LOUISIANA PIGMENT COMPANY, L.P. CONTRACTOR SAFETY HANDBOOK WESTLAKE FACILITY SAFETY IS A RESPONSIBILITY THAT WE ALL SHARE. LOUISIANA PIGMENT COMPANY, L.P. QUALITY STATEMENT With a dedication to the pursuit of business excellence, we will develop and continuously improve systems throughout our operation with the focus on meeting or exceeding both internal and external customer’s needs in a way that: • Develops knowledgeable employees who take ownership • Provides a safe work environment • Provides an environmentally secure workplace • Promotes the use of quality principles and statistical tools throughout the organization to produce quality products and services • Maximizes system capability and flexibility while minimizing total costs So that Louisiana Pigment Company, L.P. continuously improves as a supplier of its products and services. TABLE OF CONTENTS SAFETY AND CONDUCT REQUIREMENTS/GUIDELINES FOR CONTRACTORS I. General .................................................................................................................................3 II. Policy ...................................................................................................................................3 III. Procedures ............................................................................................................................3 IV. Guidelines ............................................................................................................................4 V. Safety ...................................................................................................................................5 A. Hazard Communication ...............................................................................5 B. Housekeeping...............................................................................................5 C. Eye Protection ..............................................................................................6 D. Hearing Protection .......................................................................................6 E. Head Protection ............................................................................................6 F. Beard Policy .................................................................................................7 G. Respiratory Protection .................................................................................8 H. Safety Shower and Eye Wash Stations ........................................................8 I. Smoking, Dipping, and Chewing Tobacco Products……………………...9 J. Storage of Flammable Liquids .....................................................................9 K. Safe Clothing ...............................................................................................9 L. Safe Practices .............................................................................................10 M. Portable Ladders and Scaffolds .................................................................11 N. Compressed Gas Cylinders ........................................................................11 O. Hand Tools .................................................................................................11 P. Vehicles and Pedestrian .............................................................................12 Q. Crane and Crane Safety ………………………………………………… 12 R. Eating and Drinking………………………………………………………13 S. Cell Phones……………………………………………………………….14 VI. Safe Work Permitting Procedures ......................................................................................14 A. Hot Work Permits .....................................................................................14 B. Confined Space Entry Permits ..................................................................15 C. Isolation Blinds Procedures ......................................................................18 D. Electrical/Mechanical Equipment Lockout ...............................................19 E. Excavation Survey ....................................................................................20 F. Critical Lift Procedure ..............................................................................20 VII. Security ..............................................................................................................................21 Reg. Code: SHS-HB-CS-002 Issue Date: 06/14/12 Page 1 of 32 VIII. Personal Conduct ...............................................................................................................22 IX. Emergency Preparedness ...................................................................................................23 X. Fire Prevention ...................................................................................................................24 XI. Equipment Safety ...............................................................................................................25 XII. Environmental ....................................................................................................................26 APPENDICES A. B. C. D. E. F. G. Facilities .................................................................................................................27 Safety Supplies and Equipment .............................................................................27 Safety Briefings .....................................................................................................27 Injuries or Accidents by Contractor’s Personnel ...................................................27 Hurricane Preparation ............................................................................................28 Property Passes .....................................................................................................29 Lifting Plan ............................................................................................................30 Plant Map with Assembly Points Pass ........................................ Inside Back Cover Emergency Alarm Tone Chart ................................................................Back Cover ADDENDUM Potable Water Distribution Identification Plan ..................................................................32 Reg. Code: SHS-HB-CS-002 Issue Date: 06/14/12 Page 2 of 32 I. GENERAL This guide has been prepared to help you do your work in a safe manner. You are expected to abide by the Louisiana Pigment Company’s Safety Manual from which this guide is derived, and other company policies. The Louisiana Pigment Company (Louisiana Pigment) personnel for whom you are performing contract work or members of the safety staff will assist you with any questions you may have regarding this guide and other plant practices. II. POLICY The contractor and each of its sub-contractors have full responsibility for the safety of its agents and employees. Nothing contained herein shall relieve the contractor or subcontractor of such responsibility or liability. As noted above, all contractor representatives performing work at the Louisiana Pigment facility are required to comply with the safety requirements of Louisiana Pigment. The Louisiana Pigment representative, who is the primary contact for the contractor, is responsible for implementing this policy and conducting follow-up inspections to ensure that the contractor is in compliance. The health and safety of each employee is of primary importance. The prevention of occupational injuries and illnesses, and the protection of the environment will be given preference over all other concerns. III. PROCEDURES The contractor’s representative must review the safety rules applicable to the particular job, as well as emergency procedures, with a Louisiana Pigment representative. All temporary contractor personnel performing work in a process area are required to present a current General Health Safety Organization (Safety Council Orientation) card and maintain it on their person while working in the process area. They must attend and complete an approved Louisiana Pigment site-specific orientation prior to commencing work for Louisiana Pigment. Each contractor employee is required to acknowledge that he/she has received the site safety orientation by signing the “Contractor Personnel Training Record”. All temporary contractor personnel, which would include vendors, visitors and persons “incidental to the covered process”, are not required to be oriented at the Safety Council but are required to receive Louisiana Pigment’s plant orientation. Those exempt from the training, except for Louisiana Pigment plant orientation, are: 1. 