.e. test complete, tags rehung) offered the opportunity to walk down the entire LOTO and sign back onto the LOTO. Each Authorized Employee may now apply their lock and tag to the lock box. These Authorized Employees may now restart their work on that equipment. J. Closing the LOTO – Release From Clearance 1. When the work is complete and the Authorized Employee no longer requires a LOTO, they will check the equipment to ensure that all tools and non-essential materials are clear. The Authorized Employee will notify the Shift Supervisor/Lead Technician that he/she is ready to be removed from the LOTO as an Authorized Employee and will apprise the Shift Supervisor/Lead Technician of the status of his/her work and the status of the equipment. 2. The Authorized Employee will complete the “Lock/Tag Removed By” box on the LOTO Control Sheet and indicate that work is complete. The AE shall then remove their lock and tag from the lockbox. 3. When all Authorized Employees have signed off the LOTO, the Shift Supervisor/Lead Technician shall then initiate the closing of the LOTO. 4. The Shift Supervisor/Lead Technician, or designee, will walk down the equipment, machine or system which was under the LOTO, evaluate the safety of the equipment and the completeness of the work, and will Page 12

Policy No:EHS-502

5.

6.

7.

8.

Control of Hazardous Energy (Lockout/Tagout)

check the work area to ensure all persons are clear of the equipment. The Shift Supervisor/Lead Technician shall then remove the Supervisor Lock from the lockbox to obtain LOTO keys. After a lockout device and tag is removed by the System Operator, and the device is returned to the correct operating position, he/she will initial and date the “Lock/Tag Removed By” box for that tag on the LOTO Control Sheet and complete the Cleared Position. The System Operator will return the LOTO Control Sheet and the removed tags to the Shift Supervisor/Lead Technician. After the tags and locks have been removed, they should be checked by the Shift Supervisor/Lead Technician against the LOTO Control Sheet for location and number to verify all the tags are removed and that the removed tags are correct. The Shift Supervisor/Lead Technician will then sign the LOTO Control Sheet “LOTO Clearance Authorized By” section closing the LOTO. The Shift Supervisor/Lead Technician shall fill in the date the LOTO was closed on the LOTO Index. The Shift Supervisor/Lead Technician will notify the Control Room that the LOTO is closed and the equipment is ready for use.

4.2 Personal Lockout Procedure This Section is intended as an alternative to the Group Lockout Procedure. However, all conditions listed below must be satisfied prior to using personal lockout procedure over the group method: • • • • • •

The work scheduled will be completed within the same work shift of the employee performing the work. If there is an indication that the work will extend into another shift, Group Lockout must be used; Personal Lockout applies to S&W Energy employees only. Contractors, temporary employees, vendors, visitors, etc., shall use the Group Lockout method; The equipment has a single energy source which can readily be identified and isolated at one and only one isolation point; A single lockout device will achieve a locked-out condition; The machine or equipment has no potential for stored or residual energy or reaccumulation of stored energy after shut down which could endanger employees; and The work being performed does not create hazards for other employees. 1. Authorized Employee notifies Shift Supervisor/Lead Technician, or designee, what equipment is to be de-energized and isolated and requests a LOTO (Clearance) for Personal Lockout. This can be done verbally. 2. If approved, the Shift Supervisor/ lead Technician, or designee, documents the Personal Lockout on the LOTO Control Sheet and assigns a LOTO Number. Follow the steps outlined in the Group Page 13

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Lockout Procedure, as applicable, EXCEPT instead of AE affixing lock and tag to lockbox, he/she must affix lock and tag to isolation point. An Operations employee will shutdown, isolate, and have the Authorized Employee (person requesting the LOTO) place their personal lock on the equipment isolation point. NOTE: The single job may be assigned to one or more employees. Each employee assigned will put their personal lock on the isolation point. 3. The lockout device shall be applied to achieve Clearance. The lock shall be placed on the blocking point so as to physically secure that point and render it inoperable by any means short of destroying the lock. 4. Following placement of lock, a representative from Operations shall attempt to start the equipment. If equipment does not start, work may then proceed on the equipment. Temporary Removal of LOTO (Test Release) and Closing the LOTO shall be the same as in Group Lockout (AE’s will be removing lock and tag from isolation point instead of lockbox).

4.3 Removal of Authorized Employee Locks and Tags When Off-Site There may be times when the LOTO needs to be closed to put the equipment back into service when an Authorized Employee still on the LOTO is off-site and cannot be located. In this case, the following steps will be followed to allow closing of the LOTO. 1. The Shift Supervisor/Lead Technician will attempt to reach the Authorized Employee to determine if the LOTO may be closed. If the Authorized Employee indicates that the LOTO may be closed the Authorized Employee must return to the site to follow the normal Clearance procedures. 2. If the Authorized Employee cannot be contacted or cannot reasonably return to the site the Shift Supervisor/Lead Technician may sign the LOTO Control Sheet to authorize the removal of the Authorized Employee from the LOTO.

4.4 Lost LOTO Tags In the event that a tag for a device or piece of equipment which is LOTO’ed is lost, the following must be done: 1. If a LOTO tag is found not attached to a device or if a device which should be LOTO’ed does not have a tag, the Shift Supervisor/Lead Technician must be notified.

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2. If the tag is found, the Shift Supervisor/Lead Technician will verify the location and number of the tag with the LOTO Control Sheet and have it re-hung. 3. If the lost tag cannot be found, a Shift Supervisor/Lead Technician will issue a new tag for that device using a new tag number. The Shift Supervisor will note “Tag Lost” in the LOTO Control Sheet and indicate the number of the replacement tag. 4. If the LOTO was to be closed when the tag was discovered missing, any remaining tags and locks will be removed and “Tag Lost” will be written in the LOTO Control Sheet.

4.5 Shift Turnover 1. As part of shift turnover, oncoming and off-going Shift Supervisors must review the LOTO Index Sheets to determine the status of all active LOTO’s. 2. Upon turnover, the responsibility for active LOTO’s is automatically transferred to the oncoming Shift Supervisor, including custody of any System Operations Lock and Supervisor’s Lock keys.

4.6 Equipment Specific Lockout / Tagout Procedures 1. Each S&W Energy Facility or Site must develop Equipment Specific LOTO Procedures (ESLPs) for all major equipment, machines, and/or systems at their facility. 2. Each ESLP will contain the following elements: • • • • • • • •

5

Preparation for Shutdown; Machine or Equipment Shutdown; Machine or Equipment Isolation; Lock-out / Tag-out Device Application; Stored Energy Dissipation; Verification of Isolation; Release from LOTO; Additional measures for Outside Contractors, as needed.

Contractors 1. Contractors of S&W Energy must adhere to the S&W Energy LOTO procedure to perform Lockout / Tagout. Prior to performing work, the contractor will review the S&W Energy LOTO Procedure to ensure they understand and are able to comply with all of its requirements. 2. All outside contractors must be properly trained (i.e., completed the proper regulatory compliance training of LOTO) before being allowed to perform LOTO.

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3. Contractors shall not be permitted to request Clearances in their own name. All LOTO requests shall be initiated on the Contractor’s behalf by a designated employee (Contractor Supervisor) identified as such prior to commencement of work. These individuals should be added to the Requestor List for that Contractor. 4. Each Contractor shall have his/her own Personal Safety Lock, clearly labeled and numbered. 5. The Shift Supervisor shall be provided with a means of determining the identity of the worker affixing the lock and tag, by the lock label or number.

6

Training Training shall be provided to ensure that the LOTO Procedure is understood by all Authorized Employees at a Facility or Site or Field Service Job and that all Authorized Employees have the knowledge and skills required for safe application, usage, and removal of energy controls. Each employee shall receive training that includes the following: 1. Recognition of applicable hazardous energy sources, the type and magnitude of energy sources within the work place, and the means and methods of isolation and control. 2. The purpose, scope, and function of the LOTO Program and procedure. 3. The limitations of tags, including the following principles: •

Tags are primarily warning devices attached to energy isolating devices and do not provide the physical restraint that a lock will provide;



When a tag is attached to an energy-isolating device, it is to be removed only by the authorized person responsible for it, unless provided for under the procedures set forth in Section 4.3. Otherwise, it is never to be bypassed, ignored, or otherwise defeated; Tags shall be legible and understandable by all authorized employees, affected employees, and all other employees whose work operations are or may be in the area in order to be effective; Tags shall conform to regulatory specifications, as outlined in this procedure; and Tags shall be securely attached to energy isolating devices so they cannot be inadvertently or accidentally detached during use.

• • •

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4. Employees shall be retrained whenever they change job assignments; machines, equipment, or processes change that present a new hazard; or there is a change in the policy or regulation. 5. Retraining shall be conducted when results of the annual inspection reveal deviations from the Program. 6. All other employees whose work operations are or may be in an area where the Program may be used, shall be instructed about the procedures and about the prohibition relating to attempts to re-start or re-energize machines or equipment which are locked out or tagged out. 7. Training records shall be maintained, including the employee names and dates of training and made readily available upon request.

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Auditing / Inspections 1. An annual inspection of the LOTO Program shall be conducted to ensure that the Program and the regulatory requirements are being followed. The inspection shall be: • Conducted to correct any deviations from the Program; • Scheduled by Site or Facility Manager and conducted by Shift Supervisor/Lead Technician or another qualified independent source; • Include a review between Headquarters Operation and each Authorized Employee of their responsibilities under the Program ; and • Be recorded and maintained on file, identifying the machines and equipment where Program was utilized, date of inspection, employees involved in inspection, and name of Inspector. 2. A random sample of the LOTO paperwork should be reviewed to note any discrepancies or deviations from the Program. 3. If during the inspection a discrepancy or procedural inadequacy is found, steps shall be taken immediately to determine the reason for, and the corrective action necessary to remedy the discrepancy. 4. A sample Audit Inspection Form is supplied to assist in this annual requirement.

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References 29 CFR 1910.147

Control of Hazardous Energy (Lock Out/Tag Out)

29 CFR 1910.269

Electric Power Generation, Transmission, and Distribution

Forms See Appendix K

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K.1 LOTO Index K.2 Facility Authorized Personnel List K.3 Annual LOTO Audit / Inspection Form K.4 LOTO Control Form

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Environmental Health and Safety Manual Policy No. EHS-503

Policy Title: Personal Protective Equipment (PPE)

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2 3 4 5 6 7 8

Purpose and Scope.................................................................................................. 2 Definitions ................................................................................................................ 2 Procedure ................................................................................................................ 2 PPE Requirements................................................................................................... 4 Training .................................................................................................................... 8 Auditing / Inspections ............................................................................................... 8 References............................................................................................................... 8 Forms....................................................................................................................... 8

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Policy No:EHS-503

Personal Protective Equipment (PPE)

1 Purpose and Scope The purpose of this procedure is to minimize and control the exposure to hazards and the potential for injury through the proper selection and use of personal protective equipment (PPE). It also provides guidance on performing hazard assessments and generating job safety analyses (JSAs) for specific types of jobs.

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3

Definitions •

Hazard Assessment – A documented analysis performed on each job task or operation to determine all possible hazards of performing that job. Based on the hazards determined, precautions must be taken to minimize those hazards and ensure safety (proper PPE, procedures, etc.)



Job Safety Analysis (JSA) – A method for studying a job in order to identify hazards or potential accidents associated with each step or task of a job and for developing solutions or preventative measures that will eliminate, nullify, or prevent such hazards or accidents. This documented analysis should include personal protective equipment, based on the hazards identified, for the employee’s job function and responsibilities.



Program Administrator – For purposes of this procedure, an individual suitably trained, designated by the employer (Facility or Site Manager) to administer the requirements of Hazard Assessments and JSAs.

Procedure A. PPE Inventory Each Facility or Site must inventory all PPE that is currently in use or in stock at the Facility. Record the type, style, make, part number and size of PPE, as available. The sample PPE Inventory Form in this procedure may be used to record all available data. • •

The Facility or Site Manager, or designee shall delegate a Program Administrator to distribute and control access to the PPE in the inventory. The inventory shall be conducted annually or when stock is low.

B. Hazard Assessment A Hazard Assessment of all job tasks performed in the workplace shall be conducted. The Hazard Assessment shall be used to develop Job Safety Analyses, which include appropriate PPE requirements identified in Hazard Assessment. Every employee should have a JSA for his/her type of job or job duties. In the Attachment Section of this procedure there is a list of SOME jobs that, as a minimum, require hazard assessments. The list is not a complete list but contains some of the more typical jobs / tasks involved in power plant operations.

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Policy No:EHS-503

Personal Protective Equipment (PPE)

The Hazard Assessment shall be conducted with a thorough examination of the actual job tasks that employee is responsible for and performs. It must identify the possible hazards encountered in performing the task and identify the safety precautions necessary to eliminate the hazard, along with the PPE required when performing the task. Employees who actually perform the job tasks being evaluated shall conduct the Hazard Assessment. These individuals know the work process and are most familiar with and sensitive to the actual and potential hazards of the job. Hazard Assessments shall be conducted on a priority basis. Job tasks that meet any of the following criteria should be evaluated first: • • • •

Any job task which has resulted in an injury or accident; Job tasks with the potential for chemical exposure (loading / unloading, transferring totes); Job tasks with the potential for electrical exposure; and/or Job tasks with the potential for physical exposure (high noise, heat, vibration, etc.).

In conducting the Hazard Assessments, each job task shall be evaluated for the following types of hazards: • • • • • • • • • • •

Chemical (inhalation, ingestion and skin contact with dust, fumes, mists, gases, vapors or liquids); Electrical; Physical (heat, noise, vibration); Ergonomic stressors (repetitive motion, lifting, awkward postures); Falling/moving/flying objects; Radiation; Lasers, infrared and ultraviolet light; Biological; Other (potential for falls, fire, explosion, pinching); Need for control measures (machine guarding, ventilation, isolation, worker rotation, lifting devices and tool designs) to do the job safely; or Need to follow procedures (LOTO, Confined Space Entry etc.).

Any previous noise monitoring surveys or air monitoring results shall be incorporated and made part of hazard assessment. The Hazard Assessment Form provided in this procedure may be utilized to list the steps required to perform the job task, the potential hazards associated with each step, the safety precautions to take to eliminate the hazards and the PPE required to be worn to perform the job task. The Hazard Assessment Form shall be reviewed initially, upon completion, to verify the assessment was conducted properly, and reviewed periodically thereafter. It must be signed by the Facility Manager (certification) upon completion and review. Page 3

Policy No:EHS-503

Personal Protective Equipment (PPE)

Should any safety deficiency be identified while conducting the Hazard Assessment, the deficiency shall be corrected immediately. At the least, safety deficiencies shall be treated as an audit finding and shall be tracked to closure as soon as possible. A list of jobs requiring hazard assessments is provided in the Attachment Section of this procedure. Should a particular job task change, it must be reviewed by the EHS Engineer, Safety Coordinator, or designee, at the Site (if applicable) for any process changes that may impact environmental, health or safety issues. If there is no EHS Engineer at the Site, duty shall be conducted by the Facility or Site Manager, or designee. Should an injury/accident occur while performing a job task, the Hazard Assessment and JSA shall be reviewed as part of the incident investigation. It should be determined whether or not the JSA was properly adhered to or if it needs revision. C. Link of PPE Inventory and the Hazard Assessments Upon completion of the PPE Inventory and the Hazard Assessments, the Program Administrator delegated must verify that the PPE on-site covers the PPE required to perform the job tasks evaluated for the Hazard Assessments. The PPE identified must be of the appropriate type as identified by the individual Hazard Assessments. PPE must also be stocked in sufficient quantities and sizes to meet the needs of the Facility or Site. The Hazard Assessment Form must then be filed in a location easily and readily accessible to all employees and anyone else requesting to review it.

4

PPE Requirements

The following section provides the minimum requirements to protect against hazards identified at any S&W Energy Facility or Site: A. Eye and Face Protection – Safety Glasses Only approved safety glasses that meet regulatory (i.e., OSHA) and ANSI requirements shall be worn by site employees. The frames shall be plastic and the lenses shall be impact resistant. Side shields are required. Safety glasses shall be imprinted with Z87.1 to illustrate the glasses meet the regulatory and ANSI standard. Employees who wear prescription glasses shall wear safety glasses that incorporate their prescription into the lens or shall wear protection over their prescription glasses. Over protection shall be plastic and impact resistant and shall display the Z87.1 stamp. For protection from bright sunlight or injurious light radiation, safety glasses with filter lenses with a shade number appropriate for the work being performed shall be worn. Page 4

Policy No:EHS-503

Personal Protective Equipment (PPE)

Contact lenses shall not be worn if an employee’s job involves any of the following: •

Working with chemicals including, but not limited to, fumes, vapors, mists, solvents, and particulate matter (i.e. fiberglass); Welding, soldering, brazing, cutting and grinding; and Working in dusty environments.

• • • B. Head Protection

Site employees shall wear hard hats at all times while at the Facility or Site except in designated areas (i.e. office areas, control room, locker room) where a hazard is present. Hard hats shall conform to ANSI Standard Z89.1 for protection from falling or flying objects. When protection from possible electrical shock is required, the hard hat shall conform to ANSI Standard Z89.2. Objects will not be carried inside the helmet, as proper clearance is needed for the protective system to be effective. Hard hat suspension systems should be replaced when needed. All hard hats shall be replaced every two to five years, or when the hard hat displays physical damage (cut, dented etc.) that would compromise the integrity of the hard hat protection. C. Foot Protection Hard or Steel toe, leather upper, ANSI approved (meeting ANSI Z41) safety shoes with rubber soles are required for all site employees other than those personnel who work solely in administrative areas. When working with and loading / unloading chemicals (i.e., ammonia), the use of rubber boots compatible with those chemicals is required. The following PPE is required WHEN DETERMINED by Hazard Assessments: D. Splash Hazard Present – Eye Protection Chemical Goggles - All chemical goggles shall meet regulatory requirements. The lens shall be impact resistant. Ventilation buttons should be located on top of the goggles. Chemical goggles shall be labeled as evidence as meeting regulatory or ANSI requirements. Face Shields - Only face shields that meet regulatory requirements shall be worn by employees. Face shields shall be labeled as evidence of meeting regulatory or ANSI requirements. Both chemical goggles and face shields shall be worn when working with or loading / unloading chemicals such as ammonia, sulfuric acid, caustic etc.

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Policy No:EHS-503

Personal Protective Equipment (PPE)

A standard sign: “CAUTION, EYE HAZARD AREA, DO NOT ENTER WITHOUT EYE PROTECTION” or its equivalent, must be posted in every area where eye protection is mandatory. All employees, Contractor Workers, and visitors entering such an area must wear the required eye protection. E. Body Protection For chemical handling (including loading / unloading), employees shall wear a complete chemical suit including jacket and bib overalls, plastic or rubberized apron, rubber gloves, chemical resistant boots, chemical goggles and face shield. For welding, employees shall wear a leather vest, gloves, flame resistant clothing and a helmet/face shield with appropriate lenses. For working on energized equipment or open flames, employees shall wear, flame resistant clothing and insulated gloves. For material handling, employees shall wear, at the minimum, general-purpose gloves. Other body protection may be required depending on the type of material being handled. F. Hand Protection Appropriate hand protection shall be worn when an employee’s hands are exposed to hazards, such as those from skin absorption of harmful substances; severe cuts, abrasions or lacerations; punctures; chemical burns; or thermal burns. Employees must take into consideration when selecting hand protection, the tasks to be performed, duration of use, and the actual or potential hazards to which they may be exposed. Work gloves should be worn whenever possible, except when wearing the gloves would create a hazard such as in the vicinity of moving parts. Rubber gloves must be worn when acids and caustics are handled. Rubber gloves are also necessary in certain situations involving electrical work. Insulated or heat resistant gloves must be worn when handling steam hose or when performing other duties in which regular work gloves do not afford adequate protection against burning of the hands. Leather or leather-palm gloves should always be worn when handling wire rope. Gloves should be worn when the hands are wet from any substance causing a slippery grip.

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Policy No:EHS-503

Personal Protective Equipment (PPE)

G. Hearing Protection Employees shall wear approved hearing protection when exposed to noise levels greater than 85 dB and/or where mandatory hearing signs are displayed. Reference Hearing Protection and Conservation procedure for further hearing protection requirements. H. Fall Protection Employees shall wear an approved full body safety harness with shock absorbing lanyard when work involves climbing or working 4 feet (1.2 m) or more above a lower level. All safety harnesses should be 100% synthetic fiber webbing. Leather buckles, straps, attachment points, etc. are not acceptable. All snap hooks must be of the locking type. Body belts and non-locking snap hooks are not acceptable as part of a personal fall arrest system. The harness shall fit snugly, be properly adjusted, and buckled. The wearer shall allow no more slack in the lanyard than is necessary. All safety harnesses should be regularly inspected for excessive wear or damage that could cause them to fail. Harnesses with visible wear or damage should be destroyed, not discarded. Safety harnesses must not be subjected to treatment that could damage or weaken them. Full body safety harness with lifeline will be used by each entrant when working in confined spaces. I. Respiratory Protection Employees shall use approved respirators for all designated job tasks requiring respiratory protection. Reference the Respiratory Protection procedure for further respiratory protection requirements.

PPE should not be the sole method of hazard exposure control. Administrative tools, engineering controls, and equipment safeguards should be considered.

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Policy No:EHS-503

5

Personal Protective Equipment (PPE)

Training

All S&W Energy Facility or Site employees (including Field personnel) shall be trained on the requirements and guidelines of this procedure initially, upon hire. The training shall include: • • • • • •

Content and importance of JSA and Hazard Assessment requirements; When PPE is necessary; What PPE is necessary: The proper donning, adjustment and wear of PPE; The limitations of PPE; and The proper care, maintenance, and useful life and disposal of PPE.

The Facility or Site shall ensure that each affected employee demonstrates that he/she understands the requirements of this procedure before being allowed to work in areas where PPE is required. If there is any change in the hazard or PPE identified for certain tasks or jobs, the JSA shall be reviewed, amended, and employee retrained to ensure he/she understands the new hazard and PPE required. Refresher training is required every 3 years, if not given more frequently due to changes.

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Auditing / Inspections

The PPE & JSA Procedure shall be reviewed every 2 years. Documented training records, Hazard Assessments, and updated JSAs may be reviewed as part of this inspection or audit. This procedure will be updated as necessary.

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References • • • •

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29 CFR 1910.132 to 1910.140 PPE Requirements ANSI Standard for Eye and Face Protection (ANSI Z87.1) ANSI Standard for Protective Footwear (ANSI Z41) ANSI Standard for Protective Headgear for Industrial Workers (ANSI Z89.1, or Z89.2)

Forms

See Appendix L • •

L.1 - Personal Protective Equipment Inventory L.2 - Hazard Assessment Form

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Environmental Health and Safety Manual Policy No. EHS-504

Policy Title: Respiratory Protection

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2 3 4 5 6 7 8 9 10 11 12 13

Purpose and Scope.................................................................................................. 2 Definitions ................................................................................................................ 2 General .................................................................................................................... 3 Job & Area Hazard Assessment / Selection of Respirator ....................................... 4 Medical Evaluations ................................................................................................. 7 Fit Testing ................................................................................................................ 8 Maintenance and Care............................................................................................. 9 Contractors ............................................................................................................ 11 Recordkeeping ....................................................................................................... 11 Training .............................................................................................................. 11 Auditing / Inspections ......................................................................................... 12 References ......................................................................................................... 12 Forms ................................................................................................................. 12

Page 1

Policy No:EHS-504

Respiratory Protection

1 Purpose and Scope The purpose of this procedure is to define the proper selection and use of respiratory protection equipment, to provide guidance for medical evaluations for those employees who must wear respirators, to outline the requirements that ensure proper maintenance and care of respiratory equipment, and to define required training of employees in regards to respiratory standards. A respiratory program shall be implemented in order to prevent excessive exposure of employees to occupational dusts, fumes, mists, gases and vapors. This procedure and its requirements meet all regulatory obligations for Respiratory Protection.

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Definitions • • • • • • • • • • • •

Air Purifying Respirator - A respirator with an air purifying filter, cartridge, or canister that removes specific air contaminants by passing ambient air through the air-purifying element. Canister (or Cartridge) – A container with a filter, sorbent, or catalyst, or combination of these items, which removes specific contaminants from the air passed through the container. Emergency Situation - Any occurrence such as, but not limited to, equipment failure, rupture of containers, or failure of control equipment that may or does result in an uncontrolled significant release of an airborne contaminant. Employee Exposure – Exposure to a concentration of an airborne contaminant that would occur if the employee were not using respiratory protection. End-of-Service-Life indicator (ESLI) - A system that warns the respirator user of the approach of the end of adequate respiratory protection, for example, that the cartridge is approaching saturation or is no longer effective. Fit Factor – A quantitative estimate of the fit of a particular respirator to a specific individual. Fit Test – The use of a protocol to qualitatively or quantitatively evaluate the fit of a respirator on an individual. Immediately Dangerous to Life or Health (IDLH) - An atmosphere that poses an immediate threat to life, would cause irreversible adverse health effects, or would impair an individual’s ability to escape from a dangerous atmosphere. Negative Pressure Respirator – A respirator in which the air pressure inside the face piece is negative during inhalation with respect to the ambient air pressure outside the respirator. NIOSH – National Institute for Occupational Safety and Health. Oxygen Deficient Atmosphere - An atmosphere with oxygen content below 19.5% by volume. PLHCP – Physician or other Licensed Health Care Professional; individual whose legally permitted scope of practice allows him/her to independently provide or be delegated the responsibility to provide some, or all, of the health care services required under this Program (i.e.; respiratory protection).

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Policy No:EHS-504



Positive Pressure Respirator - A respirator in which the pressure inside the respiratory inlet covering exceeds the ambient air pressure outside the respirator. Pressure Demand Respirator - A positive pressure atmosphere-supplying respirator that admits breathing air to the face piece when the positive pressure is reduced inside the face piece by inhalation. Program Administrator – An individual suitably trained, designated by the employer to administer the requirements of this procedure and its elements. Qualitative Fit Test - A pass/fail fit test to assess the adequacy of respirator fit that relies on the individual's response to the test agent. Quantitative Fit Test - An assessment of the adequacy of respirator fit by numerically measuring the amount of leakage into the respirator. Self-Contained Breathing Apparatus (SCBA) - An atmosphere-supplying respirator for which the breathing air source is designed to be carried by the user. Service Life – The period of time that a respirator, filter or sorbent, or other respiratory equipment provides adequate protection to the wearer. Supplied-Air Respirator (SAR) - An atmosphere-supplying respirator for which the source of breathing air is not designed to be carried by the user. Tight-Fitting Face piece – A respiratory inlet covering that forms a complete seal with the face. User Seal Check – An action conducted by the respirator user to determine if the respirator is properly sealed to the face.

• • • • • • • • •

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Respiratory Protection

General

The Facility or Site must develop and implement a written respiratory protection program per regulatory standards which includes required work-specific procedures for required use of respiratory protection. This procedure meets the requirements of these standards. The Facility Manager or Lead Supervisor must appoint an individual (referenced as Program Administrator), or team, to administer or oversee the respiratory protection program and conduct the required evaluations of program effectiveness. The Program Administrator shall be selected based on his/her knowledge of the respiratory hazards at the workplace and the requirements of the respiratory protection standard. The respiratory protection program must include the following provisions: • • • • •

Procedures for selecting respirators; Medical evaluations of employees required to use respirators; Fit testing procedures; Procedures for proper use of respirators in routine and reasonably foreseeable emergency situations; Procedures and schedules for cleaning, disinfecting, storing, inspecting, repairing, discarding, and otherwise maintaining respirators;

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Policy No:EHS-504

• • • •

Respiratory Protection

Procedures to ensure adequate air quality, quantity, and flow of breathing air for atmosphere-supplying respirators; Training of employees in the respiratory hazards to which they are potentially exposed during routine and emergency situations; Training of employees in the proper use of respirators, including putting on and removing them, any limitations on their use, and their maintenance; and Procedures for regularly evaluating the effectiveness of the program.

Respiratory Protection will be properly used where administrative or engineering controls fail to reduce air contaminants to within regulatory prescribed limits. It shall NOT be used as a substitute for accepted engineering control measures against air contaminants.

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Job & Area Hazard Assessment / Selection of Respirator A. Respiratory Protection Hazard Assessment The Facility or Site shall select and provide an appropriate respirator based on the respiratory hazards to which the worker is exposed and workplace and user factors that affect respirator performance and reliability. Respiratory hazards must be evaluated throughout the workplace environment to identify relevant conditions and user factors and base selection on these factors. All respiratory hazard(s) in the workplace shall be identified and evaluated as part of a Hazard Assessment process. This Hazard Assessment process is the same process and can be substituted for the process identified in generating Job Safety Analyses (JSA) for employees (an additional EHS procedure). NOTE: JSAs are required by regulation. As hazards are identified per job, the proper personal protective equipment, which may include respiratory protection, is identified. For each job task for which a Hazard Assessment is conducted, a reasonable estimate of employee exposures to respiratory hazard(s) and an identification of the contaminant’s chemical state and physical form shall be determined. Where the employee’s exposure during performance of the job task cannot be identified or reasonably estimated, an IDLH atmosphere will be assumed. Air monitoring is the recommended method to establish employee exposure. The Facility or Site shall determine the routine tasks that could result in personnel exposure to an atmosphere that is, or could rapidly become, hazardous. For example, tasks could include spray painting and the handling of ammonia, acids and caustics, etc.

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Policy No:EHS-504

Respiratory Protection

The Facility or Site shall determine those areas where an oxygen deficient atmosphere exists or could develop. These areas shall be considered IDLH atmospheres. The Facility or Site shall evaluate the nature of emergency response at their locale. The Facility or Site shall indicate whether respiratory protection shall be utilized for emergency response efforts or for escape only. B. Selecting a Respirator The Facility or Site shall provide a variety of respirator choices to ensure that each employee required to wear a respirator can obtain an acceptable fit. Only respirators approved by NIOSH shall be purchased and worn. Information to be considered in selecting the type of respirator to be used includes: •

Estimated or actual contaminant concentration where the respirator will be used; • Characteristics and limitations of available respirators; • Regulatory-published Permissible Exposure Limits, Threshold Limit Values, or NIOSH Recommended Exposure Limit; • Nature of contaminant: gas, vapor, or particulate; • Could the contaminant concentration become immediately dangerous to life or health; • If the contaminant is flammable, does the estimated or actual concentration approach the lower explosive limit; • Does the contaminant have adequate warning properties (i.e. odor); • Is the contaminant an eye irritant; • If the contaminant is a gas or vapor, is there an available cartridge that traps it efficiently and safely; • Can the contaminant be absorbed through the skin; • The Respirator Specification Form in the Attachment Section shall be utilized to document the type of respiratory protection required for the specific hazard present. C. Respirator Requirements for Routine Tasks For protection against gases and vapors, a full or half-face atmosphere supplying or air-purifying respirator (cartridge or canister type) must be utilized. A separate respirator must be purchased and maintained for each site employee that uses a respirator on a routine basis. Air-purifying respirators (cartridge or canister type) have limitations to the concentration for which a particular cartridge/canister can be used. Therefore, the respirator shall be equipped with an end-of-service-life indicator (ESLI) certified by NIOSH for the contaminant.

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Policy No:EHS-504

Respiratory Protection

If there is no ESLI appropriate for conditions at the Facility or Site, a changeout schedule for canisters and cartridges shall be implemented that is based on objective information or data that will ensure that canisters and cartridges are changed before the end of their service life. The Facility shall describe the information and data relied upon, the basis for the canister and cartridge change-out schedule and the basis for reliance on the data. For more information on establishing a facility cartridge change-out schedule, see the Guidance on the Development of a Cartridge Change-Out Schedule and the Respirator Cartridge Selection Chart in the Attachment Section of this procedure. For protection against particulates, an atmosphere supplying respirator or an air purifying respirator equipped with a filter certified by NIOSH, as a high efficiency particulate air (HEPA) filter, or an air-purifying respirator equipped with a filter certified for particulates by NIOSH under, shall be utilized. See Guidance on the Development of a Cartridge Change-Out Schedule for reference to a list of respirators approved by NIOSH. D. Respirator Requirements for IDLH Atmospheres Facility or Site employees are prohibited to enter IDLH atmospheres EXCEPT when necessary for response to emergency situations. If entry to an IDLH atmosphere is necessary, the following requirements must be met: •

Employees in an IDLH atmosphere shall use a full-face pressure demand SCBA certified by NIOSH for a minimum service life of thirty (30) minutes or a combination full face pressure demand supplied-air respirator (SAR) with auxiliary self-contained air supply. • One employee at a minimum or, when needed, more than one employee will be located outside the IDLH atmosphere when entry into that IDLH atmosphere is necessary. • Visual, voice, or signal line communication will be maintained between the employees inside the IDLH atmosphere and the employee located outside the IDLH atmosphere at all times. • Employees outside the IDLH atmosphere shall be equipped with pressure demand or other positive pressure SCBA's or SAR with auxiliary SCBA and appropriate retrieval equipment for removing the employee(s) who enter the IDLH atmosphere. E. Respirator Requirements for Emergency Situations When responding to emergency situations, air supplying-type respirators [i.e. Self-Contained Breathing Apparatus (SCBA)] must be used. For those Facilities that have the potential requirement for use of respirators during an “Emergency Response”, a minimum of two SCBA’s must be purchased and maintained on-site for emergency response situations. Respirators provided for escape only shall be NIOSH-certified for escape from the atmosphere in which they will be used.

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Policy No:EHS-504

Respiratory Protection

If the Facility provides supplied-air and/or SCBA type respirators, the Facility must confirm with the manufacturer of the compressed air, compressed oxygen, liquid air, and/or liquid oxygen that the breathing gas meets all requirements under applicable regulatory standards.

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Medical Evaluations

This Section specifies the minimum requirements for medical evaluation that must be implemented to determine an employee’s ability to use a respirator. The Facility or Site shall identify a physician of licensed health care professional (PLHCP) to perform medical evaluations using a medical questionnaire or equivalent medical examination. The PLHCP shall use a Medical Evaluation Questionnaire (example provided in Attachment Section) or a similar form that includes all of the information provided in the example in performing the medical exam. The medical exam and the questionnaire shall be kept confidential and filed in the employee’s personnel file. Annually, a PLHCP will perform a medical evaluation to determine that all employees required to wear respirators are medically fit to wear the respirator. Pulmonary function tests will be included in the employee’s medical evaluation. The Facility or Site must provide the PLHCP with a copy of this procedure, a copy of the regulatory standard and the following information prior to the employee’s medical exam: • • • • •

Type and weight of the respirator to be used; Duration and frequency of respirator use; Expected physical work effort; Additional personal clothing and equipment to be worn; and Temperature and humidity extremes that may be encountered.

This information, and any other supplied prior to the medical evaluation, need not be provided for subsequent evaluations if the information has not changed. If an employee refuses a medical evaluation/exam, they cannot work in an atmosphere that requires the use of a respirator. Employees shall not be assigned to tasks requiring the use of respirators unless they have been medically evaluated, fit tested (discussed in next section), and trained on the use and care of their respirator. Following the exam, the PLHCP will provide the Facility with a recommendation regarding the employee’s ability to use a respirator. The Respirator Clearance Evaluation, Examiner’s Written Opinion Form in the Attachment Section can be utilized but at a minimum the recommendation shall include: •

Any limitations on respirator use related to the medical condition of the employee including if the employee is not medically able to use the respirator; Page 7

Policy No:EHS-504





Respiratory Protection

The need for follow-up exams: A follow-up exam is required when an employee provides a positive response to any question among questions 1-8 in Section 2 of the sample Medical Evaluation Questionnaire provided in this procedure; and A statement that the employee was provided with a copy of the physician’s or licensed health care professional’s recommendations.

The PLHCP’s recommendation shall be maintained in the employee’s personnel file. Other than annual evaluations, more frequent medical examinations regarding respirator use shall be administered under the following scenarios: • • •

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An employee reports medical signs or symptoms that are related to the ability to use a respirator; The health care professional administering the program informs the employer that the employee needs to be reevaluated; or A change occurs in the conditions that may result in a substantial increase in the physiological burden placed on the employee.

Fit Testing Each employee required to wear a respirator shall be either qualitatively or quantitatively fit tested with the same make, model, style and size of respirator that the employee will use. The Fit Test Protocol in the Attachment Section of this procedure shall be utilized. Whenever possible, the respirator manufacturer’s representative shall provide employee initial and annual fit testing. Employees trained by the manufacturer’s representative are also qualified to perform fit testing of Facility personnel. Fit testing for all employees required to wear a respirator shall be performed in a test environment at the time of initial fitting, whenever a different respirator face piece (size, style, model, or make) is used, and at least annually thereafter. The isoamyl acetate procedure shall be used as the preferred qualitative fit test method. Irritant smoke shall be used as an alternate method. Fit test results shall be documented, including the date, name of the tester, type of test, test results, employee name, and name and model number of the respirator which was found to fit properly. See Attachment Section for the documentation form. Employees shall perform field qualitative fit checks and field inspection prior to entering a contaminated atmosphere. Field Qualitative fit checks shall consist of the following checks: •

Positive pressure check: Close exhalation valve with palm. Breathe into mask. Fit is satisfactory if some pressure can be built up inside mask without any leakage.

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Respiratory Protection

Negative pressure check: Close off the inlet openings of the cartridge with palms. Inhale gently so that a vacuum occurs within the face piece, and hold breath for 10 seconds. If no inward leakage is detected, then the respirator seal is good.

The Facility or Site shall prohibit employees to wear a respirator when conditions prevent a good seal of the respirator face piece to the face. This may include: Facial hair that comes between the sealing surface of the face piece and the face or that interferes with valve function; Temple pieces on glasses, goggles or other personal protective equipment. Absence of one or more dentures. Site employees shall notify the Facility Manager or Supervisor if there is any reason why the fit of their respirator may be compromised. An additional fit test shall be conducted whenever the employee reports or the Facility Manager, a Supervisor or any employee makes a visual observation of changes in an employee’s physical condition that could affect respirator fit. Such conditions include, facial scarring, dental changes, cosmetic surgery or an obvious change in body weight.

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Maintenance and Care A. Cleaning and Disinfection Individual employees shall clean and disinfect their own respirators as often as necessary to be maintained in a sanitary condition. Employees shall follow the Respirator Cleaning and Disinfection Procedure provided in Appendix M. Disposable respirators can be reused if they will continue to provide the same protection to employees. Disinfection before use is required if respirators are used by more than one person. Emergency use respirators shall be cleaned and disinfected after each use. B. Storage After cleaning, respirators shall be stored to protect them from damage, contamination, dust, sunlight, extreme temperatures, excessive moisture, and damaging chemicals. They shall also be packed or stored to prevent deformation of the face piece and exhalation valve. Emergency and rescue respirators shall be quickly accessible and stored in a clearly marked container. Respirators shall be placed in plastic bags and sealed. Respirators shall be stored in this manner whenever they are not in use. 7.8 Respirators shall be stored so that the face piece and exhalation valve are not bent or distorted.

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Policy No:EHS-504

Respiratory Protection

C. Inspection Respirator inspection shall include (where applicable) checking the tightness of connection and condition of the face piece; the head straps; the gaskets and diaphragms; valves, the connecting tube, cartridges, and canister or filters; and rubber parts for pliability and deterioration. Employees shall inspect routine use respirators before each use and during cleaning. Respirators maintained for use in an emergency shall be inspected monthly and shall be checked for proper function before and after each use. Emergency escape-only respirators shall be inspected before being carried into the workplace for use. SCBA's shall be inspected monthly. Air and oxygen cylinders shall be maintained in a fully charged state and shall be recharged when the pressure falls to 90% of the manufacturer’s recommended pressure level. Any deficiencies identified during the monthly inspection shall be corrected immediately, or the SCBA shall be removed from service. Monthly inspection information of SCBA’s and respirators maintained for emergency use shall include the date of the inspection, the name of the inspector, the findings / deficiencies, required corrective actions and a serial number or other means of identifying the inspected respirator. This information may be documented on a tag attached to the respirator, the storage compartment for the respirator or as an inspection report stored as paper or electronic files. The SCBA Inspection Form in the Attachment Section of this procedure is recommended for documenting these inspections. D. Repair Respirators that fail inspection or are otherwise found to be defective must be removed from service, and must be discarded or repaired or adjusted in accordance with the following procedures (always reference manufacturer’s recommendations): • • • •

Repair shall be done only by persons trained in proper respirator assembly. Replacement and repairs shall not deviate from manufacturer's recommendations. Replacement parts shall be only those designed for the specific respirator being worn. A supply of replacement parts shall be maintained.

Disposable respirators shall be discarded when they require repair.

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Policy No:EHS-504

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Respiratory Protection

Contractors Contractors shall provide respiratory protection for their own employees under their own respiratory protection program. Contractors are responsible for ensuring their Contractor Workers have the proper respiratory fit testing and training. Contractors shall not engage in practices that violate the requirements of this procedure or S&W Energy’s Contractor Safety Policy. Contractors must comply with the requirements outlined in the regulatory standards.

9

Recordkeeping Records of medical evaluations regarding respiratory protection shall be retained at least as long as the employee’s duration of employment PLUS 30 years. Fit Test records, either quantitative or qualitative, shall be retained until the next fit test is conducted (annually). A written copy of the most current Respiratory Protection Program shall be maintained on file for life of Facility or service. It shall be updated as necessary and made readily accessible.

10 Training Respiratory Protection Fit Testing training will be conducted for all employees who will be responsible for wearing a respirator both initially when hired, annually thereafter, and after any change which might affect the fit of a respirator. All S&W Energy employees (at a Facility or Site or Field personnel) who will be wearing a respirator or be involved in emergency situations where respirators may be used, shall be trained on the requirements and guidelines of this procedure at least on an annual basis. Training shall include: • • • • • • • •

Why the respirator is necessary and how improper use, fit, or maintenance can compromise the protective effect of equipment; What the limitations and capabilities of the respirator are; How to use the respirator effectively, especially during emergency situations or instances where respirator malfunctions; Instructions on the proper donning and wearing of the respirator and checking its fit and operation (including demonstrations); Instructions in maintenance, storage, and inspection of the respirator; The rationale of the respirator selection used based on the nature of the hazard; A discussion on the importance and timing of changing filters and/or cartridges; and How to recognize medical signs and symptoms that may limit or prevent the effective use of respirators. Page 11

Policy No:EHS-504

Respiratory Protection

• Retraining may be more frequent under the following circumstances: • •

Changes in the workplace that may affect respirator use; or Inadequacies of the employee’s knowledge and understanding of the program or any of its parts.

11 Auditing / Inspections The Respiratory Protection Procedure shall be reviewed every two years. This procedure will be updated as necessary. During this review, the Inspector or Auditor shall: • • • •

Ensure employees are using the respirators correctly; Ensure the Program, and all its elements, are being met and satisfied; Ensure proper hazard assessments were conducted and the appropriate respirator is being used accordingly; and Ask employees for their views on the Program effectiveness. Employees shall be asked to comment on their respirator fit, appropriate respirator selection for the hazards they may encounter, proper respirator use under the conditions at the Facility and proper respirator maintenance. Any problems identified by an employee shall be corrected.

Any records may be reviewed during this audit or inspection.

12 References 29 CFR 1910.134

Respiratory Protection

42 CFR Part 84

Respirator Cartridge Selections

ANSI Z88.6-1984

ANSI Standard for Respirator Use - Physical Qualifications for Personnel

ANSI Z88.2 – 1992

ANSI Standard for Respiratory Protection

ANSI K13.1-1973

Identification of Air Purifying Respirator Canisters and Cartridges

13 Forms See Appendix M • • • • • • • •

M.1 - Respirator Specification Form M.2 - Guidance on Development of a Cartridge Change-Out Schedule M.3 - Respirator Cartridge Selection Chart M.4 - OSHA Medical Evaluation Questionnaire M.5 - Fit Test Protocol M.6 - Respirator Fit Test Documentation Form M.7 - Respirator Cleaning and Disinfection Procedure M.8 - SCBA Inspection Form

Page 12

Environmental Health and Safety Manual Policy No. EHS-505

Policy Title: Hearing Protection and Conservation

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2 3 4 5 6 7 8 9 10 11 12

Purpose and Scope.................................................................................................. 2 Definitions ................................................................................................................ 2 Monitoring Procedure – General Requirements and Information ............................. 3 Monitoring Procedure – Area Monitoring.................................................................. 4 Monitoring Procedure – Personal Monitoring ........................................................... 4 Monitoring Procedure – Other Requirements........................................................... 5 Audiometric Testing ................................................................................................. 5 Hearing Protection - Equipment ............................................................................... 7 Training .................................................................................................................... 7 Auditing / Inspections ........................................................................................... 8 References ........................................................................................................... 8 Forms ................................................................................................................... 8

Page 1

Policy No:EHS-505

Hearing Protection and Conservation

1 Purpose and Scope This procedure provides all regulatory required elements and guidance for implementing a hearing conservation program. The procedure outlines monitoring, testing, appropriate protective equipment (both area and personal), training, and recordkeeping requirements for protection against occupational noise exposure. Regulations require that Facilities or Sites must be monitored to determine area noise levels and that a hearing conservation program must be implemented where employees’ are exposed to occupational noise levels that exceed 85 dBA on an 8-hour, time weighted average (TWA) basis.

2

Definitions • • • • • • • • •

• • •

Action Level – An 8-hour time-weighted average of 85 decibels measured on the A-scale, slow response, or equivalently, a dose of 50 percent. Area Noise Monitoring Survey – A survey conducted using a sound level meter to determine the levels of noise (in decibels) for a given or specified area. Attenuation – The method to reduce the amplitude or magnitude of noise levels by use of hearing protection; to reduce in force. Different hearing protection offers different levels and amounts of attenuation. Audiogram – A chart, graph, or table resulting from an audiometric test showing an individual’s hearing threshold levels as a function of frequency. Audiologist – A professional specializing in the study and rehabilitation of hearing, who is certified by the Speech-Language-Hearing Association (or equivalent) or licensed by a Board of Examiners. Baseline Audiogram – The audiogram against which future audiograms are compared. Decibels (dBAs) – A unit to measure noise level, measuring relative difference in power, usually between acoustic signals; a unit of measure of sound. Hertz (Hz) – Unit of measurement of frequency, numerically equal to cycles per second. Noise Dosimeter – An instrument that integrates a function of sound pressure over a period of time in such a manner that it directly indicates a noise dose. A dosimeter stores sound level measurements and integrates these measurements over time, providing an average noise exposure reading for a given period of time, such as an 8-hour workday. Otoloryngologist – A physician specializing in the diagnosis and treatment of disorders of the ear, nose, and throat. Personal Noise Monitoring Survey – A survey conducted using personal noise dosimeters over a period of time, determining the noise exposure of the individual over that time period (typically 8-hour time weighted average). Sound Level – Ten times the common logarithm of the ratio of the square of the measured A-weighted sound pressure to the square of the standard pressure.

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Policy No:EHS-505

• • •

3

Hearing Protection and Conservation

Sound Level Meter – An instrument for the measurement of sound level, measuring intensity at a given moment. Standard Threshold Shift - A change in hearing threshold relative to the baseline audiogram of an average of 10 dBA or more at 2000, 3000, and 4000 Hz in either ear. Time-Weighted Average (TWA) – Sound level which if constant over the specified exposure time period (i.e. 8-hour), would result in the same noise dose as is measured.

Monitoring Procedure – General Requirements and Information

The noise levels of each Facility or Site must be monitored initially and every time there is a change to the plant's configuration or operation that could change the noise profile. All personnel shall have the opportunity to observe noise level surveys being conducted, and to review the results of these surveys. Surveys are to be conducted according to the following procedures: Based on the results of noise monitoring, if employees will be subjected to noise levels exceeding those listed in the table below, employee exposure to these noise levels must be controlled in one of more of the following methods: Hours Per Day 8 6 4 3 2

dBA 85 92 95 97 100

Hours Per Day 1.5 1 .5 .25 None

dBA 102 105 110 115 140

Implementing practical and feasible engineering solutions and adaptations to reduce noise levels. These may include, but are not limited to, mechanical isolation, screening, enclosing, vibration damping, etc. Limiting the time during which an employee may be exposed to the hazardous noise levels. An employee may not be exposed to noise levels for time periods exceeding those listed in the table above unless personal hearing protection is provided and used (administrative control). If controls are not practical or feasible to implement to reduce noise levels below the listed values in the table, personal protective equipment shall be provided and used to reduce the levels. A hearing conservation program must be implemented if 8-hour time-weighted average exceeds 85 dBA. The hearing conservation program will consist of all

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Policy No:EHS-505

Hearing Protection and Conservation

elements outlined in this procedure. Implementation of this procedure satisfies requirements of this program.

4

Monitoring Procedure – Area Monitoring

Using sound level meters, area monitoring shall be performed (can be part of general monitoring). Area monitoring is conducted to determine the noise level present in various areas of the Facility or Site. The Facility or Site shall determine a monitoring route. This route should include all locations personnel would be expected to go during a shift or workday. Area noise monitoring shall be conducted along this route using the calibrated sound level meter set on the A-scale at slow response (refer to manufacturer guidelines and instructions on proper care and use of equipment). Noise level readings shall be recorded along with the date, time, general equipment status, location of reading, and any other factors that might affect the plant's noise levels. A suitable form for recording this data is provided in this procedure. A marked-up site map should be attached to the form indicating Facility or Site areas with noise levels exceeding 85 dBA. Based on the results of area noise monitoring, the following actions shall be taken: Hearing protection must be worn when working in all areas determined in the area survey to have noise levels exceeding 85 dBA. Double hearing protection must be worn in any area having noise levels over 100 dBA. Personnel should limit their exposure to noise levels over 100 dBA. S&W Energy will provide the appropriate hearing protection to all employees and Facility or Site visitors based on the results (this responsibility will be determined in advance). Employees must be given the opportunity to select their hearing protection based on review of area monitoring results. All areas requiring hearing protection or are high noise areas shall be clearly marked. All areas requiring double hearing protection shall be marked "Double Hearing Protection Required".

5

Monitoring Procedure – Personal Monitoring

Using dosimeters, personal noise monitoring shall be performed (can be part of general monitoring). Personal noise monitoring is conducted to determine the average noise level to which employees are exposed. The average is referred to as a time-weighted average. Personnel must be broken down into groups of employees normally exposed to similar noise levels. A typical group breakdown could include lead operators, junior operators, and mechanics. The dosimeter should be reset and calibrated (refer to manufacturer’s guidelines on proper care and use of equipment). Employees shall wear dosimeters during

Page 4

Policy No:EHS-505

Hearing Protection and Conservation

their normal workday. A TWA should be determined for a representative of each job group. Take two separate surveys for each job group. After each survey, the following information shall be recorded: • • • •

Date and time period of monitoring; Name and job group of the person monitored; Operational status (what are conditions at time of monitoring); and Any other variables which might affect the noise level.

A suitable form for recording this data is provided in this procedure (in Appendix N) Based on results of Personal noise monitoring, the following actions shall betaken; If personal noise monitoring results indicate that any job group is exposed to a TWA exceeding 85 dBA, all members of that job group must be notified, in writing, of their exposure level. If a job group TWA exceeds 90 dBA, management must be notified to review the feasibility of administrative and engineering controls to reduce this exposure level. All areas of high noise levels shall be clearly marked

6

Monitoring Procedure – Other Requirements Copies of all area and personal noise monitoring results are to be available for any audit or for personnel to review. Records of these surveys shall be retained indefinitely. Monitoring shall be repeated whenever a change in production, process, or equipment, or controls, increases noise exposure to the extent that: • •

Additional employees may be exposed at or above the action level; or The attenuation provided by hearing protectors may be rendered in adequate.

Any employee shall be given the opportunity to observe any noise measurements conducted.

7

Audiometric Testing

If the implementation of a hearing conservation is mandated by the noise monitoring process, S&W Energy Facility or Site personnel shall undergo baseline and annual audiograms. Audiograms must be performed and evaluated in accordance with regulatory standards. Audiometric tests shall be administered by a licensed or certified audiologist, otolaryngologist, a physician, or technician who is certified by the Council of

Page 5

Policy No:EHS-505

Hearing Protection and Conservation

Accreditation in Occupational Hearing Conservation (or equivalent) or who has satisfactorily demonstrated competence in administering audiometric examinations. Within 6 months of an employee’s first exposure at or above the noise action level, a valid baseline audiogram shall be conducted for that employee. If for any reason the baseline is not given within that first 6-month period, employee shall wear hearing protection for any period exceeding that 6 months until the baseline is obtained. Baseline audiogram tests shall be preceded by at least 14 hours without exposure to workplace noise. Hearing protection may be substituted for this requirement. Employees must be notified of the need to avoid high levels of occupational noise for the 14-hour period preceding the baseline audiogram. The audiogram from the pre-employment physical may serve as the baseline audiogram. At least annually after receiving the baseline audiogram, a new audiogram shall be conducted for those subject employees. The annual audiogram shall be compared to the baseline to determine if a standard threshold shift has occurred or other problems exist. If annual audiogram shows a standard threshold shift has occurred, employee may obtain retest (to verify) within 30 days and consider the retest as their annual audiogram. If annual audiogram shows a standard threshold shift has occurred, the employee shall be notified of this fact in writing within 21 days of determination. If it is suspected by physician or audiologist that a problem exists, the employee shall be notified and all tests and test results shall be reviewed with him/her. Unless the physician or audiologist determines that the standard threshold shift or other problems identified are not work or occupational-related, S&W Energy shall: • • •

Fit employees with the proper hearing protection (if employees not wearing any) and train them in the proper use and care of such protection; Refit employees with hearing protection of greater attenuation (if employees currently wearing protection) and retrain them on the proper use and care of such equipment; or Refer employee to clinical physician for additional testing if it is suspected that the shift or problem is caused or aggravated by wearing hearing protection.

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Policy No:EHS-505

Hearing Protection and Conservation

Audiometric test results should be evaluated to determine if hearing degradation is occurring. Audiometric test results shall be maintained by S&W Energy and shall contain the following information: • • • • •

Name and job classification of employee; Date of the audiogram; The examiner’s name; Date of last calibration of audiometer; and Employee’s most recent noise exposure assessment.

Audiometric test results shall be maintained for the duration of the employee’s employment. The employee or former employer or designated representatives shall provide access to records upon request.

8

Hearing Protection - Equipment Hearing protection shall be provided or made available to ALL employees exposed to an 8-hour TWA of 85 dBA or greater. Hearing protection shall be replaced as necessary. Employees may request hearing protection even if the noise levels are below the published action levels. Hearing protection shall be enforced in areas posted as such, based on noise surveys or other requirements. Employees shall be able to select the most suitable hearing protection for them, as provided by S&W Energy. S&W Energy (the Facility or Site Manager) shall ensure that appropriate hearing protection is made available to employees. Employees shall be provided training on hearing protection as well as training on proper use and care of protection. Fit testing shall be provided for those required to wear hearing protection. For areas where hearing protection is required, hearing protector attenuation shall be evaluated to ensure the protectors are providing the proper level of protection or id additional protection is required.

