KENNECOTT UTAH COPPER

Transcription

1 INTRODUCTION: This Standard specifies the safety controls associated with delivery driver travel and freight / cargo loading and off-loading operations at KUC properties DEFINITIONS: Access Point - A primary point of entry for deliveries onto KUC property Authorized KUC representative A KUC employee, contractor partner, or a Rio Tinto employee who is trained and authorized by KUC to administer this standard. (Person(s) that has been assigned responsibility, by the Site Owner, for performing the requirements of this Standard in a specific area) Delivery Categories Class 1 - Delivery (low risk) deliveries of low risk materials to low risk locations. Examples include: o UPS / FedEx driver delivering packages to offices; o Drivers delivering food or drinks to office based locations; o Drivers delivering laundered clothing to change houses; o Vending machine delivery drivers including delivering PPE to vending machines or tool cribs; o Drivers delivering hand held packages to warehouses / KUC sites. Class 2 - Delivery (routine consumables) - deliveries of routine chemicals and consumables. These deliveries may be high risk and / or the location may have high risk. Examples include: o Fuel to the Mine; o Coal to the UPP; o Chemicals to Concentrator, Refinery, or Smelter. Class 3 - Delivery (cargo / freight) deliveries of loads that are tethered / tied down and requires a forklift, crane, or other picking equipment to pick and unload. If unclear, delivery drivers should be considered Class 3. Examples include: o Pipe or pumps to plant site; o Steel, tank, or other item to a project site; o Freight deliveries to a facility. o Does not include drivable vehicles (e.g. forklift, JLG, backhoe, dozer, etc.). Page 1 of 10:

2 3a Deliveries Class 3 deliveries that are delivered by a driver that: o Has only received site specific Hazard Training; and o Who is not directly involved in unloading the cargo (except the possible removal of gates, load securing devices, tarps etc. when instructed to do so). Examples of 3a Deliveries are drivers new to KUC, infrequent drivers, and non-routine drivers. 3b Deliveries Class 3 deliveries that are delivered by a driver that: o Has received site specific Hazard Training, is current on all regulatory training and task training for any equipment that will be operated, is current on all required site specific license training and training on the safe loading and unloading of trucks; and o Either unloads the cargo or is involved in the unloading process. Examples of 3b Deliveries are KUC or Rio Tinto Procurement drivers, or KUC Vendor Drivers that deliver on a frequent or routine basis Delivery Risk Assessment & Control Plan - A document that can be used to meet the SHEA and SHEAP requirements for Class 2 Deliveries Delivery The transport of freight / product / cargo to a KUC location Escort A person assigned, trained, and deemed competent by the Site Owner or designee to meet a delivery driver at the KUC access point, evaluate the load securing devices with the driver, assure proper installation of locks / zip-ties / tags to restraints, guide the driver to the destination within the facility, and stay with driver at all times not allowing them to unstrap or loosen a load, or conduct other work activities until the permit to unload is completed Loading Operation - Includes all types of general freight / cargo loads that require a forklift, crane, or other picking equipment to load. Loading Operations does not include drivable vehicles (e.g. forklift, JLG, backhoe, dozer) or commodities in bulk that lack structure or fixed shape (e.g. liquids, gases, sand, gravel, aggregates) that are transported in a tank, hopper, box or similar device Cargo Loading Permit - A permit required before the start of any loading operation. Page 2 of 10:

3 Permit to Unload A Permit required for designated Class 3 deliveries. See paragraph Site Owner The site based representative that has been assigned accountability for implementing this Standard in their specific area. The Site Owner is not required to oversee or attend the unloading, but is accountable for the unloading activities. The site owner is responsible to verify that all escorts have been trained, tested and deemed competent through written or oral verification, and that a current list of approved escorts is maintained Vendor - A contracted Company that supplies and / or delivers materials or goods to KUC. The Delivery Driver is typically the agent of the vendor UNLOADING REQUIREMENTS: Class 1 Deliveries A) Check in - All Class 1 Delivery Drivers are required to check in at a designated access point before completing each delivery. (See Class 1 Tracking Sheet in the Health and Safety eroom) Upon arrival at the designated access point, the Security or designated KUC representative will: o Confirm the delivery (what delivery to what location); o Require the driver to sign-in; and o Verify personal protective equipment and provide the driver with site specific safety information, as appropriate. This may include: - A site map outlining prescribed driving routes and predesignated parking / off-loading locations; - A listing of key site safety rules (Site specific Hazard Training); and/or - Other information that may be relevant to the delivery Class 2 Deliveries A) Delivery Identification - Each KUC facility is required to: o Identify and document all Class 2 deliveries to the facility (See Class 2 Delivery Driver Tracking Sheet in Health and Safety eroom); and o Assign a site based representative as the Site Owner for each identified delivery. Page 3 of 10:

4 B) Delivery Risk Assessment - A KUC Level 1 Risk Assessment is required to be completed by the Site Owner or designee for each identified delivery. A Delivery Safety Health and Environmental Analysis (SHEA) and Safety Health and Environmental Action Plan (SHEAP) are required to be completed for each type of delivery. The SHEA is based upon the outcomes of the Delivery Risk Assessment and provided to the Delivery Vendor. The SHEAP is prepared by the Delivery Vendor based upon the identified hazards in the SHEA. The final SHEAP must be approved and signed by the Site Owner. Delivery SHEAP s are required to be reviewed and updated periodically or each time the contract for supply of the material is re-issued, or if a significant delivery incident occurs. A Delivery Risk Assessment & Control Plan (See Exhibit ) - may be used to complete the SHEA and SHEAP requirements. All drivers are required to have a signed copy of the Delivery SHEAP (or Delivery Risk Assessment & Control Plan) readily available for review and / or audit by any KUC representative. If a delivery driver is unable to provide a signed copy of the correct delivery SHEAP (or Delivery Risk Assessment & Control Plan) the Site Owner must be contacted and may choose to deny access or provide and review a copy of the Delivery SHEAP / Delivery Risk Assessment & Control Plan with the driver. C) Training - All Class 2 Delivery Drivers must complete individual facility site specific Hazard Training and participate in a site pre-work walk-through to become familiar with basic site safety issues (e.g. where to park, emergency evacuation routes, eye wash / safety shower locations, locked & labeled chemical connections etc.). D) Check in - All Class 2 Delivery Drivers are required to check in at a KUC designated access point unless an alternative check-in procedure has been identified in the SHEAP / Delivery Risk Assessment Control Plan. Upon arrival at the designated access point, the Security or designated KUC representative will: o Confirm the delivery (what product to what location); o Confirm that the driver has a signed copy of the correct Delivery SHEAP (or Delivery Risk Assessment & Control Plan) Page 4 of 10:

5 o Require the delivery driver to sign in, verify appropriate personal protective equipment, and provide any other relevant (site specific) safety information that may be appropriate. E) After the Class 2 delivery truck arrives at the tank / fill-line and before any hoses are connected, both the delivery driver and the site owner (or designee) will complete the Bulk Chemical Unloading Acknowledgement form unless specifically exempted by a risk assessment. (See Exhibit ) Chemical Tank / Chemical Pipe Fill Locks - Every KUC facility must assure that all chemical fill lines or chemical tanks are labeled and secured. This will provide a secondary control to assure that the correct chemical is being delivered to the correct tank / fill-line and that the driver has the proper hose fittings and equipment for the task Class 3 Deliveries Check in 3a Deliveries are required to check in at a KUC access point. The Site Owner is responsible for communicating delivery details and contact information to access point personnel. Upon arrival of a Delivery Driver at a designated access point: 1. The Security Officer or designated KUC representative will: o Confirm the delivery (what delivery to what location); o Contact an appropriate Site Owner to accept the load and arrange for an escort; o Require the Delivery Driver to check in / sign in; o Verify personal protective equipment, site specific Hazard Training and provide any other site specific safety information that may be appropriate; o Instruct the driver that no unloading operation, including removal of gates, or releasing tension in load securing devices is to commence until instructed to do so by the Site Owner or designee; o Provide Delivery Driver a blank copy of the permit to unload. Ask and verify that the Delivery Driver reads and signs the back of the permit, acknowledging not to unstrap or loosen the load until a permit to unload has been completed and signed by site owner or designee; and o Instruct Delivery Driver to take permit to unload to offloading site. 2. The escort will: o Meet and evaluate the load securing devices with the driver. Page 5 of 10:

6 - The escort or Delivery Driver will install a KUC lock and tag on all load winch straps and / or ratchet strap restraints reachable from the ground level (no climbing on truck bed). Photo of Winch Strap Photo of Ratchet Strap - Escort or Delivery Driver will install a KUC zip-tie and tag on all load chain binder restraints reachable from the ground level (no climbing on truck bed). Photo of Chain Binder Photo of Chain Binder o No lock / tie / tag will be required to be installed on a restraint that would require the driver to climb onto the bed of the truck or load to attach the device. Note: Safe access to the bed of the truck to remove straps must be addressed when completing the Permit-to-Unload. 3b Deliveries may be required to stop at a KUC access point for a routine check in / sign in or card reader access may be required as per facility policy. Travel to Unload Site Page 6 of 10:

7 3a Deliveries The Site Owner will assign an escort to guide the delivery driver to their destination within the facility. The escort will: o Instruct the delivery driver not to unstrap or loosen the load or conduct other work activities until a permit to unload is completed, signed, and instructed by the site owner (or designee) to begin any work activities; o Instruct the delivery driver to leave all locks & tags and/or zip-ties & tags in-place; o Verify the Delivery Driver is wearing the correct PPE before exiting; o Remain with the driver at all times to ensure compliance, and communicate and enforce all applicable KUC Requirements. 3b Deliveries -No escort is required unless specifically designated by the Site Owner. Permit to Unload 3a Deliveries A Permit to Unload is required for all 3a deliveries. No unloading activities including removing gates, release tension in securing devices or anything holding the load secure shall commence until a Permit to Unload has been completed. All persons involved in the unloading procedure must sign the Permit to Unload to ensure that everyone participating understands the identified hazards and the selected safety controls. The Permit to Unload will be approved by an authorized representative of the site owner who is supervising the unloading. (See Exhibit ) After the Permit to Unload has been completed, and all load securing requirements are in-place, and all risks are identified and controlled, the Escort or Delivery Driver can remove locks & tags (or zip-ties & tags) as needed. 3b Deliveries - A Permit to Unload is required for any 3b delivery that has one or more of the following: 1) Potential stored energy that could shift, roll, tip-over, fall, or move once unsecured; 2) All wedged loads; 3) All potentially unstable loads or any load that may require stabilization (i.e. forklift or crane) prior to unloading. The Permit to Unload must be signed by all persons involved in the unloading procedures and be approved by the authorized representative supervising the unloading. (See Exhibit ) Page 7 of 10:

8 LOADING REQUIREMENTS The following requirements apply to KUC personnel, Rio Tinto personnel in KUC facilities, commercial truck drivers, and contractors participating in loading operations Cargo Loading Permit - Before the start of a loading operation, a Cargo Loading Permit (See Exhibit ) is required. o The Cargo Loading Permit is to be completed by an authorized KUC representative and the truck driver. o Where the authorized KUC representative is not the person who will operate the forklift or crane those operator(s) should also take part in the Cargo Loading Permit. o Any identified hazards and the corrective actions required to be taken, must be detailed in the controls section of the Cargo Loading Permit. The Cargo Loading permit is to be signed off by all persons involved in the loading operation to ensure that everyone participating is aware of the identified hazards and the selected safety controls. o A Cargo Loading Permit is not required for recurring loading operations (i.e. same load in same location) where an applicable risk based loading JSA / SOPs or risk assessment has been generated and reviewed with all persons involved in the loading operation Exclusion zones - Pedestrian exclusion zones are to be set and demarcated through the use of barricading or by the use of spotters during loading operations. Anyone not directly involved in the loading operation is not to enter these exclusion zones unless the forklift or crane operator has signaled that it is safe to enter and the forklift or crane operation has ceased all movement. (See Standard 16.3 Restricted Access Barricading o Loading operators will immediately stop work if the location of the driver cannot be confirmed or any pedestrian or vehicle enters the exclusion zone without permission. o The commercial truck driver is to remain outside the exclusion zone in a designated location (safety zone) during the loading operation unless otherwise instructed by the operator The following requirements apply when performing the task of loading any vehicle: Page 8 of 10:

9 o Trucks are to be loaded on level surface or safe surface that is as close to level as practicable. o Truck wheels are to be chocked and brakes set. o Forklift and crane operators are to ensure that their equipment is inspected and of suitable capacity to load the freight. (Know the weight of the load) o Persons performing rigging are to check and ensure that all rigging is inspected and all connections are correct prior to commencing a lift. o If a hazard is identified during loading, the KUC representative is to be contacted to assist in an agreed upon corrective action Loading team - The loading team may consist of: o An authorized KUC representative. o A trained loading operator (i.e. forklift / crane operator). o Riggers assigned to assist the crane operator. o Spotters / escorts site control personnel. o The truck driver Completion of loading - Once loading is complete drivers are responsible to physically check that their load is secure, and verify that there is no damage sustained to the consignment. Also, that all load restraint equipment (i.e. tarps, straps, dunnage) is properly applied and secured before driving / moving the vehicle Drivers will ensure that all loads entering public highways comply with all DOT Federal Motor Carriers Cargo securement Rules. o All vehicle structures, systems, parts and components used to secure cargo must be in proper working order. o Requirements concerning securement, working load limits, blocking and bracing are applicable to all loads being transported. All cargo securement systems must meet the requirements, except to the extent a commodity-specific rule imposes additional requirements that prescribe in more detail the securement method to be used. o Each tie down must be attached and secured in a manner that prevents it from becoming loose, unfastening, opening or releasing while the vehicle is in transit. Also, edge protection must be used whenever a tie down would be subject to abrasion or cutting at the point where it touches an article of cargo and or transport trailer. o The cargo securement system used to restrain cargo against movement must meet requirements concerning the minimum number of tiedowns. When an article of cargo is not blocked or Page 9 of 10:

10 positioned to prevent movement in the forward direction, the number of tiedowns needed depends on the length and weight of the articles and must meet DOT requirements. o Cargo must be firmly immobilized or secured on or within a vehicle by structures of adequate strength, dunnage (loose materials used to support and protect cargo) or dunnage bags (inflatable bags intended to fill space between articles of cargo or between cargo and the wall of the vehicle), shoring bars, tie downs or a combination of these. o Articles of cargo that are likely to roll must be restrained by chocks, wedges, a cradle or other equivalent means to prevent rolling. The means of preventing rolling must not be capable of becoming unintentionally unfastened or loose while the vehicle is in transit. o Articles of cargo placed beside each other and secured by transverse tie downs must be: - Placed in direct contact with each other, or - Prevented from shifting towards each other while in transit RECORDKEEPING Each KUC site is responsible for recording and retaining the following: o Class 1 Deliveries; o Class 2 Deliveries & assigned Site Owners; o Copies of all Class 2 Delivery SHEAP s or Delivery Risk Assessment & Control Plan; o Class 2 Bulk Chemical Unloading form o Class 3 Permits to Unload for 30 days if unload activity has no incident (or with the investigation if unload task activity has incident). o The Load Risk Assessment 30 days if loading activity has no incident (or with the investigation if loading activity has incident). REFERENCES DOT Federal Motor Carriers Safety Regulations (FMCSRs) Cargo Securement Handbook for Drivers J. J. Keller and Associates Product Code 445-H KUC Safety and Health Standard 16.3 Restricted Access Barricading The following forms are available in the Health and Safety eroom: Class 1 Delivery Driver - Tracking Sheet Class 2 Delivery Driver - Tracking Sheet KUC Access Point Map KUC Plant Site Parking Maps Page 10 of 10:

11 REVISION HISTORY: MOC# Description of Change Prepared By Date New Standard KUC Fatality Response Team; 09/09/2009 Review and approve by the KUC Standards Committee Changes submitted by Energy Services and Refinery H&S Advisor requiring a new form Bulk Unloading Acknowledgement Exhibit for Class 2 Deliveries Changes require an escort for all class 3a deliveries; defining the duties of the escort; require Security (or site owner) to provide driver a blank copy of a Permit to Unload ; and add new language to the back of the permit. Driver is required to read & sign back of permit and take the permit to the unloading site. Defines general requirement to apply locks / zipties and tags to all 3a load securing devices. Also, included requirements from the KUC 14.5 Loading Standard Changed the Loading Risk Assessment form to a Permit to Load; KUC Standards Committee 02/11 KUC Standards Committee 09/12 Curt Thompson 10/2013 initiated change, MOC approved 02/2014 Page 11 of 10:

12 Exhibit Class 2 Delivery Driver - Risk Assessment & Control Plan REV. 1 (08/09) DELIVERY ACTIVITY: VENDOR NAME (inc. Emergency Phone Number) KUC PLANT: CONTRACT # WORK AREA: KUC SITE OWNER (inc. Phone Number) Start Date: Review Date: Expiration Date: DESCRIPTION OF WORK KUC Site Owner s Description KUC Site Owner Responsible for identifying and checking potential HSE hazards and requirements. Vendor - Responsible for: 1.Addressing HOW identified hazards or requirements will be controlled/addressed 2.Including any additional risk that have not been identified 3.Reviewing all identified risk and controls with each driver Vendor Driver Responsible for knowing and following all identified controls KUC Hazard Identification Vendor Safety Controls 1. General check all applicable and describe any VENDOR Information additional requirements Regulatory required training requirements Provide list of drivers, training and date of completion and location (DOT/HAZMAT, MSHA and /or OSHA) of training records Describe required task training (all tasks that Provide list of drivers, training received and date of completion are performed specific to delivery) Driver can read, speak, and understand English Verification Notes: Complete facility site specific H&S training List training date. 2. Emergencies check all applicable and describe any additional requirements Immediate Reporting of Accidents, Injuries, Fire or Spills. KUC Site Emergency Phone Number and procedure. Vendor Emergency Contacts Notes: VENDOR CONTROLS (Do not call 911) List designated KUC Emergency #and procedure to report emergencies: Provide telephone numbers (24 hour contact); Page 1of 4 Plant: and supersede all other revisions.