2. 3. 4. Truck drivers (not staying in the facility to work). Engineers who enter to bid/review/estimate jobs. Engineering firms who work in office environment. Repair personnel for rental (or job) equipment. Reg. Code: SHS-HB-CS-002 Issue Date: 06/14/12 Page 3 of 32 5. 6. 7. 8. 9. Delivery personnel. Service type personnel. (Xerox, soft drink, telephone, laundry delivery, etc.) Clerical (office environment). Janitorial work. Supply services that do not influence process safety. The contractor is required to report to the Louisiana Pigment representative any chemical release to the environment; either to the air, water or soil. The contractor is required to report to the Louisiana Pigment representative ANY injury that occurs while working at any Louisiana Pigment facility. The contractor is required to be in compliance with all applicable requirements of the Occupational Safety and Health Administration, National Fire Protection Agency, Louisiana Department of Environmental Quality, and Environmental Protection Agency. IV. GUIDELINES Non-Louisiana Pigment personnel working at any Louisiana Pigment locations shall be familiar with and conform to the following general guidelines: A. Conduct yourself so you do not create a hazard to yourself, your fellow employees, Louisiana Pigment personnel or property. B. Do not operate Louisiana Pigment equipment (valves, switches, controllers, etc.) without the specific approval of the Louisiana Pigment personnel for whom you are doing work. C. Keep your supervisor informed of any environmental, health, or safety problems or any other hazards so that prompt corrective action can be taken. D. Work should not begin until your supervisor and the Louisiana Pigment personnel for whom you are performing work reach an agreement as to the method of operation and a work permit is issued. E. If your work requires you to enter any Louisiana Pigment operating areas, you must know the safety rules and procedures applicable to that area. F. Strict adherence to Louisiana Pigment’s Environmental, Health and Safety rules are required. Any deviation must be reviewed with the operating area supervisor and a representative of the Environmental and/or Safety Departments. Failure to obey rules could result in the termination of your contract. G. Exposure of Louisiana Pigment’s personnel to your worksite and operations should be minimized and limited to the extent practical. Reg. Code: SHS-HB-CS-002 Issue Date: 06/14/12 Page 4 of 32 H. Prior to the commencement of any work, the appropriate permit must be completed, i.e., “General Work”, “Hot Work”, or “Confined Space”. Other specialty permits may be required. Consult with your assigned Louisiana Pigment representative. I. There is to be no chemicals brought into any Louisiana Pigment facilities without prior written approval from the Environmental and Safety Departments. V. SAFETY Safety is a responsibility that we all share at Louisiana Pigment. We require all contractors to accept Louisiana Pigment's philosophy and work safely. The purpose of this section is to help you prevent injuries. All contract personnel are required to comply with the following rules and all additional requirements specified by the Environmental and Safety Departments. A. Hazard Communication 1. Your Louisiana Pigment contact must obtain approval of all chemicals and each approved chemical will be assigned a number (LPC #) prior to your bringing any chemical on Louisiana Pigment property. 2. Do not use chemicals before receiving proper training. 3. Maintain at your worksite all Material Safety Data Sheets (MSDS’s), a master list of chemicals to be used onsite, and a copy of your written hazard communication program. 4. Provide employee training for label descriptions, warning properties, use of required personal protective equipment and first aid precautions for chemicals to be used. 5. Maintain proper labels on all containers. B. Housekeeping - The contractor is responsible for keeping their work areas clean. Trash such as paper, plastic, and wood that is not contaminated can be placed in the common trash containers. Your Louisiana Pigment contact should be consulted if there is any doubt about what or where disposals are to be made. Disposal of hazardous or classified waste must be coordinated through the Louisiana Pigment’s Environmental and Safety Departments. 1. Maintain a clean work area and clean up work debris and tools at the end of the shift, each day and/or at the end of the job. NO JOB IS COMPLETE UNTIL THE AREA IS CLEAN and all material disposed of in proper containers. Reg. Code: SHS-HB-CS-002 Issue Date: 06/14/12 Page 5 of 32 2. Remove exposed or protruding nails without delay. 3. Report any spill or release immediately to a Louisiana Pigment representative, even if the situation is deemed to have no impact. 4. Pallets, brooms, mops or ladders, etc., should be placed in racks or rooms provided for them. 5. Arrange boxes or containers in such a manner that they will not fall. 6. Glass drink bottles are not allowed into the plant or beyond the guardhouses. 7. Any fires that occur, no matter how small, must be immediately reported to a Louisiana Pigment representative, even if the situation is deemed to have no impact. C. Eye Protection 1. Safety Glasses with side shields, in accordance with ANSI/Z87.1, are to be worn upon entrance into the plant. Offices, break rooms, lunchrooms, control rooms, smoke shacks and Stores Receiving are the only exceptions to the Safety Glasses rule in the plant. Light enhancing shaded glasses are accepted if written permission is obtained from the Louisiana Pigment’s Plant Manager or Administration Manager in advance. Safety glasses must meet Louisiana Pigment specifications. Photo gray lens are not allowed. Transition lens are allowed. 2. Wearing of street glasses and/or contact lens is prohibited. 3. Face shields, chemical splash goggles or other types of eye protection must be readily available and worn as specified for the various areas or required by specific jobs. D. Hearing Protection 1. Hearing protection must be worn in areas designated by posted signs, or as supervision of the job deems necessary. 2. Contractor equipment generating noise levels above 85 dBA must be reviewed with the Louisiana Pigment Company representative before operation. E. Head Protection 1. Hard hats are required in all areas of the plant except offices, control rooms, Product Warehouse, labs, smoke shacks, lunchrooms, and break rooms. Reg. Code: SHS-HB-CS-002 Issue Date: 06/14/12 Page 6 of 32 2. Hard hats are not required in the Maintenance Building Shop area unless overhead work is in progress. 3. Hard hats are required when entering or exiting the plant. 4. Hard hats are designed with a bill in the front to deflect anything from the face and are NOT to be worn backwards. 