Changes to the Hot Work Standard: Updates to the Global Standard

1. Personal Safety- Simplified and Harmonized StandardsMOC for ODMS 06.05.C.09Global Hot Work Standard- Freeport Changes to the Hot Work Standard: Updates to the Global Standard Freeport additions removed from the standard Freeport requirements for application of the standard

2. Background • Dow Personal Safety Standards have been reviewed and the requirements simplified. • hROH Personal Standards have also been reviewed and the requirements between the hDow and hROH Standards have been harmonized into one Standard. • For hDow locations there are no new requirements, however, some requirements were clarified based on the information in the hROH standard. • The current Hot Tap process has not changed and the link will remain in the Hot Work Standard.  

3. Summary of Changes to the Global Hot Work Standard • The Hot Work standard has been re-ordered due to the removal of statements and clarification of several sections within the standard. Also, action oriented statements have been added to the Roles and Responsibilities. • Within this power point, wording changes and clarifications from the previous Global standard are shown in BLUE COLOR. • Freeport changes/deletions are in RED COLOR. • Freeport additions remaining in the standard are in GREEN COLOR

4. Summary of Changes to the Global Standard Hot Tapping • In the Hot Work Standard, three methods for isolation of equipment containing flammable are described. • For Hot Tap activities, this requirement is not met. To allow the use of Hot Tap process, a new statement was included in Hot Work Standard: • 4.1  In the case of Hot Taps, all Hot Tap (including Drill and Tap) activities are required to follow Dow’s GMISS (2.2.18) and MOC requirements to ensure that changes to equipment/piping are properly evaluated and approved.  Following Dow’s Global Hot Tap Work Process, including meeting the EMETL requirements and the utilization of the attached checklists (including approvals) satisfy these requirements for the equipment modification and allow the hot work without the above three methods of isolation.

5. Summary of Changes to the Global Standard Exemption Section: Added examples & clarification. • The requirements of this standard do not apply to: • Exempt Areas, like offices and other classified general purpose areas (not hazardous) when there are no open flames or sparks. However, work in these areas involving an open flame or sparks is covered by the standard. (see How to define Hot Work Areas) . • Refueling of motor vehicles at a refueling station. • Motor vehicles and rail cars traveling in General or Flammable Areas AND that are in compliance with the facility's vehicle entry procedure.  Process hazard analysis methods shall be used to define and document the safeguards to be included in this procedure. • Approved welding areas, engineering workshops and maintenance shops.

6. Summary of Changes to the Global Standard General requirements: Added some examples to 1.1 and relocated item 1.4 (with no wording changes). 1.1. Hot Work activities (cutting, welding, other) shall not be done in a Restricted Area.  For temporary changes, see 2.5. 1.2. Hot Work shall not be done in Flammable or General Areas if there are other practical means to do the job or the equipment can be moved to a Shop or Exempt Area. 1.3. In the event of an injury, fire, gas release or other emergency, all Hot Work in the area, or that could be affected, shall be shut down. Hot Work shall be suspended until the emergency is cleared. If the work stoppage was due to a spill of a flammable or combustible material, then atmospheric monitoring is required before work can resume. 1.4. New Construction areas with unit(s) free of flammables and not operating are, for Hot Work, regarded as General Areas until the situation that defines the Hot Work Areas is introduced.  This is when flammables are introduced.

7. Summary of Changes to the Global Standard Facility/Work Group leadership Responsibilities were re-worded to action oriented statements. A clarification was added for work in laboratories: • 5. Laboratories meeting the criteria stated below may follow the requirements provided in Global Hot Work Process for Managing Fire Risk in Laboratories. Criteria include: • Ventilated labs (single pass supply and exhaust air system) and; • Labs are in full compliance with Loss Prevention Principles (LPP) 12.5 and; • Routine work will not result in the release of flammable chemicals that will cause air concentration above 10% LFL (Lower Flammability Limit) within that laboratory or inside the fume hood. • Laboratories not meeting the criteria above must comply with the requirements of this standard.

8. Summary of Changes to the Global Standard Responsibilities for persons preparing the effected area or equipment for Hot Work were re-worded as action oriented statements. An example was included for activities that are prohibitive: • Item 6. Prohibit activities that could generate a flammable atmosphere that could reach the high energy ignition source, (for instance, drum, pail and other potentially “open” transfers of flammable liquids into or out of an area where hot work is in progress), until the Hot Work is complete.