9

Training All Facility or Site employees (including Field personnel) shall be trained on the requirements and guidelines of this procedure annually. The following topics must be covered: • • • • •

The effects of noise on hearing; The purpose of hearing protection, its advantages and disadvantages; Attenuation of various types; Instructions on selecting, fitting, use and care of hearing protection; and The purpose of noise surveys and audiometric testing (brief description of procedures).

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Policy No:EHS-505

Hearing Protection and Conservation

10 Auditing / Inspections The Hearing Protection and Conservation Procedure shall be reviewed every two years. This procedure will be updated as necessary. Audiometric results shall be inspected annually to determine if standard threshold shift has occurred.

11 References 29 CFR 1910.95 (& Appendices)

Occupational Noise Exposure

12 Forms See Appendix N • •

N.1 - Area / Personal Noise Monitoring Survey Record N.2 - Hearing Protection and Conservation Program Auditing Checklist

Page 8

Environmental Health and Safety Manual Policy No. EHS-506

Policy Title: Hazard Communications

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2 3 4 5 6 7 8 9

Purpose and Scope.................................................................................................. 2 Definitions ................................................................................................................ 2 Chemical Management Requirements ..................................................................... 4 Written Hazard Communications (HAZCOM) Program ............................................ 6 Labels and Other Forms of Warning ........................................................................ 7 Material Safety Data Sheet (MSDS)......................................................................... 8 Training .................................................................................................................... 9 Auditing / Inspections ............................................................................................. 10 References............................................................................................................. 10

Page 1

Policy No:EHS-506

Hazard Communications

1 Purpose and Scope This procedure provides the requirements and guidelines to ensure either the employees at the workplace or the supplier evaluates hazardous substances and materials manufactured or received in the workplace and that information concerning their hazards is communicated to all employees. The HAZCOM procedure includes the requirements for developing and maintaining a written hazard communication program for the workplace, including lists of hazardous chemicals on site, labeling and storage requirements for hazardous materials as well as information regarding Material Safety Data Sheets, MSDS, (their definition and function). This procedure requires each Facility or Site to develop a written Hazard Communication Program and outlines the elements that shall be included in the written document. This procedure also includes guidance on the Facility or Site’s chemical management requirements (inventory, storage, handling, hazardous material approval process, etc.). The HAZCOM program and procedure does NOT include guidelines regarding hazardous wastes (procedures and guidelines included in a separate procedure) or hazardous chemicals / substances contained within articles (see definition of article).

2

Definitions •

• •



• • • •

Article – A manufactured item other than a fluid or particle which is formed to a specific shape or design during manufacture process, which has end use functions dependent in whole or in part upon its shape or design during end use, which under normal conditions of use does not release more than very small quantities of a hazardous chemical and does not pose a physical or health hazard. Chemical – Any element, chemical compound or mixture of elements or compounds. Combustible Liquid – Any liquid having a flashpoint at or above 100 degrees F but below 200 degrees F, except any mixture having components with flashpoints of 200 degrees F or higher, the total volume of which makes up 99% or more of the total volume of the mixture Container – Any bag, barrel, bottle, box, can, cylinder, drum, reaction vessel, storage tank, secured tank truck or the like that contains a hazardous chemical. For purposes of this procedure, pipes or piping systems as not to be considered containers. Exposure or Exposed – Describes that an employee is subjected in the course of employment to a chemical that is a physical or health hazard, and includes potential (accidental or possible) exposure. Flammable – A chemical that falls into one of the following categories: Flammable Gas – A gas that at ambient temperature and pressure forms a flammable mixture with air at a concentration of 13% by volume or less; Flammable Liquid – Any liquid of having a flashpoint below 100 degrees F, except any mixture having components with flashpoints of 100 degrees F or Page 2

Policy No:EHS-506





• • •

• •

• •

• •

Hazard Communications

higher, the total of which make up 99% or more of the total volume of the mixture; Flammable Solid – A solid agent other than an explosive or blasting agent, that is liable to cause fire through friction, absorption or moisture, spontaneous chemical change, or retained heat from manufacturing or processing, or which can be ignited readily. When ignited readily, a flammable solid burns vigorously and persistently as to create a serious hazard. Flashpoint – Lowest temperature at which a liquid or solid gives off a vapor in such a concentration that when the vapor combines with air near the surface of the liquid or solid, a flammable mixture is formed and ignites. The lower the flashpoint, the more flammable the product. Hazardous Chemical – Any chemical, which is a physical hazard or a health hazard. Hazardous Material – Material possessing a high potential for harmful effects upon persons. Hazard Warning – Any words, pictures, symbols, or combination thereof appearing on a label or other appropriate form of warning which convey the specific physical and health hazard(s), including target organ effect(s) of the chemical(s) in the container(s). Health Hazard – A chemical for which there is statistically significant evidence based on at least one study conducted in accordance with established scientific principles that acute or chronic health effects may occur in exposed employees. Immediate Use – In reference to this procedure, immediate use means the hazardous chemical will be under the control of and used only by the person who transfers it from a labeled container and only within the work shift in which it is transferred. Label – Any written, printed, or graphic material displayed on or affixed to containers of hazardous chemicals. Material Safety Data Sheet (MSDS) – Written or printed material concerning a hazardous chemical which is prepared by the manufacturer of a chemical that contains, among other information, the name, physical properties and chemical characteristics, hazards associated with the chemical, appropriate personal protective equipment to be worn when using the chemical, storage requirements, and what to do in case of an emergency with the chemical. All information provided on an MSDS shall be in accordance with regulatory standards. Physical Hazard – A chemical for which there is scientifically valid evidence that it is a combustible liquid, a compressed gas, explosive, flammable, an organic peroxide, an oxidizer or unstable or reactive material. Trade Secret – Any confidential formula, pattern, process, device, information or compilation of information that is used in an employer’s business, and that gives the employer an opportunity to obtain an advantage over competitors who do not know or use it.

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Policy No:EHS-506

Hazard Communications

The Facility or Site’s HAZCOM Program and procedure also serves as a guide to the Facility or Site’s Chemical Management requirements.

3

Chemical Management Requirements A. Approval and Inventory The Facility shall develop a list of all hazardous chemicals on-site, or in more general terms, keep a current chemical inventory. The list or inventory shall be developed by the Facility Manager or designee and kept up-to-date as new chemicals are added and others are deleted from the list. The written inventory should be classified into categories of hazardous chemicals or materials, according to specific regulatory classifications and definitions. Designations include hazardous materials, extremely hazardous substances, hazardous waste, acutely hazardous substances, etc. Most of the designations have a separate EHS procedure dedicated to that topic. Reference regulatory standards and S&W Energy’s EHS Manual for the requirements of different classifications of hazardous materials. The Facility shall develop an approval process, where the chemicals on-site must be approved before being accepted. The chemical approval process shall include criteria based on several factors such as the physical or health hazards associated with the chemical, its ability to perform its function, its byproducts (after use), etc. The approval process shall include a systematic check, where it must be approved by every department before being accepted. Once on the Approved Site Chemical Inventory, each hazardous chemical or material accepted and brought on-site must be accompanied by an MSDS. No chemical shall be accepted or received unless the appropriate MSDS is provided. Containers of hazardous materials entering the Facility or Site must be checked to ensure that the materials are properly labeled with the chemical name and contents, the appropriate hazard warning, and the name and address of the supplier or manufacturer. It is recommended that the labeling follow a standard and recognizable labeling system such as NFPA standards. Reference the HAZCOM labeling portion of this procedure for details on labeling requirements for hazardous materials. Each MSDS must be maintained by the Site and made readily accessible to all employees. MSDS’s shall be current and reflect the inventory of hazardous chemicals on-site at that time. MSDS’s for those chemicals that are no longer onsite shall be maintained for the life of the facility.

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Policy No:EHS-506

Hazard Communications

B. General Drum Handling and Storage of Hazardous Materials Hazardous materials shall be stored in drums that are in good condition. The material must be compatible with the drum. The drum storage area shall be designed and operated to contain any leaks or spills (the proper containment shall be installed). The area should be covered unless a drainage system is installed to properly handle rainwater accumulation. The hazardous material storage area shall be inspected regularly. The inspector shall check for leakage and deterioration of the drums or the containment system. Ignitable and reactive materials must be stored at least 50 feet (17 meters) inside the Facility property line. Incompatible materials must be kept separated by barriers such as walls, berms, etc. Drums must be clearly marked with the amount and contents of the container and the hazards of the material. Refer to the Hazard Communication portion of this procedure for information on labeling. C. Handling and Storage of Flammable and Combustible Materials Small quantities of flammable liquids should be stored in approved safety containers. These approved safety containers have self-closing caps, flame arrestors, and pressure relief vents. The container shall be labeled accordingly. Dispensing drums shall be equipped with a special self-closing faucet and a pressure-vacuum relief vent. A ground wire shall also be attached. Storage cabinets, rooms, or specified area should be designated to store flammable liquids. Large quantities of flammable liquids should be stored well away from the immediate work area. Reference the regulatory standards for specifications on cabinets and storage rooms. Never handle a flammable substance near a heat source or bring a heat source near a flammable substance. Safe transfers of flammable liquids are made in an open, well-ventilated area where the vapors will be dissipated by large volumes of fresh air. Employees shall ensure there is a bond between containers to eliminate static electricity. Using funnels and spouted cans are recommended for quick transfers and prevention of spills. Rags saturated with flammable or combustible liquids are highly susceptible to spontaneous combustion and must be disposed of in containers provided for that purpose. They shall never be piled on the ground.

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Policy No:EHS-506

4

Hazard Communications

Written Hazard Communications (HAZCOM) Program Each Facility shall develop, implement and maintain at each workplace, a written hazard communication program. The HAZCOM program shall describe how the following are met at the specified workplace: • • •

Labeling and other forms of warning for hazardous chemicals; Acceptance, use, and maintenance of Material Safety Data Sheets (MSDS’s); and Distribution of information to employees and employee training.

The written HAZCOM program shall include a list of the hazardous chemicals known to be present at the Facility, using identities or names located on the chemical’s MSDS. The list may be compiled for the Facility or Site as a whole or for individual work areas. Reference the Chemical Inventory, as described in Section 3. The written HAZCOM program shall include the methods the Facility or Site will use to inform employees of the hazards associated with chemicals contained in their work areas (whether they are associated with non-routine tasks or in unlabeled pipes). If the Facility or Site uses or stores hazardous chemicals on site, they must make provisions to inform employees of other employers working on-site (i.e., construction, contractors, etc.) of the elements of the Site’s HAZCOM program, if there is a potential of exposure. The Facility shall ensure the following: • • •

The other employer’s employees have access to MSDS’s for each hazardous chemical they may be exposed to; The methods the employer will use to inform the other employer’s employees of any precautionary measures that need to be taken to protect them during an emergency involving these chemicals; and The methods used to inform the employer’s employees of the Facility’s labeling system used in the workplace.

The written HAZCOM Program shall be made readily available, upon request, to employees, their designated representatives, or any regulatory agency. It is recommended that a copy of the program be positioned in a central location, i.e., a control room or office, so that it can be accessed at any time. This should be the centralized location where the MSDS’s are located as well. Contact the S&W Energy EHS Manager for a written HAZCOM program template.

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Policy No:EHS-506

5

Hazard Communications

Labels and Other Forms of Warning Each Facility shall ensure that each container of hazardous chemicals leaving the workplace are properly labeled, tagged, or marked. These containers shall be labeled with the following information, at the minimum: • • •

Identity of the hazardous chemical; Appropriate hazard warnings; and Name and address of chemical manufacturer, importer, or other responsible party.

The labeling of hazardous material containers leaving the Facility shall be in accordance with the regulatory standards outlined in this procedure as well as in accordance with the standards of the Department of Transportation (DOT) and their labeling guidelines for hazardous chemicals. The two labeling systems shall not be in conflict with one another. Each Facility shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with the following information, at a minimum: • •

Identity of the hazardous chemical therein; and Appropriate hazard warnings, or alternatively, words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which in conjunction with the other information immediately available to employees under the HAZCOM program, will provide employees with specific information regarding the physical and health hazards of the hazardous chemical.

Employer shall ensure that the labeling system is consistent using recognized labels or tags. It is recommended that the labeling be consistent with NFPA or other equivalent standards. Portable containers of hazardous chemicals are not required to be labeled if the hazardous chemicals are transferred from labeled containers and which are intended for immediate use by the employee who performs the transfer. Process vessels containing hazardous material shall be labeled. Examples include ammonia tanks, acid and caustic tanks, waste oil containers, and chemical mixing tanks. Piping containing hazardous materials shall be labeled indicating the substance in the pipe. This includes ignitable materials such as natural gas and fuel oil. The distance between labels should not exceed 25 feet. Pipe labels shall contain the contents and the direction of flow within the pipe. No one shall remove or deface existing labels on containers of hazardous chemicals unless the container is immediately marked with the required information following removal of original label.

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Policy No:EHS-506

Hazard Communications

The labels or other forms of warning shall be legible, in the appropriate language(s) so all employees understand, and prominently displayed on each container or readily available in the work area throughout each work shift. If the Facility becomes newly aware of any significant information regarding the hazards of a chemical, the labels designated to that chemical shall be revised within three months of becoming aware of the new information.

6

Material Safety Data Sheet (MSDS) Each Facility shall obtain and maintain a material safety data sheet for each hazardous chemical that is used in the workplace. Each MSDS shall be in a language that can be read and understood by all employees and shall contain at least the following information: •

• • • • • • •

• • •

The identity used on the label. If the hazardous chemical is a single substance, the chemical and common name should be provided. If the hazardous chemical is a mixture, the chemical and common names of the ingredients which contribute to the known hazards and the common name of the mixture itself shall be provided; Physical and chemical characteristics of the hazardous chemical (such as flashpoints, vapor pressures, etc.); Physical hazards of the hazardous chemical including potential for fire, explosion, or reactivity; Health hazards of the hazardous chemical including signs and symptoms of exposure and any medical conditions which are generally recognized as being aggravated by exposure to the chemical; The primary routes of entry; The permissible exposure limits used or recommended by the chemical manufacturer or responsible party who prepared the MSDS, where available; Information concerning whether or not the hazardous chemical is a carcinogen or is a possible carcinogen; Any generally applicable precautions for safe handling and use which are known to the chemical manufacturer or responsible party preparing the MSDS, including appropriate hygienic practices, protective measures, and procedures for clean-up or spills and leaks; Emergency and first aid procedures; The date of preparation of the MSDS or the last revision or change to it; and The name, address and telephone number of the chemical manufacturer or other responsible party preparing or distributing the MSDS who can provide additional information on the hazardous chemical and appropriate emergency procedures, if necessary.

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Policy No:EHS-506

Hazard Communications

If no relevant information is found for any given category on the MSDS, the chemical manufacturer or responsible party who prepared the MSDS shall mark it to indicate that no applicable information was found. If a Facility receives an MSDS which doesn’t contain information in the specified category AND there is no information regarding “not applicable”, the chemical manufacturer or responsible party should be contacted to discuss the discrepancy. Each delivery of a hazardous chemical must be accompanied by the corresponding MSDS. If there is no MSDS, the chemical shall not be received. If for any reason the Facility or Site loses or cannot locate the MSDS for a certain chemical, the chemical manufacturer or other responsible party shall be contacted immediately to obtain an MSDS for that chemical. The Facility or Site shall maintain copies of the required MSDS’s for each hazardous chemical and shall ensure that they are readily accessible during each work shift to all employees. Electronic access, microfiche, and other alternatives to maintaining paper copies of the MSDS’s are permitted as long as there are no barriers to immediate employee access. If employees must travel between workplaces during their course of work, the MSDS’s for any hazardous chemical may be kept at the primary workplace location. However, the employer must ensure that the information on an MSDS can be obtained by the employee immediately in case of an emergency. MSDS’s can be kept in any form, including operating procedures, and may be designed to cover groups of hazardous chemicals where it may be more appropriate to address the hazards of a process rather than individual chemicals. However, employers shall ensure that the required information is supplied in all cases and is readily accessible to all employees when required or requested.

7

Training All S&W Energy Facility or Site employees (including Field personnel) shall be trained on the requirements and guidelines of this procedure and the Site’s HAZCOM program at the time of their initial assignment (upon initial hire). In addition, employees shall be trained whenever a new physical or health hazard the employees have not previously been trained about is introduced into their work area. Refresher training is required every 2 years. Information and training may be designed to cover categories of hazards or specific chemicals. The training shall include at least: •

Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area (such as monitoring conducted, monitoring devices, visual appearance or odor of certain chemicals, etc.);

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Policy No:EHS-506

• •



8

Hazard Communications

The physical and health hazards of the chemicals in the work area; The measure employees can take to protect themselves from these hazards, including specific procedures implemented that include appropriate work practices, emergency procedures, and personal protective equipment; and Details of the hazard communication program, including an explanation of the labeling system and material safety data sheets and how employees can obtain and use the appropriate hazard information.

Auditing / Inspections

The Hazard Communication Procedure shall be reviewed every 2 years. Documented chemical management information or the written HAZCOM program may be reviewed as part of this audit or inspection. This procedure will be updated as necessary.

9

References 29 CFR 1910.1200

Hazard Communications

29 CFR 1910.106

Flammable and Combustible Liquids

Page 10

Environmental Health and Safety Manual Policy No. EHS-507

Policy Title: Hazardous Waste Operations and Emergency Response (HAZWOPER)

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2 3 4 5 6 7 8

Purpose and Scope.................................................................................................. 2 Definitions ................................................................................................................ 2 Determining Applicability.......................................................................................... 3 Emergency Response Plan...................................................................................... 3 Procedure ................................................................................................................ 4 Training .................................................................................................................... 7 Auditing / Inspections ............................................................................................... 9 References............................................................................................................... 9

Page 1

Policy No:EHS-507

Hazardous Waste Operations and Emergency Response (HAZWOPER)

1 Purpose and Scope This procedure establishes guidelines to enable compliance with HAZWOPER regulations for those Facilities or Sites that are subject to the regulatory standard based on their operations and inventory of chemicals and materials. The guidelines and requirements are intended to limit the exposure of employees dealing with uncontrolled releases of hazardous material and to protect the environment from uncontrolled releases by the best means possible. This program applies to all Facilities or Sites that have the potential for an uncontrolled release of hazardous substances that may require emergency response operations to eliminate or control the hazard. The level of response will depend on Facility or Site preparation, equipment, and employee level of training in combination with the hazards associated with each Facility. Community response is also factored into HAZWOPER applicability and level of response for each Facility. This procedure shall be used with S&W Energy’s Emergency Response Procedure and S&W Energy’s Waste Management Procedure.

2

Definitions •

• •





Clean-Up Operation – An operation where hazardous substances are removed, contained, incinerated, neutralized, stabilized, cleared-up, or in any other manner processed or handled with the goal of making the site safer for people or the environment. Controlled Release – Releases that are contained by in-place facilities or safeguards, does not go off property, can be stopped by closing valves, or absorbed/neutralized promptly at the time of release. Emergency Response – A response effort by employees from outside the immediate release area or by other designated responders (i.e., local fire departments, mutual aid groups, designated HAZMAT teams, etc.) to an incident that results in or potentially results in an uncontrolled release of a hazardous substance or other incident that can be classified as an emergency. Hazardous Materials (HAZMAT) Response Team – An organized group of employees, designated by the employer who are expected to perform work to handle and control actual or potential leaks or spills of hazardous substances requiring possible close approach to the substances; the response is for the purpose of control or stabilization of the incident. Hazardous Substance – Any substance designated in any of the categories listed below and exposure to which results or may result in adverse affects on the health or safety of employees: 1. Any substance defined under designated sections of CERCLA (Comprehensive Environmental Response, Compensation, and Liability Act, commonly known as Superfund); 2. Any biological agent and other disease causing agent which after release into the environment and upon exposure, ingestion, inhalation, or assimilation into any person, either directly from the environment or Page 2

Policy No:EHS-507





Hazardous Waste Operations and Emergency Response (HAZWOPER)

indirectly, will or may reasonably be anticipated to cause death, disease, behavioral abnormalities, etc. 3. Any substance listed by the U.S. Department of Transportation (DOT) as hazardous material (under 49 CFR 172 and appendices); or 4. Any hazardous waste as defined in 40 CFR 261.3 or 49 CFR 171.8. Incident Command System (ICS) – System implemented as part of the Emergency response indicating the channels of communication and identification of individuals responsible for certain tasks and activities. One individual (and back-up) at each Facility is designated to lead the Incident Command System. Uncontrolled Release (Uncontrolled Incident) – A release of a hazardous substance which cannot be controlled by shutting off valves, cannot be controlled by in-place facilities such as dikes, catch basins, sump tanks, etc., or cannot be absorbed or neutralized promptly. An uncontrolled incident can also be a fire that has progressed beyond the incipient stage, cannot be suppressed by the use of fire extinguishers, requires the use of chemical protective clothing and/or requires the use of positive pressure respirators.

The Facility or Site shall be evaluated for hazardous substances to determine the level of Emergency Response. All employees assigned to work activities as the normal work assignment or to provide assistance on an emergency basis must be informed of the hazardous substances identified or known to be present.

3

Determining Applicability The requirements of this procedure cover emergency response operations for releases of, or substantial threats of releases of, hazardous substances without regard to the location of the hazard. In addition, each Facility or Site shall be evaluated to determine if they are subject to Hazardous Waste regulations as they are outlined by RCRA (Resource Conservation and Recovery Act). Depending on applicability to RCRA standard levels, there may be additional requirements other than the general HAZWOPER requirements included in this procedure. Consult with the S&W Energy EHS Manager for applicability status and additional requirements.

4

Emergency Response Plan An emergency response plan shall be developed and implemented to handle anticipated emergencies prior to commencement of emergency response operations. The plan shall be in writing and available for inspection and duplication by employees, their representatives, or regulatory agencies.

Page 3

Policy No:EHS-507



Hazardous Waste Operations and Emergency Response (HAZWOPER)

All elements that must be included in an Emergency Response Plan and the developmental steps to create such a written Plan are outlined in S&W Energy’s Emergency Response procedure in S&W Energy’s EHS Manual. Reference this procedure for a template Plan and other requirements.

Prior to initiating emergency response activities, the Facility or Site shall be surveyed to determine the presence of hazardous conditions, such as explosive gases, toxic gases, oxygen deficiency, or other life threatening conditions. Following the identification of hazards and a determination of the proper personal protective equipment (PPE) is available and sufficient to safeguard personnel, a continuing monitoring program should be implemented and continue for the duration of the emergency response activities. A site control program should be developed during the planning stages of any emergency response activity and modified as necessary as information becomes available. •

The Site Control Program should include a site map, the designated work zones, site communication procedures, safe work practices and the identification of the nearest medical services. This information may be included in the Facility’s Emergency Response Plan.

A detailed description of the response activities that may be required in the event of a release as applicable to a given Facility or Site and/or hazardous substance should also be developed, including notification/alerting procedures and emergency response contact telephone numbers.

5

Procedure A. Handling Emergency Response - ICS Each Facility or Site shall develop a site-specific Incident Command System (ICS) and shall designate an individual in charge of the ICS. All emergency response activities and their communications shall be directed, coordinated and controlled through the designated individual. The designated individual in charge of the ICS shall identify, to the extent possible, all hazardous substances or conditions and identify appropriate analysis, exposure limitations, engineering controls, handling procedures and use of new technologies. The designated individual in charge of ICS shall implement appropriate emergency operations and assure personal protective equipment available and worn is appropriate for the hazards to be encountered. The individual in charge of the ICS shall limit the number of emergency response personnel at the emergency site, in those areas of potential or actual exposure, to those who are actively performing necessary emergency operations.

Page 4

Policy No:EHS-507

Hazardous Waste Operations and Emergency Response (HAZWOPER)

The individual in charge of the ICS shall designate a safety official, who is knowledgeable in the operations being implemented at the emergency response site, with specific responsibility to identify and evaluate hazards and to provide direction with respect to the safety operations for the emergency at hand. When activities are determined to be dangerous to life and health or to involve an imminent danger condition, the safety official shall have the authority to terminate activities and immediately inform the individual in charge of the ICS of the situation. After emergency operations have terminated, the individual in charge of ICS shall implement appropriate decontamination procedures. B. Personal Protective Equipment Selection Chemical protective clothing and equipment to be used by organized and designated HAZMAT team members shall meet the following requirements: Personal Protective Equipment (PPE) shall be selected and used which will protect employees from the hazards and potential hazards they are likely to encounter as identified during a site characterization or a job safety analysis. •

• •

PPE shall be selected based on an evaluation of the performance criteria of the PPE relative to the requirements and limitations of the site, the task-specific conditions and duration, and the nature of the hazards or potential hazards involved. The level of protection provided by PPE selection shall be increased when additional information on site conditions indicates that increased protection is necessary. A written personal protective equipment plan shall be established. S&W Energy’s PPE / JSA procedure in the EHS Manual satisfies this requirement.

Respiratory protection shall be provided according to S&W Energy’s Respiratory Protection Procedure and policy. Specific hazards or potential hazards will require varying levels of respiratory protection. This shall be determined during site hazard characterization or analysis. •

Positive pressure self-contained breathing apparatus, or positive pressure air-line respirators equipped with air escape air supply, shall be available and used when chemical exposure levels present may create a substantial possibility of immediate death, serious illness or injury, or impair the ability to escape.

Totally-encapsulating chemical protective suits (Level A protection) shall be used in conditions where skin absorption of a hazardous substance may result in a substantial possibility of death, serious illness or injury, or impair the ability to escape.

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Policy No:EHS-507

Hazardous Waste Operations and Emergency Response (HAZWOPER)



Totally-encapsulating suits shall be capable of maintaining positive air pressure and shall be capable of preventing inward gas leakage of more than 0.5%. Consult with vendor or manufacturer recommendations and test methods for verification of these requirements. C. Medical Surveillance A medical surveillance program shall be initiated for all employees that: • • • •

Have been exposed to hazardous substances at or above permissible limits, regardless of respirator use, for 30 days or more per year; or Wear a respirator for 30 days or more per year; or Are injured or acquired illnesses through over exposure to hazardous substances; or Are members of HAZMAT teams.

Medical examinations under the established medical surveillance program shall be given according to the following frequency guidelines: 1. For employees who have been exposed to hazardous substances at or above permissible limits, regardless of respirator use, for 30 days or more per year, employees who wear a respirator for 30 days or more per year, or for members of HAZMAT teams, medical examinations shall be given: • Prior to assignment; • At least once every twelve months for each employee covered unless the physician believes more frequent examinations are necessary; • At termination of employment or reassignment to a new area; and • As soon as possible after an employee believes or there is notification that the employee has developed signs or symptoms indicating possible overexposure to a hazardous substance. 2. For employees injured or who have acquired illnesses through over exposure to hazardous substances, medical examinations shall be given: • As soon as possible following the emergency incident or indication of symptoms. Follow S&W Energy’s Medical Records Access / Recordkeeping procedure for detailed information on content of medical examinations and who shall conduct or perform the evaluations. D. Decontamination Decontamination procedures shall be developed and tailored to each site, appropriate to the hazardous substances present.

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Policy No:EHS-507

6

Hazardous Waste Operations and Emergency Response (HAZWOPER)

Training

Training shall be based on the duties and functions to be performed by each responder of an emergency response organization. All employees must be trained prior to hire or prior to taking part in any of the tasks or responsibilities of emergency response they are assigned. A. There are several levels of emergency response training. Each Facility or Site must determine the employees to be trained and the level they are to be trained based on the Site’s capability to respond and the surrounding area’s emergency response assistance. The training shall be given in accordance with the following: First Responder Awareness Level – Individuals who are likely to witness or discover a hazardous substance release and have been instructed to initiate emergency response activities by notifying the appropriate individuals. These employees must not take any further action other than notifying the proper authorities. This level of training shall include the following: • • • • • •

An understanding of what hazardous substances are, especially those specific to the site, and the risks associated with each; An understanding of the potential outcomes associated with an emergency created when hazardous substances are present; The ability to recognize the presence of hazardous substances in an emergency; The ability to identify the hazardous substance, if possible; An understanding of the role of the first responder awareness individual in the scheme of the Site’s emergency response system; and The need to recognize the need for additional resources and to make appropriate notifications to the community.

First Responder Operations Level – Individuals who respond to releases or potential releases of hazardous substances as part of the initial response to the site for the purpose of protecting nearby persons, property, or the environment from the effects of the release. They are instructed to respond in a defensive fashion without actually trying to stop the release. Their function is to contain the release, keep it from spreading, and prevent exposure. First Responders at the Operations Level require at least 8 hours of training and include the following training: • • •

Knowledge of the basic hazard and risk assessment techniques; Know how to select and use proper personal protective equipment provided; An understanding of basic hazardous materials terms;

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Policy No:EHS-507

Hazardous Waste Operations and Emergency Response (HAZWOPER)

• • •

Know how to perform basic control, containment and/or confinement operations within the capabilities of the resources and personal protective equipment available. Know how to implement basic decontamination procedures; and An understanding of the relevant standard operating procedures and termination procedures.

Hazardous Materials Technician Level – Individuals who respond to releases or potential releases for the purpose of stopping the release. They assume a more aggressive role than First Responder level in that approach the release in order to plug, patch or otherwise stop the release of a hazardous substance. Hazardous Materials Technician shall have received at least 24 hours of training equal to First Responder Level but meet the following additional topics: • • • • • • • • •

Know how to implement the employer’s emergency response plan; Know the classification, identification, and verification of known and unknown materials by using field survey instruments and equipment; Be able to function in an assigned role in the Incident Command System (ICS); Know how to select and use proper specialized chemical PPE provided to the hazardous materials technician; Understand hazard and risk assessment techniques; Be able to perform advance control, containment, and/or confinement operations within the capabilities of the resources and PPE available; Understand and implement decontamination procedures; Understand termination procedures; and Understand basic chemical and toxicological terminology and behavior.

On-Scene Incident Commander – Incident Commanders who will assume control of the Incident scene beyond the first responder awareness level, shall receive at least 24 hours of training equal to the first responder operations level and in addition have competency in the following areas and shall so certify: • • •

Know and be able to implement the employer’s incident command system; Know how to implement the employer’s emergency response plan; Know and understand the hazards and risks associated with employees working in chemical protective clothing; Page 8

Policy No:EHS-507

Hazardous Waste Operations and Emergency Response (HAZWOPER)

• • •

Know how to implement the local emergency response plan; Know of the state emergency response plan and of the Federal Regional Response Team; and Know and understand the importance of decontamination procedures

Each Facility or Site shall be evaluated to determine the level of training required. Trainers who teach any of the above levels shall have training credentials and instructional experience to demonstrate competent instructional skills and a good command of the subject.

B. All S&W Energy Facility or Site employees (including Field personnel) shall be trained on the requirements and guidelines of this procedure and at the First Responder Awareness Level. Other levels of training should be given, as necessary. Refresher training is required annually, no matter what level is required. C. All employees assigned to an Emergency Response Team working at a site exposed to a hazardous substance, their supervisors and management of the site shall receive training before they are permitted to work.

7

Auditing / Inspections The HAZWOPER Procedure shall be reviewed every 2 years. This procedure will be updated as necessary.

8

References 29 CFR 1910.120

Hazardous Waste Operations and Emergency Response

Page 9

Environmental Health and Safety Manual Policy No. EHS-508

Policy Title: Emergency Response

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2 3 4 5 6 7 8 9 10 11

Purpose and Scope.................................................................................................. 2 Definitions ................................................................................................................ 2 Emergency Action Plans & Emergency Response Plans – General Requirements. 2 General Guidance for Emergencies ......................................................................... 4 Evacuation Routes and Assembly Areas ................................................................. 9 Plot Plans ................................................................................................................. 9 Alarms, Whistles, Signals, Alerts.............................................................................. 9 General Procedures ............................................................................................... 10 Training .................................................................................................................. 11 Auditing / Inspections ......................................................................................... 11 References ......................................................................................................... 11

Page 1

Policy No:EHS-508

Emergency Response

1 Purpose and Scope The purpose of this procedure is to provide policy and guidance for creating Emergency Action Plans and Emergency Response Plans for a Facility or Site. The types of incidents and scenarios covered under these Plans include, but are not limited to, fire, explosions, bomb threats, medical emergencies, high winds, sever lightning or hurricanes, heavy rainfall and floods, earthquakes, heavy snowfall or ice, and/or any hazardous material spill or leak. Emergency Response requirements cover all types of S&W Energy Facility or Site classifications including Office Building (Headquarters or Regional Office), Power Plant Facility, and/or Field Locations. Each Plan will include all minimum requirements as this procedure indicates but each must be tailored specifically to each type of Facility classification.

2

Definitions • •

• • • •

3

Emergency Action Plan – A plan for a workplace, or parts thereof, describing what procedures the employer and employees must take to ensure employee safety from fire or other emergencies. Emergency Response Plan – A plan developed and implemented to handle anticipated emergencies prior to the commencement of emergency response operations. It is also intended to minimize hazards to employees, the public or the environment from fires, explosions, or any unplanned sudden or nonsudden release of hazardous materials, hazardous waste or hazardous constituents to air, soil, surface water or ground water. The plan is designed to set procedures for reporting all releases or threatened releases of hazardous materials. Field Location – Short-term job-sites with work currently in progress. LEPC – Local Emergency Planning Committee / Commission. Office Building – Stand-alone facilities which are primarily dedicated to administration, sales, technical and management support. Power Plant Facility – Fixed industrial locations operated and maintained on an ongoing basis by S&W Energy (O&M Facilities)

Emergency Action Plans & Emergency Response Plans – General Requirements A. Emergency Action Plan Each Facility or Site shall develop an Emergency Action Plan in writing to inform employees of the actions to be taken in case of an emergency. The Facility or Site shall establish the types of evacuation to be used in emergency circumstances. The following elements, at a minimum, shall be included in the Emergency Action Plan:

Page 2

Policy No:EHS-508

Emergency Response



Emergency escape procedures and emergency escape route assignments; • Procedures to be followed by employees who remain to operate critical plant operations before they evacuate; • Procedures to account for all employees and visitors after emergency evacuation has been completed; • Rescue and medical duties for those employees who are to perform them; • The preferred means of reporting fires and other emergencies; and • Names or regular job titles of persons or departments who can be contacted for further information or explanation of duties under the plan. B. Emergency Response Plan Each Facility or Site shall develop an Emergency Response Plan in writing to handle anticipated emergencies involving hazardous materials or substances. The following elements, at a minimum, shall be included in the Emergency Response Plan, to the extent they are not addressed elsewhere: • • • • • • • • • • • • •

Pre-emergency planning and coordination with outside parties; Personnel roles, lines of authority, and communication; Emergency recognition and prevention; Safe distances and places of refuge; Site security and control; Evacuation routes and procedures; Decontamination procedures; Emergency medical treatment and first aid; Emergency alerting and response procedures; Critique of response and follow-up; PPE and emergency equipment; Site topography, layout, and prevailing weather conditions; Procedures for reporting incidents to local, state, and federal governmental agencies;

The Emergency Response Plan shall be rehearsed regularly as part of the overall training program for site operations.

Emergency Action Plans and Emergency Response Plans are very similar with many of the same requirements. They may be combined into one comprehensive Plan as long as the minimum requirements, as outlined in this Section for both Plans, are satisfied.

Page 3

Policy No:EHS-508

Emergency Response

The Emergency Action Plans and Emergency Response Plans shall be reviewed periodically and, as necessary, be amended to keep it current with new or changing conditions or information. An employee alarm system shall be installed in accordance with regulatory standards to notify employees of an emergency situation; to stop work activities if necessary; to lower background noise in order to speed communication; and to begin emergency procedures. Elements of the alarm system include: • • •

Loud or distinct enough to be perceived above ambient noise or light levels by all employees in the affected areas; A clearly recognizable signal to evacuate the work area, if necessary, or to perform actions under Emergency Response; and Preferred means of reporting emergencies and communication (manual pull box alarms, radio, public address system, telephones, etc.).

Each alarm device or component shall be constructed and installed to comply with local standards and approved. Employer must ensure that each alarm system is restored to normal operating condition following any use or test. Employer shall ensure that all alarm systems are maintained in operating condition except when undergoing repair or maintenance. In such a case, alternative alarm systems must be used; Back-up power supplies shall be maintained.

4

General Guidance for Emergencies Emergency procedures are necessarily general, as much depends on the severity of the emergency, often aggravated by circumstances such as heavy seas, bad communications, disrupted logistics, and rescue difficulties. Concern in order of importance is: 1. The safety of the personnel working in the emergency area 2. Protection of equipment 3. Minimum loss in production An Emergency Action Plan and Emergency Response Plan, if separate, are to be maintained at each work site at all times while work is in progress. All assigned personnel are to be thoroughly briefed on its content and availability. It is the responsibility of each Manager and Supervisor to ensure this briefing is conducted and documented. The personal safety and property of residents around the emergency area must be preserved as much as possible. Page 4

Policy No:EHS-508

Emergency Response

The extent of the emergency area should be defined and restricted. All necessary equipment and specialists should be brought in for assistance, as required. Damage to property should be rectified as soon as the situation allows the equipment and personnel to enter the area. Legal aspects such as claims should be promptly reported to senior management for handling. Consider the facility and determine the effect each type of emergency can have on the normal operations and on the standard emergency procedures established. Changes and revisions to such operations or procedures may result. Review all normal operations carefully, to ensure that no critical operation is started which can not be completed before it may become necessary to commence evacuation procedures. Make certain that the appropriate pre-planned evacuation procedure is suited to each circumstance. Ensure that in the event of an emergency alert the following instructions are adhered to: • • • •

Retain transportation assets in ready status for as long as possible. Any construction or non-essential operations are to be stopped and work begun to secure all facilities. Personnel are not to be assigned duties which will necessitate their being at remote parts of field or isolated parts of an installation for a prolonged period unless they have radio communications readily available. A weather forecasting service is to be monitored to provide timely warning of impending bad weather.

In the event it becomes necessary to respond to any one of the following types of emergencies, the Plan should provide instructions and information applicable to the specific emergency conditions. A. Fire or Explosion All personnel will immediately prepare to evacuate upon hearing a fire alarm signal. Time and situation permitting, all equipment and materials currently in use should be properly disconnected, shut off, or otherwise secured to preclude additional hazardous conditions. Do Not go to the scene of the fire unless specifically told to do so. In the event of a fire, Company personnel should immediately: •

Trip the nearest fire alarm (if provided) or report the fire by telephone to the Local Fire Department and/or the Client Fire/Security Office. The appropriate emergency telephone numbers are to be prominently posted at each work location.

Page 5

Policy No:EHS-508



Emergency Response

If assigned personnel are trained in the use of fire extinguishers AND, using prudent judgment, the fire can be extinguished quickly, minimizing the hazard by quick action, Company personnel should respond accordingly. DO NOT FIGHT A FIRE ALONE! If the fire gets large or out of control, then evacuate. Once the fire brigade or fire department has arrived on the scene, Company personnel should clear the area of the fire scene and go to the designated assembly point via the evacuation route immediately. Do not discuss the incident or your actions with anyone not connected with the Company, the Fire Department, Client Operations or Security. All communication of information to other parties will be by the Company Management or the client representative as appropriate. All personnel are to remain at the designated assembly area until the All Clear Signal is sounded or specific instructions are provided for other action.

B. Bomb Threats In those circumstances in which determined individuals plan to inflict damage or disrupt operations, regardless of motive, it is extremely difficult to prevent them. Security plans should be drawn up to act as a deterrent, introducing obstacles and making access more difficult. These plans should be drawn up in consideration of the available civil authorities and treated as confidential. Personnel should not place themselves in jeopardy to apprehend intruders but should concentrate their efforts on containing the effects of an incident. In the event a phone call warns of a bomb threat the following may prove helpful: • • •

The individual receiving a telephone call in which the caller states a bomb has been planted and is set to detonate should remain calm and quietly summon assistance while keeping the caller on the phone. Interrupt the caller as often as possible by asking questions and asking the caller to repeat. This may prevent the caller from completing the message and hanging up. Be polite and act very concerned. Inform the caller that the detonation of the bomb could result in death or serious injury to innocent people. Using the following as a guide, attempt to record details of the call:

• • •

Date and time call received Exact words of caller. Questions to ask: 1. When is bomb going to explode? 2. Where is bomb right now? 3. What kind of bomb is it? 4. What does it look like? 5. Why did you place the bomb? Page 6

Policy No:EHS-508

Emergency Response



Description of caller's voice: Male / Female, Young / Middle Age / Old, Accent, Tone of Voice • Background Noise • Is voice familiar? If so, who did it sound like? C. Medical Emergencies Facilities selected to provide these Emergency Medical services are to be posted for ready reference at each facility or job location. Managers should direct activities to identify selected facilities in near proximity to each work location and should arrange for posting of the necessary Emergency Information. Managers of departments that work at various job sites should ensure the nearest medical facility is identified during the initial site job walk and include the information for posting in a Job Safety Packet prepared for short term work locations. All on-the-job injuries/illnesses other than minor first aid cases, i.e. cleansing of abrasions and scratches and application of band aids must be transported as soon as possible for medical care and/or treatment. Transport non-emergency injuries/illnesses to the doctor's office (if identified) on an Emergency Information Posting. NOTE: Call prior to transport to ensure doctor's availability and for alternate instructions in the event a hospital is recommended for treatment. NOTE: An Ambulance service is to be utilized only when required due to nature of the injury/illness which rules out the use of other transportation. All on-the-job injuries/illnesses must be reported and investigated in accordance with the instructions provided in the Accident Investigation and Reporting section of this Manual. D. High Winds, Severe Lightning or Hurricanes A comprehensive set of step by step instructions should be prepared in advance and all personnel should familiarize themselves with their instructions. At any time when a storm is forecast steps should be taken immediately to safeguard personnel and facilities in the more exposed areas. E. Heavy Rainfall or Floods An analysis of road and field conditions should be made of the surrounding area in the event of flooding. Check whether emergency procedures can be carried out in the event of flooded roads, bridges, etc.

Page 7

Policy No:EHS-508

Emergency Response

Tanks, pipelines and other equipment should be firmly secured against floating. Tanks should be kept full if practical. If time permits, wells in the more exposed areas should be closed in either by safety valves in the well or with the master valve at the surface. For evacuation purposes helicopters equipped with floatation gear and winch may be required in flooded areas. F. Earthquakes Earthquakes are unpredictable with today's technology and as a result it is extremely difficult to implement protective or preventative measures other than making those architectural modifications that minimize structural damages in critical areas. The following actions are recommended to be taken during and immediately after an earthquake: • Shut-off sources of release of process fluids. • • Investigate what gases can be expected in the exposed areas. • • Check for toxic vapor or liquids. • • Check possibility of damaged equipment collapse. • • Restrict personnel access to area. • • Keep fire-extinguishing equipment ready for use. • • Any further actions needed to put the installations in a safe condition. • • Consider effect of possible subsequent tidal wave. G. Heavy Snowfall or Ice In areas where the possibility of excessive snowfall or icing exists, pre-planned instructions and necessary equipment should be available for safeguarding personnel and facilities. Vital equipment should be protected against collision damage due to poor visibility, snowing-in or icing by using signs, crash barriers or other aids. H. Hazardous Material Leak or Spill Accidental spills of hazardous materials must be reported at once to the Manager/Job Supervisor and (if applicable) designated client representative, per Reporting Procedures. If safe to do so, get information on the spilled material, control entry to the spill site and watch over the area until help arrives.

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Policy No:EHS-508

Emergency Response

Do not attempt to clean-up spills without direction and/or training. If trained at the First Responder Operations Level, dike around liquid spills to prevent drainage into water supply and contact with other materials. Check the Material Safety Data Sheets (MSDS) for personal protection equipment requirements and for disposal instructions and precautions. See the Hazardous Waste Operations and Emergency Response Program (HAZWOPER) for additional guidance for events of this nature.

5

Evacuation Routes and Assembly Areas Floor plans of each Office Facility with clear routes of egress established and prominently marked shall be developed. Once the floor plans have been prepared, the floor plan for each floor showing the evacuation route will be prominently posted for ready reference by building occupants. Specifically designated assembly areas will be established for each facility and such areas will be noted on the posted floor plan which contains the marked evacuation routes. Evacuation routes for Power Plant Facilities will be established by the Facility Manager and will be posted prominently for quick reference by assigned employees. Evacuation routes for Field Locations will be as specified by client or property owner. NOTE: It is the job supervisor's responsibility to obtain this information from the client representative immediately upon arrival at the job site and instruct his assigned crew accordingly.

6

Plot Plans Plans should be developed for each owned, leased or operated property which show the orientation of the structure on the property, the location of hazardous material storage, points of entry and egress, and the location of fire hydrants and fire extinguishers. The Plot Plans will be kept readily available, removed from the facility in the event of fire or explosion and provided to local Emergency Response Units. Responsibility for the development, custody and control of Plot Plans will be assigned to the Manager at Office Facilities and the Facility Manager at Power Plant Facilities.

7

Alarms, Whistles, Signals, Alerts Each facility will establish and maintain a method of communicating the occurrence of an emergency which requires action by (or the evacuation of) assigned personnel.

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Policy No:EHS-508

Emergency Response

The alarm system must be tested monthly to ensure proper operation and a written record of the test is to be maintained on site. These communications may be any audible signal or alarm that is sufficient to provide adequate warning to all locations within each facility. In some cases, communication by voice may be sufficient, depending on the size of the facility and its ambient noise level. The job supervisor immediately upon arrival at the site must determine alarms established by clients for the Field Locations and all assigned personnel must then be instructed in the characteristics of and the correct response to all emergency alarm signals. The following information (if applicable) shall be obtained and posted at each Field Location work site: • • • • • • • •

Fire Alarm (describe) Evacuation Alarm Signal (describe) All Clear Signal (describe) Alarm Boxes (note locations) Fire Extinguishers (note locations) Windsock (note location) Evacuation Route Assembly Area NOTE:

8

It is the responsibility of each Job Supervisor to ensure the above information is obtained, recorded herein, posted prominently, and that each member of the assigned crew is familiarized with this information during a pre-job safety orientation meeting and walk through.

General Procedures Immediately upon the sounding of an emergency alarm, all unnecessary work will cease and, time permitting; all unnecessary equipment will be shutdown or secured to prevent additional hazard sources. NOTE: Personnel assigned specific emergency shutdown duties will perform their assigned tasks. All personnel not assigned specific duties requiring their presence during the emergency will immediately proceed to evacuate the facility, utilizing routes specified and posted for their work site. All personnel will proceed directly to designated assembly points as soon as they have cleared the danger area. Managers and Supervisors shall gather all assigned personnel to obtain a head count to ensure all personnel present at the work site prior to the emergency are accounted for. Page 10

Policy No:EHS-508

Emergency Response

Supervisors shall provide a report of missing personnel to the senior company (or client) representative present at the assembly area, or to the Emergency Response Unit Officials present at the site. All personnel will remain in the assembly area until permission is specifically given to leave the assembly area or the emergency is declared secure by announcements made by the Emergency Response Officials, through the sounding of an "All Clear" signal, or through the senior company (or client) representative present.

9

Training All personnel must be trained on the alarm system established at his/her place of assignment. Annual Fire/Evacuation Drills will be conducted to ensure assigned personnel are familiar with Alarm Signals, Emergency Procedures, Evacuation Routes, and Assembly Areas. All assigned personnel will also receive training on the Fire Prevention Plan. New employees will be provided instruction on the Alarm Signals, Emergency Procedures, Evacuation Routes, and Assembly Areas during the first day of work at a facility. The Office Manager or Facility Manager / Supervisor, or designee, shall review the plan with each employee covered by the plan at the following times: • • •

Initially when the plan is developed, Whenever the employee's responsibilities or designated actions under the plan change, and Whenever the plan is changed.

All S&W Energy employees shall be trained on the requirements and guidelines of this procedure and on their Emergency Response / Action Plan specifically. Training is required annually.

10 Auditing / Inspections The Emergency Response Procedure shall be reviewed every two years. The procedure will be updated as necessary. The Emergency Action and Emergency Response Plans developed as a result of this procedure shall be reviewed every two years. The Plans will be updated as necessary and retraining conducted accordingly.

11 References 29 CFR 1910.38

Emergency Action & Fire Prevention Plans

29 CFR 1910.120

Hazardous Waste Operations and Emergency Response

29 CFR 1910.165

Employee Alarm Systems

Page 11

Environmental Health and Safety Manual Policy No. EHS-509

Policy Title: Fall Protection

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2 3 4 5 6 7 8 9 10

Purpose and Scope.................................................................................................. 2 Definitions ................................................................................................................ 2 Assessment and Control Options............................................................................. 4 Fall Protection System Categories ........................................................................... 5 Selection of Proper Fall Protection........................................................................... 5 Inspection, Maintenance, and Care.......................................................................... 9 Training .................................................................................................................. 10 Auditing / Inspections ............................................................................................. 10 References............................................................................................................. 10 Forms ................................................................................................................. 10

Page 1

Policy No:EHS-509

Fall Protection

1 Purpose and Scope This procedure provides the requirements and guidelines in regards to fall protection. The procedure provides requirements that ensure all S&W Energy Facilities or Sites identify and evaluate fall hazards around the workplace, to ensure there is proper selection and use of fall hazard controls, to ensure fall protection equipment is used, inspected and maintained, and to ensure all employees are given the appropriate level of training to perform work that involves fall protection. This procedure shall be used in combination with S&W Energy’s Personal Protective Equipment / Job Safety Analysis, Ladders and Scaffolding, and Walking and Working Surfaces procedures.

2

Definitions • • •

• • •

• • •

Anchor Point (“Tie-Off” Point) – Secure point of attachment for the connection device and fall protection system. Anchor points are typically beams or other similar sturdy support structures located above or at an even level with the user. Body Belt – A strap with means both for securing it about the waist and attaching it to a lanyard, lifeline or deceleration device. Body Harness – Straps that secure about the person in a manner that distributes the fall-arrest forces over at least the thighs, pelvis, waist, chest and shoulders with a means for attaching the harness to other components of a personal fall arrest system. Body Wear – Part of fall protection systems, the support equipment worn by the user performing the fall hazard work. Connecting Device (Connector) – Device used to connect the parts of a personal fall arrest system or positioning device system together. Deceleration Device – Any mechanism, such as a rope grab, shock-absorbing lanyard or self-retracting lifeline, which serves to dissipate a substantial amount of energy during the fall arrest, or otherwise limits the energy imposed on the employee during fall arrest. Deceleration Distance – The additional vertical distance a falling person travels, excluding lifeline elongation and free fall distance, before stopping. From the point at which a deceleration device begins to operate. Fall Arrest System – A system including, but not limited to an anchor point, connection device, and a body belt or harness used to arrest an employee in a fall from a working level. Fall Hazard – Any situation in which a fall from an elevated height could result in an injury. A fall hazard is present when: •



Work is conducted at unprotected heights at or exceeding four (4) feet above the lower level, such as unprotected sides or edges of a walking or working platform, floor or wall openings, ramps and other similar locations; or Work is conducted above dangerous equipment or processes at unprotected work heights below four (4) feet.

Page 2

Policy No:EHS-509



• • •

• •



• •

Fall Protection

Horizontal Lifeline – A connection device used in conjunction with an attached fall arrest device between the body wear and the anchor point. Typically flexible lifeline is suspended horizontally (keeping taut) between two fixed anchor points at a level even or above the user. Lanyard – A flexible line of rope, wire rope, or strap that generally has a connector at each end for connecting the body belt or body harness to a deceleration device, lifeline or anchor point. Positioning Device System – A body belt or body harness system rigged to allow an employee to be supported on an elevated vertical surface, such as a wall, and work with both hands free while leaning backwards. Retractable Lifeline – A self-contained device linking the body wear to the anchor point. The device acts as a continuously taut lanyard, allowing the user to travel varying distances and directions while still attached to a fall protection device. Rope Grab – A deceleration device that travels on a lifeline and automatically, by friction, engages the lifeline and locks to arrest a fall. Safety Lanyard – The connection device linking the body wear to the anchor point or as a connection device to a lifeline system. Typically safety lanyards are short lines made up of rope strap, webbing, cable, or similar materials with connectors on both ends. Snap-Hook – A connector consisting of a hook-shaped member with a normally closed keeper, or similar arrangement, which may be opened to permit the hook to receive an object and when released automatically closes to retain the object. Unprotected – For the purposes of this procedure, without standard guardrails or similar protection. Vertical Lifeline (Rope Grab) – A connection device used in conjunction with an attached fall arrest device, such as a rope grab, between the body wear and the anchor point. Typically, the flexible lifeline is suspended vertically from an anchor point overhead.

Fall hazards are present at any height. However, according to regulatory standards, fall hazards are present, as defined at 4 feet in general industry and 6 feet in construction. Because S&W Energy operates most of its Facilities as part of general industry, the minimum distance where fall protection is required is 4 feet and meets the criteria in the definition of a fall hazard. EACH SITUATION SHALL BE EVALUATED SEPARATELY TO DETERMINE PRESENCE OF A FALL HAZARD AND TO DETERMINE WHETHER OR NOT FALL PROTECTION SHALL BE REQUIRED.

Page 3

Policy No:EHS-509

3

Fall Protection

Assessment and Control Options

A. Fall Hazard Assessment A fall hazard assessment shall be conducted to identify the location and relative fall hazard associated for an activity. Management and employees shall work together to identify fall hazards within the work place. Fall hazards can include, but are not limited to the following: • • • • •

Work at unprotected heights exceeding 4 feet or above dangerous equipment or processes; Wall and/or floor openings; Employee elevating equipment; Railcars; and Ladders Tasks identified as fall hazards shall be documented by the Facility or Site on the Fall Hazard Assessment / Inventory form, provided in the Attachment section of this procedure. All locations requiring the use of fall protection will be labeled as such. An example sign or label reads as the following: “NOTICE – Fall Protection Controls Required”.

B. Fall Hazard Control Fall hazards identified shall be in controlled in one of two ways: eliminating the hazard or, if that is not possible or feasible, then utilize fall protection controls. When choosing fall hazard control options, elimination versus implementation and use of fall protection equipment, the following factors should be considered; • • • • • •

Probability of a fall, based on the conditions of the work location and the type of work to be conducted; Potential injury resulting from a fall; Frequency employees are exposed to a fall hazard; Number of employees exposed to the fall hazard; Feasibility and practicality of controlling the hazard; or Cost associated with controlling the hazard. If elimination is chosen, some methods to consider are providing guardrails for work platforms, providing guardrails or covers for floor or wall openings, or relocating equipment or controls to eliminate the need to access locations with fall hazards. If fall protection is chosen, ensure that all fall protection system consists of these three components: body wear, connecting device, and anchor point. When fall protection controls are selected, they shall be selected to provide proper protection for the employee, they shall be selected according to manufacturer’s recommendations, and they shall be selected by someone who is qualified and knowledgeable on fall protection equipment and use. Page 4

Policy No:EHS-509

Fall Protection

The Fall Protection Evaluation form should be completed for the fall hazard identified with the fall protection method (control of hazard). A sample form is provided in the Attachment section of this procedure. A photo is sometimes a good tool to use and provide with this evaluation. Please attach any photos to the evaluation form.

