What is a Confined Space ?

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2. What is a Confined Space ? • Any space with limited or restricted openings for entry and exit and is not designed for continuous occupancy (see definition of continuous occupancy in the note below), or • Any space with a potential danger of solid, liquid, or vapor engulfment, or • Any space where the combination of poor ventilation and difficulty of access/escape poses a risk of a person being affected by one or more of the following: • A fire or explosion • Oxygen deficiency or enrichment • Heat or cold • Flowing solids and liquids • Gases, vapors, mists or dusts Note: A space that is Designed for Continuous Occupancy is a space that: • Has ventilation designed to provide a normal atmosphere, and • Will allow a person to work and move around while standing erect, and • Will allow a person to enter and work for a prolonged period without additional consideration for their health and safety. DOW RESTRICTED - For internal use only

3. Confined spaces may include, but are not limited to: • Vessels, tanks, towers, vessels skirts, tank cars, bag houses, pipes, and ventilation and exhaust ducts, silos and vats. • Equipment under construction or fabrication or in demolition with limited openings for entry or with the potential danger of engulfment. • Newly created confined spaces during maintenance and servicing activities (for example: flame enclosures for hot work activities). • Boilers, furnaces, and analyzer housings/sheds. • Dikes, pits, trenches and excavations with restricted access that are more than 4 feet deep or less than 4 feet deep but with the potential danger of solid, liquid, or vapor engulfment. • Trenches, dikes and cooling tower basins that could contain, hold or produce dangerous air contaminants or oxygen deficient atmosphere. DOW RESTRICTED - For internal use only

4. Some CSE’s are easy to recognize DOW RESTRICTED - For internal use only

5. Some CSE’s are not easy to recognize DOW RESTRICTED - For internal use only

6. Feedback Exercises (True or False) Which of the following are considered a Confined Space. A. Space with limited or restricted openings for entry and exit that is not designed for continuous occupancy. Space with potential danger of solid, liquid or vapor engulfment. C. Space where the combination of poor ventilation and difficulty of access and escape poses a risk of a person being affected by heat or cold. D. Space where adequate shoring of the sides of the space is not possible. T T T T DOW RESTRICTED - For internal use only

7. Confined Space Incident Description:At approximately 12:15 pm, workers on the fifth level of the structure, approximately 60 feet above the ground, were performing a black light inspection at an open end of a 48-inch-wide horizontal pipe, which had been opened for the purpose of maintenance. The two open pipe ends were wrapped with clear plastic sheeting in order to keep the pipe free of debris until the oxygen feed mixer was reinstalled. Nitrogen was being injected into the process equipment to protect new catalyst in reactors from exposure to moisture. The nitrogen was also flowing through some of the piping systems connected to the reactors. The nitrogen was venting from one side of the open pipe where formerly it had been connected to an oxygen feed mixer. No warning sign was posted on the pipe opening identifying it as a confined space or warning that the pipe contained potentially hazardous nitrogen. The two workers had secured a sheet of black plastic over the end of the pipe where they were working to provide shade to make it easier to conduct the black light test during daylight. What went wrong with this scenario ????? DOW RESTRICTED - For internal use only

8. Feedback Exercise • What were the key learning’s from this incident ? • Communication • Understand the hazards of any gases that may being used • Creating a Confined Space without realizing it • Be aware of your surroundings and other work • Ensure Operations knows what you are planning on doing • ???? DOW RESTRICTED - For internal use only

9. CSE Recognition Identify if the following would be considered a confined space. Cooling Tower Basin Analyzer Buildings Rainwater Trenches with restricted access deeper than 4 ft Distillation Tower Vessel Skirt Tank Cars Welding enclosures (Tarps) for Hot Work Activities Fin Fan Exchanger Under Shroud DOW RESTRICTED - For internal use only

10. Summary Confined Spaces may not be obvious – name an example ? Obvious Hazardous conditions (IDLH – immediately dangerous to life and health ) may exists within a confined space, unless knowledge of the previous state of a confined space is understood – name something that might make a CSE an IDLH condition ? Recognition of work in confined spaces must trigger the use of the Global Standard Requirements and Plant Procedures – what if you don’t have a CSE procedure, what must you do ? DOW RESTRICTED - For internal use only