9. Summary of Changes to the Global Standard Personnel Performing Hot Work: Requirements Table was removed from the text of standard, and included as an attachment. In order to make it more clear for the user, the definitions for hazardous areas from the LPP 3.1 were included in an extra column. Zone 1 Areas were relocated to restricted area, as previously described. Functional testing of gas meters was included, to ensure that the gas detector is working properly. • Make sure the Atmospheric Monitoring was conducted. This means the area around the Effected Area was tested initially and during the Hot Work using appropriate gas detection monitoring apparatus to assure that the area is free of concentrations of flammable gases, vapors, combustible gases or combustible liquids. Also, make sure a functional (bump) test or calibration of combustible gas meters was made before each day’s use, using an appropriate test gas, and that in case of a functional test failure, a full calibration procedure was followed before further use.

10. Summary of Changes to the Global Standard Responsibilities for Person doing atmospheric monitoring, Fire Watches, Hot Work Operating Procedure Writters were re-written to direct speech. • A reference and link to atmospheric monitoring guidelines were included in the standard.

11. Former Freeport Additions Removed: 2. Hot Work Requirement - Facility/Work Group Leadership The requirement to maintain a list of authorized Hot Work Permit roles and the need to review the list annually was previously removed from the Global Standard and has now been removed as Freeport requirements. Please note that facility/work group leaders are still responisble for proper authorization of roles related to the Hot Work Standard. Authorization by leaders is still required to issue SWP and to provide secondary approval for Hot Work. How to document this (list, electronic file, etc.) is flexible and at the discretion of facility.

12. Freeport Requirement Updates: In Freeport, the requirement to use the Hot Work Checklist for high energy hot work in flammable areas remains. • The Hot Work Checklist provides guidance. • The Global Hot Work Checklist shall be completed for all high energy hot work in Flammable Areas. This is documented on the Hot Work Permit section of the Safe Work Permit and also on the ‘Freeport Requirements for Application of Global Safety Standards’ document which will be linked on the Freeport EH&S Standards Website • For Hot Work permitting the Global Work Permit (SWP) Standard is used. The Global Hot Work Permit SWP Template is provided as a template that meets the Hot Work documentation requirements. Sites may, and are strongly encouraged, though not required, to use this template. • The Freeport version of the Hot Work Permit has been updated and is required. • A Freeport Internal Combustion Entry (ICE) Checklist is still available (not required) and will be linked on the Freeport EH&S Standards Website

13. Freeport Version of the Hot Work Permit Template • The Hot Work Permit (‘Pink Section’) has been updated to include: • Reorganization for better usability • Line item to make sure bump test is performed • Checkbox to use if high energy hot work is being performed in a flammable area- if the box is checked, the hot work checklist is required and the rest of the ‘Pink Section’ does not need to be completed- this eliminates former redundancy and confusion. • Line item to make sure heat exposure to gaskets, seals, and liners is considered (also on global template) • The Hot Work Permit will be added back as a section on the Safe Work Permit

14. Updated Freeport Hot Work Permit Checkbox added for High Energy Hot Work in Flammable Area Heat Exposure reminder added Bump test reminder added

15. Resources • Hot Work Standard • http://ehs.intranet.dow.com/library/standards/0605_HotWork/ • Hot Work Top 10 Checklist • \\txnt56\ehs_texas\Working\Management of Change\Global Hot Work Standard - 2012\03 English Hot Work Top Ten List.pdf • Hot Work Checklist • \\txnt56\ehs_texas\Working\Management of Change\Global Hot Work Standard - 2012\0605_HW_Checklist.docx • Freeport ICE Checklist • \\txnt56\ehs_texas\Approved\RspCareEmployee Health & Safety\Global Standard Implementation\Hot Work • Freeport Requirements for Application of Global Safety Standards • \\txnt56\ehs_texas\Working\Management of Change\Global Safe Work Permitting - 2012\Freeport Requirements for Application of Global Safety Standards.docx • Audit/Self Assessment Checklist • http://ehs.intranet.dow.com/virtual/documents/ODMS_Checklists/0605_Hot_Work_Audit_Checklist.doc • R&D Audit/Self Assessment Checklist • http://ehs.intranet.dow.com/virtual/documents/ODMS_Checklists/0605_R&D_Hot_Work_Audit_Checklist.doc