4

Fall Protection System Categories

When fall protection is selected as the means to control the fall hazard, there are four (4) different categories of fall protection systems available to use, depending on the application. The 4 systems are Fall Arrest, Positioning and Restraint, Suspension, and Retrieval. Choose the fall protection system that provides the best protection against a fall and/or an injury due to a fall hazard for the task or job specified. The Attachment section of this procedure provides detailed information on these four systems as a reference.

5

Selection of Proper Fall Protection

A functioning fall protection system must be designed not only to provide protection to the user but also to allow them the ability to perform the job task required without, or with minimal, limitations. A trained and qualified person must select fall protection. Good resources can either be a professional engineer (someone who can certify the proper design and rating) or the manufacturer’s representative. The trained and qualified individual must be able to provide information on the specific limitations, use, inspection and maintenance or each component and the system. It is important to ensure the proper fall protection is selected for each individual situation, which involves evaluating many different factors. Some factors to consider when selecting the fall protection system for the job are as follows: • • • • • • • • • • •

Severity and magnitude of the fall hazard; Number and frequency of employees exposed to the fall hazard; Permanent or temporary fall hazard; Need for user mobility (vertical vs. horizontal) to perform the task; Location of fixed anchor points or availability of temporary anchor points; Safe falling distances available above the lower level or equipment accounting for free fall and deceleration distance; Potential for user to swing into other hazards in the event of a fall; Manufacturer’s use limitations for the fall protection equipment and components; Work being performed increasing the potential for a fall (i.e., on a narrow ledge, unstable work platform, etc.); Environmental conditions increasing the potential for a fall (i.e., rain, snow, high wind, slippery surfaces, etc.); and Rescue required in the event of a fall.

Page 5

Policy No:EHS-509

Fall Protection

The various fall protection systems have selected limitations and are suited for defined use applications. Use the table below as a guideline when selecting the proper fall protection system: Fall Protection System Fall Arrest

Positioning

Recommended:

Typical Applications:



Any potential for falls from an • elevated height • • •



Work in a fixed position with accessible anchor points Minimal potential for free fall (less than 2 feet) No exposure to the fall hazard (within 6 feet) No potential for free fall Access only from above

• Restraint



Suspension

• •

Retrieval



• • • • •

User removal from above the • working area

Working on elevated platforms or work surfaces Working on top of rail cars Climbing on fixed ladders In conjunction with positioning, restraint and suspension systems Cleaning windows from a window ledge Working on rebar structure Work performed on a roof or ledge structures Window washers and painters Suspension into a tank or other structure Confined space entry

The following guidelines, precautions, and facts about the three (3) fall protection components should be reviewed prior to selecting and/or using fall protection equipment: •

Body wear typically consists of a full body harness but it can also be a safety belt or chest harness where conditions warrant. It is most commonly made of nylon, polyester or similar webbing material. The recommended body wear is the full body harness.

The full body harness suspends the victim (who has fallen) in an upright position while waiting for assistance. For these reasons, it is recommended to use safety belts ONLY in conditions with little or no potential for free falls. The physical shocks to the midsection or suspension from a body belt are not desirable in the event of a fall and can cause serious injury.

Page 6

Policy No:EHS-509



The following table describes the recommended applications for two types of body wear:

Fall Protection: Full Body Harness

Fall Protection: Safety Belt

Recommended:

Not Recommended:

• •



• • • • • • • •

Any potential for free fall Use within manufacturer’s limitations

Use outside manufacturer’s limitations

Recommended:

Not Recommended:

• •

• •

• • •

Fall Protection

No potential for free fall Positioning or restraining protection only Use within manufacturer’s limitations

Any potential for free fall Use outside manufacturer’s limitations

All connection devices must have a minimum strength of 5,000 pounds per user. Most lanyards have shock-absorbing features to provide additional force reduction (up to 80%) in the event of a fall. Shock-absorbing lanyards may not be applicable in all situations, particularly where fall distances are minimized. Safety lanyards should not be attached to a retractable lifeline since they may add additional free fall distance to the overall system. Retractable lifelines give the user the ability to move in various directions within safe working distances of the lifeline. Vertical lifelines give the user the ability to move limited horizontal distances and different vertical heights when the system is adjusted. Only one user is allowed per vertical lifeline, since a fall by on user would shock the lifeline and potentially cause other users on the same system to fall. Horizontal lifelines give the user the ability to move horizontally the length of the lifeline. Lifelines should not be wrapped directly around the support structure. The recommended applications for connecting devices are outlined in the table below:

Fall Protection: Shock Absorbing Lanyard

Recommended: •



Not Recommended:

• Adequate height above the lower level to accommodate the deceleration distance (expansion) of the lanyard • Use within manufacturer’s limitations •

Page 7

Inadequate height above the lower level to accommodate the deceleration distance (expansion) of the lanyard Use with retractable lifeline Use outside manufacturer’s

Policy No:EHS-509

Fall Protection

limitations Fall Protection: Safety Lanyard (non-shock absorbing)

Recommended:

Not Recommended:



Potential for only minimal free fall Inadequate height to the lower level to accommodate the deceleration distance (expansion) of the lanyard Use within manufacturer’s limitations Anchor point available overhead Swing from the fall will not direct the user into other structures or hazards Adequate height to the lower level to accommodate the deceleration distance of the retractable lifeline Use requires horizontal and/or vertical travel Use within manufacturer’s limitations Anchor point available overhead Swing from the fall will not direct the user into other structures or hazards User requires no or limited horizontal or vertical travel Single user on the system Use within manufacturer’s limitations



Anchor point available at each end of the work area User requires frequent horizontal travel Multiple users on the system (provided the proper rating) Use within manufacturer’s





• Retractable Lifeline

• • •

• • Vertical • Lifeline (Rope Grab) • • • •

Horizontal Lifeline

• • • •

Page 8



• • •



• • • • •

• •

Potential for moderate to maximum free fall Use outside manufacturer’s limitations

No anchor point available overhead Swing from the fall will direct the user into other structures or hazards Inadequate height to the lower level to accommodate the deceleration distance of the retractable lifeline Use outside manufacturer’s limitations

No anchor point available overhead Swing from the fall will direct the user into other structures or hazards User requires frequent horizontal and vertical travel Multiple users on the same system Use outside manufacturer’s limitations No anchor point available at each end of the work area User requires frequent vertical travel Use outside manufacturer’s limitations

Policy No:EHS-509

Fall Protection

limitations • • • •

Anchor points positioned above the user reduce the distance of free fall. Area of anchor point shall be free of rough or sharp edges that can cause damage to the connector or lifeline. The connection to the anchor point should be a direct connection with a locking device (snap-hooks with spring loaded keeper, cross arm strap, eyebolt) to properly secure the connection device. Knots are not permitted as a means to tie off, since they reduce the support strength.

When selecting or designing fall protection systems, it is important to remain clear of electrical hazards. Under certain circumstances, fall protection equipment may be electrically conductive and possible cause electric shock or electrocution.

6

Inspection, Maintenance, and Care

All fall protection equipment shall be inspected to ensure the equipment is properly functioning. Inspection frequency will depend upon type of use, frequency of use, and date/age of the equipment. Equipment should not go more than 3 months without being inspected. Although thorough inspections are required at least every quarter (3 months), a pre-use inspection shall be conducted on all equipment prior to each use. Use manufacturer’s recommendations on frequency of inspection

Use the following as basic fall protection equipment inspection criteria: • • • • • •

Inspect body wear webbing, harnesses and safety lanyards for cuts, burns, chemical damage, abrasions, stretching, frayed fibers or edges, pulled stitches or other signs of wear. Inspect body wear buckles, D-rings, and safety lanyard hardware for proper function, elongation, distortion, loose components, rust, cracks, free movements or other signs of wear or malfunctioning. Inspect the spring-loaded keeper on the locking snap-hooks for proper functioning, seating and spring closure. Inspect the shock absorber of shock lanyard for any signs of wear affecting the functioning of the absorber, for signs of elongation, deployment or the warning flag. Inspect ropes and cables for cuts, burns, chemical damage, abrasions, stretching, frayed fibers or edges, pulled stitches or other signs of wear. Inspect for proper functioning of mechanical fall protection components (retractable lifelines, winches, etc.)

Page 9

Policy No:EHS-509



Fall Protection

Inspect anchor points for cracks, rusting or other signs of support deterioration and inspect for secure attachment.

Any fall protection equipment found to be defective shall be removed from service immediately until replaced or repaired. All fall protection equipment will be cleaned and maintained in a good working order following each use. Follow manufacturer’s recommendations for maintenance and storage of fall protection equipment.

7

Training

All S&W Energy Facility or Site employees (including Field personnel) who will be involved with assessment of fall hazards in the workplace, using fall protection, and/or inspecting fall protection equipment, shall be trained on the requirements and guidelines of this procedure (initially). Refresher training is required every 2 years. The training must be site-specific and include the following elements: • • • • • • •

Types of general fall hazards; Identification of site specific fall hazards; Means to eliminate or minimize fall hazards; Types of fall protection used on site; Limitations of fall protection; Use and care of fall protection; and Inspection of fall protection

Fall protection should be a combination of classroom and hands-on training. Since misuse of equipment can result in serious injury or even death, it is extremely important that employees are able to physically demonstrate their ability to properly use the equipment as well as understanding the basic fundamentals.

8

Auditing / Inspections

Fall protection equipment shall be inspected daily or prior to each use to ensure they are free of defects and not damaged. If not used as often, equipment shall be inspected at least every 3 months. The Fall Protection Procedure shall be reviewed every 2 years. This procedure will be updated as necessary.

9

References

29 CFR 1910.21 to 29 CFR 1910.30

Subpart D, Walking-Working Surfaces

29 CFR 1910.269

Electrical Power Generating Facilities

10 Forms See Appendix O

Page 10

Policy No:EHS-509

Fall Protection

O.1 - Fall Hazard Assessment / Inventory O.2 - Fall Protection Evaluation Form

Page 11

Environmental Health and Safety Manual Policy No. EHS-510

Policy Title: Powered Industrial Trucks

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2 3 4 5 6 7

Purpose and Scope.................................................................................................. 2 Definitions ................................................................................................................ 2 Fork Truck Requirements and Guidelines................................................................ 3 Training .................................................................................................................... 6 Auditing / Inspections ............................................................................................... 8 References............................................................................................................... 8 Forms....................................................................................................................... 8

Page 1

Policy No:EHS-510

Powered Industrial Trucks

1 Purpose and Scope The purpose of this procedure is to provide the requirements for the operation and maintenance of industrial powered trucks (i.e., fork trucks, forklifts, etc.). It also establishes the required training for personnel assigned to operate the trucks and includes general design criteria for a majority of the industrial powered trucks commonly found and operated at S&W Energy Facilities or Work Sites. The requirements and design specifications of this procedure apply to fork trucks, tractors, platform lift trucks, motorized hand trucks, or other specialized industrial trucks powered by electric motors or internal combustion engines. This procedure does NOT apply to compressed air or non-flammable compressed gas-operated industrial trucks nor does it apply to vehicles intended primarily for earth moving or over-the-road hauling.

2 • • • • •



• • •

Definitions Approved Industrial Truck – A truck that is listed or approved for fire safety purposes for the intended use by a nationally recognized testing laboratory, using nationally recognized testing standards. Class I (Atmosphere) – Locations in which flammable gases or vapors are, or may be present in the air in quantities sufficient to produce explosive or ignitable mixtures. Class II (Atmosphere) – Locations that are hazardous because of the presence of combustible dust. Class III (Atmosphere) – Locations where easily ignitable fibers or filings are present but not likely to be in suspension in quantities sufficient to produce ignitable mixtures Competent (Qualified) Trainer - For purposes of this procedure, a person with the knowledge, training, and experience to train powered industrial truck operators and evaluate their competence. An example of a Competent (Qualified) Trainer is a person who, by possession of a degree, certificate, or professional standing, or who by extensive knowledge, training, and experience has demonstrated the ability to train and evaluate powered industrial truck operators. Designations – Describes the different classifications of powered industrial trucks based on type of fuel used to power and specific areas or “atmospheres” most suitable for operation. Refer to the Attachment section in this procedure which includes the eleven different designations and brief descriptions of each. Mast – The upright section of a forklift that contains a set of tracks that house ball bearings, rollers and chains. It tilts forward or backward and may shift from side to side. Overhead Guard(s) – Keeps falling objects from hitting the operator but is not strong enough to withstand the force of a heavy load. Operators – Any employee properly trained, according tom this procedure, to use a powered industrial truck and whose job responsibilities include truck operation.

Page 2

Policy No:EHS-510





Powered Industrial Trucks

Powered Industrial Truck – Any mobile powered-propelled truck used to carry, push, pull, lift, stack or tier materials. They can be ridden or controlled by a walking operator. In this procedure, Powered Industrial Trucks may be referred to as fork trucks, fork lift, or just truck. Unattended – When the operator is 25 feet or more away from the vehicle which remains in view or whenever the operator leaves the vehicle and it is not in view.

All users of Powered Industrial Trucks (fork trucks) shall ensure that it is approved and bears some label or other identifying mark indicating approval by the testing laboratory.

3

Fork Truck Requirements and Guidelines

A. General The user of an industrial truck shall ensure that all nameplates and markings are in place and are maintained in legible condition. No user or customer shall modify or make additions to the industrial truck which affects capacity and safe operation WITHOUT the manufacturer’s prior written approval. All markings shall be changed accordingly, if so modified. The atmosphere or location where the industrial powered truck is to be used shall be classified as hazardous or non-hazardous prior to the consideration of the type of truck to be used. For those industrial powered vehicles that require battery changing and charging the following guidelines and requirements apply: • •

There shall be a designated area for battery charging. Facilities or Sites shall be equipped for flushing and neutralizing spilled electrolyte, for fire protection, and for adequate ventilation for fumes generated during gassing of batteries. • When charging batteries, acid shall be poured into water; water shall NOT be poured into acid. • Trucks shall be securely positioned and brake applied before attempting to charge or change battery. • Care shall be taken to assure that vent caps are functioning. • Smoking shall be prohibited in the charging area. • Precautions shall be taken to prevent open flames, sparks, or electric arcs in the battery charging areas. • Metallic objects shall be kept away from the top of uncovered batteries. B. Truck Operations No person shall be allowed to stand or pass under the elevated portion of any fork truck, whether loaded or empty.

Page 3

Policy No:EHS-510

Powered Industrial Trucks

Unauthorized personnel shall not be permitted to ride on powered industrial trucks. If powered industrial vehicle is equipped with seat belts, employer and operator shall ensure they are properly functioning and operator must wear them during use. Arms and legs are prohibited from being placed between the uprights of the mast or outside the running lines of the truck. When a truck is left unattended, load engaging shall be fully lowered, controls shall be neutralized, power shall be shut off, and brakes set. Wheels shall be blocked if parked on an incline. A safe distance shall be maintained from the edge of ramps or platforms while on an elevated dock or platform. Trucks shall not be used for opening or closing of doors. Brakes shall be set and wheel blocks in place to prevent movement of trucks while loading or unloading. In areas where fork trucks are used, there shall be sufficient headroom under overhead installations (i.e., lights, pipes, sprinkler systems, etc.) to prevent damage or accidents. An overhead guard shall be used as protection against falling objects. Only approved industrial trucks shall be used in hazardous locations (Reference the Truck Designation / Location Classifications in the Attachment section of this procedure) If a truck is equipped with vertical and/or horizontal controls elevatable with the lifting carriage or forks for lifting personnel, the following additional precautions shall be taken for the protection or personnel being elevated: • • •

Use of a safety platform firmly secured to the lifting carriage and/or forks; Means provided whereby personnel on the platform can shut off power to the truck; Protection from falling objects, as necessary

Fire aisles, access to stairways, and fire equipment shall be kept clear. If the truck for any reason is in need of repair, defective, or in any way unsafe, the truck shall be taken out of service until it has been restored to safe operating condition. Authorized personnel shall make all repairs. Fuel tanks shall not be filled while the truck is running. Spillage shall be avoided and spilled fuel shall be washed away or properly cleaned-up and the tank cap replaced before restarting the engine. No truck shall be operated with a leak in the fuel system until the leak has been corrected.

Page 4

Policy No:EHS-510

Powered Industrial Trucks

C. Traveling All traffic regulations shall be observed including Facility or Site speed limits. Under all travel conditions, the truck shall be operated at a speed that will permit it to be brought to a stop in a safe manner. Other trucks traveling in the same direction shall not be passed at intersections, blind spots, or other dangerous locations. The driver is required to slow down and sound the horn at cross aisles and other locations where vision is obstructed The driver is required to look in the direction of and keep a clear view of the path of travel. Grades shall be ascended and descended slowly. • •

When ascending and descending grades in excess of 10%, loaded trucks shall be driven with the load upgrade. On all grades, the load and load engaging means shall be tilted back if applicable and raised only as far as necessary to clear the road surface.

Stunt driving and horseplay shall not be permitted. Dockboards and bridgeplates shall be properly secured before they are driven over and their maximum rated capacity never exceeded. Elevators shall be entered squarely. Once on the elevator, the controls shall be neutralized, power shut off, and brakes set. Motorized hand trucks must enter the elevator with load end forward. D. Loading Only stable and safely arranged loads shall be handled. Caution shall be exercised when handling off-center loads which cannot be centered. Only loads within the rated capacity of the truck shall be handled. Trucks equipped with attachments shall be operated as partially loaded trucks when not handling a load. A load engaging means shall be placed under the load as far as possible; the mast shall be carefully tilted backward to stabilize the load. An elevated load shall not be tilted forward except when the load is in the deposit position over a rack or stack. Tilting forward with load engaging means tilted is prohibited except to pick up a load. E. Maintenance Authorized personnel shall make all repairs. No repairs shall be made in Class I, Class II, or Class III locations. Trucks in need of repair to the electrical system shall have the battery disconnected prior to repair.

Page 5

Policy No:EHS-510

Powered Industrial Trucks

All parts replaced shall be equivalent as to the design and safety with those of the original parts. Trucks shall not be altered either in regards to relative positions of various parts from the original design or relative to the addition of extra parts not provided by the manufacturer UNLESS it is approved by the manufacturer and altered by authorized personnel. Additional counterweighing of fork trucks shall not be done unless approved by the manufacturer. Fork trucks shall be examined before being placed into service. Such examination shall be made daily or prior to each use. An example checklist is provided in the Attachment section of this procedure. Checklists shall be maintained on file along with records of alterations or repairs, testing results, or other manufacturer’s information pertinent to the safe operation and maintenance of the fork truck.

Fork Trucks and other powered industrial vehicles shall be inspected DAILY or prior to each use. Checklists shall be maintained on file. Any vehicle that emits hazardous sparks or flames from the exhaust system shall immediately be removed from service and not returned to service until the cause for emission of sparks or flames has been eliminated. When the temperature of any part of any truck is found to be in excess of its normal operating temperature, creating a hazardous atmosphere, the vehicle shall be removed form service until the cause of such overheating is eliminated. Trucks shall be kept in a clean condition. Non-combustible agents shall be used for cleaning trucks.

4

Training

Employers must develop and implement a training program. The employer shall ensure that each powered industrial truck operator is competent to operate such a vehicle safely as demonstrated by the successful completed training and evaluation specified in this section. Training shall consist of a combination of formal instruction (i.e., lecture, discussion, video tape, etc.), practical evaluation (demonstrations performed by the trainer and exercises performed by the trainee) and evaluation of the operator’s performance in the workplace. All operator training and instruction shall be conducted by persons who have the knowledge, training, and experience to train powered industrial truck operators and evaluate their competence (a Competent Qualified Trainer). As a standard part of training, all operators shall be trained in the following topics (unless demonstrated that they do not apply in the workplace). These are the minimum requirements for the formal instruction portion of fork truck training: Page 6

Policy No:EHS-510

• • • • • • • • • • • • • • • • • • •

Powered Industrial Trucks

Operating instructions, warning, and precautions for the types of truck the operator will be authorized to operate; Truck controls and instrumentation: where they are located, what they do and how the work; Engine or motor operation; Steering and maneuvering; Visibility including restrictions due to loading; Fork and attachment adaptation, operation, and use limitation; Vehicle capacity; Vehicle stability; Vehicle inspection and maintenance that the operator will be required to perform; Refueling and/or recharging of batteries; Operating limitations; Typical and possible surface conditions where the vehicle will be operated; Composition of loads to be carried and load stability; Load manipulation, stacking and unstacking; Pedestrian traffic in areas where the vehicle will be operated; Various types of truck designations and classifications; Hazardous (classified) areas where the vehicle will be operated; Ramps and other sloped surfaces that could affect the vehicle’s stability; Closed environments where the build-up of noxious gases (i.e., carbon monoxide) could become an issue.

As a standard part of training, all operators shall be evaluated on performance of operating the powered industrial truck taking into consideration the topics discussed in the formal instruction. This is the minimum requirement for the practical evaluation portion of the fork truck training. Practical evaluation can be determined in any one of the following ways (Reference Sample Evaluation in Attachment Section). • • •

A discussion with the employee; An observation of the employee operating the powered industrial truck; A performance test

No tests (i.e., quizzes) are required. However, the employer or trainer MUST verify competency through some method of evaluation. Records verifying operator training may be requested during an audit. Sample quizzes are provided in this procedure which may be used. To verify completed training, the employer shall certify that each operator has been trained and evaluated as required. The certification shall include the name of the operator, the date of the training, the date of the evaluation, and the identity of the person performing the training or evaluation. Training certifications shall be maintained on file until the next certification is given.

Page 7

Policy No:EHS-510

Powered Industrial Trucks

An evaluation of each truck operator’s performance shall be conducted at least once every three years. Refresher training shall be conducted as often as required below or at least every three years (and include the same material as initial training): • • • • •

Whenever the operator has been observed to operate the vehicle in an unsafe manner; Whenever the operator has been involved in an accident or near-miss incident; When the operator has received an evaluation that reveals that he/she is not operating the truck safely; When the operator is assigned to operate a different type of truck; or When a condition in the workplace changes in a manner that could affect safe operation of the truck.

Trainees, who are not fully trained per the regulatory requirements and certified, may operate a powered industrial vehicle ONLY: • •

5

Under the direct supervision of persons who have the knowledge, training and experience to train operators and evaluate their competence. Where such operation does not endanger the trainee or other employees.

Auditing / Inspections

The Powered Industrial Trucks (Fork Truck Safety) Procedure shall be reviewed every 2 years. Safety checklists and training records will be reviewed as part of this procedure audit. The procedure will be updated as necessary.

6

References

29 CFR 1910.178

Powered Industrial Trucks

ANSI B56.1-1969

National Standard for Powered Industrial Trucks

7

Forms

See Appendix P P.1 - Fork Truck Designations P.2 - Sample Daily Fork Truck Maintenance Checklist P.3 - Sample Fork Truck Evaluation Test

Page 8

Environmental Health and Safety Manual Policy No. EHS-511

Policy Title: Electrical Safety

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2 3 4 5 6 7 8

Purpose and Scope.................................................................................................. 2 Definitions ................................................................................................................ 2 General Procedure / Requirements.......................................................................... 4 Grounding ................................................................................................................ 9 Electrical Equipment Locations .............................................................................. 10 Training .................................................................................................................. 11 Auditing / Inspections ............................................................................................. 11 References............................................................................................................. 11

Page 1

Policy No:EHS-511

Electrical Safety

1 Purpose and Scope The purpose of this procedure is to provide policy and guidance to ensure that safe electrical work practices are followed in S&W Energy facilities or on job sites where S&W Energy employees are working. When it is necessary to perform work in an area where there is likely to be exposure to energized circuits or electrical hazards, the special precautions included in this procedure must be followed. This procedure pertains to all those employees working on electrical equipment or in and around areas where electrical hazards may be present. They shall be trained to recognize and/or avoid hazards to which they will or may be exposed. This procedure shall be used in conjunction with the S&W Energy Lock-Out / Tag-Out (LOTO) Procedure.

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• • • •

Definitions Affected Employee – An employee whose job requires him or her to operate or use a machine or piece of equipment on which servicing or maintenance is being performed under LOTO, or whose job requires him or her to work in an area in which such servicing or maintenance is being performed. Alternating Current (A-C) – Current which reverses its direction of flow at regular intervals. Ampacity – The current carrying capacity for electrical conductors measured in amperes. Bond – The electrical interconnection of conductive parts designed to maintain a common electrical potential. Bus – A conductor or group of conductors that serve as a common connection for two or more circuits. Circuit – A conductor or system of conductors through which an electrical current is intended to flow. Conductor – A material, usually in the form of a wire, cable or bus bar, used for carrying an electric current. Deenergized – Free of from any electrical connection to a source of potential difference and from electric charge; not having a potential different from that of the earth. (This term is used only in reference to current carrying parts, which are sometimes energized or live). Designated Employee – An employee who is designated to perform specific duties under the terms of this procedure and who is knowledgeable in the construction and operation of the equipment and the hazards involved. Direct Current (D-C) – Current which flows in one direction. Enclosed – Surrounded by a case, housing, fence, or walls which will prevent persons from accidentally contacting energized parts. Energized (Alive or Live) – Electrically connected to a source of potential difference, or electrically charged so as to have a potential significantly different from that of the earth in the vicinity.

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Policy No:EHS-511

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• • • • • • •

• • •

Electrical Safety

Energy Source – Any electrical, mechanical, hydraulic, pneumatic, chemical, nuclear, thermal, or other energy source that could cause injury to personnel. Exposed Parts – For live (energized) parts, capable of being accidentally touched or approached closer than a safe distance by a person; for wiring methods, on or attached to the surface or behind panels which allow access; and for communication systems, circuits in such a position that failure of the supports or insulation will cause contact with another circuit. Ground – A conducting connection, whether intentional or accidental, between an electric circuit or equipment and the earth, or to some conducting body that serves in place of the earth. Ground Fault – A condition in which the fault current to ground is greater than the predetermined value for the circuit. Ground Fault Circuit Interrupter (GFCI) – A device whose function is to interrupt the electric circuit to the load when a fault current to ground exceeds some predetermined value that is less than that required to operate the overcurrent protection device of the supply circuit. Grounded – Connected to earth or to some other conducting body that serves in place of the earth. Guarded – Covered, fenced, enclosed, or otherwise protected, by means of suitable covers or casings, barrier rails or screens, mats, or platforms, designed to minimize the possibility, under normal conditions, of dangerous approach or accidental contact by persons or objects. High Voltage – Nominal voltages equal to 600 Volts or above. Impedance – The reactance and resistance which opposes the flow of current in an AC circuit. Inductance – the property of electrical circuit which produces an electromotive force by the variation of the current in the circuit itself or a neighboring circuit. Insulated – Separated from other conducting surfaces by a dielectric (including air space) offering a high resistance to the passage of current. Low Voltage – Nominal voltages of below 600 Volts. Nominal Voltage – Voltage value assigned to a circuit or system to designate the voltage class (service), such as 120/240 and 600. Portable Electric Tools – Equipment includes portable appliances, tools, hand lamps, appliances, and other portable apparatus that are connected by cord and plug. Majority of Portable Electric Tools, used in this procedure, have 120 Volt / 60 Hertz motors. Overcurrent – A condition in which the current is greater than the rate current of the equipment or the ampacity of the conductors. Overcurrent can result from overload, short circuit, or ground fault. Overload – A condition in which the equipment is operated in excess of its normal full load, or conductor is operated in excess of its rated ampacity. Qualified Employee – A person knowledgeable in the equipment involved and hazards associated with the work task, as applicable to the construction or operation of electric power generation, transmission or distribution activities and or equipment. There are specific requirements to become a Qualified Employee: Page 3

Policy No:EHS-511

• • •

Electrical Safety

Have the skills and techniques necessary to distinguish live parts from other parts of electrical equipment; Have the skills and techniques to determine nominal voltage of exposed live parts; and Know the clearance distances required (in the regulations) and the corresponding voltages

In addition, a Qualified Employee is: •

A person who must have the appropriate training per regulatory standards; and

An employee who is undergoing on-the-job training and who, in the course of such training, has demonstrated the ability to perform duties safely at his or her level of training and who is under the direct supervision of a qualified person is considered to be qualified for the performance of those duties. Retraining is required before performing tasks that are completed at intervals greater than once per year. •

Short Circuit – A path of a circuit, which drops from its normal resistance to very low resistance. Voltage – The effective potential difference between any two conductors or between a conductor and ground. Voltages are expressed in nominal voltages unless otherwise indicated. The operating voltage of the system may vary from this value. Working Clearances – Authorizations to perform specified work or permission to enter a restricted area.

• •

All repair and maintenance work on electrical equipment shall be performed by trained and authorized personnel only (QUALIFIED EMPLOYEE).

3

General Procedure / Requirements

Where work requires employees to work on or near exposed circuit parts or equipment, and there is danger of injury due to electrical shock, unexpected movement of equipment, or other electrical hazards, the circuit parts and equipment that endanger the employees shall be deenergized and locked- and tagged-out in accordance with S&W Energy’s Lock-Out / Tag-Out procedure.

Only Qualified Persons may work on equipment or circuits that have NOT been deenergized.

Page 4

Policy No:EHS-511

Electrical Safety

When it is not feasible to deenergize and lock or tag out electrical circuits and equipment, employees are permitted to work on or near exposed energized electrical equipment (conductors and circuit parts), provided the appropriate safety related work practices are implemented for the voltage level of the exposed electrical equipment. Permission for this work must be granted by the Facility or Site Manager, or designee. In no situation or at any time shall a S&W Energy employee be authorized to work on or near energized circuit parts or equipment when the voltage level exceeds 600 volts, nominal due to extreme dangers associated with and the lack of frequent experience working on high voltage systems. In these situations, a licensed electrical contractor must be used. A. Notify all personnel concerned or affected before starting any electrical equipment. B. Always assume a circuit is “hot” until you have checked it. Watch for any loose wires. C. Employees shall be thoroughly familiar with emergency trip switches. D. Interlocks and safety devices shall be maintained in a safe and operable condition. No interlock or other safety device shall be modified tom defeat its function except for repair or adjustment. E. Always remove the load from a circuit before pulling the switch. In addition, always close panel doors on switches before they are turned on. F. Ventilate the working area well and keep fires and sparks away from charging batteries since the acid fumes could ignite and explode. Always remember that hydrogen gas is generated while charging a battery. G. All employees shall know the proper type of fire extinguisher to use when a fire occurs of electrical nature. Know where these fire extinguishers are located. NEVER USE WATER ON AN ELECTRICAL FIRE. H. Employees shall not be permitted to work in areas where they are likely to encounter electrical hazards UNLESS they have been trained on and are fully aware of the general safe work practices specified below: • • •



Alertness of Employees - Employees should not knowingly be permitted to work on or near energized circuits when their alertness is recognizably impaired due to illness, fatigue or other reasons. Proper Lighting - Employees must not enter spaces containing exposed electrical parts unless adequate illumination is provided. Employees shall not reach blindly into areas which may contain energized equipment. Space Considerations - When work near exposed electrical equipment is in an area such that the space confinements is a safety concern, special consideration must be given to the number of employees working in the area and the amount of equipment at the scene so as not to interfere with safe passage near exposed circuits. Working Clearances - Safe distances (and working clearances) shall not be less than indicated in the Tables, included in the Attachment Section of this procedure, while working on or near live circuit parts. Distances shall be Page 5

Policy No:EHS-511

Electrical Safety

measured from the live parts if such parts are exposed or from the enclosure front opening if such are enclosed. • Housekeeping and Janitorial Duties - Housekeeping and janitorial duties must not be performed adjacent to exposed energized electrical parts where such parts present an electrical safety hazard, unless adequate precautions are taken. (Water, steam, conductive cleaning fluid, steel wool, or metalized cloth are examples of materials not suitable for use in the vicinity of energized components unless procedures are followed to prevent electrical contact). • Overhead Lines – When work is performed in areas where energized overhead lines are not guarded, isolated, or insulated, precautions must be taken to prevent employees from contacting such lines directly (through the body) or indirectly (through conductive tools or equipment). Again, reference the Tables in the Attachment Section of this procedure for required and recommended Approach Distances and Working Clearances. I. Employees shall be safeguarded from injury by utilizing appropriate personal protective gear and equipment / tools while working in situations in which there are potential electrical hazards. These include, but are not limited, to the following: •

Flame-Resistant Clothing – Flame-resistant clothing should be worn by all electrical workers because of the electrical hazards they face. A full body NOMEX suit is recommended wear. Employees exposed to electrical hazards SHALL NEVER wear fabrics which contain the following fabrics, either alone or in blends: • • • •

Acetate; Nylon; Polyester; or Rayon

Some fabrics specifically designed for use in protective clothing include flame-retardant materials, synthetic materials, synthetic-cotton blends, and 100% cotton. Avoid WOOL clothing, as wool produces cyanide gas when it burns. All protective equipment shall be inspected prior to each use, shall be tested annually, and shall be maintained and stored in a safe, reliable condition. •

Conductive Apparel - Conductive articles of jewelry and clothing such as watch bands, bracelets, rings, necklaces, key-chains, metalized aprons, belt buckles, or metal headgear shall not be worn where such items present an electrical contact hazard with exposed energized parts. They can be worn ONLY IF they can be rendered nonconductive by covering, wrapping, or using some other effective means of insulation.

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Policy No:EHS-511









Electrical Safety

Eye and Face Protection – Suitable eye and face protection shall be worn for voltage in excess of 300 volts, nominal and when performing work on exposed energized parts of equipment where there is a danger of injury to the eyes and face from electric arc or flashes. Headgear – Electrical workers must wear nonconductive head protection whenever they could be exposed to the danger of contacting energized parts or equipment. Check hardhats to ensure proper rating (conforming to ANSI Z89.2, Class E Hard Hat.) Footwear – Workers must wear some type of footwear that protects them against accidental electric current when working near energized parts. Over shoe styles include boots, rubbers, and galoshes. Shoes with shock resistant soles are the most common. Shoes shall be inspected to ensure integrity prior to working near energized parts. Electrical Safety Gloves – When working on or near low-voltage, energized electrical parts, rubber gloves are required. (See Table below for glove classes according to voltage rating). Whenever rubber gloves are used, they shall be protected by outer leather or canvas gloves. In addition, rubber gloves shall be air tested prior to each use (i.e., check inside and out for breakdowns, punctures, cracks, and/or cuts).

Class of Insulating Item 00 0 1 2 3 4

Voltage Rating 500 1,000 7,500 17,000 26,500 36,000

Typical Color Beige Red White Yellow Green Orange

NOTE: Never use Rubber Gloves for Voltages greater than the rated Voltage. Leather gloves DO NOT provide protection from electrical currents. Leather gloves should be worn OVER rubber gloves to protect the rubber from cuts, abrasions, etc. and shall NEVER be used IN PLACE of rubber gloves regarding electrical work.

Bare Hand Work is PROHIBITED on ANY circuit over 50 volts.



Ladders – Metal ladders and scaffolds are electric conductors; they should never be used around electric circuits or in place where they can come in contact with electrical circuits. Portable ladders and scaffolds shall be of nonconductive type only.

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Policy No:EHS-511



• •

• •



Electrical Safety

Insulated Tools - Employees must use suitable insulated tools or handling equipment where it is possible for these items to make contact with energized equipment or parts. This type of protective equipment helps insulate electrical workers from flashover, shock, and burn hazards. Insulated tools are designated as “secondary” protective devices and must be used in conjunction with appropriate personal protective gear, NOT IN PLACE OF IT. Electrical Safety Matting, Blankets, and Protective Barriers – Protective shields, barriers or insulating materials (suitable for the voltage rating of the equipment) shall be used to prevent electrically induced injuries for voltages in excess of 300 volts, nominal and when employees are working in the vicinity of exposed energized parts when the possibility of heating or arcing is likely. Insulating blankets are a “secondary” source of worker protection. Blankets must be tested before they are initially used and annually thereafter. If they are damaged in any way, blankets must be taken out of service immediately. Permanent Rubber Matting – Permanently installed rubber insulated floor matting (suitable for the voltage rating of the equipment) shall be installed in switchgear rooms, motor control centers, and all other applicable locations to provide continuous protection from any electrical safety hazards that exist. In outdoor motor control centers where permanent installation is not possible, the rubber matting shall be readily accessible. Hot Sticks (Shotguns) – Used on Live Lines, these insulated sticks of reinforced fiberglass, epoxiglass, or wood are considered “live-line tools” and are used to energize or deenergize the elements of conductors or parts associated with electrical equipment. They are typically used to help maneuver and shift pieces of equipment of provide the proper working clearances and distances with its extended reach. Workers must still use gloves when using Hot Sticks.

J. To alert other employees that there are exposed energized parts or components in the area, the following alerting methods shall be used, as required and feasible: • •



Safety signs and tags shall always be used to warn employees that there are potential hazards in the area. Barricades shall be used in conjunction with safety signs when it is necessary to prevent or limit personnel access to work areas where the possibility of exposure to exposed energized conductors is highly likely. Metal barricades must not be used in these situations. Manual signaling shall be used when work areas prevent signs and barricades from being effective alert measures.

K. Only employees who have a thorough knowledge of working safely with test instruments and equipment on energized circuits shall be permitted to perform testing work on electronic circuits or equipment where there is danger of injury due to accidental contact with energized parts or improper use of test equipment.

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Policy No:EHS-511

Electrical Safety

Test instruments and equipment and all associated test leads, cables, power cords, probes, and connectors shall be visually inspected for external defects or damage before each use. If damaged in any way, the equipment shall not be sued until replaced or repaired. Test instruments and their accessories shall be rated for the circuits and equipment to which they will be connected and must be suitable for the environment in which they will be used. L. After work on energized systems, the employee performing the work is responsible for removing any personal protective equipment and barricades, and reinstalling all permanent barriers and/or covers. M. Portable electric tools shall be treated in such a manner as not to damage or impair the safety of the device. Some examples of POOR work practices that shall be avoided when using or handling these types of tools include: • • • •

Raising and lowering the tool using the power cord; Using the cord to pull the plug from the socket; Using the tool in a manner for which it was not designed (i.e., as a hammer); Using the tool in a manner such that it is exposed to water, steam, or excessive dust.

Prior to each use, portable electric tools should be inspected for damage to the plug, cord, or external case. Inspect for loose parts, cracks or tears, and wear that might prevent the insulation from functioning properly and thus creating a safety hazard. If tools or electrical equipment is not used daily or frequently, then a quarterly inspection is required. Any defective or broken tool or piece of equipment must IMMEDIATELY be taken or tagged “OUT OF SERVICE” to prevent from using.

4

Grounding

EFFECTIVE GROUNDING states the path to ground: 1. Is permanent and continuous; 2. Has the capacity to conduct any fault current that may be imposed upon it; and 3. Has low enough impedance to limit the voltage to ground and facilitate the operation of circuit overcurrent devices.

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Policy No:EHS-511

Electrical Safety

Only flexible cords and cables which contain an equipment grounding conductor shall be used for cord and plug connected electric equipment. Existing equipment grounding connections shall never be by-passed. Adapters which interrupt the continuity of the equipment grounding connection (i.e., convert a three prong plug to a two-prong plug) shall not be used. NOTE: In the case of a power tool that is double insulated, a flexible cord without a grounding conductor may be used, but not recommended. Whenever portable electric tools are used, the equipment must be protected via a ground fault circuit interrupter (GFCI). Each Site should have an Assured Equipment Grounding Program. It is an inspection program covering the following: • • •

All cord sets (extension cords; Receptacles that are not a part of the permanent wiring of the structure; Equipment connected by cord and plug that is available for use or is used by employees.

Under this program, regulatory standards mandate that the following two tests be performed BEFORE the first use of new equipment, AFTER suspected damage to the equipment, and at THREE MONTH INTERVALS (QUARTERLY): • • • • •

5

A continuity test to ensure that the equipment grounding conductor is electrically continuous; A test must be performed on receptacles that are not part of the permanent wiring of the building or structure, on all cord sets, and on cord- and plugconnected equipment that is required to be grounded; A test to ensure that the equipment grounding conductor is connected to its proper terminal.

Electrical Equipment Locations

The entrances to enclosures containing exposed high voltage energized parts, such as transformers or switchyards, shall be kept locked, if capable. Access doors or gates to rooms, vaults, or fenced enclosures containing electrical equipment shall be readily opened from the inside without the use of a key. Post entrances to rooms and other guarded locations containing exposed live parts with conspicuous signs forbidding unqualified persons to enter. Permanent and easy-to-read warning signs shall be posted on all doors and gates that provide access to enclosures containing exposed energized parts and conductors forbidding unqualified persons to enter. Signs shall be legible at 12 feet, of sufficient durability to withstand the environment, and shall read something similar to the following: “WARNING: HIGH VOLTAGE – KEEP OUT”.

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Policy No:EHS-511

Electrical Safety

Put up appropriate caution signs on metal-enclosed switchgear, unit substations, transformers, pull boxes, connection boxes, and similar equipment

6

Training

Any S&W Energy Facility or Site employees (including Field personnel) who will be involved with electrical work on or near exposed energized parts (a qualified employee) or working in areas where electrical work may be performed, shall be trained on the requirements and guidelines of this procedure initially, upon hire. Qualified employees shall be trained and competent in the following: • • • •

The skills and techniques necessary to distinguish exposed live parts from other parts or electrical equipment; The skills and techniques necessary to determine the nominal voltage of exposed live parts; The minimum approach distances specified and the corresponding voltages to which the qualified person will be exposed; and The proper use of precautionary techniques, personal protective equipment, insulating and shielding materials, and insulated tools for working on or near exposed energized parts of electric equipment.

Refresher training is required annually.

7

Auditing / Inspections

A quarterly inspection of electrical equipment should be made and findings recorded. All electrical hand tools, extension cords and other protective equipment should be inspected periodically and results documented. A visual inspection should be conducted prior to any use of this equipment (check for electrical integrity and insulation). The Electrical Safety Procedure shall be reviewed annually. This procedure will be updated as necessary.

8

References

29 CFR 1910.137

Electrical Protective Equipment

29 CFR 1910.269

Electric Power Generation, Transmission, and Distribution

29 CFR 1910.331-335

Safety-Related Work Practices - Electrical

Page 11

Environmental Health and Safety Manual Policy No. EHS-512

Policy Title: Fire Protection and Prevention

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2 3 4 5 6 7 8 9 10 11

Purpose and Scope.................................................................................................. 2 Definitions ................................................................................................................ 2 Procedure ................................................................................................................ 3 General Fire Prevention and Fire Safety Requirements........................................... 4 Fire Prevention and Fire Safety Equipment Requirements ...................................... 5 Testing, Inspection, and Maintenance of Fire Prevention Safety Equipment ........... 5 Alarm Systems ......................................................................................................... 6 Training .................................................................................................................... 6 Auditing / Inspections ............................................................................................... 7 References ........................................................................................................... 8 Forms ................................................................................................................... 8

Page 1

Policy No:EHS-512

Fire Protection and Prevention

1 Purpose and Scope The purpose of this procedure is to provide general guidance to prevent the onset of fire in the workplace. This procedure also defines the minimum requirements for Facility- or Site-specific fire protection and prevention procedures and plans. This procedure does NOT provide direction for cutting, burning, welding, brazing, or any other hot work operations. Specific procedures for these activities are provided separately in S&W Energy’s EHS Manual. This procedure does NOT provide direction for emergency response. Specific procedures for these activities are provided separately in S&W Energy’s EHS Manual.

2

Definitions • •

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Automatic Fire Detection Device – A device designed to automatically detect the presence of fire by heat, flame, light, smoke or other products of combustion. Carbon Dioxide – A colorless, odorless, electrically non-conductive inert gas which acts as an extinguishing agent by reducing the concentration of oxygen or fuel vapor in the air, such that combustion is not possible and cannot continue. Combustible Liquid – A liquid having a flashpoint at a specified temperature at or above 100 degrees F and below 200 degrees F. Dry Chemical – An extinguishing agent composed of very small particles of chemicals such as sodium bicarbonate, potassium bicarbonate, or potassium chloride, supplemented by special treatment to provide resistance to packing and moisture absorption, as well as to provide proper flow capabilities. Dry Powder – A compound used to extinguish or control Class D fires. Flammable Liquid – A liquid having a flashpoint at a specified temperature below 100 degrees F, with a vapor pressure of less than 40 pounds per square inch at 100 degrees F. Flash Point – Lowest temperature at which a liquid or solid gives off a vapor in such a concentration that when the vapor combines with air near the surface of the liquid or solid, a flammable mixture is formed. The lower the flashpoint, the more flammable the product. Grounding – The procedure used to carry an electrical charge to ground through a conductive path. Halogenated Agent – A colorless, electrically nonconductive gas that extinguishes fires by inhibiting the chemical chain reaction of fuel and oxygen. Incipient Stage Fire – A fire that is at the initial or beginning stage and that can be controlled or extinguished by a portable fire extinguisher, Class II standpipe, or small hose system, without the need for protective clothing or breathing apparatus. Multipurpose Dry Chemical – A dry chemical which is approved for use on Class A, Class B, and Class C fires.

Page 2

Policy No:EHS-512

• •

3

Fire Protection and Prevention

Safety Can – An approved container, no more than 5 gallons capacity, having a spring closing lid and spout cover and designed to safely relieve internal pressure under fire exposure. Standpipe Systems: • Class I Standpipe System – A 2.5-inch hose connection for use by fire departments and those trained in handling heavy fire streams. • Class II Standpipe System – A 1.5-inch hose system that provides a means to control and extinguish incipient stage fires. • Class III Standpipe System – A combined system of hose, for the use of employees trained in hose operations, that is capable of controlling the more advanced stages of fire (beyond the incipient stage) in the workplace’s interior. • Small Hose System – A system of hose, with a minimum diameter of 5/8 of an inch which can be used by employees to control and extinguish incipient fires.

Procedure

A Fire Protection/Prevention Plan must be prepared specifically for each Facility or Site. The plan should be either included or referenced in the Facility or Site Emergency Response Plan and/or Emergency Action Plan. •



The Fire Protection and Prevention Plan and the Emergency Response Plan have many differences but contain a lot of the same information. If the information is not included in one Plan because it is already included in another Plan, the information must at least be referenced. This ensures that both plans are in compliance with regulatory requirements. The plan is to be maintained on-site, kept up-to-date, and made readily available for employee review.

The following is a list of key elements that shall be included in a Fire Protection and Prevention Plan: • • • • • • • •

Potential fire hazards and their proper handling and storage requirements; Potential ignition sources and their control measures (refer to the Attachment Section of this procedure for table of Common Industrial Ignition Sources and Preventive Measures); Types of fire protection equipment or systems that control a fire; Job titles of personnel responsible for maintenance of equipment and systems installed to prevent or control fires; Job titles of those personnel responsible for control of fuel source hazards (i.e., flammable and combustible material); Housekeeping procedures that help control accumulations of flammable and combustible waste material and residues; Maintenance requirements for equipment and systems installed on heat producing equipment to prevent accidental ignition of combustible materials; Emergency telephone numbers and contact information;

Page 3

Policy No:EHS-512

• •

Fire Protection and Prevention

Emergency shut down procedures; and Emergency notification system.

Every Facility or Site shall evaluate the possible fire hazards around the workplace and determine the measures to prevent and/or contain a fire.

4

General Fire Prevention and Fire Safety Requirements

All fires shall be reported tom the local fire authorities, to Company management, and where applicable, to the Client Company. Good housekeeping and equipment maintenance must be practiced to keep fire hazards to a minimum. Matches and cigarette lighters should not be carried into any area where an explosive atmosphere may exist. Smoking must be confined to specifically designated areas. Smoking is not permitted within 35 feet (10.7 meters) of combustible or flammable materials. Areas where flammable gases or liquids are used or stored should be designated as a “No Smoking” area. Appropriate signs should be displayed. Oily waste or oil soaked clothing must be properly disposed. Covered metal containers for disposal of oily rags, waste, and other flammable rubbish must be provided. Containers must be emptied and disposed of on a daily basis or emptied enough to keep the premises in a safe and sanitary condition. Before an open flame (i.e., a welding torch) is carried into an enclosed are such as a small confined building, a tank, or vessel, a test shall be conducted to detect the presence of gas. Use of a combustible gas indicator is recommended. When volatile hydrocarbon liquids, such as condensates, gasoline, and some oils, are decanted into open metal containers, the open container must be grounded. Threaded connections or a bonding wire to the vessel or piping should be used to prevent generation of static electricity near an ignition source. Only approved safety cans should be used to store gasoline. The can shall be properly labeled identifying the contents. Oil or gasoline from leaks should not be burned. Any leakage should be cleaned up and disposed of in the proper manner. All leaks should be repaired and reported as soon as possible. If immediate repair is not possible, adequate warnings must be provided to affected personnel and extra precautions against fires implemented. • •

In the event of a gas leak, all fires, open flames, and engines should be shut down immediately. When testing for leaks around fittings, use soapsuds or the appropriate leaktest fluid. NEVER USE AN OPEN FLAME.

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Policy No:EHS-512

Fire Protection and Prevention

Flammable Liquids Flammable liquids and sprays must not be used near open flames or be used for cleaning purposes. Flammable liquids shall not be stored in open containers or in glass containers.

5

Fire Prevention and Fire Safety Equipment Requirements

Fire fighting equipment is for fire use only and shall be kept in its designated place at all times when not in use. All fire protection equipment must be located in designated areas that are clearly identified with appropriate markings. • •

The equipment should be located in the vicinity of likely fire hazards but easily accessible to operating personnel. All employees should familiarize themselves with the location and proper use of fire extinguishing equipment.

Fire protection equipment and apparatus shall be colored red for easy identification. Fire extinguishers partially used shall be discharged of pressure, recharged or replaced immediately. Extinguishers should not be filled with any material other than that which is designated on the extinguisher. All fire extinguisher hose nozzles (and all fire fighting equipment) should be kept free of obstruction at all times. An empty or defective fire extinguisher should never be hung until it has been serviced or repaired. Fire extinguishers should be kept filled. Manufacturer’s instructions for refilling and maintaining must be followed. Reference the Attachment Section of this Procedure for information on the different classes of fires and the appropriate rated fire extinguishers to be used in each case.

6

Testing, Inspection, and Maintenance of Fire Prevention Safety Equipment

All portable fire extinguishers must be inspected monthly by designated personnel. Designated on-site personnel can conduct the inspection. Each monthly inspection must be recorded on a tag affixed to each unit. Each unit must be serviced annually by a certified contractor. The contractor must affix a service tag. Automatic sprinkler systems must be serviced semi-annually by a licensed contractor. A service tag must be affixed, documenting the service.

Page 5

Policy No:EHS-512

Fire Protection and Prevention

A licensed contractor must do a non-discharging actuating test on fixed extinguishing systems at least annually. These systems typically are classified as automatic fire protection systems that use foam, carbon dioxide, halon, Freon, or other chemicals. Employees should be instructed to leave the building when testing these systems to avoid inhalation of these chemicals. All fire hoses and hose reels should be tested at least every year at maximum available working pressure or more frequent if circumstances indicate. (Unlined fire hoses inside buildings shall be excluded from pressure testing). Smoke detectors shall be tested quarterly to ensure they are in proper operating condition.

7

Maintenance records for fire equipment must be maintained for five years. Alarm Systems

Each workplace should have established procedures for reporting fires and other emergencies and for sounding emergency alarms. Emergency alarm systems may include manual pull box alarms, public address systems, radio and telephones, and direct verbal communications. All employees in the affected work area should be able to hear and recognize any alarm above ambient noise or light levels. Emergency notification can consist of a steam whistle, air horns, strobe lights, or similar lighting devices. Emergency telephone numbers shall be posted near telephones, employee notice boards, and other conspicuous places. Manually operated actuation devices for use in conjunction with employee alarms must be unobstructed, conspicuous, and readily accessible. Employee alarm systems should be properly maintained in operating condition. Trained personnel should perform all servicing, testing and maintenance. An alarm backup system should be provided when the system is out of service or under repair. If a fire is observed, employees should first activate the alarm system, notify the control room (or equivalent primary contact area), and follow the site emergency Action Plan and/or Emergency Response Plan accordingly.

8

Training

All S&W Energy Facility or Site employees (including Field personnel) shall be trained in understanding the purpose and function of this procedure and shall be trained on the requirements and guidelines in their Facility- or Site-specific Fire Protection and Prevention Plan initially, upon hire. Refresher training is required annually.

Page 6

Policy No:EHS-512



Fire Protection and Prevention

Maintenance, or other designated personnel, may additionally be trained in procedures for proper inspection, operation, maintenance, and repair of fire detection and extinguishing systems.

If assigned specific duties for fire suppression, designated employees must be instructed on the proper use of available fire fighting equipment at the facility or Site. Training must occur annually. Training on this procedure and its requirements should be given in conjunction with the Facility or Site’s Emergency Response Procedures. Employees shall receive basic instruction in the procedures to be followed in the event of a fire in their work area. Fire drills shall be conducted annually and may be included as part of the emergency response drill. Personnel required to use fire extinguishers to control incipient fires must receive annual training.

9

Auditing / Inspections

Fire extinguishers in the facility shall be inspected monthly by the designated site personnel or fire safety vendor. Other fire safety equipment shall be inspected per the guidelines and requirements of Section 6 of this procedure. A review of the written Fire Protection and Prevention Program should be done annually. The written Fire Protection and Prevention Program must be signed and dated following any review or revision. In addition, a periodic review and evaluation of the program should be done after any incident or evacuation. The Fire Protection and Prevention Procedure shall be reviewed every 2 years. This procedure will be updated a necessary.