11. Personnel Preparing a Confined Space for Entry • If you are preparing a confined space entry, you must: • Isolate the confined space from materials and energy sources; • Clean and decontaminate the confined space of hazardous • materials; • Ventilate the confined space; • Note - If it is not feasible to provide additional ventilation/exhaust consult • your EH&S Delivery representative or Site Industrial Hygiene Focal • Point. • Perform Hazard Monitoring; • Prior to entry, the CSE Permit Issuer shall ensure that hazard monitoring has been conducted and documented.  The Safety Attendant will conduct additional monitoring as required by the CSE Operating Procedure and ensure that it is documented on the CSE Permit. DOW RESTRICTED - For internal use only

12. CSE Permit Issuer • If you are issuing a CSE Permit, you must: • Have the required training, knowledge and skills, • Be authorized to issue CSE Permits, • Review the CSE Operating Procedure and Emergency and Rescue Plans • with the Safety Attendant(s) and the personnel entering the confined • space, • Ensure hazard monitoring has been completed: • Oxygen content, • Flammable vapors (%LEL), • Chemical contaminants • Radiation, when a radiation source is present • Temperature, when the temperature inside the confined space has the potential to approach an effective atmospheric temperature of above 122F/50C, or below -20F/-29C in still air. DOW RESTRICTED - For internal use only

13. CSE Permit Issuer • If you are issuing a CSE Permit, you must: • Shut down all CSEs (cancel permits), and initiate emergency plans (if • necessary) when: • There is a fire, gas release or any other emergency in the area • and the Safe Work Permit (SWP) is cancelled, or • The working conditions and precautions at the beginning of the • job cannot be maintained, or • The permit has exceeded 16 hours, or • There is a change in job scope, craft type or hazards. • Suspend CSE permits if: • The rescue team becomes unavailable for any reason, or • The work is suspended and the confined space is left • unattended, or • The SWP is suspended. • Note - The initial CSE Permit for a non-routine entry which extends beyond one work shift must be approved by personnel authorized to approve CSE Permits. If the job scope, craft type and hazards remain the same, then on the second and subsequent shifts, the Permit Issuer can approve the CSE Permit. DOW RESTRICTED - For internal use only

14. CSE Permit Approver • To approve a CSE Permit, you must: • Be authorized to Approve CSE Permits, • Not approve a Non-Routine CSE permit that you issued • (Non-routine CSE requires second approver), • Conduct an on-site inspection prior to entry with Safety Attendant(s), Crew, • Job representative or Crew representative to verify that requirements of • the Safe Work Permit (SWP), CSE Operating Procedure, and CSE Permit • have been addressed. • Note - The initial CSE Permit for a non-routine entry which extends beyond one work shift must be approved by personnel authorized to approve CSE Permits. If the job scope, craft type and hazards remain the same, then on the second and subsequent shifts, the Permit Issuer can approve the CSE Permit. DOW RESTRICTED - For internal use only

15. Personnel Accepting a Safe Work Permit for CSE • If you are accepting a Safe Work Permit (SWP) and a CSE Permit for a Confined Space Entry, you must: • Obtain the CSE Operating Procedure, Rescue Plan, CSE Permit, and • SWP • Review with the CSE Permit Issuer the hazards and precautions identified • in the CSE Operating Procedure and permits, • Ensure that any equipment brought into the confined space meets the • CSE Equipment Specifications, • Not bring compressed gas cylinders (other than breathing air cylinders) • into the confined space, • Test hoses that are connected to non-air gas cylinders prior to use, • Remove hoses that are connected to pressurized non-air gas cylinders • immediately after use, • Communicate to the Permit Issuer if there is any change in the job scope • or the potential hazards present in the area. DOW RESTRICTED - For internal use only

