Owner: Judy Brinkman Site Director

Title: Contractor Management Procedure Site Function: Ecology, Health & Safety Procedure No.: 4.03 Page: 1 of 12 Kankakee Reviewed: 08/16/2016 Effective: 08/16/2016 Supersedes: 10/2/09 Preparer: Jodie Turner TES Contractor Supervisor Owner: Judy Brinkman Site Director Approver: Travis Rollins TES Manager 1. PURPOSE To establish minimum environmental, health, and safety (EHS) requirements for the qualification and oversight of Contractors for the Kankakee Site. 2. DEFINITIONS 2.1. BASF Contractor Safety Improvement Leader This BASF employee or designee is the point person for the site for communication, performance strategy as well as the point of contact for all contractor safety concerns. 2.2. Competent person An individual, by way of training and/or experience; is knowledgeable of applicable standards and guidelines is capable of identifying existing and predictable hazards in the surroundings or working conditions which are hazardous to employees is designated by their employer, and has the authority to take appropriate actions 2.3. Contractor A company which will be either placing or bringing contractor(s), temporary (contract) employee(s) or contractor employee(s) onto the Kankakee site. 2.4. Subcontractor A subcontractor is a company that has a direct agreement or contract with a contractor hired by BASF to perform work at Kankakee. 2.5. Contractor employee A contractor employee is an individual engaged by or through a third party to perform services principally for the third party and whose day-to-day activities are directed by the contractor company, not BASF. 2.6. Contingent staff Contingent staff is an individual for whom BASF provides direct supervision in their day-to-day activities and direction as to how an activity is to be performed. 2.6.1. Temporary agency worker Is a worker providing temporary labor employed by a temporary staffing agency or directly through a managed service provider for a period of short duration, typically around one year, and typically in areas such as light industrial, administrative/clerical, laboratory or an accounting support role. Printed On 11/18/16 Printed copy is uncontrolled

2.6.2. Contracted worker Is a worker employed by a consulting firm or a temporary staffing Agency to provide service to BASF pursuant to a contract between BASF and the firm, typically for a large project and typically within areas such as IT, engineering, or maintenance and management consulting services. 2.7. Field Audits A process of conducting field reviews of contractor employees, to ensure that the contractor is performing to BASF expectations and to identify and mitigate hazards to ultimately eliminate or reduce injuries and illnesses. 2.8. Managed Service Provider (MSP) An MSP is a third party company that facilitates selection, on-boarding, oversight and off-boarding processes for temporary agency workers at BASF. 2.9. CSSP (also known as Contractor Screening Service Provider) Contractor Screening Service Provider (CSSP) is a service provider that maintains a qualification system and database for managing the EHS processes and systems for BASF contractors and managed service providers (MSPs). 2.10. CSSP exempt list The CSSP exempt list consists of contractor companies who meet the service personnel definition. 2.11. PQF (pre-qualification form) A PQF is a questionnaire used to evaluate contractors to determine EHS qualification to work at BASF. 2.12. Pre-task plan (PTP) A PTP is a written plan such as a Job Safety Analysis (JSA) or Job Hazard Analysis (JHA) that describes job tasks in step-by-step sequence, identifies associated hazards for each step, and outlines proper hazard controls that minimize/mitigate the risk of injury or illness to the individual(s) performing that task. 2.13. BASF contact Sometimes referred to as a process owner, requisitioner or job representative, is a BASF employee who identifies scope of work and requests contracted services. 2.14. Safe work permits Safe work permits are written authorization to perform work describing tasks, associated risks, and appropriate control measures. 2.15. Contractor Safety Concept A contractor safety concept is a written safety plan for major projects, e.g., turnaround, shut down, plant expansion projects, etc. 2.16. Service personnel Service personnel provide service work that traditionally poses low EHS risk to production related processes or facilities and does not involve or introduce EHS hazards to the work area. 3. SCOPE This procedure applies to contractors at the Kankakee Site.