13 3. Pre-Delivery Site Safety Tour (pre 1 st delivery) check all that are required Describe/Provide Pre-task Risk Assessment i.e. (TRACK) Site Specific Walk-Through Conducted by Site- Owner (required before first delivery only) Controlled Access Point -. Entry Point Identified Site Map/Route reviewed Delivery parking location identified on map Emergency Phone Identified Emergency Evacuation Area Identified Wind Sock Locations Identified Fire Extinguisher Locations Identified. Spill Equipment Location Identified Safety Showers & Eye Washes Identified Labeled Chemical Fill-Line located Notes: VENDOR CONTROLS Verification that employees trained on pre-task assessments. List who completed walk-through & date. List location/description Attached to Control Plan Attached to Control Plan 4. General Plant/Site Hazards/Requirements check all applicable and describe any additional requirements Railroad Crossings/Railcar Movement Semi-Truck Traffic Light Vehicle Traffic (Forklifts, Cars, etc.) Pedestrian Traffic Seat belts and Cell Phones requirements Notes: VENDOR CONTROLS 5. Delivery Site Specific Hazards or Potential Unsafe Condition Reviewed Pipes not labeled or unknown fill pipe Filling tank w/ wrong chemical Frozen or clogged hoses or fill-lines Slips, Trips & Falls (Snow, Ice, Water) Pinch Points (hoses, pumps, connections) Uneven / unleveled surfaces Safety Shower/Eye Wash not working Barricades or hazard tape needed for delivery Fall from height ladders/ stairs / platforms, etc. Forklift usage (totes, pallets, bags) Notes: VENDOR CONTROLS Contact site owner for direction Contact site owner to verify correct tank/chemical. Unlock fill line. Contact site owner for direction Contact site owner Contact site owner Driver required operate Safety Shower & Eye Wash before every delivery to verify water is flowing/available for an emergency. Contact site owner 6. Chemical Hazards VENDOR CONTROLS Delivery Driver has reviewed MSDS Delivery Driver has MSDS copy in Truck Notes: Verification that driver knows and understands potential hazards of chemical and emergency procedures Page 2of 4 Plant: and supersede all other revisions.

14 7. Truck Specific Hazards VENDOR CONTROLS Load unusual size Possibility of load shifting Load strapped or secured from movement Daily Truck Pre-Op Inspection Define procedure Delivery Truck Blind Spots Spotter needed Contact site owner Truck rolling/moving while parked Define procedure - Set emergency brake. Always Use Wheel Chock. Generating heat, arc, or other ignition source Describe procedure (i.e. grounding etc) while delivering flammable gases/liquids. Vehicle Fire Vehicle has ABC Fire Extinguisher No eating food/drink outside of truck cab Verification that this has been communicated No Smoking during delivery Verification that this has been communicated All Pets need to stay in cab Verification that this has been communicated All Truck passengers must stay in truck cab Verification that this has been communicated No loose items on truck (hoses, buckets, etc.) Verification that this has been communicated Lines capped after delivery Notes: Verification that this has been communicated 8. Personal Protective Equipment check all required VENDOR CONTROLS Required PPE Provided by Vendor Safety Glasses w/ sideshields Chemical Protective Gloves Cut Prevention Gloves (Leather, Kevlar, etc.) Chemical Splash Goggles Face Shield Chemical Protective Boots Chemical Protective Jacket Chemical Protective Pants/Bibs ½ Face Air Purifying Respirator Full-face air purifying respirator Respirator Cartridges Match Chemical Supplied Air (SCBA or Air-Line) Protective Shoes (Safety toe / Metatarsal) Hearing Protection Fall Protection if working above 6 or working from ladder without 3-point contact Hard hat Knee Pads Other Notes: PPE required to be provided by Vendor, verification that mandatory requirement to wear when out of vehicle has been communicated List Cartridge type: 9. Environmental Hazards VENDOR CONTROLS Spill outside of containment Describe procedure Spill from hoses, valves, connections Describe procedure Spill from truck Describe procedure Gas Release Describe procedure Emergency Spill/Release Number List Spill containment materials available No spill clean-up material will leave KUC Notes: Page 3of 4 Plant: and supersede all other revisions.

15 The Risk Assessment/Control Plan is required to be reviewed and signed by the KUCC Site Owner and Vendor to be valid. The approved Plan must be reviewed with each delivery driver and each driver must participate in a site safety tour. All drivers are required to have a signed copy of the Delivery Risk Assessment & Control Plan readily available for review and / or audit by any KUC representative regarding on-site deliveries. KUC Site Owner: Print Name Signature Date Vendor: Page 4of 4 Plant: and supersede all other revisions.

