Geismar Site Reviewed: 09/10/18 Effective: 09/10/18 Supersedes: 12/13/17 Preparer: Owner: Approver:

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1 Procedure No.: GSS27 Page: 1 of 18 RECORD OF REVISIONS Date Details of Change 09/10/18 Removed reference to phosgene orientation. Refer to MOC #0175-EHS /3/17 Updated Job Observation and Periodic Review sections to better align with N- ID-OSA 002. Updated the reference to the BASF procedure (now N-ID-OSA 002). 06/12/17 Periodic review. 03/29/16 Renamed PICS to Avetta to align with rebranding of the system. 01/19/16 Added 4.3 (Contractor Safety Concept) to align with BC Revised Attachment 5 (Pre-Access / Pre-Job Checklist). 09/22/14 Added several new items related to the revised BC , including: Identified the site s Contractor Safety Improvement Leader (5.1.1) Added expectations for contractor safety representatives (4.2.5) Added requirement for Job Hazard Analysis process (4.2.6) Added requirement for Pre-Access / Pre-Job Checklist (4.2.7) Added new responsibilities (5.3.6) Added Attachments 4 and 5 12/13 Periodic review to ensure consistency with BC Miscellaneous edits. 08/13 Added A & B to ensure consistency with BC /12 Periodic review to ensure consistency with BC Updated definition of Service Personnel 04/11 Revised sections related to contractor qualification and approval to ensure consistency with BC Eliminated Contractor EHS Review Summary and Approval Form Eliminated Conditional Approval Form Added PICS approval flowcharts 10/10 Revised 4.3 (Site Entry) to ensure consistency with current practices regarding site/unit orientations. 01/10 Revised contractor selection criteria in and added references to PICS Revised all sections to ensure consistency with BC Deleted definitions for Alliance Contractor, Incidental Contractor, Non- PSM/RMP Contractor, PSM/RMP Contractor, Routine Contractor, Unique Contractor, and Work. Revised definitions for Consultant, Contractor, and Service Personnel Added definitions for Contractor Employees, Contracted Employees, and Delivery Personnel. Revised Scope, Qualification Process, Periodic Review process, emergency approvals, and Attachment 3. Added process for condition approvals and annual management system review. 04/03/03 The following information has been added to Attachment 4 to ensure the

2 Procedure No.: GSS27 Page: 2 of 18 minimum information required by purchasing is gathered prior to performing work for at the Geismar site: Legal Name of Company, Street address (not PO Box), City, State, and Zip, Phone number, Fax number, Contact Name 01/21/03 The Purpose and Scope of this procedure have been expanded to include qualification of Non-PSM/RMP contractors and other safety-related aspects of on-site contractor work. Due to the detailed changes in the Purpose and Scope, the name was changed to Site Contracting Safety Requirements. The following definitions were added or modified: BASF coordinator, Consultant, Contractor, Experience Modification Rate, Incidental Contractor, Material Provider, Non-BASF Contractor, Non-PSM/RMP Contractor, PSM/RMP Contractor/Subcontractor, Subcontractor, Supplier, Total Recordable Incident Rate, Work Section Includes qualifying non-psm/rmp contractors. Section Added with Attachment 4 to allow for emergency qualification of contractors. Section New requirements for sending appropriate procedures to approved contractors. Section New to this procedure. It includes site entry and orientation requirements. These requirements were previously found in the Geismar PSM/RMP Guide. Section New to this procedure. It includes requirements for reporting incidents and initial treatment of injuries. These requirements were previously found in GSS06. Section Modified to require contractor safe work audits with documented deficiencies to be sent to Purchasing. Section 5 - New to this procedure. Attachment 1 Slight modifications have been made to this qualification form. Attachment 2 New attachment Attachment 3 New attachment Attachment 4 New attachment 11/27/17 Replaced EHS BC References. Removed reference to Proact database. Added reference to EHS Plan in 4.4. Added expectation for Permit Issuer to verify PTP. Added or designee to BASF Contractor Coordinator. 9/2018 Added definition of Exempt List and to clarify how Service Personnel are handled. Removed reference to Contractor Safety Improvement Leader from E&M Shared Services, since the E/M Service Manager role no longer exists. Updated where ACL is available (Geismar Quick Links) Added to clarify completion of Pre-Access / Pre-Job Checklists for routinely used contractors. Updated Attachment 3 to replace PICS with Avetta