4. PROCEDURE 4.1. General Requirements 4.1.1. Program Management A. Contractors and subcontractors working at Kankakee must meet minimum EHS qualification criteria for work that: affects or has the potential to affect the EHS of manufacturing or manufacturing-related areas, laboratories, or offices. introduces chemical or physical hazards into the work area, such as generating a hazardous chemical exposure, operating machinery or powered equipment/tools, or generating hazardous waste. Section 4.2.1 details contractor risk classification. B. Kankakee uses a CSSP to facilitate the EHS qualification process for all contractors. C. All subcontractors must be registered with our CSSP and meet the same EHS qualification criteria. BASF Procurement is responsible for informing the managing contractor of this requirement in the contract documents. D. The EHS approval process for a contractor that provides only contingent staff is outlined in the BC032.033 corporate procedure. If the contractor provides both contingent staff employees and contractor employees, the contractor is required to obtain EHS approval per this procedure. E. Kankakee has a Contractor Safety Improvement Leader that reports through the TES organization. The Contractor Safety Improvement leader is responsible for ensuring concepts of the contractor EHS performance strategy are in place at the site. 4.2. Contractor Selection A BASF service purchase order, service contract, or any other formal agreement to work cannot be generated for a contractor to work at a BASF site that has not been EHS reviewed and approved. The method illustrated in 4.03.01 Site Service Purchase Requisition Process shall be used. 4.2.1. Full EHS Approval BASF currently uses a CSSP to coordinate contractor qualification. The process is as follows. 1. BASF contact identifies scope of work and/or contractor. 2. BASF notifies contractor of BASF approval requirements. 3. Contractor contacts and registers with our CSSP. 4. CSSP assigns a risk classification to contractor based upon contractor work capability or scope. Effective Jan. 1, 2014, the classifications have changed from low, medium and high risk to the following: a. Non-Safety Sensitive (pre-2014 low risk CSSP ranking) contractors whose work has traditionally posed a minimal EHS risk. Examples typically include: office janitorial offsite/office engineering lawn care/lawn maintenance (excluding landscaping) IT(information technology, software development) office equipment repair uniform laundry

b. Safety Sensitive (pre-2014 medium and high risk ranking from our CSSP) - contractors whose work involves higher risk activities where there is incident potential. Examples typically include: shipping and receiving activities landscaping/weed abatement pest control abatement/remediation confined space demolition lockout/tagout elevated work mobile crane operation electrical work hazardous waste hot work work over water rigging trench and excavation work 5. CSSP reviews contractor PQFs and related EHS information according to the minimum BASF criteria: total recordable incident rate (TRIR) 3 - year average of 1.8 or less days away from work case rate (DAFWCR) 3 - year average of 1.0 or less experience modification rate (EMR) of 1.0 or less no regulatory citations within last 3 years no fatalities within last 3 years EHS programs and procedures in place to meet regulatory and BASF s requirements. 6. An initial flag color is assigned by the CSSP as stated below: Green Full EHS approval when all regulatory and BASF criteria are met. Red signifies deficiencies in meeting regulatory and or BASF requirements based off the type of work the company performs. 7. If EHS qualification and approval criteria are met (green flag status), then the contractor is eligible to participate in the selection process or may continue service to BASF as long as technical and procurement approvals are in place. 8. If subcontractors are to be used, a list of those subcontractors must be disclosed to BASF for qualification and approval before work performance. The qualification and approval process for subcontractors is the same with the exception that the managing contractor may be required to facilitate transfer of necessary documents to our CSSP for evaluation. *Refer to 4.03.02, Contractor EHS Approval Flowcharts and RACI, for additional guidance. 4.2.2. Conditional EHS Approval

1. When contractors do not meet minimum EHS performance criteria (e.g., EMR, TRIR, DAFWCR, regulatory compliance history, or EHS programs), the site may grant a conditional approval. This should be case-by-case with consultation from EHS, Procurement, Engineering, Maintenance, and Operations considering the following situations: contractor previous safety performance within BASF safety performance trends within recent years comparison with contractor industry average from the U.S. Department of Labor / Bureau of Labor and Statistics nature of any safety program deficiencies regulatory agency compliance history nature of citation and abatement scope or risk level of work to be performed presence of contractor EHS professional on site availability of alternative safer contractor companies Conditional approval (force red to yellow) allows the contractor to work at a facility under certain prescribed conditions. Only BASF may assign a conditional approval for a contractor, not the CSSP. The Kankakee site may grant full approval (force red to green) if the nature of the deficiency warrants, such as minor regulatory citations, etc. *Refer to 4.03.03, Contractor Conditional Approval Decision Tree, for additional guidance. 2. Once conditional approval is decided, all information shall be documented and saved with the CSSP via the Forced Flag Form (4.03.04 BASF Forced Flag Form). Acceptable conditional work requirements include, but are not limited to: providing an escort increased supervision increased number of field audits additional training conducting periodic EHS meetings or safety huddles developing and implementing contractor journey roadmap developing or improving specific EHS plans, such as confined, space entry, respiratory protection, fall protection, forklift operation, etc. providing medical surveillance 4.2.3. Emergency EHS Approval 1. A site manager or designee may grant emergency approvals for a contractor in consultation with EHS, Engineering and Maintenance, and Procurement. Emergency approvals are temporary and valid for the emergency job only. Once the emergency job is completed, the contractor is required to participate in the EHS qualification and approval process for continued work at a BASF site. Examples of emergency approvals may include: short-term remediation of spill or release unplanned repair of process-related equipment impacting production correction of high-risk unsafe workplace condition

