Wegmans Process Safety Management Ammonia Awareness Affecting Contractors

1. WegmansProcess Safety Management Ammonia Awareness Affecting Contractors

2. Process Safety Management (PSM) • Regulation was put into effect by OSHA in which an analytical tool/plan focuses on preventing releases of any substance defined as a “highly hazardous chemical” by OSHA and the EPA. (29CFR1910.119) Since 1992

3. 14 Elements of PSM • Employee Participation • Process Safety Information (PSI) • Process Hazard Information (PHA) • Written/Standard Operating Procedures (SOP’s) • Training • Contractor Awareness • Pre-Start Up Safety Review • Mechanical Integrity (MIP) • Hot Work Permit Program • Management of Change (MOC’s) • Incident Investigation • Emergency Response Plan (Integrated Contingency Plan) • Compliance Audit • Trade Secrets

4. Risk Management Program (RMP) • Regulation was put into effect by EPA in which facilities with explosive, flammable or toxic materials above the threshold quantities are required to manage accidental chemical release prevention. (40 CFR part 68) Since 1999

5. Process • Any activity or combination of activities including any use, storage, manufacturing, handling or the on-site movement of highly hazardous chemicals as defined by OSHA and the EPA.

6. Wegmans has 3 covered processes above 10,000 lb. of anhydrous ammonia • 300 Market Street has 15,000 lbs. Anhydrous Ammonia • 360 Market Street has 14,000 lbs. Anhydrous Ammonia • 500 Market Street has 23,000 lbs. Anhydrous Ammonia • Note: Majority of the piping is on the roofs

7. SDS/MSDS Anhydrous Ammonia

8. Who in addition to Wegmans Employees must comply? • Any contractors that are affecting the system • Any contractors that are being affectedby the system • An affecting contractor works directly or adjacent to the system • An affected contractor works in any of the Wegamans Market St. facilities. • Note: Any contractor in this meeting is considered an affecting contractor

9. Who in addition to Wegmans Employees must comply? • Contractors performing maintenance or repair work on or adjacent to a covered process. • Contractors performing turnaround work on or adjacent to a covered process. • Contractors performing major renovation work on or adjacent to a covered process • Contractors performing specialty work on or adjacent to a covered process • Any Subcontractors doing the above work

10. Wegmans Duty to Contractors • Inform principals of the companies, providing contracting services, potential dangers our processes might pose to their employees • Inform principals of the companies, providing contracting services, Asset Protection’s protocol in the event of an onsite emergency • What Wegmans will do • What Contractor’s employees should do • Inform principals of the companies, providing contracting services, Wegmans protocol for their employees to enter, work at and exit the site. • Post form 300A and ensure the contractors maintain an OSHA Log. Copies of the log will be taken, upon notifications of any injuries.

11. Contractors’ Duty to Wegmans Inform Wegmans of any and all hazards their employees might discover. Inform Wegmans of any unique hazards the work might present (i.e. hazardous chemicals, flammable chemicals, hot work, overhead work) i. Wegmans retains the right to deny such work practices ii. If acceptable, Wegmans retains the right to make needed notifications, or adjustments

12. Contractors’ Duty to Wegmans Educate and train their employees Retain and supply documentation of said training. Identify which employees have been trained. Wegmans may verify. Maintain an OSHA Log and inform Wegmans immediately of any OSHA recordable injuries at Wegmans. Must have all SDS of materials in custody on site

13. PSM training is required BEFORE contractor will be issued an Access Card to enter the Market Street Facility

14. Building Security

15. PSM Ammonia Awareness Video https://www.youtube.com/embed/61bF6Q4Uu5g?rel=0 Spanish or English subtitles are available by selecting the Closed Caption/Subtitle Button and then clicking the gear (settings) icon and selecting either English or Spanish Note: This is a new video so please use this link or a new DVD, not the old one

16. Evacuation Plan

17. No parking/No obstruction/No crane activity zones

18. Roof Access SOG

19. Documentation Needed • CQ-1 • Safety Programs • CQ-2 • Roster • Any other Info Pertaining to Safety • CQ-3 • CQ-4 • CQ-5 (after completion of work)

20. Task List • Must complete all the listed items • Do not return, the list is for your use • Return forms to PSMCoordinator@wegmans.com

21. CQ-1 Form (Page 1) • Review, complete, sign and return prior to starting work • Only need to hand in 1 • Please write neatly • Include an up to date officer with contact information • Include all of the 4 pages or it will not be complete • If it does not pertain to you, write N/A

22. CQ-1.2 Form (Page 2) • Add Previous Work at Wegmans Market St. • If none, write none • Do not leave it blank

23. CQ-1.3 Form (Page 3) • If there is a serious accident/incident, please explain in a separate letter

24. CQ-1.4 Form (Page 4) • If you write YES, for the safety programs, you must include them with your paperwork • If the safety programs are not electronic, you can mail them or deliver them to 100 Market St.