5. Welders will be required to wear hard hats in the process areas when not welding and using a welder’s helmet. F. Beard Policy 1. This policy is established to prevent exposure to inhalation hazards resulting from improper seals of respiratory protective equipment. 2. This policy applies to all Louisiana Pigment employees and contractors working at or assigned to the Lake Charles facility who may be required to wear a respirator. It does not apply to all visitors (see Item 4-5, “Exceptions”). 3. OSHA 1910.134(G)(1)(i) states that the employer (Louisiana Pigment Co., L.P.) shall not permit respirators with tight-fitting face pieces to be worn by employees who have facial hair that interferes with the proper seal of respiratory protection equipment. Therefore, Louisiana Pigment has adopted a policy to comply with this requirement. 4. Moustaches: Employees are allowed to wear moustaches as long as the moustache does not in any way interfere with the seal of a full-face respirator. The shape and sizes of the face differ from one person to the next but in general, in order to achieve a good seal with a full-face respirator, the moustache should not extend down more than one half of an inch from the corner of the mouth. 5. Exceptions: Exceptions to this policy are as follows: a. Visitors who are not required to enter the plant or process areas. b. Contract personnel who are preparing job bids, provided that: (1) (2) (3) Reg. Code: SHS-HB-CS-002 A Louisiana Pigment employee escorts them at all times while they are on the plant site. Their time in the field is kept to an absolute minimum (less than one (1) hour). Once a bid has been awarded, the contractor employees must conform to Louisiana Pigment’s NO beard policy if the nature of their work may require them to wear a respirator. Issue Date: 06/14/12 Page 7 of 32 c. Special guests receiving plant tours are exempt, provided that: (1) (2) d. They are escorted at all times by a Louisiana Pigment employee. Their time in the field is kept to an absolute minimum (less than onehour.) Truck drivers or vendors whose sole purpose for entering the Louisiana Pigment plant is to make a pickup or delivery and is under the supervision of a Louisiana Pigment supervisor or designee while in the plant, plant access is limited only to the directed point of pickup or delivery, time in the plant is no more than what time it takes to make the pickup or delivery, and is restricted from any operating areas of the plant unless accompanied by a Louisiana Pigment employee. DEVIATIONS FROM THE GUIDELINES AND/OR EXCEPTIONS DESCRIBED ABOVE MUST BE APPROVED IN ADVANCE BY THE DEPARTMENT SUPERINTENDENTS OF THE AFFECTED AREAS AND THE SAFETY DEPARTMENT. G. Respiratory Protection - Louisiana Pigment personnel will review respiratory protection requirements prior to the job beginning. 1. The contractor shall provide suitable respirators when such equipment is necessary to protect the health of their employee. 2. The contractor shall be responsible for the establishment and maintenance of a respiratory protection program as outlined by OSHA. 3. Persons should not be assigned to tasks requiring use of respirators unless it has been medically determined that they are physically able to perform the work and use the equipment. The respirator user’s medical status should be reviewed at least annually. 4. Fit testing, pulmonary function tests and employee-training records should be available upon request by Louisiana Pigment Company. H. Safety Shower and Eye Wash Stations - Are green in color and marked by a blue light. 1. Safety shower and eye wash stations are located where chemicals are dispensed or handled and at battery charging stations. If any chemicals are spilled on the body, flush immediately with plenty of water by using the safety shower and remove contaminated clothing at once. In case of a splash in the eye, flush for 15 minutes with eyelids open. Report either case to your supervisor. Special procedures may exist for certain chemicals. Be sure to discuss potential chemical exposures with a Louisiana Pigment representative before starting work. Reg. Code: SHS-HB-CS-002 Issue Date: 06/14/12 Page 8 of 32 2. Eye wash fountains and safety showers are not to be used for any purpose other than safety reasons. I. Smoking, Dipping, and Chewing Tobacco Products The use of any tobacco products is only allowed in designated areas. Your Louisiana Pigment contact can direct you to these areas. J. Storage of Flammable Liquids 1. Flammable liquids should not be stored in operating buildings unless absolutely necessary and only in limited quantities according to classification. The Safety Department must approve storage. 2. Safety cans and approved storage cabinets are required for small quantity storage inside operating areas. K. Safe Clothing 1. Loose clothing, such as shirttails outside pants, neckties, bandanas, open sweaters or jackets are not to be worn when around moving machinery, electrical equipment, or in any of the units. 2. Long pants are required for anyone doing work within the plant. The legs of pants are to be worn over the top of the shoes or boots and not tucked into the top of the boots when inside the process units and lab or while performing welding or burning tasks. 3. Loose fitting jewelry such as wristwatches, finger rings, necklaces, bracelets and earrings are not allowed when working around moving machinery. 4. A good quality, leather / rubber, steel toed, work shoe or boot, must be worn at all times in the process areas and in the Maintenance Shop. Unsafe shoes such as open strap, sandals, tennis or canvas shoes are prohibited in the process areas. Safety shoes or boots must meet the requirements and specifications of the American National Standard Institute (ANSI) standard for safety toed footwear, Z41.1. 5. Sleeveless (tank-top) type shirts or short pants are prohibited as work clothes for anyone who is performing work for Louisiana Pigment. Long sleeve shirts are not required in most operating units of Louisiana Pigment, unless the permit specifies long sleeves or arm protection. Your Louisiana Pigment contact person will advise you as to the requirements for the areas you are to be working in. 6. Exceptions: Exceptions to this policy are as follows: Reg. Code: SHS-HB-CS-002 Issue Date: 06/14/12 Page 9 of 32 A. Truck drivers or delivery personnel going only to Stores are exempt; if: 1. the sole purpose for entering the Louisiana Pigment plant is to make a pickup or delivery, 2. is under the supervision of a Louisiana Pigment supervisor or designee, 3. plant access is limited only to the directed point of pickup or delivery at stores, 4. the time in the plant is no more than what time it takes to make the pickup or delivery. L. Safe Practices 1. Operation of machinery, valves, or equipment having a “DANGER-DO NOT OPERATE” tag is prohibited. 2. Do not start, shut down, or manipulate operating process equipment without prior authorization, except in emergencies. 3. Where climbing is necessary, use an appropriate ladder. 4. Handrails should be used when going up or down the stairs. 5. Do not carry tools or sharp objects in your pockets. 6. Machine guards must never be removed except when making repairs to the equipment. Guards must be installed before equipment is started. 7. Never enter a barricaded area. The barricade indicates a hazardous location. Yellow tape indicates a potential hazard. You must be aware of the hazard before entering the barricaded area. Red tape indicates a serious or immediate hazard. Only personnel permitted for work inside the barricaded area or approved by an authorized operations representative should cross the tape. All permit-required PPE must be worn inside the barricaded areas. 