Control of Hazardous Energy Sources

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1 Wyandotte No.: WYN Page: 1 of 23 Preparer: Owner: Approver: Preparer: EHS Hub Team Revision Date Revision Number EHS Hub Team (Signature on File) 11/5/05 Original Original Document Revision History Details of Change EHS Hub Manager (Signature on File) 07/08 1 Format changes made along revisions to reflect changes with Corporate Control of Hazardous Energy Procedure (Refer to Safety and Health Advisory 167) 10/12/11 2 Changes made based on 2010 EHS Management Reviews as well as incorporated previous Wyandotte s standard into template format. Also, modified site Master Tag form as part of Control of Hazardous Energy Procedure. 1/7/15 3 Changes made to sec Requirements for Locks and Tags to reflect: Personal locks shall have owners name on lock. Department locks shall have a unique number and be color coded all the same color. 8/3/16 4 Master tag sheet only revised to reflect audit finding in WYDR. Added section for energy sources and magnitude along with requirement to list specific steps for releasing stored energy. 7/17/17 5 Based on Wyandotte EHS Coordination Audit finding, revised the first section under 4.7

2 Wyandotte No.: WYN Page: 2 of 23 1 PURPOSE To establish minimum standard work practices and procedures at the Wyandotte site for isolating Hazardous Energy Sources and otherwise disabling machines or equipment to prevent unexpected or unintentional energizing, startup, or release of stored energy that could cause personal injury or equipment damage. The standard also implements requirements defined in BASF, BC DEFINITIONS 2.1 Affected Employee A person whose machine or equipment is to be serviced or maintained under lockout/tagout or is working in an area which such activities are being performed Authorized Employee A person who locks out/tags out machines or equipment or performs work on equipment subject to this procedure. The Authorized Employee and the Affected Employee may be the same under certain circumstances De-Energized Disconnected from all Energy Sources and containing no residual or stored energy Designated Representative Authorized Employee that oversees or leads a work crew and is allowed to affix or remove Lockout/Tagout Devices on behalf of the Authorized Employees of the work crew Energy Isolating Device A device that physically prevents the transmission or release of energy. An Energy Isolating Device is capable of being locked out if it has a hasp or other means of attachment to which, or through which, a lock can be affixed or it has a locking mechanism built into it. Such devices include, but are not limited to the following: A manually operated electrical circuit breaker; A disconnect switch; A manually operated switch by which the conductors of a circuit can be disconnected from all underground supply conductors, and in addition, no pole can be operated independently; A valve; A blind; Any similar device used to block or isolate energy.

3 Wyandotte No.: WYN Page: 3 of 23 On/off push buttons, selector switches and other control circuit type devices are not Energy Isolating Devices Energy Source Any source of electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other energy (e.g., radiation) Hazardous Energy Source Any source of electrical, mechanical, hydraulic, pneumatic, kinetic, chemical, thermal or other energy, including stored, inertial or residual energy, that if unexpectedly or inadvertently released, could cause injury to personnel, or if introduced into a process could be hazardous or cause equipment damage Hot Tap A procedure used in the repair, maintenance and services activities which involves welding on a piece of equipment (pipelines, vessels or tanks) under pressure, in order to install connections or appurtenances. It is commonly used to replace or add sections of pipeline without the interruption of service for air, gas, water, steam, and petrochemical distribution systems Isolation The process of preparing and positioning of equipment or components of equipment in order to segregate them from Hazardous Energy Sources. Energy isolation must be performed in accordance with equipment specific hazardous energy control procedures, and must achieve a Zero Energy State Learning Objective(s) Specific knowledge, skills, or attitudes the training participant is intended to have learned at the conclusion of the training program. As a minimum, the learning objectives will include applicable regulatory training elements Lock Box A box that contains the master key and provisions for Locking/Lockout with multiple locks that is generally used in situations where multiple work crews are working on equipment Locking/Lockout The placement of a Lockout Device(s) on an Energy Isolating Device, in accordance with an established equipment specific hazardous energy control procedure in order to ensure the Energy Isolating Device and the equipment is controlled to a Zero Energy State and cannot be operated until the Lockout Device is removed.