Page 7

Policy No:EHS-512

Fire Protection and Prevention

10 References 29 CFR 1910.38

Employee Emergency Response Plans and Fire Prevention Plans

29 CFR 1910.106

Flammable and Combustible Liquids

29 CFR 1910.144

Safety Color Code for Marking Physical Hazards

29 CFR 1910.157

Portable Fire Extinguishers

29 CFR 1910.158

Standpipe and Hose Systems

29 CFR 1910.159

Automatic Sprinkler Systems

29 CFR 1910.164

Fire Detection Systems

29 CFR 1910.165

Employee Alarm Systems

29 CFR 1910.252

Welding, Cutting, Brazing / Fire Protection and Prevention

NFPA Standard 51B NFPA Publication Fire Protection Systems Inspection, Test, and Maintenance Manual

11 Forms See Appendix Q Q.1 - Classes of Fires and Appropriate Fire Extinguishers Q.2 - Sample Fire Prevention Checklist Q.3 - Sample Fire Extinguisher Inventory Form

Page 8

Environmental Health and Safety Manual Policy No. EHS-513

Policy Title: Confined Space Entry

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2 3 4 5 6 7 8 9 10

Purpose and Scope.................................................................................................. 2 Definitions ................................................................................................................ 2 General Requirements ............................................................................................. 4 Procedure(s) ............................................................................................................ 6 Contractor Requirements For Confined Space Entry ............................................. 11 Rescue Services .................................................................................................... 12 Training .................................................................................................................. 13 Auditing / Inspections ............................................................................................. 13 References............................................................................................................. 13 Forms ................................................................................................................. 13

Page 1

Policy No:EHS-513

Confined Space Entry

1 Purpose and Scope This procedure outlines the guidelines to safeguard employees and contractors against health and safety hazards associated with work to be performed within Confined Spaces. More specifically, it defines the minimum requirements for identifying and evaluating confined space hazards around a Facility or Site and establishes requirements for safe entry into Permit-Required and Non-Permit Required Confined Spaces. This procedure serves as the Permit-Required Confined Space Program and provides written procedures reflecting regulatory requirements for preparing permits for entry and for returning the permit space to service following termination of entry.

2

Definitions •

Attendant - An individual stationed outside a Permit-Required Confined Space who monitors the Authorized Entrants and who performs all Attendants’ duties assigned in this procedure. Attendant’s duties include: • • • • • • • • •

Knowing the hazards that may be faced during entry into any one confined space; and Maintaining an accurate account of Entrants in the permit space by monitoring sign-in / sign-out log; and Remaining outside the permit space during entry operations until relieved by another Attendant; and Communicating with Entrants as necessary to monitor safety status and work progress; and Monitoring activities to determine if it is safe to remain in the space or need to evacuate; and Summoning rescue activities as soon as it is determined that assistance is needed; and Performing non-entry rescue, as required. Authorized Entrant - An employee who is authorized by the Facility or Site Manager, or their designee, to enter a Permit-Required Confined Space. This can also be a Contractor employee, designated by Contractor representative. Confined space - A space that meets the following requirements: • • •

Is large enough and so configured that an employee can bodily enter and perform assigned work; and Has limited or restricted means for entry or exit (for example: tanks, vessels, vaults, and pits are spaces that may have limited means of entry); and Is not designed for continuous employee occupancy.

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Policy No:EHS-513











Confined Space Entry Permit - A written or printed document that is required to be completed and posted at the entrance to a Permit-Required Confined Space prior to entry into that space. The permit shall be completed by the Entry or Shift Supervisor. A Contractor Supervisor may complete the Permit for Contractor employees but the Permit must still be reviewed and signed by Site Supervisor. Engulfment - The surrounding and effective capture of a person by a liquid or finely divided (flowable) solid substance that can be aspirated to cause death by filling or plugging the respiratory system or that can exert enough force on the body to cause death by strangulation, constriction, or crushing. Entry - The action by which a person passes through an opening into a permitrequired confined space. Entry includes ensuing work activities in that space and is considered to have occurred as soon as any part of the entrant’s body breaks the plane of an opening into the space. Entry Supervisor - An employee (i.e., Shift Supervisor, or designee, foreman, or crew chief) responsible for determining if acceptable entry conditions are present at a permit-required confined space where entry is planned, for authorizing entry and overseeing entry operations, and for terminating entry as required by this procedure. For entries involving Contractors, the Entry Supervisor shall be a qualified Contractor employee. An Entry Supervisor may also serve as an Attendant or as an Authorized Entrant, if properly qualified and trained. Duties of Entry Supervisor may be passed from one individual to another during course of an entry. Hazardous Atmosphere - An atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to self -rescue (that is, escape unaided from a permit space), injury, or acute illness from or more of the following causes: • • • •

• •

Confined Space Entry

Flammable gas, vapor, or mist in excess of 10% of its Lower Flammable Limit (LFL); Airborne combustible dust at a concentration that meets or exceeds it’s LFL; Atmospheric oxygen concentration below 19.5% or above 23.5%; Atmospheric concentration of any substance for which a dose or permissible exposure limit is published in Subpart G, Occupational Health and Environmental Control, or in Subpart Z, Toxic and Hazardous Substances, of 29 CFR 1910.1000 and which could result in employee exposure in excess of its dose or Permissible Exposure Limit. Any other atmospheric conditions that is immediately dangerous to life and health.

Hot Work Permit – Written authorization by the Facility or Site, allowing operations such as riveting, welding, cutting, burning, and heating (or others) capable of providing a source of ignition.

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Policy No:EHS-513



• • • • •

Immediately Dangerous to Life and Health (IDLH) – Any condition that poses an immediate or delayed threat to life or that would cause irreversible adverse health effects or that would interfere with an individual’s ability to escape unaided from a permit-required confined space. Inerting – The displacement of the atmosphere in a confined space by a noncombustible gas (such as nitrogen) to such an extent that the resulting atmosphere is noncombustible. Lower Explosive Level (LEL) - Lowest concentration of a gas, vapor, dust or mist that will ignite in air. Non-Permit Required Confined Space - A confined space that does not contain, or with respect to hazardous atmospheres, have the potential to contain any hazard capable of causing death or serious physical harm. Permissible Exposure Limit (PEL) - Atmospheric concentration of any substance for which a dose is published in regulatory standards (i.e., Subpart Z, Toxic and Hazardous Substances, of 29 CFR 1910.1000). Permit-Required Confined Space - A confined space that has one or more of the following characteristics: • • • •

• •

3

Confined Space Entry

Contains or has a potential to contain a hazardous atmosphere; Contains a material that has the potential for engulfing an entrant; Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section; or Contains any other recognized serious safety or health hazard.

Qualified – Refers to a person with specific training, knowledge, and experience in the area for which the person has responsibility and the authority to control. Retrieval System - The equipment (including a retrieval line, chest or full-body harness, wristlets, if appropriate, and a lifting device or anchor) used for nonentry rescue of persons from permit spaces.

General Requirements

A. Evaluation of the Workplace / Site The Facility or Site Manager, or designee shall evaluate the workplace or worksite and identify each confined space. Each confined space identified must be classified as either Permit-Required Confined Space or Non-Permit Required Confined Space. The Facility or Site shall use the Confined Space Inventory Form to record all applicable information regarding hazardous atmospheres, associated hazards, personal protective equipment required to enter the space and rescue equipment required to be on-hand for each space identified. Determinations and dates the space was tested will be made available to entrants/contractors upon request.

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Policy No:EHS-513

Confined Space Entry

B. Permit-Required Confined Space For Facilities with Permit-Required Confined Spaces, the Facility shall: 1. Develop and implement a written Confined Space Permit Program and subsequent procedures to coordinate entry operations into Permit-Required Confined Spaces 2. Coordinate entry operations when employees of more than one employer are working simultaneously as Authorized Entrants in a Permit-Required Confined Space. 3. Develop and implement testing guidelines and procedures for classifying the type and magnitude of the hazards and conditions within the space. 4. Implement permitting system to identify proper approval for entry. 5. Develop communication procedures to be used by Authorized Entrants and Attendants to maintain contact during the entry. 6. Identify the rescue and emergency services, either on-site or off-site, that can be summoned and the means for summoning those services. 7. Inform employees exposed to permit-required confined spaces by posting danger signs (labeling): • • •



The sign must be posted by the entry point of the Permit-Required Confined Space. A recommended Confined Space Entry sign is given in the Attachment section of this procedure. The sign must be clearly and permanently labeled. The sign shall not be placed on a hatch cover or in any area where the sign can be covered from view. When entrance covers are removed, the opening shall be promptly guarded by a railing, temporary cover, or other temporary barrier that will prevent an accidental fall through the opening and protect each employee in the space from foreign objects entering the space. An example sign may read: “DANGER – PERMIT REQUIRED CONFINED SPACE, DO NOT ENTER”.

C. Non-Permit Required Confined Space An Attendant is not required for entry into a Non-Permit Required Confined Space. However, it is recommended that no employee work alone in any spaces around the Facility or Site. The “buddy system” should be adhered to when possible. Air monitoring is required initially in order to classify the space as a Non-Permit Required Confined Space. This air monitoring information will be recorded the Confined Space Entry Permit (Page 2) for documentation purposes. Page 2 of the Confined Space Entry Permit on which monitoring data was recorded will then be filed with the Confined Space Inventory Form. As long as conditions do not change, no additional air monitoring is required. However, if there is ever a question about the condition of the atmosphere in the space, consult the Shift Supervisor and/or Facility or Site Manager and retest the atmosphere. Page 5

Policy No:EHS-513

Confined Space Entry

When there are changes in the use or configuration of a Non-Permit Required Confined Space that might increase hazards to Entrants, the space shall be reevaluated and, if necessary, reclassified as a Permit-Required Confined Space. D. Reclassification of a Permit-Required Confined Space A space classified by the Facility or Site as a Permit-Required Confined Space may be reclassified as a Non-Permit-Required Confined Space under the following procedures: 1. If the permit space poses no actual or potential atmospheric hazards and if all hazards within the space are eliminated without entry into the space, the permit space may be reclassified as a Non-Permit-Required Confined Space for as long as the non-atmospheric hazards remain eliminated. 2. If it is necessary to enter the space to eliminate hazards, entry shall be performed under normal Permit-Required Confined Space procedures. If testing within that entry demonstrates that the hazards have been eliminated, the permit space may be classified as a Non-Permit-Required Confined Space for as long as the hazards remain eliminated. 3. The testing that reclassified the Permit-Required Confined Space as a NonPermit-Required Confined Space must be documented, including the date, location of space, and person making the determination (this can be done on the air monitoring section of the Confined Space Entry Permit (Page 2 of the Permit)). The space shall be reclassified on the Confined Space Inventory Form.

Control of atmospheric conditions through forced air ventilation DOES NOT constitute ELIMINATION OF THE HAZARDS for purpose of reclassification. It cannot be reclassified if the hazardous atmosphere is being CONTROLLED and NOT ELIMINATED.

4

Procedure(s)

A. Pre-Entry Requirement

No person shall enter a Permit-Required Confined Space without at least one Attendant outside the permit space into which entry is authorized for the duration of entry operations. Attendant and Entrant should have either visual contact of one another or be able to communicate verbally in case of emergency.

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Policy No:EHS-513

Confined Space Entry

Prior to entry: 1. Provide pedestrian, vehicle, or barriers, as necessary, to protect entrants from external hazards. 2. Ensure the space has met specified acceptable entry conditions (identified on Confined Space Inventory). • •

Test the internal atmosphere to ensure no hazards exist. Conditions shall be monitored for oxygen content, flammable gases (vapors), and potential toxic contaminants, in that order. Refer to Section on Testing of a Confined Space. Clean, purge, inert, flush, and/or ventilate the space, as necessary, to eliminate or control any hazardous atmosphere present.

3. Isolate the space by use of a physical disconnect or by blanking all piping or feed lines (exceptions are process vessels where blanking off would not be acceptable). Systems, which could carry hazardous substances into the space, must be isolated and locked out or tagged out in accordance with applicable Facility and/or Site procedures. 4. Provide temporary lighting, as necessary. Temporary lighting used in the space shall be of vapor proof design, with heavy cords and insulation in good condition. Explosion-proof, intrinsically safe, or twelve (12) volt (or less) lighting systems shall be used in Permit-Required Confined Spaces. 5. Identify equipment, such as personal protective equipment, testing equipment, communications equipment, alarm systems, and rescue equipment, to be used during the entry. Utilize the Pre-Entry Checklist in the Attachment Section of this procedure in preparation for entry. NOTE: This is not an exhaustive list and may not be the only necessary preentry steps 6. Provide at least one Attendant at each Permit-Required Confined Space. 7. Prepare and complete required information on Confined Space Entry Permit and obtain correct signatures and approvals for entry. All paperwork shall be kept on file. B. Entry Requirements / Entry Process

The Attachment Section of this Procedure includes a Confined Space Entry Permit Form, for reference. It contains all the information required and may be used at the Facility or Site. Any other Form used must contain at least the same information as the Form attached.

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Policy No:EHS-513

Confined Space Entry

Entry Permit 1. Before entry, a Confined Space Entry Permit shall be completed, approved, and posted at the entry to the Permit-Required Confined Space and is in effect for the duration of work in the space. Provisions shall be made if the work carries over to the next shift (i.e., issue a new permit for the next shift). The Permit shall be posted so that all Authorized Entrants can review and confirm that all pre-entry preparations have been completed. 2. The Entry Supervisor, or designee, shall complete the permit for entry into Permit-Required Confined Spaces by on-site employees. A Contractor Supervisor shall fill out the Permit for any entry involving a Contractor. HOWEVER, in this case, the Permit MUST be reviewed and approved by the Entry Supervisor from the Facility or Site. A Confined Space Entry Permit must include the following: • • • • • • • • • • • • • • •

Identification of the confined space to be entered; Purpose of the entry; Date and duration of the permit; Personnel (by name) currently serving as Attendant(s); Name(s) of the current Authorized Entrant(s); NOTE: This requirement may be met by using a separate Sign-In / Sign-Out Log that is posted outside of space next to permit. Name of Entry Supervisor A list of hazards in the Permit-Required Confined Space; A list of measures used to isolate the Permit-Required Confined Space and eliminate or control the hazards (LOTO, purging, inerting, ventilating, and flushing); The acceptable entry conditions; Monitoring and testing results of the conditions within the Permit-Required Confined Space (includes names of testers and times). Refer to Section on Testing of a Confined Space. The rescue and emergency services available and the means to summon them; Communication procedures for Attendants and Entrants; Any required equipment (such as respirators, communication, alarms, etc.); and Any additional permits (such as hot work) for the Permit-Required Confined Space.

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Policy No:EHS-513

Confined Space Entry

3. The Entry Supervisor identified on the Permit shall sign the permit to authorize entry upon his/her approval of all requirements being satisfied. 4. The Entry Supervisor shall terminate entry and cancel the entry permit when: • •

The entry operations covered by the entry permit have been completed; or A condition that is not allowed under the entry permit arises in or near the permit space.

The Facility or Site shall retain copy of the canceled Permit for at least 1 year to facilitate review of Program. C. Other Entry Requirements 1. A Confined Space Sign In/Sign Out Log will be kept at the entry portal of the space and all employees/Contractors will sign this log each time they enter or exit the Permit-Required Confined Space. 2. The current Attendant may not enter or leave the Permit-Required Confined Space entrance until properly relieved by someone who is properly trained in confined space entry and briefed on the hazards of that particular confined space. D. Testing of a Confined Space 1. The Entry Supervisor, or a trained Facility or Site employee, shall test the atmosphere of the confined space immediately prior to employee entry with a calibrated direct-reading instrument. A written record of test results from air monitoring must be made on the Confined Space Entry Permit. The Entrant must have the opportunity to observe this testing if so desired and has the right to request reevaluation. 2. Facilities or Sites must provide and maintain on-site test equipment that can properly perform the air monitoring tests. 3. Test equipment shall be calibrated in accordance with manufacturer's requirements. Instrument calibrations shall be recorded on an Instrument Calibration Log, an example of which is provided in the Attachment Section of this procedure. 4. All available means must be utilized to evaluate the confined space atmosphere without entering the space (i.e., extension probes, remote sensors, or insertion of the test equipment). 5. Multiple points of testing shall be taken along the path of entry. Entry into the space is permitted to perform this requirement when other means have been exhausted. Readings shall be taken to adequately define the conditions of path of entry. If the confined space area is sufficiently large, the space shall be adequately tested (i.e., in a multi-point grid fashion) to provide the most accurate conditions present.

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Policy No:EHS-513

Confined Space Entry

If Entry is required to perform testing, appropriate and sufficient personal protective equipment (PPE) must be used to provide the top level of safety (i.e., self-contained breathing apparatus or airline respirators). In addition, an Attendant must be present. 6. There may be no hazardous atmosphere within the space whenever any employee is inside the space. Therefore, if a hazardous atmosphere is known or expected to exist (i.e., toxic contaminants thought to exceed the PEL), entry is not permitted. 7. When testing for atmospheric hazards, test first for oxygen, then for combustible gases and vapors, then for toxic gases and vapors. 8. Entry into a Permit-Required Confined Space is allowed under the following conditions: • • •

Oxygen count is within the 19.5% to 23.5% level (between oxygen deficient and oxygen rich environments; and LEL is less than 10%; and Level of any substance found in Subpart Z of 29 CFR 1910.1000, Table Z-1, Limits for Air Contaminants, is less than the PEL (under OSHA) or other limits established by any regulation.

Entry MAY be permitted if the conditions above are exceeded ONLY IN AN EMERGENCY SITUATION AND BY ENTRANTS OR ATTENDANTS WHO ARE PROPERLY TRAINED. Proper personal protective equipment (i.e., respirators, self-contained breathing apparatus, etc.) must be used to ensure safety. 9. If the LEL is above 10%, ventilate the space until the LEL is less than 10%. If this condition is not possible, no one may enter the space unless it is an emergency situation and there are no ignition sources. 10. If, as a result of testing, it is determined that oxygen deficient or oxygen rich environments and/or dangerous air contamination does not exist, entry into the space may proceed. Re-testing must be done if the space has been vacant for more than four (4) hours or at the change of a shift to ensure that oxygen deficiency and/or dangerous air contamination has not developed. 11. Oxygen-consuming equipment such as cutting torches must not be used unless provisions are made to ensure adequate combustion air and exhaust gas venting. Also, any activity which can result in a change in atmospheric conditions should be monitored AT LEAST hourly. Continuous monitoring is the preferred method of monitoring. 12. Welding is permitted in Confined Spaces, however, the compressed gas tanks or gas cylinders are NOT allowed inside the Space (they must be located outside

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Policy No:EHS-513

Confined Space Entry

the Confined Space). Local exhaust ventilation shall be used to remove welding fumes. 13. Continuous forced air ventilation shall be used as follows: •

• •

The forced air ventilation shall be so directed as to ventilate the immediate areas where a hazardous atmosphere is confirmed or suspected and an employee is or will be present within the confined space and shall continue until all employees have left the space; The air supply for the forced air ventilation must be from a clean source; and An employee may enter the space after air monitoring has confirmed that forced air ventilation has eliminated any hazardous atmosphere;

14. The atmosphere within the Space shall be periodically tested as necessary to ensure that the continuous forced air ventilation is preventing the accumulation of a hazardous atmosphere. 15. If a hazardous atmosphere is detected during entry: • • •

5

Each employee shall immediately leave the confined space; The confined space shall be evaluated to determine how the hazardous atmosphere developed; and Measures will be taken to correct the cause of the recurrence of the hazardous environment before re-entry takes place.

Contractor Requirements For Confined Space Entry

Contractors of S&W Energy must adhere to the S&W Energy Confined Space Entry procedure to perform work in confined spaces. Prior to commencement of any work involving confined space entry, the Contractor shall review the S&W Energy Confined Space Entry Procedure to ensure they understand and are able to comply with all of its requirements. Contractors shall be made aware of all the Confined Spaces on-site (Inventory Form) and why they are classified as such (i.e., hazards associated with each). Contractors shall be made aware of any special procedures or precautions associated with confined spaces or areas around confined spaces where the Contractor may be working. Contractors must use the Facility or Site Confined Space Entry Permit, as provided in this procedure. The contractor may have designated Entry Supervisor to sign the Permit for entry approval, HOWEVER, this must be reviewed, signed, and approved by Facility or Site Entry Supervisor before entry of Contractors are allowed. If a Contractor wishes to use their own company permit, they must first discuss the matter with the Facility or Site Manager. If the Permit is deemed equal, then an exception may be made.

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Policy No:EHS-513

Confined Space Entry

If the Contractor cannot provide his/her own rescue services, the Contractor must notify the Facility or Site prior to arriving on-site so that the Facility can assist in coordinating or locating rescue services. The Contractor Supervisor shall designate a qualified and trained Entry Supervisor and Attendant(s) to oversee entry activities into the confined space. The Contractor must perform air monitoring of the confined space to ensure a safe environment is established prior to entry into the space (Some Facilities or Sites may not allow Contractors to test but instead have Facility or Site employee perform this task, observed by and communicated to Contractor). It is recommended that Facility personnel re-test the atmosphere in the space to confirm the air monitoring results obtained by the Contractor. The Entry or Shift Supervisor or designee shall accompany the Contractor Supervisor to the space entrance to post the completed Confined Space Entry Permit. The Entry or Shift Supervisor must authorize entry into the confined space in order for the Contractor’s work to begin.

6

Rescue Services

Rescue services must be coordinated ahead of time and may be provided by on-site employees or an off-site service for any site that has Permit-Required Confined Spaces. The emergency number must be clearly identified on the permit and posted throughout the Facility. Each member of the rescue service shall be trained to perform the assigned rescue duties. Outside rescue services must be made aware of the hazards of the confined spaces, must have access to comparable permit spaces or afforded the opportunity to practice at the Facility where they will be doing the rescue in order to develop rescue plans and practice rescues. At this time the Facility can evaluate a prospective rescuer’s ability to perform the rescues at that Facility. If local outside rescue services are not available, on-site teams must be properly equipped and receive the same training as Authorized Entrants, plus training in the use of personal protective and rescue equipment and first aid, including CPR. They must practice simulated rescues at least annually. To facilitate non-entry rescue, retrieval systems or methods shall be sued whenever an authorized entrant enters a permit space unless the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue of the entrant. Retrieval systems shall meet the following requirements: •

A full chest or body harness and life-line attached with a D-ring in the center of the back or above the head, or other retrieval means including manual or mechanical retrieval-assisted equipment must always be used unless it creates a greater hazard or would not be feasible for retrieval.

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Policy No:EHS-513



Confined Space Entry

The other end of retrieval line shall be attached to a mechanical device or fixed point outside the permit space in such a manner that rescue can begin as soon as the rescuer becomes aware that rescue is necessary.

Hospital or treatment facilities must be provided with any MSDS or other information in a Permit-Required Confined Space hazard exposure situation that may aid in the treatment of rescued employees.

7

Training

Training shall be provided so that all employees whose work is regulated by this Procedure acquire the understanding, knowledge, and skills necessary for the safe performance of their duties assigned. A. All employees who are involved in confined space entry operations will be trained in all aspects of this procedure, as well as for specific Facility procedures and programs, such as Lockout/Tagout, Respiratory Protection, Personal Protective Equipment (PPE), and the proper use and calibration of required monitoring devices for Permit-Required Confined Spaces as they pertain to Confined Space Entry. B. Authorized Entrants and Attendants shall be trained on: C. The hazards that may be faced during entry, including information on the mode, signs or symptoms and consequences of exposure; and D. Proper use of monitoring equipment for testing atmospheric conditions, including calibration procedures; and E. Communication with Attendant, to recognize signals or commands to avoid dangerous situations and evacuate when necessary; and F. Rescue services and techniques. G. Training shall occur initially upon hire and refresher training will be conducted every two years or more frequently if program changes have occurred. H. If the Facility has an on-site rescue team, they will be trained initially and then annually thereafter, as well as perform annual drills. I. Training records shall be maintained, including the employee names and dates of training. They should be made readily available, upon request.

8

Auditing / Inspections

The Confined Space Entry Procedure shall be reviewed annually, including review of active and closed permits, canceled permits, equipment calibration logs, etc. The procedure will be updated as necessary.

9

References 29 CFR 1910.146

Confined Space Entry

29 CFR 1910.1000, Subpart Z

Limits For Air Contaminants

10 Forms See Appendix R Page 13

Policy No:EHS-513

Confined Space Entry

R.1 - Example Confined Space Entry Permit (2 Pages) R.2 - Pre-Entry Checklist R.3 - Confined Space Inventory Form

Page 14

Environmental Health and Safety Manual Policy No. EHS-514

Policy Title: Walking and Working Surfaces

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2 3 4 5 6 7 8 9 10 11

Purpose and Scope.................................................................................................. 2 Definitions ................................................................................................................ 2 General Requirements ............................................................................................. 3 Protection for Floor Openings .................................................................................. 3 Protection for Wall Openings and Holes .................................................................. 4 Protection for Open-Sided Floors, Platforms, and Runways .................................... 4 Fixed Industrial Stairs............................................................................................... 5 Other Working Surfaces........................................................................................... 5 Training .................................................................................................................... 5 Auditing / Inspections ........................................................................................... 6 References ........................................................................................................... 6

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Policy No:EHS-514

Walking and Working Surfaces

1 Purpose and Scope This procedure provides the requirements and guidelines to ensure compliance with work performed on various platforms (i.e., stairs, elevated platforms other than ladders and scaffolding, etc.) and more general standards and requirements for walking and working surfaces located throughout the workplace or job site. Safety requirements for wall and floor openings, open holes (such as manholes or confined space entryways), and work areas around stairs, windows, open-sided floors, etc., are included in this procedure. The Walking and Working Surfaces procedure is provided to protect employees from injury during work and to achieve 100% compliance regulations. This procedure should be used in conjunction with S&W Energy’s Ladders and Scaffolding and Fall Protection procedures. This procedure provides the basic requirements of protection in or on the specified walking and working surfaces. It does not include design and construction criteria of those safety devices mentioned. Refer to regulatory standards for these specifications. In addition, requirements for other working platforms such as aerial lifts and manlifts are not included as part of the scope of this procedure. The general requirements will apply to these working platforms (also reference the S&W Energy’s Ladders and Scaffolding and Fall Protection Procedures for more general requirements). However, these working platforms are not as common at the Facilities or Sites as the other walking and working surfaces outlined in this procedure. Therefore, they will be addressed on as asneeded basis, per regulatory standards.

2 • • • • • • • • •

Definitions Floor Opening – An opening in any floor, platform, pavement, or yard measuring 12 inches or more in its least dimension through which persons may fall. Some examples may include a hatchway, stair or ladder opening, pit or large manhole. Handrail – A single bar or pipe supported on brackets from a wall or partition to furnish persons with a handhold in case of tripping. Mid-Rail – A rail approximately midway between the guardrail and platform used when required, and secured to the uprights erected along the exposed sides and ends of the platforms. Nosing – The portion of a tread projecting beyond the face of the riser immediately below. Platform – A working space for persons that is elevated above the surrounding floor or ground. Riser – The upright member of a step situated at the back of a lower tread and near the leading edge of the next higher tread. Runway – A passageway for persons elevated above the surrounding floor or ground level, such as a footwalk along shafting or a walkway between buildings. Standard Railing – A vertical barrier erected along exposed edges of a floor opening, wall opening, ramp, platform or runway to prevent falls of persons. Toeboard – A vertical barrier at floor level erected along the exposed edges of a floor opening, wall opening, platform, runway or ramp to prevent falls of materials. Page 2

Policy No:EHS-514

• •

Walking and Working Surfaces

Tread – The horizontal member of a step. Wall Opening – An opening, at least 30 inches high and 18 inches wide in any wall or partition, through which persons may fall.

3

General Requirements

A. All work areas, passageways, storerooms and service rooms must be kept in a clean, orderly and sanitary condition. B. All floors must be maintained in a clean and dry condition to the best possible extent. Where wet processes are used, utilize drainage, platforms, mats and other means to provide a safe working surface. C. Every floor, working place and passageway must be kept free from protruding nails, splinters, and holes, loose boards or obstructions that could create a hazard. D. Where mechanical handling equipment is used, sufficient safe clearances must be provided for aisles, loading docks, doorways and turns. Permanent aisles and passageways must be identified. E. Open pits, tanks, ditches, etc., must be provided with covers and/or guardrails to protect employees from the hazard(s) presented. F. Approved floor openings must be conspicuously posted, and the load placed in that area may not exceed the rated capacity.

4

Protection for Floor Openings

A standard railing shall guard every stairway floor opening. The railing shall be provided on all exposed sides, except at the entrance to the stairway. Every ladderway floor opening or platform shall be guarded by a standard railing with standard toeboard on all exposed sides, except the entrance to the opening. The passage through railing shall be provided with a swinging gate or so offset that a person cannot walk directly into the opening. Every hatchway and chute floor opening shall be guarded by either: • •

A hinged floor opening cover of standard strength and construction equipped with standard railings or permanently attached thereto so as to leave only one exposed side; or A removable railing with toeboard on not more than two sides of the opening and fixed standard railings with toeboards on all other exposed sides.

A floor opening cover of standard strength and construction shall guard every pit and trapdoor floor opening. Every manhole floor opening shall be guarded by a standard manhole cover, which need not be hinged in place. Every temporary floor opening shall have standard railings, or shall be constantly attended by someone. Every floor hole into which persons can accidentally walk shall be guarded by either:

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Policy No:EHS-514

• •

Walking and Working Surfaces

A standard railing with standard toeboard on all exposed sides; or A floor hole cover of standard strength and construction.

Every floor hole into which persons cannot accidentally walk (on account of fixed machinery, equipment or walls) shall be protected by a cover that leaves no openings more than 1 inch wide. Where doors or gates open directly on a stairway, a platform shall be provided and the swing of the door shall not reduce the effective width to less than 20 inches.

5

Protection for Wall Openings and Holes

Every wall opening from which there is a drop of more than 4 feet shall be guarded by either: • •

Rail, roller, picket fence, half-door, or equivalent barrier. Where there is exposure below to falling materials, a removable toeboard or the equivalent shall also be provided; or An extension platform onto which materials can be hoisted for handling, and which shall have side rails or equivalent guards and standard specifications.

Every chute wall opening from which there is a drop of more than 4 feet shall be guarded by a rail, roller, picket fence, half-door, or equivalent barrier, or any combination thereof. Every window wall opening at a stairway landing, floor, platform, or balcony from which there is a drop of more than 4 feet, and where the bottom of the opening is less than 3 feet above the platform or landing shall be guarded by standard slats, standard grill work, or a standard railing. Every temporary wall opening shall have adequate guards, but need not be of standard construction.

6

Protection for Open-Sided Floors, Platforms, and Runways

Every open-sided floor or platform 4 feet or more above adjacent floor or ground level shall be guarded by a standard railing, or equivalent, on all open sides except where there is an entrance to a ramp, stairway, or fixed ladder. The railing shall be provided with a toeboard wherever persons can pass, wherever there is moving machinery, or wherever there is equipment with which falling materials could create a hazard. Every runway shall be guarded by a standard railing, or equivalent, on all open sides 4 feet or more above adjacent floor or ground level. If tools or materials are to be used on the runway, a toeboard is required on each exposed side to prevent them falling to a lower level.

Page 4

Policy No:EHS-514

Walking and Working Surfaces

Regardless of height, open-sided floors, walkways, platforms, or runways above or adjacent to dangerous equipment shall be guarded with a standard railing and toeboard.

7

Fixed Industrial Stairs

Fixed stairs must be provided where: • • • •

Operations necessitate regular intervals between levels; Access to elevations is daily or at each shift for purposes of inspection or regular maintenance; Work at various levels may result in exposure to acids, caustics, or other harmful substances; Work at different levels involves the carrying of tools or equipment by hand

Stair treads must be slip resistant and the nosings must be of non-slip finish.

8

Other Working Surfaces

Portable and powered dockboards shall be strong enough to carry the load imposed on them. Portable dockboards shall be secured in position, with devices that will prevent their slipping. Powered dockboards shall be designed in accordance with Commercial Standards. Handholds, or other effective means, shall be provided on portable dockboards to permit safe handling.

If the proper protection cannot be provided for the walking and working surfaces and areas outlined in this procedure (i.e., guardrails and toeboards around open holes, etc.), then fall protection is required when working in these areas. Reference S&W Energy’s Fall Protection procedure to ensure that the situation meets all criteria of a fall hazard and the proper fall protection is used in each situation.

9

Training

All S&W Energy Facility or Site employees (including Field personnel) who will be working in areas or on platforms as outlined in this procedure shall be trained on the requirements and guidelines of this procedure initially, upon hire. Refresher training is required every 2 years.

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Policy No:EHS-514

Walking and Working Surfaces

10 Auditing / Inspections The Walking and Working Surfaces procedure shall be reviewed every 2 years. This procedure will be updated as necessary.

11 References 29 CFR 1910.22

Walking & Working Surfaces, General Requirements

29 CFR 1910.23

Guarding Floor and Wall Openings and Holes

29 CFR 1910.24

Fixed Industrial Stairs

29 CFR 1910.30

Other Working Surfaces

Page 6

Environmental Health and Safety Manual Policy No. EHS-515

Policy Title: Ladders and Scaffolding

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2 3 4 5 6 7 8 9 10

Purpose and Scope.................................................................................................. 2 Definitions ................................................................................................................ 2 General Requirements for Ladders .......................................................................... 3 Proper Selection, Safe Set-Up, and Safe Use of Ladders........................................ 4 Proper Care and Storage ......................................................................................... 5 Specific Ladder Types – Additional Requirements................................................... 6 Scaffolding ............................................................................................................... 7 Training .................................................................................................................. 10 Auditing / Inspections ............................................................................................. 10 References ......................................................................................................... 10

Page 1

Policy No:EHS-515

Ladders and Scaffolding

1 Purpose and Scope This procedure defines the guidelines and requirements for the general use and storage of ladders used on-site and the general use and safety standards of scaffolding used on-site. In addition, the procedure outlines general precautions and requirements, what to look for during inspections, and requirements specific to various types of ladders and scaffolds. This procedure DOES NOT include the requirements for constructing or manufacturing ladders and scaffolds. It provides some information on the design criteria and guidelines for erection of scaffolding but primarily focuses on safe use and precautions. Reference ladder and scaffold manufacturer guidelines for detailed information on design and construction. All ladders and scaffolds must be verified that they have been constructed to the appropriate standards and are in compliance w/ safety standards before they are used.

2

Definitions • • • • • • • • • •

Cage – A guard, which is an enclosure that is fastened to the side rails of the fixed ladder or to the structure to encircle the climbing space of the ladder for the safety of the person who must climb the ladder. Cleats - Ladder crosspieces of rectangular cross-section placed on the edge on which a person may step in ascend or descend. Coupler – A device for locking together the components of a tubular metal scaffold. Extension Ladder – A non-self-supporting portable ladder, adjustable in length. It consists of two or more sections traveling in guides or brackets so arranged as to permit length adjustment. Manually Propelled Mobile Scaffold – A portable-rolling scaffold supported by casters. Platform – A working space for persons elevated above the surrounding floor or ground. Rungs – Ladder crosspieces of circular or oval cross-section on which a person may step in ascending or descending a ladder. Runner – The lengthwise horizontal bracing or bearing members or both. Runway – A passageway for persons elevated above the surrounding floor or ground level, such as a footwalk along shafting or a walkway between buildings. Scaffold – Any temporary elevated platform and its supporting structure used for supporting workmen or materials or both. • • •

Light Duty Scaffold – A scaffold designed and constructed to carry a working load not to exceed 25 pounds per square foot. Medium Duty Scaffold – A scaffold designed and constructed to carry a working load not to exceed 50 pounds per square foot. Heavy Duty Scaffold – A scaffold designed and constructed to carry a working load not to exceed 75 pounds per square foot. Page 2

Policy No:EHS-515

• • • •



3

Ladders and Scaffolding

Sectional Ladder – A non-self-supporting portable ladder, non-adjustable in length, consisting of two or more sections so constructed that the sections may function as a single ladder. Standard Railing – A vertical barrier erected along exposed edges of a floor opening, ramp, platform, or runway to prevent falls of persons. Toeboard – A vertical barrier at floor level erected along exposed edges of a floor opening, wall opening, platform edge runway, or ramp to prevent falls of materials. Tube and Coupler Scaffold – An assembly consisting of tubing which serves as posts, bearers, braces, ties, and runners, a base supporting the posts, and special couplers which serve to connect the uprights and to join the various members. Tubular Welded Frame Scaffold – A sectional, panel or frame metal scaffold substantially built up of prefabricated welded sections which consist of posts and horizontal bearer with intermediate members. Panels or frames shall be braced with diagonal or cross braces.

General Requirements for Ladders

Before a ladder is used it shall be inspected to ensure safety. Check for the following: • • • • • • • •

Steps and side rails are free of oil, grease, paint, water, or other foreign material that may make ascending or descending the ladder dangerous (slippery); Steps are firmly anchored to the side rails; Rungs, rails, braces, uprights, or side rails loose or damaged; Loose or missing hinges, screws, nails, nuts, or bolts; Defects in any of the hardware connections; Sharp corners or rough edges that could cut or scratch; or Decayed or split steps, braces, or rails (on a wooden ladder); If a ladder was dropped, recheck it thoroughly before using it. If a ladder is damaged or defective, remove it from service.

Never use a defective ladder. Tag or label it so that it may be repaired, replaced, or destroyed. Do not leave ladders unattended unless properly secured. Wood ladders should never be painted. Never use a wood ladder that has been painted. The paint can conceal defects in the ladder. The bottom section of section ladders shall be equipped with safety shoes. The feet and rungs shall be slip-resistant. Employees shall not work on ladders (outside) during storms or high winds.

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Policy No:EHS-515

Ladders and Scaffolding

If a ladder is damaged or defective, remove it from service immediately. Either replace the ladder or repair it, according to manufacturer’s recommendations, before returning the ladder back into service.

4

Proper Selection, Safe Set-Up, and Safe Use of Ladders

A. Selection Different jobs require different ladders: stepladders, straight ladders, extension ladders, sectional ladders, etc. To select the proper ladder, consider the following: • • • • •

Is the ladder strong enough to support the employee as well as any equipment that is required? Is the ladder long enough so the employee can work safely, without standing on the top rung or stretching beyond a safe distance? Can the ladder be properly positioned so that the employee will not have to reach outward more than arms length? Can the ladder be secured in place and properly tied off? Will the ladder pose a safety hazard for the work that needs to be done?

Metal or aluminum ladders, or ladders with metal side rails, shall not be used near electrical equipment or lines. Only wood, fiberglass, or other non-conducting ladders shall be used in these situations. B. Set-Up Ladders shall not be placed in a horizontal position and used as a runway or a scaffold unless designed for this purpose. Place portable ladders so that both side rails have secure footing. Provide solid footing on soft ground to prevent the ladder from sinking. Never lean a ladder against unsafe backing or set up behind a door that opens toward the ladder without locking or otherwise securing the door from opening. Always tie ladders to solid structures, if tie-off is possible. The top section should always be securely tied off to something substantial. Employee shall not set up ladders near overhead obstructions and/or energized lines. If a ladder needs to be set up in area where there is high traffic, a barrier shall be erected or set-up to keep people from walking or working too close and possibly bumping or moving the ladder while someone is on it. Keep the area around the base of the ladder free from clutter. Ladders shall not be placed on boxes, barrels, or other unstable bases to achieve more height.

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Policy No:EHS-515

Ladders and Scaffolding

The base or foot of the ladder should be placed one-fourth the ladder length from the vertical plane of the top support. When ladders are used to climb from one level to another, the top of the ladder must extend 3 feet above the higher level. C. Use (Carrying and Climbing) A ladder shall be carried horizontally, rather than vertically. Employees should never carry a ladder by themselves (unless it can be carried easily). If it is too long or too heavy, seek assistance. Only one employee shall work from a ladder at one time. If work requires two employees, a second ladder shall be used. Employees shall face the ladder when ascending and descending and shall use both hands. If tools or other objects must be transported up or down elevated work platforms, use a rope tool belt, or pouch. Never slide down a ladder. Be sure that employees are wearing footwear that is not slippery (i.e., free from oil or grease) before climbing. A full body harness with lanyard is required when working more than 4 feet above ground level without standard railings or other fall protection. (Reference Fall Protection Procedure for detailed requirements on fall protection). Employees shall not tie their safety harness off to a ladder unless the ladder is permanently secured. Do not reach further than arms length from the ladder. Move the ladder as work progresses. RULE OF THUMB: Keep belt buckle inside rails. An employee should not be climbing a ladder if ill or on prescription drugs. If an employee gets dizzy or panics while on a ladder, the following steps are recommended: • • •

5

Drape your arms over a rung: Rest your head against another rung or a side rail; and/or Do not continue climbing, wait until the feeling passes

Proper Care and Storage

Do not leave a ladder in position for an extended period of time. If the job is done, return the ladder to storage so it is out of the way.

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Policy No:EHS-515

Ladders and Scaffolding

Designate ladder storage areas at the Facility or Site. Make sure all employees are aware of these locations so that a ladder can be obtained for use at anytime or in case of an emergency. Do not leave ladders next to stairways, creating possible tripping hazards. Ladders should be stored in a dry place. In storage, rest the ladder on support racks so it hangs straight and level. If unable to store in an upright position, place the ladder on the edge and lean against a wall, and not on plant equipment.

6

Specific Ladder Types – Additional Requirements

In addition to the requirements in previous sections, outlining general precaution and requirements of ladders, proper selection, use and storage, the following safety guidelines and requirements must be adhered to for the specific type of ladder identified. Remember all other requirements for ladders still apply. A. Fixed Ladders Check to ensure there are no loose or missing cleats before climbing a fixed ladder. If the ladder is 20 feet or longer, it must be equipped with a cage. Ladder cages must extend 42 inches above the top of the next landing. Verify, before use, that there are no parts of the cage that are damaged or corroded. Cages begin 7 to 8 feet from the base of the ladder. Anchoring shall be checked to make sure it is solid (not loose or broken). Verify that the fixed rungs on the walls have not been damaged or the surface around the rungs missing any material that could compromise the anchoring. B. Straight Ladders and Extension Ladders Employees shall not climb higher than the third rung from the top on straight or extension ladders. Straight ladders shall be equipped with safety shoes. Straight and extension ladders shall be equipped with non-slip or slip resistant feet. The minimum width between side rails of a straight ladder and any section of an extension ladder shall be 12 inches. The length of single ladders or individual sections of ladders shall not exceed 30 feet. Two section ladders shall not exceed 48 feet in length and over two section ladders shall not exceed 60 feet in length. Visually inspect extension ladders to ensure that the ropes or lines are not worn, loose, or broken. Also check to see locks are operable and in good condition.

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Policy No:EHS-515

Ladders and Scaffolding

C. Step Ladders Be sure the stepladder is fully open and locked before starting to climb. The locking device shall be of sufficient size and strength so as to securely hold the front and back sections in open positions. Employees shall not work from the top step of a stepladder. This does NOT apply to safety platform ladders. Step ladders longer than 20 feet shall not be used on-site. If an employee is working on a step ladder 10 feet or more above the ground or the floor, the ladder shall be held by at least one other person. Stepladders shall not be used as straight ladders. Never climb on the back supports of a stepladder. Never stand on the tray of stepladder. Don’t climb higher than the second rung from the top on a stepladder.

SUMMARY FOR LADDERS: 1. Select the right ladder for the job to be done. 2. Only ladders that are in good condition, company approved and meet regulatory specifications shall be used. 3. Inspect the ladder from top to bottom prior to use to make sure it is safe and secure. 4. Place the ladder on a firm, solid surface and level it. 5. Position the ladder at the proper angle. 6. Stay inside the side rails as you work. 7. Return the ladders to proper storage upon completion of job tasks.

7

Scaffolding

A. General Requirements All scaffolds must be built or erected according to regulatory (i.e., OSHA) standards. Employees shall not work on scaffolds during storms or high winds. Any scaffold damaged or weakened from any cause shall immediately be repaired and shall not be used until repairs have been completed. All scaffold platforms and walkways shall be designed, constructed, and maintained to support 4 times the maximum weight they are expected to support during use.

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Policy No:EHS-515

• •

Ladders and Scaffolding

All hardware used to construct scaffolds (nuts, bolts, nails, etc.) shall be of adequate size and sufficient numbers to develop the strength needed. The poles, legs, uprights of scaffolds shall be plumb and securely and rigidly braced to prevent swaying and displacement.

All scaffold platforms and walkways shall have top railings, mid railings, and toeboards in conformance with regulatory standards. The footing or anchorage for scaffolds shall be sound, rigid, and capable of carrying the maximum intended load without settling or displacement. Unstable objects such as barrels, boxes, loose brick or concrete blocks may not be used to support scaffolds or planks. All work platforms and walkways shall be fully planked at all times work is in progress. All planking or platforms shall be overlapped (a minimum of 12 inches) or secured from movement. Scaffolds shall not be altered or moved horizontally while they are in use or occupied. When mobile scaffolding is being relocated, the source of power shall be disconnected. Overhead protection shall be provided and must be worn for employees working on scaffolds whenever work is being carried on above them. A scaffold over a walkway, aisle, or work area shall have the sides screened (one half inch mesh or equivalent) from toeboard to the top of the rail, extending along the entire opening, where an employee is required to work or pass under the scaffold. An access ladder or equivalent safe access shall be provided. The first rung of the scaffold access ladder shall be no greater than 12 inches above the floor / ground level and shall extend at least three rungs above the scaffold platform when overhead space permits. Use a swing gate when possible to access the scaffold platform. Scaffold assemblies and platform work surfaces shall be visually inspected daily before use by the user for obvious structural deficiencies. Scaffolds shall be free of ice, snow, oil, grease, or other slippery materials before being used. Scaffolds shall not be erected or placed within close proximity (20 feet) of power lines without approval from the Facility or Site Manager. When erecting a scaffold greater than 6 feet in height, employees shall wear a safety harness with a safety line or lanyard attached to the scaffolding or nearest structure capable of supporting their body weight and impact load. Scaffolds, which are more than one section high, MUST be tied off. Scaffold shall be secured to permanent structures through use of anchor bolts, reveal bolts, or equivalent means.

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Policy No:EHS-515

Ladders and Scaffolding

Avoid overcrowding scaffolds. Overloading can weaken the structure or cause scaffolds to become top-heavy. When hoisting material onto a scaffold, use a tag-line. Never lay hand tools or excess material on the edge of scaffolds or beams where they may fall. Hard hats must be worn when workers on or below scaffolds are exposed to overhead hazards. B. Tubular and Coupler-Type Scaffolding Tubular metal scaffolds and coupler type scaffolds shall be erected and used according to manufacturer’s recommendations. • •

Proper seating and locking of all connections shall be rigidly observed, and diagonal bracing or equivalent must be securely bolted or wired to upright members. The support posts shall be spaced no more than 6 feet apart by 10 feet along the length of the scaffold for light duty tube and coupler scaffolds, 6 feet by 8 feet for medium duty tube and coupler scaffolds, and 6 feet by 6 and a half feet for heavy duty tube and coupler scaffolds.

Adequate base support shall be provided for uprights. Cross bracing shall be installed across the width of the scaffold at least every third set of posts horizontally, and every fourth runner vertically. Tube and coupler scaffolds shall be constructed to support four times the maximum intended loads. Fixed scaffolds shall be secured to the building structure at 26 feet vertically and 30 feet horizontally. Competent and experienced personnel who have had the appropriate training shall erect all tube and coupler scaffolds. All general requirements for scaffolds apply. Manually-Propelled Scaffolds Rolling-type metal scaffolds shall be used only on hard, smooth, level surfaces. Do not ride a scaffold that is being moved. Rolling scaffolds exceeding 5 feet in height shall have their wheels locked or chocked when in use. When freestanding rolling towers are used, their height shall not exceed four times the minimum base dimension. Two horizontal, diagonal braces shall be used on manually propelled scaffolds.

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Policy No:EHS-515

Ladders and Scaffolding

All general requirements for scaffolds apply.

8

Training Each S&W Energy Facility or Site employees (including Field personnel) who will be involved with conducting work using a ladder or scaffold, or may be responsible for inspecting good safety practices involving ladder or scaffold use, shall be trained on the requirements and guidelines of this procedure (initially). Refresher training is required every 2 years. As referenced in the Purpose and Scope, the guidelines and requirements included in this procedure outline safety precautions and simple safety standards for the use and inspection of scaffolds and ladders. In the case of scaffolds, additional, more in-depth training is required, per regulations, if employees are responsible for erecting scaffolding. It must be approved and a tag affixed indicating it was built to standard to each approved scaffold once erected. Reference Federal, State, or local regulations if this is the case at your Facility or Job Site.

9

Auditing / Inspections Ladders and Scaffolds shall be inspected daily or prior to each use to ensure they are free of defects and contain all the safety precautions necessary. The Ladders and Scaffolding Procedure shall be reviewed every 2 years. This procedure will be updated as necessary.

10 References 29 CFR 1910.25

Portable Wood Ladders

29 CFR 1910.26

Portable Metal Ladders

29 CFR 1910.27

Fixed Ladders

29 CFR 1910.28

Safety Requirements for Scaffolding

29 CFR 1910.29

Manually-Propelled Mobile Ladder Stands and Scaffolds

Page 10

Environmental Health and Safety Manual Policy No. EHS-516

Policy Title: Bloodborne Pathogens

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2 3 4 5 6 7 8 9

Purpose and Scope.................................................................................................. 2 Definitions ................................................................................................................ 2 General Policy.......................................................................................................... 3 Post Exposure Precautions ...................................................................................... 5 Post Incident Actions................................................................................................ 6 Medical Evaluations and Medical Records............................................................... 6 Training .................................................................................................................... 8 Auditing / Inspections ............................................................................................... 9 References............................................................................................................... 9

Page 1

Policy No:EHS-516

Bloodborne Pathogens

1 Purpose and Scope This procedure provides the policy requirements and guidelines to comply with the Bloodborne Pathogens standard and the requirement to develop a written Exposure Plan. The guidance and plan provides information that will help employers eliminate and minimize employee exposure to bloodborne pathogens, including but not limited to hepatitis B (HBV) and human immunodeficiency virus (HIV). It also includes procedures that are to be followed in case there is an exposure incident. This procedure and policy applies to all employees, at a minimum, for awareness purposes.

2 • • • • • •

• • • • • • • •

Definitions Blood – Human blood or human blood components and products made from human blood. Bloodborne Pathogens – Pathogenic microorganisms that are present in human blood and can cause disease in humans. Contaminated – The presence or reasonable anticipated presence of blood or other potentially infectious materials on an item or surface. Contaminated Laundry – Laundry which ahs been soiled with blood or other potentially infectious materials or may contain sharps. Contaminated Sharps – Any contaminated object that can penetrate the skin including, but not limited to, needles, scalpels, broken glass, etc. Decontamination – The use of physical or chemical means to remove, inactivate or destroy bloodborne pathogens on the surface or item to the point where they are no longer capable of transmitting infectious particles and the surface of the item is rendered safe for handling, use or disposal. Engineering Controls – Controls such as sharp disposable containers, selfsheathing needles, etc., which isolate or remove the bloodborne pathogen hazard from the workplace. Exposure Incident – A specific eye, mouth, other mucous membrane, non-intact skin, or parenteral contact with blood or other potentially infectious materials that result from performance of employee’s duties. HBV – Hepatitis B virus. HIV – Human immunodeficiency virus. Licensed Health Care Professional – A person whose legally permitted scope of practice allows him or her to independently perform the activities such as vaccinations and post-exposure evaluations and follow-up. Occupational Exposure – Reasonable anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of an employee’s duties. Parenteral – Piercing mucous membranes or the skin barrier through such events as punctures, bites, cuts or abrasions. Regulated Waste (Biohazardous Waste) – Liquid or semi-liquid blood or other potentially infectious materials; contaminated items that would release blood or other Page 2

Policy No:EHS-516

Bloodborne Pathogens

potentially infectious materials in a liquid or semi-liquid state if compressed; items that are caked with dry blood or other potentially infectious materials and are capable of releasing these materials during handling. Source Individual – Any individual, living or dead, whose blood or other potentially infectious materials may be a source of occupational exposure to employees. Sterilize – The use of physical or chemical procedure to destroy all microbial life including highly resistant bacteria. Universal Precautions – An approach to infection control, where all human blood and certain human body fluids are treated as if known to be infectious for HIV, HBV, and other bloodborne pathogens. Work Practice Controls – Controls that reduce the likelihood of exposure by altering the manner in which a task is performed.

• • • •

Each employer having employees with occupational exposure shall establish a written Exposure Control Plan. This procedure and policy outlines the requirements of an Exposure Plan. Implementation of this procedure meets all of the elements of the Written Exposure Plan. Because this industry does not typically encounter exposure of bloodborne pathogens, the Exposure Control (Bloodborne Pathogens Plan) is primarily for awareness. Exposure will most likely occur when assisting someone whom is injured (clean up) or involved in an accident where infectious materials may be used for first aid, etc. However, all employees shall be made aware of the dangers or exposure and procedures to prevent exposure.

3

General Policy

A. Personal Protective Equipment Each Facility or Site shall supply personal Protective Equipment (PPE). The PPE required for bloodborne pathogen exposure controls include disposable latex gloves, protective eyewear and/or facemask, protective CPR shield, and biohazard clean up and disposal kit. •

Gloves shall be worn when it can be reasonably anticipated that the employee may have hand contact with blood, other potentially infectious materials, mucous membranes, and non-intact skin. Disposable gloves shall not be washed or decontaminated for re-use

PPE will only be considered appropriate if it does not permit blood or other infectious material to pass through it or to reach the employee’s work clothes,

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Policy No:EHS-516

Bloodborne Pathogens

street clothes, undergarments, skin, eyes, or mouth under normal conditions of use and for the duration of time which the PPE will be used. PPE must be stored in a separate unlocked cabinet or box, in an accessible area, and made available to all employees. The employees shall use the appropriate PPE whenever there is potential for occupational exposure. B. Engineering and Work Practice Controls Engineering and work practice controls shall be used to eliminate or minimize employee exposure. The controls should be used in combination with effective and appropriate PPE. Engineering and safe work practices should be examined and maintained or replaced on a regular schedule (such as annually), as necessary, to ensure their effectiveness. Employees shall wash their hands with soap and water immediately, or as soon as feasible, after the removal of gloves or other PPE. Employees shall wash their hands following the contact of body areas that may be contaminated with blood or other potentially infectious material. Eating, drinking, smoking, applying cosmetics (i.e., lip balm) and handling contact lenses is prohibited in the work area when there is potential for occupational exposure. Immediately, or soon as feasible after use, contaminated sharps (reusable) shall be placed in appropriate containers. The containers shall be puncture resistant, labeled and color-coded properly, and leak-proof. C. Facility or Site Maintenance or Housekeeping Facilities or Sites shall be maintained in a clean and sanitary condition. All equipment and working surfaces shall be cleaned and decontaminated after contact with blood or other potentially infectious materials. Broken glass which may be contaminated with blood or other infectious material shall not be picked up directly with the hands. It shall be cleaned up using mechanical means only or with appropriate hand protection. D. Vaccinations Hepatitis B vaccine shall be made available, at no cost, to all employees. The vaccination shall be offered within 10 working days of initial assignment to all employees who have or potential to have occupational exposure. Employees who decline the vaccination shall be required to sign a release. The release shall be kept on file with the employee’s record. No employee shall work in an area where there is occupational exposure or a major potential for exposure unless he has had the Hepatitis vaccination.