8. Do not block access to emergency equipment, such as fire extinguishers, safety shower/eye wash stations, or SCBA’s. 9. Do not block or obstruct elevators, exit doors, stairways, first aid rooms and driveways leading to them. 10. Running within the fenced area of the plant is prohibited except in the case of an emergency. 11. Do not cut any utility line or open/close any valve without receiving authorization. 12. Do not use Louisiana Pigment’s hoists or elevators without prior authorization. Reg. Code: SHS-HB-CS-002 Issue Date: 06/14/12 Page 10 of 32 13. Shoulder length or longer hair must be pulled up and tucked into the hard hat when in any process area. M. Portable Ladders and Scaffolds 1. Check quarterly inspection tag and carefully inspect ladders for defects before using. Do not use if the ladder has not been inspected. 2. Maintain proper angle. (Distance from wall should be one-quarter the height of the ladder.) 3. Defective ladders should be repaired or discarded. 4. Secure ladders at the top. 5. Only fiberglass ladders are permitted, not metal or wood. 6. Ladders should not be supported against anything smaller than two inch outside diameter steel process piping, any polypropylene (plastic) piping, or electrical conduit. 7. Scaffolds are to be erected ONLY by or under the direction of a competent person and are to be tagged and certified by a competent person indicating that the scaffold is ready for use. Scaffolds used for multiple days are to be checked before use and re-certified by a competent person at each shift. DO NOT use a scaffold unless it has an up-to-date certification tag. N. Compressed Gas Cylinders 1. Keep cylinders in an upright position and secure with chain, nylon ratchet strap, or cable. 2. Follow established procedure for handling gas cylinders. 3. Cylinders (full or empty) must have cylinder caps on when not in use. 4. Assure all compressed gas cylinders are properly labeled and have valid inspection dates. 5. Pressure in hoses attached to bottles must be released when bottles are not in use. O. Hand Tools 1. Select and use the proper tools for the job, whether they are supplied by Louisiana Pigment or supplied by the contractor. Reg. Code: SHS-HB-CS-002 Issue Date: 06/14/12 Page 11 of 32 2. Do not use defective tools. 3. Store tools properly when not in use. P. Vehicles and Pedestrians 1. All traffic signs must be obeyed. 2. Only properly trained and certified persons are allowed to operate forklifts. Seatbelts must be worn while driving a forklift. 3. No passengers are allowed on forklifts. 4. Personnel who are required to ride in truck cabs must wear seatbelts. Personnel are not allowed to ride in the rear of trucks. 5. Reckless driving will not be tolerated. 6. Vehicles must be turned OFF and keys left in the ignition when unoccupied. 7. The use of utility carts or golf carts is allowed for transportation of personnel. Seatbelts must be worn while driving or riding utility carts or golf carts. You must possess a plant issued picture I.D. to drive/operate utility or golf carts. 8. The maximum speed limit in the plant is 9 miles per hour. Q. Cranes and Crane Safety 1. Overhead and mobile crane operators shall be qualified by a written and proficiency examination. 2. An on-site proficiency review shall be made by a Louisiana Pigment representative prior to a crane operator performing lifts on-site. 3. Security and the adjacent operating area must be notified when a crane is set up and blocking a roadway. 4. American Society of Mechanical Engineers (ASME), National Electrical Code (NEC), and Occupational Safety and Health Administration (OSHA) guidelines shall be followed when working near exposed electrical distribution and transmission lines. 5. Operation practices shall comply with ASME and OSHA standards including: A. Only designated personnel shall be permitted to operate a crane. Reg. Code: SHS-HB-CS-002 Issue Date: 06/14/12 Page 12 of 32 B. A clearly legible load-rating chart shall be easily visible to the operator while sitting in his control station. C. Outriggers shall be fully extended when lifting a load, otherwise a critical lift plan must be completed. D. Wood blocks used to support outriggers shall be strong enough to prevent crushing and should extend two feet wider than the outrigger plate. E. No person shall be allowed to stand or pass under a load on the hook. F. The operator shall not be permitted to leave his position at the controls while the load is suspended. G. Tools, oil cans, waste, rags, etc. shall not be permitted loose in or about the cab or on the deck of the crane. H. Machines shall not be refueled with the engine running. I. Crane manufacturer’s recommendations must be reviewed when considering wind load. J. A critical lift plan must be completed, if any one of the following is true: NOTE: See Critical Lift Procedure starting on Page 20) 1. Lift exceeds 70% of the rated capacity of the crane 2. Any lift that requires more than 75% of the maximum boom length. Consideration must be given to adjacent operating units within the boom length. 3. Lift requires more than one crane or hoisting device. 4. Lift involves a personnel basket. (See Suspended Personnel Basket Procedure in the Louisiana Pigment Safety Manual.) 5. Any lift made over an operating unit, including fuel, feed, or product lines of an operating unit. 6. Crane inspection and testing procedures shall comply with ASME and OSHA standards. R. Eating and Drinking 1. Eating and drinking is allowed only in designated areas. Your Louisiana Pigment representative can direct you to the designated areas. Reg. Code: SHS-HB-CS-002 Issue Date: 06/14/12 Page 13 of 32 2. Exceptions: Exceptions to this policy is as follows: A. Closed, sealed containers (i.e., water coolers) placed in the work area as a necessity is allowed. The liquid is intended to be consumed immediately once placed in an open container. S. Cell Phones 1. Cell phones may only be used for personal business on Company premises during break times and in designated break areas. All other use of cell phones on Company premises is restricted to Company related business only. Cell phones may not be used while driving. The Camera function on a cell phone may NOT be used in the workplace unless the holder has a valid camera pass. Any pictures taken on plant premises must be approved by the Plant manager or his designee. VI. SAFE WORK PERMITTING PROCEDURES WORK PERMITS ARE REQUIRED FOR ALL CONTRACTOR WORK, BOTH HAZARDOUS AND NON-HAZARDOUS. Hot work, confined space, isolation blinds, electrical/mechanical lockout, and jobs that require excavations receive special attention at Louisiana Pigment. Ask the production supervision of the area you are working in if you have any questions about these permits. For more detailed information on permitting systems in place at Louisiana Pigment, consult the Permitting Procedures in the Louisiana Pigment Safety Manual. A. HOT WORK PERMITS Examples of work requiring use of HOT WORK PERMITS are welding, cutting, grinding, chipping, and drilling. Hazardous Classified Areas require a Hot Work Permit for all jobs performed in the designated area. HOT WORK PERMITS shall be issued only when adequate precautions have been taken to assure that the work can be done safely. Piping to be worked on must normally be depressurized, isolated by blinds, or disconnected and decontaminated. Attention must be given to the surroundings, such as sewers, vents, insulation, other process lines, etc. Other precautions to be taken during the course of the work must be specified on the permit. Supervision, responsible for the equipment/area involved, and personnel over the area where work is being done, issue the hot work permits. The appropriate Louisiana Pigment representative or the designated Louisiana Pigment Supervisor authorizes