Hazard Communication Program

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Standard No.: BCF020.050 Page: 1 of 11 RECORD OF REVISIONS Date Rev # Details of Change 9/15 2 Changed MSDS to SDS. The SDS terminology and format was adopted on May 25, 2012 in OSHA 1910.

1 Standard No.: BCF Page: 1 of 11 RECORD OF REVISIONS Date Rev # Details of Change 9/15 2 Changed MSDS to SDS. The SDS terminology and format was adopted on May 25, 2012 in OSHA Hazard Communication. Manufacturers, distributors, and importers of materials must complete the conversion from MSDS s to SDS s in Delete section 3.9 MSDS updated to SDS Delete section 3.7 Industrial Hygiene Manuals IH manuals no longer exist Delete all references to IH manuals throughout policy Under section 5.5 initial training (2) added how to access IH monitoring data through the Texas Hub IH coordinator, and how to access the Occupational Noise Exposure Standard.

2 Standard No.: BCF Page: 2 of PURPOSE Ensure that BASF employees and contractors are informed of the hazards associated with the chemicals used in their workplaces. Ensure that proper labeling and other forms of warning information are utilized in accordance with applicable Federal, State, and local regulations. Ensure that Data Sheets are available and utilized in accordance with applicable Federal, State, and local regulations. Ensure that training programs effectively inform BASF employees and contract employees of the nature of the chemical hazards present at the Freeport site, and comply with the requirements of Federal, State and local regulations. Ensure compliance with BWR-002, Occupational / Industrial Hygiene Work RACI. 2. SCOPE This standard applies to the BASF Freeport Site. 3. DEFINITIONS 3.1 Back-up DVD s for SDS s DVD s that are periodically provided to SDS/SDS Administrators and which contain copies of SDS s for materials in the electronic SDS databases. 3.2 Chemical Storage Tank Vessel used to contain a raw material, process chemical, product, or intermediate. This definition applies to Hazard only. 3.3 Container A bag, barrel, bottle, box, can, cylinder, drum, reaction vessel, storage tank, or the like that contains a hazardous chemical 3.4 Electronic SDS Databases Two separate databases that contain the controlled, electronic copies of SDS s. The first is for BASF manufactured products, by-products, and intermediates and is entitled, MSDS in SAP. The second is for non-basf products and is entitled,

3 Standard No.: BCF Page: 3 of 11 Non-BASF Products MSDS. Both databases are found on the MSDS Search page on the BASF Intranet. Attachments A and B contain additional information about these two databases. 3.5 Freeport Site Laboratory Label Label to be affixed to all laboratory in-house and commercial lab samples, and all dedicated in-house reagent containers. This label must follow one of the following formats. BASF CORPORATION FREEPORT, TX. R & D SAMPLE NON-COMMERCIAL BASF BASF NON-HAZARDOUS DATE: CONTENTS: SAMPLE OR CHEMICAL NAME: BASF CONTACT: DATE: PHONE: ORDER # NAME: PHONE: HAZARDS: FLAMMABLE CORROSIVE CHARGE: BLDG.: OXIDIZER TOXIC/SPECIFY UNKNOWN OTHER/SPECIFY LABEL FOR SAMPLES SHIPPED TO AN OUTSIDE LAB (BLUE) NON-HAZARDOUS SAMPLE AND REAGENT LABEL (GREEN) BASF HAZARDOUS DATE: CONTENTS: NAME: PHONE: DEPT.: BLDG.: CHG.: TOXICITY WARNING FLAMMABLE SKIN INHALATION CORROSIVE EYES INGESTION CARCINOGEN SENSITIZER