16 Exhibit KENNECOTT UTAH COPPER Class 3 Delivery Driver Permit to Unload (Standard 14.4) Rev 4 10/13 No unloading activities (including cargo unstrapping or cargo movement) are authorized until Permit to Unload is issued. Permit will be kept at unload site until unload activity work is complete. Originated By: (Print Name Below) Site Owner or Designee: (Print Name ) Date and Time Issued: AM PM Delivery Driver s Name: EMERGENCY NUMBERS (801) Delivery Driver Company s Name: c Mine c Concentrator c Smelter Unload Area / Specific Location: c Refinery cpower Plant c Tailings c MAP Cargo Unload Description: PRE-UNLOADING REVIEW A. Are the Truck/Trailer wheels chocked, brakes set, and parked on level solid ground? B. Has an area walk-through been conducted, area hazards reviewed, and TRACK discussed? c Yes c No C. Has the trailer been inspected for any damage (inc. Tires, straps, deck, side-rails, etc.)? c Yes c No D. Has the cargo been inspected for load damage or load shifting (inc. pallets, supports, wedges, straps, shrink-wrap, etc.)? c Yes c No E. Is there a current KUC JSA/SOP or Risk assessment for this unloading task and has it been reviewed? If YES, you may proceed to unload in accordance with the JSA/SOP. If NO, complete entire permit. AREA HAZARDS (Check only those that apply) 1. Truck Hazards/Risk 2. Park-up Area Hazards 3. Overhead Hazards 4. Cargo Lay-Down Area Hazards 5. Weather Hazards c Fall from truck trailer bed c Unlevel surface c Electrical Lines c Un-level/uneven surface c Snow / Ice c Vehicle engine left running c Pot holes c Piping c Predefined cargo lay-down area c Low Visibility (Fog or Dust) c Other Passengers c Unstable soil (mud/sand) c Roof Edges/eaves c Predefined cargo containment system c Rain and / or Lightning c Animals (e.g. dogs) c Slips/Trips/Falls c Vegetation (e.g. trees) c Slips/Trips/Falls c High Winds c c c c c POSSIBLE CARGO HAZARDS POSSIBLE UNLOADING HAZARDS c 6. Wedged cargo c 13. Straps/Chains Stored energy c 20. Unstable cargo after unstrapping c 27. Dropping cargo during lift c 7. Rolling cargo potential c 14. Movement after unstrapping c 21. Cargo center of gravity unknown c 28. Dropping cargo moving to lay-down c 8. Shifting cargo potential c 15. Movement upon gate removal c 22. Cargo weight unknown c 29. Observer area predefined c 9. Top-loaded items (high gravity center) c 16. Pinch points c 23. Lifting equipment capacity unknown c 30. Vehicle traffic (trucks, railcars) c 10. Potential unstable cargo c 17. Sharp surfaces c 24. Rigging capacity unknown c 31. Pedestrian traffic c 11. Multiple pieces of cargo c 18. c 25. Person falling from truck bed c 32. Pinch points c 12. Cargo damage (Pallets, wedges, c 19. c 26. Spotter needed for cargo lift c 33. IDENTIFIED UNLOAD HAZARDS AND SAFETY CONTROL IMPLEMENTED No. Safety Controls Implemented No. Safety Controls Implemented c Yes c Yes c No c No REQUIRED PERMITS REQUIRED EQUIPMENT c Falls - Working at Heights c c Crane c Barricade Tape & Tag c Crane - Critical Lift c c Forklift c Lifting Tag Line c Electrical - Close Proximity c c Rigging c REQUIRED PERSONAL PROTECTION EQUIPMENT c Hard Hat & Safety Glasses c Shirt & Long pants c Hearing Protection c c Safety Footwear c Cut resistant gloves (Kevlar / leather) c Fall Protection c UNLOAD REVIEW and ACCEPTANCE - I have been instructed as to the conditions of this permit and I am adequately trained to perform this unloading task. Print Name Signature Date FINAL PERMIT TO UNLOAD IS APPROVED BY THE authorized representative of the Site Owner supervising the Unloading TITLE: PRINT NAME: SIGNATURE: and supersede all other revisions.

