Document Number: HSE 116 Current Rev: 6/6/20 Revised By: …...Document Number: HSE 116 Revised By:...

Document Number: HSE 116 Revised By: B Crochet Manager Approval: MOC No. HSE 18 10

Revisions noted in italics

Current Rev: 6/6/20 Review Cycle: 3 years Revision No. 1

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Health, Safety and Environmental Manual Procedure 116 – Contractor Safety Management

Printed controlled copy expires 24 hours after 12:30 PM on 6/9/2020

1.0 PURPOSE

Westlake has developed this document to ensure the site achieves desired safety performance

by contractors, thus enhancing contractor employee protection. This document provides

guidelines to assure that contractors and their subcontractors are meeting or exceeding

Westlake Geismar expectations and requirements.

2.0 SCOPE

This document applies to all contractor companies performing work at Westlake Geismar,

through contractual agreement, by service contract, purchase order, etc.…, including, but not

limited to contractor personnel performing projects, maintenance, repair, turnaround,

renovation or specialty work.

3.0 DEFINITIONS

3.1 Audit: a formal process to assess the Contractor’s HSE Management System and the

degree of implementation at the work site including other compliance aspects for the

scope of the work being performed.

3.2 Contract Monitor: refers to the Westlake person responsible for supervising the work

of the Contractor. This may be an engineer, foreman, superintendent, supervisor, or

other position as assigned by the management of the Westlake facility including

personnel from a “nested” Contractor, or joint venture agreement, working in a

coordinator’s role for Westlake.

3.3 Contractor: In this document, this term refers to any provider of a service, such as a

contractor, sub-contractor, field representative, individual, etc. that will perform work on

a Westlake work site, or on behalf of Westlake.

3.3.1 Nested: a Contractor that is housed onsite and performs work on a routine basis.

This may include having permanent or temporary office or break facilities.

3.3.2 Non-nested: a Contractor that performs services onsite, but does not have

permanent or temporary office or break facilities.

3.4 Dashboard: refers to the ISNetworld overall company grade or “Dashboard” grade as

measured against the Westlake established requirements (all requirements are viewable

in the ISNetworld system).

3.5 HSE: health, safety, and environmental; may also refer to the Westlake HSE department

or personnel

3.6 EMR: Experience Modification Rate (A factor developed by measuring the difference

between the insured's actual past experience or losses and the expected or actual loss).

3.7 Grade: same as “Dashboard” definition above.




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3.8 Inspection: a formal survey to assess the work site and workers’ performance;

Inspections shall be documented.

3.9 ISNetworld: refers to ISNetworld Inc. (ISN), a web based, third party company,

Westlake utilizes to provide administrative services to determine the level of compliance

Contractors achieve based on requirements established by Westlake.

3.10 Observation: an informal survey to assess the work site and workers’ performance;

observations may or may not be documented.

3.11 Procurement: refers to personnel or department responsible for purchasing or procuring

goods, services, Contractors, etc.; issuing contracts and obtaining agreements for

Westlake.

3.12 Security: also referred to as Gate1 and Gate 5, the Fire House building is located at the

Gate 1where the contract security workforce manages the following, in part: Contractor

badging, security operations, and contractor visitor orientation facilitation.

4.0 CONTRACTOR TIERS

Requirements of Tiered Contractor Companies

*ALL ENTRY REQUIREMENTS APPLY. Refer to section 5.5 Security for entry

information.

4.1 Tier 1 – Visitors/Deliveries/Vendors – these companies/individuals do not

perform work either on or adjacent to process equipment.

4.1.1 These companies or individuals do not require subscription to

ISNetworld.

Examples of these companies or individuals are:

4.1.1.1 Visitor of a Westlake Geismar employee or contractor employee.

4.1.1.2 Normal or hot shot delivery

4.1.1.3 Training rep, Sales.

4.1.1.4 Entergy & gas suppliers.

NOTE: Visitor orientation required for entry.

4.2 Tier 2 – Non-Operational Contractors – these companies may perform work either

adjacent to process equipment or adjacent to the property battery limits, but for no

reason, perform hands-on work on process equipment.

4.2.1.1 These companies do require subscription to ISNetworld.




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4.2.1.2 Exemption to ISNetworld is allowed by written approval from HSE dept.

– Safety and insurance review still required.

4.2.1.3 Their work could require safe work permits from operations. However,

they would not perform any work on process equipment.

4.2.1.5 Examples of Tier 2 companies are:

4.2.1.5.1 Vehicle and Equipment Maintenance

4.2.1.5.2 Fence Contractors

4.2.1.5.3 Portable Sanitation Services

4.2.1.5.4 Equipment Rental Companies

4.2.1.5.5 Building Contractors

4.2.1.5.6 Engineering contractors, PSM consultants, Landscaping Companies

Lab calibration, service and repair service companies

4.2.1.5.7 Chemical service companies

NOTE: Valid Basic Orientation Plus/Refresher and Westlake Geismar site-

specific required for entry (1289GVC).

