Management of Change. Supersedes: 8/21/15 (Rev. 06) Preparer: Owner: Approver: EHS Team Member EHS Team Member EHS Manager

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1 Procedure No.: PA Page: 1 of 40 Port Arthur, TX. Reviewed: 2/16 Effective: 3/4/16 Supersedes: 8/21/15 Preparer: Owner: Approver: EHS Team Member EHS Team Member EHS Manager Document Revision Change Table Revision Number Revision Description Revised By Revision Date 01 Changed Header and Footer & add related document reference VB 06/08 to BWP-001 Corporate MOC Work Process. 02 Referenced PA EHS Documentum Procedure TF 10/08 03 PSSR changes for Engineering projects; Section 1 Purpose DS 7/29/09 change 04 Section D Additional guidelines for updating equipment DS 8/26/10 files in MOC Process Section Procedure changes DS 2/14/14 05 Section 4.15 Risk Assessment Section Temporary Changes 06 Changed to remove Mockingbird and replace with MD 8/21/2015 SuccessFactors. 07 Full Procedure Review and Changes BLM 02/03/2016

2 Procedure No.: PA Page: 2 of PURPOSE This procedure outlines the requirements for the (MOC) processes at BASF Total Petrochemicals LLC (BTP). It is intended for use with the Lotus Notes Change Manager system. Other systems can be used, but they must contain the equivalent elements outlined in this procedure. Additionally, if another procedure, permitting process, or policy exists to manage specific changes, it may be used in lieu of this procedure when it complies with all applicable regulatory requirements and/or BASF required procedures (PSM/RMP regulatory requirements and G-P-PRS-010M). This procedure applies to changes that impact a process (including those covered under OSHA PSM regulations or EPA RMP regulations as well) as all capital projects. It establishes minimum requirements for managing the installation of and modifications to equipment, facilities, procedures, chemicals, and technology to assure that any impact to safety/health, the environment, and/or changes to facilities/stationary sources that affect a PSM/RMP covered process are properly evaluated prior to implementing a change. This procedure is not required for changes that are deemed replacement in kind. 2. DEFINITIONS 2.1. Change A change (other than replacement in kind) includes changes to the technology of manufacturing, process chemicals, and process equipment, or a change in the procedures of operating and maintaining the process and related equipment that can affect personnel safety, health, the environment, or is a change outside of established safe operating parameters. Changes can also include organizational/personnel changes and changes to facilities/stationary sources that affect a covered PSM/RMP process. Examples of changes are: Chemical/Technology Change A change to process chemicals and/or technology that modifies operating conditions outside of predefined safe operating limits. Examples include but are not limited to: set point changes, interlock logic revisions, alarm or interlock set point revisions (if outside preestablished safe operating limits), interlock bypasses, maximum production rates, introduction of new chemicals including chemical reintroduction, chemical substitution, changes to maximum intended inventories of chemicals that may exceed threshold levels or cause a chemical to no longer exceed a threshold level. Additionally, this could include changes in temperatures, pressure, chemical concentrations, suppliers, or methods of material handling of currently approved materials. This could also include the inadvertent mixing of chemicals that might pose a hazard.

3 Procedure No.: PA Page: 3 of DEFINITIONS cont d 2.1. Change cont d Chemical/Technology Change cont d Note that per BC , any modifications to a safety instrumented function require a hazard analysis with participation of the PS CoE and/or EHS Hub to be carried out to determine the impact on functional safety as a result of the proposed modification Emergency Change Immediate actions used to avoid or control an emergency situation. An emergency situation is one in which action must be taken immediately to avoid danger to safety, health, the environment, the community, and/or significant equipment damage or production loss. The Emergency Checklist (reference Appendix B) in the Change Manager Database should be utilized for Emergency Changes Equipment Change The change of or addition to piping, piping components, pumps, compressors, exchangers, vessels and related electrical / instrumentation components associated with a process that is outside of the current equipment, piping, or design specifications. Included are maintenance/i&e projects and repairs that are other than replacement in kind. Examples could include: new piping/equipment installation, piping rearrangements, equipment revisions, equipment demolitions, new materials of construction/design specification, design parameters, impairment of fire water systems, impairment of alarm systems. Procedure PA Impairment of Fire Protection shall be used for equipment changes that result in an Impairment of Fire Protection Facility/Stationary Source Changes Changes to buildings (including temporary installations), containers, process/emergency equipment location, or equipment that contains a process. This also includes changes involving installations or changes to emission points or stationary activities located on one or more contiguous properties; and from which an accidental release could occur from or could be impacted by. Reference the Port Arthur Facility Siting procedure for further information.