3 Procedure No.: GSS27 Page: 3 of PURPOSE The purpose of this procedure is to establish environmental, health, and safety (EHS) requirements for qualification and oversight of Contractors and Contracted Employees working at the Geismar site. BASF Procurement procedures identify additional requirements for contractors to qualify for work at the site. Attachment 3 shows a flowchart for contracting work and delineates the portions of the process addressed in this procedure. 2. DEFINITIONS 2.1. Avetta Electronic system used to approve all Contractors BASF Contractor Coordinator The BASF representative responsible for scheduling and overseeing the work performed by an on-site Contractor. This could be the person who enters the purchase requisition Consultant Person(s) who provides intellect and/or advice, but does not do work on-site Contractor A company which will be either placing or bringing Subcontractor(s) or Contractor Employee(s) onto the Geismar site to perform work Contractor Employees Individuals employed by a Contractor to perform work or services at the Geismar site Contracted Employee An individual or group of individuals for whom BASF provides direct supervision in their day-to-day activities. The term Contract will be considered as synonymous with Contracted and Contingent for the purpose of this procedure Delivery Personnel Persons providing delivery of goods and materials to the site Exempt List The service exempt list is located in the BASF Procurement Key and consists of contractor companies who meet the service personnel definition.

4 Procedure No.: GSS27 Page: 4 of Experience Modification Rate (EMR) A measure used by the U.S. insurance industry to determine premiums for workers' compensation insurance. An EMR less than 1 indicates above-average injury and illness performance, and an EMR greater than 1 indicates belowaverage performance Material Provider BASF supplier who provides physical goods and/or off-site repairs Non-BASF Contractor A Contractor working on site installing or repairing non-basf owned equipment, pipelines, tanks, etc. These contractors work under the direction of and are under contract with the owner of said equipment, pipelines, tanks, etc. This category would include Contractors working for neighboring plants with assets located on BASF property Service Personnel Personnel whose work poses low EHS risk to production-related processes and facilities and does not introduce EHS hazards to the work area. Examples include performing routine interim work on non-manufacturing equipment, such as bench-top laboratory equipment, vending machines, and office equipment Subcontractor Contractor who works on site under the supervision and responsibility of a BASF hired Contractor Supplier Non-BASF organization that provides goods (materials) or services (work or advice) and is paid by BASF (includes no-charge warranty work) Total Recordable Incident Rate (TRIR) This represents the incident rate for a common exposure base of 100 full time workers. The following formula is used for the rate calculation: TRIR = (N/EH)(200,000) Where: N = number of injuries and illnesses EH = total hours worked by all employees during a year 200,000 = base for 100 full-time-equivalent workers (40 hrs/wk, 50 wks/yr)

5 Procedure No.: GSS27 Page: 5 of SCOPE This procedure applies to all Contractors, Contractor Employees, and Contracted employees performing work at the Geismar site. This procedure does not apply to Consultants, Service personnel, Delivery personnel, Material Providers, Non-BASF Contractors, or Suppliers. 4. PROCEDURE 4.1. EHS Qualification Each Contractor company, in Subcontractors, working at or providing personnel to Geismar must be qualified and approved according to certain minimum EHS criteria. A. Each Contractor company will be required to provide the qualification information through the Avetta system. B. Construction Engineering will review each completed qualification submittal to ensure that minimum EHS requirements are met. C. The Site Manager must be informed of any decision to not approve a Contractor. The Site Manager retains the authority to override any decision to approve or not approve a Contractor At a minimum, the following criteria must be considered for approval of a Contractor company for work on-site: A. TRIR less than or equal to 1.8 for past 3-year average, B. DAFWC rate less than or equal to 1.0 for past 3-year average; C. EMR less than or equal to 1.0, and D. No fatalities within last 3 years; E. No regulatory citations within last 3 years; F. EHS programs and procedures are in place to meet BASF s requirements for the services to be provided at the site.

6 Procedure No.: GSS27 Page: 6 of PROCEDURE cont d. 4.1 Contractor Company Safety Qualification cont d If the EHS qualification criteria are met, along with other commercial and technical requirements, then the Contractor company will be assigned a green flag in Avetta and listed on the Avetta Approved Contractor List (ACL), which is available from the Quick Links section of the Geismar web page. A. For Contractor companies not on the ACL refer to Attachment 3 for the approval process. B. A previously approved Contractor who demonstrates less-than-adequate on-site EHS performance may be placed on conditional (i.e., yellow flag) or unapproved status (i.e., red flag) If the minimum EHS criteria are not met, then conditional approval (i.e., yellow flag in Avetta) may be granted by considering the following situations: A. The Contractor has previously demonstrated satisfactory performance at Geismar; B. Responsiveness of the Contractor to questions or concerns; C. Projected work hours at the site; D. The nature of any EHS program deficiencies; E. The scope or risk level of the work to be performed; F. Presence of Contractor EHS professionals on site; G. Regulatory agency compliance history (nature of citation and abatement); and H. Availability of alternative safer Contractor companies Conditional approval requires the following: A. Consultation with EHS, Procurement, Operations, and/or Engineering & Maintenance, as appropriate;

