SAFETY AND HEALTH STANDARDS MANAGEMENT of CHANGE Effective Date: 07/06/11 Standard: 14.3 Document Number: KUCSH00017 Rev: 06

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1 INTRODUCTION This standard documents the KUC requirements to ensure that effective controls are in place for the management of change and for managing the HSEQ risks associated with change The Management of Change will be completed using the Kennecott online system DEFINITION Change: Any addition / deletion, process modification, substitute item or organizational or procedural change Replacement in Kind: A replacement that satisfies the design specification with no reasonably foreseeable unintended consequences. No formal MOC approval is required however; the replacement must be reviewed with the immediate supervisor Temporary Change: Any change that is intended to exist for a short, predetermined time period Emergency Change: Immediate change needed to prevent a serious health, safety, environmental, security incident or severe economic loss Impact Level 1: Change affecting multiple plants, departing from KUC or industry standards, or potentially affecting Rio Tinto or external stakeholders Impact Level 2: Change with the potential to impact process safety information (see ), regulatory compliance, product quality or production Impact Level 3: Organizational change, document format change, change made within pre-established and accepted limits; change not affecting process safety information, regulatory compliance, product quality or production. o For all organizational changes see KUC Safety and Health Standard Process Safety Information: Includes information pertaining to: o Mine layout and ground control. o Process equipment such as materials of construction, piping and instrument diagrams, design specifications, design codes and Page 1 of 10

2 standards, equipment configuration, electrical classification and ventilation system design. o Process controls such as instrumentation, controls, alarm limits, interlocks and computerized systems. o Operations and technology such as process conditions or limits, process flow diagrams, heat and material balances, process chemistry, process materials (including material safety data sheets) and sequence of operations. o Operating procedures such as standard operating procedures, safe work practices and emergency procedures. o Safety systems such as pressure relief systems, explosion relief systems and fire protection systems. o Maintenance procedures such as preventive maintenance, inspection and testing Pre-Startup Safety Review: A formal review to verify that critical areas of the affected process have been assessed and addressed prior to commissioning, introducing hazardous materials, or energy REQUIREMENTS Note: A flowchart summarizing the KUC management of change process is found in Exhibit Key aspects of this process are as follows: IDENTIFYING CHANGE / PROPOSAL FOR CHANGE Replacements in kind may be managed outside of the management of change system. No formal MOC approval is required however; the replacement must be reviewed with the immediate supervisor. Exhibit contains examples of replacements in kind for various types of change Once the need for a change has been identified, the management of change process is initiated with the preparation of a change request using the KUC on-line management of change tool located on the Kennecott Intranet. o The completed change request will include the impact level (Level 1, Level 2, or Level 3) and the type of change (permanent or temporary). Refer to Exhibit for examples of each impact level. o The completed change request will also include a description of the proposed change, the purpose of the proposed change, expected outcome from the change, method(s) to test or evaluate the results of the change, and the technical basis for the change. Page 2 of 10

3 o Supporting documents (e.g., drawings, calculations, reports, specifications, etc.) should be attached, as appropriate, to the change request to help reviewers better understand the proposed change Change requests for temporary changes should include the expiration date and an explanation of the reasons for the temporary change. ASSESSMENT OF PROPOSED CHANGE All non-emergency change requests shall be subjected to a formal review using the KUC on-line management of change tool. The purpose of this review is twofold: 1) grant approval in concept for the proposed change, thus authorizing the originator of the change request to proceed with pre-implementation activities and 2) identify constraining and nonconstraining actions to be completed prior to change implementation and change closure, respectively. o Approval authority for an Impact Level 3 change is limited to the Area Manager or Department Superintendent. o Approval authority for an Impact Level 2 change includes the Area General Manager, Area Manager, Department Superintendent, Technical Manager, Asset Management Manager, Reliability, Safety / Health Advisor, Environmental Engineer and additional Subject Matter Experts as required. o Impact Level 1 approval authority is the same as for Impact Level 2 changes with the additional review / approval of the Chief Operating Officer. Note: Changes to KUC Health and Safety Standards are a special type of Impact Level 1 change requiring an assessment in the form of a formal review of the standard by the appointed KUC Standards Committee and MOC approval including the Chief Executive Officer and the KUC Standards Committee members A risk assessment is a constraining action that must be completed before a change can be implemented. The Safety / Health Advisor and the Environmental Engineer shall identify the appropriate level of risk assessment for Impact level 1 or Impact level 2 changes Reviewers of a proposed change must consider all actions that are essential to be completed in conjunction with the change. Consideration must be given to HSEQ hazards and controls, applicable standards to be applied, predicted impact on people, additional studies, regulatory requirements, contingency plans, training and communication, reporting metrics and requirements, organizational and staffing implications, and Page 3 of 10