4 Procedure No.: PA Page: 4 of DEFINITIONS cont d 2.1. Change cont d Personnel/Organizational Changes Includes changes to the organization where significant roles and job responsibilities are modified. Checklist for OMOC Considerations is located in Attachment C of this procedure Procedural Change The modification or addition of procedures that affect operations outside of previously established safe operating parameters (pressure limits, temperature ranges, flow rates, etc.) or any change (in any phase of operation) that may affect safety or the environment. Such procedures include start-up / shut-down, normal operations, nonsteady state operations, emergency operations, emergency shutdown, temporary operations, storage or handling, limits of operation/consequences of deviation, or safe work procedures. Additionally, procedural changes include changes to maintenance/inspection procedures. Electronic Document Management System (Documentum) In lieu of using Change Manager for Procedural Changes, the Port Arthur site uses an equivalent method via Documentum Workflows. Changes to procedures are initiated by requesting a work flow; the change coordinator then edits the procedure and routes it to a qualified technical reviewer and/or department manager to review and evaluate impacts to safety and health and subsequently approve or reject. Approved procedural changes are then routed through the Learning Management System (LMS)-Success Factors to train affected employees. Note: A Publish Only workflow in Documentum can be used for changes that are administrative in nature including procedural clarifications, formatting and/or procedure grammar corrections ONLY Replacement-in-Kind A replacement (an item, equipment, chemical, procedure, etc.) which satisfies the design specifications in the pre-existing, established Process Safety Information.

5 Procedure No.: PA Page: 5 of DEFINITIONS cont d 2.1. Change cont d Replacement-in-Kind cont d Examples: Equipment (Vessels, Pumps, Agitators, Heat Exchangers, etc.) fabricated exactly to the original design and specification or existing approved design and located in the same position as the original. Equipment and materials that are manufactured by an approved supplier to a standard specification, such as bolts, gaskets, flanges, piping, insulation, structural steel. Instrumentation transmitters, pressure and temperature gauges, etc., of the same specification and range, and purchased from an approved supplier. Electric motors and fuses of the same specification from an approved supplier. Replacement of piping with the same specification, size, flange makeup and routing as the existing Temporary Change A change that is planned for a limited duration, put into effect for trial or evaluation, or the bypassing or jumping of a safety system for maintenance. This does not apply to regular preventive maintenance that has established approved written procedures to follow that identify the alternate control measures to follow when the safety system is not functional Change Coordinator The individual assigned to a particular change, responsible for coordinating all aspects of the change. The Change Coordinator ensures that each component of the MOC and PSSR is adequately addressed, maintains appropriate documentation, obtains necessary approvals and training signoffs prior to the change, and tracks all related action items to completion. The Change Coordinator is also responsible for ensuring that the startup date and time are accurate and that affected employees are notified upon actual startup (and termination if temporary) of the change. Change Coordinators must be knowledgeable in the requirements of this procedure as well as the Port Arthur PSSR Procedure.

6 Procedure No.: PA Page: 6 of DEFINITIONS cont d 2.3. Change Manager Change Manager is a Lotus Notes-based database used by BASF Corporation for managing the MOC process. Change Manager is a module within the EHS Manager database. For the purposes of this procedure, other methods for managing change are considered equivalent Change Request The individual who is requesting the change. This person can be any employee and is responsible for assigning the Change Coordinator EHS Reviewers The HUB EHS Specialists (Environmental and Safety (PS/OSIH)) are notified of all changes once they are Approved to Proceed and serve as a reviewer for potential safety or environmental impacts (in addition to the Change Coordinator). In addition, EHS Specialists can be listed as an additional approver on Tab Facility/Stationary Source The buildings, containers or equipment that contain a process/process materials. This also includes installations or substance emitting (emission point) stationary activities which belong to the same industrial group, which are located on one or more contiguous properties, which are under the control of the same person or persons, and from which an accidental release could occur or impact Hazard Review Determination An initial review is conducted at the beginning of the MOC process to determine the impact of the proposed change. This review can be either formal or informal based on risk. To determine which level of hazard review is necessary, the Change Coordinator must fill out the risk level assessment, document the hazards in the mode of failure, and do a raw risk on the hazards identified.

7 Procedure No.: PA Page: 7 of DEFINITIONS cont d 2.8. Hazard Review, Formal A hazard review that requires a multidiscipline team including Process Operations, Engineering, EHS and/or other disciplines as needed. This could be equivalent to a BASF capital project safety review. All capital projects should have a formal hazard review regardless of Risk Level, as per BASF corporate procedure. See section 4.2 for information on what type of formal review is required Hazard Review, Informal A hazard review that may be done with two or more individuals, typically the change manager and approving manager, and involves a review of the hazards and documentation of them via the mode of failure method or by conducting some other type of documented review and including in the MOC as per the Step Review/PHA/Other method. See section 4.2 for more information Pre-Startup Safety Review (PSSR or Step 4) A systematic review of new or modified facilities performed at mechanical completion prior to startup or the introduction of regulated PSM/RMP chemicals. PSSRs must be performed for all new facilities/stationary sources (see definition in Section 2 above, this includes equipment) and for modified facilities/stationary sources when the modification is significant enough to require a change in the process safety information. This review ensures that: Construction and equipment is in accordance with design specifications; Safety, operating, maintenance, and emergency procedures are in place and are adequate; For new facilities/stationary sources (see definition above), a process hazard analysis (which meets PSM/RMP regulatory expectations for regulated facilities) has been performed and recommendations have been resolved or implemented before startup; and modified stationary sources meet the requirements contained in management of change; and, Training of each employee involved in operating a process has been completed. By performing these reviews the site meets the requirements of the OSHA PSM standard, EPA RMP regulation, and fulfills Responsible Care commitments.

