Contractor EHS Management. Supersedes: 12/2014 (Rev.11) Preparer: Owner: Approver: EHS Team Member EHS Team Member EHS Manager

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1 Procedure No.: PA Page: 1 of 26 Preparer: Owner: Approver: EHS Team Member EHS Team Member EHS Manager Document Revision Change Table Revision Number Revision Description Revised By Revision Date 07 Changes to section b to allow Nested Contract Project Managers to accompany Contractors who provide specialized, technical services into the process area. DLS 04/12 08 Modified per Safety and Health Advisory 197. Steps affected are TAD 6/ , 4.1, 4.2.1, 4.3.2, and Modified to include the addition of CRT (Contractor Review TDF 3/14 09 Team), ISTC code for LEL training and the change from a visitor orientation video to a orientation document 10 Modified to include the new requirements in Safety and Health TDF 9/14 Advisory # Added EHS Manager To Contractor Review Team (CRT) TDF 12/14 Attachment 9 Changed PICS to AVETTA as new company name Changes to comply with RCMS audit findings: DLS 7/ Named Contractor Safety Improvement Leader Contractor Safety Contact Emergency Approval Documentation Referenced LIVE NOW for inspections Added annual review requirements Added form requirement referral process for ATLIS program BASF Requirements for Transient Contractors Items Required by Contractors DLS 10/17 13 Additional Changes: Documentation of CMRT and Avetta Approval Responsibility for Contractor Orientation and Power Point Attachments 2-8 were adapted to BASF Port Arthur procedures Effective: 2014

2 Procedure No.: PA Page: 2 of PURPOSE To establish minimum environmental, health, and safety (EHS) requirements for the qualification and oversight of Contractors/Agencies and Contracted Employees as part of the BASF EHS Responsible Care Management System. 2. DEFINITIONS 2.1 BASF Contractor Safety Improvement Leader This BASF employee or designee is the point person for the site for communication, performance, strategy as well as the point of contact for all contractor EHS concerns. 2.1 Competent Person An individual, by way of training and/or experience; Is knowledgeable of applicable standards and guidelines, Is capable of identifying existing and predictable hazards in the surroundings or working conditions which are hazardous to employees, Is designated by the employer, and Has the authority to take appropriate actions. 2.2 Contactor/Agency A company which will be either placing or bringing Contractor(s), Temporary (Contracted) Employee(s) or Contractor Employee(s) onto a BASF site covered under this procedure. 2.3 Contracted/Contingent Staff Employee A Contracted/Contingent Employee is an individual or group of individuals for whom BASF provides direct supervision in their day-to-day activities and direction as to how an activity is to be performed. 2.4 Contractor A company that will be either placing or bringing Contractor(s), Subcontractors, Contingent or Contractor Employee(s) onto a BASF site. 2.5 Contractor Employee An individual engaged by or through a third party to perform services principally for the third party and whose day-to-day activities are directed by the Contractor, not BASF.

3 Procedure No.: PA Page: 3 of DEFINITIONS cont d 2.6 CMRT Contractor Management Review Team. Team of select individuals from various Texas manufacturing sites that review force flag requests and approve or disapprove such requests. 2.7 Contractor Review Team (CRT) A cross functional team consisting of members from Site EHS, TES, Maintenance and Operations that reviews and approves or denies requests for AVETTA flag status changes of contractor companies for the Port Arthur BTP Site. For current members see Attachment Contractor Safety Concept A written safety plan for major projects e.g., turnaround, shutdown, plant expansion project, etc. 2.9 Contractor Safety Contact The safety professional responsible for Contractor safety oversight of the working Contractor Company Delivery Personnel Persons providing delivery of goods and materials such as: postal service, truck trailer deliveries, office supplies, drinking water, uniform laundry, production materials and equipment, etc Industrial Safety Training Center (ISTC) Training Refers to safety and health training conducted by the Industrial Safety Training Center Job Observation Program Process of conducting field reviews of Contractor Employees, to ensure the Contractor is performing to BASF expectations and to identify and mitigate hazards to ultimately eliminate or reduce injuries and illnesses Managed Service Provider (MSP) An MSP is a third-party company that facilitates selection, on-boarding, oversight and off-boarding processes for BASF Contract/Contingent Staff National Contractor Contractor/Agency that has geographic presence and/or capability to supply services across the nation. The National Contractor works, or can work, across multiple BASF locations. Typically, a Master Agreement exists to cover their services.