the work to be done when proper safety measures have been affirmed. Reg. Code: SHS-HB-CS-002 Issue Date: 06/14/12 Page 14 of 32 PERMITS MUST BE SIGNED BY: 1. PRODUCTION UNIT REPRESENTATIVE, who has primary responsibility for assuring adequate precautions and safe conditions of work in his area. 2. CONTRACT SUPERVISION, who has the responsibility of seeing that all safety precautions are carried out during the course of the job. These permits become void when their valid time elapses, at shift change, or if a plant emergency (fire, release, spill, etc.) occurs. A permit can be re-newed when their valid time has expired as long as: (1) the operator that issued the permit is still over the ongoing job, or (2) the original maintenance crew doing the work is still on the job. At no time will a permit be valid when both the operations personnel that issued the permit, and the maintenance personnel that started the job, have been relieved by the next shift. At least one of the original parties that started the job must be on the job if it is to be re-newed. B. CONFINED SPACE ENTRY PERMITS The term “confined space” refers to a space having the characteristics of limited means of access/egress, poor or unfavorable natural ventilation, is not designed for human occupancy, and may present other hazards. Examples of confined spaces are tanks, mixers, manholes, heaters, trenches and excavations, boilers, large pipelines, cooling tower basins, and similar enclosures. Confined spaces may present atmospheric hazards such as flammable, toxic, or oxygen deficient atmospheres. Other hazards may be posed by equipment contained within the space, such as mixer blades or by the mechanical work done within the space. Confined space entry permits shall be issued only with adequate precautions, both before and during the work. Entry is defined as any part of body entering beyond the outside edge of an access point or “breaking the plane”. In general, the space must be isolated by blinding or disconnecting lines, and decontaminated both with respect to flammables and toxic material. Precautions must be taken to assure that adequate air supply is present, either by natural airflow or by use of an air mover. Internal moving parts must be locked out and, if a hazard from falling exists, secured mechanically. A trained vessel attendant must be stationed outside the opening of any confined space in which workers have entered The authorized person responsible for the confined space to be entered will issue confined space entry permits. A Louisiana Pigment representative will sign all entry permits after obtaining a reading of at least 20.9% oxygen present in the confined space and a 0% LEL reading for explosives and flammables present. An appropriate monitoring device (such as electronic monitor or detector tube) must be used to detect toxic gases present in a vessel. Gas test must be performed each time the confined space is vacated. (i.e., breaks, lunch, etc.) Reg. Code: SHS-HB-CS-002 Issue Date: 06/14/12 Page 15 of 32 An area representative and the contractor representative must sign the permit after they are sure that adequate precautions have been taken and the area is safe to enter. The appropriate supervisor must authorize the entry and work to be done. The completed confined space entry permit must be with the vessel attendant in the immediate vicinity. The permit is to remain at the job site until the work is finished or until the end of the shift. Persons responsible for continuing work requiring a confined space entry permit on a succeeding shift must have the permit re-evaluated and re-signed prior to beginning work on that shift. These permits become void when their valid time elapses, at shift change, or if a plant emergency (fire, release, spill, etc.) occurs. All electrical tools needed for work inside confined spaces must be UL approved and double insulated. A GROUND FAULT CIRCUIT INTERRUPTER (GFI) must be used at the source of power. All lights must be heavy-duty/enclosed (explosion proof) and also attached to a GFI prior to use in confined spaces or be a UL approved low voltage (i.e., 6-12 volt) lighting device. 1. DUTIES OF AN ATTENDANT Because of the important responsibilities you assume when you become an attendant for a confined space entry, you should be thoroughly familiar with your duties. Only trained vessel attendants may function as “Hole Watch”. Primary Responsibilities of a Confined Space Attendant: a. To maintain an accurate count at all times of the number of persons in the confined space. This is to be accomplished by having all entrants logged in and out. b. To recognize potential hazards associated with confined space entry and monitor as necessary to determine that it is safe for the entrants to remain in the space. c. To maintain effective contact (i.e., visual or audible) with the entrants at all times and to order evacuation of the space when necessary. d. To initiate rescue of an entrant when necessary. However, you must not enter the confined space yourself to attempt a rescue. e. Do not leave the entrance to the confined space for which you are responsible while anyone is in the confined space unless another trained attendant relieves you. f. Do not accept responsibility for more than one entrance into the confined space unless you can maintain communication with all of the entrants. Reg. Code: SHS-HB-CS-002 Issue Date: 06/14/12 Page 16 of 32 g. When attendants and authorized entrants are rotating duties, the attendant must not enter the confined space until one of the entrants has left the confined space and relieved him as an attendant. h. You must have means of alerting the necessary persons to initiate a rescue. This may be by means of an air horn or whistle, or preferably by use of a radio. i. The confined space attendant must shut down the job and order the entrants out of the confined space if any entrant refuses to wear the required personal protective equipment listed on the permit. The Authorized Supervisor must be notified immediately. j. The confined space attendant must shut down the job and order the entrants out of the confined space when an evacuation alarm is sounded. k. The confined space attendant must wear an orange vest to identify themselves as the confined space attendants. l. The confined space attendant must know how to operate, know what the preset alarms are set at, and stay close enough to the portable monitoring equipment to be able to read the LED printout on the monitor and hear the audible alarm on the monitor should it go into an alarm mode. 2. DUTIES OF AN AUTHORIZED ENTRANT Because of the important responsibility you assume when you become an authorized entrant into a confined space, you should be thoroughly familiar with your duties. Read these instructions carefully. a. You must know the hazards that may be faced during entry, recognize the signs and symptoms of exposure to a hazard, and understand the consequences of exposure to a hazard. b. You must ensure the air sampling monitor is on and the draw tube is in the confined space. c. You must maintain contact with an attendant at all times while in the confined space. d. You must use the specified safety equipment. e. You must evacuate the confined space immediately when instructed to do so by an attendant. Reg. Code: SHS-HB-CS-002 Issue Date: 06/14/12 Page 17 of 32 f. You must sign in and out with the attendant when entering and leaving the confined space. C. ISOLATION BLINDS PROCEDURE This procedure establishes a permit and blind list system to reduce the accident potential when opening lines or vessels containing hazardous materials. This includes the removal of spool pieces, covers, hatches, and blinds, breaking flanges, and pulling header plugs. Venting through a valve, by I&E craftsmen, is exempt as is disconnecting pneumatic or hydraulic lines, opening pressure taps, and normal orifice plate changing. While not all work requires blinding or isolation, permits for confined space entry, cutting, welding or other hot work, normally require a full rated blind as close to the work as possible. 