8 Procedure No.: PA Page: 8 of DEFINITIONS cont d Pre-Startup Safety Review (PSSR or Step 4) cont d New facilities or extensively modified facilities that are covered by a capital project must follow the Step Review Process. If the change goes through the capital project review steps, Step 4 (PSSR) is recommended to be attached to the PSSR Tab in Change Manager to serve as documentation of the PSSR, but must be available in the Capital Project Job Book files. BC should be followed for Capital Project Reviews, including Step 4 procedures Process Safety Management (PSM)/Risk Management Program (RMP) Regulations set forth by OSHA at 29 CFR (PSM) and EPA at 40 CFR Part 68 (RMP) to govern industry and their highly hazardous chemicals/regulated flammables and toxics in attempt to prevent or minimize consequences of catastrophic releases of chemicals Technical Reviewer For the purposes of the Change Manager system, the Technical Reviewer is an individual who may be assigned the task of reviewing the feasibility of a change prior to change approval. This usually applies only to non- capital changes since the capital investment process includes a formal technical review. The decision to conduct a local technical review is that of the change coordinator or unit change approver Unit Change Approver The individual responsible for approving various aspects of a change request. The Unit Change Approver (typically Area Manager) approves the initial change request, helps identify other requirements, and specifies if other technical approval is necessary. For changes not involving production units, the unit approver should be the person that the change coordinator deems most appropriate. For production units, the Unit Change Approver is the unit s Operations Manager (or Operations Director, or Other designee.) Unit Final Approver The Unit Final Approver is the individual responsible for providing final approval of the change. This is typically the same role as the Unit Change Approver but other approvers can be listed at the discretion of the Change Coordinator, Area Manager or Director on Tab 7 for Startup Approval.

9 Procedure No.: PA Page: 9 of SCOPE This entire policy applies to changes as defined in Section 2 Definitions, with the exception of replacement in kind, at the Port Arthur site. The tool currently used is the Change Manager module of the EHS Manager database, accessible by employees through Lotus Notes. The EHS Department is the owner of this procedure and its contents; however, each area manager is responsible for implementing and overseeing compliance with the requirements of this procedure. Further, all employees have the responsibility to recognize a change before initiating it, initiate the MOC per this procedure, assist in making changes, participate in training, and provide input in maintaining a safe working environment. 4. PROCEDURE 4.1. MOC Origination: Initiating a MOC (Change Manager Tab 1) Any person can initiate or recommend that a change be made. Minimal information, specifically, a description of the proposed change, the technical basis of the proposed change, expected impact on the safety and health of the employees affected by the proposed change, and the duration of the change should be provided. Any change will require completion of Tab 1, the Definition section of the Form. MOCs should be initiated as early as possible before start-up to allow for adequate time to review and approve the MOC. Emergency Changes Emergency changes are immediately implemented. Once resources become available during the emergency, or after the emergency situation is averted, the remainder of this MOC procedure must be carried out. This procedure should be followed typically within no more than 72 hours of implementation of the emergency change. Temporary changes A fixed expiration date, and the limiting conditions for the change, must be set for temporary changes in the initiation phase. These changes must be tracked to assure the approved time is not exceeded. Tracking the changes can be done by the Change Coordinator or other designated person. Restoration of the process to the original status can be verified with a second PSSR if necessary.

10 Procedure No.: PA Page: 10 of PROCEDURE cont d 4.1. MOC Origination: Initiating a MOC (Change Manager Tab 1) cont d If the change must remain longer than originally planned, the MOC must be reviewed to ensure there are no subsequent impacts since the original change was initiated, the date must be extended in Change Manager and a reason for the extension must be documented or the change must be made permanent. It is recommended that the extension evaluation include a multi-discipline team as appropriate. The extension evaluation can be formal or informal. Tab 8 must be used to document the date that a temporary change ended or to mark the change as permanent. Capital Projects in Change Manager In Change Manager, mark yes to signify the change is a capital project in Tab MOC Development (Change Manager Tabs 2, 3, & 4) Overall Responsibility for Implementation The Change Coordinator has overall responsibility for implementing the entire MOC procedure. The Change Coordinator evaluates the proposed change and identifies information that must be modified for the particular proposed change. Hazard Review Requirements All MOCs should include an assessment on the impact to safety, health, and the environment. The goal of an initial hazard review is to determine what and whom the proposed change will affect and determine what type of hazard review (informal or formal) should be done. First, the Change Coordinator must fill out the Risk Level Assessment in Tab 3 of Change Manager as a tool to help him/her assess the risk. The Change Coordinator should ask the appropriate personnel to help him/her fill out the risk level assessment if he/she is not knowledgeable in the answers him/herself. Secondly, the Change Coordinator should utilize Table 1 below as a guideline to determine what type of hazard review is needed depending on the outcome of the risk assessment. If the risk level is low, i.e. results in an a level 1 or 2, including if all of the questions in the risk assessment are answered no, the Change Coordinator must utilize the Mode of Failure