4 Procedure No.: PA Page: 4 of DEFINITIONS cont d PQF (Pre-Qualification Form) Questionnaire used to evaluate Contractor/Agency to determine EHS qualification AVETTA (Formerly PICS - Pacific Industrial Contractor Screening) Third party consultant that maintains a qualification system and database for managing the EHS processes and systems for BASF Contractors and Managed Service Providers (MSPs) AVETTA Exempt List The AVETTA Exempt List is located in the BASF Procurement Key and consists of the contractor companies who meet the Service Personnel Definition Pre-Task Plan (PTP) A PTP is a written plan such as a Job Safety Analysis (JSA) or Job Hazard Analysis (JHA) that describes job tasks in step-by-step sequence, identifies associated hazards for each step, and outlines proper hazard controls that minimize/mitigate the risk of injury or illness to the individual(s) performing that task Process Owner BASF person or entity that identifies scope of work and requests Contractor/Agency services. Process Owner is sometimes referred to as the requisitioner or BASF Contact Safe Work Permits Written authorization to perform work; describing task, associated risks, and appropriate control measures Service Personnel Providers of service whose work has traditionally posed low EHS risk to production related processes and facilities and does not involve or introduce EHS hazards to the work area. For example, performing routine interim work on nonmanufacturing equipment such as bench-top laboratory equipment, vending machines and office equipment. Conversely, providers of services such as building cleaning, lawn maintenance, snow removal, and cafeteria workers shall be considered Contractor, not Service Personnel, for the purposes of this procedure Subcontractor Any party who has a direct contract with the Contractor/Agency or who furnished material to the Contractor/Agency.

5 Procedure No.: PA Page: 5 of DEFINITIONS cont d Site Specific Contractor Safety Orientation Refers to the training conducted for contractors that addresses site specific safe work procedures. 3. SCOPE Applies to Contractors and Contracted Employees performing work at the Port Arthur Facility. 4. PROCEDURE 4.1. General Requirements Program Management A. Contractor/Agency and Subcontractors working at BASF Port Arthur site covered under this procedure must meet minimum EHS qualification criteria for work that: Affects or has the potential to affect the EHS of manufacturing, manufacturing-related, laboratory processes, or offices. Introduces EHS hazards into the work area. B. BASF Port Arthur site shall use AVETTA to facilitate the EHS qualification process for a Contractor/Agency covered under this procedure. Relevant documentation of the EHS contractor approval shall be maintained in the AVETTA database. C. A BASF purchase order will not be generated for a Contractor working at a site that does not meet the EHS approval as documented in AVETTA via a red flag. The red flag must be specific for the site where the contractor works. D. Contractor/Agency companies working at the BASF Port Arthur site covered under this procedure are required to ensure that any Subcontractors are registered in AVETTA and meet the same EHS qualification criteria. BASF Procurement will be responsible for informing the Contractor/Agency of this requirement in the contract documents. E. EHS approval is not required for Contractor/Agency that provides only Contracted Employees. If the Contractor/Agency provides both Contracted Employees and Contractor Employees, then the Contractor/Agency is required to obtain EHS approval.

6 Procedure No.: PA Page: 6 of PROCEDURE cont d 4.1. General Requirements cont d Program Management cont d F. Service Personnel and Delivery Personnel are not required to obtain an EHS approval under this procedure. The determination of classification of Service Personnel is the responsibility of the EHS professional or delegate for the site where work is performed Written Program As part of the Contractor/Agency qualification process, the BASF Port Arthur site shall have a written program for qualification of the Contractor/Agency and oversight of Contractor Employees that includes, but is not limited to the following: procedure for conditional EHS qualification and approvals procedure for emergency approvals communications process between BASF and Contractors Job Observation Program (conducting, data management, follow-up) procedure to conduct management system review means to ensure required training and qualifications for the job participation in accident/incident investigation participation in other EHS related activities, e.g., drills means to advise BASF of chemicals they will bring on-site means to address Contractor/Agency unacceptable performance means to certify and recertify to Contractor Employees and exchange safety and hazard information (Contractor EHS Orientations) method to develop any required Contractor Safety Concepts Pre-Mobilization Meeting Prior to the start of any capital project or large maintenance activity, a premobilization meeting shall be conducted. Meeting participants shall include but are not limited to: Contractor Safety, Project Superintendent and Field Supervision. BASF Site Contractor Safety Specialist, Project/Construction Engineer. If applicable, unit Operations Coordinator, Site Safety, Environmental and Engineering. See Attachment 5.