4 Wyandotte No.: WYN Page: 4 of Lockout Device A device that holds an Energy Isolating Device in a Safe Position and prevents the energizing of a machine or equipment until the Lockout Device is removed. A keyed lock is the most commonly used lockout device Master Tag System Hazardous Energy Source control procedures that may be used for control of multiple isolation points when equipment is being serviced by multiple groups. Since the Master Tag System relies primarily upon administrative means to control the release of potential hazardous energy, additional steps for Verification of Zero Energy State are required to ensure that protection comparable to Lockout is maintained during work covered by this procedure. Using a Master Tag System requires a mechanism to achieve personal acceptance of the Lockout/Tagout by each Authorized Employee. This may be accomplished by each Authorized Employees personally signing on/off the Master Red Tag System One Plus/Tag-Plus System utilizing a mechanism of physical protection to make equipment inoperative. This is intended to prevent unexpected or inadvertent operation of an Energy Isolation Device when Lockout cannot or is not used. Some examples include, but are not limited to: Removing an isolating circuit element; Taking off the valve handle; Chaining the valve handle; Using tie wraps to secure a valve in the proper position; Taping or securing non-lockable electrical breaker devices; Securing equipment shafts that could be rotated while being worked on; Stationing a stand-by person at the equipment Energy Isolation Device Operating /Owning Department The BASF unit or department that operates or is responsible for the daily operation of the process, area or facility where work is being conducted. Under certain documented circumstances, individuals that would not normally be considered members of the Operating/Owning Department (i.e. service and maintenance personnel) may be authorized to perform work under the provisions of the permitting exemption. The following circumstances must be met in order to consider such individuals as Operating/Owning Department personnel: They must be trained and qualified to perform the subject activities They must have a level of knowledge and experience with the operation/process (equipment, hazards, and controls) that is comparable to existing Operating/Owning Department personnel.

5 Wyandotte No.: WYN Page: 5 of 23 They are specifically authorized (individually or as a group as appropriate) in the site s/unit s written program as a member of the Operating/Owning Department for the specific tasks they perform under the exemption Permit Issuer Personnel that have been trained qualified and authorized to issue permits on behalf of the Operating/Owning Department Qualified Electrician Person who has completed formal program of training (either classroom or on the job) and qualification and is familiar with the: Hazards of electricity. Skills and techniques needed to distinguish exposed live parts from other parts of electrical equipment. Skills and techniques needed to determine the nominal voltage of exposed live parts. Clearance/approach distances required and the corresponding voltages to which the qualified person will be exposed. Applicable electric codes. Hazardous area classification and its application to electrical installations. Safety-related electrical work practices pertaining to their respective job assignments. Electrical requirements included in operating and maintenance procedures (including lock, tag, and try). Use, care, and limitations of personal protective equipment Safe Position The specific position of an Energy Isolation Device that achieves a Zero Energy State and prevents unexpected energization of the equipment (i.e., open/closed, de-activated, blocked, removed) Tagging/Tagout The placement of a Tagout Device on an Energy Isolating Device, in accordance with established procedure, to indicate that the Energy Isolating Device and the equipment being controlled may not be operated until the Tagout Device is removed in accordance with established procedures.

6 Wyandotte No.: WYN Page: 6 of Tagout Device (Tags) A standardized/prominent warning device, such as, a tag and means of attachment, which is securely fastened to an Energy Isolating Device Test Temporary re-energizing of equipment and removal of Lockout/Tagout Devices to check operation or positioning prior to completion of the work. Testing is allowed only during the limited time necessary and only on the affected components. After completion of the testing, the equipment must be de-energized and all Lockout/Tagout requirements resumed Verification Means to ensure that Isolation has been achieved for each type of Hazardous Energy Source. Examples may include sampling with chemical indicating tubes, photo-ionization detectors or combustible gas indicators, measuring ph of wash water, checking voltage, checking rotation, attempting to operate a valve or switch, successful purge/flush, etc Zero Energy State The point where all potential Hazardous Energy Sources have been verified to be De-Energized 3. SCOPE This procedure applies to the BASF Wyandotte facility located in Wyandotte, Michigan. This procedure applies to all activities where there is a potential for exposure to a Hazardous Energy Sources, unless specifically exempted following the specific exemption process(es) described in this procedure This procedure does not apply to the following: Work on cord and plug connected electrical equipment for which exposure to the hazards of unexpected energization or start up of the equipment is controlled by the unplugging of the equipment from the Hazardous Energy Source if the plug is under the exclusive control of the employee performing the service or maintenance. The plug is under the exclusive control of the employee if: It is physically in the possession of the employee or It is in arm s reach and in the line of site of the employee or The employee has affixed a Lockout/Tagout Device on the plug Activities on equipment where the Energy Source is not a Hazardous Energy Source