7 Procedure No.: GSS27 Page: 7 of PROCEDURE cont d. 4.1 Contractor Company Safety Qualification cont d. B. Identifying specific conditions for the work and a timeline for resolving the areas of concern. Specific considerations must be documented in the Avetta-provided comment box and may include, but not be limited to, the following: I. Designation of a dedicated Contractor EHS representative during the work; II. Increased supervision during the work; III. Increased field audits by BASF representatives; IV. Implementing a specific pre-job EHS plan or checklist; V. Developing a job-specific, written EHS work plan; VI. Providing additional training; VII. Conducting periodic EHS meetings or tailgate safety meetings; and/or, VIII. Additional training or meetings to ensure acceptable performance; C. Removal from conditional approval status must be justified and documented, in consultation with the EHS Department Emergency approvals of Contractors may be approved by the respective Production Director/Sr Production Manager or BASF Contractor Coordinator, according to the following: A. Notification of EHS, Engineering & Maintenance, Procurement, and/or Operations as soon as possible; B. Complete the Emergency Qualification Form (Attachment 4), including identification of additional EHS measures to be taken by the Contractor during the work; C. The emergency approval is temporary and valid only for the specific emergency job; D. Copies of the completed Emergency Qualifications must be provided to the EHS Team Leader Service Personnel may be added to the Exempt List upon review / approval of the EHS Team Leader and Contractor Safety Coordinator.

8 Procedure No.: GSS27 Page: 8 of Security, Safety, Industrial Hygiene, and Ecology Procedures The BASF Geismar site has developed procedures that address topics such as safety orientation, site entry requirements, vehicle safety, Safe Work Permits, working in confined spaces, hazard communication, PPE, general waste handling and disposal, etc. These procedures, in conjunction with governmental regulations, govern all work performed at the site Site procedures are available to all Contractors via the BASF Contractor Portal at the following link: The Contractor is responsible for training their employees in the BASF site procedures prior to deploying them for work at the site. The Contractor s supervisor is responsible for monitoring the work to assure compliance with the BASF procedures Each Contractor is required to provide a Safety representative for the first 25 craftpersons, not to exceed a ratio of 50: Each Contractor is required to have a Pre-Task Planning (i.e., Job Hazard Analysis) process, which must be completed for each permitted work activity. The Permit Issuer is responsible for verifying that each Work Crew has a PTP before issuing a permit. Attachment 4 can be used by those Contractors which do not have their own process Contractor Pre-Access / Pre-Job Checklist The BASF Contractor Pre-Access / Pre-Job Checklist (Attachment 5) should be completed prior to the start of the Contractor s work. The completed checklist should be placed in the job or project file after completion. The checklist should completed in the following situations: A. All Contractors coming from outside the local area; or B. Any job extending beyond 2 days; or C. Any job involving a high-risk activity The Contractor Pre-Access / Pre-Job Checklist may be completed once per year for contractor companies that perform multiple jobs throughout the year. Contact the Contractor Safety Specialist to determine if a checklist has already been completed for a given contractor.

9 Procedure No.: GSS27 Page: 9 of Contractor Safety Concept A written EHS plan (i.e., Contractor Safety Concept) must be developed for major projects involving special or complex hazards (ex. large TAR, expansion projects, etc.). The plan must include the following: A. Planning activities related to process and location specific hazards; B. Coordination and scheduling of work between different Contractors and BASF employees to minimize exposures related to adjacent activities; C. Specific safety plans for high-risk Contractor work (e.g., demolition activities); D. Full-time Contractor Safety representative based on ratio of craft personnel (refer to 4.2.4); E. Identification of BASF representatives for possible questions or issues concerning safety; F. Periodic safety inspections of the work site by representatives of BASF and Contractor leadership; and G. Regular communication between BASF and Contractor representatives to discuss critical issues, incidents, etc., and to ensure all employees are informed of the applicable safety requirements A template for an EHS plan is available from D6 (EHS>Plans) The written EHS plan must be communicated to affected stakeholders (ex. Construction, Maintenance, Engineering, etc.), signed by representatives from each Contractor company, and communicated to Contractor employees Site Entry and Orientations All non-basf personnel, including Contractor and Contract employees, must be badged and receive a site safety orientation according to Site Procedure GSTBE-08 (Safety Orientation) from the Alliance Safety Council (Course #12BASF-SU). Refer to GSS46 (Site Contingent Staff EHS Requirements) for additional orientation and training requirements for Contract staff Refresher orientations must be received annually, except as exempted by GSTBE The Alliance Safety Council card, which is issued to each individual, will serve as proof of the required orientation(s).