7 Procedure No.: PA Page: 7 of PROCEDURE cont d 4.1. General Requirements cont d Documentation The Contractor/Agency PQF and supportive or related documents will be the primary source of information evaluated for the EHS approval of Contractor/Agency to work at the BASF Port Arthur site. AVETTA maintains this information as well as a controlled copy of the BASF PQF for Contractors Contractor Selection Port Arthur site personnel responsible for contractor activities shall verify that all contractors selected to perform work at the site are registered and approved in the AVETTA system prior to performing work activities. A BASF service purchase order, service contract, or any other formal agreement to work on site cannot be generated for a Contractor that has not been reviewed and approved Qualification Contractor/Agency Full EHS Approval BASF currently uses AVETTA to coordinate Contractor qualification. The process is as follows: BASF Process Owner/Contact identifies scope of work and/or Contractor. BASF Procurement notifies the Contractor of BASF approval requirements. Contractor contacts and registers with AVETTA. AVETTA assigns a risk classification to the Contractor based upon the Contractor work capability or scope. Non-Safety Sensitive (Previously Low Risk) Contractors whose work has traditionally posed a minimal EHS risk. Examples include: o Office janitorial o Offsite/office engineering o Lawn care/lawn maintenance (excluding landscaping) o IT (information technology, software development) o Office equipment repair o Uniform laundry

8 Procedure No.: PA Page: 8 of PROCEDURE cont d 4.2. Qualification Contractor/Agency cont d Full EHS Approval cont d Safety Sensitive (Previously Medium and High Risk) Contractors whose work involves higher risk activities where there is incident potential. Examples include: o Abatement/remediation o Confined Space o Demolition o Lockout/tagout o Elevated work o Mobile crane operation o Electrical work o Hazardous waste o Hot work o Work over water o Rigging o Trench and excavation work o Hydroblasting and industrial cleaning o Linebreaking AVETTA reviews Contractor/Agency PQF and related EHS information according to the following minimum BASF criteria: o Total Recordable Incident Rate (TRIR) 3 year average of 1.8 or less o Days Away From Work Case Rate (DAFWCR) 3 year average of 1.0 or less o Experience Modification Rate (EMR) of 1.0 or less o No regulatory citations within last 3 years o No fatalities within last 3 years o EHS programs and procedures in place to meet regulatory and BASF s requirements. An initial flag color is assigned by AVETTA as indicated below: o Green Full EHS approval when all regulatory and BASF criteria is met. o Red signifies deficiencies in meeting regulatory and or BASF requirements based off the type of work the company performs.

9 Procedure No.: PA Page: 9 of PROCEDURE cont d 4.2. Qualification Contractor/Agency cont d Full EHS Approval cont d If EHS qualification and approval criteria are met, (green flag status) the Contractor/Agency is eligible to participate in the selection process or may continue service to BASF as long as technical and procurement approvals are in place. If Subcontractors are to be used, a list of those Subcontractors must be disclosed to BASF for qualification and approval before work performance. The qualification and approval process for Subcontractors is the same, with the exception that the managing Contractor may be required to facility transfer of necessary documents to AVETTA for evaluation Conditional EHS Approval Process When Contractors do not meet minimum EHS performance criteria (e.g., EMR, TRIR, DAFWCR, regulatory compliance history, or EHS programs) is not met, a conditional approval may be granted on a case-by-case basis with consultation from the Contractor Management Review Team (CMRT Attachment -8) considering the following situations: o Contractor/Agency previous safety performance within BASF (locally or nationally) including the nature of incidents/injuries. o o o o o o o o Contractor/Agency responsiveness to BASF questions/concerns Safety performance trends within recent years including comparison with Contractor/Agency industry average in accordance with methodology of U.S. Department of Labor Bureau of Labor Statistics. Projected work hours on site Nature of any safety program deficiencies Regulatory agency compliance history nature of citation and abatement Scope or risk level of work to be performed Presence of Contractor/Agency EHS professional on site Availability of alternative safer Contractor/Agency companies NOTE: In order for the flag change to occur a unanimous vote from the CMRT will be required. In the event of a dissenting vote the request will then be forwarded to the Site s Vice President for final approval or denial. See Attachment 9 for list of CMRT Members.