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Policy No:EHS-516

Bloodborne Pathogens

Employees who initially decline the Hepatitis B vaccine may, at a later date, receive the vaccine at no charge, provided they are still S&W Energy employees with the potential for occupational exposure.

4

Post Exposure Precautions All surfaces exposed to blood or other potentially infectious materials shall be wiped clean and disinfected using water and bleach solution (recommended 10:1 ratio). Biohazard clean up and disposal kits shall be used to clean items or equipment and surfaces that were exposed to blood or other potentially infectious materials. PPE or laundry that does not meet the Regulated Waste definition shall be disposed of in the normal trash or laundry. •

Band-Aids, gauze pads, janitorial cleaning supplies, and toiletries shall not be considered Regulated Waste if they do not meet the definition of Regulated Waste and may be disposed of in the normal trash.

Regulated Waste shall be placed in containers which are: • • • •

Closable; Constructed to contain all contents to prevent leakage of fluids during handling, storage, or transport; Labeled or color coded in accordance with guidelines included in this section; and Closed prior to removal to prevent spillage or protrusion of contents during handling, storage, transport, or shipping.

If outside contamination of the regulated waste container occurs, it shall be placed in a second container that meets all the criteria of the first container. Contaminated laundry and PPE shall be handled as little as possible and shall be bagged or containerized where they were used and without being sorted or rinsed. •

The employer shall ensure that employees who have contact with contaminated laundry wear protective gloves and other appropriate PPE to prevent exposure.

Warning labels shall be affixed to containers of regulated waste or other potentially infectious materials. Labels shall be fluorescent orange or orange-red, with lettering and symbols in a contrasting color. Each label shall have the BIOHAZARD name and symbol (reference regulatory standard for symbol). Red bags or red containers may be substituted for labels.

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Policy No:EHS-516

Bloodborne Pathogens



Labels shall be affixed as close as feasible to the container by string, wire, adhesive or other method that prevents their loss or unintentional removal.



Regulated waste that has been decontaminated need not be labeled or colorcoded.

Biohazardous waste can be stored on site for no longer than 90 days and must be removed by a Department of Health Services authorized medical waste hauler. •

5

Records of any medical waste transported off-site for treatment and disposal shall include quantity of waste transported, the date transported and the name of the registered waste hauler or individual hauling the waste. Records shall be kept on-site for at least 2 years.

Post Incident Actions The Facility Manager, or designee shall do a post-incident evaluation and follow-up each time an employee experiences an exposure incident. Then post incident evaluation is to identify and correct problems in order to prevent reoccurrence of similar events and shall include the following: • • • • • • •

Engineering control in place at the time of the Incident; Safe work practices in place at the time of the Incident; PPE and clothing utilized at the time of the Incident; and Policy control failures.

The post incident evaluations shall be maintained on file at the Facility or Site for at least 2 years.

6

Medical Evaluations and Medical Records

A. Evaluations Following any report of an exposure incident, a confidential medical evaluation and follow-up shall be conducted, including: • •

Circumstances and routes of exposure; If the source individual is unknown or their consent for testing is denied, it shall be documented and determined if and when possible collection and testing of their blood may be accomplished to determine HBV and HIV antibodies.

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Policy No:EHS-516

Bloodborne Pathogens

Collection and testing of an exposed employee’s blood for HBV and HIV status shall be done as soon as possible after consent is obtained. If the employee consents to baseline blood testing, but no HIV testing, the sample shall be preserved for a minimum of 90 days during which time testing will be done at the employee’s election. The exposure evaluating physician (or licensed healthcare professional) shall have access to the following information: • • • •

A copy of the applicable OSHA regulations; A description of the exposed employee’s duties as related top, occupational exposure; Routes of exposure; and Employee’s treatment record, including vaccination status.

The exposed employee shall receive a copy of the evaluating physician’s written report within 15 working days of completion of the evaluation. The report shall contain the following: •

Recommendations regarding the indications and receipt of Hepatitis B vaccine; • A statement that the employee has been informed of the results of the evaluation as well as information regarding other medical conditions resulting from the incident which may, in the future, require further evaluation and treatment; and • Any other findings or diagnoses shall remain confidential (Reference Medical Records Access / Recordkeeping Procedure in S&W Energy’s EHS Manual). B. Records Accurate medical records shall be established and maintained for each employee with occupational exposure(s). Medical records shall contain the following information: • • • • •

Employee name and social security number; A copy of the employee Hepatitis B vaccine record, or a signed statement declining the vaccination; A copy of the result of the examinations, testing and any follow-up procedures; A copy of the health care professional’s written report; and A copy of the information provided to the evaluation health care professional.

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Policy No:EHS-516

Bloodborne Pathogens

Employee records shall be kept confidential. Information contained in employee medical records shall not be disclosed to any person without the employee’s written consent, except as provided by law. (Refer to Medical Records Access / Recordkeeping Procedure in S&W Energy’s EHS Manual). Employee medical records shall be maintained for the duration of employment plus thirty years.

7

Training All S&W Energy Facility or Site employees (including Field personnel) shall be trained on the requirements and guidelines of the Bloodborne Pathogens policy, program, and procedure initially, upon hire. The training program shall contain at least the following elements: • • • • • • • • • • •

An accessible copy of the regulatory text of this standard and an explanation of its contents (this procedure); A general overview of the symptoms of bloodborne pathogens; An explanation of the modes of transmission of bloodborne pathogens; An explanation of the appropriate methods for recognizing tasks and other activities that may involve exposure to blood or other potentially infectious materials; An explanation of the use and limitations and methods that will prevent or reduce exposure including appropriate engineering controls, work practices, and PPE; Information on the types, proper use, location, removal, handling, decontamination and disposal of PPE; Information on the Hepatitis B vaccination; Information on the appropriate actions to take and persons to contact in an emergency involving blood or other potentially infectious materials; An explanation of the procedure to follow if an exposure incident occurs; Information on the post-exposure evaluation and follow-up; and An explanation of the signs, labeling, and color-coding of regulated waste and biohazardous waste.

Refresher training is given annually or additional training may be required when changes or modifications to tasks include added potential for exposure.

Bloodborne Pathogens training can also be given as part of CPR / First Aid training and is typically a topic covered as part of that training. If CPR and/or First Aid training is given and bloodborne pathogens is part of this training, it will satisfy the requirements of the procedure.

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Policy No:EHS-516

8

Bloodborne Pathogens

Auditing / Inspections The Bloodborne Pathogens Policy and Procedure shall be reviewed every year (annually). This procedure will be updated as necessary.

9

References 29 CFR 1910.1030

Bloodborne Pathogens

Page 9

Environmental Health and Safety Manual Policy No. EHS-517

Policy Title: Compressed Gas Cylinders

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2 3 4 5 6 7 8 9 10

Purpose and Scope.................................................................................................. 2 Definitions ................................................................................................................ 2 General Precautions and Requirements .................................................................. 2 Handling of Compressed Gas Cylinders .................................................................. 3 Compressed Gas Cylinder Storage.......................................................................... 3 Compressed Gas Cylinder Connection and Use...................................................... 4 Specific Compressed Gas Requirements ................................................................ 4 Training .................................................................................................................... 5 Auditing / Inspections ............................................................................................... 6 References ........................................................................................................... 6

Page 1

Policy No:EHS-517

Compressed Gas Cylinders

1 Purpose and Scope This procedure establishes the guidelines and requirements for handling, use and storage of compressed gases (cylinders). This includes flammable, oxidizing, corrosive and toxic gas cylinders, typically used at S&W Energy Facilities or Sites. The requirements of this procedure meet the compliance requirements established by the regulatory standards.

2 • • •

3

Definitions Corrosion (or Pitting) – The loss of wall thickness of a compressed gas cylinder by corrosive media. Flammable Gases – Gases which when mixed with air in concentrations of 13% or less (by volume) form a flammable mixture. Oxidizing Gases – Non-flammable gases, which in the presence of an ignition source and a fuel can support and vigorously accelerate combustion. Common oxidizing gases include oxygen and chlorine.

General Precautions and Requirements

Do not use compressed gas cylinders as rollers, supports or for any other purpose other than to contain and use the content as received. Do not place compressed gas cylinders where they can become part of an electrical circuit. When used for welding, the cylinders shall not be grounded or used for grounding. Do not expose compressed gas cylinders to extreme temperatures. Do not ship leaking or defective compressed gas cylinders. Contact the manufacturer for instructions. If the cylinders or valves on the cylinder are noticeably corroded, notify the gas manufacturer and follow their instructions. Keep valve protection and valve outlet caps on the cylinders at all times except when containers are secured and connected to dispensing equipment. No employee shall modify, tamper with, obstruct, remove or repair any part of the compressed gas cylinder, including pressure relief devices, or valve protection devices. Do not direct compressed gas streams toward any person. Dispose of non-refillable cylinders according to manufacturer’s recommendations. Compressed gas cylinders shall not be taken into tanks, unventilated rooms, or other confined spaces (this does not apply to gas cylinders associated with self-contained breathing apparatus, SCBAs). The contents of the compressed gas cylinder shall be properly labeled on the cylinder and the labels shall be kept in legible condition. If the label cannot be read and the employee is unsure of the contents, the compressed gas shall not be used until the contents have been verified. Page 2

Policy No:EHS-517

Compressed Gas Cylinders

Prior to each use, a visual inspection of the compressed gas cylinders shall be performed to determine that they are in good condition. Visual inspection includes checks for dents, bulges, cuts, gouges, digs, corrosion, pitting, signs of exposure to fire, or weld defects. •

4

Cylinders that are questionable should be returned to the manufacturer of the same type (or equivalent re-qualification agency) for re-inspection.

Handling of Compressed Gas Cylinders

Cylinders must not be rolled in the horizontal position or dragged in any manner. Always handle or consider the compressed gas cylinders as being full. Use an appropriate hand truck or similar handling device to move the cylinders. Make sure the cylinders are properly secured prior to moving them. Use caution to guard against cylinders violently striking against each other or other surfaces. Never lift a compressed gas cylinder by its cylinder cap. Only properly trained persons shall handle compressed gases.

5

Compressed Gas Cylinder Storage

A sign must be posted showing the hazard class or the name of the gases to be stored in each container storage area. “NO SMOKING” signs must be posted in the vicinity of the compressed gas storage area where appropriate. Cylinders should be grouped together according to hazard class, and separate storage should be provided for full and empty cylinders. Cylinders shall not be stored near readily ignitable substances. Cylinders should not be exposed to corrosive chemicals or fumes. Cylinders shall not be stored near unprotected platform edges or in locations where heavy moving objects may strike or fall on them. They should be stored in such a manner as to not obstruct exit routes or means of egress. Cylinders shall be stored in locations that are free from long exposures to damp environments (to prevent corrosion on the bottom of the cylinder). If stored on paved surfaces, the surface should be graded to prevent accumulation of water. Do not store cylinders in the sun as this may cause extreme temperature elevations and temperature swings. Cylinders shall be stored upright and secured to prevent falling (both full and empty cylinders). They shall be stored valve-end up.

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Policy No:EHS-517

6

Compressed Gas Cylinders

Compressed Gas Cylinder Connection and Use

The container valve shall be kept closed at all times except when the container is in use. Valve outlets shall be pointed away from all personnel when the valve is being opened. On valves without hand wheels, the wrench provided or recommended by the gas manufacturer must be used when opening or closing the valve. Hammers or other tools shall not be sued in attempting to open or close the valve. Open the cylinder valve slowly when using the compressed gas. Where compressed gas cylinders are connected to a manifold, the manifold and its related equipment, such as regulators, must be of proper design (appropriate temperatures, pressures, and flows) for the product they are to contain. When compressed gas cylinders are connected to a process where there is potential for back flow of process materials that may contaminate the cylinder, a check valve or other suitable device shall be used to prevent back flow into the regulator. Piping, regulators and other equipment shall be kept gas tight to prevent leakage (use an approved leak test solution or instrument). NEVER tighten connections or leaking fittings or attempt repairs while the system is under pressure. Prior to removing a regulator from a cylinder, the cylinder valve shall be closed and the regulator relieved of gas pressure. Equipment including regulators, hoses, gauges, etc., provided for use with a particular compressed gas shall not be used on gas cylinders containing a gas of different chemical properties unless information is obtained from the manufacturer that it can be done safely.

7

Specific Compressed Gas Requirements

In addition to the specific requirements for compressed gases described in this section, all general requirements also apply. A. Flammable Gases Do not sue flammable gases near open flames, sources of heat, adjacent to oxidizers and non-explosion proof electric systems, or near ungrounded electrical equipment. Post NO SMOKING signs around flammable gas storage areas and ensure portable fire extinguishers are available for fire emergencies. A flame shall not be used for detection of flammable gas leaks. Use either a flammable gas leak detector or a compatible gas leak detection solution. Spark proof tools shall be used when working with or on flammable compressed gas cylinders or systems.

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Policy No:EHS-517

Compressed Gas Cylinders

Flammable gas cylinder storage areas shall be well ventilated. The storage area must be kept free of combustible materials. Heating of these areas shall be by steam, hot water or other indirect means. Direct heating by flame is PROHIBITED. Flammable gas cylinders must be kept at least 20 feet from flammable liquids, highly combustible materials and oxidizers. Do not store flammable gas cylinders near arcing equipment, open flame or other sources of ignition. Flammable compressed gas systems, piping, tubing, fittings, gaskets, etc. must be suitable for the applicable compressed flammable gas service and for the pressures and temperatures involved. All lines and equipment associated with flammable gas systems should be grounded. B. Oxidizers Any material used in contact with oxidizing agents must be suitable for this type of service. Valves, piping, fittings, regulators, and other equipment used in oxygen service shall be of a material and pressure rating compatible with oxygen. Equipment used for oxygen must be cleaned with oxygen compatible materials free from oils, greases, and other contaminants. Oxidizers shall be stored separately from flammable gas containers and combustible materials. A minimum distance of 20 feet or a non-combustible barrier having a fire resistance rating of at least 30 minutes is considered a minimum requirement. C. Corrosive and Toxic Gases Areas where corrosive gases are utilized must be equipped with emergency showers and eyewash fountains. Toxic and corrosive gases must be stored outdoors in a separate non-combustible building without other occupancy or in a separate room without other occupancy. The room shall be constructed of non-combustible materials with a fire resistance rating of at least 1 hour. Storage areas must be adequately ventilated to prevent hazardous concentrations.

8

Training Each S&W Energy Facility or Site employee (including Field personnel) who will be involved with handling, using, or storing compressed gases and compressed gas cylinders, shall be trained on the requirements and guidelines of this procedure. Refresher training is required every 3 years.

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Policy No:EHS-517

9

Compressed Gas Cylinders

Auditing / Inspections The Compressed Gas Cylinder Procedure shall be reviewed every 3 years. This procedure will be updated as necessary.

10 References 29 CFR 1910.101

Compressed Gases – General Requirements

29 CFR 1910.252

Welding, Cutting, Brazing

29 CFR 1910.253

Oxygen-Fuel Gas Welding and Cutting

Page 6

Environmental Health and Safety Manual Policy No. EHS-518

Policy Title: Hot Work

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2 3 4 5 6 7 8

Purpose and Scope.................................................................................................. 2 Definitions ................................................................................................................ 2 Procedure ................................................................................................................ 2 Special Precautions ................................................................................................. 4 Completion of Hot Work ........................................................................................... 5 Training .................................................................................................................... 5 Auditing / Inspections ............................................................................................... 5 References............................................................................................................... 5

Page 1

Policy No:EHS-518

Hot Work

1 Purpose and Scope This procedure provides the requirements and guidelines to ensure appropriate fire prevention precautions are taken before Hot Work is performed. It also provides a method to issue and authorize Hot Work Permits.

2 •

Definitions Combustible Material – A material capable of igniting and burning; a material with a flash point at or above 100 degrees F (38 degrees C). Fire Watch – A designated individual, trained in the use of fire extinguishers and familiar with Facility or Site fire alarm sounds, signals, and fire procedures, required during welding, cutting, burning (or other Hot Work) operations. A Fire Watch shall be maintained for at least one half hour (30 minutes) after completion of Hot Work to detect and extinguish possible smoldering fires. Flammable Material – A material easily ignited and capable of burning with high rapidity; a material with a flash point below 100 degrees F (38 degrees C). Flash Point – Lowest temperature at which a liquid or solid gives off a vapor in such a concentration that when the vapor combines with air near the surface of the liquid or solid, a flammable mixture is formed. The lower the flash point, the more flammable the product. Hot Work – Any work that can cause sufficient heat to ignite nearby combustible or flammable material. This pertains primarily to the use of welding and burning equipment, but can include heat-treating, riveting, cutting, open fires, portable grinders, non-explosion-proof equipment or any other flames or spark-producing equipment. Hot Work Permit – A Permit required and issued prior to any Hot Work being performed, verifying that all fire hazards have been eliminated or controlled providing a safe area for the Hot Work operation. Permit indicates location of fire safety alarms and contacts in case of emergency (fire), location of Hot Work operation, valid length of Permit and the Fire Watch present. The Permit requires authorizing employee signature (i.e., Supervisor issuing Permit or designee) and Fire Watch.



• •





If all identified fire hazards cannot be removed from the area where Hot Work will be performed or moved to a safe vicinity and guards cannot be constructed to confine the heat, sparks, slag, etc., generated during these operations, no Hot Work shall be performed.

3

Procedure

A Hot Work Permit is required prior to conducting any Hot Work operations. The permit shall document all fire protection and prevention requirements. The Permit shall include, at a minimum: the date(s) authorized for Hot Work, the object on which Hot Page 2

Policy No:EHS-518

Hot Work

Work is to be performed, operator performing work, name of the Fire Watch, information on emergency (fire) contacts and equipment, and signature of authorization. A sample Hot Work Permit is included as part of this Procedure in the Attachment Section. If a Contractor is to perform Hot Work, the Facility or Site must advise and instruct the Contractor of all combustible, flammable, or hazardous conditions that may be present. A Contractor may complete the Hot Work Permit; however, authorization is required from the Facility or Site (i.e., S&W Energy) Supervisor, or designee. •

• •



• •

• •

Prior to Hot Work, the area where Hot Work is to be performed shall be inspected by a Shift Supervisor (responsible individual), or designee. All precautions shall be taken to ensure safety during operation (refer to the Special Precautions in next Section). A combustible gas test may be performed by the Shift Supervisor before issuing a Hot Work Permit where flammable gases may be present. The Supervisor, or designee, in charge of the work shall check to see that no other work in the area, such as line breaking or normal production procedures, can cause an unexpected release of flammable materials. Where equipment has contained flammable liquids, blinding, cleaning, venting, and disconnection, as necessary, is required to ensure that no flammable liquids enter the heated work area. The Supervisor shall designate a Fire Watch for the operation. During operation, the Fire Watch shall watch for fires in all exposed areas and try to extinguish them only when obviously within capacity of equipment available or sound the alarm. The Supervisor shall ensure proper fire extinguishing equipment or other means of emergency / fire fighting is readily available. The Supervisor, or designee, shall complete the Hot Work Permit. Upon completion and verification of all safety hazards and information on the Permit, the Supervisor, or designee, shall have the designated Fire Watch sign the Permit upon their approval). The Supervisor shall then sign the Permit, authorizing the work to commence. The Permit shall be posted in area of Hot Work or made readily available for anyone to review at any time during period of work. If the permitted activity carries over onto another shift, another permit shall be issued with the same degree of inspection and control as the preceding shift. The permit shall remain on the job until it is completed.

NOTE: Hot Work shall not be permitted in the following situations: • • •

In areas not authorized by Management; or In buildings with sprinkling systems while such protection is impaired; or In the presence of explosive atmospheres (mixtures of flammable gases, vapors, etc.) or explosive atmospheres that may develop in cleaned areas where these atmospheres existed in the past; or

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Policy No:EHS-518



4

Hot Work

In areas near the storage of large quantities of exposed, ignitable materials.

Special Precautions

The following special precautions shall be adhered to whenever and wherever applicable. They shall be checked and verified as part of the Hot Work Permit approval process, prior to commencement of Hot Work. Wherever there are floor openings (cracks in the flooring), cracks or holes in the walls, open doorways, or broken windows, precautions shall be taken so that no readily combustible material will be exposed to sparks that may go through those openings. Precautions should be taken to ensure that molten metal and slag do not fall to floors below, where welding or cutting is performed overhead and hot material may fall to the ground. The area below should be barricaded or roped off to prevent people from walking underneath. Suitable fire extinguishing equipment shall be maintained (and ready) for immediate use in case of emergency. Fire extinguishing equipment may consist of pails of water, buckets of sand, hose, or portable extinguisher. Fire Watchers are required whenever Hot Work is performed in locations where fires might develop or any of the following conditions exist: • • • •

If there exists combustible material, in building construction or contents, closer than 35 feet (10.7 meters) to the point of operation; If there exists combustible material more than 35 feet (10.7 meters) away but are easily ignited by sparks; Wall of floor openings within 35 foot (10.7 meter) radius expose combustible material in adjacent areas; or Combustible materials are adjacent to the opposite side of partition, wall, ceiling, etc., and are likely to be ignited by conduction or radiation.

Floors containing combustible material shall be swept clean within a radius of 35 feet (10.7 meters). If the floor itself is made of a combustible material, it shall be kept wet, covered with sand, or protected by fire-resistant shields. (If floors have been wet, personnel arc welding, a type of Hot Work, shall be protected from possible shock. Where practical, all combustibles shall be relocated at least 35 feet (10.7 meters) from the Hot Work operation. If not practical to move, combustibles shall be protected with flameproof covers or otherwise shielded to prevent fire. Where Hot Work is performed near walls, partitions, ceiling, or roof of combustible construction, fire-resistant shields shall be provided to prevent ignition. If performed near non-combustible walls, precautions shall be taken to prevent Page 4

Policy No:EHS-518

Hot Work

ignition of combustibles on the other side, due to conduction or radiation, preferable by relocating the combustibles.

5

Completion of Hot Work

Work area and all adjacent areas where sparks might have spread shall be inspected by the Fire Watch for at least 30 minutes after the work is completed and no more fire conditions are noted. Hot Work Permits shall be kept on file for one year.

6

Training

All S&W Energy Facility or Site employees (including Field personnel) who will be involved with Hot Work operations or working in areas where Hot Work may be performed shall be trained on the requirements and guidelines of this procedure initially, upon hire. Refresher training is required every 2 years. (Typically training is given as part of Welding, Cutting, and Brazing training course).

7

Auditing / Inspections

The Hot Work Procedure shall be reviewed every 2 years. Documented Hot Work Permits may be reviewed as part of this inspection or audit. This procedure will be updated as necessary.

8

References 29 CFR 1910.119

Process Safety Management / Hot Work

29 CFR 1910.252 (Subpart Q)

Welding, Cutting, Brazing / Fire Protection and Prevention

NFPA Standard 51B

Page 5

Environmental Health and Safety Manual Policy No. EHS-519

Policy Title: Radiation

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2 3

Scope....................................................................................................................... 2 IONIZED (X-RAY) RADIATION................................................................................ 2 NON-IONIZED (LASERS) RADIATION ................................................................... 2

Page 1

Policy No:EHS-519

Radiation

1 Scope This section provides a broad guidance pertaining to working with or around radiation. Safety is paramount when working with any form of radiation. This section in no way overrides or supercedes any regulatory standards and compliance with those standards will be maintained at all times.

2 IONIZED (X-RAY) RADIATION •

• • • • •

3

Any activity that involves the use of radioactive materials, whether or not under license from the Nuclear Regulator Commission (NRC), shall be performed by competent persons specially trained in the proper and safe operation of such equipment. When materials are used under NRC license, only persons actually licensed, or competent persons under the direct supervision of the licensee, shall perform such work. Technicians shall sufficiently barricade and post standard radiation signs around areas to be tested so that employees cannot be exposed. Technicians shall not leave a radioactive source unattended even though it may be locked in its housing and the area barricaded. Any deviation from this policy must be proposed in writing and receive joint approval of both the Safety Supervisor and the Construction Manager, or the Manager of Safety, whichever is applicable. Any paperwork necessitated by loss, contamination, etc., as required by the NRC, shall be the sole responsibility of the Safety Supervisor or the using Subcontractor with copies to the Construction Manager and the Manager, Safety.

NON-IONIZED (LASERS) RADIATION • • • • •



Only qualified and trained employees shall be assigned to install, adjust, and operate laser equipment. Proof of qualification of the laser equipment operator shall be available and in possession of the operator at all times. Employees, when working in areas in which a potential exposure to direct or reflected laser light greater than 0.005 watts (5 milliwatts) exists, shall be provided with anti-laser eye protection devices. Areas in which lasers are used shall be posted with standard laser warning placards. Beam shutters or caps shall be utilized, or the laser turned off, when laser transmission is not actually required. When the laser is left unattended for a substantial period of time, such as during lunch hour, overnight, or at change of shifts, the laser shall be turned off. Only mechanical or electronic means shall be used as a detector for guiding the internal alignment of the laser. Page 2

Policy No:EHS-519

• • • •

• •

Radiation

The laser beam shall not be directed at employees. When it is raining or snowing, or when there is dust or fog in the air, the operation of laser systems shall be prohibited where practical. Employees shall be kept out of range of the area of source during such weather conditions. Laser equipment shall bear a label to indicate maximum output. Employees shall not be exposed to light intensities above:

A. Direct Staring: 1 microwatt per square centimeter B. Incidental Observing: 1 milliwatt per square centimeter C. Diffused Reflected Light: 2-1/2 watts per square centimeter Laser units in operation should be set up above the heads of employees when possible. Employees shall not be exposed to microwave power densities in excess of 10 milliwatts per square centimeter.

Page 3

Environmental Health and Safety Manual Policy No. EHS-520

Policy Title: Machine Guarding

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2 3 4

Purpose and Scope.................................................................................................. 2 Types of Guarding.................................................................................................... 2 General Requirements for Machine Guards............................................................. 2 References............................................................................................................... 3

Page 1

Policy No:EHS-520

Machine Guarding

1 Purpose and Scope Employee exposure to unguarded or inadequately guarded machines is prevalent in many workplaces. Consequently, workers who operate and maintain machinery suffer approximately 18,000 amputations, lacerations, crushing injuries, abrasions, and over 800 deaths per year. Amputation is one of the most severe and crippling types of injuries in the occupational workplace, and often results in permanent disability. This section focuses on recognizing and controlling common amputation hazards associated with the operation and use of certain types of machines. Moving machine parts have the potential for causing severe workplace injuries, such as crushed fingers or hands, amputations, burns, blindness, just to name a few. Safeguards are essential for protecting workers from these needless and preventable injuries. Any machine part, function, or process which may cause injury must be safeguarded. When the operation of a machine or accidental contact with it can injure the operator or others in the vicinity, the hazards must be either eliminated or controlled.

2 Types of Guarding One or more methods of machine guarding shall be provided to protect the operator and other employees in the machine area from hazards such as those created by point of operation, ingoing nip points, rotating parts, flying chips and sparks. Examples of guarding methods are: • • •

3

Barrier guards Two-hand tripping devices Electronic safety devices

General Requirements for Machine Guards

Guards shall be affixed to the machine where possible and secured elsewhere if for any reason attachment to the machine is not possible. The guard shall be such that it does not offer an accident hazard in itself. Point of operation is the area on a machine where work is actually performed upon the material being processed. The point of operation of machines whose operation exposes an employee to injury shall be guarded. The guarding device shall be in conformity with any appropriate standards or, in the absence of applicable specific standards, shall be so designed and constructed as to prevent the operator from having any part of his body in the danger zone during the operating cycle. Special hand tools for placing and removing material shall be such as to permit easy handling of material without the operator placing a hand in the danger zone. Such tools shall not be in lieu of other guarding required by this section, but can only be used to supplement protection provided.

Page 2

Policy No:EHS-520

Machine Guarding

The following are some of the machines which usually require point of operation guarding: • • • • • • • • • •

Guillotine cutters. Shears. Alligator shears. Power presses. Milling machines. Power saws. Jointers. Portable power tools. Forming rolls Calendars

A. Barrels, containers, and drums Revolving drums, barrels, and containers shall be guarded by an enclosure which is interlocked with the drive mechanism, so that the barrel, drum, or container cannot revolve unless the guard enclosure is in place. B. Exposure of blades When the periphery of the blades of a fan is less than seven (7) feet above the floor or working level, the blades shall be guarded. The guard shall have openings no larger than one-half (1/2) inch. C. Anchoring fixed machinery Machines designed for a fixed location shall be securely anchored to prevent walking or moving.

4

References 29 CFR 1910.212

Machine Guarding

Page 3

Environmental Health and Safety Manual Policy No. EHS-521

Policy Title: Tools

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2

Purpose and Scope.................................................................................................. 2 General Requirements ............................................................................................. 2

Page 1

Policy No:EHS-521

1

Tools

Purpose and Scope

The proper use of all tools is vitally important in the personal safety of all employees. The following section provides general guidelines for the use of a variety of tools. This should not be considered an all-inclusive policy and prudent judgment must be used at all times while operating any tool or equipment.

2

General Requirements • • • • • • • • •

Tools shall be used only for the purpose for which they are designed. All tools, regardless of ownership, shall be of an approved type, maintained in first class condition, and be subject to inspection at any time. Tools with sharp edges shall be stored and handled so that they will not cause damage or injury. Tools such as chisels, punches, drills, and hammers that become cracked or mushroomed shall be dressed, repaired, or replaced before further use. Tools, except those normally carried on belts, that must be raised or lowered from one elevation to another shall be placed in an approved container or firmly attached to hand lines. Tools shall not be thrown from place to place or from person to person under any circumstances. Tools shall not be left lying around where they could cause tripping or stumbling. Tools shall never be placed unsecured on elevated places. When working on or above open grating or boards, care should be taken not to place tools on this walkway lest they be knocked off, causing injury to people below. All hand-held power tools must be equipped with a constant pressure switch that will shut off the power when the pressure is released. Switches or valves on any type of power tools, especially air tools, shall not be wired or tied in the open position. Any tool which is damaged or defective shall not be used. This includes wrenches with sprung or damaged jaws and chisels, drills, or punches with flared or damaged heads. Pipes shall not be used to extend a wrench handle for added leverage unless the wrench was designed for such use.

A. HAND TOOLS • Files, rasps, and other hand tools that have a sharp tang shall not be used without approved handles. • Wood handles that are loose, cracked, or splintered shall be replaced. Taping or lashing them with wire will not be permitted. • Only tools designed with striking faces shall be hit with a hammer. Files and screwdrivers should never be hit. • The use of adjustable jawed wrenches should be avoided. Use of the proper sized wrench is recommended. • Pipe wrenches shall never be used on bolts or nuts. • Striking two hammers together shall be avoided.

Page 2

Policy No:EHS-521

Tools

B. POWDER ACTUATED TOOLS (Stud Guns) • •

• • • • • • • • • • • •

Only low velocity powder actuated guns or captive stud drives will be permitted for use. Only employees who possess valid operator cards issued for the make and model of tool to be used are permitted to use powder actuated tools. The manufacturer's representative will conduct training classes at the job site upon request. Powder charges and fasteners shall be stocked in sufficient quantities to prevent the use of improper fasteners or charges. Powder actuated tools shall not be overloaded. The tool shall be tested each day before loading to see that safety devices are in proper working condition. The method of testing shall be in accordance with the manufacturer's recommended procedure. Any tool found not in proper working order, or that develops a defect during use, shall be immediately removed from service, tagged, and not used until properly repaired. Personal protective equipment shall be used in accordance with Policy 125. Tools shall not be loaded until just prior to the intended firing time. Neither loaded nor empty tools are to be pointed at any employee. Hands shall be kept clear of the open barrel end. Loaded tools shall not be left unattended. Fasteners shall not be driven into very hard or brittle materials, including, but not limited to, cast iron, glazed tile, surface-hardened steel, glass block, live rock, face brick, or hollow tile. Driving into materials easily penetrated shall be avoided unless such materials are backed by a substance that will prevent the pin or fastener from passing completely through and creating a flying missile hazard on the other side. No fastener shall be driven into a spalled area caused by unsatisfactory fastening. Tools shall not be used in an explosive or flammable atmosphere. All tools shall be used with the correct shield, guard, or attachment recommended by the manufacturer.

C. ELECTRIC TOOLS • • •

Portable electric tools (except those with self-contained power), such as electric drills, saws, etc, shall have their frames grounded at all times when connected to a source of power unless of the double insulated, UL-approved type. All electric cords and cables must be covered or elevated to protect them from damage and from becoming tripping hazards. All electric tools used will be protected with a GFCI located as near the power supply as possible.

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Policy No:EHS-521

• • •

Tools

All circular saws shall have working guards in place at all times. All plugs shall be butt end type only. Plugs with metal bodies are prohibited. All electric tools and cord sets shall be inspected in accordance with OSHA Rules and Regulations 29 CFR 1926.400 9(h) (3) and Policy 121.

D. PNEUMATIC TOOLS • • •

Employees shall not engage in horseplay with compressed air hoses. Practical jokes can cause serious injury and are strictly forbidden. Line pressure shall be maintained as low as possible to effectively accomplish the job at hand. An approved safety check valve or anti-surge valve must be installed at the manifold outlet of each supply line 1/2 inch in diameter or greater for hand-held pneumatic tools.

Page 4

Environmental Health and Safety Manual Policy No. EHS-522

Policy Title: Cranes and Rigging

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2 3 4 5 6 7 8 9 10 11

Purpose and Scope.................................................................................................. 2 Definitions ................................................................................................................ 2 General Requirements - Cranes .............................................................................. 3 Requirements for Moving the Load (Crane) ............................................................. 5 Crane Inspections .................................................................................................... 6 Crane Testing........................................................................................................... 7 Crane Maintenance.................................................................................................. 7 General Requirements - Slings ................................................................................ 7 Training .................................................................................................................. 11 Auditing / Inspections ......................................................................................... 11 References ......................................................................................................... 11

Page 1

Policy No:EHS-522

Cranes and Rigging

1 Purpose and Scope This procedure provides guidance to maintain compliance with the regulatory standards for the safe design, operation, and maintenance of cranes and other lifting devices typically found at S&W Energy work sites.

2 • • • • • • • • • • • • • • • • • • • •

Definitions ANSI – American National Standards Institute Appointed – Assigned specific responsibilities by the employer or the employer’s representative. Bridge – Part of the crane consisting of girders, trucks, and ties, footwalks and drive mechanism which carries the trolley or trolley(s). Boom – A member hinged to the front of the rotating superstructure with the outer end supported by ropes leading to a gantry or A-frame and used for supporting the hoisting tackle. Cab – The operator’s compartment of the crane. Cab-Operated Crane – A crane controlled by an operator in a cab located on the bridge or trolley. Counterweight – A weight used to supplement the weight of the machine in providing stability for lifting working loads. Designated – Selected or assigned by the employer or the employer’s representative as being qualified to perform specific tasks or duties. Footwalk – The walkway with handrail, attached to the bridge or trolley for access purposes. Frequent Inspection – Inspections of daily to monthly intervals. Gantry Crane – A crane similar to an overhead crane except that the bridge for carrying the trolley or trolleys is rigidly supported on two or more legs running on fixed rails or other runway. Hoist – An apparatus that may be part of the crane, exerting a force for lifting and lowering. Load – The total superimposed weight on the load block or hook. Load Block – The assembly of hook or shackle, swivel, bearing, sheaves, pins, and frame suspended by the hoisting rope. Outriggers – Extendable or fixed metal arms attached to the mounting base which rests on the supports at the outer ends. Overhead Crane – A crane with a moveable bridge carrying a moveable or fixed hoisting mechanism and traveling on an overhead fixed runway structure. Periodic Inspection – Inspections of 1 to 12 month intervals. Proof Load – The load applied in performance of a proof test. Proof Test – A nondestructive tension test performed by the sling or crane manufacturer or an equivalent entity to verify construction and workmanship of the sling and or crane. Qualified Person – A person with specific training, knowledge, and experience in the area for which the person has responsibility and the authorization to control.

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Policy No:EHS-522

• • •

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Cranes and Rigging

Rated Load – The maximum load for which a crane or individual hoist is designed and built by the manufacturer and shown on the equipment nameplate(s). Running Sheave – A sheave that rotates as the load block is raised or lowered. Sheave – A wheel or disk with a grooved rim, used as a pulley.

General Requirements - Cranes

A. Overhead and Gantry Cranes All new overhead and gantry cranes constructed and installed must meet design specifications of the American National Standard Safety Code for overhead and gantry cranes, ANSI B30.2 The crane shall never be loaded beyond its rated load (except for test purposes). Cranes may be modified and re-rated only if the changes and supporting structure are reviewed and approved by qualified engineer(s) or the manufacturer. All other testing and labeling requirements still apply. Outdoor storage bridges shall be equipped with rail clamps and wind indicator. The wind indicator shall be provided to give a visible or audible alarm to the bridge operator at a predetermined wind velocity. The rated load of the crane shall be plainly marked on each side of the crane; each hoist shall have its rated load marked on it or on its load block and be clearly legible from the ground floor. In addition, recommended operating speeds and special hazard warnings shall be conspicuously posted on all equipment and visible to the operator while he/she is at the control station. Pendant control stations shall be kept clean and function labels kept legible. A minimum clearance of 3 inches overhead and 2 inches laterally shall be provided and maintained between crane and any obstructions. The hoist chain or hoist rope associated with the crane shall be free of kinks or twists and shall not be wrapped around the load. The load shall be attached to the load block hook by means of slings or other approved lifting devices. An accessible fire extinguisher (rating of 5BC or higher) shall be available at all operator stations or crane cabs. Hand signals to crane operators shall be those prescribed by the applicable ANSI standard for the type of crane in use. An illustration of the standard signals shall be posted at the job-site or near the crane. See Attachment section of this procedure for copy of posted hand signals Only designated personnel shall be permitted to operate a crane. Crane operator(s) shall have proper training and able to demonstrate qualifications of such training to employer, or designee, prior to operation.

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Policy No:EHS-522

Cranes and Rigging

The Facility or Site Manager / Supervisor shall designate a competent or qualified person, who shall inspect all machinery and equipment prior to each use, and during use, to make sure it is in safe operating condition. B. Crane Cabs The cab and location of control and protective equipment shall be such that all operating handles are within convenient reach of the operator when facing the direction of travel of the cab. The cab shall be located to afford a minimum of 3 inches clearance from all fixed structures. All windows in cabs shall be of safety glass, or equivalent, that introduces no visible distortion that will interfere with the safe operation of the crane. Access to the cab and/or bridge walkway shall be by a conveniently placed fixed ladder, stairs, or platform requiring no step over any gap exceeding 12 inches. Where necessary, a ladder shall be provided to give access to the cab roof. C. Crane Footwalks and Ladders If sufficient headroom is available on cab-operated cranes, a footwalk shall be provided on the drive side along the entire length of the bridge of all cranes. Where footwalks are located, there shall not be less than 48 inches of headroom provided. Gantry cranes shall be provided with ladders or stairways extending from the ground to the footwalk or cab platform. Walking surfaces shall be of anti-slip type. Stairways must be equipped with rigid and substantial handrails. Ladders shall be securely and permanently fastened in place. D. Crane Hoisting Equipment Sheaves: • • • •

Sheave grooves shall be smooth and free from surface defects that may cause rope damage. Sheaves carrying ropes that can be momentarily unloaded shall be equipped with close-fitting guards to guide ropes back into groove when the load is reapplied. Sheaves in the bottom block shall be equipped with close-fitting guards that will prevent rope from becoming fouled when the block is lying on the ground with ropes loose. All running sheaves shall be equipped with means of lubrication.

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Policy No:EHS-522

Cranes and Rigging

Ropes: • • •

4

The rated load divided by the number of parts of rope shall not exceed 20% of the nominal breaking strength of the rope. Use manufacturer’s recommendations when using hoisting ropes. Wherever rope is exposed to temperatures at which fiber cores would be damaged, rope having an independent wire rope or wire-strand core or other temperature-resistant core shall be used. Replacement rope shall be the same size, grade, and construction as original rope furnished by crane manufacturer, unless otherwise recommended by manufacturer based on use.

Requirements for Moving the Load (Crane)

The load shall be secured and properly balanced in the sling or lifting device before it is lifted more than a few inches. Before hoisting the load, the operator shall ensure that the hoist rope is not kinked and that multiple part lines are not twisted around each other. The hook shall be brought over the load so as to prevent swinging. The operator shall take every precaution to make no sudden acceleration or deceleration of the load and ensure the load does not contact any obstructions. A person shall be designated to observe clearance of the equipment and give timely warning for all operations where it is difficult for the operator to maintain desired clearance by visual means. Cranes shall NOT be used for side pulls EXCEPT when it has been determined by qualified and responsible individual that the stability of the crane will not be affected and that various parts of the crane will not become overstressed causing damage. There shall be no hoisting, lowering, or traveling of the load with an employee ON the load. All employees shall be kept clear of loads about to be lifted and of suspended loads. The operator shall avoid carrying loads over people. The operator shall test the brakes each time a load approaching the rated load is handled. The load shall not be lowered below the point where less than two full wraps of rope remain on the hoisting drum. The operator shall not leave his/her position at the controls while the load is suspended.

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Policy No:EHS-522

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Cranes and Rigging

Crane Inspections

INITIAL INSPECTION: Prior to initial use of all new or altered cranes, an initial inspection shall be conducted which complies with provisions of this procedure.

A. Daily (or prior to each use): • Check all functional operating mechanisms of cranes and associated hoists for maladjustment or excessive wear of components interfering with proper operation (visual). • Check for deterioration or leakage in lines, tanks, valves, drain pumps, and other parts of air or hydraulic systems (visual). • Check hooks for deformation or cracks (visual); Check hooks for any cracks having more than 15% in excess of normal throat opening or more than 10 degrees twist from the plane of the unbent hook. • Check hoist chains, including end connections, for excessive wear, twist, distorted links interfering with proper function or stretch beyond manufacturer’s recommendations (visual). • Check for deformed, cracked, or corroded members. • Check for loose bolts and/or rivets. • Check for cracked and worn sheaves. • Check for worn, cracked, or distorted parts such as pins, bearings, shafts, gears, rollers, locking and clamping devices. • Check for excessive wear on brake system parts, linings, pawls, and ratchets. • Check load, wind, and other indicators over their full range for any significant discrepancies. • Check for excessive wear of chain drive sprockets and excessive chain stretch. • Any noted deficiencies must be carefully examined, should be documented, and determination made as to whether they constitute a safety hazard. B. Monthly (documented / certification): • Check all items listed under daily visual checks. Documented information should include certification record which includes date of inspection, the person performing the inspection, identifier indicating what piece of equipment was inspected, and list of any deficiencies (if no deficiencies, indicate with “OK”). • Check all ropes for deterioration (loss of strength), reduction of rope diameter, signs of internal or external corrosion, signs of wear, any broken wires, corroded or broken wires at end connections, severe kinking or unstranding. • All deficiencies listed must be carefully examined and determination made as to whether they constitute a safety hazard.

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Policy No:EHS-522

Cranes and Rigging



Monthly inspection documents shall be kept on file for at least one year. A tag should be affixed to the crane (or inspected equipment) noting last inspection results and dated. C. Annual: •

A thorough annual inspection of the hoisting machinery shall be made by a competent or qualified person or by a government or private agency approved to perform inspections. The employer shall maintain a record of the results and dates of each inspection for the life of the equipment.

Any unsafe conditions disclosed by the inspections shall be corrected before operation of the crane, hooks, hoists, ropes, etc. Adjustments and repairs shall be done only by designated and qualified personnel.

6

Crane Testing

Prior to initial use, all new and altered cranes shall be tested to ensure compliance, including test of the following functions: hoisting and lowering, trolley travel, bridge travel, limit switches, and locking and safety devices. Test results shall be documented and left on file for life of the crane and associated devices. Rated Load Test: Test loads shall be more than 125% or the rated load unless otherwise recommended by the manufacturer. All tests shall be documented and kept on file for life of the crane.

7

Crane Maintenance

A preventative maintenance program based on manufacturer’s guidelines and recommendations shall be established and followed. Anytime maintenance is done on a crane that may affect the load carrying capabilities, a re-certification and proof load test must be conducted.

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General Requirements - Slings

This Section applies to slings used in conjunction with other material handling equipment for the movement of material by hoisting. Various types of slings include alloy steel chain, wire rope, metal mesh, natural or synthetic fiber rope, and synthetic web (nylon, polyester, and polypropylene). A. All Slings • Slings that are damaged or defective shall not be used. • Slings shall not be shortened with knots or bolts or other makeshift devices. • Sling legs shall not be kinked. Page 7

Policy No:EHS-522

• • • • • • • • •

• B. • • •

• • • •

Cranes and Rigging

Slings shall not be loaded in excess of their rated capacities. Slings used in a basket hitch shall have loads balanced to prevent slippage. Slings shall be securely attached to their loads. Slings shall be padded or protected from sharp edges of their loads. Suspended loads shall be kept clear of all obstructions. All employees shall be kept clear of loads about to be lifted and suspended loads. Hands or fingers shall not be placed between the sling and its load while the sling is being tightened around the load. A sling shall not be pulled from under a load when the load is resting on the sling. A visual inspection of slings and all fastenings and attachments shall be conducted daily (or before use) by a competent, qualified person designated by the employer. Every month, a documented inspection should be conducted which includes all the daily checks in addition to the sling-specific requirements (as outlined in the following sections). Monthly inspection reports should be signed, dated, and kept on file for life of equipment. All employees should familiarize themselves with the types of slings available for easiest and safest lifting. (Alloy Steel) Chain Slings Alloy steel chain slings shall have permanently affixed to it durable identification stating size, grade, rated capacity, and reach. Before each use, each new, repaired, or reconditioned alloy steel chain sling shall be proof tested by sling manufacturer or equivalent entity. Employer shall retain certificate of the proof test. Alloy steel chain slings shall be inspected monthly. The monthly inspection should include inspection on wear, check for defective welds, check for deformation and increase in length. These inspections should be documented and kept on record. Frequency of inspections may increase based on determination from frequency of sling use, severity of service conditions, nature of lifts being made, or based on experience on service life of slings. If defects or deterioration is present, the sling shall be immediately removed form service. If alloy steel chain sling heated in excess of 1000 degrees F, it shall be permanently removed from service. Slings shall be removed from service if hooks are cracked, have been opened more than 15% of the normal throat opening measured at the narrowest point or twisted more than 10 degrees from the plane of the unbent hook. All general requirements for slings apply.

C. Wire Rope Slings • Fiber core wire rope slings shall be permanently removed from service if they are exposed to temperatures in excess of 200 degrees F. • Welding of end attachments shall be performed prior to assembly of the sling. All welded attachments shall not be used unless proof tested at twice their rated Page 8

Policy No:EHS-522



capacity by the manufacturer or equivalent entity. Employer shall retain certificate of the proof test. Wire rope slings shall be immediately removed from service if any of the following conditions are present: •

• • • • • • •

Cranes and Rigging

In running ropes, six (6) randomly distributed broken wires in one rope lay, or three (3) broken wires in one strand in one rope lay; in standing ropes, more than two (2) broken wires in one lay in sections beyond end connections or more than one broken wire at an end connection; Wear or scraping of one-third the original diameter of outside individual wires; Kinking, crushing, bird caging or any other damage resulting in distortion of the wire rope structure; Evidence of heat damage; End attachments that are cracked, deformed, or worn; Hooks that have been opened more than 15% of the normal throat opening measured at the narrowest point or twisted more than 10 degrees from the plane of the unbent hook; or Corrosion of the rope or end attachments.

All general requirements for slings apply.

D. Metal Mesh Slings • Each metal mesh sling shall have permanently affixed to it a durable identification stating rated capacity for vertical basket hitch and choker hitch loading. • Handles shall have rated capacity at least equal to the metal fabric and exhibit no deformation after proof testing. • Coatings that diminish the rated capacity of the sling shall not be applied. • All new and repaired metal mesh slings shall not be used unless proof tested by the manufacturer or equivalent entity at a minimum of 1.5 times their rated capacity. • Metal mesh slings shall be immediately removed form service if any of the following conditions are met: • • • • • •

A broken weld or broken brazed joint along the sling edge; Reduction in wire diameter of 20% due to abrasion or 15% due to corrosion; Lack of flexibility due to distortion of the fabric; Distortion of the female handle so that the depth of the slot is increased more than 10%; Distortion of either handle so that the width of the eye is decreased more than 10%; A 15% reduction of the original cross sectional area of metal at any point around the handle eye; or Page 9

Policy No:EHS-522



Cranes and Rigging

• Distortion of any handle out of its plane. • All general requirements for slings apply.

E. Natural and Synthetic Fiber Rope Slings • Fiber rope slings shall have a minimum clear length of rope between eye splices equal to 10 times the rope diameter. • Knots shall not be used in lieu of splices. • Clamps not designed specifically for fiber ropes shall not be used for splicing. • Fiber rope slings shall not be used if end attachments in contact with the rope have sharp edges or projections. • Only fiber rope slings made from new rope shall be used; use of repaired or reconditioned fiber rope is prohibited. • Natural and synthetic fiber rope slings shall be immediately removed from service if any of the following conditions are present: • • • • • • •

Abnormal wear; Powdered fiber between strands; Broken or cut fibers; Variations in the size or roundness of strands; Discoloration or rotting; or Distortion of hardware in the sling.

All general requirements for slings apply.

F. Synthetic Web Slings • Each sling shall be marked or coded to show the rated capacities for each type of hitch and type of synthetic web material. • Synthetic webbing shall be of uniform thickness and width. • Nylon web slings shall not be used where fumes, vapors, sprays, mists, or liquids of acids or phenolics are used. • Polyester and polypropylene web slings shall not be used where fumes, vapors, sprays, mists or liquids of caustics are present. • Synthetic web slings of nylon or polyester shall not be used at temperatures in excess of 180 degrees F. • Synthetic web slings, which have been repaired, shall not be used unless repaired by sling manufacturer or an equivalent entity. Each repaired sling shall be proof tested by the manufacturer or equivalent entity to twice the rated capacity prior to return to service. The employer shall retain certificate of the proof test. • Synthetic web slings shall be immediately removed from service if any of the following conditions are present:

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Policy No:EHS-522

• • • • • •

9

Cranes and Rigging

Acid or caustic burns; Melting or charring of any part of the sling service; Snags, punctures, tears, or cuts; Broken or worn stitches; or Distortion of fittings.

All general requirements for slings apply.

Training

Employees assigned to operate and inspect cranes and rigging equipment shall be trained on this procedure and its requirements initially, upon hire. Refresher training is required every 2 years.

10 Auditing / Inspections The Cranes and Rigging Procedure shall be reviewed every two years. The procedure will be updated as necessary. All test and inspection records shall be maintained for the life of the equipment (crane, lifting equipment, etc.). They shall be made available upon request and readily accessible. Test and inspection records may be reviewed during auditing and inspections.

11 References 29 CFR 1910.179

Overhead and Gantry Cranes

29 CFR 1910.180

Crawler Locomotive and Truck Cranes

29 CFR 1910.184

Slings

29 CFR 1926.550

Cranes, Derricks, Hoists, Elevators, and Conveyors

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Environmental Health and Safety Manual Policy No. EHS-523

Policy Title: Means of Egress

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2 3 4 5 6 7

Purpose and Scope.................................................................................................. 2 Definitions ................................................................................................................ 2 General Requirements ............................................................................................. 2 Housekeeping .......................................................................................................... 4 Training .................................................................................................................... 4 Auditing / Inspections ............................................................................................... 5 References............................................................................................................... 5

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Policy No:EHS-523

1

Means of Egress

Purpose and Scope

This procedure provides the fundamental requirements essential to providing a safe means of egress from fire and like emergencies. The requirements of this procedure establish then minimum requirements per regulatory standards. Exits from vehicles, vessels, or other mobile structures are NOT covered by this procedure. The Means of Egress Procedure shall be closely tied to S&W Energy’s Emergency Response Procedure (and documented Plan) and S&W Energy’s Fire Protection and Prevention Procedure (and Plan).

2 • •

• • • • •

Definitions Approved – For purposes of this procedure, equipment listed or approved by a nationally recognized testing laboratory. Emergency Action Plan – A documented plan for any workplace describing the procedures the employer and employees must take to ensure employee safety from fire or any other emergency. Reference S&W Energy’s Emergency Response Procedure for detailed information and a sample template of an Emergency Action Plan. Emergency Escape Route – The route the employees are directed to follow in the event they are required to evacuate the workplace or seek a designated refuge area. Exit Access – That portion of a means of egress, which leads to an entrance to an exit. Exit Discharge – That portion of a means of egress between the termination of an exit and a public way. High Hazard (Contents or Areas) – Classified as those contents or areas where there are materials which are likely to burn with extreme rapidity or from which poisonous or toxic fumes or explosions are to feared in case of a fire. Means of Egress – A continuous and unobstructed way of exit travel from any point in a building or structure to a public way and consists of three separate and distinct parts: the way of exit access, the exit, and the way of exit discharge.

3

General Requirements

Every building or structure (new or old) designed for human occupancy shall be provided with exits sufficient to permit the prompt escape of occupants in case of a fire or another emergency. • •

The design of the exits and other safeguards shall be such that reliance for safety to life in case of fire or other emergency will not solely depend on any single safeguard. Exit access shall be so arranged that it will not be necessary to travel toward any area of high hazard occupancy in order to reach the nearest exit, unless the path of travel is effectively shielded from the high hazard location.

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Policy No:EHS-523



Means of Egress

Free and unobstructed egress must be provided from all parts of the building at all times when it is occupied. No lock or any fastening shall be installed to prevent free escape from any exit. In no case shall access to an exit be through a bathroom or other room subject to locking except where the exit is required to serve only the room subject to locking.



Every exit shall be clearly visible or the route to reach it shall be conspicuously indicated in such a manner that every occupant of every building or structure will readily know the direction of escape from any point. Each path of escape in its entirety shall be so arranged or marked that the way to a place of safety outside is unmistakable. • •



Any door, passage, or stairway that is not an exit or does not lead to an exit, but could be mistaken for an exit, must be identified with a sign reading “Not an Exit” or by a sign indicating the actual use for the space. Exits and access to exits shall be marked by readily visible signs in all cases where the exit or way to reach the exit is not immediately visible to the building’s occupants. As sign reading “EXIT” with an arrow indicating the direction of the nearest exit shall be placed in every location where this direction is not immediately apparent. The minimum width of any way of exit access shall in no case be less than 28 inches.