10 Procedure No.: GSS27 Page: 10 of Incident Reporting and Initial Treatment of Injuries Contractor and Contract Employees shall report any hazards created by their work or found during their work to their BASF coordinator All environmental, health, and safety incidents must be immediately reported to the respective BASF Contractor Coordinator for investigation and corrective action, per GSS26 (EHS Accident/Incident Reporting) Except for exposure to chemicals, the Contractor shall be responsible for administering medical treatment for their employees. In the event of any serious or life-threatening injury, BASF will assist in emergency medical services. A. Each Contractor shall have an injury/illness case management system in place to address the manner in which their employees receive medical treatment when injured or becoming ill during work-related activities. B. Contractors are expected to use a pre-determined Occupational Health Provider for treatment of work-related injuries/illnesses, unless the injury or illness is serious or life-threatening and warrants direct transport to a hospital Emergency Room All persons exposed to chemical inhalations or skin contact with chemicals, must report to BASF Medical for evaluation. 4.7 Contractor Job Observations Contractor job observations will be conducted by each BASF Contractor Coordinator or designee. Frequency of observations will be based on the risk of the work. A. Completed observations should be forwarded to the Contractor Safety Specialist Each Cluster/Department should integrate contractor job observations into their Safety Contact / Safety Audit process. A. Completed observations should be forwarded to the BASF Safety Specialist Peer-to-peer observations, as part of the ERP SPEAR process, will be recorded in the RINCON database. This database serves as the tracking system to document and analyze observation data, as specified in N-ID-OSA-002.

11 Procedure No.: GSS27 Page: 11 of Periodic Review of Contractor EHS Performance Contractor EHS performance reviews will be conducted in Avetta according to the requirements of N-ID-OSA Contractor Management System Review Site EHS shall conduct an annual review of the contractor management system, as demonstrated through site procedure EC-13 (EHS Compliance Assessment Process) Results of the management system review will be documented in the CAP database. 5 RESPONSIBILITIES: 5.6 E&M Shared Services Group Reviews services provided by Contractor companies Identifies additional qualifications or certifications required for highly specialized services Reviews Contractor qualifications, including EHS performance data and program materials Interviews Contractor companies, as necessary, to determine reasons for deviations from established criteria Approves or disapproves Contractor companies for work on the site from an EHS perspective Develops and maintains the site procedure groups and initiates the process for distribution of new or revised procedures according to Procurement Distributes site procedures to qualified Contractors in accordance with 4.2 and maintains distribution records Initiates normal qualification process when a future need for the Contractor is anticipated.

12 Procedure No.: GSS27 Page: 12 of Resolves discrepancies in site entry for Contractors and Subcontractors. 5.8 BASF Contractor Coordinator or Designee Ensures the Contractor and any Subcontractors are approved in Avetta prior to scheduling the work Initiates Emergency Approval process and sends a copy of the approved emergency qualification form to the EHS Department Notifies Security when a Contractor has been approved via the emergency qualification process Provides field oversight of the Contractor s work to ensure BASF and governmental regulatory policies and procedures are followed in performing the work Conducts and documents field reviews of each Contractor and Subcontractor Coordinates incident investigations for Contractor and Subcontractor environmental, health, and safety incidents Leads completion of the BASF Contractor Pre-Access / Pre-Job Checklist, as needed. 5.9 Production Director/Sr Production Manager Approves emergency qualification of a contractor company, as necessary EHS Department 6 ATTACHMENTS Assists with Contractor approvals as needed Reviews and updates GSS27 as needed Coordinates annual review of the contractor management system. Attachment 1 Emergency Qualification for a Contractor Company (Refer to Documentum) Attachment 2 Example Field Audit Checklist Attachment 3 Contractor Approval Flowcharts Attachment 4 Example Job Hazard Analysis Form Attachment 5 BASF Contractor Pre-Access / Pre-Job Checklist

13 Procedure No.: GSS27 Page: 13 of 18 7 RELATED DOCUMENTS 29 CFR , Process Safety Management of Highly Hazardous Chemicals 40 CFR 68, Accidental Release Prevention Provisions BC037, Record Retention Policy GSTBE #8 - Site Orientations N-ID-OSA 002 Contractor EHS Management GSS46 Site Contingent Staff EHS Requirements

14 Procedure No.: GSS27 Page: 14 of 18 Attachment 1 Emergency Qualification for a Contractor Company (Refer to D6)

15 Procedure No.: GSS27 Page: 15 of 18 Attachment 2 Example Field Audit Checklist (Refer to D6)

16 Procedure No.: GSS27 Page: 16 of 18 Attachment 3 Contractor Approval/Selection Flowcharts Contractor Selection & Approval Flowchart

17 Procedure No.: GSS27 Page: 17 of 18 Attachment 4 Example Job Hazard Analysis Form (Refer to D6)

18 Procedure No.: GSS27 Page: 18 of 18 Attachment 5 Geismar Contractor Pre-Access / Pre-Job Checklist (Refer to D6)