4 BASF Corporation Parsippany, New Jersey Proper Shipping Name: Standard No.: BCF Page: 4 of Hazardous Waste Label Label to be affixed to all containers containing hazardous wastes (color - yellow). 3.7 Laboratory Amounts Quantity of a chemical that can be easily and safely manipulated by one employee and is not used to produce commercial quantities of chemicals. 3.8 MSDS/SDS Administrator The person responsible for maintaining and updating the Non-BASF Products MSDS electronic database (see Section 3.2) for a site or block. This is the EHS Specialist. Training for MSDS/SDS Administrators is available from the OS/IH CoE. 3.9 National Fire Protection Agency (NFPA) Diamond Hazard label that follows the following format: X:\DATA\EHSWEB\ Docs\\lcm\c-std Health, fire, and reactivity hazards are ranked from zero to four - zero being least hazardous; four being most hazardous. Specific hazards are illustrated with graphics Non-Bulk Shipment Label Label affixed to all non-bulk shipments that follows the following format. BASF Product Name DANGER: FIRST AID: STORAGE AND HANDLING: SPILL OR LEAKS: FIRE: EMPTY CONTAINERS: DISPOSAL: CHEMICAL EMERGENCY: ATTENTION: D. O. T. HAZARD CLASS LABEL (IF REQUIRED) LOT NO. NET WT. Product:

5 Standard No.: BCF Page: 5 of Non-Hazardous Waste Label Label to be affixed to all containers containing non-hazardous wastes (color - green) Process Vessel Vessel in which chemical or physical properties of contents are altered (i.e. exchanger, reactor, etc). This definition applies to Hazard only SDS or Data Sheet Similar to a MSDS or Material Data Sheet. All SDS s have a standard format as defined in OSHA Hazard Communication. The SDS format and terminology and format was adopted by OSHA on May 25, Manufacturers, distributors, and importers of materials must complete the conversion from MSDS s to SDS s by June 1, RESPONSIBILITIES 4.1 It is the responsibility of the Texas Hub EHS Team to: Audit plant compliance to this standard. Maintain and update controlled copies of MSDS/SDS s in the Non- BASF Products MSDS database (see Section 3.2). Updates are based on chemical inventories supplied by operations, maintenance, and QA/QC laboratories, and will be conducted as necessary (at least annually) to ensure information is current. When the Non-BASF Products MSDS database contains MSDS/SDS s that are more than 3 years old, attempts should be made to replace them with more recent versions. Ensure that a battery-powered computer, DVD player, and printer are available in the site ambulance. Also ensure that the Back-up DVD s for MSDS/SDS s are available in the site ambulance. Ensure that initial, generic, hazard communications training for all new BASF employees is accomplished using the Mockingbird Online training courses. Assist business units with development of new MSDS/SDS s for BASF products, by-products, waste streams, and intermediates where appropriate. 4.2 It is the responsibility of all contractors to: Comply with the hazard communication requirements found in the Contractor Manual.

6 Standard No.: BCF Page: 6 of 11 Participate in unit specific safety and health orientations as necessary. Comply with the requirements of this standard. 4.3 It is the responsibility of the Production Execution Manager to: Ensure tank and container labeling satisfies the requirements of this standard. Maintain an up-to-date Vessel and Chemical Inventory that includes raw materials, products, by-products, intermediates, waste streams, catalysts, process additives, inhibitors, water treatment chemicals, heat exchange fluids, etc. that are found in process vessels and chemical storage tanks (see Attachment C for a suggested format and instructions). This inventory must also include process chemicals in unlabeled containers that do not have specific equipment numbers (e.g., 40 lb. bags that contain inhibitors; totes that contain additives; etc.). Provide an annual Vessel and Chemical Inventory update to the Texas Hub EHS Team. Conduct initial, unit/department-specific, hazard communications training that satisfies the requirements of this standard. Conduct periodic hazard communications training that satisfies the requirements of this standard. 4.4 It is the responsibility of the Area Maintenance Manager to: Ensure maintenance container labeling satisfies the requirements of this standard. Maintain a list of all maintenance chemicals (lubricants, oils, paints, cleaners, welding rods, etc.). Provide an annual update to the Texas Hub EHS Team. Supply the EHS Specialist and/or MSDS/SDS Administrator with MSDS/SDS s for all new maintenance chemicals. Conduct initial, task specific, hazard communications training that satisfies the requirements of this standard. Conduct periodic hazard communication training that satisfies the requirements of this standard. 4.5 It is the responsibility of Procurement & Logistics to: Ensure container labeling satisfies the requirements of this standard. Ensure non-bulk customers receive MSDS/SDS s with shipments. Conduct initial, task specific, hazard communications training that satisfies the requirements of this standard.