7 Wyandotte No.: WYN Page: 7 of Operation and maintenance of electric power generation, transmission, distribution lines/equipment. These tasks require specific training, work practices and employee protection from these special hazards presented by working with energized electrical equipment not identified in this procedure Hot Taps that are covered by the Wyandotte Hot Tap Procedure, WYN The following procedures/processes may be exempted from the Hazardous Energy Source control program if a risk assessment and appropriate control measures has been documented in the form of a total job analysis, job safety analysis or written procedure and approved by management Activities performed by Operating/Owning Department personnel where the work is routine, repetitive and integral to the use of the equipment and under the exclusive control of the individual(s) performing the work. Exclusive control means within 10 feet. One example of such an activity could be changing a filter on a filter pot with integrated isolation and proper draining. At the Wyandotte site through the use of the safe work permit process and the Wyandotte Control of Hazardous Energy procedure, a review and as appropriate a risk assessment will be conducted by the owning group and the knowledgeable maintenance personnel to ensure appropriate safeguards are in place to work on equipment which has been properly isolated Routine electrical tasks that can only be performed in an energized state, and are conducted by a Qualified Electrician. Refer to the Wyandotte Electrical Hot Work Standard, WYN for additional information regarding working on electrical work, including the conditions and safety precautions under which work can be performed on energized electrical equipment. The above referenced standard also provides requirements to be followed for working on various types of energized work at the Wyandotte site, including requirements which must be met.

8 Wyandotte No.: WYN Page: 8 of PROCEDURE 4.1. General Requirements All activities regarding Control of Hazardous Energy (i.e., Lock, Tag, Try and Verify) must comply with the requirements outlined in this standard as well as the requirements outlined in the BC Corporate Procedure, BC Authorization Personnel, excluding Operating/Owning Department personnel, shall not perform activities involving the control of Hazardous Energy Sources without prior written authorization in the form of a safe work permit issued by a Permit Issuer. The applicable equipment specific Hazardous Energy control procedure(s) shall, at a minimum, be referenced on the permit. The Permit Issuer must be a different individual than the individual performing the activity At the Wyandotte site all activities regarding Control of Hazardous Energy (i.e., Lock, Tag and Try and Verify) will follow the BC Corporate requirements in addition to following Wyandotte site requirements: The primary operating personnel responsibility for preparation of a system or equipment and the application of this procedure shall rest with personnel designated by management The authorized primary operator may delegate the authority to execute the lock-out to knowledgeable service personnel from a servicing department. Prior to delegation of this authority, the primary operator and the service personnel will review the following: a. The service personnel s knowledge of procedures and equipment. b. The complexity of the system to be locked out. c. The preparation requirements for the system to be locked out. d. Current conditions affecting the system The primary operator will then authorize the delegation by signing and dating the master tag sheet. Note: Delegation to service personnel must be made to individuals with proper qualification and must not be made to other groups in general The service personnel performing the work will determine that the lockout procedures have bee performed properly Personnel excluding Operating/Owning Department personnel shall not perform activities involving the control of Hazardous Energy Sources

9 Wyandotte No.: WYN Page: 9 of 23 without prior written authorization in the form of a Safe Work Permit as required by site standard, WYN , Safe Work The applicable equipment specific Hazardous Energy Control procedure shall be used as reference for completing the Master Tag Sheet and the Master Tag Sheet shall be attached to the Safe Work Permit The Permit Issuer must be different than the person performing the activity. 4.3 Zero Energy State Verification All activities shall be performed, to the extent possible, under a Zero Energy State that has been verified, at a minimum, by Operating/Owning Department personnel. For permitted work, verification of Zero Energy State shall be documented on the permit. When Zero Energy State verification is not possible, proper PPE and/or additional administrative/engineering controls shall be utilized to minimize exposure to hazards Ensure safe work procedures and permit includes verification of zero energy Verification Considerations Equipment interlocks, where applicable, must be verified that they are not engaged in order to prevent the Isolation. Attempts to verify a local field switch on equipment controlled automatically or remotely (such as by DCS systems) cannot not serve as the sole means to verify Isolation. If work is being performed on electrically operated devices in such a manner that failure to de-energize the circuit could put workers in contact with live circuits, voltage will be tested by a Qualified Electrician to verify that the power is de-energized. Other methods may be necessary to determine if energy sources have been isolated. 4.4 Communication Prior to the performance of activities subject to this procedure Affected Employees will be notified of the work activities and any potential hazards/consequences associated with the work. This notification may be in the form of a job analysis, a job safety analysis (JSA) or written procedure approved by management. In addition, Affected Employees will be notified prior to placing equipment back into service. The communication is unit dependent and may include open permit posting in control room, logbooks, radio communication, etc. 4.5 New and Replacement Equipment