When more than one exit is required from a story, at lest two of the exits shall be remote from each other and so arranged as to minimize any possibility that both may be blocked by any one fire or other emergency condition. Means of egress shall be so designed and maintained as to provide adequate headroom, but in no case shall the ceiling height be less than 7 feet and 6 inches not any projection from the ceiling be less than 6 feet and 8 inches from the floor. Where a means of egress is not substantially level, such differences in elevation shall be negotiated by stairs or ramps. No furnishings, decorations, or other objects shall be placed as to obstruct exits, access thereto, egress there from or visibility thereof. Adequate and reliable illumination must be provided for all exit facilities. No building under construction shall be occupied until all exit facilities are completed and ready for use. No existing building under repair shall be occupied unless all existing exits and fire protection are maintained continuously. Every exit, way of approach to the exit and way of travel from the exit must be maintained free of obstructions. Every automatic sprinkler system, fire detection and alarm system, exit light, fire door and other items of emergency equipment must be continuously maintained in proper Page 3

Policy No:EHS-523

Means of Egress

operating condition. Periodic inspections and tests shall be made a necessary to ensure proper maintenance. Refer to S&W Energy’s Fire Protection and Prevention procedure for details on inspection of fire detection and protection equipment. Mirrors shall not be placed on exit doors or adjacent to any exit in such a manner as to confuse the direction of the exit. Where accumulations of snow or ice are likely, exterior exits shall be covered with a roof or area continuously cleared to ensure free of any obstructions. An Emergency Action Plan must be developed and maintained at the Facility or on-site and available for employee review. Refer to S&W Energy’s Emergency Response procedure for details on the elements of this Plan and the information provided. A Fire Prevention Plan must be developed and maintained at the Facility or on-site and available for employee review. Refer to S&W Energy’s Fire Protection and Prevention procedure for details on the elements of this Plan and the information provided.

4

Housekeeping

General cleanliness and common sense around the workplace can prevent most accidents as well as keep all areas clear for the appropriate means of egress. Some general housekeeping guidelines are listed below: •

• • •

5

Keep air hoses, welding leads, and extension cords out of doorways and off the floor to prevent tripping. Each employee (and visitor and contractor) is responsible for keeping his/her immediate work area free of trash and tools not in use. Clean up all spilled liquids immediately to prevent the possibility of someone slipping and falling. Stack materials and supplies in a safe manner and keep them out of walkways. Never pile trash or other materials, especially storage rooms, in areas where they would block exits or fire doors.

Training

All S&W Energy Facility or Site employees (including Field personnel) shall be trained on the requirements and guidelines of this procedure. Training can be incorporated into Facility or Site Emergency Action Plan and/or Fire Prevention Plan training, including the drills associated with each of those training requirements. Refresher training ON THIS PROCEDURE ONLY is required every 3 years or more frequently if changes to the Facility or Site occur that alters means of egress. Refer to S&W Energy’s Emergency Response and Fire Protection and Prevention procedures for the requirements on content and frequency of training, which should include Means of Egress.

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Policy No:EHS-523

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Means of Egress

Auditing / Inspections

The Means of Egress Procedure shall be reviewed at least every 3 years or more frequently if Facility or Site changes dictate. This procedure will be updated as necessary.

7 References 29 CFR 1910.22

Walking & Working Surfaces – General Requirements

29 CFR 1910.35 – 1910.37

Means of Egress (Subpart E)

29 CFR 1910.38

Emergency and Fire Prevention Plans

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Environmental Health and Safety Manual Policy No. EHS-524

Policy Title: Driver Safety

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2 3 4 5 6 7 8 9

Purpose and Scope.................................................................................................. 2 Definitions ................................................................................................................ 2 General Procedure................................................................................................... 2 Disciplinary Action Procedures................................................................................. 4 Accident Procedures ................................................................................................ 4 Vehicle Inspection .................................................................................................... 4 Training .................................................................................................................... 5 Auditing / Inspections ............................................................................................... 5 References............................................................................................................... 5

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Policy No:EHS-524

Driver Safety

1 Purpose and Scope This procedure provides the requirements and guidelines for motor vehicle safety. The requirements and guidelines are provided and enforced to ensure that Facility or Site vehicles will be operated and maintained in a safe manner and that all vehicles and drivers comply with all government regulations (Federal, State, and Local). It also provides steps to be taken in the event of an accident. This procedure applies to all S&W Energy employees who operate a vehicle (either leased or owned) for the purpose of their job or work tasks. This includes office personnel or sales people renting an automobile for business.

2 • • • •

Definitions Accident – For the purpose of this procedure, any event involving a Facility or Site vehicle which results in any amount of damage, injury, or liability for or against the employee responsible or the Facility (Company). Class A Vehicle – The designation or classification for a lightweight Facility vehicle. This designation may include passenger cars, panel trucks, and pick up trucks with a load capacity rating of ¾ tons (3,300 kilograms) or less. Class C Vehicle – The designation or classification for a heavyweight Facility vehicle. This designation may include stake-body, dump, and multi-axle trucks. Facility Vehicle – All vehicles owned or leased by the Facility or Site and provided to employees to perform their work responsibilities.

Violation of State licensing, Department of Transportation (DOT), or any other requirements for the safe and legal operation of Company vehicles will result in the immediate suspension of employees driving privileges. It is S&W Energy policy to check an employee’s motor vehicle record prior to first authorization of use and periodically thereafter.

3

General Procedure

ANY EMPLOYEE WHO DRIVES A FACILITY VEHICLE MUST HAVE A VALID DRIVER’S LICENSE. All facility vehicles shall be properly licensed and insured per government regulations (i.e., registration, tag, and title). A proof of insurance must be with the vehicle at all times (i.e., keep insurance card in the glove compartment).

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Policy No:EHS-524

Driver Safety

No vehicle shall be driven when the load on the vehicle interferes with proper vision, free movement of the driver, accessibility to emergency equipment, or exit from the vehicle cab. The operator of a facility vehicle and all other occupants within the passenger compartment must wear seatbelts. Transporting of persons in an unauthorized manner in facility vehicles is prohibited. Transporting in an unauthorized manner shall be deemed to include the following actions: • • • •

Transporting more than 3 persons, including the driver, in the front seat. Transporting persons on the fenders, running boards, or tops of vehicles. Transporting persons with appendages extending from the vehicle. Transporting persons in other than a seated position. All loads shall be properly secured and checked prior to transport. Motor vehicles shall not be fueled while the engine is running, unless such action is needed to fuel the vehicle. Smoking and using cellular telephones while the vehicle is being fueled is prohibited. Hazardous materials transportation is limited to small quantities (i.e., below quantities requiring placards or special licenses). Class C vehicles should be equipped with an audible warning device when traveling in reverse (back-up alarm). Vehicles shall be left on facility property when not in use. Vehicles shall be securely locked with keys removed during non-working hours. All vehicles should be parked off the street, where possible, during non-working hours. Traffic laws are to be obeyed at all times. The driver operating the vehicle is responsible for any traffic citations received related to driver control. All traffic citations received while driving a facility vehicle must be reported to the Facility Manager, or designee. Employees shall report any change in their driving status to the Facility Manager, or designee, as soon as the change is known. Records of such driver’s status shall be maintained and kept on file at the Facility. Facility vehicle status and use shall be known at all times. The Attachment Section of this procedure contains a Facility vehicle Sign In / Sign Out Sheet, which is a recommended tool to monitor the status of all facility vehicles.

Drivers should carry their valid driver’s license with them at all times.

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Policy No:EHS-524

4

Driver Safety

Disciplinary Action Procedures If an accident has been determined to be preventable, the Facility Manager, or designee, will initiate disciplinary actions commensurate with the severity of the accident, taking into consideration the driver’s previous accident record and driving experience. The involved driver will be subject to immediate discipline and may be held responsible for all damages and resulting liabilities if it is determined that an accident was preventable and was caused by any one of the following reasons: • • • • • • •

Driving under the influence of drugs and/or alcohol; Driving by an unauthorized driver of a Facility vehicle; Driving a Facility vehicle for unauthorized purposes; or Driving in blatant violation of the law (i.e., driving without a valid driver’s license, excessive speed, driving recklessly, unauthorized parking, etc.). Failure to report an accident or leaving the scene of an accident will result in disciplinary action.

5

Accident Procedures In case of a vehicle accident, the driver must stop and set out emergency reflectors or flares to protect the driver, any passengers, and the vehicle. Specifics of the accident should be discussed with the police and representative of the Facility (or Company), only. The driver should not assume any blame or responsibility, express opinions, or become involved in any arguments as a result of the accident. In addition to reporting the accident to the Facility or Site, localreporting requirements should be followed. Each driver is required to report every accident, property damage, or loss incident involving a Facility vehicle to the Facility Manager, or designee, as soon as possible. Vehicle accidents shall be reported per the Facility EHS Incident Reporting (and Follow-up) procedures.

6

Vehicle Inspection No vehicle shall be placed in service until it has been properly inspected and found to be in good operating condition. All applicable Federal, State, and local government inspection requirements shall be met. All vehicles should be on a scheduled safety and maintenance program.

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Policy No:EHS-524

• •



Driver Safety

Vehicles should be visually inspected on a daily basis, or prior to each use, checking mirrors, windows, lights, horn, tires, and brakes. Other than daily visual inspections, vehicles in use should be checked in more detail on a regular basis, at least quarterly, to assure that it is in safe operating condition and free from apparent damage that could cause failure when in use. A mechanic or a Facility employee who is capable and qualified to inspect the motor vehicle should conduct this more detailed inspection. The Attachment Section of this procedure contains a checklist to be used by the driver to ensure safety of Class A vehicles. The Facility or Site should develop a similar checklist for Class C vehicles, if applicable. Completed checklists and records of tests and safety inspections shall be maintained at the Facility or Site and be made available upon request by the designated authority. A vehicle not meeting safe operating conditions shall be immediately removed from service. Its use shall be prohibited until unsafe conditions have been corrected. The vehicle shall be re-inspected before being returned to service.

7

Training

All S&W Energy Facility or Site employees (including Field personnel) who are or may be required to drive a Facility vehicle shall be trained on the requirements and guidelines of this procedure prior to the use of the vehicle. A valid driver’s license is ALWAYS required. Refresher training is required every 3 years. Defensive driver training courses may be required for any employee at the discretion of the Facility Manager, or designee. Drivers may be required to attend periodic training classes, as required by local jurisdiction.

8

Auditing / Inspections

Vehicle should be inspected according to the Vehicle Inspection Section of this procedure. The Driver Safety Procedure shall be reviewed every 3 years. Documented vehicle inspection reports, vehicle repair records, and employee driving records may be reviewed as part of this inspection or audit. This procedure will be updated as necessary.

9

References

U.S. Federal Motor Carrier Safety Regulations

Page 5

Environmental Health and Safety Manual Policy No. EHS-525

Policy Title: Housekeeping

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2

Purpose and Scope.................................................................................................. 2 General Requirements ............................................................................................. 2

Page 1

Policy No:EHS-525

1

Housekeeping

Purpose and Scope

This policy provides guidelines for all S&W Energy facilities and site regarding housekeeping and general worksite cleanliness. Housekeeping is maintaining the job site in a neat and orderly manner with the proper removal of trash. A dirty, cluttered job site is hazardous.

2

General Requirements

The following will be adhered to: • • • • • • • • • • •

Scrap materials shall be disposed of as each job is completed by each craftsperson. The job is not complete until the trash and scrap have been removed. The project will be kept in an orderly manner at all times. Trash receptacles shall be provided at practical and strategic locations. Trash receptacles shall be dumped at regular intervals and shall not be allowed to overflow. Oily rags, etc. shall be kept separate and disposed of separately in metal fireresistant containers with tops. Periodically, a general cleanup will be affected with all Contractors and Subcontractors required to share in the operation. All scrap lumber, forms, and crates shall have protruding nails removed upon dismantling. Glass drinking bottles shall not be permitted on S&W Energy projects. Lunch and food waste shall be disposed of immediately in trash barrels as generated. Barrels shall have tightly closing lids. All office trailers shall be kept in good, clean order. Scaffolds shall be cleaned on a regular basis, and debris removed as soon as possible. Materials shall not be thrown down from scaffolding except in controlled situations and only at the direction of the Safety Supervisor when appropriate precautionary methods have been implemented.

A. MATERIAL STORAGE • All material must be properly stacked and secured to prevent sliding, falling, or collapse. Aisles, stairs, and passageways must be kept clear to provide for the safe movement of employees and equipment and to provide access in emergencies. • The storage of materials must not block any exit from a building or free access on the form system. • Material stored inside buildings or structures under construction must not be placed within 6 feet of any hoist-way or other inside floor opening, or within 10 feet of any exterior wall which does not extend above the top of the material stored. • Pipe, conduit, and bar stock should be stored in racks or stacked and blocked to prevent movement. Page 2

Policy No:EHS-525

• •

Housekeeping

The quantity of materials stored on scaffolds, platforms, or walkways must not exceed that required for one days operation, nor exceed the capacity of the scaffold. Non-compatible materials shall be segregated in storage. Lumber:

• • • •

Protruding nails must be pulled when stripping forms or uncrating materials. Lumber shall be stacked on level and solidly supported sills. Lumber shall be so stacked as to be stable and self-supporting. Fire protection shall be provided in accordance with S&W Energy’s Fire Protection and prevention policy.

B. OUTSIDE STORAGE AREAS • Outside storage areas shall be kept clean, free of debris, and graded so that water will run off. • Grass and weeds shall be controlled by cutting or approved weed killers. • Access roads and lanes shall be adequate to allow free movement of material handling equipment and shall be kept level and free of potholes. • Dust control should be utilized to minimize personnel to excessive exposures. C. MATERIAL DISPOSAL • S&W Energy and subcontractors are responsible for collecting and disposing of their own trash on the project unless covered under conditions of the contract. • All waste and surplus materials shall be collected and disposed of as soon as each individual task or job is complete. • Disposing of waste materials or debris by burning is prohibited, except when specifically authorized by the Project Safety Department; then, only in compliance with federal, state, and local fire regulations. Usable Materials: • •

All extra parts, bolts, etc., shall be returned to their appropriate storage facilities. All employees shall return usable scrap to an organized area out of the general confines of the work site. This area shall be kept in good order.

D. SPILLS • Liquid spills shall be cleaned up as soon as they occur by S&W Energy or subcontractors. • If cleanup cannot be affected immediately, the spill area shall be barricaded with an acceptable physical barrier or tape until cleanup is effected. • Any time a non-biodegradable material is spilled or discharged into sewer or run-off ditch systems, S&W Energy or the subcontractor responsible shall immediately notify the Construction Manager and Safety Supervisor. It is the responsibility of site management to make timely reports to appropriate agencies requiring notification. Page 3

Policy No:EHS-525



Housekeeping

S&W Energy or the subcontractor responsible for the non-biodegradable spill shall assist project personnel to affect a cleanup that conforms to the spill prevention, control, and countermeasure plan for the project.

E. WASTE RECEPTACLES • Waste containers should not have been previously used for toxic or dangerous materials. • Metal drums or cans shall be stationed throughout the project in close proximity for all contractors and crafts to dispose of project-generated trash. Drums or cans must be: • Dumped on a regularly scheduled basis so drums will not become overfilled. • Shall be marked with a stenciled sign "TRASH." • Paper or cardboard drums and boxes will not be used for trash collection. • Large waste receptacles, such as dumpsters, are required to have a platform with steps and handrails in place at all times for employee access. • All solvent waste, oily rags, and flammable liquids shall be kept in fire-resistant covered containers until removed from the project.

Page 4

Environmental Health and Safety Manual Policy No. EHS-603

Policy Title: Waste Management

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2 3 4 5 6 7 8 9 10 11 12 13

Purpose and Scope.................................................................................................. 2 Definitions ................................................................................................................ 2 Identify and Classify Wastes .................................................................................... 4 Determination of Generator Status........................................................................... 6 Management of Hazardous Waste........................................................................... 8 Land Disposal Restrictions (LDR) .......................................................................... 12 Transportation Requirements (Disposal, Labeling, and Manifesting) ..................... 15 Other Reporting and Recordkeeping Requirements .............................................. 18 Waste Minimization ................................................................................................ 20 Training .............................................................................................................. 21 Auditing / Inspections ......................................................................................... 22 References ......................................................................................................... 22 Forms ................................................................................................................. 22

Page 1

Policy No:EHS-603

Waste Management

1 Purpose and Scope This procedure provides the requirements and guidelines for managing waste, in particular hazardous waste, at a S&W Energy Facility or job-site. The Waste Management procedure includes guidance on identifying and classifying wastes generated on-site, determining generator status, managing the wastes (i.e., labeling, storage, accumulation, ID certification), transportation requirements, land disposal requirements, if applicable, and all recordkeeping and reporting. Waste Management applies to all employees at each Facility or job-site in some capacity. Managers and Supervisors must be aware of manifesting and managing requirements while other employees need to be aware of accumulation, labeling, storage, and handling requirements. Reference the Training section of this procedure for information on employee training requirements.

2

Definitions • • • • • • • • • •

Acutely Hazardous Waste – All wastes designated with an “H” Hazard Code, which includes all “P” listed wastes (Reference the Attachment Section for further descriptions). CERCLA – Comprehensive Emergency Response, Compensation, and Liability Act. CESQG – Conditionally-Exempt Small Quantity Generator. Characteristic – For purposes of Hazardous Waste definition and this procedure, exhibiting ignitability, corrosivity, reactivity, or toxicity properties. Container – Any portable device, in which a material is stored, transported in, treated, disposed of, or otherwise handled. Containment Building – A hazardous waste management unit that is used to store or treat hazardous waste. EPCRA (or SARA Title III) – Emergency Planning and Community Right-toKnow Act (or Superfund Amendments and Reauthorization Act). Episodic Generation – Hazardous Waste generators who periodically exceed or fall below normal generation limits from month to month. Generator – According to RCRA, any person (or Site, business entity) who produces hazardous waste or who causes a hazardous waste to become subject to a regulation. Hazardous Waste – A solid waste, or combination of solid wastes, which because of its quantity, concentration, or physical, chemical, or infectious characteristics, may cause or significantly contribute to an increase in mortality rate or irreversible illnesses or pose a substantial hazard (present or potential) to human health or the environment when improperly treated, stored, transported, disposed of or otherwise managed. A waste is hazardous if it is not listed as an exemption, according to RCRA, and is a listed waste and characteristic. A hazardous waste must be a solid waste, as defined.

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Policy No:EHS-603

• •



• • •





• • •

• • •

Waste Management

Hazardous Waste Management – The systematic control of the collection, source separation, storage, transportation, processing, treatment, recovery, and / or disposal of hazardous waste. Land Disposal – Placement of a waste in landfills, underground injection wells, waste piles, land treatment units, surface impoundments, salt domes, underground mines and caves, concrete vaults, bunkers, or any other placement on or in the land. Land Disposal Restrictions (LDR) – A program implemented by EPA and RCRA as part of the Hazardous and Solid Waste Amendments (HSWA) that is focused on minimizing concerns regarding the short term and long term effects of hazardous waste disposal and to substantially diminish the toxicity of hazardous wastes prior to disposal. LQG – Large Quantity Generator Non-Acutely Hazardous Waste – Hazardous waste not designated as Acutely hazardous. Point of Generation (POG) – At or before the location where a solid waste produced by a system, process or waste management unit is determined to be a hazardous waste, but before the waste is either combined with other hazardous wastes or materials. Prohibited Wastes – Restricted hazardous wastes that are currently subject to LDR treatment standards and the prohibitions on dilution and storage. Since treatment standards have been established for virtually all hazardous wastes, most hazardous wastes are also prohibited wastes. Resource Conservation and Recovery Act (RCRA) – An act developed, established, and passed into law, in 1976, by the Environmental Protection Agency (EPA, the Federal government) that basically promotes the protection of health and the environment and to conserve valuable raw materials and energy resources. One of the main focuses of this complex regulation is the management of hazardous wastes, creating the “cradle-to-grave” management system and establishing programs to protect the environment. Restricted Waste – Hazardous wastes for which LDR treatment standards have been set and are the broadest category of wastes subject to the LDR requirements. Satellite Accumulation Area – Hazardous waste storage at or near the point of generation prior to removal to a centralized storage area. Solid Waste – For purposes of this procedure, a solid waste is any garbage, refuse, sludge, or any other discarded material including solid, semi-solid, liquid, or contained gaseous materials. Hazardous wastes are a subset of solid wastes. Neither is necessarily physically “solid”. SQG – Small Quantity Generator. Tank – According to RCRA, a stationary device designed to hold hazardous waste that is constructed primarily of non-earthen materials which provide structural support. Treatment – Any method, technique or process, including neutralization, designed to change the physical, chemical, or biological character or composition Page 3

Policy No:EHS-603



Waste Management

of any hazardous waste so as to recover energy or material resources from the waste, or so as to render such waste as non-hazardous, or less hazardous; safer to transport, store, or dispose of; or amenable for recovery, amenable for storage, or reduced in volume. Examples of treatment include: Incineration, distillation, evaporation, crushing lamps, open detonation, compacting wastes, chemical precipitation, dilution, filtration, neutralization, combustion, or blending fuel. Waste Minimization – A program implemented with the intended result of reducing the amount of waste generated and disposed of, by using techniques such as source reduction and environmentally sound recycling. This may include equipment or technology modifications, process modifications, reformulation of products, substitution of raw materials, or improvements of housekeeping, maintenance, or inventory control. Treatment of wastes for destruction or disposal is NOT waste minimization.

The steps involved in management of wastes include the following: 1. 2. 3. 4. 5. 6. 7.

Identify and classify waste generation (determine if hazardous) Determine generator status Management of the wastes (storage, handling, accumulation, permitting) Identification of Land Disposal Restrictions (LDRs), if applicable Identify transportation requirements (labeling, manifesting and disposal) Establish recordkeeping and reporting requirements Establish appropriate training for all levels of employees, including management

3

Identify and Classify Wastes

Each Facility or Site shall identify all waste streams and their points of generation (POG) at their Facility or Site. Each waste stream shall be analyzed at the POG, prior to being treated or commingled with any other waste, to determine if the waste generated is hazardous. Determining if a site generates hazardous waste is a three-step process (keep in mind that the waste must be a solid waste as defined in Section 2): • •

Check to see if the waste meets any of the exclusions in Section 261.4 (Reference the Attachment Section of this Procedure); If the waste is not excluded, check to see if it meets any of the hazardous waste listings (Reference the Hazardous Waste Listings in the Attachment Section of this Procedure):

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Policy No:EHS-603



Waste Management

If not listed, determine whether the waste exhibits a characteristic of hazardous waste (one of four: ignitability, corrosivity, reactivity, or toxicity). Reference the description of these characteristics in the Attachment Section of this Procedure. NOTE: Exclusions from the definition of solid waste include Domestic Sewage, Clean Water Act Permitted Discharges (industrial wastewater discharges), and Nuclear Materials (Radioactive Wastes). The waste must be classified at the POG. A substance may not be hazardous at the origin of a process but may become hazardous as a product or waste of a process, at the point it is generated. The reverse is also true.

Use either process knowledge or analytical methods to assist in determining if the solid waste is a hazardous waste. Process knowledge involves evaluating the materials used in the process that generates the waste to determine if the waste stream contains hazardous constituents that would render the waste hazardous or if the process is one that presumes to generate a hazardous waste. Process knowledge can also be used to determine a waste or waste stream to be non-hazardous. Analytical knowledge and methods involves sampling and testing the material using any number of analytical methods including, but not limited to, total constituent analysis, TCLP, EP, pH testing, paint filter methods, etc. Reference the regulatory standards for acceptable and published analytical methods. Correctly apply mixture, derived-from and contained-in rules when determining if the solid waste is hazardous waste. Mixture Rule – Any mixture of a listed hazardous waste and a solid waste, no matter what percentage of the waste mixture is composed of the listed hazardous waste; the entire mixture must be managed as the listed hazardous waste and carry the applicable listing waste code(s). Derived-From Rule – Any solid waste derived from the treatment, storage, or disposal of a listed hazardous waste is a hazardous waste. Contained-In Policy – Materials that are not solid waste but contain listed hazardous waste, must be managed as a hazardous waste until the State or EPA determines that the materials no longer contain a hazardous waste. For all hazardous wastes, determine the applicable hazardous waste codes. This is important for manifesting of waste, labeling and storage requirements. The Attachment Section contains information on hazardous waste codes. If the waste is determined to be hazardous, each Facility or Site is classified as a hazardous waste generator, according to RCRA standards, and subject to the standards and requirements for managing hazardous waste in this procedure.

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Policy No:EHS-603

Waste Management

Facilities or Sites that generate hazardous waste must obtain an EPA (or State) identification number. If the waste is determined to be non-hazardous, RCRA disposal requirements do not apply. Wastes shall be disposed of and managed according to the specific Facility or Site rules for the types of wastes generated.

The importance of accurate, complete, and rapid waste categorization cannot be overemphasized. Most RCRA violations can be traced back to improper waste identification.

4

Determination of Generator Status

Once a Facility or Site has determined that they do in fact generate hazardous waste, they must determine their generator status. There are three (3) key factors in determining the classification or status level of a hazardous waste generator. These factors include: • • •

The quantity of waste generated on a monthly basis (the amount generated in a month and NOT the amount disposed of or transported off-site in a month); The type of waste generated; and The amount of waste stored on site at any one time.

There are three (3) generator categories that may apply to a Facility or Site. They are Conditionally Exempt Small Quantity Generators (CESQG), Small Quantity Generators (SQG), and Large Quantity Generators (LQG). Each Facility or Site must determine the amount of hazardous waste they generate on a monthly basis and the amount of hazardous waste stored on-site at any one time (“counting your waste”). • •

When “counting your waste” to determine generator status, do not count any waste that is excluded or exempted from regulation. Reference the exemptions in the Attachment Section of this procedure. Count each waste only once per calendar month (i.e., spent solvent reclaimed and reused).

Each Facility or Site must determine the type of waste generated on-site (non-acute or acute hazardous waste; reference the Definition Section for definitions of these waste types).

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Policy No:EHS-603

Waste Management

A. Conditionally Exempt Small Quantity Generators (CESQG) Facilities or Sites that generate or produce less than 100 kg of non-acute hazardous waste (normal hazardous waste) and less than 1 kg of acute hazardous waste per calendar month shall classify themselves as a CESQG. Facilities or Sites that do not accumulate more than 1,000 kg of non-acute hazardous waste at any time shall classify themselves as a CESQG. CESQ Generators are exempt form most hazardous waste management regulations, including LDR treatment standards. They have no limits on how long they can store their wastes on-site. B. Small Quantity Generators (SQG) Facilities or Sites that generate or produce more than 100 kg but less than 1,000 kg of non-acute hazardous waste (normal hazardous waste) and less than 1 kg of acute hazardous waste per calendar month shall classify themselves as an SQG. Facilities or Sites that do not accumulate more than 6,000 kg of non-acute hazardous waste at any time shall classify themselves as an SQG. SQ Generators may store their waste on-site for 180 days, or for 270 days if the waste is shipped more than 200 miles, without a permit. C. Large Quantity Generators (LQG) Facilities or Sites that generate or produce more than 1,000 kg of non-acute hazardous waste (normal hazardous waste) or more than 1 kg of acute hazardous waste per calendar month shall classify themselves as an LQG. Facilities or Sites do not have a limit as to the amount of waste they may accumulate on-site. LQ Generators may store their wastes on-site for 90 days or less without a permit.

Generators who store waste longer than the time allowed are subject to extensive permitting requirements under RCRA.

If the amount of waste generated in a given calendar month places the generator in a different generator status category, the Facility or Site is responsible for complying with all applicable requirements for that category for all waste generated during that calendar month (Episodic Generation). • •

Notification must be made to the State or EPA (RCRA Department) if the Facility or Site changes generator status, especially for SQG and LQG where EPA ID numbers are required and for inspector’s verification during an audit. Try to maintain generator status and avoid episodic generation. Some states may limit the number of status changes you can make annually. Page 7

Policy No:EHS-603

5

Waste Management

Management of Hazardous Waste

A. General Facility Standards The following requirements apply to SQGs and LQGs that manage waste without a permit (additional requirements may apply to generators who have permits): •

Generators must obtain a site-specific EPA identification number (see the following section); Generators who treat hazardous waste on-site to meet LDR standards must have a Waste Analysis Plan (WAP) that specifies the frequency of testing and those restricted wastes meet appropriate treatment standards under LDRs. (Reference sections that include treatment of hazardous wastes and LDRs) Generators must maintain and operate their facilities in a manner that will prevent fires, explosions, or unplanned releases of hazardous waste; and When there is an imminent or actual emergency situation, the generator must provide and implement emergency procedures, as outlined in the Facility or Site’s Emergency Response or Action Plan.



• •

B. Identification Numbers Except for conditionally exempt small quantity generators of hazardous waste, all sites that generate, treat, store, or dispose of hazardous waste must obtain a hazardous waste activity identification (ID) number. This number is used on all required documentation pertaining to hazardous wastes generated at the site. •

• •

Identification numbers can be obtained by contacting the EPA Regional Office or through the appropriate State agency in charge of implementing RCRA requirements. A form is required to be completed and submitted, providing the necessary information. Numbers are available for emergency situations or one-time shipments of hazardous waste. A hazardous waste ID number is NOT a permit. It does NOT provide authorization for a Facility or Site to receive hazardous wastes from another Facility (unless a specific RCRA permit is obtained).

Generators may not offer hazardous waste for transportation, disposal, or treatment to entities that do NOT have a hazardous waste ID number.

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Policy No:EHS-603

Waste Management

EPA ID numbers for hazardous waste are to be issued in the name of the Customer or Owner of the Facility or Job-Site (similar to all other permitting such as air, water, etc.). Whether operating a Facility as part of an O&M or performing work on a job-site as part of a Field Service job, S&W Energy only manages the hazardous waste. S&W Energy shall NEVER obtain an EPA ID number in their name or sign hazardous waste disposal manifests unless they own the site or contractual arrangements have been made with the Customer or Owner.

C. Accumulation Standards Generators may store their waste on-site WITHOUT having to obtain a permit as long as the short-term accumulation requirements are met. • • • •

For CESQG, hazardous waste may be accumulated on-site without a time limit as long as the amount of waste never equals or exceeds 1,000 kg of non-acute hazardous waste or 1 kg of acutely hazardous waste at any one time. For SQG, hazardous waste may be accumulated no more than 180 days (270 days if the waste must be transported father than 200 miles from the site), as long as the amount accumulated never exceeds 6,000 kg at any one-time. If these periods are exceeded, the Facility will be considered the operator of a hazardous waste storage facility, requiring a permit. For LQG, hazardous waste may be accumulated no more than 90 days. If the LQG exceeds the accumulation requirements without a permit, it is classified as an interim status storage facility and it must, among other requirements, prepare a closure plan with financial assurance and assume potential liability from the release of hazardous constituents and associated costs.

Except where satellite accumulation areas are used, the accumulation periods described above begin at the time of generation and NOT at the time of hazardous waste identification. •

The clock begins for a particular container of hazardous waste when the first drop of hazardous waste enters the container. The container shall be labeled with this date.

D. Satellite Accumulation Areas Satellite accumulation areas must have the following requirements:

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Policy No:EHS-603

• • • • • •

• • • •

Waste Management

Must use containers (not tanks) that are in good condition and compatible with the wastes they contain (recommended UN-approved or DOT-approved containers); Must be marked with the words “Hazardous Waste” or similar words that convey the contents of the container; Must be closed except when it is necessary to add or remove wastes; Must not exceed more than 55 gallons of non-acute hazardous waste or one quart of acute hazardous waste. More than one container may be used in a satellite accumulation area, so long as the total does not exceed 55-gallons; Once the storage limit of 55 gallons is met, the container should be moved to the 90/180-day storage area in that same day, but no more than 3 days, to prevent excess accumulation and potential fines from Inspectors. The container shall be marked with the date the container is full or the date the 55-gallon storage limit is met. This is the time that the 90/180-day storage limit begins. While a container with capacity greater than 55 gallons may be used, the 55-gallon limit still remains; The 90/180-day storage time limit does not apply to satellite accumulation areas UNTIL 55 gallons of non-acute hazardous waste or one quart of acute hazardous wastes are accumulated; Nothing precludes the placement of several satellite accumulation areas in close proximity to one another, however, each must be clearly marked to make the designation between them; There are no recordkeeping requirements for satellite accumulation areas other than proper labeling of the container and the date excess accumulation begins (or date of 55 gallon limit); and There are no air emission requirements for satellite accumulation areas;

E. Hazardous Waste Storage – Containers (i.e., 55-gallon drums) • • • • • •

Containers storing hazardous waste must be in good condition. Incompatible wastes must NOT be stored in the same container and the constituents of the waste must be compatible with the material of which the container is made. Containers must be securely covered except when wastes are added or removed. Containers shall be handled in a manner as to prevent ruptures or leaks. Weekly inspections must be conducted and documented to assure that containers remain in good condition and to assure storage limits (time and amount) are not exceeded. Containers meeting the definition of “empty”, according to RCRA can be managed as non-hazardous waste.

F. Hazardous Waste Storage – Tanks

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Policy No:EHS-603

• •

Waste Management

Tanks storing hazardous waste must be evaluated to assess structural integrity and compatibility with the wastes they will hold. Tank systems (and ancillary equipment such as valves and piping) must have secondary containment and leak detection systems.

G. Hazardous Waste Storage – Containment Buildings • • • • • • •



Only LQ Generators are authorized, by regulation, to store hazardous waste in containment buildings. They can not be used for SQ Generators. Containment buildings must be completely enclosed and have self-supporting walls. Containment buildings must contain a primary barrier designed to withstand the movement of people, waste, and handling equipment. Containment buildings shall be operated in a manner that prevents waste from being tracked in and out of the unit. If wastes with a liquid component are stored in the unit, the containment building must be provided with secondary containment. If wastes are totally comprised of liquid (100% liquid), they cannot be managed in a containment building. Hazardous wastes may be stored in containment buildings for less than 90 days without a permit. Generators must have on file a documented procedure or written description that ensures the waste volume remains in the unit no longer than 90 days. Facilities or Sites must obtain, before operating the containment building (unit), a certification by a qualified registered professional engineer that the containment building meets the design standards as described in regulation. This certification must be kept on file.

H. Air Emission Standards – FOR LQ GENERATORS ONLY •

• •

Large quantity generators who accumulate hazardous waste on-site are subject to RCRA organic air emission standards (under 40 CFR 265, Subparts AA for process vents, Subpart BB for equipment leaks, and Subpart CC for tanks and containers). Compliance with the air emission standards is part of the LQG conditional exemption from the requirement to obtain a permit or interim status for the on-site accumulation of hazardous wastes. Units such as wastewater treatment units, neutralization units, closed-loop recycling units, satellite accumulation units, and totally enclosed treatment units are exempt from RCRA air emission standards.

I. Treatment of Hazardous Waste

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Policy No:EHS-603

Waste Management

Generally, hazardous waste cannot be treated unless the Facility or Site has a RCRA permit. However, certain activities are available to generators without a permit. Exemptions from permitting requirements for hazardous waste treatment units include the following: • • • • •

Wastewater treatment units; Totally enclosed treatment facilities; Elementary neutralization (treatment of corrosive-only) units; Emergency response action treatment units; and/or Addition of absorbent material to waste in containers. Hazardous wastewater may be treated without a RCRA permit so long as the treatment occurs in a tank (see definition of tank) and the discharge runs directly to a publicly owned treatment works (POTW) or is subject to National Pollution Discharge and Elimination Standard (NPDES) requirement. Corrosive-only wastes may be neutralized in tanks without a permit. This exemption can not be used to treat a corrosive waste that is a listed waste or meets other hazardous waste characteristics. Treatment may occur in totally enclosed treatment systems as long as the system is hard-piped to a production process and assured that no hazardous waste constituents will escape into the ambient environment. Sorbent material may be added to waste in a container provided the addition occurs at the time the waste is first placed in the container. Adding sorbent to liquid hazardous waste is considered treatment and must comply with additional requirements under RCRA. If the sorbent is to be discarded, ultimately, in a landfill, the sorbent material must be non-biodegradable. The Facility or Site may treat waste in containers and tanks, or containment buildings during the 90-day accumulation period.

J. CESQG Special Hazardous Waste Management Requirements Because conditionally exempt small quantity generators manage hazardous wastes under reduced regulation (i.e., are exempt from many RCRA obligations that apply to small or large quantity generators), they must manage their wastes according to specific requirements. CESQ Generators that send their waste to municipal solid waste landfills or nonmunicipal solid waste landfills must ensure that such landfills are subject to design and operating standards set forth in the RCRA standards.

6

Land Disposal Restrictions (LDR)

Certain Facilities or Sites may be subject to LDR standards, depending on several factors, primarily focusing on generators who dispose of their wastes off-site. Page 12

Policy No:EHS-603

Waste Management

Hazardous wastes subject to the LDR cannot be land disposed unless first treated to specific levels or by specified technologies. The LDR program has three major components that may affect operations: • • •

Treatment standards, that typically mandate pretreatment prior to disposal; Prohibitions that ensure wastes are not merely diluted or stored to avoid applicable standards; and Paperwork requirements to ensure the program is enforceable, all handlers of the waste are aware of their obligations, and that handlers can demonstrate to the Facility or Site compliance in writing. Each Facility or Site must determine their applicability to the LDR Program. Hazardous waste must be disposed of off-site (destined for land disposal at any point in its life cycle). However, land-based units such as tanks, containers, drip pads, containment buildings, and “pump and treat” operations that manage hazardous waste do NOT constitute land disposal. If the waste is subject to an exemption or exclusion, the LDR program is not applicable. These exemptions and exclusions include: • • • •

Wastes exempt in 40 CFR Part 261 (see Attachment Section outlining the waste exemptions); Wastes generated by CESQ Generators. Facility or Site must be SQG or LQG to be subject to LDR; “Newly Listed” or identified wastes for which there is no standard in effect; or Wastes that are granted a variance. All exemptions must be documented to prove the LDR program is not applicable. The waste generated must be hazardous at the POG (reference Section on identifying and classifying wastes). All hazardous waste codes of applicable hazardous waste must be identified. The hazardous waste must be either restricted or prohibited wastes to be applicable to LDR standards (see Definition Section for definitions of restricted and prohibited wastes). If the waste (or any treatment residue from the waste) is placed in a landfill, surface impoundment, waste pile, salt dome, or other land-based unit (other than those exempt listed above), the LDR program applies. Temporary storage of hazardous waste on land triggers LDR compliance.

If the Facility or Site meets the criteria listed in Section 6.1, the LDR program is applicable to that Facility. Generators should NOT rely on their waste vendors to comply with these obligations.

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Policy No:EHS-603

Waste Management

After making the determination as to whether or not the Facility or Site is subject to the LDR program, and if the answer is YES, the following obligations must be met: • • • • • •

Determine whether the hazardous waste is a restricted or prohibited waste; Determine the concentration of regulated hazard constituents present in the hazardous waste; Determine whether the waste is wastewater or non-wastewater category of waste; Determine which treatment standards are applicable; Assess whether treatment standards have been met; and Ensure the dilution and storage prohibition are not violated. Hazardous wastes subject to LDRs cannot be land disposed unless first treated to applicable levels and are subject to dilution and storage prohibitions as well. Generators disposing of hazardous wastes off-site must either certify their wastes meet the LDR standards or notify the treatment, storage, and disposal (TSD) facility that the wastes do not meet the treatment standards. In addition to restricted and prohibited wastes, the EPA has established treatment standards for listed and characteristic hazardous wastes. Use 40 CFR Part 268 and the associated tables to identify the LDR treatment standards for the categorized waste for LDR requirements. Use all of the classifications and waste types identified to find the appropriate standard. Use established treatment methods to reach the treatment standards for disposal.

If you do not know all the applicable waste codes, the concentrations of hazardous constituents in the waste, and whether the waste is a wastewater or non-wastewater, compliance with LDRs is difficult to attain. The importance of accurate and complete waste identification to compliance cannot be overemphasized.

The final step in compliance with LDR requirements is to ensure all the proper paperwork is completed and reports filed and sent accordingly. The paperwork required for the LDR program consists of all documentation of hazardous waste categorization, notification, certification and recordkeeping. The initial shipment of waste off-site for storage, recycling, treatment, or disposal must be accompanied by a one-time LDR notification that waste is or is not subject to treatment standards.

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Policy No:EHS-603

Waste Management

If the initial shipment DOES NOT meet the applicable treatment standards, a onetime notification must be prepared and sent with shipment that includes: • • • • •

EPA Hazardous Waste and Manifest Numbers; Treatability group and subcategory, if any; A statement that the waste is subject to LDRs Waste analysis data, if available; If the waste is exempt from LDR, a statement that the waste does not have to meet the treatment standards before land disposal is required. This should also be noted in the Facility or Site’s operating record at the POG or after it. If the waste DOES meet the treatment standards, both notification AND certification are required. The notification portion includes all the information as indicated above. The certification portion includes the following:

• •

Statement certifying that treatment standards have been met; and A statement certifying that waste has been improperly diluted to meet the standards. Notification and certification are required for initial shipments only. A new notification and certification is required when the waste destination or treatment status changes. Notification and certification records need to be maintained for at least 3 years. Generators treating prohibited wastes on-site to meet treatment standards must prepare a Waste Analysis Plan (WAP). The WAP must be:

• • •

Based on detailed physical and chemical analysis of a representative sample; Describe how the generator will meet the standards; and Contain all information to comply with 40 CFR Part 268 when treating wastes including description of Facility processes, identification of types and quantities of waste and description of sampling procedures.

IMPORTANT NOTE: An LDR determination must be made for all hazardous waste generated at the Facility or Site.

7 A.

Transportation Requirements (Disposal, Labeling, and Manifesting) Labeling, Packaging, Marking, and Placarding Page 15

Policy No:EHS-603

Waste Management

Any person or employee who prepares hazardous waste for transportation must be trained in accordance with Department of Transportation (DOT) requirements. DOT training is different from training required by RCRA. RCRA training does not satisfy the DOT training requirements. The training Section of this procedure provides mot information. All hazardous waste must be properly packaged, labeled, marked and placarded before they leave the site. • • •

Packaging must comply with the DOT packaging requirements of 49 CFR Parts 173, 178, and 179. Each package must be labeled as required by DOT, 49 CFR Part 172. In addition to marking the package in compliance with Part 172, the generator must place the following inscription on any package of 110 gallons or less: HAZARDOUS WASTE – Federal Law prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the United States Environmental Protection Agency (US EPA). Generator’s Name & Address: Manifest Document Number:



The generator must offer the proper placards to the transporter, according to 49 CFR Part 172, Subpart F. Each Facility or Site that offers hazardous materials for transportation, or which transports hazardous materials must have the following emergency response information immediately available:

• • • •

The description of the hazardous material; The immediate hazards to health and the risks of fire and explosion; The immediate precautions to be taken in the event of an incident, such as methods for handling fires or spills; and Preliminary first aid measures. NOTE: A Material Safety Data Sheet (MSDS) can satisfy the information request as long as it provides all of the information required. Any Facility or Site offering hazardous materials for transportation must provide a 24-hour emergency response telephone number for use during an emergency.

B. Manifests A manifest must accompany each shipment of hazardous waste by a Facility or Site that generates over 100 kg / month of hazardous waste. •

The Facility accepting the hazardous waste must be designated on the manifest. An alternate Facility may also be designated. If the waste cannot be delivered to Page 16

Policy No:EHS-603



the principal Facility listed on the manifest, the generator must designate another Facility, or the waste must be returned to the generator. Each manifest must be filled out accurately and completely. Information required on manifest include: • • • • • •

• •



Waste Management

Manifest number; DOT proper shipping description of the waste; Generator’s name, address, and EPA identification number; Name, address, and EPA identification number of the designated facility; Name and EPA Identification number of the transporter; and Appropriate signatures (generator, transporter, and designated facility).

Disputes with transporters or disposal / treatment Facilities regarding the contents of the manifest should be carefully documented and kept on file. While it is permissible for the generators to allow a vendor to fill out the manifest, the generator must sign the manifest and is responsible for the accuracy. Therefore, it is not recommended to rely on the vendors to complete the manifest. The proper manifests shall be chosen. • • •

The first choice is the State manifest, in which the designated Facility is located. If no manifest is required in the State of the designated Facility, the second choice is the manifest of the State in which the State is generated. If neither of the first two states’ manifests is required, then EPA’s hazardous waste manifest (Federal form) may be used.



The generator must retain a copy of each manifest, signed by the transporter at the time the waste is removed form the Facility or Site. All transporters must be provided a copy for their records. C. Exception Reporting The Facility designated to receive the wastes must receive two copies of the manifest: one for its own records and one to return to the generator. The generator is responsible for ascertaining that the waste has been received by the proper Facility and report cases in which a return manifest is not received. • •

If a LQG does not receive a signed copy of a manifest from the designated endpoint Facility within 35 days of transport, the generator must determine the status of the hazardous waste. If the manifest copy is not returned within 45 days of initial waste shipment, an LQG must forward a report to the appropriate environmental agency. The report must include a legible copy of the manifest and statement of the efforts undertaken to locate the waste and the results of those efforts.

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Policy No:EHS-603



Waste Management

SQ generators must submit a legible copy of the manifest (along with some indication that the required copy of the manifest has been received), if the generator has not received a signed copy of the manifest within 60 days of the initial shipment. No formal report is required. The manifest must also be accompanied by a waste minimization certification, certifying that the generator has a waste minimization program in place. This certification is printed directly on most manifests (Reference section on Waste Minimization). Any necessary LDR paperwork must accompany the manifest. CESQ Generators are NOT required to use a manifest.

Hazardous Waste must be transported by vendors with approved EPA or State hazardous waste identification numbers and only to permitted treatment, storage, or disposal Facilities Each Facility or Site shall assure that the transporter they use is qualified and has the appropriate ID and that the disposal Facility to which the waste is going is approved and properly permitted to maintain compliance.

8

Other Reporting and Recordkeeping Requirements

A. Biennial Report A Biennial report must be filed with either the authorized State agency (or EPA) by March 1 of each even-numbered year for LQGs. For generators who treat, store, or dispose of hazardous waste off-site, the biennial report must identify: • • • • •

General Facility information, including EPA ID number and generator’s name and address; Transporter information, including name and address of all transporters used; Designated treatment, storage, and disposal facility information; Waste description and quantity information; and Waste minimization efforts information.

For generators who treat, store, or dispose of hazardous waste on-site, the biennial report must identify: •

Descriptions of the types and quantities of hazardous waste the Facility handled during the year; and

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Policy No:EHS-603



Waste Management

Descriptions of all methods used to treat store, and dispose of wastes.

SQGs and CESQGs do not have to file a biennial report. B. Release Reporting (Contingency Plans and Incident Reporting) All RCRA hazardous wastes are CERCLA hazardous substances and, therefore, subject to CERCLA or EPCRA immediate notification requirements. All CERCLA hazardous substances are assigned reportable quantities that must be reported if exceeded. Reference CERCLA or EPCRA standards for details on the quantities and reporting. Whenever a reportable quantity or more of hazardous substance (or hazardous waste) is released into the environment, immediate notice to the National Response Center (NRC) must be provided within 24 hours of the release. Facilities that store wastes on-site pursuant to the RCRA 90-day exemption (LQGs) from a permit requirement, must have a contingency plan in place and comply with associated reporting requirements in the event of a release (incident reporting). Contingency Plans describe the response actions to be taken, including reporting requirements, whenever an imminent or actual emergency occurs. They must include the following: • • •

A description of planned response and emergencies; A description of arrangements for response support; A description of emergency coordinators, including names, contact information and emergency equipment available; and evacuation procedures.

NOTE: Existing Spill Prevention Control and Countermeasure (SPCC) Plans and/or Emergency Response Plans may be amended to meet contingency plan requirements. In the event of a fire, explosion or a release concerning a hazardous waste that could threaten human health or the environment, immediately notify the applicable regional agency identified in the contingency plan or the National Response Center. Written notification to the EPA Regional office is required within 15 days of any incident that requires implementation of the contingency plan. This notification shall include: • • • •

General facility information; Incident description; Injury and hazard assessment; and Name and estimated quantity of materials involved.

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Policy No:EHS-603

Waste Management

Contingency Plans shall be amended whenever regulations change that affect the content, the Plan fails, Facilities change, emergency coordinators or information changes, or emergency equipment changes. SQGs have similar requirements when it comes to release reporting and contingency plans. Reference the regulations as these requirements vary State to State. CESQG are not required to comply with contingency plan requirements. The incident reporting requirements, under contingency plan implementation, do not have quantitative thresholds and thus apply where neither CERCLA nor EPCRA release reporting requirements apply. C. Recordkeeping All records under RCRA must be retained for a certain period of time: CATEGORY

MINIMUM TIME RETENTION REQUIRED Signed manifests and receipt copies 3 years Waste analyses 3 years LDR records 3 years Biennial reports 3 years Manifests 3 years Exception reports Active life All land disposal documentation 3 years Training records for current employees Until site closure or 3 years following employment at Site Contingency plan Active life EPA ID number Active life Records of tank design, installation, releases, etc. Active life

9

Waste Minimization

Waste Minimization requirements apply to hazardous waste management generators, specifically LQGs that generate hazardous waste on-site. SQGs must make a “good faith effort” to minimize waste and select best affordable waste management options. Reference the Definition Section for a definition of Waste Minimization. Each LQG must establish a waste minimization program. Each manifest signed must certify that a program exists and is in place at applicable Sites or Facilities. The program shall address issues to reduce the volume or quantity of waste generated and reduce the toxicity of the waste to the extent economically practicable. Biennial reports must also contain information regarding waste minimization efforts, providing comparisons from previous years as indication or proof of reduction. Waste minimization program elements include:

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Policy No:EHS-603

• • • • • •

Waste Management

Management support statement (signed by top-level management); Characterization of waste generation and management costs; Periodic minimization assessments; Cost allocation system; Technology transfer; and Program implementation and review The program shall be written and documented, made available for inspection, and include the signature of corporate responsible officer for RCRA compliance. EPA has published guidance on waste minimization. Reference their literature for assistance.

10 Training All S&W Energy Facility or Site employees (including Field personnel) who will be involved with Hazardous Waste operations or working in areas where Hazardous Waste operations may be performed shall be trained on the requirements and guidelines of this procedure. The training program that teaches Facility or Site personnel their obligations and teaches awareness of hazardous waste operations according to RCRA must: • • • • •

Train employees who are responsible for managing hazardous waste in the mechanics of their job function; Train employees as to why they must perform certain tasks in a prescribed manner; Be directed by a person trained in hazardous waste management procedures; Be designed to ensure that the Facility personnel are able to respond to emergency situations; and Be given to Facility personnel and successfully completed within 6 months of hire or assignment to the Facility or Job-Site; Hazardous Waste awareness training is required annually. For SQGs, all employees must be trained so that they thoroughly understand and are familiar with proper waste handling and emergency procedures relevant to their responsibilities. For those Facilities or Sites who manage hazardous waste, training shall include the following:

• • • • •

Chemical characteristics of the waste that they are assigned to manage What to do in case of a spill; Types of personal protective equipment (PPE) or clothing to be worn; Proper operation of trucks, forklifts, or any other machinery to be used in waste management; and Who to inform in case of emergency. Hazardous Waste Management training is required annually.

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Policy No:EHS-603

Waste Management

Any person or employee (Facility or Site) who prepares waste for transportation must be trained in accordance with DOT training requirements (49 CFR part 172.704). DOT training must include the following: • • •

General awareness / familiarization training designed to enable employees to recognize and identify hazardous materials; Function-specific training that is applicable to the transportation related functions the employee performs; Safety training that focuses on required emergency response information, measures to reduce employee exposure, and procedures for avoiding accidents. DOT training must be given within 90 days after employment. DOT certification is also required IF any S&W Energy employee is authorized to sign hazardous waste manifests. No employee may sign a hazardous waste manifest unless he has the proper certification and training.

11 Auditing / Inspections The Waste Management Procedure shall be reviewed annually. Documented records and plans may be reviewed as part of this annual audit. This procedure will be updated as necessary.

12 References 40 CFR 260

RCRA Basic Definitions

40 CFR 261

Hazardous Waste Listings and Characteristics, Recycling Exemptions, & Solid and Hazardous Waste Exemptions

40 CFR 262

RCRA Generator Standards

40 CFR 263

RCRA Transporter Standards

40 CFR 264

Standards for Permitted Treatment, Storage, and Disposal Facilities

40 CFR 266

Management Standards for Specific Types of Recycled Hazardous Waste

40 CFR 268

Land Disposal Restrictions (LDR)

40 CFR 273

Universal Waste Standards

49 CFR 171

DOT: General Information, Regulations, and Definitions

49 CFR 172

DOT: Hazardous Materials Emergency Response Information, Communication, and Training

49 CFR 173

DOT: General Requirements for Shipments and Packaging

49 CFR 178

DOT: Specifications for Packaging

13 Forms See Appendix S

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Policy No:EHS-603

Waste Management

S.1 - Exemptions from Hazardous Waste – Categories S.2 - Hazardous Waste Listings (and Some Hazard Codes)

Page 23

Environmental Health and Safety Manual Policy No. EHS-604

Policy Title: Toxic Substance Control Act

Date: 3/30/2006

Revision: 1

Approval: Richard Wolf

Table of Contents 1 2 3 4 5 6

Purpose and Scope.................................................................................................. 2 Definitions ................................................................................................................ 2 Procedure / Requirements ....................................................................................... 2 Training .................................................................................................................... 4 Auditing / Inspections ............................................................................................... 4 References............................................................................................................... 4

Page 1

Policy No:EHS-604

Toxic Substance Control Act

1 Purpose and Scope This procedure provides the requirements applicable to S&W Energy under the Toxic Substance Control Act (TSCA). Specifically, this procedure provides the requirements and responsibilities of all employees (and employers) to identify, assess, manage, and reduce potential risks posed by exposure to existing chemical substances in the workplace through the process of identifying adverse health affects (when they occur or become known), submitting allegations of such information, and notifying employees and keeping records of these allegations. TSCA has many parts and many requirements but only the section pertaining to records and reports of allegations of chemical substances causing significant adverse reactions to health and/or the environment (section 8(c)) applies to S&W Energy under the current scope of business.

2 • •

Definitions Allegation – A statement made without formal proof or regard for evidence, that a chemical substance or mixture has caused a significant adverse reaction to health or the environment. Known Human Effects – A commonly recognized human health effect of a particular substance or mixture as described either in: • • • • •

• •

3

Scientific articles or publications; or The Company’s product labeling or Material Safety Data Sheet (MSDS); An effect is not a “Known Human Effect” if: It was a manifestation of a toxic effect after a significantly shorter exposure period or lower exposure level than described; or It was a manifestation of a toxic effect by an exposure route different from that described.

Significant Adverse Reactions – Reactions that may indicate a substantial impairment of normal activities, or long-lasting or irreversible damage to health or the environment. Substance – For purposes of this procedure / policy, a chemical substance or mixture, unless otherwise indicated.