4.3 Tier 3 – Operational Contractors –These companies perform maintenance or

repair, turnaround, major renovation or specialty work either on or

adjacent to process equipment; this tier consists of nested and job-specific

contractors.

4.3.1.1 These companies require subscription to ISNetworld.

4.3.1.2 Examples of operational contractors, but not limited to:

4.3.1.2.1 Mechanical contractors

4.3.1.2.2 Electrical and Instrumentation Contractors

4.3.1.2.3 Scaffolding Contractors

4.3.1.2.4 DCS Contractors

4.3.1.2.5 Fire equipment maintenance/service providers

4.3.1.2.6 Turnaround services.

NOTE: Work permits are required for most of their work.

NOTE: Required to review and accept policies annually via ISNetworld.

NOTE: Valid Basic Orientation Plus/Refresher and Westlake Geismar site-specific

orientation (1289GVC), valid TWIC is required for entry

NOTE: Escorts are not allowed for contractors performing any work within the

fence line.

5.0 RESPONSIBILITIES

5.1 Procurement Department

5.1.1 Issue contracts for services to only those companies that have satisfied all

contractor qualification requirements for Westlake Geismar.

5.1.2 Ensure contractors have the required insurance requirements set by Westlake.

5.1.3 Retain copies of all required contract documents for PSM audit purposes. 5.1.4 Inform all contractors that a condition of performing work at the Geismar




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Complex is to adhere to the site safety requirements.

5.1.5 Prior to Westlake issuing a Purchase Order will verify through ISNetworld

Health, Safety and Insurance compliance is acceptable.

5.2 Westlake Representative / Work Coordinator

5.2.1 Ensure contractors and subcontractors has acceptable ISNetworld company

grade before requesting them to the site.

5.2.2 Conduct Pre-Job meeting with contractors identifying applicable HSE

Procedures and requirements.

5.2.3 Require contractor representative to attend the monthly contractor safety

meeting. .

5.2.4 Ensure that all contract employees performing work have necessary

training, qualifications and/or certifications to perform their task.

5.2.5 Monitor contractor's work areas for compliance to all applicable regulations

and Westlake HSE policies and procedures.

5.2.6 Participate in audits of Contractor work areas and ensure closure on audit

action items findings in a timely manner.

5.2.7 Obtain contact information for contractors’ home office, corporate HSE

contact, job superintendent and site HSE representative.

5.2.8 Review all contractor chemical inventories and SDS and send all new

chemicals through “New Chemical Approval” process.

5.2.9 Complete “Post Job Evaluation” for all jobs performed by a contractor to

include safety, production, and quality work.

5.2.10 Provide a copy of this procedure to all contractors that will be

performing work on this site and highlight where they may find all of

Westlake’s HSE Procedure ( Section 6.5.5)

5.3 Health, Safety & Environmental (HSE) Department

5.3.1 Monitor ISNetworld grades for all connected contractors; work with ISN and

the contractor to maintain an acceptable grade.

5.3.2 Evaluate contractor HSE requirements to ensure full compliance with

requirements of this policy during the qualification process. This will be

accomplished within ISNetworld.

5.3.3 Review contractors and subcontractors with Grade “C” ISNetworld and aid to

reconcile for entry or further action by contractor.

5.3.4 Review contractors and subcontractors with Grade “F” and recommend to

Plant Manager for denial or variance. Prepare and sign variance if

appropriate.

5.3.5 Review annually contractor's (Evergreen) safety performance and verify

implementation through field inspections and surveillance.

5.3.6 Make and maintain Westlake Geismar HSE Procedures available to

contractors through website http://www.westlake.com/geismar-hse

5.4 Security

5.4.1 Ensure contractor company has A or B ISNetworld company grade; Contact

HSE for further instructions. Contact HSE when contractor has “C” or “F” or does

not appear on daily ISNetworld Report. Contact HSE duty person after business

hours.

5.4.2 Ensure that contractors wear temporary badge and appropriate safety




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equipment (e.g. hard hat, safety glasses with side shields, and NIOSH approved

acid gas (chlorine) escape respirator) prior to entry into the facility.

5.4.3 Ensure that all contractors have proper credentials and safety orientations prior

to entering plant for work.(TWIC, Basic orientation Plus, Westlake Geismar

Site specific orientation)

5.4.4 Provide site-specific orientation for contract personnel prior to allowing work

on site for emergency jobs via HSE approval 5.4.5 Ensure that all contractor employees use the turnstiles or scanners when

entering and leaving the complex. 5.4.6 Periodically inspect vehicles upon entering and all vehicles when exiting the plant per

Westlake Geismar security plan.

5.4.7 Contact HSE for any contractor-related security issues.

5.5 Contractors and Subcontractors

5.5.1 Ensure all employees and subcontractor employees complete the Basic

Orientation Plus and Westlake Geismar site-specific orientation prior to

beginning work on site. The Spanish version of the Basic Orientation is not

accepted at the Geismar site.

NOTE: All contract employees on the job site shall be able to speak and read

English.

5.5.2 Ensure all employees are trained on all applicable Westlake Geismar HSE

procedures.