10 Wyandotte No.: WYN Page: 10 of 23 Whenever replacements, major repair, renovation, modification of a machine or equipment is performed, and whenever new machines or equipment are installed, Energy Isolating Devices for such equipment shall be designed to accept a Lockout Device. In particular, quarter-turn valves must include a locking mechanism to ensure that the valve cannot be inadvertently operated. 4.6 Equipment Specific Hazardous Energy Control Procedures All activities, subject to the requirements of this procedure, shall be performed using written equipment specific hazardous energy control procedures. These procedures shall be prepared for each piece of equipment or for each group for similar equipment (i.e. equipment with similar energy source type/magnitude and similar isolation requirements) Equipment Specific Hazardous Energy Control Procedures Equipment specific energy control procedures are not required if all of the following eight conditions are met: The equipment has no potential for stored or residual energy or reaccumulation of stored energy after shut down that could endanger employees; Equipment has a single Hazardous Energy Source that can be readily identified and isolated; The Isolation and Locking out of the Hazardous Energy Source will completely de-energize and deactivate the equipment; The equipment is isolated from the Hazardous Energy Source and locked out during service/maintenance; A single Lockout Device will achieve a locked-out condition; The Lockout Device is under the exclusive control of the Authorized Employee performing the service or maintenance; The service/maintenance does not create hazards for other employees; and The site/unit has had no incidents involving the unexpected activation or re-energization of the equipment during service/maintenance. At the Wyandotte site unless not required as described in 4.6.1, each unit/group shall develop Equipment Specific Hazardous Energy Control Procedures. These procedures shall be prepared for each piece of equipment or for each group of similar equipment (i.e. equipment with similar energy source/type/magnitude and similar isolation requirements). The format and structure of the procedure may include, but is not limited to the following: inclusion as part of operating procedures, job safety analyses, total job analyses, maintenance procedures or equipment drawings depending on the complexity of the equipment. A checklist or equipment drawings can be used to supplement a generic procedure if it provides the required information.

11 Wyandotte No.: WYN Page: 11 of 23 When conducting, equipment lock outs, sketches or drawings should be attached to the Master Tag Sheet as part of the overall Safe Work Permit process. 4.7 Lockout/Tagout Devices Lockout Devices shall be designed to withstand the rigors of the application and environment in which they are applied. They shall have positive identification as to the ownership of the device by department or individual. At the Wyandotte Lockout Devices, shall be standardized at the unit/group level to facilitate identification of equipment affected by lockout/tagout; Authorized Employee(s) protected by the device and will be used only for work covered by this procedure. Personal locks shall also have the owners name on the back. Therefore, each Electrical Energy Source shall be locked out with a specific colored operations lock unique for each unit. In addition, the servicing group locks will be unique at the unit level. Lockout/Tagout devices used for energy isolation under this procedure are not to be used for tasks not related to Servicing and/or Maintenance, such as operational control or restriction of equipment use. Out of Service equipment will not be locked out or tagged in the same fashion that is covered by the Wyandotte Control of Hazardous Energy Procedure. Out of Service equipment is covered by WYN , Operation Control Out of Service Equipment Program Requirements for Locks and Tags The Red Danger Tag (which has wording such as DANGER DO NOT OPERATE ) is to be used to identify block valves, bleed valves, motor starters, on/off switches, automatic valve air supply, radiation shutters, and slip blinds, etc. used in the application of the Wyandotte site Control of Hazardous Energy Procedures. The Tag will include: a. Signatures, remarks and dates which must be clear and legible. b. The red tag is normally accompanied with an approved lock by both the primary operator and the service personnel. The only exceptions to this are as follows: Dual locks are not required when locking out a job where both the lock out and the service work will be performed by a single group of personnel. Dual locks are not required when a lock box is used and the red tags signed and field verified by service personnel. No locks are required when red tagging slip blinds No locks are required if material contained is non-hazardous, below 120 deg. F, and routinely less than 70 psig (for example, potable water).