16. Safety Attendant • If you are the Safety Attendant for CSE, you must: • Have the required training, knowledge, and skills (for Contract EE’s this is • obtained through Contractor Safety Council and will be document on their • training badge) • Obtain the CSE Procedure for this entry, • Conduct hazard monitoring at all entry and exit points and at representative • locations where the work will be done prior to entry, • Conduct hazard monitoring  at regular intervals if continuous monitoring is • not being done, • Monitor for other contaminants • Contaminants generated by work being performed during the confined space entry, (e.g. welding, paint/solvent vapors, volatiles from sludge/heel clean-out, curing agents.) DOW RESTRICTED - For internal use only

17. Safety Attendant • If you are the Safety Attendant for CSE, you must: • Conduct continuous monitoring of oxygen content within the CS • Continuously monitor % LEL if the previous contents were flammable or if • the work being done may introduce a flammable atmosphere, • Log monitoring results on the confined space permit Appendix A (include • date, time and name of person performing monitoring) if periodic monitoring • is being done • Be able to communicate with the rescue team (either directly or via the • control room), • Maintain a line of sight or other continuous two-way communication with the • Entrants, be able to recognize an emergency and monitor conditions • outside of the space (e.g. gas bottles, air bottles, or other hazards that • may impact the job), • Log (Appendix A) who goes in or out of the confined space and check that • personnel entering the confined space are wearing the required PPE.  DOW RESTRICTED - For internal use only

18. Safety Attendant • If you are the Safety Attendant for CSE, you must: • Ensure the entry/exit to the confined space is kept clear, document employee’s • entering/exiting the CSE on the CSE Permit. • Monitor the O2/LEL meter for compliance of the CSE air space while EE’s are • inside the CSE • Shut down the job, order the Entrants out of the confined space and initiate • emergency plans (if necessary) • Stay outside the confined space unless you have a role in the Rescue Plan • and a backup attendant is present. • A job may require more than one Safety Attendant: •   Additional Safety Attendants may be required when it is not possible to • continually monitor conditions inside and outside the confined space (e.g. • bottle watch, or entries on two levels) or if you need a rest break. In these • situations, get another Attendant to assist. • If the Safety Attendant is not the person who conducts hazard monitoring, • then the role of the Safety Attendant is to ensure the results are logged on • the CSE Permit. DOW RESTRICTED - For internal use only

19. Which of the following are responsibilities for a Safety Attendant for Confined Space entry? To approve the Confined Space entry To secure needed equipment for the confined space entry team To continually observe the integrity and the proper use of personal protective equipment To enter the Confined Space in an emergency as outlined in the emergency and rescue procedure prior to the arrival of additional rescue help. F F T F DOW RESTRICTED - For internal use only

20. What about Lunch Break ? Question : If workers leave the CSE for lunch, what do they need to do upon returning? Answer : If the confined space is left unattended during the break, then monitoring at the same location for initial CSE must be done, initial your monitoring results as verification the monitoring was completed, before entry is allowed. If an attendant is left in place (within 35’ and has direct sight of the CSE entrance) during break or lunch, there is no need to re-monitor the air and when workers return, the attendant documents their entrance and they return to work. As a good practice - when a confined space is left unattended, place a sign on the entry point that states “ CSE - Do Not Enter Without Permit". DOW RESTRICTED - For internal use only

21. What’s New ??? There is no longer a Global Standard with Freeport additions, TxOp will follow the Global CSE Standard. Appendix A - • The CSE Permit has been updated with an Appendix, • CSE Permit - Appendix A must be retained for 75 years in the U.S. plus the length of employment, (Appendix A, page 3 of the CSE Permit) Appendix A is used to document the Hazardous monitoring results Atmospheric concentration of any substance which could result in employee exposure in excess of its dose or permissible exposure limit DOW RESTRICTED - For internal use only