11 Procedure No.: PA Page: 11 of PROCEDURE cont d 4.2. MOC Development (Change Manager Tabs 2, 3, 4) cont d Hazard Review Requirements cont d method to document the hazards identified and the existing or needed control measures. Even if all of the answers to the risk assessment are answered no, there still may be other safety, health, or environmental hazards that need addressed. As noted at the bottom of Table 1, electing to perform a formal team hazard review as opposed to utilizing the Mode of Failure method for level 1 and 2 risks is acceptable (and in some cases preferred.) If the risk assessment results in a level 3 or 4 (equivalent to High or Critical Risk on Mode of Failure), then the hazards will need to be reviewed and documented via a formal hazard assessment or PHA if applicable. If the change is a capital project, then the step review process will be followed in lieu of doing the mode of failure method/formal PHA. The only time a formal hazard review is not completed is when a capital project step review waiver has been granted in which case a Mode of Failure analysis can be utilized. In all cases, any supporting hazard/safety review documentation should be attached in Tab 3, including the meeting minutes for capital projects and open action items should be documented in Tab 4. Additionally, per BC , any modifications to a safety instrumented function require a hazard analysis with participation of the PS CoE and/or PS Hub to be carried out to determine the impact on functional safety as a result of the proposed modification. The Change Coordinator should assemble a team with the individuals shown in Table 1 in order to do the hazard review and document the hazards in the format indicated (mode of failure or Hazard Review). The team should address each risk noted during the risk assessment and any additional hazards presented or potentially presented by the change. Even if all of the answers to the risk assessment are answered no, the team should document any other safety, health, or environmental hazards that need addressed. The Keyword Checklist used during Capital Project Reviews is an excellent tool to use to help identify hazards. If no additional areas for consideration can be identified, then a statement that no additional EHS impacts could be identified is recommended to be documented in Tab 3. Note that if any of the hazards may require significant training of Operators or personnel, it is recommended to include the area Learning and Development Coordinator in the hazard review.

12 Procedure No.: PA Page: 12 of PROCEDURE cont d 4.2. MOC Development (Change Manager Tabs 2, 3, 4) cont d Hazard Review Requirements cont d It is recommended that to evaluate the risk appropriately or determine the control measures as necessary (and documentation required), the team should utilize the Corporate Risk Matrix and evaluate the raw risk of each hazard. If the raw risk determination results in a higher level of risk than the initial risk level assessment, units must follow the hazard review type and documentation requirements as shown in the column of the accurate raw risk determination level. For example, if a risk level assessment is level 2 and the raw risk rank determination level results in a C risk, a Formal Hazard Analysis must be done and an update must be made to the PHA (or a new PHA must be done) which is what is in line with a level 3 risk. The appropriate type of hazard review should be performed and hazards should be documented accordingly. If a capital project review or PHA is required, meeting minutes or a PDF of the PHA should be attached in the Attach Associated Documents section of Tab 3. If controls being documented in the mode of failure method are needed, then action items should be entered under the checklist on Tab 4 under add additional action items. Finally, the names of the individuals involved in the hazard analysis/hazard review must be documented at the bottom of Tab 3 in the box called reviewers for impact on safety and health.

13 Procedure No.: PA Page: 13 of 23 Risk Level from Risk Level Assessment TABLE 1 (HAZARD REVIEW MATRIX)-GUIDELINES Hazard Mode of Failure Analysis Raw Method Result Risk Corporate Risk Matrix Guide * Personnel Required for Involvement in Hazard Review Hazard Review Type PSSR Form Level 1-All Change Coordinator N/A N/A-No risk has Informal; PSSR Short questions and one other person been documenting NA Form (tab 4) answered no must agree that there identified Low in the Mode of and no other are no hazards Risk Failure section is hazard presented by the sufficient identified change and document NA in the mode of failure method section Level 1 (at least one question was answered yes or a hazard is identified but not listed in the risk level assessment) Change Coordinator and one other person who is familiar with the process F, E Low Risk Informal; document using Mode of Failure ** PSSR Short Form (tab 4) Level 2 Change Coordinator, EHS, Operations/Process Engineering, other disciplines as necessary. D Medium Risk Informal; document using Mode of Failure ** PSSR Short Form (tab 4), Long Form Optional Level 3 Level 4 Level 4 Formal Hazard Review (PHA/Step Review Equivalent) Formal Hazard Review (PHA/Step Review Equivalent) Formal Hazard Review (PHA/Step Review Equivalent) C High Risk Formal; PHA update; new PHA or Step 3 B High Risk Formal; PHA update new PHA or Step 3 A, A/B Critical Process Formal; PHA update new PHA or Step 3 PSSR Short (tab 4) and Long Form PSSR Short (tab 4) and Long Form PSSR Short (tab 4) and Long Form *The Guidelines listed are intended to be equivalent to the table in Tab 3 under Mode of Failure Evaluation View Risk Level If the raw risk determination results in a higher level of risk than the initial risk level assessment, units must follow the hazard review type and documentation requirements as shown in the column of the accurate raw risk determination level. Example: If a risk level assessment is Level 2 and the raw risk rank determination level results in a C risk, a Formal Hazard Analysis must be done and an update must be made to the PHA/a new PHA/Step 3 Equivalent review should be done. **It is also acceptable for operating units to elect to document the change and the hazards in the PHA Documentation rather than using the Mode of Failure method. Ensure documentation as appropriate is included or referenced in the PHA.