5.5.3 Ensure all contract employees are trained, qualified and/or certified for all

work they perform on site.

5.5.4 Follow at a minimum Westlake Geismar’ s HSE Procedures. They may go

above and beyond these requirements to follow their company HSE

procedures.

5.5.5 Fill out Contractor New Employee Site-Specific Health and Safety

Indoctrination prior to performing any work onsite and turn in to HSE

Department.

5.5.6 All HSE Training shall be made available upon request.

5.5.7 Immediately report injuries, illnesses or other significant safety issues to the

HSE Dept.

5.5.8 Conduct and document weekly safety inspections of the work site.

5.5.9 Conduct weekly safety meetings for all employees.

5.5.10 Turn in a first injury report/incident investigation report to the HSE Dept. by

end of shift following any incident, injury or near miss. 5 Business days for

the final Root cause analysis with corrective action items identified and

addressed (RCA).5.5.11 Contact HSE Dept. prior to leaving site with any

employee that is being taken on or offsite for any evaluation for an injury.

5.5.12 Contact HSE Dept. when Medical treatment or evaluation is complete and

provide an update to the OSHA classification/return to work status of

employee or employees.




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5.5.13 Conduct JSA’s prior to conducting any permitted work at the Geismar site.

5.5.14 Conduct daily tailgate safety meetings.

5.5.15 Comply with all applicable federal regulations and Westlake Geismar safety

policies and procedures.

5.5.16 Participate in scheduled third-party or Westlake Geismar internal process

safety management (PSM) audits for contractors; this will include providing

requested documentation and following action items to closure.

5.5.17 Submit hours worked monthly to HSE ADMIN Assistant. 5.5.18 Attend post-job evaluation with Westlake Geismar representative.

5.5.19 Drug and Alcohol

5.5.19.1 It is Westlake’s position that all contract employees be drug and

alcohol free while they are on our property and/or equipment and

in any way performing a service for Westlake.

5.5.19.2 It is imperative that your employees be drug and alcohol free to

insure the efficient operation of our facilities, as well as conform to

the law, and most importantly, provide for safety and protection of

all employees as well as the general public.

5.5.19.3 It is required that each contractor inform his employees of our

position regarding controlled substances, and the contractor’s

responsibility to enforce this with his own employees.

5.5.20 Review HSP 116 (this document), applicable Westlake HSE procedures

and adhere to these procedures while working at Westlake Geismar.

5.5.21 Ensure appropriate safety equipment (e.g. hard hat, safety glasses with side shields,

and NIOSH approved acid gas (chlorine) escape respirator) prior to entry into the

facility.

5.6 Plant Manager

5.6.1 Meets with contractors on regular intervals to communicate contractor

expectations at the Geismar site.

5.6.2 Meets with contractors to resolve contractor performance issues whether it be

safety or quality

5.6.3 Reviews variances submitted by HSE for contractors with Grade “F” in

ISNetworld and signs the variance if he deems the contractor favorable to

work at the Geismar site.

6.0 PROCEDURE

6.1 Site Entry Requirements

6.1.1 Standard PPE

6.1.1.1 Hard hat

6.1.1.2 Safety glasses with side shields

6.1.1.3 Escape Respirator (Cl2/Acid Gases)

6.1.1.4 Additional PPE to enter any work area




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6.1.1.4.1 Safety-toed footwear

6.1.1.4.2 Work gloves

6.1.1.4.3 Flame Resistant Clothing

6.1.1.4.4 Ear plugs

6.1.1.4.5 Goggles (In Goggle-designated areas)

NOTE: Specialized PPE to protect from process hazards will be noted on the work permit.

NOTE: Specialized PPE to conduct your work will be documented on your

JSA.

6.1.2 Credentials

6.1.2.1 Basic Orientation Plus/Refresher

6.1.2.2 Geismar Site Specific (1289GVC)

6.1.2.3 Valid TWIC

6.1.3 Long term Nested/Core Contractors

6.1.3.1 When core/nested contractors have been onsite for 1 year, un-interrupted,

they shall not be required to renew their Basic Orientation Plus or the

WLV Geismar Sites Specific.

6.1.3.2 If any Core Contractor has been offsite for more than 6 months, they must

present current Basic Orientation Plus and the WLV Geismar Sites

Specific.

6.2 Qualifications

6.2.1 The following information will be utilized to measure a Contractor’s and sub-

contractor’s prior safety performance. Contractors and sub-contractors that do

not adequately meet an acceptable level of achievement will not be allowed to

perform work at Westlake Geismar Facility without a variance.

6.3 Required Qualification Submittals

6.4 Prior to or as part of the bid evaluation process all prospective contractors shall

submit the following information to their ISNetworld account for review and

acceptance by Westlake:

6.4.1.1 Answer the Pre-Qualification Questionnaire within the ISN account.

6.4.1.2 OSHA 300 and 300A logs covering the past three years and the current

year to date for the company and local/regional office.