4 revisions to the process safety information. These actions can be identified from the standard checklist included with the KUC on-line management of change tool or added, as required, by the reviewers. o Each action identified by the reviewers must be designated as either constraining or non-constraining. Constraining actions must be completed prior to implementation of the change, whereas nonconstraining actions must be completed before the change request can be closed Revisions to process safety should be regarded as constraining actions. However, controlled temporary records (e.g. redlined drawings and procedures) may be used to satisfy this requirement provided the progress toward completion of the permanent records is tracked regularly until they are brought up to date A formal pre-startup safety review (PSSR) must be identified as a constraining action for new facilities or for modifications to existing facilities that are significant enough to require a change in the process safety information. (See Standard 14.6) When an initial change request is altered, it must be reviewed and reauthorized prior to implementation The originator of the change must ensure that all constraining actions identified in the change review have been completed prior to implementation of the change. o Objective evidence of action completion for all constraining actions must be attached to the change request. IMPLEMENT CHANGE The change authorization review for Impact Level 3 changes will be completed by the Area Manager or Department Superintendent. The change authorization review for Impact Level 1 and Impact Level 2 changes will be completed by a designee appointed by the General Manager. o If the change authorization review finds any constraining actions that have not been satisfactorily completed, the change request is returned to the originator to complete the identified actions. o If the change authorization review results in confirmation that all constraining actions have been completed, the change request is authorized for implementation. Page 4 of 10

5 Authorized changes shall be communicated to all affected crews and the training shall be documented A post-implementation notification must be made to all affected persons advising that the change has taken place Once the change has been implemented and all non-constraining actions have been completed, the originator shall verify that physical changes have not introduced any unexpected hazards and complete and close the change request. EMERGENCY CHANGE A change satisfying the criteria as an emergency change is initiated by preparing an emergency change request using the KUC on-line management of change tool Emergency change requests are reviewed and approved by the Area Manager. The Area Manager may delegate approval authority for emergency changes to a Department Superintendent in their absence. o Copies of the emergency change request shall be provided to the appropriate support and technical personnel. o Emergency changes shall be communicated to all affected crews and the training shall be documented. Training shall be conducted at the start of each crew s shift and repeated throughout the duration of the emergency change until all affected crews have received the communication Prior to implementing an emergency change, site HSE personnel must be notified to ensure that emergency controls are adequate to prevent adverse health, safety and environmental impacts. o Emergency changes must be implemented in accordance with all critical control procedures (e.g., work permits and safe work practices) and must be preceded by the completion of a Level 1 Pre- Task Hazard Assessment Emergency changes have a 24-hour duration but may be extended after 24 hours with approval from the General Manager. A normal nonemergency change request (either permanent or temporary) shall be initiated by the next normal workday after the extension. Note: The emergency change request cannot be closed until the nonemergency change request has been authorized A post-implementation review will be conducted by the Area Manager for all emergency changes to confirm that all applicable aspects of the Page 5 of 10

