Houston Ops EH&S Stand Down

Houston Ops EH&SStand Down Aug/Sept 2015 DOW RESTRICTED - For internal use only

Introduction • Recent chemical burn at HT and trend for recordable injuries and near misses at Houston Operations require stand down and dialogue • Based on GIRD data, the most common p-LIFE near miss and injuries at Houston Operations have been chemical exposures. • These events have typically involved line of fire issues and lack of proper protective equipment. Many of these events were line and equipment openings. DOW RESTRICTED - For internal use only

3 Key Messages • Three key messages as part of this stand down: • Personal Protective Equipment (PPE) use MUST always be used as defined by permit, procedure, PPE grid for the required task. • One-Plus is require for ALL ISOLATING DEVICES including Red Tag Master, Individual Red Tag, and Energy Control Operating Procedure (ECOP) • If an exposure/burn occurs, the severity is significantly reduced by proper use of the safety shower/eye bath including staying in the shower until ESS arrives on scene. DOW RESTRICTED - For internal use only

Personal Protective Equipment • Since 2014 Houston Operations has experienced 3 Dow Operator injuries due to burns/chemical exposure • Each instance involved PPE not being worn or not being worn properly for the task per the procedure • Each instance would likely have been prevented had the defined PPE been worn correctly during the task • All involved a procedural LEO task • PPE IS A LAYER OF PROTECTION! Don’t make a choice that will compromise it. DOW RESTRICTED - For internal use only

Personal Protective Equipment • ALWAYS wear PPE as proscribed by procedure, permit or PPE grid • For the duration of the activity, unless otherwise specified • ALWAYS intervene when you see someone not wearing proper PPE for task • Hold each other and ourselves accountable • NEVER relax PPE without proper approval • Engage leadership, H&S before relaxing PPE for a task DOW RESTRICTED - For internal use only

One-Plus • One-Plus of an isolating device is REQUIRED by the Isolation of Energy Standard • This applies to all aspects of IOES • Red Tag Master • Individual Red Tag • Energy Control Operating Procedure (ECOP) • Exclusive Control • Following slides are guidance by Personal Safety Expertise to help define and clarify One Plus DOW RESTRICTED - For internal use only

IOES Guidance Document One-Plus practices Red Tag placement Tie-wrap management DOW RESTRICTED

One-Plus Guidance • Definition from IOES: • One-Plus is the method, practice, or design used to physically prevent inadvertent operation of an isolating device. "One plus" means that two separate, unrelated actions must occur to defeat the isolating device. The "One" refers to the isolating device itself and the "Plus" refers to the steps taken to prevent inadvertent operation of the isolating device. • Isolation when One-plus is required: • Master Red Tag System • Individual Red Tag System • Energy Control Operating Procedure (ECOP); including exclusive control • How One-Plus is achieved: • Manufacture’s design • Additional safeguard DOW RESTRICTED

One-Plus Guidance • Roles that apply One-plus: • Facility Representative (Master Red Tag System, Individual Red Tag System) • Authorized Procedure User (ECOP) • Roles that verify One-plus is effective: • Facility Representative (Master Red Tag System, Individual Red Tag System) • Job Representative (Master Red Tag System, Individual Red Tag System) • Worker (Individual Red Tag System) • Authorized Procedure User (ECOP) DOW RESTRICTED

One-Plus Guidance • Why one-plus is critical: • The primary means of isolation is the use of a tag-out system. WE must protect people from the unexpected release of hazardous energy. • Things are going to occur that are unexpected and unplanned. • To prevent inadvertent operation of an isolation device. • We can not engineer the human factor out of our plants. A dropped tool, an inattentive worker are going to happen. • One-plus must be effective. It is a layer of protection. Even manufacture’s designs can wear, slip or fail. DOW RESTRICTED

Manual Valve Evaluation Confirm the valve is in the desired position? Does the valve have a straight handle ? Secure the valve by: - Removing the handle, or - Securing the handle (cable tie, rope, chain etc), or - Covering the valve handle If these are not feasible, find another way of ensuring the valve cannot be inadvertently operated. Start Yes No Do you need to use excessive forcea or tools to operate it? Yes “One Plus is inherent in the design or design & location of the valve. No Is it located where it would be nearly impossible for someone to access itb? No Yes DOW RESTRICTED

Foot notes for Manual Valve Flowchart (previous slide) aExcessive force is generally defined as having to use two hands and to pull with maximum effort on the valve handle in order to get it to move. In this situation it should be virtually impossible for the valve handle to be inadvertently operated due to the difficulty in getting the valve handle to move. bThe valve is in a location where it is not accessible by ordinary means. For example the valve is in a pipe rack and in order to access it a JLG or scissor lift is needed. In addition, there must not be any work in the vicinity of the isolating valve. If the Facility Representative is using a ladder, they must assure that the ladder can not reposition the valve. DOW RESTRICTED

Summary • All isolation devices are required to be protected from inadvertent operation (one-plus). One-plus is a layer of protection. • There are many ways to achieve one-plus, either thru the manufacture’s design or something that the Facility Representative or Authorized Procedure User does. • Sometimes one-plus is going to protect many people (Master Red Tag System, Individual Red Tag System) and sometimes it is protecting a single worker from themselves (exclusive control). • How do you know if one-plus is effective? • What happens if a scaffold board strikes a valve handle, a slip blind or other isolation device? Would it turn, fall or change position enough to release hazardous energy? • Conduct physical tests to assure effectiveness. DOW RESTRICTED