12 Wyandotte No.: WYN Page: 12 of 23 Non-laminated red danger tags are to be signed by the primary operating manager or his/her designee and laminated prior to becoming six months old. This laminated tag must be accompanied by a primary operating group lock. Equipment that is no longer active must not be covered by this procedure, but rather the Wyandotte WYN , Operation Control Out of Service Equipment Program. Personal locks shall have the owners name on the lock. Department locks shall have a unique number on each lock and be color coded all the same color per department. Tags shall be able to withstand chemical and weather exposure and be incapable of being inadvertently or accidentally removed. The Tagout Device attachment shall be: Of a non-reusable type, Attachable by hand, Self-locking, and Non-releasable with a minimum unlocking strength of no less than 50 pounds. All information on the tags must be legible and able to withstand environmental conditions. Tags used for Tagout purposes may only be used for Hazardous Energy Source Isolation purposes Locks versus Tags In accordance with BC ,, where locks are used, they shall be attached in such a manner as to hold the Energy Isolation Device in a safe position. If an Energy Isolating Device is capable of being locked out, equipment specific hazardous energy control procedures shall specify Lockout unless the site can demonstrate that the use of a Tagging/Tagout system provides protection comparable to that of a Lockout system. One Plus/Tag Plus is the minimum Tagging/Tagout requirement for an Energy Isolating Device that has the potential for unexpected or inadvertent operation. If a piece of existing equipment is incapable of accepting a Lockout Device or the site chooses to use Tagging/Tagout, the Tagout Device shall be attached to the Energy Isolating Device. Where the tag cannot be placed directly on the Energy Isolating Device, it must be located as close

13 Wyandotte No.: WYN Page: 13 of 23 as safely possible to the device, in a position that would be immediately obvious to anyone attempting to operate the device Instances where individual locks/tags are not used In all cases where an Authorized Employee does not place their individual locks/tags on Hazardous Energy Sources, alternative methods are acceptable if: Hazardous Energy Source control is verified to be in a Zero Energy State; Individual Authorized Employees are given the opportunity to personally verify Isolation if they choose. Individual Authorized Employee protection is maintained (each individual signs-in and signs-out); Multiple Employees/Crews Involved in Lockout/Tagout (Group Lockout/Tagout) When one or more employees or work crews are required to perform work functions that necessitate equipment to be Locked/Tagged out, one of the following requirements for equipment will be met: Each employee involved in the work function will place their individual lock or tag on the Energy Isolation Device, or A Master Tag or equivalent system will be used as long as there is a means to positively account for all employees involved in the work function, or A Designated Representative will place a crew/department Lockout Device or tag on the Energy Isolating Device and ensure there is a mechanism to positively account for all employees involved in the work function. When crew/department locks are used, the key will be kept under the control of the Designated Representative responsible for the crew lock. Applied Lockout Devices may not be keyed alike. Group lockout must afford both the Authorized and Affected Employees protection comparable to that of individual Lockout Devices Using A Lock Box A Lock Box may be used when many locks will be necessary to secure equipment or a system to be serviced by multiple Servicing Departments/Groups. When a lock box is used, the following will be observed: At least one Lockout Device, the primary (Owning/Operating Department) Lockout Device, will be applied directly to the Energy Isolating Device.

14 Wyandotte No.: WYN Page: 14 of 23 The key to the primary Lockout Device will be placed inside the Lock Box. No keys are to be duplicated for these locks. The Lock Box will be kept by Operating/Owning Supervision. All Authorized Employees servicing the equipment shall place their personal Lockout Devices on the Lock Box, or, a Designated Representative of each crew shall place an individually keyed group Lockout Device on the Lock Box. Each Authorized Employee placing a Lockout Device on the Lock Box shall ensure that the key remains in their possession at all times. If a group Lockout Device is used, all crew members working under the group Lockout Device must be informed of the individual designated as responsible for the Lockout Device (Designated Representative), the location of the Lockout Device and Lock Box, and notified when the lock is applied and removed. The key to the group Lockout Device must remain in the possession of the Designated Representative at all times. After application of Lockout Devices/tags and prior to beginning work, Authorized Employees of both the Operating/Owning Department and the Servicing Department/Group or Designated Representative of each shall verify isolation. Upon completion of work, the work crew shall remove their locks from the box. The locks/tags on the Energy Isolating Devices shall be removed by the Operating/Owning Department last Testing/Positioning of Equipment For situations in which Lockout/Tagout Devices must be temporarily removed from the Lockout Device and the machine or equipment energized in order to test or position the machine, equipment or component, the following sequence of actions will be followed: Approval Approval must be obtained from the Operating/Owning Department and Authorized Employees.