14 Procedure No.: PA Page: 14 of PROCEDURE cont d 4.2. MOC Development (Change Manager Tabs 2, 3, 4) cont d Information that Should be Evaluated During the Hazard Review Verifies that the proposed change does not violate existing safeguards in the relevant PHA nor creates a potential hazard scenario Technical feasibility of the proposed change Technical justification and necessity of the change The necessary time period to implement the change Adequate design information/specifications to perform a valid review (based on group judgment and knowledge of the process) Whether modifications to written procedures are required (including time limit for temporary changes) The expected duration of the change for temporary changes. It is the responsibility of the Change Coordinator to document all significant comments, regardless of the method used to collect them. It is highly recommended that all significant comments from the hazard review should be documented within and/or attached to the MOC so they reside with the rest of the MOC documentation. Unit Approval (Tab 2) For changes not involving operating production units, the unit approver should be the person that the change coordinator deems most appropriate. For production units, the Unit Change Approver is typically the Operations Manager. In the event that the Area Manager is absent, the Area (e.g Operations) Director or Area Manager Designee may have the authority to assume responsibility for the Area Manager. Alternate technical reviewers and approvers can be named at the discretion of the Change Coordinator and/or Area Unit Manager. Addressing Gaps in Information/Action Item Assignment During the required hazard review and while Tab 2 is being approved, the Change Coordinator should begin assigning tasks to responsible parties to address gaps in information or to accomplish tasks that will be required to implement the proposed change. Action items are to be assigned in Tab 4. This is also the start of the MOC implementation phase; see section 4.3 for more information.

15 Procedure No.: PA Page: 15 of PROCEDURE cont d 4.2. MOC Development (Change Manager Tabs 2, 3, 4) cont d PSSR Team Member Selection The hazard review team should determine who should be on the PSSR team and the names of those individuals should be documented in Tab 6 when Tab 6 gets completed. See Section 4.4 for more details on PSSR. Approval to Proceed to the MOC Implementation Phase If the unit change approver and any additional technical reviewers on Tab 2 approve the change, the MOC process enters the implementation phase. Changes that aren t approved for minor, correctable reasons are held for further work and review. If a change proves to be unworkable, the originator is notified of both the status and reasons MOC Implementation (Tabs 4 and 5) MOC Implementation Requirements The Change Coordinator takes the lead on implementation of the change. If affected, the following areas at a minimum must be completed during the implementation: Design and installation of the change Update of affected procedures, including operating, maintenance/mechanical integrity, or emergency procedures as applicable. Update of affected Process Safety Information (e.g. P&IDs, C&E Matrix, PSV Information ) Informing/training of all affected operations, maintenance, and contractor employees on the change (see Sec 4.5 Documentation) In order to confirm that all required information is properly updated, the Change Coordinator is required to consider how the change in question affects process safety information, operating procedures or mechanical integrity documentation. In the Change Manager system, Tab 4 is utilized to assign relevant action items. The majority of Tab 4 should be reviewed and filled out during the hazard review by the Change Coordinator and required team members. Tab 5 is utilized to assign the required training and document how the change is communicated to affected personnel.

16 Procedure No.: PA Page: 16 of PROCEDURE cont d 4.3. MOC Implementation (Tabs 4 and 5) cont d Action Items from Capital Project Reviews All uncompleted items resulting from capital project SHE/Step reviews should be entered into Tab 4 (creating an action item if one does not already exist in Tab 4). Operating Procedure Modifications Operating Procedure modifications may be modified through the Documentum Workflow Process as outlined in Section 2.7. Training Requirements: Who is Responsible The Change Coordinator is responsible for filling out the Training Tab (Tab 5) of the Change Manager MOC and should follow the same requirements/responsibilities outlined below. The Change Coordinator can delegate the Training Responsibilities as appropriate. It is the trainer s responsibility to determine when the appropriate time is to do the communication/training. Notifying and communicating the change too early may present a hazard in itself. Training must occur prior to startup (or prior to the employee returning to work on the affected job task/in the affected area), it is essential for the trainer to allow enough time for training of employees to occur. In addition, it is the responsibility of the Change Coordinator or designee to verbally or electronically notify employees upon the actual startup date/time of the change or of the actual termination of the temporary change. For Production Units and the TES Department, the Change Coordinator is responsible for filling out the Training Tab (Tab 5) of the Change Manager MOC and is responsible for coordinating the communication of the change/required training and ensuring that appropriate personnel are informed of/receive the appropriate training prior to the start of the change or prior to returning to work on job tasks that are specific to the activities/areas/equipment affected by the change, where appropriate The Change Coordinator or Designee (Trainer) will assign the required communication and training to the appropriate personnel depending on the risk level, type of change, and based on how the employee s job task will be affected. Note that PSM/RMP regulations state that employees involved in operating a process and maintenance and contract employees whose job tasks will be affected by a change in the process shall be informed of, and trained in the change prior to the start-up of the process, or affected part of the process.