1. PERMIT INITIATION The Louisiana Pigment Operations Supervisor, or designee, will initiate the permit at the facility control room or designated location. If a standard blind list based on past work is not available, the Operations Supervisor or his designee will prepare one. This list showing specific blinds and locations should be attached to the permit. Operations personnel, prior to issuance of a permit, shall check blind lists for accuracy. 2. PRE-WORK JOB SITE INSPECTION The Operations Representative, who is preparing the equipment, is responsible for determining whether work can safely start before the permit is issued. He/She will ensure that the line or vessel to be worked is depressurized. If questions regarding toxic gas hazards or use of breathing equipment arise, assistance from the Safety Department can be requested. 3. PRE-WORK JOB SITE INSPECTION Operations will provide a blind list for each application which will include a simplified drawing and location for each blind. The list will include the responsible installing department, i.e., Maintenance, Operations, etc. and will have a section for the initials of the installer, the date of installation and removal. A Safe Work File or Lock, Tag and Try Sheet may be used as a blind list. The Operations Department will be responsible for installing orange plastic numbered tags at the required blinding locations per the blind list. The maintenance personnel will be responsible for installing a blue tag of the same type, at installation, with a corresponding number at the same locations to insure that the proper blinds are installed in the proper location. Reg. Code: SHS-HB-CS-002 Issue Date: 06/14/12 Page 18 of 32 After blind installation is completed, and while work protected by the blinds is being performed, the blind list with all initials and dates shall be kept in the designated Operations Area. When the blind list has been initialed as removed, the blind list will then be forwarded with the permits to the appropriate Operations Supervisor. Once the work has been complete, the maintenance personnel shall remove the blue tags and blinds, return them to the Operations Department, and initial the space indicating that the blinds have been removed. The Operations Department will then verify that the blinds have been removed, remove the orange tags and return the equipment to service using the appropriate procedure. If a blind that was installed to satisfy the requirements of a permit must be removed, the Operations Representative must be notified and the permit cancelled. 4. BLIND REQUIREMENTS a. Blind requirements shall conform to ANSI Standard B16.5 “Pipe Flanges and Flange Fittings,” API Standards 605 “Larger Diameter Carbon Steel Flanges,” current Louisiana Pigment Company design specifications, and/or a pressure/temperature design rated flange. b. A blind other than a spectacle blind must have a handle attached long enough to extend at least two (2) inches beyond pipe flanges in order to eliminate any doubt whether the in-line device is a blind or a spacer. c. Blinds, blind flanges, spacers and spectacle blinds must have the proper rating stamped on the handle, or the blind edge. d. All blinds, spacers and spectacle blinds, which are installed, shall have new gaskets which conform to current Louisiana Pigment design specifications, and/or be a pressure/temperature design rated gasket. e. All flange make-ups shall be fully bolted. The bolts shall be tightened to the correct torque values and torque sequence per current Louisiana Pigment specifications. D. ELECTRICAL/MECHANICAL EQUIPMENT LOCKOUT Electrical and mechanical equipment lockout is required to clean, repair, install, dismantle, service or inspect any equipment or system which, if accidentally operated or energized, could cause personal injury or property damage. The electrical or mechanical system must be locked and tagged by production personnel prior to maintenance installing locks on an energy-isolating device. Reg. Code: SHS-HB-CS-002 Issue Date: 06/14/12 Page 19 of 32 E. EXCAVATION SURVEY The issuance of a permit that involves excavation is contingent upon the completion of a Pre-Excavation Survey that must be completed by a competent person. An Excavation survey is required any time digging twelve (12) inches or more below grade is done, or any time the use of heavy equipment (i.e., backhoes, track hoes, dozers, etc.) is used to dig, no matter what the depth is, on Louisiana Pigment property. This permit must be signed by the Shift Supervisor, the Maintenance (or Contractor) Supervisor, and competent person. It is attached to a General Work, Hot Work, or Confined Space permit. The Excavation Survey shall stay on the job site attached to the work permit, in a conspicuous location. The Excavation Survey and permit must be returned to the Production or issuing Supervisor when the job is completed or at the end of the shift. EXEMPTIONS: The use of heavy equipment in the Landfill cells. F. CRITICAL LIFT PROCEDURE 1. The jobsite supervisor shall ensure that a formal lifting plan is developed, documented and reviewed for all “CRITICAL” lifts, prior to mobilization. Reviews should occur again, prior to equipment set-up and prior to a lift. See Appendix E. 2. Variables such as weight of loads, length of boom, radius of lifts, value of loads, value of loss that may result from an accident, multi-crane lifts, etc., may dictate when a lift is defined as “CRITICAL”. For the purpose of this Critical Lift procedure, a formal Lifting Plan is to be developed, documented and reviewed for: a. Any lift which exceeds 70% of the rated capacity of the equipment as determined by the load chart for the specific piece of lifting equipment; b. Any lift or equipment set-up where more than 75% of the maximum boom length is utilized; c. Any lift made over an operating unit, including fuel, feed or product lines of an operating unit. (Consideration must be given to adjacent operating units within the boom length); d. Any lift where personnel are hoisted in a personnel basket. The Suspended Personnel Basket Procedure in the Louisiana Pigment Safety Manual must be followed; e. Any other lifts which may not be completely routine. Reg. Code: SHS-HB-CS-002 Issue Date: 06/14/12 Page 20 of 32 3. Once a formal Lifting Plan has been developed, if any of the variables in the equipment, load, or lift change, a new lift plan must be developed. 4. Select and use the proper tools for the job. 5. Do not use defective tools. 6. These guidelines in no way limit the documentation of any lift. Many variables may dictate that other lifts may be defined as “CRITICAL” or documentation may be desired for other lifts. 7. ALL lifts should be planned with equipment capabilities, weights of loads, radius of lifts, etc., determined before any lift is made. NO lift will be allowed if the weight exceeds 95% of the rated chart capacity. 8. The signed and dated documentation of the formal Lifting Plan is to be retained in the jobsite files. 