10 Procedure No.: PA Page: 10 of PROCEDURE cont d 4.2. Qualification Contractor/Agency cont d Conditional EHS Approval cont d Once a conditional EHS approval has been granted, the Contractor/Agency is designated as conditional (yellow flag) in the AVETTA database and may perform work on a BASF site. The conditions for working under a conditional status must be documented in AVETTA and include a timeline for addressing or resolving concerns. Acceptable conditional work requirements may include, but are not limited to: o resolving a specific EHS concern o increasing dialogue to provide for updates on Contractor/Agency performance and communication expectations to obtain feedback o providing a dedicated escort or Contractor/Agency EHS representative o increased supervision by BASF or Contractor/Agency o increased number of job observations on work activity o requiring additional training o conducting periodic EHS meetings or safety huddles o o developing and implementing Contractor/Agency Journey Roadmap developing or improving specific EHS plans, such as confined, space entry, respiratory protection, fall protection, forklift operation, etc. After CMRT gives approval, it is documented in the Avetta Notes and Attachment 2 (Flag Change Request Form) and filed in the Group Drive. NOTE: In certain situations, the Contractor/Agency may be granted full approval versus conditional approval Emergency Approvals A site manager or designee may grant emergency approvals for a Contractor in consultation with EHS Site Services, Engineering and Maintenance. Emergency approvals are temporary and valid for the emergency job only. Once the emergency job is completed, the Contractor/Agency is required to participate in the EHS Qualification and Approval process for continued work at the BASF Port Arthur site. Some examples of emergency approvals may include: o Short-term remediation of a spill or release o Unplanned or emergency repair of process-related equipment o Unplanned or emergency repair of lab-related equipment o Correction of high-risk unsafe workplace condition

11 Procedure No.: PA Page: 11 of PROCEDURE cont d 4.2. Qualification Contractor/Agency cont d Emergency Approvals cont d When emergency approvals are granted, site management, EHS Site Services and/or Procurement may require additional EHS measures such as increased supervision and/or auditing of the work throughout the job. Emergency approvals are documented and retained in the Contractor AVETTA EHS Review folder for the purposes of performing the Contractor/Agency Management System Review. EHS Site Services, Procurement, and other appropriate functions shall be informed of the emergency approval as soon as practical Service Personnel Designation Providers of service whose work has traditionally posed low EHS risk to production related processes or facilities and does not involve or introduce EHS hazards to the work area, can be designated as Service Personnel. For example, performing routine interim work on non-manufacturing equipment such as bench top laboratory equipment, vending machines, and office equipment/cleaning may be considered Service Personnel tasks. The determination for the Service Personnel classification must be made for each site where the service provider works and must be based on knowledge of the work that the service provider is capable of performing Pre-Access to Site EHS Site Services is responsible to complete the review for potential Service Personnel designation. If it is determined that the Contractor meets the Service Personnel designation, the BASF contact and the EHS professional will work with the Site Procurement Liaison to add the Contractor company to the AVETTA Exempt List BASF Requirements for Transient Contractors A BASF contact shall be identified for each Contractor/Agency job. This Contact is the Person/Company requesting the services of this contractor group. This person/company is responsible for conducting the Pre-access orientation specified in Section using the Power Point slide presentation in the link in Attachment 7. Contractor Safety Specialist may be able to assist in this process. The BASF contact will be responsible for ensuring all EHS requirements are met before the Contractor Employee(s) begins work.