15 Wyandotte No.: WYN Page: 15 of 23 Clearing Machines or equipment must be cleared of non-essential tools and materials, and assurance made that components are operationally intact. Personnel must be cleared from the machine or equipment to ensure that all are safely positioned. Testing Testing shall be performed in the sequence: The work crew locks/tags are removed first. Operating/Owning Department locks/tags are then removed. The Operating/Owning Department will then restore all valves, switches, etc. to their normal operating position and perform the test. Post Test/Positioning Equipment/machines must be de-energized and energy control measures previously in place must be restored before servicing activities may resume. Refer to section 4.11, Blue Tag procedure for additional site requirements related to equipment testing Removal of Locks/tags After Completion of Work All Locks/Tags shall be removed by the person(s) applying them or the Designated Representative upon completion of work. After verification that all work is completed, all Operating/Owning Department locks/tags shall be removed by an Authorized Employee from the Operating/Owning Department. In the case where a lock or tag has not been removed by the person applying it or the owner cannot be identified, Operating/Owning Department Supervision may remove the lock/tag only upon positive verification that the employee responsible for the Lockout/Tagout is not available, and that the removal will not create an unsafe condition. All Affected Employees shall be informed before equipment is placed back into service. A completed Master Tag Sheet will include a review by both the permit issuer and the permit acceptor that lockout and preparations have been completed and work may begin.

16 Wyandotte No.: WYN Page: 16 of Master Tag Sheet The Wyandotte site uses the Master Tag Sheet to document lock, tag, try and verify information. Specific information about the Master Tag Sheet is as follows: The number and location of all red tags will be recorded on the Master Tag Sheet. If two (2) or more Master Tag Sheets are required, the extra sheet (s) will be attached to the first sheet and a note made on each sheet (Example: Sheet 1 of 3) Any special instructions, problems or precautions will be noted on the Master Tag Sheet. When all the information has been recorded and the sheet(s) completed, the sheet(s) will be returned to the primary operator and a copy made available for unit audit purposes. In situations where the person doing the work does not apply a personal lock to the equipment or group lock box but instead relies on locks applied by the primary operating or servicing group, this person must sign in and out on the Master Tag Sheet. Refer to Section 4.7 of this procedure for further clarification of this requirement The alternative methods are acceptable if: a. Hazardous Energy Source control is verified to be in a Zero Energy State, and b. Individual Authorized Employees are given the opportunity to personally verify isolation if they choose. When all work has been completed, prior to removing any locks, the last group will verify that any personnel who signed in on the Master Tag Sheet are no longer on the system and have signed out. They now complete the release portion of the Master Tag Sheet. After the release portions, have been completed and equipment tested, the personnel who performed the lockout will remove their locks and tags, restore equipment to its normal position and return the unit to service. In the event that equipment which has been worked on requires further testing, or checking prior to returning to regular service, the service person requiring the test, or check will remove the necessary locks and will sign the Master Tag Sheet Release for Testing. The primary operator will then make the necessary tests or checks for the service personnel. If the equipment is satisfactory, the service personnel will remove all remaining locks, restore all equipment to the normal position and sign the release portion of the Master Tag Sheet. If after testing, the equipment requires further work, the service personnel will reinstall all locks that were removed and reinstate all Lock, Tag, Try and Verify procedures and sign the Master Tag Sheet, Lock, Tag and Try reinstituted.

17 Wyandotte No.: WYN Page: 17 of 23 In the event the second page of the Master Tag Sheet is lost, the person responsible for releasing the equipment will sign off the fist page with a note that the second page was lost. Where electrical circuits have to be de-energized for electrical or mechanical work to be performed by personnel trained in verification techniques in accordance with WYN , Electrical Hot Work, shall have the equipment de-energized and physically checked that the equipment is properly deenergized. The stop/start switch controlling the locked out electrical or electrically driven equipment must be tried by both operations and maintenance to verify the circuit is de-energized. When fuses are pulled or T- Leads are disconnected these should be noted on the Lock, Tag and Try form. 4.9 Removal of Unidentifiable Locks The individual who installed the lock should remove the lock. In the event that a person forgets to remove their lock prior to leaving the plant, the person should be called back in so that it can be removed. In the event the lock cannot be identified or the person who installed the lock cannot be contacted, the following procedure will be in effect: Individual locks may only be removed on the approval of that individual s manager or another member of management to whom he/she specifically delegates this authority of if the lock cannot be identified by an appropriate member of management. Prior to the lock being removed and after approval has been received, the entire work site will be physically checked to ensure that all aspects of equipment are clear. This inspection must be conducted at the supervisory level, or above, by all departments involved. In all cases where an individual s lock must be forcibly removed, an incident report must be written and distributed Plant Specific Procedures The following general requirements apply for all Control of Hazardous Energy lock, tag, try and verify situations. IDENTIFY: Proceed to equipment in the field, note position number on motor or equipment and turn off power at Field Control Station, i.e., Push Button Station. VERIFY: Proceed to power source (Motor Control Center). Compare number at power source switch (Motor Control Center) with position number found under IDENTITY above. DE-ENERGIZE AND LOCK: Turn the switch to OFF and attach red DANGER-DO NOT OPERATE tag and lock. Check to be sure that the switch or breaker cannot be operated after locking. Note: When operating a disconnect switch or breaker, stand to one side and turn head away from switch. Also, follow PPE requirements defined under WYNO32.043, Electrical Hot Work.