6.4.1.3 Workers Compensation Insurance Experience Modification Rate (EMR)

documentation from the contractor’s workers comp carrier for the past

three years.

6.4.1.4 A current copy of their HSE Manual

6.4.1.5 A valid Certificate of Insurance, which meets Westlake’s insurance requirements




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6.5 Other Data

6.5.1 In addition, a review may be conducted of audit reports from former clients, the

Greater Baton Rouge Industry Alliance (GBRIA), and previous Westlake

projects.

6.5.2 All HSE Training shall be made available upon request

6.5.3 All personnel entering the facility shall complete New Employee Site-Specific

Health and Safety Indoctrination (Appendix A) prior to performing any work

onsite. This completed form shall be turned in to the HSE Department.

6.5.4 It is the expectation of Westlake, that Contractors use Westlake’s Health and

Safety Procedures to orient their employees on the Westlake site-specific HSE

requirements that may affect their work.

6.5.5 Use the following URL to obtain the latest revision of Westlake, Geismar’ s HSE

Procedures , http://www.westlake.com/geismar-hse

6.6 Selection criteria

6.6.1 Submittal Review

6.6.2 Pre-Qualification Questionnaire

6.6.3 HSE Programs

6.6.4 25% below the 3-year averages of the TRIR and DART, compared to BLS

6.6.5 The contractor’s EMR rate (1.0)

6.6.6 0 fatalities within the last three years

6.6.7 0 OSHA and/or EPA citations within the last three years

6.6.8 Certificate of Insurance meeting Westlake requirements

NOTE: All ISNETWORLD requirements shall be met prior to entry to the site or an approved

variance must be attained.

6.7 Pre-Bid Meetings

6.7.1 Based upon the size and scope of the project a pre-bid meeting may be conducted

and made available to all prospective contractors. During the pre-bid meeting, a

Westlake Geismar representative will discuss the HSE requirements of this

Contract and any unique expectations, based upon the project scope.

6.8 Contract Language

6.8.1 To ensure Contractors are made aware of Westlake HSE requirements the

contract language shall contain details of special issues expected of contractors

when working within the Geismar Complex (see appendices).

6.9 Re-Qualification

6.9.1 Contractors shall re-qualify annually.

6.9.2 Re-Qualification includes updates to all original submittal criteria.

6.10 Project-Related Work




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6.10.1 Pre-Job Meetings

6.10.1.1 Following contract award a pre-construction meeting (Pre-Job)

will be held with the Contractor and Westlake. A Westlake

Health and Safety Representative shall attend this meeting.

6.10.1.2 The following will be reviewed:

6.10.1.2.1 Job Scope

6.10.1.2.2 HSE Expectations (VPP Requirements)

6.10.1.2.3 Manpower and Equipment

6.10.1.2.4 Applicable HSE Procedures

6.10.1.2.5 Requirements for Health and Safety Plan

6.10.1.2.6 Entrance Requirements

6.10.1.2.7 Contractor HSE Oversight

6.10.1.2.8 Chemical Hazard Communication

6.10.1.2.9 Any Special Requirements

6.10.1.3 During the pre-construction meeting a Westlake Geismar Safety

Representatives will be assigned to the project for coordination

with the Contractor.

6.10.1.4 All ISNetworld requirements shall be met prior to entry to the site.

6.10.2 Orientation

6.10.2.1 All Contractor employees are required to attend Westlake

Geismar Site-Specific Orientation at an Alliance Safety Council

or other ARSC council prior to beginning work on-site.

(1289GVC)

6.10.3 Work in Progress

6.10.3.1 Audits

6.10.3.1.1 Throughout the duration of the project, the authorized

Westlake Geismar representative for the contractor will

perform occasional informal worksite inspections and as

warranted and at least one formal audit (Appendix B).

Findings from these visits will be tracked by the Authorized

Westlake Geismar Representative to ensure mitigation or

elimination. The formal audit results will be reviewed with

contractor and kept in the Project File for three years.

6.10.3.2 Post Evaluation

6.10.3.2.1 Following completion of a project completed by a contractor

the authorized Westlake Geismar representative will conduct

a Post Job Evaluation (Appendix C) of the Contractors

performance, safety, production and quality.

6.11 Nested Contractors 6.11.1 Nested Contractors will undergo at least one PSM Contractor Audit (either

local or 3rd

party) every 3 years.




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7.0 HSE Requirements

7.1 Hazard Communication

7.1.1 Westlake Geismar maintains Safety Data Sheets (SDS) for hazardous chemicals

used on site. SDSs are available to contractor personnel upon request. Request

may be made in any control room or to your Westlake Geismar representative.

7.1.2 The Contractor will submit a copy of the hazardous material inventory and all

associated SDS to authorized Westlake P representative for review and

acceptance, prior to the materials being brought onsite. The authorized Westlake

representative will review all SDS and send all new chemicals through the new

chemical approval process.

7.2 Safety Representative

7.2.1 The Contractor will assign a Safety Representative to each project. The safety

representative will be on site full time when the project crew size is 25 or greater

or otherwise requested by the Westlake Geismar Representative.