17 Procedure No.: PA Page: 17 of PROCEDURE cont d 4.3. MOC Implementation (Tabs 4 and 5) cont d Training Requirements: Who is Responsible cont d If training is needed, the Change Coordinator is not always responsible for performing the actual training, but is responsible for determining what type of training is required, who should receive the training, ensuring that the appropriate person (Change Coordinator, LDC, Operations Manager, EHS) performs the training, and for ensuring that affected personnel are trained prior to the start of the change or prior to returning to work on the equipment/in the area affected by the change The Change Coordinator is responsible for ensuring that the correct documentation of the communication of the change/training is maintained. It is highly recommended that training documentation is attached/retained in the Change Manager MOC. A. Question 13 on Tab 5 may be utilized to ensure that affected personnel are informed of the change by obtaining the electronic signature of each affected employee. Employees receiving the notice via Lotus notes must be added at the bottom of Tab 5. In the event that another means of communicating the change is used, evidence that those affected by the change have been informed MUST be maintained. Examples of other means of proof of notification may include (these must be included with the MOC documentation): Hand written signatures and dates attached to a printout of the change Informal/Formal meeting where affected individuals are informed of the change. Attendance and date are documented for each meeting by meeting leader

18 Procedure No.: PA Page: 18 of PROCEDURE cont d 4.3. MOC Implementation (Tabs 4 and 5) cont d Training Requirements: Who is Responsible cont d B. Question 14 on Tab 5 should be marked yes when actual training needs to occur (more than just informing them of the change). Training must occur whenever a change affects the job tasks of an employee involved in operating a process, maintenance employees, and/or contract employees. As a rule of thumb, training usually should occur whenever there is a change to operating procedures, safety procedures/safe work practices, maintenance/mechanical integrity procedures, process overview (including changes to process hazards and chemicals), emergency response procedures and the emergency response plan. However, there may be other reasons for why training should be done and/or may involve other personnel. If Question 14 is marked yes, an attachment of the training and/or a detailed description of the training must be documented in the Additional Training Information box. Additionally, the Change Coordinator must document the means that were used to assess that the employees understood/were competent in the training material and have no further questions (ex. Written test, verbal test, observation/demonstration, etc). Each name of those receiving the training and the date of the training must be documented. The electronic signoffs via lotus notes may be used to certify that each employee received the training and has no further questions, or a statement of similar nature should be put in this box. When handwritten signatures are obtained, they should be attached. C. Examples of proof of training may include (these must be attached/referenced in the MOC): Computer Based Training and records of test results (ex. LMS) and the CBT name is referenced in the MOC. Informal/Formal meeting where affected individuals are trained on the change. Attendance and date are documented for each employee by meeting leader and a copy of the test questions is attached.

19 Procedure No.: PA Page: 19 of PROCEDURE cont d 4.3. MOC Implementation (Tabs 4 and 5) cont d Training Requirements: Who is Responsible cont d The description of the type of training, copy of verbal or written test questions and/or certification that observation/demonstration was used as type of competency testing, and the hand written signatures of employees receiving the training. Attachment of powerpoint slides of the training with questions at the end and documentation of handwritten signatures Attachment of training description and written test questions with signatures D. In the event that an employee is on vacation or not on shift during the time of the change, the Change Coordinator or Designee should document in the training tab of the MOC the means for ensuring that those employees receive training prior to returning to work (on the affected job task). This may involve Shift Supervisor s in the training process to help ensure that all shifts are trained prior to returning to work. Exceptions to obtaining all sign offs prior to the startup date of the change (whether via lotus notes, CBT, or hand written) must be addressed and it must be ensured that all affected employees are trained prior to working in the affected area/performing the affected task. If an employee will be out for an extended time, the trainer may keep a record outside of Change Manager of all MOCs that occurred during his/her absence and train him/her upon returning to work. Proof of his/her training should be kept in his/her training files PSSR (Change Manager Tab 6) Determining if a PSSR is Required A PSSR is required for all new facilities/stationary sources (see definition in Section 2, this includes equipment) and modified facilities/stationary sources when the modification is significant enough to require a change in the process safety information.