9. All lifting equipment and procedures shall be in accordance with applicable OSHA and ANSI specifications. VII. SECURITY The following guidelines are listed so that Louisiana Pigment may effectively monitor and account for the entrance, movement and exit of all personnel and visitors to and from Louisiana Pigment. Access to Louisiana Pigment may be denied to anyone at the discretion of Louisiana Pigment management. A. Each employee of an outside contractor will present his/her company identification upon entering or exiting Louisiana Pigment property. All temporary contract personnel working in a process area must present a current General Health and Safety Orientation (Safety Council Orientation) badge, maintain that badge on their person, and complete the Louisiana Pigment site orientation annually. B. Long-term contract personnel must present a current General Health and Safety Orientation (Safety Council Orientation) badge upon initial entry of the Louisiana Pigment plant and must have completed the Louisiana Pigment site orientation. C. Cameras of any type or kind are prohibited on the plant site, unless permission is specifically granted by the Plant Manager or his designee and a Louisiana Pigment Camera Pass is issued. D. No photos are allowed to leave the plant site without approval of the Plant Manager or his designee. Reg. Code: SHS-HB-CS-002 Issue Date: 06/14/12 Page 21 of 32 E. Contractors and their employees normally will be governed by the terms of the particular contract. F. Contract personnel are restricted to the particular area in which they are working unless authorized to enter other areas. G. Prior to contract employees arriving for work, the Louisiana Pigment representative will designate the proper entry gate and parking facilities you are to use. H. Vehicles entering and leaving the plant will be inspected by Louisiana Pigment Security personnel. I. Contractor equipment/tool pass forms will be completed prior to arrival and leaving the plant site. This form must be kept current during the job. J. Seatbelts must be worn while in moving vehicles on Louisiana Pigment property. VIII. PERSONAL CONDUCT Certain general rules of personal conduct are necessary for successful operation of any organization. The following rules are not intended to cover all situations that might arise, but it is assumed that contractor’s employees are not to engage in any activity that interferes with the normal continuity of plant operations, or the maintenance of order, on the premises. The following actions or activities are NOT allowed: A. Use of any tobacco products (dipping, chewing, smoking, etc.) in unauthorized areas. B. Bringing intoxicating beverages or drugs onto the plant property. Coming to the plant under the influence of alcoholic beverages or drugs, drinking alcoholic beverages or using drugs on Louisiana Pigment property. C. Bringing firearms or any type of unauthorized explosives onto the plant property, including parking lots. D. Engaging in fights, horseplay, practical jokes, etc. E. Willful damage to plant or personal property. F. Using threatening or abusive language toward fellow employees, Louisiana Pigment personnel, or supervision. G. Stealing. H. Gambling on plant property. Reg. Code: SHS-HB-CS-002 Issue Date: 06/14/12 Page 22 of 32 I. Posting notices on plant property without prior approval of the Human Recourses Manager. J. Circulation or distributing written material of any type in the working area without prior approval from Louisiana Pigment’s Human Resources Manager. K. Pointing compressed air hoses toward anyone or using compressed air to clean clothing without an OSHA-approved restrictive orifice. L. Cleaning clothing or your person with flammable or toxic solvents. M. Loitering or taking shortcuts through process areas, QA Lab areas, shipping areas or shops. N. Jumping from platforms, scaffolds, loading docks, trucks, or other high places. O. Walking under suspended loads. P. Entering any Louisiana Pigment’s office or company vehicle without authorization. Q. Obstructing access to emergency equipment such as fire extinguishers, safety showers, or breathing apparatus. This equipment must never be used except in an emergency. R. Any form of solicitation without prior approval from Louisiana Pigment’s Human Resources Manager IX. EMERGENCY PREPAREDNESS Contractors are required to review Louisiana Pigment’s emergency procedure with their employees. An emergency is defined as a fire, chemical spill or release, accident, rescue operation or any similar incident that threatens property damage or personnel injury. EMERGENCY ALARM TONES TONES Intermittent Beeps High/Low Siren – Unit Specific Hi/Low Siren – Plant Wide Steady, Continuous Tone Reg. Code: SHS-HB-CS-002 RESPONSES Area Emergency Problematic condition - stay alert contact Operations for details. Unit Evacuation Unit specific – evacuate upwind to a designated assembly area. Plant Wide Evacuation All Clear Issue Date: 06/14/12 Proceed crosswind – upwind to designated assembly area. Resume normal operations. Permits to be revalidated. Page 23 of 32 H2S CONDITION 10 ppm Amber Light Non-essential personnel evacuate. 20 ppm Amber Light and Red Light Essential personnel don fresh air. 50 ppm Amber and Red Light Audible Evacuation Tone Fresh air required Operations divert gas stream Implement emergency action plan Keep all roads, streets and gates clear during an emergency for possible use by fire trucks, ambulances, Emergency Response Team, etc. Periodically, plant-wide emergency alarm testing will be conducted with notice given prior to each test. Onsite construction personnel should use this opportunity to review with their employees the proper steps they should perform upon hearing that an alarm situation exists somewhere on the plant site. Do not interrupt construction work for a preannounced alarm test. The proper response for contract employees in an emergency or evacuation is as follows: 1. Shut down all HOT WORK, i.e., internal combustion engines, compressors, welders, etc. 2. Calmly but quickly assemble at each contractor’s parking area or a pre-designated assembly area. 3. Perform a head count, report to a LPC contract representative, and await further instructions. 4. Upon receiving the “ALL CLEAR” signal, activities may resume. ALL WORK PERMITS MUST BE REVALIDATED IN AN AREA EVACUATED, ONCE AN ALL CLEAR HAS SOUNDED, BEFORE WORK CAN RESUME. X. FIRE PREVENTION Louisiana Pigment’s facilities and equipment are designed to incorporate maximum protection to prevent fires, release of toxic materials, and other types of accidents. To help Louisiana Pigment maintain a work area free of fire hazards, the following rules apply: A. Do not operate fire protection valves without proper authorization. Reg. Code: SHS-HB-CS-002 Issue Date: 06/14/12 Page 24 of 32 B. Cleaning solvents must have a high flashpoint (above 150 degrees Fahrenheit) and be of low toxicity. Gasoline, carbon tetrachloride, and other similar liquids are not to be used for cleaning. C. Contract personnel requiring fire protection equipment for hot work jobs must bring fire protection equipment to the job site before starting the job and return the equipment after the job is complete. Installed fire extinguishers and standpipe fire hoses will not be used for routine standby purposes. D. Notify the Safety Department and area supervision immediately after using or charging a fire extinguisher. Fire extinguishers brought to jobs for standby are not to be charged unless needed for an emergency and are not considered used unless they have been charged. E. Maintain a clearance of at least 24 inches between sprinkler heads and material or equipment to be protected. F. Fire equipment and fire system components are not to be used for anything other than fire protection purposes unless specific permission is obtained from the Safety Department and Utilities/Neutralization Department. G. Oil contaminated rags must be placed in one of the oil contaminated debris bins. H. Access to fire hydrants, fire extinguishers and other emergency equipment must never be obstructed. I. All fires must be immediately