22. Appendix A – Filled out DOW RESTRICTED - For internal use only

23. Appendix A – Filled out DOW RESTRICTED - For internal use only

24. What’s New ??? • Addition of a Hazard Review Guidance Document for an alternate method of isolation when disconnecting (air gap), blinds/pancakes/spectacles, or double block and bleed are • not practical. • What would be an example ? • Requirement to complete 5 air changes per hour (ACH) prior to entry (previously identified in the FAQ section); • Addition of a Ventilation Guidance Document and a • Blower Air Exchange Rate Calculation Document • Requirement to conduct hazard monitoring with ventilation air movers off for a minimum of 15 minutes, DOW RESTRICTED - For internal use only

25. What’s New ??? • Requirement to complete 5 air changes per hour (ACH) prior to entry (previously identified in the FAQ section); • Addition of a Ventilation Guidance Document and a • Blower Air Exchange Rate Calculation Document • Requirement to conduct hazard monitoring with ventilation air movers off for a minimum of 15 minutes, • Allowance of subsequent non-routine entry to be approved by the Permit Issuer only when the job scope, craft type, and hazards remain the same as the initial entry permit • Introduction of a document that identifies the “Top Ten” things to look for when observing a CSE in the field. DOW RESTRICTED - For internal use only

26. What’s New ??? • Allowance of subsequent non-routine entry to be approved by the Permit Issuer only when the job scope, craft type, and hazards remain the same as the initial entry permit. • This means, if you have a CSE with the same job scope, same crafts • and same identified hazards, then one person can write and approve • the CSE Permit with the approval of your Leadership if you are going • to do this. • Introduction of a document that identifies the “Top Ten” things to look for when observing a CSE in the field. DOW RESTRICTED - For internal use only

27. What’s New ??? • Removal of these requirements: • Facility/Work Group Leadership to; • Maintain lists of confined spaces in their area(s), • Maintain lists of authorized personnel (Approvers), • (Delegation of Authority is required in TxOp T-10 Standard, Page 8) • Annually review and approve Confined Space Entry Operating Procedures for each routine, repetitive confined space entry, • Removal of training requirement for CSE Permit Approver DOW RESTRICTED - For internal use only

28. Monitoring Air Quality The standard requires that hazard monitoring be performed at all entry and exit points and inside the confined space at points that represent the breathing air quality of the locations where the entrants will be doing the work. There may be some occasions where entry has to be made to perform the hazard monitoring inside the space at a location that represents the breathing air quality of the entrants doing the work (e. g., large storage tank). If You can't monitor the air that people will breath inside the confined space, then we do not allow entry. If you have a CSE entry and could not monitor the air of a representative spot where workers will be, what are other options to get the sample ? • Don an SCBA and enter the CSE to measure the air quality within the CSE • Add tubing to the end of the monitor and use a pole/stick to move the other • end of the tubing into the CSE where workers are expected to work • Attach a rope to the monitor and lower into the CSE from a higher elevation • to monitor the air quality • What are some methods that you may have used in the past ???? DOW RESTRICTED - For internal use only

29. Which of the following is TRUE of hazard monitoring of Confined Space entries: Be performed while ventilation air movers are operating. Be performed only in the center of the Confined Space. Be continuously performed. Be performed inside the Confined Space at points that represent the breathing air quality of the locations where the people will be doing their work. F F T T DOW RESTRICTED - For internal use only

30. CSE Procedure • The following requirements supplement but do not replace the requirements of ODMS 05.03.04. • The CSE procedure must be a written document that includes the following information: (CSE Procedure Template) • Scope of the job (i.e. clean and replace epoxy coating), • Preparation of the space for entry, including: • Isolation of energy sources (line & equipment opening if applicable), • Cleaning and clearing requirements, and • Ventilation requirements, including methods that will be used. • Specific hazard monitoring requirements with details on what, when, and where • to monitor, including what equipment will be used, • Required Personal Protective Equipment (PPE) for preparation of the space • and actual entry, consider: • The hazards present in the confined space, • The previous contents of the confined space, and • The hazards posed by the equipment or materials used in the job or task (e.g. welding, painting, grinding, use of ladders or scaffolding, etc.). • The procedure must include a thermal stress plan if the temperature has the • potential to approach the following ranges; above 122 F / 50 C, or below -20 F • / -29 C. DOW RESTRICTED - For internal use only