18 Wyandotte No.: WYN Page: 18 of 23 CLEAR: Before trying to start, be sure equipment is clear of personnel and tools. TRY(CONFIRM): Attempt to start equipment at both local and remove Control Station, i.e., Push Button Station. Note: After pressing start button, stop button must be pressed to assure de-activation form power source. In instances where it is necessary for an individual to lock out equipment on which work is already in progress, this step may be satisfied by obtaining verbal confirmation from another individual who personally witnessed, or physically made, the TRY step Blue Tag-out Procedures Additional Requirements The purpose of the Blue Tag-Out Procedure is to prescribe the minimum conditions and controls for those limited situations where the performance of maintenance work on power, mechanical or process equipment involves the frequent positioning or testing of the equipment and to conform to the State of Michigan Occupational Safety and Health Standards (MIOSHA) for electrical lockouts. It is each person s responsibility to ensure their own safety and the safety of others when working on or exposed to hazards on any equipment, piping or machinery General Requirements The primary responsibility for preparation of a system or equipment and the application of this procedure rests with the operating supervisor or the supervisor having immediate jurisdiction over the area in which the system or equipment is located. Any additional responsibility shall rest with the service personnel performing the work, who will determine to the best of their ability and knowledge that the provisions of this procedure have been applied prior to starting work. The blue DANGER EQUIPMENT in PROCESS OF REPAIRS tag is to be used for protection of personnel. Signatures, remarks and dates must be clear and legible. Most jobs requiring the Blue Tag Procedure involve additional equipment/devices be locked out under Section 4.7 above. In such cases individuals, must have locks on each Red Tag and Blue Tag portion of the system. Normally there will be only one blue tag per Master Tag Sheet. If more than one blue tag is required or a job, production and maintenance management must inspect and agree that no combination of activated devices can create an unsafe condition. Prior to performance of any work falling within the scope of this procedure, the operating supervisor shall ascertain the following:

19 Wyandotte No.: WYN Page: 19 of Management System Review -- The system or equipment has been shut down in accordance with prescribed area procedures. -- The system or equipment has been isolated with all power, steam and process material sources having been secured. -- All devices controlling power, air, steam, nitrogen and process material (including blanketing gases) of the system or equipment on which the work is to be performed have been placed in a safe position and tagged in the position with properly completed tags. -- In all instances requiring the deactivation of hazardous materials Program Review The site shall review the effectiveness of the site s program at least annually to ensure that the management systems are properly implemented and the elements adequately control exposures to Hazardous Energy Sources. As a minimum, the following management system elements shall be included in the review: A review of the site procedure and permit to ensure all currently required elements are included. A review of incident reports involving Hazardous Energy Source control activities that have occurred since the last management system annual review. Interviews with Permit Issuers, Authorized employees, and other Affected Employees, including contractor employees where applicable regarding their roles and responsibilities Equipment specific hazardous energy control procedures review A representative number of equipment specific Hazardous Energy isolation procedures shall be reviewed annually. Based on the number of equipment specific Hazardous Energy Procedures, a minimum one-third will be conducted each year. The review must be performed by an Authorized Employee that is not currently utilizing the procedures under review, and shall include: A comparison of the procedure(s) with existing equipment design and layout A comparison of the procedure(s) with actual implementation practices Interviews with Authorized Employees utilizing the procedure(s) that includes: A discussion of with each Authorized Employee regarding their responsibilities under the procedure(s)