12 Procedure No.: PA Page: 12 of PROCEDURE cont d 4.3. Pre-Access to Site cont d BASF Requirements cont d The BASF contact shall be responsible for coordinating the reporting of Contractor/Agency accidents/incidents in accordance with site reporting requirements. The BASF contact shall ensure Contractor Employee accidents/incidents are entered in AIMS Items Required by Contractors All Contractors must have an Employee Referral form (Attachment 5) before processing. All Contractors must have a Background Verification Form submitted to the SCC 48- hours prior to arrival. (Attachment 6) NOTE: This is an added form due to Corporate Security guidelines. Background checks are normally done by ISTC before issuing the badge. All Contractors must have a Badge Request Form submitted to the SCC 48-hours prior to arrival. (Attachment 3) If the contracted employee does not arrive with the Employee Referral form, the following will apply: SCC will provide a Referral Form to be completed by the contract employee. Security team member will have form signed by the employee s on-site supervisor or BASF Representative that requested the work. The Contractor/Agency will be notified by ATLIS Team Member to ensure knowledge of the procedure and provide the required form and process for future work at the BASF Port Arthur site. NOTE: This form is in addition to, and not a substitute for, the Safety Requirements to work at the BASF Port Arthur site.

13 Procedure No.: PA Page: 13 of Pre-Access to Site cont d Contractor Referral Exemptions The following contractors may be exempt from the referral process: Contractors who are on-site for short periods of time (i.e. truck drivers, contract laundering service). Contractors who provide specialized, technical services. Contractors who must be brought on site for work on a one time, emergency basis Contractor Safety Concept For major projects involving special or complex hazards, e.g. shutdown or plant expansion projects, representatives with adequate knowledge of the process, materials and equipment (e.g., maintenance or construction engineer, defined EHS professional) shall develop a concept for the implementation of the Contractor s safety requirements. The Contractor Safety Concept includes: Planning activities related to process and location specific hazards Coordination and scheduling of work between different contractors and BASF employees (avoiding risks due to interaction of different activities) Specific safety plans for high-risk contractor work (e.g. demolition activities) Ensuring Contractors know the necessary BASF contacts (or contacts to the main contractor for turnkey projects) for possible questions or issues concerning safety Specific safety supervision of the construction site on a regular basis (e.g. safety tours, safety supervision). Regular consultations held to discuss critical points and ensure all employees are informed of the applicable safety requirements, and Multi-contractor coordination measures necessary to avoid accidents due to potential increase risk from on-going simultaneous work activities. Prior to starting the work, this concept shall be discussed with the construction/maintenance managers of the contractors and relevant BASF services. The implementation plan must be signed by all affected contractors. After that, the contractors must inform all their employees about the applicable safety measures. Whenever there is a change in the scope of the activities, the concept must be updated and reviewed accordingly.

14 Procedure No.: PA Page: 14 of Pre-Access to Site cont d EHS Orientation Before work begins, the Contractor/Agency shall ensure that each of its Contractor Employees has received site and/or unit-specific EHS orientation. In situations where the Contractor/Agency directly provides orientation to their Contractor Employees, documentation must be provided. All Contractor Employee EHS orientations shall include: provisions for the right to inspect work and STOP WORK as appropriate practices to control the entrance, presence and exit of Contractor Employees means for Contractors to provide BASF with information about hazards that the Contractor Employees may generate means to ensure that the Contractor Employee informs BASF of any chemicals brought on-site, means to ensure that Contractor Employees are included in any BASF sponsored accident/incident investigations that involve them or their work, overview of site s Job Observation Program emergency plans, alarms, and evacuation procedures, known or potential hazards, such as, confined spaces, electrical, fire, explosion, or process hazards related to the Contractor Employee s work or work area, site specific EHS requirements, and Pre-Access / Pre-Job EHS Process This process is not a site orientation, but a structured and documented EHS dialog between the BASF contact and the Contractor crew representative (supervisor, general foreman, safety representative, superintendent, etc.) responsible for executing the work. Presentation is detailed in Attachment - 7 and is normally given to the crew by the Contractor Safety Specialist. If that person is not available. It is the responsibility of the Project Manager to ensure this orientation is done. The minimum information covered in the prejob process shall be: Contractor company Contractor company manager s information (name, phone number, , etc.) responsible and accountable for the work execution Foreman information responsible for the on-site work (name, phone number, etc.) Direct supervisor of the foreman completing the work on site (name, phone number, etc.) Any plans to use Subcontractors Topics to cover during the Contractor orientation are listed in the Contractor Orientation Checklist (Attachment 4). Complete the checklist during orientation to ensure all required topics are covered and the completed checklist will be filed by the Contractor Safety Specialist.