BACK UP SLIDES • The following slides show acceptable and unacceptable methods to achieve one-plus, attach red tags, and manage tie-wraps. DOW RESTRICTED

Switchgear A good example of One- Plus. The One- Plus is the lock DOW RESTRICTED

Switchgear A good example of One-Plus. The One-Plus is the nylon cable tie thru the hole DOW RESTRICTED

Round Handle Valve A good example of One Plus. The One Plus is the nylon cable tie which is restricting movement of the valve handle. DOW RESTRICTED

Round Handle Valve A good example of One-Plus. The One-Plus is the nylon cable tie which is restricting movement of the valve handle. DOW RESTRICTED

Round Handle Valves A good example of One-Plus. The One-Plus are the plastic covers, sometimes referred to as “clam shells” or “doughnuts”. DOW RESTRICTED

Round Handle Valves Another good example of One Plus showing 4 covers and 4 Red Tags on 4 different valves. DOW RESTRICTED

Straight Handle Valve This may be a poor method to attach the red tag. Can the red tag slide off? Car seal is preventing movement of the valve handle A good example of One-Plus. The One-Plus is the metal car seal. DOW RESTRICTED

Straight Handle Valve A good example of One Plus. The picture is showing a close up view of the metal car seal securing the valve handle. DOW RESTRICTED

Straight Handle Valve The valve handle is secured into position by the nylon cable tie. It is hard to determine if this prevents the handle form rotating. DOW RESTRICTED

Large Gate Valve A good example of One-Plus that is inherent to the design. This valve is very difficult to operate. This valve cannot be operated unless someone uses a valve wrench, two hands and a step ladder. DOW RESTRICTED

Valve is difficult to access This example of One-Plus is achieved 2 ways - large multi-turn valve (inherent to the design) and remote location. This valve is located more than 20’ up in the air making it very difficult to access and there will be no work done in the vicinity of the valve. DOW RESTRICTED

Valve is difficult to access Missing red tag - The Red Tag must be hung even when the isolation device is difficult to access. Good example of One-Plus. This valve is located more than 20’ up in the air making it very difficult to access and there will be no work done in the vicinity of the valve. DOW RESTRICTED

Chain Operated Valve A good example of One-Plus. The two chains are locked together. DOW RESTRICTED

One Plus by Design Bolt is securing the valve into position A good example of One-Plus by design. The valve is secured into position by the nut and bolt. DOW RESTRICTED

One-plus by Design - Round Handle Valve A good example of One-Plus designed into the valve. In order to operate the valve, the metal plate must be disengaged from the metal tab. metal tab fits in slot – make sure tab and slot are not worn DOW RESTRICTED

One-plus by Design Two more examples of one-plus provided by the manufacturer Tab on handle must be slid upwards prior to turning Handle must be squeezed prior to turning DOW RESTRICTED

Valve Handle Removed A good example of One-Plus. The valve handle has been removed and secured to the valve (so it isn’t lost). Note: some valves may leak thru the stem when the handle is removed. The Fac Rep must understand the equipment. DOW RESTRICTED

Proper one-plus (valve handle removed) DOW RESTRICTED

Valve Handle Removed A good example of One-Plus. The valve handle has been removed. DOW RESTRICTED

Good example of One-Plus: Two Cable Ties used to loop through and one-plus DOW RESTRICTED

Although the cable tie was not long enough, the Facility Rep found a way to properly one-plus this valve without removing the handle DOW RESTRICTED

Poor Example of One Plus Nut is not secured to the bolt A Poor example of One-Plus. This is a poor example because the nut is not secured onto the bolt and could easily fall off. DOW RESTRICTED

Several examples of cable tie only attached to valve handle (no one-plus) Missing Tag? DOW RESTRICTED

Missing Red Tag? In a RCI, PSM inspection, or job walk, this could be confusion. Keep your house clean, remove all cable ties! DOW RESTRICTED

Poor Example of One-Plus A Poor example of One-Plus. There is no One-Plus. The handle has not been removed or secured. This handle could easily be kicked, bumped especially since its at ground level. DOW RESTRICTED

Poor Practice A Poor practice. When removing the Red Tags, the cable ties were left in place. The cable ties should be removed and discarded after each use. DOW RESTRICTED

Poor Practices Poor practice. Do NOT do this. The cable tie is not protecting the switch from inadvertent operation. Switches are not isolation devices. Hopefully in these examples, the switchgear is isolated and tagged out. DOW RESTRICTED

Wrong Tool for the Job! Do NOT use a knife to cut the cable tie. This is the wrong tool for the job. DOW RESTRICTED

Proper Cable Tie Cutting Technique A good example of proper tool use for cutting the cable tie. DOW RESTRICTED

Red Tag used on an air mover. This is an incorrect use of the Red Tag. Red Tags are used to isolate energy, not keep equipment in place. DOW RESTRICTED

Poor Example of Tag Attachment Is a Red tag missing? A Poor practice. The Red Tag MUST be securely attached to the isolating device. In this example, the tag could easily be removed or blown off by wind. DOW RESTRICTED

Houston Ops EH&S Stand Down