6 management of change process have been applied to the emergency change and to determine how the normal management of change process can be applied if a similar change occurs The status of all emergency changes shall be tracked at the plant leadership level to ensure timely closure or conversion to a nonemergency change request In addition to the post-implementation review of all emergency changes, monthly reviews of all open change requests shall be completed at the plant level to assess compliance with the Management of Change Standard and to identify areas for improvement in the management of change process. These reviews should include a review of change documents, interviews with change stakeholders and field observations with the results reported the to plant leadership team RECORDKEEPING Retention of all changes should be maintained in compliance with established records retention and document control policies. REFERENCE Rio Tinto HSEQ Management System, Element 11 Management of Change Rio Tinto HSEQ Management System, Work Cycle WCMS1101 Management of Change KUC Safety and Health Standard 3.1 New Employee Orientation KUC Safety and Health Standard 14.6 Commissioning (Future Standard) REVISION HISTORY: MOC # TS Description of Change Prepared By Date Update the Degree of Impact Change Exhibit list - revision recommended by the MOC Champion and Custodians Revisions submitted by the HESQ MS Champions and custodians to comply with the Element 11 requirements. Updated format and Document number added. KUC Safety and Health Standards Committee KUC Safety and Health Standards Committee 03/31/08 07/31/08 Page 6 of 10

7 14283 A redesign of the MOC process which includes a clear definition of change, impact levels and approval authority; Risk assessment triggers; Pre-approval and post-approval requirements; and MOC governance. The revised standard will not be effective until: 1) the on-line MOC application is redesigned to mirror the changes in the standard, 2) beta testing of the new on-line application is complete and 3) training in the new standard and on-line application. A separate action ( ) has been created for the redesigned MOC application, beta testing and workforce training. KUC Principal Advisor Safety Risk Management KUC Safety and Health Standards Committee 07/01/11 Page 7 of 10