15 Procedure No.: PA Page: 15 of Work Execution Contractor Job Observation Program Each manufacturing site that nominally incurs 1000 contractor work hours per year shall have a Job Observation Program at the Port Arthur facility is the LIVE NOW observation process which includes: o Identification of multiple observers at all levels, to include production, maintenance, supervisors, managers, engineers, EHS professionals, etc. o Training for observers o A feedback process to communicate findings internally and to the Contractor/Agency. o A tracking system to document and analyze observation data o A frequency schedule established based on risk 4.4. Work Execution cont d Pre-Task Planning (PTP / JSA) All Contractors approved to work at the Port Arthur Site via Safe Work Permits are required to have, at minimum, a PTP/JSA process. At a minimum, all PTP s/jsa s shall have the following elements: job/project title job location date when the work is performed all crew members signoff job description with job steps risk/hazard description for each job step risk/hazard controls / elimination / mitigation for each recognized hazard The PTP/JSA tool is a separate document and must be reviewed by all members of the work crew. NOTE: See Attachment 8 for example of PTP/JSA Monitoring, Evaluation and Feedback Contractor Periodic Reviews EHS performance data for all Contractor risk classifications shall be updated annually. Contractors classified as safety sensitive will receive an audit of their safety program manual by AVETTA at least every three years. The review shall include Contractor injury statistics, EMR, regulatory agency citations and EHS programs.

16 Procedure No.: PA Page: 16 of Monitoring, Evaluation and Feedback cont d The results and findings of the annual and/or 3-year review may be used to adjust the Contractor approval status BASF Contractor Management System Review/Safety Performance Evaluation The Port Arthur Site shall review the effectiveness of practices at least annually to ensure that the Contractor/Agency management system is properly implemented and the elements adequately support Contractor/Agency performance improvement. As a minimum, the following elements of the Contractor/Agency management system shall be included in the review: Review the site procedure to ensure written requirements are in agreement with the Corporate procedure. Inclusion of affected stakeholder involvement in the development and/or revision of site procedure for adequacy. Adequate understanding of Contractor/Agency management roles and responsibilities among affected stakeholders (Procurement, Engineering, Maintenance, Operations, EHS, etc). System to provide opportunity for feedback and communication with Contractor Employees, e.g., meetings, exchanges, forums, etc. Maintenance of Contractor/Agency approval documentation. Efficiency and adequacy of conditional approval process. Efficiency and adequacy of emergency approval process. Documented Contractor/Agency orientation performed in a timely manner before work. Verification mechanism in place to ensure contractor orientation was understood. Contractor Job Observations performed adequately, timely with appropriate follow-up. Information/data from affected stakeholders (Procurement, Operations, Maintenance, Engineering, EHS, etc) adequate and accessible in order to conduct periodic contractor reviews or re-approvals. Results of annual management system review communicated to affected stakeholders. Safety performance review of all Contractors (by AVETTA) Contractor hours accounting process *Refer to Section 6, Related Documents, Attachment #11, Contractor EHS Management System Checklist in N-ID-OSA 002 BASF Procedures.

17 Procedure No.: PA Page: 17 of Monitoring, Evaluation and Feedback cont d Contractor Hours Accounting All Contractor companies shall turn in hours to the site where work was completed each month. These hours will be periodically reconciled by use of the site s electronic badging system Oversight - Contracted/Contingent Employee Incident Recordkeeping and Reporting Each BASF site must maintain an OSHA log of recordable injuries and illnesses for BASF and Contracted/Contingent Employees. The log may be subdivided to show separate listings for Contracted/Contingent Employees, but the log must be considered as one log for compliance purposes; i.e., annual posting of the log Orientation and Training Requirements for EHS orientation and training of Contracted/Contingent Employees shall be equivalent to the minimum requirements for newly hired BASF employees that perform similar work activities. An EHS training assessment shall be performed for Contracted/Contingent Employees by BASF supervision to determine the level and extent of training required based on the work to be performed. BASF Contracted Employee supervision shall ensure that the training assessment and required training is received for their Contracted/Contingent Employee. In addition to the EHS and skills training, the program shall include the means to orient Contracted/Contingent Employees and document training provided by BASF Training Visitor Orientation The visitor safety orientation consists of a document describing the emergency alarms, evacuation routes, hazard communication information, etc. Visitors will also be given a plant map and a wallet card valid for 1 year. The orientation will be performed at the main entry gate. The following contractors may be exempted from ISTC training, but shall receive at a minimum, the BASF Port Arthur site visitor safety orientation training: Contractors who are on-site for short periods (i.e. truck drivers, contract laundering service). Contractors who provide specialized, technical services. These contractors must be accompanied at all times by a BASF employee or an approved nested contract project manager who has been oriented to the facility through the BASF- EHS orientation and is knowledgeable