Procedure / Requirements

If any person, such as employee of company, individual consumer, a neighbor of the company’s Facility, another company on behalf of its employees, or an organization on behalf of its members, feel that they have been subject to a significant adverse reaction due to a chemical substance or material, or some by-product thereof, shall have the right to notify the company of such a case in the form of an allegation. Significant adverse reactions to human health that must be recorded through the allegation reporting process are, but not limited to:

Page 2

Policy No:EHS-604

• •

Toxic Substance Control Act

Long-lasting or irreversible damage, such as cancer or birth defects; Partial or complete impairment of bodily functions, such as reproductive disorders, neurological disorders or blood disorders; An impairment of normal activities experienced by all or most of the persons exposed at one time; An impairment of normal activities which is experienced each time an individual is exposed.

• •

Significant adverse reactions to the environment (includes environs of the plant or disposal site) that must be recorded through the allegation reporting process are, but not limited to: • • • • • •

Gradual or sudden changes in the composition of animal or plant life in an area; Abnormal number of deaths of organisms; Reduction of the reproductive success or vigor of a species; Reduction in agricultural activity, whether crops or livestock; Alterations in the behavior or distribution of a species; or Long-lasting or irreversible contamination of components of the physical environment, including groundwater, surface water, soil surfaces, etc.

Allegations must be submitted either in writing and signed by the alleger or are submitted orally. In the case of an oral allegation, the company must transcribe the allegation into written form or inform the alleger to submit in writing for recordkeeping purposes and compliance. The allegation must include or implicate the substance said to have caused the significant adverse reaction by one of the following ways: • • • • •

Naming the specific substance; Naming the mixture that contains the substance; Naming an article that contains the specific substance; Naming a company process or operation in which substances are involved; or Identifying an effluent, emission, or other discharge from a site of manufacturing, processing, or distribution of a substance.

Companies are not required to record significant adverse reactions to human health that do not meet the definition of known human effects as defined previously. Companies are not required to record a significant adverse reaction to the environment if the alleged cause of the reaction can be directly attributable to an accidental spill or other accidental discharge, emission exceeding permitted limits, or other incident of environmental contamination that has been reported to the regulatory agency under applicable authority.

Page 3

Policy No:EHS-604

Toxic Substance Control Act

Records of all allegations of significant adverse reactions made as part of this procedure / policy shall be maintained at the company’s headquarters or at any other appropriate location central to the company’s operations. The allegation record shall consist of: • •

• •

The original allegation, as received; An abstract of the allegation and other pertinent information such as name and address of site which received the allegation, the date the allegation was received, the implicated substance, description of the alleger (company employee, individual consumer, company neighbor, etc.), and a description of the alleged health or environmental effect(s); The results of any self-initiated investigation with respect to the allegation; and Copies of any further required records or reports relating to the allegation.

Records of significant adverse reaction allegations shall be retained for 30 years from the date of such actions were first reported. If a company ceases to do business, the successor must receive all of these records. If the company ceases to do business and there is no successor, records shall be submitted to the Federal Regulatory agency. Companies must make records of allegations available for inspection by any designated representative of the regulatory agency. Upon request, the regulating agency may request that the allegations be submitted. Upon this request, the company shall submit the designated records to the proper agency indicated. This shall be done no later than 45 days following the request. Any person or company submitting copies of allegations may assert a business confidentiality claim as part of the submitted information.

4

Training

All S&W Energy employees shall be trained on the requirements and guidelines of this procedure annually.

5

Auditing / Inspections

The TSCA Procedure shall be reviewed every 3 years. This procedure will be updated as necessary.

6

References 40 CFR 717

Records and Reports of Allegations that Chemical Substances Cause Significant Adverse Reactions to Health or the Environment

Page 4

Policy No. EHS-501

Contractor Safety – Appendix A.1

BID SOLICITATION / CONTRACTOR QUALIFICATION FORM – Page 1 Contractor to Complete Sections I - V I Contractor Name:

SIC#: Contact Name: Fax:

Address: Phone:

II. Insurance / Workers Compensation Insurance Agent/Carrier: Address: Insurance Coverage ($ amt.): Workers Compensation Carrier: Address:

Contact Name: Phone:

Contact Name: Phone:

III. Safety Information (Accident Rates)

Year

Rate (I&I or EMR)

Injury & Illness Rate (I&I) or Experience Modification Rate (EMR) for the 1. past 3 years: (I&I Rate = injury + illness cases x (200,000 hrs.) / (total hrs. worked) 2. 3. (Contact Insurance Carrier or Workers Comp Carrier for EMR) Lost Workday Case Rate for the past 3 years: (lost workday cases) x (200,000 hrs.) / (total hrs. worked)

1. 2. 3.

Has there been a work-related death within the past five (5) years? Has the company received a citation from a regulatory agency within the past five (5) years? If yes to either question, explain (attach additional sheets if necessary):

Yes Yes

No No

NOTE: If Contractor employs less than 10 employees FOR ENTIRE COMPANY, OSHA does not require I&I rates recorded. However, Contractor shall provide safety information relating to injury and illness.

IV. Additional Required Information Wastes to be Generated: Estimated Quantities of Wastes Contractor Work to Generate: Subcontractors to be Used?

Oil

Oily Debris

Solvents

Paint

Other(s) _____________________________

Noise >85 dB Chemical Exposure, specify ____________________ Excessive Dust Fugitive Emissions, specify _________________________ Other _____________________ Yes If yes, list names:

V. On behalf of the Contractor, I acknowledge that all information provided on this form is true and that I agree to provide any support information that may be requested from PES as proof of information here provided. The Contractor agrees that: • The Contractor shall ensure, to the extent possible, that all Subcontractors, Suppliers, and Agents of the Contractor, in connection with the Contractor’s work at the PES Facility or Site, shall act in full compliance with local, state and federal laws. • The Contractor has attached all documentation requested for submittal with this quote and agrees to provide all requested documentation upon award of the Contract for the job quoted (reference next page for other possible required information). Title: Contractor Representative

(Print): Contractor (Signature):

Date:

Representative

Page 1

Policy No. EHS-501

Contractor Safety – Appendix A.1

BID SOLICITATION / CONTRACTOR QUALIFICATION FORM – Page 2 Facility to Complete Sections VI - X VI. Scope of Work:

VII. Submittals With quote

Document

Upon Award

Health & Safety Program

With quote

Document

Upon Award

Other:

HAZCOM Program Certificate of Insurance for Worker MSDS (of Chemicals Brought On-Site) EHS Training Certification

VIII. Training Documentation Training Confined Space Entry Lock Out / Tag Out Electrical Safety

Regulation (OSHA) 29 CFR 1910.146 29 CFR 1910.147 29 CFR 1910.269 29 CFR 1910.333

Training

Regulation (OSHA) 29 CFR 1910.134 29 CFR 1910.28 26 CFR 1910.451

Respiratory Protection Scaffolds (erection & use) Other (use additional sheets):

IX. Safety Meetings, Inspections, and Equipment Frequency of Safety Meetings:

Frequency of Safety Inspections:

Safety Equipment to be Supplied by Contractor: Chemical Protection, specify Confined Space Rescue Equipment Confined Space Air Monitor (4 gas)

Hearing Protection, specify

Fall Protection, specify Hard Hats

Safety Shoes (steel toe) Other(s):

X.

Respiratory Protection, specify Safety Glasses (w/ side shields)

Contractor Qualification Review Date Bid Specification ______/______/______

Contractor Qualification: Reason Why Not Contractor Reviewer(s): Title: Title:

Date Quote ______/______/______

Approved First Name: First Name:

Page 2

Not Approved Last Name: Last Name:

Policy No. EHS-501

Contractor Safety – Appendix A.2

Contractor EHS Training Tracking Certification Form YEAR

COMPANY OR CONTRACTOR NAME

CONTRACTOR REPRESENTATIVE NAME Last

First

CONTRACTOR WORKERS FOR COMPANY LISTED ABOVE Last

First

Work to be Performed (LOTO, Confined Space, etc.)

Last

First

Work to be Performed (LOTO, Confined Space, etc.)

CONTRACTOR TRAINING CERTIFICATION: EHS Training Certification is valid for one year. Training shall be verified and certified on an annual basis, adding or deleting names, updating status, as part of annual re-certification of vendor. I verify that all employees listed above as Contractor Workers have been properly trained per regulatory standards for the work that is listed for them to perform. The regulatory training is current and up to date. No Contractor Worker will perform duties for which he/she is not properly trained. CONTRACTOR REPRESENTATIVE (Signature): ____________________________________________

Page 1

Date: ________________________

Policy No. EHS-501

Contractor Safety – Appendix A.3

Contractor Environment, Health & Safety (EHS) Rules Form Each Contractor Worker must read, understand and comply with the following rules.

Contractor Safety Policy S&W is committed to providing a safe and healthy work environment for all employees, both on-site and Contractor Workers, and is committed to avoiding adverse impact to the environment in performance of all site activities.

General 1. The Contractors must sign a Daily Contractor Work Permit at the beginning of the day. 2. Contractor Workers shall not work at any time when their ability is or may be impaired as a result of the use of legal prescription drugs. 3. Contractor Workers must be seated in moving vehicles and seat belts worn while the vehicle is in motion. 4. Fighting, horseplay, gambling, possession of firearms or other weapons, possession or use of alcohol or illegal or unauthorized drugs is prohibited. 5. Except in “Designated Smoking Areas,” smoking is not permitted on Facility property. 6. Eating and Drinking is only permitted in designated areas. 7. All tools and equipment shall be inspected prior to use. Unsafe tools and equipment shall not be used. 8. Contractor Workers will perform work in such a manner as to assure at all times maximum safety to self, fellow workers and the public and in accordance with all Federal, State, and Local requirements. 9. Contractor Workers who do not either feel qualified for or physically able to perform will not attempt to work. 10. Contractor Workers will perform work according to proper EHS practices and procedures as posted, instructed, and prescribed. 11. Contractor Workers will obtain specific instructions and/or clarifications from their Supervisor before proceeding with work in situations where an EHS requirement or procedure is not completely understood. 12. Contractor Workers will observe and adhere to all warning signs, signals, and notices. 13. Contractor Workers shall not be permitted to wear loose or flapping clothing or have rags or other objects extending from pockets or belts when in the immediate proximity of machinery, motors, engines, or rotating equipment. 14. Contractors may not use Facility tools, moving equipment, or stock room supplies without prior approval from the Facility or Site (S&W) Representative. 15. Contractors shall never operate any machine or rotating equipment unless all guards and safety devices are in place and in proper operating condition. 16. Contractors shall remain in the general area of their assigned work. Do not enter other areas unless authorized by the Facility or Site (S&W) Representative.

Immediately report every work-related Injury, Illness or Near Miss sustained at the Facility or Site to your Supervisor.

Conduct The following list is not a complete list but includes acts and behavior which are prohibited and for which a Contractor Worker may be removed from the Facility: 1. Use of obscene or abusive language; racial, gender, or ethnic slurs. 2. Failure to follow specific instructions or specifications.

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Policy No. EHS-501

3. 4. 5. 6. 7.

Contractor Safety – Appendix A.3

Deliberately damaging, defacing, or misusing Facility or Site property or the property of others. Removing Facility or Site property from the premises without appropriate authorization. Gambling, bookmaking or selling lotteries on Facility or Site property. Immoral or indecent conduct; sexual harassment. Illegally possessing, selling, distributing or manufacturing drugs on Facility or Site property.

Asbestos & Other Fibers 1. All fibrous materials must be accompanied by a MSDS and must be treated with care. 2. Unless a Facility or Site is documented to be asbestos free, the Contractor Worker shall not disturb any fibrous material, but shall notify the Supervisor immediately if any is found. 3. Any Contractor performing asbestos abatement must comply with requirements stipulated in Facility or Site procedures and any Federal, State, or local regulatory requirements. Barricades and Notice of Work Activity 1. The Contractor Supervisor, or designee, is responsible for notifying the Facility (S&W) Representative if barricades, signs or other notices of work activity are required. The Contractor Supervisor will work with Facility or Site personnel, as designated, to erect all necessary barricades and notices to safeguard all individuals, both Contractor Workers and site employees, during the conduct of the Contractor’s work. 2. Barricades and notices are required around excavations, holes, or openings in floors, roofs, elevated platforms, around certain types of overhead work, and whenever necessary to warn people against falling objects or debris. 3. Blinking lights must be used on protective barricades, where lighting is inadequate. 4. The use of Caution Tape, yellow and black tape, means access to areas may be permitted only when it is safe to do so. 5. Areas in which entry is not permitted will be taped-off with red and black barricade tape and have signs similar to “Danger - Do Not Enter” posted. Contractor Workers shall not enter such areas. Confined Space Entry 1. Contractors must be pre-qualified by the Facility to perform the work (have appropriate training per regulatory requirements) and briefed on the hazards of the confined space(s) prior to beginning work. 2. Contractors shall use S&W Confined Space Entry procedures, unless another arrangement has been agreed upon by the Contractor and S&W.

No one will enter a PERMIT-REQUIRED CONFINED SPACE until a confined space entry permit has been issued and posted.

Cranes and Motorized Equipment 1. The Contractor is responsible for mobile equipment operator training, applicable examinations and certifications to qualify to operate equipment, and DOT licensure. 2. Only certified operators with valid certifications may operate cranes and other motorized equipment at the S&W Facility or Site. Defective Equipment 1. The Contractor Worker shall ensure that all tools and equipment shall be inspected prior to use. Any defective equipment shall be tagged “OUT OF SERVICE” and removed until it has been repaired or discarded. Demolition 1. All demolition work shall be conducted in such a manner as established in accordance with the Engineering requirements.

Page 2

Policy No. EHS-501

Contractor Safety – Appendix A.3

Emergency Response 1. Contract Workers shall review and become familiar with the Facility’s or Site’s Emergency Response Plan and procedures before beginning assigned work. This is typically done at initial safety meeting. 2. The Contractor shall ensure that all Contractor Workers are familiar with the Facility’s or Site’s spill notification and evacuation procedures as described in the Emergency Response Plan and know where to muster in an emergency. Also, the Contractor shall be made aware of all emergency contacts and procedures for reporting fires. 3. The Contractor must arrange to have spill containment (secondary containment), decontamination of affected clothing, equipment and spill clean-up, if applicable to activities performed on-site. Contractor may provide their own or get assistance from Facility to provide. 4. Spills must be properly managed to prevent harm or degradation of the environment, access to storm water or sanitary sewer drains, and to ensure worker safety. 5. Evacuate the area if a spill involves hazardous, explosive, or flammable materials. 6. Contractor Supervisors are required to know who is on their job, and be able to account for them at all times, especially after an evacuation. 7. Contractor Supervisors must report missing personnel and their presumed location to the Facility (S&W) Representative as quickly as possible. 8. Approved First Aid supplies shall be made available by the Contractor for its Contractor Workers in ample quantities at all times. If this cannot be supplied, the Contractor shall ask for the assistance of the Facility or Site to provide. Excavations 1. Prior to commencement of any excavation, the Contractor shall notify the Facility (S&W) Representative, Shift Supervisor, or designee. 2. Contractor, in conjunction with Facility or Site personnel, shall ensure that excavation areas are properly barricaded and have posted warning signs to ensure the safety of all individuals on-site. Fire Protection 1. The reason for discharging a fire extinguisher shall be discussed with all Contractors. After recharging, the extinguisher shall be returned to its original location by the Facility Representative, or designee. 2. Contractor Workers shall not obstruct in any way access to fire extinguishers, fire hose stations or other fire apparatus, emergency eye wash stations and showers, spill response equipment or other safety related equipment. 3. Contractor Workers shall know the location and correct operation of the nearest fire alarm and fire extinguisher. 4. Contractor Workers shall know the location of designated fire exits and shall not block access to those exits. 5. Contractor Workers shall not refuel equipment while it is running or when hot. 6. Contractor Workers shall keep combustible and flammable materials away from hot surfaces and ignition sources. 7. Contractor Workers will store flammable materials in approved cabinets (supplied by the Contractor or Facility). Hazard Communication Program (HAZCOM) 1. Any HAZARDOUS MATERIALS brought on site must be accompanied by the associated MSDS. They shall be approved by the Facility or Site prior to the Contractor bringing them on-site. The MSDS must be provided to the Facility Representative, or designee. All hazardous material must be in an approved container, including all flammable substances. Hazardous materials are not to be left on site. 2. All containers used by the Contractor shall be properly labeled as to the contents and physical and health hazards at all times. 3. Each Contractor will have a HAZCOM program that includes at a minimum: complete MSDS’s on hand at the work site for each chemical used, chemical inventory, adequate training for all personnel Page 3

Policy No. EHS-501

Contractor Safety – Appendix A.3

that covers: physical and health hazards of all products, proper handling of the products, and personal protective equipment.

A copy of the Facility or Site’s HAZCOM program and the Facility or Site MSDS inventory will be made available to any Contractor Worker upon request.

Hazardous Substance / Waste Management 1. Contractor Workers shall properly handle all hazardous and toxic substances and materials utilized in its work at the Facility or Site. 2. Propane and compressed gas cylinders must be chained upright and on approved carriers when moved. 3. All Contractors are responsible for the proper disposal of construction debris generated at this Facility or Site. 4. Contractors must make advance arrangements with the Facility Representative for the placement of the proper waste collection containers at the work-site and is not to be placed in any existing waste container located at the Facility or Site without approval by the Facility. 5. Enclosed disposal chutes are to be used whenever waste materials are to be dropped more than 10 feet. 6. Contractor Workers will comply with requirements of S&W’s Hazardous Material Handling and Waste Management procedures while on-site. Hot Work 1. Contractor Workers shall not perform hot work (welding, cutting, brazing, and burning operations) without obtaining a Hot Work Permit. 2. Contractor Workers shall comply with S&W’s Hot Work procedure and all its requirements. Housekeeping 1. The Contractor Worker shall maintain all walkways and work areas clear of obstructions, tripping hazards, and debris. 2. All oily rags must be disposed of in appropriate containers designed for oily wastes. Ladders and Scaffolding 1. All ladders must be approved for use before being put into service. Each user must inspect ladders visually before using. 2. If it is necessary to place a ladder in or over a doorway, barricade the door and/or post warning signs. 3. Metal ladders must not be used for electrical welding, or near electric lines or services. 4. Ladders must be tied off, with the user wearing a safety harness, if it is necessary to use a ladder on top of a scaffold or close to the edge of an elevated platform, roof, or floor opening. 5. The top of the ladder must extend at least three (3) feet beyond the supporting object, when used as access to an elevated work area. 6. Sound, rigid and suitable footing is required for all scaffolds and no unsuitable objects shall be used for support, such as barrels, boxes, bricks or concrete blocks. 7. Guardrails and toe boards shall be installed in conformance with regulatory and engineering requirements and standards. 8. Where persons are required to pass underneath, all scaffolds will be provided with ½” mesh screening between the tow board and guardrail. 9. Scaffold and components shall be capable of supporting four times its intended load without failure. 10. Personnel must wear properly tied-off safety harnesses on scaffold platforms not equipped with standard handrails or completed decking. Safety harnesses must be secured before stepping onto the scaffold, and must not be removed until personnel are clear of the scaffold. Harnesses must be tied off to independent lifelines or building structures – one lifeline per person. Page 4

Policy No. EHS-501

Contractor Safety – Appendix A.3

11. No one is allowed to ride a rolling scaffold while it is being moved. All tools and materials must either be removed or secured on the deck before moving. Pulling the scaffold along from overhead while on the scaffold is prohibited. 12. Brick, tile, block or other similar materials may not be stacked higher than 24 inches on the scaffold deck. 13. All scaffolds shall be erected and maintained in accordance with regulatory and engineering requirements and standards. 14. Contractors shall comply with S&W’s Ladders, Scaffolding and Fall Protection procedures. Lead Paint 1. For operations comprising of the grinding, welding, or burning of lead painted surfaces the Facility (S&W) Representative must be notified prior to the start of work. If it is not known whether the surface has lead paint on it, the Facility (S&W) Representative will be consulted. 2. The area shall be posted that work is being conducted on lead painted surfaces. 3. Work practices such as using HEPA vacuum and exhaust ventilation will be applied. Lockout / Tagout 1. Contractor Workers must get approval from the Facility or Site Shift Supervisor, BEFORE beginning work on LOTO'ed equipment. 2. All electrical wires and circuits are to be considered energized unless power is definitely disconnected and the applicable switches locked and tagged out. 3. Contractors shall comply with S&W’s Lockout / Tagout procedure. Personal Protective Equipment (PPE) 1. Contractor Workers shall wear flame resistant or 100% cotton long sleeved shirts and long pants while involved in tasks with exposure to flames or electric arcs. Shirts with sleeves (long or short) will be worn at all other times. 2. ANSI-approved hard hats shall be properly worn by all Contractor Workers and visitors throughout the Facility, except in office areas and in other designated areas. (Metal hard hats are prohibited.) 3. ANSI-approved safety glasses with side shields shall be properly worn by all Contractor Workers and visitors throughout the Facility, except in office areas. 4. Both chemical goggles and face shields shall be worn when working with or loading / unloading chemicals such as ammonia, sulfuric acid, caustic etc. 5. ANSI approved safety shoes must be worn by all Contractors working on site. No sneakers or dress shoes will be allowed. 6. Approved full body harnesses and lanyards shall be properly used when working in areas where a potential fall hazard exists. 7. Approved hearing protection shall be properly used in designated areas. When in doubt of noise levels, hearing protection shall be used. Double hearing protection must be used when working in or around the turbines/generators when in operation with enclosures open. 8. Respiratory protection will be properly used where administrative or engineering controls fail to reduce air contaminants to within OSHA prescribed limits. Contractors shall comply with S&W Respiratory Protection procedure, or equivalent procedure of their own. 9. Contractors are responsible for ensuring their Contractor Workers have the proper respiratory fit testing and training. 10. Other approved PPE such as face shields, protective clothing, gloves, etc. shall be used by Contractor Workers where the risk of injury or illness may be prevented by its use. 11. All requirements as described in S&W’s Personal Protective Equipment procedure shall be met. Reporting EHS Incidents 1. The Contractor Supervisor is responsible for reporting any work related injury/illness or near misses (or environmental incidents) to the Facility (S&W) Representative as soon as they become known. 2. The Contractor Worker, Contractor Supervisor and Facility (S&W) Representative will complete all required paperwork per S&W’s EHS Incident Reporting procedure. Facility or Site-Specific Contractor EHS Rules Page 5

Policy No. EHS-501

Contractor Safety – Appendix A.3

Any S&W Facility or Site shall add any site-specific EHS rules not previously covered in these Rules. Use additional sheets, if necessary. Any attachments or additions shall be kept with the original set of rules. The first time each Contractor arrives on-site each year, they must read and sign this Form (which shall include any site-specific rules added). Records shall be maintained for 3 years.

Contractor EHS Rules Compliance Statement I HAVE READ AND FULLY UNDERSTAND THE ABOVE RULES. I HAVE BEEN INFORMED OF THE PROPER ACTIONS TO TAKE IN THE EVENT OF A FACILITY EMERGENCY AND HAVE BEEN BRIEFED ON ALARM LOCATIONS, EVACUATION ROUTES AND MUSTER AREAS. Printed Name:

Company:

Signature:

Date:

Page 6

Policy No. EHS-501

Contractor Safety– Appendix A.4

Daily Contractor Work Permit This form must be completed in full by the Contractor Supervisor prior to any work being conducted. Contractor Work to be Done: Work Will Involve:

Today’s Date:

Confined Space Entry

Hot Work

Hearing Protection

LOTO

Respiratory Protection

Others: Contractor Supervisor Certification Contractor Workers under my supervision at this Facility or Site will work within the requirements established in all S&W Energy Solutions (SWES) procedures that are applicable to their work. Within the last year, Contractor Workers under my supervision have received and have acknowledged that they will comply with the site Contractor Environment, Health and Safety Rules. I have been advised by the Facility (PES) Representative of the hazards associated with this job, the location of emergency equipment, procedures for reporting an emergency, evacuation routes and any additional personal protective equipment that is required to perform the job. I have communicated all of this information to EACH Contractor Worker under my supervision. I understand it is my Company’s and my own responsibility to ensure that all Contractor Workers under my supervision are identified on the Contractor EHS Training Tracking Certification Form and ensure that each have been trained to the appropriate standards for which they are to perform work.

ADDITIONAL INFORMATION:

Contractor Supervisor:

Date: ____/____/____

Witnessed by Shift Supervisor, Control Room Operator, or Designee:

Date: ____/____/____

Page 1

Policy No. EHS-501

Contractor Safety – Appendix A.5

Sample Weekly Safety Meeting Form Contractor Name: Date: Safety Topic: Mtg. Conducted

AM

Time: Signature Meeting Attendees

Print Name

Signature

1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19 20. 21. 22. 23. 24. 25.

Description of Meeting:

A copy of this form must be given to the Facility (S&W) Representative. Page 1

PM

Policy No.EHS-501

Contractor Safety – Appendix A.6

Sample Contractor Inspection Checklist – Page 1 Contract

Job:

Chemical Storage/Usage • MSDSs for chemicals brought on site? • Correct chemical dispensing (grounding and containment)? • Chemicals in proper containers? • All containers labeled? Compressed Gases • Cylinders secured? • Protective cap fastened? • Incompatible cylinders separated? Confined Space • Entry permit displayed? • Air monitoring results recorded? • Safety equipment utilized? • Attendant/standby person present? • Rescue equipment ready? • Rescue services identified? Electrical Safety / LOTO Have all Contractors: • Signed onto the LOTO Form? • Been afforded the opportunity to walk down the LOTO • Each Contractor Worker on the LOTO has their own personal lock • Electrical equipment/extension cords in good condition? • Are tools and/or plugs grounded (GFCI)? Elevated Work Areas • Openings in floors and walls guarded? • Appropriate fall protection used? Excavations • All underground utilities identified? • Proper agency contacted (i.e. DIGSAFE)? • Appropriate sloping and/or shoring? • Hazardous conditions controlled? • Means of entry and egress established? • Work area access controlled? Comments:

Yes

Page 1

No

Corrective Action

Policy No.EHS-501

Contractor Safety – Appendix A.6

Sample Contractor Inspection Checklist – Page 2 General Safety • Is work area free of debris and clutter? • Is access to work areas, walkways, exits, safety showers, fire extinguishers unobstructed? • Are floors dry? • Work area access controlled? • Date of last fire extinguisher inspection? Hand Tools • Tools in good condition? • Guards in place? Hot Work (Welding, Cutting, Sparking) • Hot work permit displayed? • No flammable or combustible materials in the area? • Fire watch posted? • Welding screen in place? • Fire extinguishers nearby & charged? • Means to report fires easily accessible? • Appropriate PPE in use? • Leads and gas hoses in good condition? Ladders and Scaffolds • Ladders secured and tied off? • Scaffold railings and toe boards secure? Motorized Equipment • All equipment inspected? • All fork trucks, cranes, manlifts in good working condition? • All operators trained? • Seat belts worn? • Safe operating procedures followed? Personal Protective Equipment (PPE) Is all required PPE being worn? • Safety Shoes • Hard Hats • Safety Glasses • Hand/Arm protection • Respiratory protection • Hearing protection Other:

Yes

No

Corrective Action

Inspection Conducted By: Contractor S i Facility R i

Date: Date:

Page 2

Policy No. EHS-102

Medical Records Appendix B

Medical Records Access Request Form I, ____________________________________ (full name of worker / patient), hereby authorize ______________________________ (Individual or organization holding the medical records) to release to ___________________________________ (Individual or Organization authorized to receive the medical information), the following medical information from my personal medical records:

(Describe generally the information desired to be released) I give my permission for this medical information to be used for the following purpose:

But I do not give permission for any other use or re-disclosure of this information. Other information or special requests:

(Describe any additional information that may be important to this request and authorization such as (1) a particular expiration date of consent or authorization of this letter, (2) medical information to be recorded in the future that this consent may cover, or (3) describe portions of the medical records which you intend not to be released as a result of this letter). Full Name of Employee or Legal Representative:

Signature of Employee or Legal Representative:

Date of Signature:

Page 1

Policy No. EHS-104

EHS Management of Change Appendix C.1

EXAMPLES OF CHANGES AND REPLACEMENT-IN-KIND – Page 1 Examples of “Changes” (requiring the Management of Change Process): •

Introduction of a new chemical, or reintroduction of a chemical after an absence of 2 years or more;



Installation of new equipment, piping, electrical or control systems, or modifications to existing equipment, piping, electrical, or control systems;



Installation of a new building or structure, or modification of an existing building or structure;



Shutdown of an operating facility for 6 months or more, or restart of a facility following a 6month idle period;



Revision of a procedure or process parameter to allow operation outside of the wellunderstood and documented “safe operating scenario”;



Any procedural modification (new or existing) or change to a controlled document;



Revision of a hardware or software control system, control scheme, or critical alarm limit;



Any change in safety alarm settings, interlocks, and process trips;



Any change in safety relief valve setting or capacity;



Any repair or replacement NOT IN KIND, where either materials, material surfaces or properties, testing, fabrication techniques, or applicable codes are changed;



Any changes in safety or protective equipment as to location and type (fire protection, alarms, vapor detection systems, etc.)

Page 1

Policy No. EHS-104

EHS Management of Change Appendix C.1

EXAMPLES OF CHANGES AND REPLACEMENT-IN-KIND – Page 2 Specific Examples of Activities Which Do NOT Constitute A Facility or Operational Change (no Management of Change Process required): •

Replacement-In-Kind of equipment, Facility structures, piping, instrumentation, electrical components, or any other piece of equipment or apparatus (replacement of equipment with equipment having the same technical specifications);



Change in set point of an operating guide alarm;



Routine service changes of multiservice operating systems where the operating procedures provide appropriate guidelines for such service changes, and where the procedures have been subjected to a Facility or operational Review prior to becoming effective;



Building modifications (interior redesign within an existing structure);



Changes to computer control applications, unless the changes would appear on P&ID's;



Operating procedures (or permits) that are in agreement with past operating practices.

These two lists are not intended to be all encompassing. These are only a few listed examples and types. Each proposed change shall be reviewed to see if it meets the applicability criteria of the Management of Change procedure and policy.

Page 2

Policy No. EHS-104

EHSManagement of Change Appendix C.2

CHANGE MANAGEMENT RECORD (CHANGE REQUEST FORM) – Page 1 Person Proposing Change:

Date:

System to be Modified:

Basis For Change (check all that apply): Safety

Operational Necessity

Economic New Material or Design _____________________________

Environmental

Procedural

Other:

Scope / Justification of Change: Description:

Attach Pictures, Drawings, P&IDs, or Other Documents, as necessary. Initial Review: Signature:

Date:

Final Review (Change Request Approval): Signature:

Date:

Page 1

Policy No. EHS-104

EHSManagement of Change Appendix C.2

CHANGE MANAGEMENT RECORD (CHANGE REQUEST FORM) – Page 2 CHECK ALL THAT APPLY

REQ’D

RESPONSIBILITY

COMPLETION DATE

Detailed Parts List / Cost Process Hazard Review Hazardous (New or Revised) Material Review Revised Operating Procedures Revised Maintenance Procedures Training (Operator or Maintenance) P&ID Update Electrical Drawing Update Spare Parts Review Regulatory Agency Permit Safety Review X REQUIRED Other:

Facility Change Request Completed: Signature:

Date:

THIS FORM MUST REMAIN ON SITE FOR THE DURATION OF THE POLICY OR PROCEDURE

Page 2

INITIALS

Policy No. EHS-202

OSHA Inspection Procedure Appendix D.1

NOTICE TO OSHA

It is the policy of S&W Energy to cooperate with any governmental agency seeking to lawfully enforce federal, state, or local laws and regulations pursuant to the safeguards guaranteed to us by the Constitution of the United States. S&W Energy is familiar with federal court decision and the ruling of the Supreme Court of the United States in the Marshal v. Barlow’s, Inc. that all warrantless searches or inspections of company property, or any portion thereof, conducted pursuant to Section 8(a) of the Occupational Safety and Health Act of 1970 are unconstitutional. Therefore, S&W Energy chooses to exercise its constitutional rights and will not permit or is any employee of the Company authorized to permit, any search or inspection by any representative of the Occupational Safety and Health Administration unless conducted pursuant to a valid warrant. S&W Energy does not believe that probable cause exists for an OSHA inspection of its property. In the event that the Secretary of Labor believes otherwise and decides to make application for an inspection warrant, S&W Energy hereby requests that it be given advance notice of such application so it can have an opportunity to oppose the same. This statement of policy has been reduced to writing and is being delivered in hand to each OSHA representative seeking to make a warrantless search of our property so that OSHA will be officially advised of everything stated herein.

This notice to OSHA was delivered in hand on the premises of the S&W Energy project to , a representative of OSHA, by

, a representative of S&W Energy, on , 20

at

Page 1

o’clock

Policy No. EHS-202

OSHA Inspection Procedure Appendix D.2

NOTICE OF PROTEST

ProEnergy Services acknowledges the existence of an inspection warrant which appears on its face to authorize an OSHA inspection to be conducted on these premises. The company does not believe that the said warrant was issued pursuant to the law and does not believe that probable cause exists for the warrant. However, since the warrant is facially in proper form, the Company believes it could be cited for contempt of court if it declined to allow the inspection to begin as stated in the warrant. The Company, therefore will allow the inspection UNDER PROTEST. By so doing, we do not waive our right to challenge the validity of the inspection or the authorization of its conduct and specifically preserve the right to do so should any OSHA enforcement proceeding be commenced against this company, based on this inspection or should there be any other reason to litigate this matter.

This Notice of Protest was delivered in hand on the premises of this company to , a representative of OSHA, by

, a representative of

ProEnergy Services, on

, 20

Page 1

, at

o’clock

Policy No. EHS-301

OSHA Recordkeeping and Reporting Appendix E.1

OSHA RECORDABLE INCIDENT FLOWCHART

GUIDE TO RECORDABILITY CASES UNDER THE OCCUPATIONAL SAFETY AND HEALTH ACT (OSHA) If a CASE

Results from a work accident or from an exposure in the work environment and is:

A Death

NOTE: A CASE must involve a death, an injury, or an illness to an Employee

An Illness

Does not result from a work accident or from an exposure in the work environment

An Injury which Involves:

Medical Treatment other than First Aid

Loss of Consciousness

Restriction of Work or Motion

THEN CASE MUST BE RECORDED

Page 1

Transfer to Another Job

None of These

THEN CASE NOT TO BE RECORDED

Policy No. EHS-301

OSHA Recordkeeping and Reporting Appendix E.2

OSHA RECORDABLE INCIDENT CHECKLIST A.

An occupational injury (caused by an instantaneous event in the work environment) is OSHA recordable if at least one of the following items is checked: Medical Treatment: Treatment of INFECTION (application of nonprescription medication is considered first aid and not recordable). Application of ANTISEPTICS during second or subsequent visit Treatment of SECOND or THIRD DEGREE BURN(S) Application of SUTURES (stitches) Application of BUTTERFLY ADHESIVE DRESSING(S) OR STERI STRIP(S) in lieu of stitches Removal of FOREIGN BODIES EMBEDDED IN EYE if more than irrigation is required Removal of FOREIGN BODIES FORM WOUND if procedure is more complicated than using tweezers or other simple techniques Use of PRESCRIPTION MEDICATIONS (except a single dose administered on the first visit for minor injury or discomfort) Use of HOT OR COLD SOAKING THERAPY during second or subsequent visit to medical personnel Application of HOT OR COLD COMPRESS(ES) during second or subsequent visit to medical personnel CUTTING AWAY DEAD SKIN (surgical debridement) Application of HEAT THERAPY during second or subsequent visit to medical personnel Use of WHIRLPOOL BATH THERAPY during second or subsequent visit to medical personnel PHYSICAL THERAPY SESSIONS during second or subsequent visit to medical personnel POSITIVE X-RAY DIAGNOSIS (fractures, broken bones, etc.) ADMISSION TO A HOSPITAL or equivalent medical facility for medical treatment involving more than one observation Series of treatments given by a CHIROPRACTOR 2.

Loss of Consciousness

3.

Restriction of Work or Motion Light duty / restricted work activity Days away from work

4.

Transfer to Another Job (as a result of an injury)

**IF ONE ITEM ABOVE IS CHECKED, THE WORK-RELATED INJURY IS ALMOST ALWAYS RECORDABLE**

B.

An occupational illness (a case resulting from anything other than an instantaneous event in the work environment) is always recordable. Work-related illnesses usually occur over time, and result in both acute and chronic illnesses caused by inhalation, direct contact, etc. The difference between a recordable injury and recordable illness is well-represented using a hearing loss example. If a loss of hearing from an explosion (an instantaneous event) AND it fits into one of the injury recordability criteria above, it is a recordable injury. If a loss of hearing resulted from exposure to industrial noise over a period of time, it is a recordable illness. Another example of a recordable illness is work-related carpal tunnel syndrome, because it is almost always results from repetitious movement.

Page 1

Policy No. EHS-301

OSHA Recordkeeping and Reporting Appendix E.3

OSHA RECORDABILITY GUIDANCE – NOTES When is an injury or illness considered work-related? If an event or exposure in the work environment caused or contributed to the condition or significantly aggravated a preexisting condition. Work-relatedness is presumed for injuries and illnesses resulting from events or exposures occurring in the workplace, unless specifically noted otherwise. The work environment includes the establishments and other locations where one or more employees are working or are present as a condition of their employment.

Which work-related injuries and illnesses do you record? See Previous Recordability Flowchart

What are additional “Criteria” for recordability? Record the following conditions if they are work-related: • Any needle stick injury or cut from a sharp object that is contaminated with another person’s blood or other potentially infectious material; • Any case involving an employee to be medically removed under the requirements of an OSHA health standard; • Any Standard Threshold Shift (STS) in hearing (i.e., cases involving an average hearing loss of 10dB or more in one ear); and • Tuberculosis infection as evidenced by a positive skin test or diagnosis by a physician or other licensed health care professional.

What is First Aid? If incident requires only the following types of treatment, consider it First Aid and NOT Recordable: • • • • • • • • • • • • •

Using non-prescription medications at non-prescription strength; Administering tetanus immunizations; Cleaning, flushing, or soaking wounds on the skin surface; Using wound coverings, such as bandages, Band-Aids, gauze pads, etc. Using hot or cold therapy; Using any totally non-rigid means of support, such as elastic bandages, wraps, no-rigid back belts, etc.; Using temporary immobilization devices while transporting an accident victim (splints, slings, neck collars, or back boards); Drilling a toenail or fingernail to relieve pressure, or draining fluids from blisters; Using eye patches; Using simple irrigation or a cotton swab to remove foreign bodies not embedded in or adhered to the eye; Using irrigation, tweezers, cotton swab or other simple means to remove splinters or foreign material from areas other than the eye; Using finger guards; Using massages; Drinking fluids to relieve heat stress.

• Under what circumstances should you NOT enter employee’s name on the OSHA 300 Form: • Any injury or illness to an intimate body part or to the reproductive system; • An injury or illness resulting from a sexual assault; • A mental illness; • A case of HIV, hepatitis, or tuberculosis, • A needle stick injury or cut from sharp object contaminated with blood or other infectious material; • Other illnesses that an employee may request that his or her name not be entered on the Log. Under these circumstances, “Privacy Case” should be entered in the space provided for “Employee Name”

Page 1

Policy No. EHS-302

EHS Incident Reporting Appendix F.1

EHS INCIDENT REPORT FORM – PAGE 1 Incident Report #:

Facility / Site / Job Name:

Location:

Phone #:

GENERAL INFORMATION: EMPLOYEE INVOLVED (if Injury/Illness/Fatality/Near Miss): TYPE OF INCIDENT: S&W Energy Employee Contractor ___________________________________________ (Company Name) Visitor Customer Other: ______________________________________________ Not Applicable (if environmental/permit/spill related) __________________________________________ Date of Incident:

Day of Week:

Injury/Illness/Fatality Near Miss Fire Spill/Release Permit Violation Explosion Other:

Approximate Time (AM/PM):

Shift:

IF PERMIT VIOLATION, EXCEEDANCE, or RELEASE: TYPE OF PERMIT VIOLATION (ENVIRONMENTAL) Air Description (NOx, SO2, CO, NH3, etc.): ____________________________________________ Permit Limit (include units): _________________________ Actual Reading (include units): _______________________ Water Description (pH, heavy metals, oil&grease, etc.) ____________________________________ Permit Limit (include units): _________________________ Actual Reading (include units): _________________________ Chemical Spill / Release Description (include name of chemical, off-site migration, and estimated quantity): ________________________________________________________________________________________________________ Other: ____________________________________________________________________________________________________

NOTIFICATIONS:

DATE:

Facility/Site/Office Manager (Supervisor) Customer Representative (if applicable) S&W Energy EHS Manager

Page 1

TIME:

CONTACT NAME / METHOD:

Policy No. EHS-302

EHS Incident Reporting Appendix F.1

EHS INCIDENT REPORT FORM – PAGE 2

INJURY / ILLNESS / NEAR MISS - PERSONNEL INFORMATION Last Name:

First Name

IF CONTRACTOR, Company Name:

Phone:

Job Title:

Middle Initial:

Age:

Company Contact Name:

Type of Injury (Body Parts Injured):

Medical Treatment Provided (EMT or Hospital Name, Info):

DESCRIPTION OF INCIDENT – DETAILED SEQUENCE OF EVENTS: (Attach additional pages as necessary)

WITNESSES OF INCIDENT (IF APPLICABLE): Last Name:

First Name:

Middle Initial:

Last Name:

First Name:

Middle Initial:

Last Name:

First Name:

Middle Initial:

Page 2

Policy No. EHS-302

EHS Incident Reporting Appendix F.2

EHS INCIDENT INVESTIGATION REPORT FORM (Attach Additional Pages, If Necessary) Reference Same Incident Report Number that Relates to this Investigation: Incident Report #:

Facility / Site / Job Name:

Location:

INDIVIDUALS INTERVIEWED: LAST NAME FIRST NAME

MI

Phone #:

JOB TITLE

DESCRIPTION OF CAUSES AS A RESULT OF INVESTIGATION: Who, When, Where and Why

FOLLOW-UP CORRECTIVE ACTIONS (Attach Additional Pages if Necessary): Estimated Corrective Action(s) Responsible Completion Date Person

Actual Completion Date

INVESTIGATION TEAM: Investigator: ________________________ ________________________ Job Title: ______________________ Date: __________ Investigator: ________________________ ________________________ Job Title: ______________________ Date: __________

CLOSURE APPROVAL: Facility/Site/Office Manager, Supervisor

_____________________ ____________________ Print

Signature

ALL CORRECTIVE ACTIONS MUST BE TRACKED TO CLOSURE AND CLOSURE APPROVED

Page 1

________ Date

Policy No. EHS-304

EHS Monthly Reporting, Field Service Appendix H

Field Service Monthly EHS Report Form Facility / Site Name:

Month:

S&W Energy Injuries and Illnesses Number of Recordable Injuries and Illnesses Number of Recordable Injuries or Illnesses Involving Days Away From Work (Include Number of Days Missed) Number of Recordable Injuries or Illnesses Involving Days of Restricted Work Duty (Include Number of Days w/ Restricted Work Duty) Total Number of All S&W Energy Employee Hours Worked – Combined

Facility Environmental Exceedances Number of Air Permit Exceedances Nitrogen Oxides (NOx): Sulfur Dioxide (SO2): Carbon Monoxide (CO): Ammonia (NH3): Other: Number of Water Permit Exceedances Wastewater: Storm water: Other: Number of Reportable Spills and Releases

Agency Inspections Number of Regulatory Agency EHS Inspections / Audits Health & Safety: Environmental:

Violations / Citations / Fines Number of Violations / Citations / Notices of NonCompliance Number of Fines Proposed (Include $ Amount)

Page 1

Month

Year:

Year to Date

Number:

Number:

Days:

Days:

Number:

Number:

Days:

Days:

S&W Energy Solutions (SWES) EHS Training Matrix - Appendix I

Course #

1

EHS Course Title

Topics

To inform employees on the Accident Prevention, Signs meaning of various Danger and & Tags Caution Signs and Tags

To inform employees of the proper handling, loading, & unloading procedures

2

Ammonia Loading & Unloading

3

Methods of recognizing asbestos, ACMs, & related health effects associated w/ asbestos exposure, operations that could result in asbestos exposure, protective controls, work practices, medical surveillance requirements, communication reqs. INCLUDE Section on Fiber Management (identification and hazards of Asbestos Mgt. Awareness ceramic fibers other than asbestos) (Class IV)

4

5 6

7

Applicability

All employees

Regulatory Required (R)

Best Practice (BP)

R

All employees (at least awareness). More extensive course for those handling Ammonia.

All employees - if proven that site or work does not conatin any asbestose or never will, this training is optional. Required if handling (along with other required training).

S&W Required (S&W)

S&W

R

Regulatory Reference

Comments

Refresher (Y/N)

Frequency (Yrs)

Refresher Requirement

29CFR1910.145 (C)

Y

Every 3 years

S&W

N/A

Y

Every 2 Years

S&W

29CFR1910.1001(j)

Y

Annually

29CFR1910.1001(j)

N/A

Y

Every 2 Years

BP

Back Safety

To inform employees of safe lifting practices, and ways to protect and care for the back (can be inlcuded as part of Ergonomics training) All employees

Bloodborne Pathogens

To inform employees of methods of minimizing occupational All employees who receive exposure to HBV, HIV, etc. by first aid and/or CPR using universal precautions. training.

R

29CFR1910.1030

Y

Annually

29CFR1910.1030

Confined Space Entry

For entry into confined spaces-training, permitting, hazard recognition

R

29CFR1910.146(d) & (g)

Y

Every 2 Years

S&W

Confined Space Rescue Team - Classroom

Designated individuals, depending on Site requirements. These indiviuals must also be trained in First Aid, CPR, To train personnel on how to rescue someone from a confined and Bloodborne Pathogens. space

R

29CFR1910.146(k)

Y

Annually

29CFR1910.146(k)

All employees except Admin.

BP

Page 1 of 7

2/19/2007

S&W Energy Solutions (SWES) EHS Training Matrix Appendix I

Course #

8

EHS Course Title

Confined Space Rescue Team Drill - Hands-On

Topics

Applicability

Refresher (Y/N)

Frequency (Yrs)

Refresher Requirement

Y

Annually

29CFR1910.146(k)

R

29CFR1910.269 29CFR1910.146(k)

Y

Annually

29CFR1910.269 29CFR1910.146(k)

R

29CFR1910.179 29CFR1910.184

Y

Every 2 Years

S&W

N/A

Y

Every 3 years

S&W

29CFR1910.147, 29 CFR1910.269

Y

Every 2 Years

S&W

N/A

N

N/A

N

Annually

S&W

10

Crane & Rigging Safety

Crane-specific operations and inspection. Inspection and use of slings and attachments. (Couple training with Slings and Derricks)

Any employee assigned to operate/inspect cranes. Employees assigned to use/inspect slings and attachments.

11

Defensive Driving (Use of Cars on Company Business)

Discussion of proper driving techniques, attitudes, and safety measures.

All employees who operate vehicles for company use.

Energy Control & Power Lockout (EPCL) Lockout/Tagout (LOTO)

All employees who are involved in maintenance and service of equipment Recognition of energy sources and the need to apply locks/tags under LOTO or who work to such sources to assure proper in areas where LOTO is deenergization for maintenance. being performed.

EHS Awareness

EHS Vision and Commitments. Overview of envrionmental, health , & safety regulations. All employees

EHS Policy

Review S&W Energy Services EHS Policy (include business Drug & Alcohol Policy)

14

Regulatory Reference

Comments

29CFR1910.146(k)

To inform and teach employees proper CPR techniques.

13

Best Practice (BP)

R

CPR

12

S&W Required (S&W)

To train personnel through practical experience how to All confined space rescue rescue someone form a confined team members (may space include outside agencies)

Any person who is on a confined space rescue team, or designated individuals (based on site or contractor requirement) must be trained in CPR. All employees trained in CPR must also be trained in Bloodborne Pathogens.

9

Regulatory Required (R)

All employees

S&W

R

BP

S&W

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Initial Only

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S&W Energy Solutions (SWES) EHS Training Matrix Appendix I

Course #

EHS Course Title

Topics

Applicability

15

Electrical Safety-QUALIFIED INDIVIDUAL

Explain fundamentals of electrical accidents. Define proper procedures for identifying energized equipment & working on electrical equipment safely. All employees allowed to Define appropriate safe distances work on or near energized to energized equipment. parts.

16

Electrical Safety-UNQUALIFIED INDIVIDUAL

Explain fundamentals of electricity All employees other than and electrical safety (may be those identified as portion of Quailified training). Qualified Individuals

17

Emergency Action Plan Classroom

Explains actions to be taken by employees during an emergency. All employees

18

Emergency Response / Action Plan - Drill

Demonstrates preparedness of employees to respond to an emergency (INCLUDE Fire Drill)

Employee Alarm Systems

To inform employees on how to report emergencies (can be combined with Emergency Action Plan Training) All employees

Ergonomics

Discussion of ergonomics, and how to minimize potentially harmful workplace situations.

All employees

21

Fall Protection

Proper inspection & use of fall protection systems, stairways, ladders, etc.

22

Familiarize employees with the Fire Extinguisher (Portable) proper inspection and use of Awareness portable fire extinguishers

19

20

23

24

25

Regulatory Required (R)

S&W Required (S&W)

Best Practice (BP)

Regulatory Reference

Comments

29CFR1910.269(a) 29CFR1910.332(a)

Y

N/A

N

29CFR1910.38(a)(5)

Frequency (Yrs)

Refresher Requirement

Annually

S&W

Y

Annually

S&W

N/A

Y

Annually

S&W

29CFR1910.165(b)

Y

Annually

S&W

R (Proposed)

29CFR1910.900

Y

Every 3 years

29CFR1910.900

All employees (except Admin)

R

29CFR1926.503

Y

Every 2 Years

S&W

All Employees

R

29CFR1910.157(g)

Y

Annually

29CFR1910.157(g)

Fire Prevention Plan Classroom

Informs employees on the site fire hazards of the materials and processes to which they are exposed. All employees

R

29CFR1910.38(b)

Y

Annually

S&W

Fire Prevention Plan-Drill

Demonstrates preparedness of employees to respond to a fire (INCLUDE as part of Emergency Action Drill) All employees

N/A

Y

Annually

S&W

29CFR1910.151

Y

Every 3 years

29CFR1910.151

First Aid

To train employees on proper First Aid techniques.

R

Refresher (Y/N)

S&W

R

All employees

Employees designated by site or contractor requirements. Designated individuals must also be trained in Bloodborne Pathogens.

S&W

R

S&W

R

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Initial Only

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S&W Energy Solutions (SWES) EHS Training Matrix Appendix I

Course #

EHS Course Title

Topics

S&W Required (S&W)

Best Practice (BP)

Applicability

Regulatory Required (R)

Any employee who packages, handles, labels, or is involved with transport hazardous materials

R

49CFR172.704(a)

Y

Every 3 years

49CFR172.704(a)

R

49CFR172.704(a)

Y

Every 3 years

49CFR172.704(a)

Y

Annually

40CFR262.16 40CFR265.16 40CFR262.34

Comments

Regulatory Reference

Refresher (Y/N)

Frequency (Yrs)

Refresher Requirement

26

DOT: Hazardous Material Transport TrainingAwareness

Awareness training on the labeling, packaging, & shipping requirements for the transport of hazardous materials

27

DOT: Hazardous Material Transport Training CERTIFICATION

Same as above HOWEVER includes additional information Employee designated to which allows employee to beocme sign hazardous material certified to sign manifests manifests

Hazardous Waste Management

Awareness training on hazardous waste classification, identification, All employees who are storage, manifesting, labelling, associated with managing land ban requirements (RCRA) hazardous waste

R

40CFR262.16 40CFR265.16 40CFR262.34

29

Hazard Communication (HAZCOM)

All employees - training must be given to those employees working in areas where a new Discusses Material Safety Data chemical or material has Sheets (MSDSs), chemical labeling systems, facility specific been introduced, informing chemicals and chemical hazards. of hazards.

R

29CFR1200(h)

Y

Every 2 Years

S&W

30

To inform employees who are likely to discover a hazardous substance release to initiate Hazardous Waste Operations and Emergency appropriate emergency response Response (HAZWOPER) actions by notifying the proper people about the release. All employees Awareness Level

R

29CFR1910.120(q)

Y

Annually

29CFR1910.120(q)

31

HAZWOPER - First Responder Operations Level

To train employees to take defensive actions in responding to All employees except a release of a haz. substance. Admin.

R

Initial - 8 hours mandatory

29CFR1910.120(q)

Y

Annually - 8 hours

29CFR1910.120(q)

32

To train employees to respond to releases for the purpose of stopping the release, including All employees except HAZWOPER-Hazardous Admin. Materials Technician Level taking offensive actions.

R

Intial - 24 hours mandotory

29CFR1910.120(q)

Y

Annually - 8 hours

29CFR1910.120(q)

28

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2/19/2007

S&W Energy Solutions (SWES) EHS Training Matrix Appendix I

Course #

EHS Course Title

Topics

Applicability

Regulatory Required (R)

Any one who has Incident Commander responsibilities as identified in Emergency Response Plan

R

R

33

To inform employees how to respond to hazardous materials spills including taking offensive actions to stop the release and to inform employees of skills & HAZWOPER - On Scene knowledge needed to assume Incident Commander Level control of the incident scene.

34

Hearing Protection

Effects of noise on hearing, purpose of hearing protection, audiometric testing, and explanation of testing procedures

All employees working in areas which may be subject to hearing protection requirements.

Incident Reporting and Investigation

Reporting, recordkeeping, and investigations of EHS Incidents (include OSHA Recordkeeping and Reporting)

All employees

Lead Safety Awareness

Recognition of potential exposures to airborne concentrations of lead. Information to idenitfy and plan for related situations which may necessitate special safety precautions and which may impact All employees who may be cost. affected

R

Medical Records Access

Employers will inform employees of the location and availability of their medical records. All employees

PCB Awareness

To train employees about the presence of PCBs onsite and rules and regulations concerning PCBs.

Permits, Air

To inform employees of their sitespecific air permit limits and All employees engaged in monitoring requirements. Include air permit recordkeeping CEMs information, if applicable and reporting

40

Permits, Wastewater

To inform employees of their sitespecific wastewater permit limits and monitoring requirements. Include stormwater permitting, where applicable.

All employees engaged in wastewater permit recordkeeping and reporting

41

Personal Protective Equipment (PPE)

Identification and proper use of personal protective equipment.