25. CQ-1.5 Form (Page 5) • Contractor must sign certifying the forms are complete and accurate • Wegmans contractors will approve you to work at Market St. Facilites for the year. • Paperwork is not complete until you sign off

26. CQ-2 Form • Do not return letter to us, this is for your use

27. Roster (CQ-2 Form) • Please return a roster with all the employees who are entering Market St. and have signed a CQ-3 • Must include: • Description of training • Date of the training • Verification training is understood (i.e. written test, oral test, demonstration) • Keep roster current: • New/updated training • New employee

28. Additional Training Any contractors who work directly on the ammonia system must be trained in Wegmans SOPs. • Include on your training roster • Please indicate on your CQ-1 if you work directly on the system

29. Other Needs (CQ-2) • Review ‘Wegmans Facilities Group Rules for Contractors’ with your employees • Review & Modify your Job Site Emergency Action Plan • Review Wegmans Construction Specific Programs (ie Permits) with your employees • Advise Wegmans of any hazards • Advise Wegmans of any intentions to use Sub-Contractors

30. CQ-3 Form • A copy of the ‘Wegmans Facilities Group Rules For Contractors’ MUST be provided to each employee signing a CQ-3 • Must be submitted to Wegmans for each contract employee or sub-contractor, prior to commencement of work • Any new employee entering Market St. must sign a CQ-3 and update roster • Contractor must send one annually for each employee.

31. CQ-4 Form • Evaluation completed by designated Wegmans representative • Completed during or after completion of each project • May be sent to contractor depending on the circumstances

32. CQ-5 Form • Questionnaire will be sent upon completion of job • Review, complete and return

33. If you do not complete all of the documents above within two weeks, you will not be able to enter the complex until they are complete and received by Wegmans.

34. If you would like to review the Wegmans Process Safety Management Plan or Risk Management Program, please contact Alyssa Giarrosso

35. FAQ’s • What is Ammonia? • Ammonia (NH3) also known as Anhydrous Ammonia is a 100% natural chemical, an environmentally friendly refrigerant. • Where do we use it? • We use Ammonia at our Wegmans Market St. complex. 300 Market Street has 15,000 lbs. of Anhydrous Ammonia, 360 Market Street has 14,000 lbs. of Anhydrous Ammonia and 500 Market Street has 23,000 lbs. of Anhydrous Ammonia. • How many Elements are in the PSM program • 14 Elements. • What does PSM stand for? • Process Safety Management • If you have questions, how do you get answers? • If you would like to review the Wegmans Process Safety Management Plan or Risk Management Program, please contact your Wegmans representative who will put you in contact with a member of the PSM Core Team. • How does Wegmans keep its contractors safe while working in our refrigerated ware houses? • Majority of the piping is built on the roofs; it almost nullifies the risk of exposure. If an incident does occur, alarms will sound and an evacuation will occur. Since we first installed the systems, there has not been a reportable incident at the complex. • What does a PHA team do? • The Process Hazard Analysis employee team completes their analysis by asking over 300 “What If” questions to explore whether or not enough safeguard exist to protect our employees, our products and our community. They then present their recommendations and findings for corrective actions, this creates an even safer environment. • Is Ammonia a safe product? • Yes, ammonia is a safe and environmentally friendly chemical. Ammonia also has a very distinguishable odor, which will allow you to know when it is present at very low levels. • Why do we use the MOC processes? • MOCs assure that proper engineering work is preformed and that an appropriate hazard analysis is re-done as needed.

36. Contractor Safety Orientation • Wegmans has implemented a contractor safety orientation for all contractors that is to be completed each year. • This website contains the signoff sheet, orientation video and FAQs • https://www.dropbox.com/sh/8eenxf8lou7p5wd/AACfunJSitZHpQ3YhVQ-R-zxa?dl=0

37. Contractor Safety Orientation • Once each employee has been trained, they will sign off on the signoff sheet and the signoff sheet should be sent to ContractorEHS@wegmans.com

38. Contractor Safety Orientation • Once the training is completed, each employee will receive a card that they will need to carry on them while working at Wegmans. • If you need more cards, please send an email to ContractorEHS@wegmans.com stating how many cards you need as well as where to send them.

39. Open Discussion • Questions?