8 Exhibit Management of Change Process Page 8 of 10

9 Exhibit Change Matrix Replacement in Kind Level 1 Change Level 2 Change Level 3 Change Change Category Impact Description: Not a change no MOC required Approval Authority: No approval required Impact Description: Change affecting multiple plants, departing from KUC or industry standards, or potentially affecting Rio Tinto or external stakeholders Approval Authority: Chief Operating Officer, Area General Manager, Area Manager, Department Superintendent, Technical Manager, Asset Management Manager, Safety/Health Advisor, Environmental Engineer, Subject Matter Experts (as required) Impact Description: Change with the potential to affect process safety information, regulatory compliance or product quality Approval Authority: Area General Manager, Area Manager, Department Superintendent, Technical Manager, Asset Management Manager, Safety/Health Advisor, Environmental Engineer, Subject Matter Experts (as required) Impact Description: Organizational change, document format change, change made within preestablished and accepted limits; change not affecting process safety information, regulatory compliance or product quality Approval Authority: Area Manager or Department Superintendent Changing materials of construction (including internal parts) Changing pipe diameter, schedule number or flange rating Relocating tank or vessel nozzles Process equipment changes Replacing vessels, tanks or piping with equipment having the same dimensions, configuration, materials of construction, wall thickness, pressure and vacuum rating, design temperature, post-weld heat treatment, etc. Repairing a corroded vessel to restore its original wall thickness Replacing a valve with one that is identical to the original or meets all of the design specifications for the original valve Replacing rotating equipment with new equipment of the same material, capacity, flange rating, seal design, driver type, horsepower, etc. Level 2 process equipment changes satisfying the criteria for a Level 1 change Derating a vessel to operate at a lower pressure consistent with the decreased wall thickness Changing valve type or trim characteristics Changing the impeller size, driver horsepower or driver type (including electrical classification) on rotating equipment Changing the seal design on rotating equipment Changing pump type (e.g. centrifugal to positive displacement) Adding a valve where there was none Adding a new pipe or branch connection Note: Level 3 authority not appropriate for process equipment changes Making a piping system repair in a manner that conforms exactly to the original design specification Replacing a section of pipe with a hose Changing gasket material Changing insulation material Adding heat tracing or replacing steam heat tracing with electric heat tracing Running temporary power to temporary equipment Resetting an alarm or interlock trip point beyond the safe operating range Adding a new instrument, alarm or interlock Modifying the programming within the DCS system Process control changes Tuning a controller to more tightly control a process variable Replacing a DCS system component with an identical replacement Replacing an instrument with an identical spare Level 2 or Level 3 process control changes satisfying the criteria for a Level 1 change Installing new control loops (field control hardware or DCS system) or tying several control loops together in a cascaded control scheme Moving a conventional analog control loop into the DCS system Replacing the same DCS module with an upgraded version with enhanced capabilities Resetting an alarm or interlock trip point, but staying within a previously-defined safe operating range Bypassing an interlock using the DCS system Changing the range on an instrument calibration Replacing an instrument with an instrument utilizing a different technology or output signal Changing machine settings beyond the established limits Operations & technology changes Modifying process operating parameters (e.g. flow, temperature, pressure, time, ph, speed, production rate, inventory, weight, level, density, frequency, power, etc.) but staying within the safe operating range established by current operating procedures Modifying the packaging of raw materials, intermediates or products where the new packaging satisfies the requirements established for safe handling of the subject material Using alternative vendors as sources of a feed stock that meets all established purchase specifications Rearranging warehouse stock within established inventory limits, compatibility groupings and fire protection system capability Level 2 or Level 3 operations and technology changes satisfying the criteria for a Level 1 change Temporarily bypassing a process equipment item Addition of a new flow path Jumpered process or service piping for a production change Purchasing feedstock outside of established purchase specifications as a lower-cost alternative to the normal supply Changing to a more reactive material recommended by the traditional vendor Exceeding the maximum volume permitted for bulk storage of potentially hazardous materials Modifying process operating parameters (e.g. flow, temperature, pressure, time, ph, speed, production rate, inventory, weight, level, density, frequency, power, etc.) outside of current procedure limits but within previously-established safety, quality or operating limits Storing or using a new chemical Creating a new operating procedure Procedure changes Making minor editorial changes or typographical corrections to operating or maintenance procedures Use of OEM manual maintenance procedures Sampling at the same frequency, but at different time (assuming that other related activities are constant) Delegating authorization responsibilities to a properly qualified substitute Level 2 or Level 3 procedure changes satisfying the criteria for a Level 1 change Modifying operating procedures to change previouslyestablished safety, quality or operating limits or to reduce or eliminate operator rounds in an area Changing authorization requirements to eliminate a particular department from the approval process or modifying an existing authority delegation schedule to a lower level in the organization Eliminating a step in the approval of safe work permits Changing the frequency of flammable gas measurements required during hot work jobs Modifying operating procedures within previouslyestablished safety, quality or operating limits Relocating information on safe upper and lower limits, consequences of deviation, etc., from the operating procedure to a separate referenced document Making substantive formatting changes in the facility operating procedures Safety system changes Scheduling process outages as required to provide access to safety systems for inspection, testing and PM Recharging a fixed fire protection system with the same firefighting agent previously used Replacing an explosion relief vent panel with an identical unit from the same manufacturer Replacing a pressure relief valve with a new valve that is either identical to the original or meets all the relevant design and performance specifications established for the valve Operating a process with an essential safety system (e.g. interlock or pressure relief valve) out for maintenance but with alternative means of protection provided, as specified in the operating procedures Level 2 safety system changes satisfying the impact criteria for a Level 1 change Postponing scheduled safety system inspection, testing and PM activities Changing a fixed fire protection system (e.g. replacing a Halon system with a CO2 system) Adding an isolation valve beneath a pressure relief valve or modifying the inlet or discharge piping Installing new equipment within the discharge path of an explosion relief vent panel or redirecting the discharge of a pressure relief valve Increasing or reducing the relieving pressure of a pressure relief valve or the burst pressure of an explosion relief vent panel Continuing operation with an essential safety system (e.g. interlock or pressure relief valve) out of service but with no alternative means of protection provided Note: Level 3 authority not appropriate for safety system changes Changes in inspection, testing, PM Changing to another brand of lubricant that meets the specifications established for the particular service required Decreasing the test interval for a process interlock Reassigning inspection, testing and PM tasks to comparably qualified personnel within the same work group Level 2 or Level 3 inspection, testing, PM changes satisfying the criteria for a Level 1 change Changing to a lubricant that is outside current specifications Increasing the test interval for a process interlock Reassigning certain maintenance tasks from maintenance personnel to operators Discontinuing certain inspection, testing and PM tasks Postponing a unit turnaround beyond the prescribed run time limit Reassigning inspection, testing and PM tasks to comparably qualified personnel in a different work group Increasing inspection frequency based on accepted engineering methods (e.g. remaining life calculations) in accordance with established facility procedures Changing the inspection method (including the installation of online monitors that transmit readings to the DCS) Page 9 of 10