7 Standard No.: BCF Page: 7 of 11 Conduct periodic hazard communication training that satisfies the requirements of this standard. 4.6 It is the responsibility of the Laboratory Manager to: Ensure container labeling satisfies the requirements of this standard. Supply the EHS Specialist and/or MSDS/SDS Administrator with copies of MSDS/SDS s for all new chemicals. Conduct initial, task specific, hazard communications training that satisfies the requirements of this standard. Maintain a list of all laboratory chemicals. Provide an annual update to the Texas Hub EHS Team. Conduct periodic hazard communication training that satisfies the requirements of this standard. 4.7 It is the responsibility of the Business Groups and BASF Product Regulations Operations to: Evaluate hazards associated with all BASF products, by-products, and intermediates. Generate MSDS/SDS s for BASF products, by-products, and intermediates. Supply bulk customers with MSDS/SDS s Update and distribute MSDS/SDS s when there are new and significant changes in health or safety information. 4.8 It is the responsibility of BASF Freeport employees to comply with the requirements of this standard. 5. PROCEDURE 5.1 Hazard Evaluation Procedure 1. The hazard evaluations for BASF Freeport, Texas products are conducted by Corporate Toxicology and include information available from current toxicology databases and in-house toxicology and chemical property studies. 2. BASF Freeport, Texas relies on hazard evaluations and updates available from chemical manufacturers and distributors for all incoming chemicals.

8 Standard No.: BCF Page: 8 of Labeling 1. All chemical storage tanks must be conspicuously labeled with the vessel number, the contents, and a NFPA Diamond. Hazard information on storage tank contents is available from the Vessel and Chemical Inventory. Process vessels must be conspicuously labeled with the vessel number. Process vessels do not require a hazard label. Hazard information on process vessel contents is available from the Vessel and Chemical. 2. Unit Operations Manuals must be maintained and updated to reflect the existing operating parameters of the process. 3. Labels on incoming supplier containers must remain legible in their entirety. Any supplier label that has become illegible must either be replaced with a new supplier label or must be replaced with an inhouse label with the same information as the supplier label. 4. All in-house portable containers, including in-house and outgoing sample containers, and in-house lab reagent containers, must be conspicuously labeled with contents, and one of the following: NFPA Diamond Freeport Site Laboratory Label 5. All staged railcars and staged tank trucks used for temporary storage or as a temporary process vessel must be conspicuously labeled with the contents and a NFPA Diamond. Hazard information on temporary storage/process vessel contents is available from the Vessel and Chemical Inventory Sheet. 6. All in-house, non-waste drums and totes must be conspicuously labeled with the contents and a NFPA Diamond. Hazard information on in-house, non-waste drums/totes contents is available from the Vessel and Chemical Inventory Sheet. 7. In addition to hazard communication required labeling, all waste containers, must be labeled with the contents and one of the following (including accumulation period): Non-Hazardous Waste Label Hazardous Waste Label 8. All bulk shipments must be placarded according to DOT Requirements (40 CFR 172 Subpart F). 9. All non-bulk shipments must be conspicuously labeled with a Non- Bulk Shipment label (Hazard Class Label/Placard must satisfy 40 CFR 172 Subpart E & F).

9 Standard No.: BCF Page: 9 of Multiple container areas or holders with the same contents may be bulk labeled with a single label (i.e. drum staging areas, auto sampler trays, sample holders, etc.) 11. Containers used by a single employee during a single shift do not require labeling. 12. Labeling may be accomplished through the use of signs, stickers, or stencils. Logbooks, lab book sample logging systems, Request for Analysis forms, or Developmental Request Order forms may be used for lab apparatus or other lab containers. 13. If a container has a DOT label/placard and a Hazcom label, labels must be located on the container so that the information on each label does not detract from the information on the other. 14. All containers required to be marked, labeled, or placarded per DOT Hazardous Materials Regulations (49CFR ) must remain marked, labeled, or placarded until the container is sufficiently cleaned of residue and purged of vapors to remove any potential hazards. 5.3 MSDS/SDS Availability 1. Information regarding production chemical hazards is available at all times in the electronic MSDS/SDS databases (see Section 3.2). 2. Information regarding maintenance chemical hazards is available at all times in the electronic MSDS/SDS databases (see Section 3.2). 3. Information regarding laboratory chemical hazards is located in the electronic MSDS/SDS databases (see Section 3.2). 4. In the event of a computer network outage or power outage, all MSDS/SDS administrators have back-up DVD s for the Non-BASF Products MSDS database. In addition, the site ambulance has a battery-powered computer, DVD player, printer, and back-up DVD s for the Non-BASF Products MSDS database and the MSDS in SAP database (BASF Products). 5. Materials that are no longer used shall be not be deleted from the electronic MSDS/SDS databases by the EHS Specialist and/or the MSDS/SDS Administrator. Instead, obsolete materials shall be archived (disassociated) in order to comply with OSHA and BASF records retention requirements. 6. When chemicals must be listed on work permits, permit issuers shall always use full chemical names, not abbreviations or codes. This will make it easier for permit acceptors to locate and consult MSDS/SDS s.