All employees

35

36

37

38

39

All employees who may be affected

S&W Required (S&W)

Best Practice (BP)

Regulatory Reference

Comments

Initial - 24 to 40 hours mandatory 29CFR1910.120(q)

Refresher (Y/N)

Frequency (Yrs)

Refresher Requirement

Y

Annually - 8 hours

29CFR1910.120(q)

29CFR1910.95(k)

Y

Annually

29CFR1910.95(k)

N/A

Y

Every 3 years

S&W

29CFR1910.1025(l)

N

R

29CFR1910.1020 29CFR1926.33

Y

Annually

CFR1910.1020

R

29CFR1910.1200

Y

Every 2 Years

S&W

Y

Every 3 years (or when permits change) S&W

N/A

Y

Every 3 years (or when permits change) S&W

29CFR132(f)

Y

Every 3 years

S&W

Initial Only

S&W

S&W

R

Page 5 of 7

N/A

S&W

2/19/2007

S&W Energy Solutions (SWES) EHS Training Matrix Appendix I

Course #

EHS Course Title

Topics

Applicability

Regulatory Required (R)

S&W Required (S&W)

Best Practice (BP)

Comments

Regulatory Reference

Refresher (Y/N)

Frequency (Yrs)

Refresher Requirement

R

29CFR1910.178

Y

Every 3 years (or when evaluation proves more frequent)

Explain the purpose, proper use and care of the respirator. Discuss the characteristics of the hazardous environment, and the limitations of the respirator. All employees who may Discuss different types and when need to don respirator to use. during work activities.

R

29CFR1910.134(a)

Y

Annually

29CFR1910.134(k)

All employees who may need to don respirator during work activities.

R

29CFR1910.134(e)

Y

Annually

29CFR1910.134(e)

Scaffolds

All employees who work on a scaffold or who erect, Explain requirements on scaffold dismantle, move, operate, types, how to erect and dismantle, repair, maintain, or inspect scaffolds. operate and inspect scaffolds

R

29CFR1910.28 29CFR1926.454

Y

Every 2 Years

S&W

46

Slings & Derricks

Any employee assigned to Recognition of damage and operate/inspect derricks defects in slings and all fastenings (cranes). Employees and attachments. (Couple training assigned to use/inspect with Cranes and Rigging) slings and attachments.

R

29CFR1910.181(b) 29CFR1910.184(d)

Y

Every 2 Years

S&W

47

Spill Prevention Control and Countermeasures (SPCC)

To train employees on the operation and maintenance to prevent the discharges of oil (may All employees except only apply to some Sites) Admin.

R

40CFR110 and 112

Y

Every 3 years or when plan changes 40CFR110 and 112

48

Toxic Substances Control Act (TSCA) Section 8

Employees who work with chemicals must be able to recognize the health and safety effects regarding these chemicals and understand the process of reporting an incident such as an adverse health effect. All employees

R

40 CFR717

Y

Annually

40 CFR717

49

Recognize the hazards relating to ladders and stairs and minimize Walking/Working Surfaces the dangers. All employees

R

29CFR1910.106

Y

Every 2 years

S&W

42

Employees designated to Powered Industrial Trucks Inspection requirements and safe operate and/or inspect (Forklifts) operation of fork trucks. forktrucks

43

Respiratory Protection

44

Respiratory Protection FIT Quantitative or qualitative test to TESTING ensure proper respirator fit.

45

Page 6 of 7

29CFR1910.178

2/19/2007

S&W Energy Solutions (SWES) EHS Training Matrix Appendix I

Course #

50

EHS Course Title

Topics

To inform employees of safe welding, cutting, and brazing Welding, Cutting, & Brazing practices (include Hot Work)

Applicability

Regulatory Required (R)

All employees engaged in welding/brazing operations

R

S&W Required (S&W)

Best Practice (BP)

Comments

Regulatory Reference 29CFR1910.252 29CFR1910.254

Page 7 of 7

Refresher (Y/N)

Y

Frequency (Yrs)

Every 2 years

Refresher Requirement

S&W

2/19/2007

Policy No. EHS-402

EHS Auditing Process Appendix J

S&W Energy EHS Audit Findings Tracking Form AUDIT TYPE

FINDING TYPE / EHS CATEGORY

FINDING DESCRIPTION

CORRECTIVE ACTION

CONTACT NAME / RESPONSIBLE PERSON

FINDING DATE

EXPECTED COMPLETION DATE

STATUS

Policy No. EHS-502 Rev. 2

Control of Hazardous Energy (Lockout/Tagout) Appendix K.1

Index for Lockout / Tagout Control Sheets Control Sheet Date / Time Shift Supervisor Number Hung: Authorizing Description of Work Hanging

Date / Time Cleared:

Shift Supervisor Authorizing Clearing

Policy No. EHS-502 Rev.2

Control of Hazardous Energy (Lockout/Tagout) Appendix K.2

S&W Energy Authorized Personnel List

________________ (Facility / Site Name)

NAME

TITLE

Designated Shift Supervisor or Lead Tech? Y/N

Policy No. EHS-502 Rev.2

Control of Hazardous Energy (Lockout/Tagout) Appendix K.3

ANNUAL LOCK-OUT/TAG-OUT (LOTO) AUDIT FORM Name of Auditor / Inspector: ________________________

Date of Audit: ________________

This Form is meant to be used as a Guide to assist in the Annual Audit of the Facility / Site LOTO Program. The audit should be a review of the topics addressed in each of the questions posed below. Interviews will need to be conducted and records and documentation will need to be reviewed to get proper results. The Audit is required to ensure the proper measures are being implemented to provide a safe and effective LOTO program and to remain in compliance with regulatory standards. Please expand on the questions listed below and attach additional sheets, if necessary (or use back of Form). This Form, and any associated paperwork, shall be signed, dated, and kept on file at the Facility / Site. Any deficiencies or action items resulting from this inspection should be documented and followed-up to implement the proper corrections. 1. Does the Facility / Site have a written Lock-Out / Tag-Out (LOTO) Procedure? • •

Has the Facility / Site implemented and trained Employees on the LOTO Procedure? Y or N Date of Last LOTO Training Given: ______________________________________

2. Has the Facility / Site defined all areas and equipment where LOTO is required (inventory)? • • •

Y or N

Y or N

Has the Facility / Site generated Equipment Specific LOTO Procedures (ESLPs) for “Major Equipment”? Y or N Are these ESLPs written and documented? Y or N Do they meet the requirements as outlined in the Procedure? Y or N

3. Are Employees provided with locks and tags?

Y or N

4. Are all employees trained to recognize equipment or systems which has been locked out and/or tagged out and shall not be operated until the LOTO lifted (random sample of employee interviews)? Y or N 5. Are only trained and authorized employees permitted to Lock and Tag out equipment?

Y or N

6. Is ALL Facility / Site equipment capable of being locked out with the unit completely isolated and completely de-energized? Y or N Please indicate those pieces of equipment or systems which are not capable of being locked out and provide reasons why they are not. _____________________________________________________________________ _____________________________________________________________________ _____________________________________________________________________ _____________________________________________________________________ 7. Does the LOTO procedure address verification of de-energized equipment?

Y or N

8. Does the LOTO procedure address shift change?

Y or N

9. Does the LOTO procedure address Contractors?

Y or N

10. Randomly review open and closed LOTO’s to determine if correct paperwork is being filed and that the LOTO’s are being performed and closed according to the Procedure. Specifically identify any deficiencies. Use additional sheets or back of this form, as necessary.

ATTACHMENT EHS-502 Rev 2 K.4 - LOCKOUT / TAGOUT CONTROL SHEET DATE AND TIME SHEET OPENED

DATE AND TIME CLOSED

NUMBER

PAGE

OF

_

_ EQUIPMENT DESCRIPTION: __________________________

_____________________________________________________________________________

WORK SCOPE FOR LOCKOUT/DANGER TAGOUT AND WORK TO BE COMPLETED PRIOR TO RELEASE: _____________________________________________________________________________________________________________________________________________ REFERENCES, DRAWINGS USED FOR LOCKOUT/TAGOUT PREPARATION. ______________________________________________________________________________________________________________________________________________

LOTO Requested By:

LOCK # / TAG LETTER

LOTO Authorized By:

NAME AND NUMBER OF Energy Isolating Device (DESCRIPTION)

Lock / Tag Hung By: Initials / Date

LOTO Position

Lock / Tag Removed By: Initials / Date

Cleared Position

/ / / / / / / / / / / / / / Test Release Authorization: Date/Time ____________ OVER PLEASE...

Authorized By _______________________ Authorized Employee _______________

Title

Date & Time

Sign On

Date & Time

Sign Off

Shift Supervisor Authorized Employee /Contractor Authorized Employee/Contractor Authorized/ Employee /Contractor Authorized Employee /Contractor Authorized Employee /Contractor Authorized Employee /Contractor Authorized Employee /Contractor Authorized Employee /Contractor Authorized Employee /Contractor Authorized Employee /Contractor Authorized Employee /Contractor

LOTO Clearance Authorized By _________________________________________

Date/Time _____________________________

Each Authorized Employee must sign on & sign off to work under this control sheet. By signing on the tagout, the Authorized Employee indicates he has walked down the system and has initialed all the tags on the tagout. Locks & Tags cannot be removed until all Authorized Employee(s) and the Shift Supervisor have signed off. Maintenance requiring more than one Authorized Employee will require each employee to sign on and off at the beginning and the end of the job. The Authorized Employee in charge of the job must be indicated next to the sign-on. TRANSFER OF AUTHORIZED EMPLOYEE IN CHARGE When one Authorized Employee in charge starts a job and another Authorized Employee in charge will finish the job, the responsibility as the Authorized Employee in-charge must be transferred by signing below. During extended maintenance shutdowns where the job may take several days, the authorized employees in charge for each shift may sign on and write their shift time by their signature, then once the job is completed they sign off.

Sign-On

Sign-Off

Sign-On

Sign-Off

_____________________________

_____________________________

__________________________

___________________________

_____________________________

____________________________

__________________________

____________________________

____________________________

____________________________

___________________________ ____________________________

Policy No. EHS-503

Personal Protective Equipment Appendix L.1

S&W Energy Personal Protective Equipment Inventory Facility:

Date:

Page

Of

INSTRUCTIONS: Complete the Personal Protective Equipment (PPE) Inventory for each article of PPE currently used at the Facility. Under the PPE type, enter the manufacturer, model and style of PPE available. Enter the PPE in order by the affected body part, such as eye and face, hand, head, foot, body, respiratory, and hearing. Provide a hazard description for each article of PPE and assign a Part # for reference. PPE Type Example: Lab Safety, Neoprene Gloves, black

Body Part

Hazard Description

Hand

Chemical Burns

Part # XX-YY

Quantity Available 4 pair

Policy No. EHS-503

Personal Protective Equipment Appendix L.2

S&W Energy Job Hazard Assessment Form Job Title: Analysis By: Title: Review By: Title: New Facility Manager: Revised Required and/or Recommended PPE: Sequence of Basic Job Steps

Page

Of

Date: Date: Approved By:

Date Approved:

Potential Hazards

Recommended Action / Procedure

Annual Review: Reviewer / Date: _______________ Reviewer / Date: _______________ Reviewer / Date: _______________ Reviewer / Date: _______________ Reviewer / Date: _______________ Reviewer / Date: _______________

Page 1

Policy No. EHS-504

Respiratory Protection Appendix M.1

S&W Energy Respirator Specification Form Facility:

Employee’s Name:

Date:

Job Description:

Contaminant Estimated or Actual Contaminant(s):

Concentration Level:

Nature of Contaminant: Gas, Vapor, or Particulate (circle one)

Warning Properties:

If a gas or vapor, is there any absorbent that traps it?

Yes

No

Explain:

Could Contaminant(s) become IDLH?

Yes

No

Explain:

If flammable, does concentration approach LEL?

Yes

No

Explain:

Is contaminant(s) an eye irritant?

Yes

No

Explain:

Can contaminant(s) be absorbed through the skin?

Yes

No

Explain:

OSHA Permissible Exposure Level, ACGIH TLV or NIOSH REL:

Respirator

Recommended Respiratory Protection First Choice: Make: Second Choice: Make: Characteristics of respirator:

Model #:

Type:

Model #:

Type:

Limitations of respirator: NIOSH Approval Numbers:

Respirator Identification:

Page 1

3

(ppm or mg/m )

(i.e. odor)

Policy No. EHS-504

Respiratory Protection Appendix M.2

GUIDANCE ON DEVELOPMENT OF CARTRIDGE CHANGE-OUT SCHEDULES – Page 1 OSHA regulation 29 CFR 1910.134 no longer allows a contaminant’s warning properties (smell, taste, or irritation) to be used to determine cartridge breakthrough. The user must have a respirator equipped with a NIOSH approved end-of-service-life indicator (ESLI) for the specific contaminant or must use a cartridge change-out schedule for the specific cartridge and contaminant. Currently, there are limited cartridges equipped with an ESLI. Therefore, at this time a cartridge change-out schedule is the only viable option for those cartridges that will be used. This document is intended to provide guidance in establishing their specific change-out schedules. This guidance is only a starting point for developing such a program. Each site’s program will be different due to individual site characteristics that must be included in any change-out schedule determinations. Manufacturer Consultation The best course of action in establishing a cartridge change-out schedule is to consult the manufacturer of the cartridge. The following information has been obtained for commonly used safety product providers. Company North Safety Products 3M –Occupational Health and Environmental Safety Products MSA Safety Products

Web Site http://www.safetyonline.net/north/ http://www.mmm.com/market/safety/ohes2/index. html http://www.msanet.com/safetyproducts/index.html

Phone Number 1-800-430-4110 1-800-896-4223 1-800-MSA-2222

The following information is provided to assist you in understanding the various issues surrounding the establishment of a cartridge change-out schedule, to provide recommendations for establishing a change-out program and to provide resources for obtaining further detailed information. Precautions When Using Data to Establish Your Change Schedule The following is a partial list of factors which may affect the usable cartridge service life and/or the degree of respiratory protection attainable under actual workplace conditions. These factors should be considered when developing a cartridge change-out schedule. • • • • • • •

• •





• • • • • •

Type of contaminant(s) Contaminant concentration Relative humidity Breathing rate Temperature Changes in contaminant concentration, humidity, breathing rate and temperature Mixtures of contaminants: (1) multiple contaminants present simultaneously versus (2) alternate usage of the same cartridges against different contaminants on different occasions Accuracy in the determination of the conditions The contaminant concentration in the workplace can vary greatly. Consideration must be given to the quality of the estimate of the workplace concentration. Cartridge storage conditions (exposure to trace levels of contaminants and humidity and elevated temperatures) Storage conditions between multiple uses of the same respirator cartridges. It is recommended that the chemical cartridges be replaced after each work shift. Contaminants adsorbed on a cartridge can migrate through the carbon bed without airflow. Desorption of the contaminant (including those with poor warning properties) after partial use of the chemical cartridge can occur after a short period (hours) without use (e.g., overnight) and result in a non-use exposure to someone nearby. Age of the cartridge Condition of the cartridge and respirator Respirator and cartridge selection Respirator fit Respirator assembly, operation, and maintenance User training, experience and medical fitness Page 1

Policy No. EHS-504

Respiratory Protection Appendix M.2

GUIDANCE ON DEVELOPMENT OF CARTRIDGE CHANGE-OUT SCHEDULES – Page 2 • •





Warning properties of the contaminant The quality of the warning properties should be considered when establishing the chemical cartridge change schedule. Good warning properties may provide a secondary or back-up indication for cartridge change-out. Change schedules for contaminants with poor warning properties may require a greater safety factor than a contaminant with good warning properties. Other conditions specific to the particular user and/or workplace

Information excerpted from MSA’s Cartridge Change Test Program available on the Internet at http://www.msanet.com/safetyproducts/resptest/index.html Non-Organic Vapor Contaminants Both MSA and North Safety Products have performed end of service life estimations for non-organic vapor contaminants. Test data indicating recommended change out schedules for these cartridges can be found at http://www.msanet.com/safetyproducts/resptest/dataindex.stm – the MSA Respirator Test Data Index and at http://SafetyOnline.net/north/feature1.htm – on the North Safety Products esLife EZ Service Life Estimation Table. Organic Vapor Contaminants For organic vapor contaminants that have a boiling point of less than 149°F (65°C), the user must change cartridges no less frequently than at the end of each work shift, even if a service life estimate would permit less frequent cartridge changes. Organic vapors with this characteristic may desorb from the charcoal in the cartridge when not in use overnight. This leaves high concentrations of contaminant in the cartridge housing free to move into the respirator mask when use is resumed, exposing the user to the contaminant and the risk of serious injury or illness. Poor Warning Properties If a change-out schedule is developed for use against a organic vapor contaminant with poor warning properties (i.e. smell, taste, or irritation or above the permissible exposure limit), the user loses the ability to determine if the change-out schedule is adequate and the respirator is functioning properly because the user will not be able to detect breakthrough. For this reason, it is not recommended to use air-purifying respirators for such contaminants even though OSHA does not prohibit the use of air purifying respirators for protection against contaminants having poor warning properties. For protection against contaminants having poor warning properties, a supplied air respirator should be used. Information excerpted from the North Safety Products esLife Service Life Estimation CD-ROM website located on the Internet at http://SafetyOnline.net/north/feature1.htm Existing Warning Properties For organic vapor contaminants that have warning properties (smell, taste, irritation etc.), OSHA recommends following these rules of thumb for establishing a change-out schedule for organic vapor cartridges: •

If a chemical’s boiling point is greater than 70°C and the concentration is less than 200 ppm you can expect a service life of 8 hours at a normal work rate.



Service life is inversely proportional to work rate.



Reducing concentration by a factor of ten will increase service life by a factor of five.



Humidity above 85% will reduce service life by 50%.

Note: These generalizations should only be used with another method of predicting service life for specific contaminants.

Information excerpted from Appendix A of OSHA Directive CPL 2-0.120 - Inspection procedures for the Respiratory Protection Standard. This document can be found on the Internet at http://www.oshaslc.gov/OshDoc/Directive_toc/toc_for_CPL.html.

Page 2

Policy No. EHS-504

Respiratory Protection Appendix M.2

GUIDANCE ON DEVELOPMENT OF CARTRIDGE CHANGE-OUT SCHEDULES – Page 3 Particulate Contaminants The new 42 CFR Part 84 regulation provides for nine classes of filters (three levels of filter efficiency, each with three categories of resistance to filter efficiency degradation). The three levels of filter efficiency are 95%, 99%, and 99.97%. The three categories of resistance to filter efficiency degradation are labeled N, R, and P. The class of filter will be clearly marked on the filter, filter package, or respirator box. For example, a filter marked N95 would mean an N-series filter that is at least 95% efficient. Chemical cartridges that include particulate filter elements will carry a similar marking that pertains only to the particulate filter element. The new classes of non-powered particulate respirators require new decision logic for selection of the proper respirator. The selection process for using the new particulate classification is summarized as follows: 1. The selection of N-, R-, and P-series filters depends on the presence or absence of oil particles, as follows: •

If no oil particles are present in the work environment, use a filter of any series (i.e., N-, R-, or P-series).



If oil particles (e.g., lubricants, cutting fluids, glycerin, etc.) are present, use an R- or P-series filter. Note: Nseries filters cannot be used if oil particles are present.



If oil particles are present and the filter is to be used for more than one work shift, use only a P-series filter.

2. Selection of filter efficiency (i.e., 95%, 99%, or 99.97%) depends on how much filter leakage can be accepted. Higher filter efficiency means lower filter leakage. 3. The choice of face piece depends on the level of protection needed--that is, the assigned protection factor (APF) needed. Note: To help you remember the filter series, use the following guide: N for Not resistant to oil, R for Resistant to oil, P for oil Proof Use Limitations of Particulate Respirators The service life of all three categories of filters efficiency degradation (i.e., N-, R-, and P-series) is limited by considerations of hygiene, damage, and breathing resistance. All filters should be replaced whenever they are damaged, soiled, or causing noticeably increased breathing resistance (e.g., causing discomfort to the wearer). R- or P-series filters can be used for protection against oil or non-oil aerosols. N-series filters should be used only for non-oil aerosols. Use and reuse of the P-series filters would be subject only to considerations of hygiene, damage, and increased breathing resistance. Generally, the use and reuse of N-series filters would also be subject only to considerations of hygiene, damage, and increased breathing resistance. However, for dirty workplaces that could result in high filter loading (i.e. 200 mg), service time for N-series filters should be extended beyond 8 hours of use (continuous or intermittent) by performing an evaluation in specific workplace settings that: (a) demonstrates extended use will not degrade the filter efficiency below the efficiency level specified in Part 84, or (b) demonstrates the total mass loading of the filter(s) is less than 200mg. The R-series filters should be used only for a single shift (or for 8 hours of continuous or intermittent use) when oil is present. However, service time for the R-series filters can be extended using the same two methods described above for N-series filters. These determinations would need to be repeated whenever conditions change or modifications are made to processes that could change the type of particulate generated in the user's facility. A list of Particulate Respirators Certified Under 42 CFR Part 84 is available on the Internet at http://www.cdc.gov/niosh/p84intro.html Information was excerpted from the NIOSH Guide to the Selection and Use of Particulate Respirators Certified Under 42 CFR 84, DHHS (NIOSH) Publication No. 96-101, January 1996 that can be found on the Internet at http://www.cdc.gov/niosh/userguid.html.

Page 3

Policy No. EHS-504

Respiratory Protection Appendix M.3

RESPIRATOR CARTRIDGE SELECTION CHART

Color-coding identifies cartridges manufactured for each type of contaminant. The following chart is provided to aid in selecting the proper cartridge.

A T M O S P H E R IC C O N T A M IN A N T C O L O R A S S IG N E D W h ite A cid G as Y ello w A cid G as & O rg an ic V apo r G reen A m m on ia G as O ra n ge D ust, F um es & M ists (O th er th a n ra d io ac tiv e m a teria ls) B la ck O rg an ic V ap o rs (E x ce p t tritiu m & N o b le g a ses ) O liv e O th er V ap o rs & G ases n o t listed ab o v e References: Information for this chart is taken from ANSI K13.1-1973, Identification of Air Purifying Respirator Canisters and Cartridges. Note:

1. A purple stripe shall be used to identify radioactive materials in combination with any vapor or gas. 2.

An orange stripe shall be used to identify dust, fumes, and mists in combination with any vapor or gas.

3.

Where labels only are colored to conform to this table, the canister or cartridge body shall be grey or a metal canister body may be left in its natural metallic color.

The user shall refer to the wording of the label to determine the type and degree of protection the canister or cartridge will afford.

Page 1

Policy No. EHS-504

Respiratory Protection Appendix M.4

OSHA Respirator Medical Evaluation Questionnaire CFR 1910.134- Appendix C The Occupational Safety and Health Administration requires the use of the following questionnaire initially as part of our respiratory protection program. Please complete the form and return it to the physician and / or health care provider utilized by your Facility. Lung tests and physical exams are only required currently if deemed necessary by the physician or licensed health care provider after reviewing your answers. You will have the opportunity to discuss your responses with the health care provider if you chose or have a physical examination if deemed necessary, and then be given a copy of a written opinion. You may also request a copy of the questionnaire and exam. If you have any questions about this form or related to your ability to wear a respirator, please ask your physician or health care provider. To the employer: Answers to questions in Section 1, and to question 9 in Section 2 of Part A, do not require a medical examination. To the employee: Can you read (circle one): Yes / No Your employer must allow you to answer this questionnaire during normal working hours, or at a time and place that is convenient to you. To maintain your confidentiality, your employer or supervisor must not look at or review your answers, and your employer must tell you how to deliver or send this questionnaire to the health care professional who will review it. Part A. Section 1. (Mandatory) The following information must be provided by every employee who has been selected to use any type of respirator (please print). NAME:____________________________________DATE:_______________________________ AGE:_______ SEX:_______

HEIGHT: __________ft. _________in. WEIGHT_________lb.

JOB HELD/APPLIED FOR:________________________________SS#____________________ 1. 2.

A phone number where you can be reached by the health care professional who reviews this questionnaire: ( ) _____ - ____ The best time to call you at this number:__________________________

3.

Has your employer told you how to contact the health care professional who will review this questionnaire: YES / NO (see top of page instructions)

4.

Check the type of respirator you will use (you can check more than one category): a._______ N,R, or P disposable respirator (filter-mask, non-cartridge type only). b._______

5.

Other type (half or full-face piece type, powered-air purifying, supplied-air, self-contained breathing apparatus).

Have you worn a respirator: Yes/No If “yes” what type(s):

If you have answered this questionnaire in the past, please answer the questions in this box. If you check yes on any of these questions, then answer all the questions on the next 2 pages. If you answer no to the questions in this box STOP, skip to the 3rd page and sign your name at the bottom. No further exam is needed. 1) Do you have any medical concerns or problems wearing a respirator? Yes____ No ____ 2) Were you sent to be evaluated because someone else thought you were having problems or you failed your “fit” test because of a possible health problem? Yes____ No____ 3) Have there been any significant changes in what you do, such as: a) increased physical effort, b) increased temperature in your work area, or c) increased use of personal protective clothing? Have these changes caused you any problems when wearing your respirator? Yes____ No____

Page 1

Policy No. EHS-504

Respiratory Protection Appendix M.4

OSHA Respirator Medical Evaluation Questionnaire Part A. Section 2. (Mandatory) Questions 1 through 9 below must be answered by every employee who has been selected to use any type of respirator. 1.

Do you currently smoke tobacco, or have you smoked tobacco in the last month: YES/NO

2.

Please place a check before any conditions you have ever had : a._____ Seizures (fits) b._____ Diabetes (sugar disease) c._____ Allergic reactions that interfere with your breathing d._____ Claustrophobia (fear of closed-in places) e._____ Trouble smelling odors

3.

Have you ever had any of the following pulmonary or lung problems? a._____ Asbestosis g.______ Silicosis b._____ Asthma h.______ Pheumothorax (collapsed lung) c._____ Chronic bronchitis i.______ Lung cancer d._____ Emphysema j.______ Broken ribs e._____ Pneumonia k.______ Any chest injuries or surgeries f.______ Tuberculosis l.______ Any other lung problem that you’ve been told about

4.

Do you currently have any of the following symptoms of pulmonary or lung illness? a._____ Shortness of breath b._____ Shortness of breath when walking fast on level ground or walking up a slight hill or incline c._____ Shortness of breath when walking with other people at an ordinary pace on level ground d._____ Have to stop for breath when walking at your own pace on level ground e._____ Shortness of breath when washing or dressing yourself f._____ Shortness of breath that interferes with your job g._____ Coughing that produces phlegm (thick sputum) h._____ Coughing that wakes you early in the morning i._____ Coughing that occurs mostly when you are lying down j._____ Coughing up blood in the last month k._____ Wheezing l._____ Wheezing that interferes with your job m._____ Chest pain when you breathe deeply n._____ Any other symptoms that you think may be related to lung problems

5.

Have you ever had any of the following cardiovascular or heart problems? a._____ Heart attack e._____ Swelling in your legs or feet (not caused by walking) b._____ Stroke f._____ Heart arrhythmia (irregular heart beat) c._____ Angina g._____ High blood pressure d._____ Heart failure h._____ Any other heart problems that you’ve been told about

6.

Have you ever had any of the following cardiovascular or heart symptoms? a._____ Frequent pain or tightness in your chest b._____ Pain or tightness in your chest during physical activity c._____ Pain or tightness in your chest that interferes with your job d._____ In the past two years, have you noticed your heart skipping/missing a beat e._____ Heartburn or indigestion that is not related to eating f._____ Any other symptom that you think may be related to heart or circulation problems

7.

Do you currently take medication for any of the following problems? a._____ Breathing or lung problems

b._____ c._____ d._____

Heart trouble Blood pressure Seizures

Page 2

Policy No. EHS-504

Respiratory Protection Appendix M.4

OSHA Respirator Medical Evaluation Questionnaire 8.

If you’ve used a respirator, have you ever had any of the following problems? a._____ Eye irritation b._____ Skin allergies or rashes c._____ Anxiety d._____ General weakness or fatigue e._____ Any other problem that interferes with your use of a respirator

9.

Would you like to talk to the health care professional who will review this questionnaire about your answers to this questionnaire? YES/NO

A “Yes” answer to any question, 1-8, in Section 2 will require a follow-up examination. ______________________________________________________________________________________________________ _____

Questions 10 to 15 below must be answered by every employee who has been selected to use either a full-face piece respirator or a self-contained breathing apparatus (SCBA). For employees who have been selected to use other types of respirators, answering these questions is voluntary. Everyone is requested to sign the form at the bottom. 10.

Have you ever lost vision in either eye (temporarily or permanently): YES / NO

11.

Do you currently have any of the following vision problems? a._____ Wear contact lenses c._____ b._____ Wear glasses d._____

Color blind Any other eye or vision problem

12.

Have you ever had an injury to your ears, including a broken eardrum? YES / NO

13.

Do you currently have any of the following hearing problems? a._____ Difficulty hearing b._____ Wear a hearing aid c._____ Any other hearing or ear problems

14.

Have you ever had a back injury? YES/NO

15.

Do you currently have any of the following musculoskeletal problems? a._____ Weakness in any of your arms, hands, legs, or feet b._____ Back pain c._____ Difficulty fully moving you arms and legs d._____ Pain or stiffness when you lean forward or backward at the waist e._____ Difficulty fully moving your head up or down f._____ Difficulty fully moving head side to side g._____ Difficulty bending at your knees h._____ Difficulty squatting to the ground i._____ Climbing a flight of stairs or a ladder carrying more than 25 lbs. j._____ Any other muscle or skeletal problem that interferes with using a respirator

Employee Signature:__________________________

Date:_____________

Examiners Signature:_________________________

Date:_____________

Examiner or designated representative- For subsequent years, after initial qualification to wear a respirator using this questionnaire; the employee does not need a medical evaluation if the ‘boxed’ questions on page 1 are all answered (no). If this is the case, please indicate below with an X: _______ This employee does not need further medical evaluation at this time. Fit testing is authorized, if indicated.

Page 3

Policy No. EHS-504

Respiratory Protection Appendix M.5

Fit Test Protocol General Fit-Testing Requirements 1.

The following criteria shall be used to help determine the adequacy of the respirator fit: Chin properly placed; Adequate strap tension, not overly tightened; Fit across nose bridge; Respirator of proper size to span distance from nose to chin; Tendency of respirator to slip; Self-observation in mirror to evaluate fit and respirator position.

2.

The employee shall conduct a user seal check, either the negative and positive pressure seal checks. Before conducting the negative and positive pressure checks, the subject shall be told to seat the mask on the face by moving the head from side-to-side and up and down slowly while taking in a few slow deep breaths. Another face piece shall be selected and retested if the employee fails the user seal check tests.

3.

The test shall not be conducted if there is any hair growth between the skin and the face piece-sealing surface, such as stubble beard growth, beard, mustache or sideburns which cross the respirator-sealing surface. Any type of apparel which interferes with a satisfactory fit shall be altered or removed.

4.

If a employee exhibits difficulty in breathing during the tests, she or he shall be referred to a physician or other licensed health care professional, as appropriate, to determine whether the employee can wear a respirator while performing her or his duties.

5.

If the employee finds the fit of the respirator unacceptable, the employee shall be given the opportunity to select a different respirator and to be retested.

6.

Exercise regimen. Prior to the commencement of the fit test, the employee shall be given a description of the fit test and the employee's responsibilities during the test procedure. The description of the process shall include a description of the test exercises that the subject will be performing. The respirator to be tested shall be worn for at least 5 minutes before the start of the fit test.

7.

The fit test shall be performed while the employee is wearing any applicable safety equipment that may be worn during actual respirator use which could interfere with respirator fit.

8.

The following test exercises are to be performed for all fit testing. The employee shall perform exercises, in the test environment, in the following manner:

Normal breathing. In a normal standing position, without talking, the subject shall breathe normally. Deep breathing. In a normal standing position, the subject shall breathe slowly and deeply, taking caution so as not to hyperventilate.

Page 1

Policy No. EHS-504

Respiratory Protection Appendix M.5

Fit Test Protocol Turning head side to side. Standing in place, the subject shall slowly turn his/her head from side to side between the extreme positions on each side. The head shall be held at each extreme momentarily so the subject can inhale at each side. Moving head up and down. Standing in place, the subject shall slowly move his/her head up and down. The subject shall be instructed to inhale in the up position (i.e., when looking toward the ceiling). Talking. The subject shall talk out loud slowly and loud enough so as to be heard clearly by the test conductor. The subject can read from a prepared text such as the Rainbow Passage (see below), count backward from 100, or recite a memorized poem or song Bending over. The employee shall bend at the waist as if he/she were to touch his/her toes. Normal breathing. Same as exercise (1). 9.

Each test exercise shall be performed for one minute except for the grimace exercise which shall be performed for 15 seconds. The employee shall be questioned by the test conductor regarding the comfort of the respirator upon completion of the protocol. If it has become unacceptable, another model of respirator shall be tried. The respirator shall not be adjusted once the fit test exercises begin. Any adjustment voids the test, and the fit test must be repeated.

Isoamyl Acetate (IAA) Qualitative Fit Test (QLFT) Protocol NOTE: This protocol is not appropriate to use for the fit testing of particulate respirators. If used to fit test particulate respirators, the respirator must be equipped with an organic vapor filter. 1.

The fit test chamber shall be a clear 55-gallon drum liner suspended inverted over a 2-foot diameter frame so that the top of the chamber is about 6 inches above the employee's head. If no drum liner is available, a similar chamber shall be constructed using plastic sheeting. The inside top center of the chamber shall have a small hook attached.

2.

Each respirator used for the fitting and fit testing shall be equipped with organic vapor cartridges or offer protection against organic vapors.

3.

After selecting, donning, and properly adjusting a respirator, the employee shall wear it to the fit testing room. This room shall be separate from the room used for odor threshold screening and respirator selection, and shall be well ventilated, as by an exhaust fan or lab hood, to prevent general room contamination.

4.

A copy of the test exercises and any prepared text from which the subject is to read shall be taped to the inside of the test chamber.

5.

Upon entering the test chamber, the employee shall be given a 6-inch by 5-inch piece of paper towel, or other porous, absorbent, single-ply material, folded in half and wetted with 0.75 ml of pure IAA. The employee shall hang the wet towel on the hook at the top of the chamber. An IAA test swab or ampule may be substituted for the IAA wetted paper towel provided it has been demonstrated that the alternative IAA source will generate an IAA test atmosphere with a concentration equivalent to that generated by the paper towel method.

Page 2

Policy No. EHS-504

Respiratory Protection Appendix M.5

Fit Test Protocol 6.

Allow two minutes for the IAA test concentration to stabilize before starting the fit test exercises. This would be an appropriate time to talk with the employee; to explain the fit test, the importance of his/her cooperation, and the purpose for the test exercises; or to demonstrate some of the exercises.

7.

If at any time during the test, the subject detects the banana-like odor of IAA, the test is failed. The subject shall quickly exit from the test chamber and leave the test area to avoid olfactory fatigue.

8.

If the test is failed, the subject shall return to the selection room and remove the respirator. The employee shall repeat the odor sensitivity test, select and put on another respirator, return to the test area and again begin the fit test procedure described in steps 1 through 7 above. The process continues until a respirator that fits well has been found. Should the odor sensitivity test be failed, the subject shall wait at least 5 minutes before re-testing. Odor sensitivity will usually have returned by this time.

9.

If the subject passes the test, the efficiency of the test procedure shall be demonstrated by having the subject break the respirator face seal and take a breath before exiting the chamber.

10. When the employee leaves the chamber, the subject shall remove the saturated towel and return it to the person conducting the test, so that there is no significant IAA concentration buildup in the chamber during subsequent tests. The used towels shall be kept in a self-sealing plastic bag to keep the test area from being contaminated.

Page 3

Policy No. EHS-504

Respiratory Protection Appendix M.6

Respirator Fit Test Documentation Form Name of Employee Tested:_______________________________ Date:____________________________ Expiration Date: _____________________________________

Type of Fit Test: (check one) Qualitative

Quantitative

Isoamyl Acetate Test used?

Yes

No

Fit Factor and Strip Chart Recording Attached?

Yes

No

Smoke Irritant Test used?

Yes

No

Other recordings of the test?

Yes

No

Respirator Information: Make: _______________________________ Model: _____________________________________________ Style: _______________________________ Size: _______________________________________________ Results:

Pass

Fail

Retain this record until the next fit test is administered (annually if not sooner). cc: Employees training record

Page 1

Policy No. EHS-504

Respiratory Protection Appendix M.7

Respirator Cleaning and Disinfection Procedure 1.

Remove filters, cartridges, or canisters.

2.

Disassemble face pieces by removing speaking diaphragms, demand and pressure-demand valve assemblies, hoses, or any components recommended by the manufacturer. Discard or repair any defective parts.

3.

Wash components in warm (110 deg. F [43 deg. C] maximum) water with a mild detergent or with a cleaner recommended by the manufacturer. A stiff bristle (not wire) brush may be used to facilitate the removal of dirt.

4.

Rinse components thoroughly in clean, warm (110 deg. F [43 deg. C] maximum), preferably running water. Drain.

5.

When the cleaner used does not contain a disinfecting agent, respirator components should be immersed for two minutes in one of the following: a.

Hypochlorite solution (50 ppm of chlorine) made by adding approximately one milliliter of laundry bleach to one liter of water at 110 deg. F [43 deg. C] or,

b.

Aqueous solution of iodine (50 ppm iodine) made by adding approximately 0.8 milliliters of tincture of iodine (68 grams ammonium and/or potassium iodide/100 cc of 45% alcohol) to one liter of water at 110 deg. F [43 deg. C] or,

c.

Other commercially available cleansers of equivalent disinfectant quality when used as directed, if their use is recommended or approved by the respirator manufacturer.

6.

Rinse components thoroughly in clean, warm (110 deg. F [43 deg. C] maximum), preferably running water. Drain. The importance of thorough rinsing cannot be overemphasized. Detergents or disinfectants that dry on face pieces may result in dermatitis. In addition, some disinfectants may cause deterioration of rubber or corrosion of metal parts if not completely removed.

7.

Components should be hand-dried with a clean lint-free cloth or air-dried.

8.

Reassemble face piece, replacing filters, cartridges, and canisters where necessary.

9.

Test the respirator to ensure that all components work properly.

Page 1

Policy No. EHS-504

Respiratory Protection Appendix M.8

SCBA Inspection Inspect Monthly & After Each Use SCBA Location: Date:

Unit / ID # Inspected by: Sat / Unsat

Functional check of SCBA

Corrective Action

Inspector Initials

Alarm Works Properly Regulator Functions Properly Facepiece: Clean, not distorted, no tears, no cracks Elastic Parts: Pliable no deterioration Head Harness: Clean, no tears, no cracks no missing pieces. No loss of elasticity. No wear from buckle. Lens: Clean & Clear, no cracks, sealed to mask Exhalation Valve: Clean, good seal, no tears, tight Inhalation Valve: Clean, good seal, no tears, tight Cylinder: No dents or gouges, fits tightly in band

Cylinder Hydro Test Date _______________ Gage: Cylinder >90% full, check gage face, indicator Harness: Clean, no wear, fully extended Demand Valve O-ring: clean, no tears, seated properly SCBA Cleaned and reassembled after inspection & drying

If any defects are found DO NOT USE RESPIRATOR. Turn in the respirator to your supervisor immediately for repair or replacement.

Page 1

Policy No. EHS-505

Hearing Protection and Conservation Appendix N.1

AREA / PERSONAL NOISE MONITORING RESULTS DATE / TIME OF TEST: COMMENTS / ADDITIONAL FACTORS:

AREAS WITH NOISE LEVELS EXCEEDING 85 dBA: AREA

NOISE LEVEL

RETAIN RECORDS INDEFINITELY (This form can be used for area and/or personal noise monitoring survey results. In all cases, please provide additional information, i.e., area or personal, TWA’s, etc., as applicable.)

Page 1

Policy No. EHS-504

Hearing Protection and Conservation Appendix N.2

S&W Energy Hearing Protection and Conservation Program Auditing Checklist

REQUIREMENT

YES

Are feasible engineering and/or administrative controls considered for implementation or utilized to keep noise exposures within allowable limits? Where sound levels exceed an 8-hour exposure of 85 dBAs, is a continuing effective hearing conservation program administered? (This procedure includes all elements of required hearing conservation program) Does S&W Energy make hearing protection available to all employees exposed to an 8-hour TWA of 85 decibels or greater? Are noise levels measured using a sound level meter (for area surveys) or a noise dosimeter (for personal surveys) and are records of these levels being recorded and maintained on file? Where engineering controls are not feasible, are administrative controls (i.e., worker rotation) being considered for implementation or used to minimize individual employee exposure to noise? Is there an on-going program to educate and train employees in safe levels of noise and exposure, effects of noise on their health, and use of personal protection? Is approved hearing protective equipment (noise attenuating devices) available to every employee working in noisy areas? Are the attenuating devices appropriate for the areas (properly rated equipment used)? If you use ear protectors, are employees properly fitted and instructed in their use? Are employees in high noise areas given periodic (annual) audiometric testing to ensure that S&W Energy has an effective hearing protection system?

Page 1

NO

ACTION REQUIRED / COMMENTS

Policy No. EHS-509

Fall Protection Appendix O.1

S&W Energy Fall Hazard Assessment / Inventory Location

Reason(s) for Access

Fall Hazard Work at Unprotected Heights at or Exceeding 4 Feet Ladders Lifts Wall or Floor Openings Railcars and Vehicles Other: ____________________________________ Work at Unprotected Heights at or Exceeding 4 Feet Ladders Lifts Wall or Floor Openings Railcars and Vehicles Other: ____________________________________ Work at Unprotected Heights at or Exceeding 4 Feet Ladders Lifts Wall or Floor Openings Railcars and Vehicles Other: ____________________________________ Work at Unprotected Heights at or Exceeding 4 Feet Ladders Lifts Wall or Floor Openings Railcars and Vehicles Other: ____________________________________ Work at Unprotected Heights at or Exceeding 4 Feet Ladders Lifts Wall or Floor Openings Railcars and Vehicles Other: ____________________________________ Work at Unprotected Heights at or Exceeding 4 Feet Ladders Lifts Wall or Floor Openings Railcars and Vehicles Other: ____________________________________

Facility:

Location:

Contact:

Date of Evaluation:

Page 1

Policy No. EHS-509

Fall Protection Appendix O.2

Fall Protection Evaluation Form Location of Fall Hazard: Reason For Work / Task:

Description of Fall Hazard: Work at Unprotected Heights Exceeding 4 Feet Wall or Floor Openings

Ladders Lifts

Railcars / Vehicles Other: ______________________________________________________________________ Fall Protection Equipment Category: Fall Arrest Positioning Suspension Retrieval Other: ______________________________________________________________________ Equipment Required:

Type

Equipment Location

Inspection Frequency

Location of Anchor Point: Description of Use Procedures:

Maintenance and Storage of Equipment:

Limitations and Precautions:

Facility:

Location:

Contact:

Date of Evaluation:

Page 1

Policy No. EHS-510

Powered Industrial Trucks Appendix P.1

INDUSTRIAL TRUCK DESIGNATIONS

Designation / Classification

Description D DS

DY

E ES

EE

EX

G GS

LP LPS

Similar to G classification but are Diesel engine powered instead of Gasoline engine powered. Diesel powered and provided with additional safeguards to the exhaust, fuel, and electrical systems. (May be used in some locations where a D-unit may not be suitable). Diesel powered that have all the safeguards of the DS classification and in addition do not have any electrical equipment (including ignition) and equipped with temperature limitation features. Electrically powered having minimum acceptable safeguards against inherent fire hazards. Electrically powered, including all safeguards as the E classification with additional safeguards to the electrical system to prevent emission of hazardous sparks and to limit surface temperatures. (May be used in some locations where an E-unit may not be suitable). Electrically powered, including all safeguards as an E and ES classification, where the electric motor and all other electrical equipment is completely enclosed. (May be used in some locations where an E- or ES-unit may not be suitable). Electrically powered, different from the E, ES, and EE classifications in that the electrical fittings and equipment are so designed that the units may be used in certain atmospheres containing flammable vapors or dust. Gasoline powered having minimum acceptable safeguards against inherent fire hazards. Gasoline powered, including all safeguards as the G classification with additional safeguards to the exhaust, fuel, and electrical systems. (May be used in some locations where a G-unit may not be suitable). Similar to the G unit, only Liquefied Petroleum Gas (LPG) is used as fuel instead of Gasoline Liquefied Petroleum Gas (LPG) powered including additional safeguards to the exhaust, fuel, and electrical systems. (May be used in some locations where an LP-unit may not be suitable).

Page 1

Policy No. EHS-510

Powered Industrial Trucks Appendix P.2

Daily Forklift Checklist [ X ] Needs Attention [ √ ] OK [ N/A ] Not Applicable to This Unit Items Requiring Attention Must Be Reported To The Shift Supervisor Immediately

Date: From _____________ To _______________

Item to be checked Engine Oil Engine Oil Leaks Trans. Oil Trans. Oil Leaks Hyd. Oil Hyd. Oil Leaks Hyd. Hoses Engine Coolant Radiator Hoses Fuel Tires Seat Belt All Control Functions Gauges Brakes Parking Brake Safety Devices Back-Up Alarm Horn Lights Overhead Guards Fire Extinguisher

Sun

Mon

Comments:

Operators Signature

Page 1

Tue

Wed

Thu

Fri

Sat

Policy No. EHS-510

Powered Industrial Trucks Appendix P.3

PERFORMANCE TEST FOR FORK TRUCK OPERATORS

Employee Name

Date

1. Shows familiarity with truck controls. 2. Gave proper signals when turning. 3. Slowed down at intersections. 4. Sounded horn at intersections. 5. Obeyed signs. 6. Kept a clear view of direction of travel. 7. Turned corners correctly - was aware of rear end swing. 8. Yielded to pedestrians. 9. Drove under control and within proper traffic aisles. 10. Approached load properly. 11. Lifted load properly. 12. Maneuvered properly. 13. Traveled with load at proper height. 14. Lowered load smoothly/slowly. 15. Stops smoothly/completely.

Page 1

Time

Policy No. EHS-510

Powered Industrial Trucks Appendix P.3

PERFORMANCE TEST FOR FORK TRUCK OPERATORS

16. Load balanced properly. 17. Forks under load all the way. 18. Carried parts/stock in approved containers. 19. Checked bridgeplates/ramps. 20. Did place loads within marked area. 21. Did stack loads evenly and neatly. 22. Did drive backward when required. 23. Did check load weights. 24. Did place forks on the floor when parked, controls neutralized, brake on set, power off. 25. Followed proper instructions for maintenance - checked both at beginning and end.

TOTAL SCORE:

____________

RATING EVALUATOR: ___________________________ ADDITIONAL COMMENTS:

Page 2

Policy No. EHS-512

Fire Protection and Prevention Appendix Q.1

CLASSES OF FIRES & APPROPRIATE FIRE EXTINGUISHERS Every fire extinguisher is rated for the class or classes of fire it is designed to extinguish. An extinguisher may be rated A, BC, or ABC. An extinguisher solely rated for a Class A fire will not adequately extinguish a Class B, C, or D fire. In some cases, the improper type of extinguisher may spread the fire. Class A and B extinguishers also carry a numerical rating to indicate the extinguishing potential of the unit. The numerical rating indicates how large a fire an experienced person can safely put out with that unit. Class A Fire Fires that occur in ordinary materials such as wood, paper, rags, and rubbish. The quenching and cooling effects of water or of solutions of containing large percentages of water are of first importance in extinguishing these fires. Class A Extinguishers Class A extinguishers work by cooling the lit material to a temperature below its ignition temperature and soaking the material to prevent re-ignition. Class A extinguishers typically use pressurized water, foam, or multi-purpose dry chemicals to extinguish a fire of ordinary combustible materials. Class B Fire Fires that occur in the vapor-air mixture over the surface of flammable liquids such as gasoline, oil, grease, paints, and thinners. The limiting of air is of primary importance. Generally, regular, dry chemical, multipurpose dry chemical, carbon dioxide and foam may be sued depending on the circumstances of the fire. Solid streams of water are likely to spread the fire but on large fires of this class, water fog nozzles prove effective. Class B Extinguishers Foam, carbon dioxide, and dry chemicals are typical agents used in a Class B fire extinguisher. Class B extinguishers extinguish flammable liquids or gases by removing the oxygen and preventing the vapors from reaching their ignition temperature. Class C Fire Fires that occur in or near electrical equipment where non-conducting extinguishing agents shall be used. Dry chemical, carbon dioxide, compressed gas or vaporizing liquid may be used. Foam or solid stream of water should NOT be used because both are good conductors and can expose the operator to severe shock. Class C Extinguishers Energized electrical equipment is extinguished by using Class C extinguishers. Class C extinguishers contain an agent that is not capable of conducting an electric charge, such as

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Policy No. EHS-512

Fire Protection and Prevention Appendix Q.1

carbon dioxide or dry chemicals. Water extinguishers or extinguishers with agents capable of conducting an electric current are never to be used on Class C fires. Class D Fires Fires that occur in combustible metals such as magnesium, titanium, zirconium, lithium, and sodium. Specialized techniques, extinguishing agents and equipment are needed to control and extinguish fires of this type. Normal extinguishing agents generally should not be used, as there is danger in most cases of increasing intensity of the fire because of a chemical reaction between some extinguishing agents and the burning metal. Class D Extinguishing Agents Class D extinguishing agents are specifically designed for the material involved and should only be used on Class D fires. Class D extinguishing agents work by absorbing the heat from the ignited material and cooling it below its ignition temperature. Class D extinguishers are used to respond to fire involving flammable metals. All S&W Energy employees who are responsible for responding to incipient stage fires should be properly trained on the use of portable fire extinguishers. The PASS method is a common method for using a portable fire extinguisher: •

Pull the pin to unlock the handle.



Aim low at the base of the fire.



Squeeze the handle while holding the extinguisher upright.



Sweep the extinguisher from side to side, covering the fire with the extinguishing agent.

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Policy No. EHS-512

Fire Protection and Prevention Appendix Q.2

Fire Prevention Checklist † No makeshift wiring † Extension cords serviceable † Motors and tools free of dirt and grease † Lights clear of combustible materials † Safest cleaning solvents used

Electrical Equipment

† Fuse and control boxes clean and closed † Circuits properly fused or otherwise protected † Equipment approved for use in hazardous areas (if required) † Ground connections clean and tight and have electrical continuity

Friction

† Machinery properly lubricated

† Machinery properly adjusted and/or aligned

Special Fire-Hazard Materials

† Storage of special flammables isolated

† Nonmetal stock free of tramp metal

Welding And Cutting

† Area surveyed for fire safety

† Combustibles removed or covered † Permit issued

Open Flames

† Keep away from spray rooms and booths

† Portable torches clear of flammable surfaces † No gas leaks

Portable Heaters

† Safely mounted on noncombustible surface † Not used as rubbish burners † Use of steel drums prohibited

† Set up with ample horizontal and overhead clearances † Secured against tipping or upset † Combustibles removed or covered

Hot Surfaces

† Hot pipes clear of combustible materials † Ample clearance around boilers and furnaces

† Soldering irons kept off combustible surfaces † Ashes in metal containers

Smoking And Matches

† “No smoking” and “smoking” areas clearly marked † Butt containers available and serviceable † Flammable waste materials in closed, metal containers † Flammable waste material containers emptied frequently

† No discarded smoking materials in prohibited areas

Spontaneous Ignition

† Piled material, cool, dry, and well ventilated † Trash receptacles emptied daily

Static Electricity

† Flammable liquid dispensing vessels grounded or bonded † Moving machinery grounded † No accumulations of rubbish † Safe storage of flammables † Passageways clear of obstacles † Automatic sprinklers unobstructed † Proper type † In proper location † Access unobstructed † Clearly marked

† Proper humidity maintained

Housekeeping

† Premises free of unnecessary combustible materials † No leaks or dripping of flammables and floor free of spills † Fire doors unblocked and operating freely with fusible links intact

Extinguishing Equipment

† In working order † Service date current † Personnel trained in use of equipment

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Policy No. EHS-512

Fire Protection and Prevention Appendix Q.3

Fire Extinguisher Inventory Form Serial or ID Number

Location in the Facility

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Status of Equipment

Policy No. EHS-513

Confined Space Entry Appendix R.1

CONFINED SPACE ENTRY PERMIT – PAGE 1 of 2 ALL PAGES OF THIS PERMIT WILL REMAIN POSTED AT THE ENTRANCE TO THE CONFINED SPACE FOR THE DURATION OF THE PERMIT VALID DATES Description of Confined Space: _________________________________________________ Date: ______________________

PERMIT VALID: FROM __________________ TO __________________________ Purpose of Entry: ______________________________________________ Proof of Isolation: LOTO# ____________ Permits Associated with Entry:

Hot Work, identify _______________________

Other: _____________

Entry Supervisor(s) (includes Contractor Entry Supervisor)

Authorized Entrant(s) (includes Contractors)

Current Attendant(s)

List of Possible Hazards Present Limited Means of Entrance / Egress Hazardous Atmosphere Potential For Engulfment / Drowning Electrical Hazard Welding or Cutting Oxygen Deficiency Toxics Flammables

Yes

No

Slipping / Tripping / Falling Chemicals (Known or Likely) Others: Special Requirements Fire Extinguisher on standby? Lifeline / Escape Harness? Low Voltage Lighting (12V or less)?

Yes

No

Identify Communication: _______________________ Identify Rescue Procedures: ____________________

Measures to Isolate, Eliminate, or Control Hazard Lifeline / Safety Harness Forced Ventilation or Continuous Monitoring Purge and Block or Isolate Inlet Valve Proof of Isolation (LOTO Permit) Hot Work Permit Forced Ventilation, Continuous Monitoring Forced Ventilation, Continuous Monitoring Forced Ventilation, Continuous Monitoring, Non-Sparking Tools, Fire Extinguisher and Low Voltage Lighting Lifeline / Safety Harness Purge & Flush Others:

Special Requirements Protective Clothing? Respirator(s)? SCBA(s) on standby? Secure Area (Caution Tape, etc.)? Tripod Emergency / Escape Unit?

IN EMERGENCY CALL (Facility Emergency Number) Page 1

Yes

No

Policy No. EHS-513

Confined Space Entry Appendix R.1

CONFINED SPACE ENTRY PERMIT – PAGE 2 of 2 ALL PAGES OF THIS PERMIT WILL REMAIN POSTED AT THE ENTRANCE TO THE CONFINED SPACE FOR THE DURATION OF THE PERMIT VALID DATES

Test Results Tests to be Taken (Valid for one shift only) Percent of Oxygen Percent L.E.L. Carbon Monoxide Ammonia Hydrogen Sulfide Other

Permissible Exposure Limit

Test 1 Time:

Test 2

Test 3

Time:

Time:

Test 4 Time:

19.5 - 23.5%
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