7.2.2 When no safety representative is onsite, the contractor site supervisor will be

responsible for all HSE compliance and issues that arise.

7.3 Medical First Aid

7.3.1 When the contract work force exceeds five (5) personnel, the Contractor will

provide at least one (1) employee trained in Basic First Aid and CPR to be onsite

during project work hours.

7.3.2 The Contractor will maintain a first aid kit of adequate size for the number of

employees working on the project.

7.3.3 Westlake Geismar maintains an Emergency Response Team (ERT) available on

all shifts. In the event of a medical emergency, notify Westlake Geismar

operations personnel for assistance from the ERT.

7.4 Safety Violations

7.4.1 In the event of violations or unsafe practices involving imminent danger to

personnel, immediate action will be taken to stop work and correct the hazardous

situation. If violations continue or corrective actions are not taken after a

reasonable period of time, Westlake Geismar option of terminating the contract

will be enforced.

7.4.2 Violation of safety requirements by Contractor employees will result in

appropriate disciplinary action, up to and including termination.

7.5 Housekeeping

7.5.1 Housekeeping is to be an ongoing process throughout the day and not performed

only at the completion of the day's work.

7.5.2 During the course of construction, alteration, or repairs, all debris will be kept

cleared from work areas, passageways, and stairs in and around buildings or

other structures.

7.5.3 The spillage of oil or any other foreign substance onto the ground or into plant

sumps, trenches or ditches is strictly prohibited. Any spill or release must be

immediately reported to the unit or authorized Westlake Geismar representative.




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7.6 Motor Vehicle Operation

7.6.1 Observe the speed limits and all posted traffic signs. Maximum plant speed is 10 mph.

7.6.2 All drivers and passengers must utilize seat belts when the vehicle is equipped

with seat belts while operating the vehicle on Westlake Geismar property.

7.6.3 Equipment will not be fueled while the engine is running. This includes engine

driven equipment such as air compressors, welding rigs, etc.

7.6.4 Motor vehicles are to be driven to the side of the road and shut down

immediately upon sounding of the plant emergency alarm system. Vehicles'

occupants will evacuate on foot in a cross wind manner to the nearest shelter

location. Do not attempt to restart vehicles until the "All Clear" has been

sounded.

7.6.5 Drivers will sound the vehicle horn prior to backing up unless vehicle is

equipped with a backup alarm.

7.6.6 Vehicles must not be left running unattended.

7.6.7 Vehicles may carry only the maximum number of persons it was designed to

accommodate. Passengers may only be transported if they are riding in the cab

of pickup trucks that have adequate seat belts for the number of passengers.

7.6.8 Contractors who want to bring vehicles on site for work must get management

approval (Westlake Geismar Contractor Vehicle Site Access Approval Form -

Appendix E). Once a manager has signed the approval it must be submitted to

Security prior to entry.

7.7 Cranes/Critical Lifts

7.7.1 Prior to using cranes for any work, the Contractor will present to the Contract

Monitor a copy of the crane’s Annual Inspection Certificate.

7.7.2 Cranes will be restricted to 90% of the capacity shown on the manufacturer’s

capacity chart when operating in the stability or tipping portion of the chart.

When operating in the structural integrity area of the chart, the capacity shown

on the chart is acceptable.

7.7.3 An qualified Assembly/Disassembly Director (A/D) must be present

anytime a crane is assembled or disassembled including any manipulation

to the JIB.

7.7.4 A lift will be considered critical when any of the following conditions exist:

7.7.4.1 The load exceeds 75% of the crane capacity as the crane is configured to

perform the lift.

7.7.4.2 Lifts involving more than one crane to handle a common load.

7.7.4.3 The crane or lifting device is used in an application that deviates from the

manufacturer’s recommendations including, but not limited to:

7.7.4.4.1 Boom configuration not per boom make-up chart

7.7.4.4.2 Moving a crane with longer boom than recommended 7.7.4.4.3 Exceeding capacities for restrictions shown on the load chart

7.7.4.4 Lifts made over process equipment.

7.7.4.5 Man baskets

7.7.5 Prior to making a critical lift, the Contractor will submit a rigging preplan to the

Contract Monitor for review and acceptance. Submittal will be made no later

than five (5) working days before the lift is scheduled to be made. The rigging

preplan will include:




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7.7.5.1 Manufacturer, model, and capacity of the crane(s)

7.7.5.2 Capacity charts

7.7.5.3 Working radius

7.7.5.4 Boom length

7.7.5.5 Weight of load including rigging

7.7.5.6 How the weight was determined

7.7.5.7 Size and capacity of rigging hardware (slings, shackles, etc)

7.7.5.8 Drawing showing the rig and load layout and extent of movement.

7.7.56 Tag lines must be used to control loads where rotation or uncontrolled

motion may occur.

7.8 Cell Phones in the Plant

7.8.1 Cell phone or other electronic devices use is prohibited in any process or work

area without a work permit.