10 Standard No.: BCF Page: 10 of MSDS/SDS s for new materials 1. Employees requesting the introduction of new chemicals not previously used on the Freeport site are responsible for ensuring that all new chemicals delivered to the Freeport site are accompanied with a current manufacturer's MSDS/SDS or are preceded by a current manufacturer's MSDS/SDS. In addition, the Freeport Management of Change procedure BCF Attachments 1 and 2 must be followed for all new chemicals. 2. The employee requesting a new chemical must forward the new chemical's original manufacturer's MSDS/SDS to the EHS Specialist and/or the MSDS/SDS Administrator. 3. For process chemicals, the new chemical's identity must be added to the Vessel and Chemical Inventory sheet in the Industrial Hygiene Manual by the EHS Specialist and/or the MSDS/SDS Administrator. 4. Non-BASF product MSDS/SDS s must be added to the Non-BASF Products MSDS database (see Section 3.2) by the EHS Specialist and/or the MSDS/SDS Administrator. 5.5 Initial training 1. Generic pre-assignment Hazard training will be conducted during New Employee Orientation. Training is conducted using Mockingbird Online training modules, and includes: The contents, location and availability of this standard. The contents of (29 CFR ) the OSHA Hazard Standard. The location and availability of MSDS/SDS s. How to read MSDS/SDS s. 2. Unit or department specific training must be conducted at the time of each employee s assignment by supervision. Training is conducted using approved BASF procedures and policies manuals, and will include the following: TJA Manuals (task specific procedures that include health and safety information). Applicable MSDS/SDS s, applicable Industrial Hygiene Monitoring Reports, Vessel and Chemical Inventory, etc. How to access Industrial Hygiene monitoring data through the Texas Hub Industrial Hygiene coordinator. How to access the Occupational Noise Exposure Standard.

11 Standard No.: BCF Page: 11 of Periodic training Physical and health hazard information for materials is contained in each MSDS/SDS and on the Vessel and Chemical Inventory, and each employee must understand how to obtain this information. Unit Operations Manuals including the hazards associated with the contents of piping and process vessels. Chemical and physical properties of the specific chemicals used in the unit. Unit/Site Emergency Plan and procedures for non-routine tasks. 1. Additional training shall be performed when a chemical with a new physical or health hazard the employees have not previously been trained on is introduced to a unit. 2. Additional training shall be performed when deficiencies in the hazard communication requirements are observed in the workplace. 6. RELATED DOCUMENTS All information needed to comply is included above. Additional information on the topic may be found in the following documents: OSHA 29 CFR Hazard Communication BWR-002 RCMS Document Occupational / Industrial Hygiene Work RACI BCF Management of Change (See Attachment 1 and 2) 7. ATTACHMENTS Attachment 1 Training Presentation for the BASF Electronic MSDS/SDS Databases Attachment 2 Written Procedure for Using the BASF Electronic MSDS/SDS Databases Attachment 3 Vessel and Chemical Inventory Worksheet

Title: Hazard Communication. Site Function: Ecology, Health and Safety Procedure No.: WYN Page: 1 of 15

Title: Hazard Communication. Site Function: Ecology, Health and Safety Procedure No.: WYN Page: 1 of 15 Procedure No.: WYN032.049 Page: 1 of 15 Preparer: Owner: Approver: EHS Specialist EHS Specialist EHS Hub Manager Revision History Revision Date Revision Number 03/2010 1 06/2011 2 05/2016 3 Details of