10 Replacement in Kind Level 1 Change Level 2 Change Level 3 Change Change Category Impact Description: Not a change no MOC required Approval Authority: No approval required Impact Description: Change affecting multiple plants, departing from KUC or industry standards, or potentially affecting Rio Tinto or external stakeholders Approval Authority: Chief Operating Officer, Area General Manager, Area Manager, Department Superintendent, Technical Manager, Asset Management Manager, Safety/Health Advisor, Environmental Engineer, Subject Matter Experts (as required) Impact Description: Change with the potential to affect process safety information, regulatory compliance or product quality Approval Authority: Area General Manager, Area Manager, Department Superintendent, Technical Manager, Asset Management Manager, Safety/Health Advisor, Environmental Engineer, Subject Matter Experts (as required) Impact Description: Organizational change, document format change, change made within preestablished and accepted limits; change not affecting process safety information, regulatory compliance or product quality Approval Authority: Area Manager or Department Superintendent Installing new lighting or a new type of fixture in an electrically classified area Making a repair or replacement to a lighting, building or utility system that conforms exactly to the original design specification Adding occupancy or increasing existing occupancy within the existing consequence zone for process incidents Modifying or demolition of existing process buildings Relocating lighting in a process area Site infrastructure changes Providing a new building or relocating personnel within existing buildings when the buildings are beyond the consequence zone for process incidents (e.g. fire, explosion, toxic release, etc.) Level 2 or Level 3 site infrastructure changes satisfying the criteria for a Level 1 change Installing a new road or changing the drainage, width or shoulder elevation of an existing road Modifying building HVAC systems Temporary closure of a major road Changing delivery routes through the plant Repaving an existing road while maintaining existing drainage, shoulder elevation, width, etc. Increasing steam header pressure Switching to an off-site supply of a critical plant utility Adding a branch connection to an existing utility system Organizational & staffing changes Reassigning emergency response roles among equally capable personnel Replacing an employee with a comparably qualified employee (or providing suitable overlap between the incoming and outgoing employees to allow the new employee to gain the needed qualifications) Replacing the current maintenance contractor with another qualified contractor Promoting a properly qualified operator to advanced operator Note: Level 1 authority not required for organizational and staffing changes Disbanding plant emergency response capabilities in lieu of centralized or municipal emergency response agencies Modifying the contractor screening protocol Changing the frequency of refresher training Revising the qualifications for incident investigation leaders Eliminating shift supervisors and moving to a selfdirected workforce concept Reassigning personnel from one shift team to another while maintaining the same basic staffing structure Changing from an 8-hour shift schedule to a 12-hour shift schedule Increasing or reducing the number of operators on a shift Changing from centralized maintenance to decentralized maintenance Changing the qualifications for advanced operator Policy changes Clarifying or reinforcing existing standards and policies Revising KUC HSEQ standards Revising KUC HSEQ policies Revising existing plant-level HSEQ policies Creating of new plant-level HSEQ policies Revising existing plant-level policies Creating new plant-level policies Page 10 of 10