7.8.2 If the phone is to be used in a process area, they must obtain a hot work permit.

If the phone or other electronic device (I.e. IPad) is approved for use in Class I

Div. 2 areas, a safe work permit would be adequate.

7.8.3 Cell phones or other electronic devices may be used only for work-related

activities and must not present a distraction while performing work.

7.9 Environmental

7.9.1 Drummed and Containerized Material

7.9.1.1 All contractors will be charged with the responsibility of handling all

drummed and other containerized material including: receiving,

storing, and disposing of all material received in drums as part of your

work. Contractors will be responsible for labeling and handling the

contractor additionally will be responsible for clean-up and disposal of

any material that is spilled.

7.9.2 Storm Water Pollution Prevention

7.9.2.1 The following practices should be used to keep to keep containments

from reaching storm water.

7.9.2.2 Keeping work areas neat and orderly

7.9.2.3 Keep containers (drums, buckets, roll-off boxes, totes, etc.) closed

when not in use

7.9.2.4 Promptly cleaning up areas where drips and small spills occur

7.9.2.5 Properly disposal of material from clean-up activities 7.9.2.6 Storage of materials under roof or indoors

7.9.2.7 Containment for chemicals/materials to prevent spills; management of

storm water from these containments (if exposed to weather)

7.9.2.8 Use of drip pans and berms

7.9.2.9 LABEL ALL CONTAINERS

7.9.2.10 Immediately repair any power equipment leaking fuel or fluids

7.9.3 Solid Waste

7.9.3.1 Prior to any waste generation Westlake LPHSE shall be contacted

to make the Hazardous Waste Determination required by federal

and state regulations. In some instances, the Hazardous Waste




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Determination cannot be performed prior to waste generation. In

these situations, Westlake LPHSE will make a preliminary

determination pending laboratory analysis.

7.9.3.2 Once the Hazardous Waste Determination has been made, Westlake

LPHSE will determine the required labeling and storage protocols

for the generated waste. General waste guidelines are listed below

7.9.4 Non-Hazardous Waste

7.9.4.1 All containers with Non-Hazardous Waste must:

7.9.4.1.1 Be labeled with Green Non-Hazardous Label

7.9.4.1.2 Contents must be listed on the label

7.9.4.1.3 Have the date the waste was first put into container on label

7.9.4.1.4 Be closed when full or not in use

7.9.5 Hazardous Waste

7.9.5.1 Must have Hazardous Waste Label and dated when waste first enters

drum

7.9.5.2 When drums are full, they must be moved into Hazardous Waste Storage

area within 72 hours of being full

7.9.5.3 Containers must be kept closed when not in use

7.9.5.4 Contact Westlake Geismar Supervisor if there is any question

about waste

7.10 Temporary Buildings and Tents

7.10.1 All temporary buildings, including but not limited to blast resistant modules or

otherwise known as a c-can, tents, sheds, etc. that are intended to be occupied OR

not occupied, when on Westlake Geismar property shall be reviewed and

approved by the PSM SAFETY Supervisor before the building can be

mobilized.

7.11 Material Gate Pass

7.11.1 When a contractor wants to remove any tool, material, or equipment they must get a

material gate pass and present upon departure.

7.11.2 In lieu of using a gate pass to exit the plant, vehicles entering the plant with items that

they intend to leave with on the same day, may provide the gate guards with a written

inventory of the items. The guard will verify the items coming into the plant match the

inventory list upon entry and exit of the plant. If any concerns arise, the guards can

request an additional gate pass.

8.0 TRAINING

8.1 Initial training for Westlake employees will be conducted and documented through

Westlake MOC process.

8.2 Refresher training required when changes to the procedure or employees exhibit

deficiencies in understanding this procedure.




Page 14 of 23



9.0 RECORDKEEPING

9.1 Pre-Job Meetings will be maintained in the Project File

9.2 Copies of all formal project Contractor audits shall be maintained in the Project File.

9.3 The Post Job Evaluations will be maintained in the Project File.

9.4 Contractor HSE Indoctrination Forms will be maintained by HSE.

9.5 Annual Contractor PSM Audit for nested contractors will be maintained by HSE.

10.0 PROCEDURE REVIEWS

10.1 This Program will be reviewed every three years. HSE will ensure this review is

performed. The purpose is to assess compliance and to evaluate program

effectiveness.

10.2 Following the review, the program will be revised to include any necessary changes.

Review results will be documented. All employees will be informed of any changes

made in the plan.

10.3 Revisions to this procedure shall be completed through the management of change

(MOC) procedure.

11.0 REFERENCES

11.1 29 CFR 1910.119 (h) - Process Safety Management

12.0 APPENDICES

Appendix A – New Employee Site-Specific Health and Safety Indoctrination

Appendix B – Pre-Job Meeting Form

Appendix C – Project Contractor Audit Form

Appendix D – Project Post Job Evaluation Form

Appendix E – Annual PSM Contractor Audit Form

Appendix F – Westlake Geismar Contractor Vehicle Site Access Approval Form

Revision History

Rev Changes Approved Date

1 Updated for BOP and Sites Specific for core contractors




Page 15 of 23



APPENDIX-A Contractor Employee Name (Print): Date:

Employee Number: Contractor Name:

Upon Entering, Westlake Geismar, I was instructed on the following safety rules, practices, and requirements:

Emergency signals and evacuation procedures (ERP 104 Alarms and Evacuation)

Westlake Commitment to Safety (HSE 101 Safety Policy). No job is so important that we cannot take time to

work safe.