31. CSE Rescue Plan • The CSE emergency and rescue plan must be a written document, that includes the following information (the emergency and rescue plan may be included or linked to the CSE procedure): • Potential hazards of the space and the work to be performed in the space, • Recognition of an emergency (e.g. medical emergency, thermal stress, etc.), • Means and methods for reporting an emergency, summoning the rescue • team, and communicating between the Safety Attendant and rescue team, • PPE required for safe rescue operations, • Personnel and equipment required for rescue operations, and where this • equipment is located, • Conditions and obstacles present in and around the space that may make it • difficult to enter or exit, • Means to safely exit the confined space in case of an emergency, and • Preferred method of rescue (i.e. self-rescue, non-entry rescue, entry • rescue). DOW RESTRICTED - For internal use only

32. The Confined Space Entry Operating Procedure shall always include which of the following: Line or equipment opening information. Hydro blasting procedures for clearing the Confined Space. Emergency and Rescue procedures that have been reviewed by the Rescue Team member. A relief plan to address thermal stress T F T T DOW RESTRICTED - For internal use only

33. Routine, Repetitive CSE • Confined Space Entries that meet all of the following: • They are done frequently enough such that the knowledge, skill and • experience level of the people to enter the Confined Space, the Safety • Attendant and the Personnel Issuing the Safe Work Permit is current and • correct and does not need to be reviewed prior to the entry. Frequent • Confined Space Entries are those that are done with some regular • repetition, such as weekly, bi-weekly, quarterly, etc.. • Facility / Work Group Leadership is satisfied with the knowledge, skill and • experience level of each specific person in the roles listed above with that • specific Confined Space Entry. • The hazards and safeguards are known and will not change DOW RESTRICTED - For internal use only

34. Routine, Repetitive CSE Some examples of routine and repetitive Confined Space Entries may include, but are not limited to: • Daily wash outs / cleanings of Latex rail cars. • Weekly change out of a centrifuge cloth/screen. • Weekly wash outs / cleanings of salt barges. • Daily product container inspections. • Weekly secondary containment inspections. DOW RESTRICTED - For internal use only

35. Confined Space Model Practices These Practices are not spelled out in the standard, but are recognized as model practices: Don't take small objects into a confined space (pens, rulers, lighters, keys, etc…) that you don't need and are likely to drop. When needed, CSE entrants should carry a flashlight with them in case of a lighting failure. Inspect and test all portable electric and pneumatic tools before taking them into a confined space. Have all electrical equipment plugged into a GFCI that is outside the confined space and secure. Test your communication methods throughout the entry, and not just during the permitting. Avoid the use of fire extinguishers (CO2, dry chemical, etc) in a confined space that could lead to oxygen depletion and/or airborne contaminants. DOW RESTRICTED - For internal use only

36. Which of the following equipment may be used in a confined space? Pressurized gas cylinders other than breathing air Pneumatically powered equipment powered by inert gas supplies Electrically powered equipment that uses a 115/220 volt power source with a tested GFI that is located outside of the confined space Electrically powered equipment that uses a 120/240 volt transformer F F T T DOW RESTRICTED - For internal use only

37. Confined Space Entry Scenario There is a Level 1 Chlorine release in an adjacent block and the wind is blowing toward your block. You sound the evacuation horn to alert all employees. After the all clear is blown at originating block, you blow your All Clear. A crew then approaches you about restarting their confined space work in V-1055. The EE that approved and issued the original CSE permit is no longer in the plant, who can re-issue the CSE Permit ? DOW RESTRICTED - For internal use only

38. Confined space entry permit shall be cancelled and all work stopped until a new permit is issued if which of the following occur ? A lunch break is taken by the Confined Space entry team but the Confined Space remains attended. The Safe Work permit is suspended If the emergency and rescue procedures cannot be initiated due to an evacuation of the work area. The Confined Space entry extends beyond an 8 hr shift. F T T F DOW RESTRICTED - For internal use only