20 Procedure No.: PA Page: 20 of PROCEDURE cont d 4.4. PSSR (Change Manager Tab 6) cont d Assembling the PSSR Team Members Right before Startup, the Change Coordinator is responsible for organizing and conducting a PSSR with the appropriate team members. A PSSR team may consist of: EHS Team Member Project Engineer/Manager Operations/Process Engineer Manufacturing Representative Maintenance Representative Unit Operator I&E Engineer During the hazard review, the PSSR team should be identified. For minor modifications (Level 1 (low or no risk)), a minimum of two people can perform the PSSR. The PSSR team members must be documented in Tab 6. How to Determine Which PSSR Form to Use Use the results of the Risk Level Assessment/Hazard Review to determine the proper PSSR form to be completed (see Table 1). The relationships are as follows: Risk Level 1 Short form PSSR is required Risk Level 2 Short form PSSR is required, Long Form Optional. Risk Level 3 Long Form PSSRs are required. Risk Level 4 Long Form PSSRs are required. Short form refers to the PSSR checklist that is built into tab 4 of the Change Manager module. Long form refers to the Site PSSR Long Form checklist (See PA PSSR Procedure). When the Long form is used, it must be attached to the MOC in Tab 6 or the location referenced. The PSSR Long Form should be modified (items added) to address the scope of the change as appropriate. Preparing for the PSSR An initial review of the PSSR documentation should occur early on in the process/project (hazard review team or capital project review team can do this) so action items can be appropriately assigned in the Action Tracker system with sufficient time for completion prior to the date of the PSSR and field walkthrough (when required).

21 Procedure No.: PA Page: 21 of PROCEDURE cont d 4.4. PSSR (Change Manager Tab 6) cont d Determining if a Walkthrough is Required Schedule the field verification walkthrough. Walkthroughs are required for every MOC that results in observable changes. Changes that do not result in physical modifications to the unit (ie. Interlock additions, DCS programming changes, SABL program modifications, etc) do not require a walkthrough. For example, piping modifications and observable DCS changes will require a field walkthrough. Responsibilities of the PSSR Team The PSSR team should review the status of any action items/open issues from the MOC, Step 3, PHA, or EHS reviews with the team. In addition, the status of PSSR action items should be reviewed The team should perform a walkthrough of the implemented change. During this walkthrough, any deficiencies or open items should be noted. These deficiencies should be assigned action items in Tab 4. It is not preferred to use the walkthrough punch list on Tab 6, as action items can t be assigned here. A. The PSSR team should verify that all items marked as Pre- Startup items, including those under Items to complete prior to startup on Tab 4 and the informing/training of employees as designated/documented in Tab 5, has been completed or appropriately addressed. Additionally, the team should verify that the technical basis for the proposed change has been accurately documented on Tab 1, the impact of the change on safety and health and the reviewers have been documented in Tab 3, the modifications to operating procedures and P&ID redlines have been completed, and that the necessary time period for the change has been documented (if temporary). Further, the team shall verify the following:

22 Procedure No.: PA Page: 22 of PROCEDURE cont d 4.4. PSSR (Change Manager Tab 6) cont d Responsibilities of the PSSR Team cont d Construction and equipment is in accordance with design specifications; Safety, operating, maintenance, and emergency procedures are in place and are adequate; For new facilities/stationary sources (see definition above), a process hazard analysis (which meets PSM/RMP regulatory expectations for regulated facilities) has been performed and recommendations have been resolved or implemented before startup; and modified stationary sources meet the requirements contained in management of change; and, Training of each employee involved in operating a process has been completed. B. The PSSR Team shall assign the startup date and time on Tab 6. This must be done before the MOC/PSSR can be sent to the final approvers. If this date and time changes after final approval is given, it is the responsibility of the Change Coordinator to update the date and time as appropriate. Additionally, the Change Coordinator should verbally or electronically notify all those trained/informed of the change of the official date and startup change. C. Once all open items designated as pre-startup items are complete, the MOC is routed to the Unit Final Approver for approval to startup. This is the final assurance that all before startup items planned have been implemented, and that all process safety information, all operating procedures, all training, and any other regulatory compliance documentation has been properly updated or triggered to be updated Final Approval (Change Manager Tab 7) General Final Approval Requirements The Unit Final Approver should not be the same person as the Change Coordinator.

23 Procedure No.: PA Page: 23 of PROCEDURE cont d 4.5. Final Approval (Change Manager Tab 7) cont d. Final Approval for Production Driven Changes For changes affecting Production Units, the required signature is that of the Unit Final Approver, the Operations Manager of the unit being affected by the change. In the event that the Operations Manager is the Change Coordinator, the Operations Director or Designee may be the Unit Final Approver. Or in the event that the Operations Manager is absent, the Area Director or Designee may have the authority to assume responsibility for the Operations Manager. Final Approval for Non-Production Driven Changes For changes other than those affecting Production Units, the Unit Final Approvers should be the Site Personnel with Management responsibility in the area conducting the change as appropriate In the event that one of the Final Approvers is absent, Final Approval may be delegated to the person in the next highest level of management or the person left in charge of the department while they are absent Temporary Change Completion & MOC/PSSR Closeout Temporary Change Completion Temporary changes must follow one of the following three completion options. The Change Coordinator or designated person identified as responsible for terminating the change in Tab 1 is responsible for this part: Change Removed all affected personnel must be notified by or other appropriate means. A second PSSR may be necessary to verify that the process is ready to be restored to the original status. Extend expiration date all affected personnel must be notified by , or other appropriate means, of the new expiration date. An additional hazard review may be necessary. Make Permanent A new MOC will be created and certain information copied into it.