Entry requirements, cell phones, control of entrance/exit from work areas, Westlake Security. (102 General

Safety Security Rules)

Location and use of medical supplies & emergency equipment, including eye wash stations & safety showers.

Procedures for reporting near-miss incidents, property damage, accidents, injuries, & emergency situations. (114

Incident Reporting

and Investigation)

Personal protective equipment required, including situations when additional personal protective equipment is

required &

the necessary training before use. (405 PPE)

My responsibility for the use of fall protection at Westlake Geismar. (406 Fall Protection)

Chemical hazards and physical hazards. I have been informed of the requirements of the Hazard

Communication Standard; the

chemicals & physical agents, their properties, their hazards & effects, how to recognize them, and means of avoidance

should exposure to them occur in the jobsite; and the location, availability, and meaning of safety data sheets (SDS)

(116 Independent Contractors, 116_2 Hazardous Chemical Communication)

Signs & Labels (warning and informational), including the responsibility for barricades. (102 General Safety

Security Rules)

Lock-out/tag-out procedures (505 Lockout Tag out) / Line entry procedures (507 Blinding and Line Breaking)

Work permits, including safe work permits, hot work permits, and confined space (vessel entry) permits,

excavations (501 Safe

Work Permit, 503 Confined Space entry program, 504 hot Work Permit Procedure and checklist, 508 Excavation

Procedure)

Confined space procedures (503 Confined Space entry program)

Requirements for respiratory protection, including the use & restrictions for the use of breathing air (405 PPE)

Requirements for the use of vehicles, machinery, equipment, and tools, including who is authorized (501 Safe

Work Permit)

My responsibility for inspecting tools, equipment, etc. prior to use and of immediately reporting defects or

damaged or missing

safety guards.

My responsibility for not engaging in any activity or using any tools, equipment, or procedures that may be

unsafe (102 General


Requirements for lifting plans, rigging and competent persons. (102 General Safety Security Rules)

My individual safety responsibilities, including reporting any hazards, near misses, or accidents (102 General


My responsibility for notifying and/or protecting all employees in adjacent areas. (102 General Safety Security

Rules)

Reference https://www.westlake.com/geismar-hse for Westlake Safety procedures.

THE ABOVE HAS BEEN REVIEWED WITH ME & EXPLAINED TO MY SATISFACTION. I UNDERSTAND THAT IF I DO NOT

KNOW, IF I AM IN DOUBT, OR IF I DO NOT FULL COMPREHEND ANY PART OF THE JOB INSTRUCTIONS, EQUIPMENT, OR

PROCEDURES, IT IS MY OBLIGATION TO ASK FOR EXPLANATIONS BEFORE I BEGIN ANY WORK ASSIGNMENT. AS A

CONDITION OF work while onsite at Westlake, I ACCEPT RESPONSIBILITY FOR THE PROPER USE AND CARE OF ALL

SAFETY EQUIPMENT, MACHINERY, TOOLS, & EQUIPMENT ISSUED TO ME, AND I AGREE TO ABIDE BY ALL COMPANY,

PLANT, STATE, AND FEDERAL WORK RULES, PROCEDURES, AND REGULATIONS.

Contractor Employee Signature Date




Page 16 of 23



Appendix B – Pre-Job Meeting Form Name of Project:

Contractors Involved:

Date:

1. Introductions

2. Project Overview

3. Safety

A. PPE, Site Entry Requirements (badge request)

B. Parking / Gate Entrance

C. Vehicle Access

D. Daily Safe Work Permitting, LOTO Procedure (Blue/Yellow Locks w/ name/company)

E. Safe Process Piping, Equipment, & Vessel Opening

F. FW / HW / Confined Space Policies, Metering

G. Hard Barricades: Handrail / Grating Removal, Process Equipment Barricades

H. Equipment Flagmen

I. Lightning Policy

J. Cell Phone Policy

K. Weekly / Monthly Alarms

L. Incident Notification / Emergency Contacts / Radio (channels, qty)

M. Break / Smoke Pen / Lunch Areas / Temporary Buildings

N. SDS (SiteHawk)

O. CPR / First Aid Requirements

P. Westlake HSE Procedures Website: http://www.westlake.com/geismar-hse

Q. Invitation to Quarterly Contractor Safety Meeting (Send Contractor contact info to safety)




Page 17 of 23



4. General

A. Excavation Permit, Probing Requirements

B. Hot Work / Fire Box location(s)

C. Muster Location

D. Major Equipment Mobilization, Locations

E. Change Order Process

5. Schedule

A. Mobilization / Milestones / Completion

B. Work Hours

C. Manpower

D. Update Meetings (time, location)

6. Project Execution / Planning Update

A. Contractor Submittals (WPS, SSSP, etc.)

B. Fabrication Update

C. Material / General Procurement / Manpower issues

D. Subcontractors on-site (Scaffold, NDE, M / O Crane, etc.) (Must be in ISN)

Document Number: HSE 116 Revised By: C Chapman Manager Approval: MOC No. HSE 18 10



Page 18 of 23



Appendix C – Project Contractor Audit Form

*All answers are Yes, No, or N/A. YES NO N/A

1) Does the contractor have a JSA?