2. When emergency approvals are granted, site management, EHS and/or Procurement may require additional EHS measures such as increased supervision and/or auditing of the work throughout the job. 3. Emergency approvals must be documented and retained for the purposes of performing the contractor management system review. 4.2.4. Service Personnel Designation Providers of service whose work has traditionally posed low EHS risk to production related processes or facilities and does not involve or introduce EHS hazards to the work area, can be considered service personnel. For example, performing routine interim work on nonmanufacturing equipment such as bench top laboratory equipment, vending machines, and office equipment/cleaning are service personnel tasks. The determination for the service personnel classification must be made by the EHS Specialist and must be based on knowledge of the work that the service provider is capable of performing. 4.3. Pre-Access to Site If it is determined that the contractor meets the service personnel designation, the BASF contact and the EHS Specialist will work with procurement to add the company to the CSSP exempt list. *A list of suggested trades that could qualify as service personnel is included in 4.03.05 Suggested Service Personnel List. 4.3.1. Kankakee Requirements 1. A BASF contact shall be identified for each contractor job. 2. The BASF contact will be responsible for ensuring all EHS requirements are met before the contractor employee(s) begins work. 3. The BASF contact shall ensure retention of contractor job EHS performance documentation, such as, records of inspections, job observations, and incidents. 4. The BASF contact shall ensure contractor employee accidents/incidents are entered in AIMS. 4.3.2. Contractor Safety Concept For major projects involving special or complex hazards, e.g., shut-down or plant expansion projects, representatives with adequate knowledge of the process, materials, and equipment (e.g., maintenance or construction engineer, defined EHS professionals) shall develop a concept for the implementation of the contractor safety requirements. The safety concept includes: planning activities related to process and location specific hazards coordination and scheduling of work between different contractors and BASF employees (avoiding risks because of interaction of different activities) specific safety plans for high-risk contractor work (e.g., demolition activities) Contractor safety contact (safety supervisor) to contractor worker ratios established based off of risk and agreed to prior to work beginning. (e.g. construction project may have a 1 full time safety supervisor for every 25 workers ratio, 1:25) ensuring that contractors know the necessary BASF contacts (or contacts to the main contractor for turnkey projects) for possible questions or issues concerning safety

specific safety supervision of the construction site on a regular basis (e.g., safety tours, safety supervisions), regular consultations held to discuss critical points and ensure all employees are informed of the applicable safety requirements, and multi-contractor coordination measures necessary to avoid accidents because of potential increase risk from on-going simultaneous work activities. Before starting the work, this concept shall be discussed with the construction/ maintenance managers of the contractors and relevant BASF services. All affected contractors must sign the implementation plan. After that, the contractors must inform all their employees about the applicable safety measures. Whenever a change in the scope of the activities occurs, the concept must be changed accordingly. *Refer EHS 4.03.07 Contractor Safety Concept Template for Construction Projects for additional guidance. 4.3.3. EHS Site Orientation 1. Before work begins, all contractors must have attended a Contractor Safety Certification training program provided by a BASF-Approved Training Provider (OSHA 10 or 40-hour course, Prairie State Council, Three Rivers Contractor Council, or Houston Area Safety Council), and shall receive the Kankakee site specific EHS orientation. All contractor employee EHS orientations shall include: practices to control the entrance, presence and exit of contractor employees means for contractor to provide the BASF site with information about hazards that the contractor employees may generate means to ensure that the contractor employee informs BASF of any chemicals brought on-site means to ensure that contractor employees are included in any BASF sponsored accident/incident investigations that involve them or their work overview of Kankakee s field auditing and DASH programs emergency plans, alarms, and evacuation procedures known or potential hazards, such as, confined spaces, chemical hazards, asbestos, lead, electrical, fire, explosion, or process hazards related to the contractor employees work or work area provisions for the right to inspect work and stop work as appropriate means to ensure effective communication and understanding with non-english speaking contractor employees *Refer to 04.03.08 Contractor Orientation Checklist. 4.3.4. Pre-Access / Pre-Job EHS Process This process is not a site orientation, but a structured and documented dialog between the BASF contact or designee, and the contractor crew representative (supervisor, general foreman, safety representative, superintendent, etc.) responsible for executing the work. The minimum information covered in the pre-job process will be: contractor company contractor company responsible and accountable manager s name