17 Back of Permit DRIVER INSTRUCTIONS FOR OFF-LOADING TRUCKS 1) SECURITY WILL CONTACT YOUR ESCORT; DO NOT MOVE YOUR TRUCK UNTIL ADVISED. 2) DO NOT UN-STRAP OR LOOSEN LOAD UNTIL PERMIT TO UNLOAD HAS BEEN COMPLETED AND ADVISED BY SITE OWNER IT S SAFE TO BEGIN UNSTRAPPING LOAD. A FORKLIFT OR CRANE MAY BE NEEDED TO STABILIZE THE LOAD BEFORE UNSTRAPPING. 3) WHEN LEAVING TRUCK CAB, WEAR ALL REQUIRED PPE. DO NOT LOOSEN OR UNSTRAP LOAD UNTIL ADVISED I understand and will follow the instructions I have read, and/or that have been explained to me by a KUC Representative (e.g. Security, Escort or Site Owner). Driver Signature: 4) ESCORT OR DELIVERY DRIVER TO ATTACH KUC LOCK &TAG(or ZIP-TIES & TAG)TO ALL IDENTIFIED RESTRAINTS OUTLINED in Lock &Tag Lock & Tag Zip-tie & Tag Zip-tie & Tag Escort Signature: (The escort confirms by signing this document that they are listed on the approved escort register) ******************************************************** When is a Permit to Unload Required? 3a Deliveries A Permit to Unload is required for all 3a deliveries. 3b Deliveries - A Permit to Unload is required for any 3b delivery that has one or more of the following: 1) Potential stored energy that could shift, roll, tip-over, fall, or move once unsecured; 2) All wedged loads; 3) All potentially unstable loads or any load that may require stabilization (i.e. forklift or crane) prior to unloading. and supersede all other revisions.

18 Exhibit DRIVER INITIAL KUC INITIAL Bill of Lading No. KUC Customer / Bulk Chemical Unloading Acknowledgement **PRODUCT TANK IDENTIFICATION** BEFORE ANY HOSES ARE CONNECTED I have verified that the product shown on the Bill of Lading matches the product identification shown on the storage tank. DRIVER Write down the Product Name on the Bill of Lading: CUSTOMER Write down the Product Name on the Bill of Lading: DRIVER CUSTOMER Write down the Product Name on the Customer s Storage Tank and Hose Connection: DRIVER INITIAL KUC INITIAL I have verified that the delivery hose connection to the customer plumbing connection is going to the correct storage tank. DRIVER INITIAL KUC INITIAL I have verified that the storage tank has enough capacity to receive the FULL contents of this load. If there in not room in the tank for the entire load, the driver and customer should determine a means of communicating the tank volume so the tank does not overflow. DO NOT PROCEED IF UNCERTAIN. STOP AND CONTACT SUPERVISORS IF ANY QUESTIONS Initial each box above, and then sign your name. Customer Signature : ( must be legible) Print Name Title: Driver Signature: ( must be legible) Print Name Date: Control Document No. and supersede all other revisions.

19 Exhibit KENNECOTT UTAH COPPER Cargo Loading Permit (Standard 14.4) Rev 1 02/14 No loading activities requiring a forklift or crane to load are authorized until Cargo Loading Permit is issued. Permit will be kept at loading site until loading activity is complete. Originated By: (Print Name Below) Site Owner or Designee: (Print Name ) Date and Time Issued: AM PM Delivery Driver s Name: EMERGENCY NUMBERS (801) Delivery Driver Company s Name: c Mine c Concentrator c Smelter Loading Area / Specific Location: c Refinery cpower Plant c Tailings c MAP Cargo Load Description: A. Is the truck / trailer parked on level solid ground, brakes set, and wheels chocked? PRE-LOADING REVIEW B. Has an area walk-through been conducted and TRACK discussed? c Yes c No C. Are the appropriate trained people and suitable equipment available for loading activities? c Yes c No D. Has a spotter been assigned to help loader, and been assigned the responsibility to keep the driver and all other pedestrians away from the load lift? c Yes c No E. Is there a current KUC JSA/SOP or Risk assessment for this loading task and has it been reviewed? If YES, you may proceed to load in accordance with the JSA/SOP. If NO, complete entire permit. AREA HAZARDS (Check only those that apply) 1. Truck Hazards/Risk 2. Park-up Area Hazards 3. Overhead Hazards 4. Cargo Hazards 5. Weather Hazards c Fall from truck trailer bed c Unlevel surface c Electrical Lines c Has stored energy c Snow / Ice c Vehicle engine left running c Pot holes c Piping c Can tip or fall without support c Low Visibility (Fog or Dust) c Other Passengers c Unstable soil (mud/sand) c Roof Edges/eaves c Lite cargo. Can be blown over c Rain and / or Lightning c Animals (e.g. dogs) c Slips/Trips/Falls c Vegetation (e.g. trees) c Loose cargo or in multiple pieces c High Winds c c c c c POSSIBLE LOADING HAZARDS POSSIBLE CARGO SECUREMENT HAZARDS c 6. Dropping cargo moving from lay-down c 13. Cargo center of gravity unknown c 20. Unstable cargo (tip, shift, roll, etc.) c 27. Cargo needs wedges or cradle c 7. Dropping cargo during lift onto truck c 14. Cargo weight unknown c 21. Multiple pieces of cargo c 28. Cargo needs blocking or bracing c 8. Spotter needed for cargo lift c 15. Lifting equip. capacity unknown c 22. Using worn or damaged restraints c 29. Cargo needs edge protection c 9. Top-heavy items c 16. Rigging capacity unknown c 23. Unknown strap or binder capacity c 30. Pinch points tightening restraints c 10. Driver / pedestrians near lift c 17. Contaminated cargo c 24. Climbing on truck bed / person falling c 31. c 11. Vehicle traffic (railcars, trucks) c 18. Pinch points / sharp surfaces c 25. Need to support cargo with forklift / crane before securing to bed c 12. Damage to pallet, crate, wrap, etc. c 19. c 26. Need to calculate number of straps/binders & their capacity (calculations on back of permit) IDENTIFIED LOAD HAZARDS AND SAFETY CONTROL IMPLEMENTED No. Safety Controls Implemented No. Safety Controls Implemented c Yes c Yes c No c No REQUIRED PERMITS REQUIRED EQUIPMENT c Falls - Working at Heights c c Crane c Barricade Tape & Tag c Crane - Critical Lift c c Forklift c Lifting Tag Line c Electrical - Close Proximity c c Rigging c REQUIRED PERSONAL PROTECTION EQUIPMENT c Hard Hat & Safety Glasses c Shirt & Long pants c Hearing Protection c c Safety Footwear c Cut resistant gloves (Kevlar / leather) c Fall Protection c LOAD REVIEW and ACCEPTANCE - I have been instructed as to the conditions of this permit and I am adequately trained to perform this loading task. Print Name Signature Date FINAL CARGO LOADING PERMIT IS APPROVED BY THE authorized representative of the Site Owner supervising the loading activity TITLE: PRINT NAME: SIGNATURE: and supersede all other revisions.