18 Procedure No.: PA Page: 18 of Training cont d of the hazards and emergency procedures of the area and meets the definition of Competent Person as defined in 2.1 of this procedure. The safety department, as well as security, needs prior notification to give approval before the contractor enters the site Visitor Orientation cont d If a contractor listed above will be onsite for a longer duration, or will be physically working onsite, the contractor will need the Basic Plus and the Port Arthur Specific from ISTC. Contractors who must be brought on site for work on a one time, emergency basis. These contractors must be accompanied at all times by a BASF employee. The safety department, as well as security, needs prior notification to give approval before contractor enters the site Industrial Safety Training Council (ISTC) Training In order to meet the EHS Orientation, Contractors who will be performing work in process areas must receive the ISTC training in accordance with the following requirements: Contractors trained through ISTC will receive an ISTC badge indicating the required training has been received. To allow entry onto the Port Arthur Site, the contractor employee must have the Basic Plus, as well as Port Arthur Site Specific training. Depending on the work to be performed on the BASF Port Arthur Site, the following additional codes may be required: CSE - confined space entry work FG - fire guard for hot work SU - scaffold user GM LEL Meter user The codes indicate that the contractor has attended and passed the required training. Training is valid for one year and the contractor must be retrained by the date on the badge Site Specific Contractor Safety Orientation Site specific contractor safety orientation will be conducted by ISTC. Onsite orientation may be conducted in some cases Basic Safety Training Safety training received from other safety councils may be accepted only if the local ISTC has verified the training, transferred the information into the

19 Procedure No.: PA Page: 19 of Training cont d local ISTC council database, and has printed the information on a new ISTC badge. BASF Port Arthur Facility code 09BASFPA should appear on the back of the new badge, thus preventing Port Arthur employees from having to review numerous badges and determine their authenticity. 5. RESPONSIBILITIES 5.1. Port Arthur Site Leadership Team Has primary responsibility for implementation of this procedure Environmental, Health, and Safety Manager Has primary responsibility for the initiation, re-issuance, administration, and/or interpretation of this procedure Port Arthur Site Employees and Contractors Have primary responsibility for adherence to procedure including identifying deficiencies in the procedure, and identifying, reporting and correcting activities not in compliance with the procedure. 6. RELATED DOCUMENTS Attachment 1 N-ID-OSA 002 BASF Procedure Attachment 2 Flag Change Request form Port Arthur Attachment 3 Badge Request Form Attachment 4 - Contractor/Agency Orientation Checklist (Example) Attachment 5 Employee Referral Form Attachment 6 Contractor Background Check form Attachment 7 Contractor Orientation Power Point Presentation Attachment 8 - Members of Contractor Management Review Team (CMRT)

20 Procedure No.: PA Page: 20 of 26 Attachment 2 Flag Change Request Form PICS EHS Review Form PA 2016.docx

21 Procedure No.: PA Page: 21 of 26 Attachment 3 Badge Request Form Copy of Badge Request Form.pdf

22 Procedure No.: PA Page: 22 of 26 Attachment 4 Contractor Orientation Checklist Contractor Management att4.pd

23 Procedure No.: PA Page: 23 of 26 Attachment 5 Employee referral form EMPLOYEE REFERRAL (002).pdf

24 Procedure No.: PA Page: 24 of 26 Attachment 6 Contractor Background Check Form Background Verification.pdf

25 Procedure No.: PA Page: 25 of 26 Attachment 7 Contractor Orientation Power Point Presentation 2017 Contractor Kick Off Meeting site

26 Procedure No.: PA Page: 26 of 26 Attachment 8 Contractor Management Review Team (CMRT) Perry Guentzel - TES Director Matt Auger Operations Director Wendel Langley - Maintenance Manager Kevin Carl Contractor Safety Specialist Randy Burrell Maintenance Contractor Supervisor Brad Hopper EHS Manager