39. New stuff DOW RESTRICTED - For internal use only

40. This should be discussed with the Safety Attendant on their responsibilities DOW RESTRICTED - For internal use only

41. Match the Definitions A. 1.Confined Space 2. Attended or In Place 3. Routine & Repetitive CSE 4. CSE Entry Operating Procedure 5. Entry 6. IDLH 7. Unattended No one is within 35 feet/ 10 meters and visual contact with the entry point has been lost. The passing of one’s face beyond the plane of an opening of a Confined Space. In general, the passing of one's body part beyond the plane of an opening with the intent to gain admittance to the confined space or when a hazardous atmosphere is projected from the opening and the person is exposed to the opening should be considered and treated as entry. B. Confined Space Entries that meet ALL of the following: They are done frequently enough such that the knowledge, skill and experience level of the people to enter the Confined Space, the Safety Attendant and the Personnel Issuing the Safety Work Permit is current,correct and does not need to be reviewed prior to entry. Facility / Work Group Leadership is satisfied with the knowledge, skill and experience level of each specific person in the roles listed above with that specific Confined Space Entry. The hazards and safeguards are known and will not change. C. Any condition that poses an immediate or delayed threat to life or that would cause irreversible adverse health effects or that would interfere with an individual’s ability to escape unaided from the Confined Space. D. A written procedure that meets the requirements of ODMS 05.03.04 and any additional requirements of the CSE standard E. When no one is inside the confined space, then someone involved with the Confined Space Entry is within 35 feet/10 meters and in constant visual contact with the entry point. F. G. Any Space: With limited or restricted openings for entry and exit that is not designed for continuous occupancy, or With a potential danger of solid, liquid, or vapor engulfment, or, Where the combination of poor ventilation and difficulty of access and escape poses a risk of a person being affected by one or more of the following: A fire or explosion. Oxygen deficiency or enrichment. Heat or cold, Flowing solids and liquids, Gases, vapors, mists or dusts. DOW RESTRICTED - For internal use only

42. Place CSE Steps in order Complete initial entry hazard monitoring When ready, issue a Confined Space Entry Permit Prepare the confined space . Isolate energy. Collect atmosphere data that shows entry is allowable. Determine PPE requirements. Complete “Approver” tasks and discussions with all those planning to enter. Eliminate or safeguard from hazards. Verify the equipment meets standards Create CSE operating procedure Issue SWP(s) for all entrants to enter and do work Begin forced or induced ventilation if effective. Address any thermal stress concerns Get safety attendant in place and establish continuous radio contact. Recognize that CSE is needed. Verify rescue procedures in place and rescue team ready and informed Issue CSE Permit for people to enter. 8 3 5 2 10 4 7 1 6 9 DOW RESTRICTED - For internal use only

43. CSE Maintained • Unrestricted means of entering and exiting the CSE • Safety attendant always in place while someone is in the CSE • 3. Continuous 2 way communication between Safety Attendant and all entrants. • 4. Hazard monitoring performed continuously while someone is in the CSE and the attendance has an alert horn to warn entrants if needed • 5. Safety attendant is responsible for the Safety of all CSE entrants, alerting them to any external hazards • 6. Safety attendant maintains entrance log of everyone that enters and exits CSE DOW RESTRICTED - For internal use only

44. Training Exercise: Develop a CSE utilizing the picture and information provided. DOW RESTRICTED - For internal use only

45. Tank is 1M gallon, last contained vinyl acetate, there is only one man way to enter and exit. Tank has been drained and washed. • Job scope: Repair liner as needed which will include blasting with pecan hulls and recoating liner. Cathodic protection needs to be inspected as well as thickness checks on the tank floor. • Your job: Write a CSE Permit to include all other documents needed before entry can be made. • Some things to consider: • Procedure • Rescue Plan • Hazardous monitoring • Air movers • Air conditioners • Communication • Equipment placement • Radiant heat load • Dust control DOW RESTRICTED - For internal use only

46. Questions or concerns ? What did we not discuss that you have questions about ? DOW RESTRICTED - For internal use only