20 Non-mandatory Calculating Load Securement (Use most stringent calculation between weight & length) Weight Securement Load Weight & Restraints Calculations EXAMPLE Restraints through, over, or around the cargo: The working load limit (WLL) for each restraint that goes from an anchor point on the vehicle to another anchor point on the vehicle. KUC Calculation Restraints through, over, or around the cargo: Load weight = 30,000 lbs. (LW) Each restraint = 4,000 lbs. (WLL) Number of restraints = 4 (R) Load Weight = (LW) Restraint WLL = (WLL) 1) 30,000 lbs. x ½ = 15,000 lbs. 2) 4000 lbs. x 4 restraints = 16,000 lbs. (WLL) 16,000 lbs > 15,000 lbs = Meets DOT securement (Line 2 is greater than line 1 = Meets DOT) 1. (LW) x ½ = 2. (WLL) x (R) = EXAMPLE Restraints attached to cargo: One-half the working load limit (WLL) of each restraint that goes from an anchor point on the vehicle to an attachment point on an article of cargo KUC Calculation Restraints attached to cargo: # of Restraints = (R) Load weight = 20,000 lbs. (LW) Each restraint = 5,400 lbs. (WLL) Number of restraints = 4 (R) Load Weight = (LW) Restraint WLL = (WLL) # of Restraints = (R) (If line 2 is greater than line 1 = Meets DOT) 1) 20,000 lbs. x ½ = 10,000 lbs. 2) 5,400 lbs. x 4 binders = 21,600 lbs. 3) 21,600 x ½ = 10,800 lbs. 10,800 lbs. > 10,000 lbs. = Meets DOT securement (Line 3 is greater than line 1 = Meets DOT) 1. (LW) x ½ = 2. (WLL) x (R) = (WLLR) 3. (WLLR) x ½ = (If line 3 is greater than line 1 = Meets DOT) Load Length - Securement Minimum # of Restraints Calculations EXAMPLE Loads 5 feet or less in length, and 1 weighing 1,100 lbs or less. First 5 ft = 1 Restraint EXAMPLE Loads less than 5 feet in length, weighing more than 1,100 pounds. EXAMPLE All Loads between 5 10 feet in length. 2 2 First 5 ft = 2 Restraints EXAMPLE Loads longer than 10 feet in length 2 (plus 1 restraint for each additional 10 feet, or part thereof) KUC Calculation Number of Restraints calculated by length of load Total Load Length = 5-10 ft = 2 Restraints Longer than 10ft = TBD 1) First 5 feet = # of Restraints 2) 5 10 Feet = # of Restraints 3) Over 10 feet = # of Restraints Total Min # of Restranits = and supersede all other revisions.