20 Wyandotte No.: WYN Page: 20 of 23 A discussion of any limitations of the isolation methods specified by the procedure(s) Review Documentation The review shall be documented and must include the following: 4.13 Training Name of inspector and employees included in the inspection; Date of inspection; Equipment specific hazardous energy control procedure(s) inspected and the machine or equipment on which the energy control procedure was being used Findings; and corrective action, where applicable, of any deviations or deficiencies identified during the review. Corrective actions resulting from the reviews shall be tracked to completion and must be communicated to all Authorized and Affected Employees. The Wyandotte Management review will include a review by the EHS Hub personnel to ensure requirements outlined in this procedure have been addressed, including review of equipment specific procedures, field audits of control of hazardous energy procedure and overall review of the safe work permit issuances, including use of the master tag sheet. BASF and Contracted Employees performing work as Authorized Employees shall receive training on the following: The Specific site program; Recognition of applicable Hazardous Energy Sources and their hazards; Type and magnitude of Energy Sources in the workplace; Use of adequate methods and means to control these sources, and the limitations of a Tagout system, if utilized. Use of equipment specific hazardous energy control procedures The requirements for issuing a permit, and the necessary means to safeguard against the hazards posed during these activities. BASF and Contracted Affected Employees shall receive training in: The purpose and use of the site energy control program and how it may affect their specific work operation. The limitations of a Tagout system, if utilized. BASF and Contracted Not Directly Involved in the site s hazardous energy control program:

21 Wyandotte No.: WYN Page: 21 of RESPONSIBILITIES Personnel not directly involved in the hazardous energy control program will receive awareness training for this and other safe work practices in accordance with the EHS curriculum assignment process. Training frequency for Affected Employees and Authorized Employees Training shall be delivered in accordance with the EHS curriculum assignment process. Retraining of an employee is required whenever: -- There is a change in job assignment affecting the level of participation in the program (i.e. an employee changes from an Affected Employee to an Authorized Employee). -- Deviations or inadequacies in an individual s performance of an applicable procedure indicate that lack of knowledge is a cause. -- An applicable equipment specific hazardous energy isolation procedure has been changed due to equipment or process changes or a new hazard is introduced. Documentation for BASF and Contracted Employees Training will be documented including: o Each Trainee's name, o Date(s) of attendance, o Means to verify understanding o Learning Objectives for the course Documentation shall be maintained according to BC037, Record Retention Policy and the applicable record retention schedule. Contractor Employees Refer to BC Contractor EHS Qualification and Oversight for requirements. 5.1 Manager Is responsible to: Implement this procedure Ensure adherence to the site procedure on a daily basis Review control of hazardous energy sources activities at least every 12 months. Ensure employees are trained and identified for control of hazardous energy sources activities.

22 Wyandotte No.: WYN Page: 22 of EHS Hub Team Member The EHS Hub Team Member has the primary responsibility for administration and interpretation of this procedure. 5.3 Operation/Laboratory/Office/Department Manager Designate those individuals considered assigned to the Operating/Owning Department, and those that are trained and authorized to perform activities covered under the Wyandotte Control of Hazardous Energy Program. These include Construction & Project Personnel, Contractors, Service Department Personnel and Operating/Owning personnel Designate those persons who are trained in the process and proper preparation of equipment for their area of ownership Ensure that training of personnel for this standard has been completed, verified, and documented as required: Initially to learn the requirements When changes are made to the standard When errors or deviations are found Refresher training a minimum of every three (3) years As part of the overall Management Review process of the Safe Work program, ensure associated Permits, including master tag sheets and equipment specific isolation procedures are reviewed on a periodic basis (at least every 12 months) to ensure compliance with this standard. As part of this process both field audits and paperwork audits will be included.

23 Wyandotte No.: WYN Page: 23 of 23 6 RELATED DOCUMENTS Description of Procedure Corporate No. Wyandotte No. Safe Work Permit Procedure BC WYN Safe Work Permit WYN A Safe Work Line Breaking Permit WYN E Workflow Process Safe Work Permit Instructions WYN F Line Breaking Procedure BC WYN Confined Space BC * WYN Records Retention Policy BC037 Hot Work Procedure BC * WYN Hot Taps and Stopples BC WYN Lock, Tag, Try of Controlled Hazardous Energy Sources BC * WYN Control of Hazardous Energy Master WYN A Tag Sheet Control of Hazardous Energy - Lock Box WYN B Form Control of Hazardous Energy Lock, WYN C Tag, Try and Verify Audit Form Control of Hazardous Energy WYN D Management Review Form Contractor Selection, Oversight and Safety BC WYN

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