24 Procedure No.: PA Page: 24 of PROCEDURE cont d After Startup Action Item Status Checks After approval and startup of the change, the Change Coordinator should check the status of all after startup action items and check the completeness of the MOC. Once the MOC has met completion, the Change Coordinator is responsible for closing out the MOC. MOC Close Out and Tracking Change Coordinator s should periodically review their MOCs in Change Manager to ensure that MOCs get closed out in a timely manner. It is highly recommended that MOCs be tracked to completion (on a visual board for example) in each unit s tiered meeting process 4.7. MOC Documentation Retention and Incorporation into PHAs Emergency changes, permanent changes, and expired temporary changes must be documented and retained for a period of at least five years. These changes will be used to assist in the revalidation of PHAs and to demonstrate compliance with applicable procedures and regulations. The Change Manager module is used to initiate, track and implement MOCs. Documentation Type All documentation is to be filed electronically with the MOC where feasible or put in an alternate accessible location and referenced in the MOC. The documentation will remain permanently with the MOC in the Change Manager system. 5. General Requirements 5.1. Changes that Impact Multiple Units/Departments Production units/departments implementing changes that may affect other units/departments have the responsibility to coordinate the changes with the affected units/departments Training Materials Training materials are available in Change Manager by selecting the? on the help button and choosing links titled Link to Training Materials on Change Manager and Frequently Asked Questions. The online help section for Change Manager is a good resource for questions concerning the Lotus Notes Change Manager database.

25 Procedure No.: PA Page: 25 of RELATED DOCUMENTS Procedure PA Impairment of Fire Protection Procedure PA Pre-startup Safety Reviews Procedure PA Job Book File Structure Attachment A -Emergency MOC Form Attachment B- MOC Organization Process-FLWCHART Attachment C -Guidance Checklists for Evaluation of Organizational Changes N-R-PRS 001 M Responsible Care-Process Safety

26 PA Title: EMERGENCY CHANGE SHEET Attachment A Responsibility: Date: Description of Change: Reason for Change: Potential Hazard to Personnel(s) Safeguard(s) YES Has written or verbal approval been given by a representative of operations and engineering? Are adequate procedures in place? Has a field inspection been completed? Operations Representative APPROVAL TO PROCEED WITH EMERGENCY CHANGE Maintenance Representative NOTE: Once the Emergency Change form has been completed, a (MOC) form shall be completed and circulated for approval. Effective: 3/16

27 PA Attachment B Need for change identified MOC form initiated Entered into MOC database and Tracking Number assigned MOC Form sent to OM (or designee) and fully completed Area OM (or designee) agrees to work scope NO Update MOC Database END YES Risk/Hazard Assessment Form completed Risk Level assigned based upon "Risk Assessment" form Contractor Operations MOC form only YES Level 1 Safety Checklist form YES NO Level 2 Maintenance Update Equipment Information/Files Update Procedures Train on new procedures/ programs NO **Manufacturing Rep required for process changes** Internal Safety Review YES Level 3 Environment, Health, and Safety Perform necessary reviews YES All necessary parties involved? Experienced Process Rep PHA Facilitator Operations (hourly) Formal PHA YES NO Level 4 Engineering Update Technology Infomation NO Distibution to affected groups Consult affected workers of change Appropriation Design Phase Procurement of equipment/ materials Work Performed OE/OM verified work completed PSSR based on risk level All "before" PSSR items closed YES OM verify ready for startup STARTUP Verify all "after" PSSR items closed Close MOC/PSSR and file Benefical Feedback NO END Effective: 3/16

28 PA Attachment C Basic Screening Checklist for MOC Determination Starting with a definition of the proposed change, this checklist can be used as a first screening appraisal of the type of change and consideration of the type of assessment(s) needed to evaluate the change, its potential impact and measures necessary, including possible rejection of the proposal. Y N Activity 1. Does the change add potential to increase, decrease, stop or reverse the flow in any system? 2. Can this change increase / decrease the max. operating pressure, or alter the MAWP of any equipment or system? 3. Can this change increase / decrease the temperature in process or equipment? 4. Can this change create flammable, reactive or chemical instability issues? 5. Can this change affect the composition of any stream? 6. Can this change increase corrosion or erosion rates anywhere in the system? 7. Can this change increase potential leak rates of materials to the atmosphere? 8. Does this change impact any start-up, shutdown, emergency or decontamination activities in the unit? 9. Could this change the way the operator / supervisor / staff interfaces with equipment or controls when reacting to system or process upsets? 10. Could this change have any effect on existing safeguards in the unit as defined by the unit PHA? 11. Could this change have any effect on existing safeguards in the unit as defined by the Emergency Response plan? 12. Does this change add new safeguards to the process or system? Directions for use: A yes response in any box indicates the need to complete an MOC along with the appropriate risk evaluation according to the NAFTA MOC Standardized process. Items shaded (numbers 8-12) represent specific OMOC considerations. Effective: 3/16 Page 1 of 13 Approved by: EHS Manager