foreman information responsible for the on-site work (name, phone number, etc.) direct supervisor of the foreman completing the work on site (name, phone number, etc.) the work history of the foremen completing the work on site (how long have they been foremen, what training do they have, etc.) the safety professional responsible for the work being completed on site (name, phone number, qualifications, etc.) the BASF contact information responsible for the work being completed on site the specific procedure if one of the contractor employees is injured on site (e.g., whom to call for severe medical, 911, plant security, etc.) Do they have a local medical clinic relationship established to treat non-life-threatening injuries? incident investigation process for the site pre-task planning (PTP) process requirements access to the site safety rules specific craft training requirements 4.4. Work Execution *See 4.03.09 BASF Pre-Access Pre-Job Checklist 4.4.1. Exposure Reduction Process The Kankakee Site HAS implemented the D.A.S.H observation process to address behavioral based safety. Participation is expected off all contractors. The nested contractors on-site participate as observers as well as observed. 4.4.2. Contractor Safety Contact to Worker Ratio It is recommended that a safety contact to worker ratios be established at the site for all work being performed by contractors. Whether it is maintenance or construction, a risk-based evaluation should be done for the work and a ratio established. This element should be part of the site written program for contractor employee oversight. For example: a ratio of one (1) full time contractor s safety contact will be on site for 25 or greater contractor employees. Less than 25 employees will be a minimum of one (1) part time contractor s safety contact unless otherwise specified by BASF. 4.4.3. Contractor Field Audit Program 1. The Kankakee Field audit program covers all phases of activities at the site. All levels of management perform audits throughout the plant utilizing the field audit booklet which uses topics such as; housekeeping, scaffolding, permitting, LOTO, tools and equipment, etc. 2. Training may be provided by EHS or another trained active auditor. 3. Feedback is given immediately to the crew being audited. 4. A copy of the audit will be sent to EHS for entry into a tracking spreadsheet. 5. The data collected in the spreadsheet should be shared with the nested contractors on a quarterly basis during their reviews scheduled by the Contractor Safety Improvement Leader. 6. The minimum frequency for conducting field audits for contractors shall be:

Green flagged contractors shall be audited quarterly. Yellow flagged contractors shall be audited monthly. High risk work (crane lifts, etc.) should be audited daily regardless of flags. Turnaround and large project work would require daily auditing as well. Note: The frequency and type of observations for a conditionally approved contractor may be determined during the conditional approval process with the results documented with the CSSP. 4.4.4. Pre-Task Planning (PTP) All Contractors approved to work at BASF facilities via Safe Work Permits are required to have, at minimum, a PTP process. As a minimum, all PTP s shall have the following elements: Job/Project Title Job Location Date Crew members signoff Task Description / job step Risk/Hazard Description for each job step Risk/Hazard Controls / elimination / mitigation for each recognized hazard The criteria above may be captured on and during the permitting process. However, the PTP tool is typically a separate document and must be reviewed by all members of the work crew. Individual task planning cards may be used to meet the intent of the PTP process as long as the supervisor in charge of the work reviews the individual plan. *See Section 6, Related Documents, Attachment #10, for copy of a BASF acceptable PTP form 4.5. Monitoring, Evaluation and Feedback 4.5.1. Contractor Periodic Reviews 1. EHS performance data and insurance requirements for all contractor risk classifications shall be updated annually. 2. Contractor classified as safety sensitive will receive an audit of their safety program manual through the CSSP at least every three years. The review shall include contractor injury statistics, EMR, regulatory agency citations, and EHS programs as stated in 5.2.1. 3. The results and findings of the annual and/or 3 year review may be used to adjust the contractor approval status. 4.5.2. Kankakee Contractor Management System Review/Safety Performance Evaluation The CSIL shall review the effectiveness of practices at least annually to ensure that the contractor management system is properly implemented and the elements adequately support contractor performance improvement. As a minimum, the following elements of the contractor management system shall be included in the review:

Review this site procedure to ensure written requirements are in agreement with BC032.002 BASF Contractor EHS Management. Participation of affected stakeholder in the development and/or revision of site procedure for adequacy. Adequate understanding of contractor management roles and responsibilities among affected stakeholders (Procurement, Engineering, Maintenance, Operations, EHS, etc.). System to provide opportunity for feedback and communication with contractor employees, e.g., meetings, exchanges, forums, etc. Maintenance of contractor approval documentation. Efficiency and adequacy of conditional approval process. Efficiency and adequacy of emergency approval process. Documented contractor orientation performed in a timely manner before work. Verification mechanism in place to ensure contractor orientation was understood. Contractor field audits performed adequately, timely with appropriate follow-up. Information/data from affected stakeholders (procurement, operations, maintenance, engineering, EHS, etc.) adequate and accessible in order to conduct periodic contractor reviews or re-approvals. Safety performance review of high risk contractors. Results of annual management system review communicated to affected stakeholders. 5. RESPONSIBILITIES *Refer to 4.03.11 Contractor EHS Management System Checklist 4.5.3. Contractor Hours Accounting All contractor companies will turn in hours each month for the work that is completed at the BASF sites. Each site should have a means to reasonably reconcile these hours on a periodic basis. Some of these means to reconcile can be: 1. Invoicing data 2. Sign-in and out logs with site security 3. Scan-in and out systems (badging programs) 4.5.4. Contractor Safety Forums 5.1. Site Director Kankakee will facilitate annual contractor safety forums. The purpose of the Contractor Safety Forums is to facilitate collaboration and alignment (two way dialogue) between BASF and our contractor partners. Communicate the BASF Safety Culture to our contractors. Communicate all BASF expectations regarding contractor safety including upcoming initiatives. And share best practices among various contractor companies. Desired End Result: Drive the Zero Incident Mindset within our contractor partners, thereby ultimately improving safety performance. *Refer to 4.03.12 Contractor Safety Forum Agenda Example document for more information.

The Site Director of Kankakee has the primary responsibility for the implementation of this procedure. 5.2. TES Manager The TES Manager has the primary responsibility for the initiation, re-issuance, administration, and/or interpretation of this procedure. 6. RELATED DOCUMENTS 4.03.01 Site Service Purchase Requisition Process 4.03.02 Contractor EHS Approval Flowcharts and RACI 4.03.03 Contractor Conditional Approval Decision Tree 4.03.04 BASF Forced Flag Form 4.03.05 Suggested Service Personnel 4.03.07 Contractor Safety Concept Template for Construction Projects 4.03.08 Contractor Orientation Checklist 4.03.09 BASF Pre-Access Pre-Job Checklist 4.03.10 PTP Form Example 4.03.11 Contractor EHS Management System Checklist 4.03.12 Contractor Safety Forum Agenda Example 7. REFERENCES The following documents were referenced in creating this procedure: BC032.002 BASF Contractor EHS Management 8. TRAINING Plant personnel will receive initial training regarding this procedure and additional training if significant changes are made to it.

9. PROCEDURE REVIEW/REVISION HISTORY Revision No. Reason Initiator Date No. 0 New Procedure D. Deighton 4/19/1994 1 Procedure Update / Revision D. Deighton 5/5/1994 2 Procedure Update / Revision D. Deighton 8/1/1996 3 Procedure Update / Revision D. Deighton 12/6/1996 4 New procedure name and number, new N. Christain 2/1/2000 manual name, minor revisions. 5 Remove Visitor and correct details K. Carrell 8/21/2003 6 Visitor portion was removed from procedure K. Carrell 3/23/2004 and placed into a new procedure. 7 Contractor plant entrance, section 5.1 was P. Snapp 3/20/2006 removed and placed into EHS procedure 4.04. Updated medical treatment information. 8 Renamed Procedure Contractor Safety M. Haller 1/4/2008 Procedure ; Replaced BASF Representative with Contract Initiator; Incorporated all of PSM Chapter 8. 9 Revision history from this date forward is M. Haller 10/2/2009 being maintained in Domino.doc. 10 New procedure Contractor Management Procedure replacing Contractor Safety Procedure 4.03. J. Turner 8/16/2016