reported to, and may be investigated by, the Environmental and Safety Departments. XI. EQUIPMENT SAFETY A. Every contractor must assure that their equipment is in good working order and safe operating condition. Such equipment must meet applicable regulations, and should be operated according to manufacturer’s specifications. With regard to equipment, each contractor is encouraged to utilize the following considerations: • • • • • Safe operating procedures. Emergency procedures and emergency equipment that are an integral part of equipment design. Ergonomic considerations to ensure that employees are not injured from excessive vibration, physical stress or repetitive motion. Surfaces above 140 degrees Fahrenheit protected by insulation or guarding from contact. Moving parts properly guarded. Reg. Code: SHS-HB-CS-002 Issue Date: 06/14/12 Page 25 of 32 • • • • • • XII. Relief devices properly installed, calibrated and tested with discharge piped to safe location. Sharp edges or projections properly guarded or identified. In conformance with applicable electrical standards, including grounding and enclosure of energized components or parts. Lockout capability for all energy sources. Warning devices, interlocks or limit switches as required to guard against injury. Noise levels not exceeding 85 dBA. ENVIRONMENTAL Louisiana Pigment is dedicated not only to the safety of our employees, and visitors, but also to conducting work in an environmentally sound manner. Contractors are required to comply with all applicable state and federal laws governing the storage, transport, and proper disposal of all waste. Louisiana Pigment is classified as a generator only, less than ninety (90) days storage for hazardous waste. Any hazardous waste generated by a contractor must be properly contained, labeled under the direction of a Louisiana Pigment representative and in accordance with the Environmental Waste Handling Procedure. Any chemical release to the environment by a contractor must be reported to area supervision. The contractor should immediately take steps to stop and contain the release to minimize impact to the environment. Once the release has been brought under control, the contractor must remediate the area. Remedial activities should be discussed with area supervision and the Environmental Department prior to implementation. Please note that employee safety is the primary concern during a chemical release. If the contractor is not properly equipped with the appropriate personal protective equipment and/or have knowledge of the chemicals involved, they should immediately notify area supervision of the situation. Reg. Code: SHS-HB-CS-002 Issue Date: 06/14/12 Page 26 of 32 APPENDIX A FACILITIES Louisiana Pigment representatives will designate facilities that are available for contractor use and areas where contractors are restricted from working. APPENDIX B SAFETY SUPPLIES AND EQUIPMENT Safety supplies and protective equipment such as hard hats, respiratory protection, chemical splash goggles, work gloves, safety glasses (other than visitor type) and face shields are not provided to outside contractors. Special equipment may be provided where special conditions require. The Louisiana Pigment representative or construction engineer will discuss any special conditions with the contractor and area supervisor before the job begins to establish compliance with these provisions. Eye protection must be worn except in offices, break rooms, lunchrooms, control rooms, or other designated areas. Eye protection must be worn in the “exception” areas when performing permitted work in those areas. In areas requiring special protective equipment such as goggles, face shields, or hearing protection, this equipment must be worn at all times. When in doubt about personal protective equipment requirements, check with the Louisiana Pigment representative or the immediate area supervisor before entering the area. Hard hats and safety glasses are required to be worn by all persons whose work requires them to enter the plant. The Louisiana Pigment representative and area supervision will discuss the use of the equipment with the contractor. SAFETY BRIEFINGS All personnel assigned activities on the plant site shall receive a safety orientation. The presentation must include emergency alarms, personal protective equipment and the permit system. This must be completed prior to beginning work on the plant site. INJURIES OR ACCIDENTS BY CONTRACTOR’S PERSONNEL Contractor’s employees that sustain injuries, that requires treatment, while working at Louisiana Pigment will be taken to the Louisiana Pigment medical facility. A qualified Louisiana Pigment person will attend the injured. Contractor Supervision will be notified and be present. The company shall incur no liability for, and contractor hereby agrees to indemnify the company against, any causes for action, claim, liability, or cost, including attorney’s fees, arising in whole or in part, out of the furnishing of such medical facilities to the contractor’s employees, or out of the failure to furnish such facilities. Reg. Code: SHS-HB-CS-002 Issue Date: 06/14/12 Page 27 of 32 APPENDIX C HURRICANE PREPARATIONS Contractors working at Louisiana Pigment during the hurricane season (June through October) shall take the following precautions to maintain a safe working area: A. At all times during hurricane season: 1. Tie down all temporary construction buildings with two (2) ¼” diameter wire ropes moored by 30” long, 2”x 2”x 1/4” angle iron stakes or approved equal. 2. Tie down all oil and fuel storage tanks with two (2) ¼” diameter wire ropes moored by 30” long, 2”x 2”x 1/4” angle iron stakes or approved equal. Fill small tanks and drums with water as necessary to avoid floating or being blown around. B. As Louisiana Pigment hurricane preparation proceeds and as directed by the Louisiana Pigment representative: 1. Secure all loose construction equipment such as scaffolding, lumber, sheet metal, etc. 2. Move all mobile equipment, e.g., welding machines, compressors, etc., to a parking area designated by Louisiana Pigment. 3. Back-fill all road excavations made for construction purposes and top with limestone to make passable. 4. Verify that all external scaffolds have been dismantled or secured. 5. Lower booms or draglines, etc., without blocking process units, access routes or plant roadways. 6. Back-fill all firewall openings to 100% normal grade. Reg. Code: SHS-HB-CS-002 Issue Date: 06/14/12 Page 28 of 32 APPENDIX D Reg. Code: SHS-HB-CS-002 Issue Date: 06/14/12 APPENDIX E Reg. Code: SHS-HB-CS-002 Issue Date: 06/14/12 Page 30 of 32 Reg. Code: SHS-HB-CS-002 Issue Date: 06/14/12 Page 31 of 32 ADDENDUM POTABLE WATER DISTRIBUTION IDENTIFICATION PLAN CROSS CONNECTION ALERT Cross-Connection between a Potable Water (Available for Human Consumption) source and a Non-Potable Water (Not Available for Human Consumption) source is prohibited by the Department of Health and Hospitals. Therefore, all potable water lines must be identified in your scope of work and communicated so each contractor has an understanding prior to beginning work at Louisiana Pigment. An electronic version of the Potable Water Distribution Identification Plan is available to all personnel via the Louisiana Pigment Intranet, located on the Environmental Department web page under Plans Section. Please adhere to this Plan and follow your scope of work provided by Louisiana Pigment. Contact your immediate supervisor for any information provided by Louisiana Pigment about any potable water lines that have the possibility of being in your scope of work prior to connecting or disconnecting any lines at Louisiana Pigment. Reg. Code: SHS-HB-CS-002 Issue Date: 06/14/12 Page 32 of 32