1a) If YES does the worker have knowledge of the JSA?

1b) If YES does the JSA fit the scope of work being performed?

1c) if YES Are hazards Identified and Controls adequate

2) Does the contractor know the evacuation procedures including

assembly locations?

3.) Does the contractor know what to do in the event of an injury/incident?

4.) Does the contractor know the location of the nearest safety shower?

5.) Does the contractor know what chemicals they are working with and the

potential hazards?

6.) Does the contractor have proof of training/certification for the tasks

being completed? (Rigger, Firewatch, Forklift Operation, CS Attendant)

7.) Does the contractor have proof of inspection/certification for the

equipment being used? (Manlifts, Forklifts, Cranes, Slings)

8.) Is the appropriate PPE being utilized by the contractor?

9.) Is the contractor utilizing appropriate fall protection systems?

10.) Are LOTO devices being used properly?

11.) Is the contractor's housekeeping acceptable?

12.) Is the contractor's barricade erected and tagged appropriately?

13.) Is the contractor using electrical cords properly including utilizing

GFCIs?

14.) Does the firewatch, CS attendant, bottlewatch know their duties?

15.) Are there any wildlife or environmental concerns in the area?

16.) Is the contractor familiar with applicable Westlake procedures for the

work being performed?

17.) Does Contractor have a Westlake Permit?

17a) If yes Does work being performed match Permitted work

description.

17b) If yes are all Permit requirements met by contractor?




Page 19 of 23



Appendix D – Project Post Job Evaluation Form

Post-Job Evaluation Form Question # Question Response NA

1

Project Name

2

Start Date

3

End Date

4

Westlake Contract Monitor

5

Evaluation Conducted by (Name & Title)

6

Meeting Date

7

Total Man Hours W orked

8

Total First Aid Cases

9

Total Medical Treatment Cases

10

Total Lost Time Cases

11

Total Property Damage Cases

12

Project Recordable Incident Rate (TRIR)

Response Options: Unacceptable, Improvement Needed, Met All Requirements

13

Commitment to Health and Safety

14

Quality of On Site Supervision

15

Quality of Onsite Safety Representative

16

Reporting of Injuries/Incidents

17

Participation in Accident Investigation

18

Timely Submittal of W ritten Investigation Reports

19

Compliance to Site Safety Rules

20

General Hazard Control

21

Use of PPE

22

Compliance with Permit Process

23

Response to Safety Requests

25

Housekeeping Practices




Page 20 of 23



26

Response to Housekeeping Requests

27

Condition of Tools and Equipment

28

Knowledge and Usage of Tools and Equipment

29

Participation in Emergency Drills

Response Options: On Budget, Over by up to 9.99%, Over by >10%

30

Ability to Meet Budget Requirements

Response Options: Yes/No

31

Attended Contractor Safety Meeting

32

Plant Entry Requirements Met

Response Options: Unacceptable, Improvement Needed, Met All Requirements, Exceeded Expectations

33

Overall Rating

Response is Optional

34

Safety Comments

35

Commercial Comments

36

Maintenance/Project Comments




Page 21 of 23



Appendix E – Annual PSM Contractor Audit Form

PAGE INTENTIONALLY LEFT BLANK




Page 22 of 23



Appendix F - Westlake Geismar CONTRACTOR Vehicle SITE ACCESS APPROVAL Form

WESTLAKE GEISMAR CON TRACTOR VEHICLE

SITE ACCESS APPROVAL FORM

APPLICANT INFORMATION

Driver Name (s):

Driver’s License

Number(s):

Issuing State (s)

COMPANY INFORMATION

Company phone number:

INSURANCE INFORMATION

Insurance company name:

Policy number: Expiration date:

Insurance company phone number:

VEHICLE DESCRIPTION

Vehicle Make and Model License Plate Inspection Plate Number Expiration Expiration

WESTLAKE POINT OF CONTACT

Name: Phone #:

Valid from Date:

Expiration Date:

(This date CANNOT exceed the expiration date on the insurance policy)

I authorize Westlake to verify the information provided on this form. The Westlake

manager signing this form is responsible to verify insurance coverage.

Signature of Applicant: Date

Signature of Westlake Manager: Date

The purpose of this form is to ensure that only insured authorized drivers and vehicles are permitted on Westlake property. You will need to present this form to security prior to each

entry to the site and must be visible in the vehicle while on the site. Westlake reserves the right to revoke vehicle site access approval at any time.

Date post:	28-Sep-2020
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