Employee Participation procedure

SP-39 ± Employee Participation Program (11/27/2010) Purpose: Definitions:

Responsibilities: Procedure: MOC Form:

Purpose: This Employee Participation Program describes the various approaches that Company XYZ-Cadet uses to involve associates in the elements of process safety safety management (PSM). This program¶s purpose purpose is to outline the activities which demonstrate compliance with the Employee Participation elements of OSHA¶s Process Safety Management Standard regulation and EPA¶s Risk Management Plan and to encourage employees to actively participate in the process safety m anagement systems. This plan does not list all the activities activities that our associates perform perform that are important to safety. These programs also address the requirements of the BPSM Standard. Definitions:

Associate ± Company XYZ Employee BPSMS - Company XYZ Process Safety Management System CAR ± Corrective Action Response EPA ± Environmental Protections Agency MOC ± Management of Change PAR ± Preventative Preventative Action Request PSSR ± Pre-Start Up Safety Review Responsibilities: y

y

Plant Manager- Participate in BPSMS program development and implementation as outlined i n this program and other BPSMS standards. standards. Ensure associates are afforded and use participation participation opportunities as outlined in this program and the associate participation participation plan. Provide feedback on BPSMS development development and implementation. Provide access to BPSMS BPSMS information needed by both Company Company XYZ and contract associates. Observe the provisions provisions of the Trade Secret Program. Ensure associates associates attend required required safety meetings, and that content and attendance is documented. PSM Coordinator- Update and distribute the Associate Participation Participation Program description. Coordinates program activities with with other BPSMS activities. activities. Oversees program development development and implementation. Acts as key policymaker and arbitrator for issues associated with the program. Resolve any BPSMS BPSMS information access access difficulties identified identified by Company XYZ and contract associates. Request, respond to and resolve resolve comments from associates about Company XYZ¶s development and im plementation of BPSMS programs and ensure all suggestions receive a formal response.

y

y

Company XYZ associates- Provide feedback and suggestions on BPSMS development and implementation. Observe the provisions of the Trade Secret Program. Ensure that BPSMS information necessary for  performing work safely has been obtained prior to performing assigned task. Report any difficulties in obtaining BPSMS information to the Plant Manager or PSM Coordinator. Attend and participate in required safety meetings. Contract associates and supervisors-Comply with the Contractor Safety Program requirements and provide contract associates with BPSMS information and performing required implementation tasks. Provide access and resolve any difficulties identified by contract associates in accessing BPSMS information. Observe the provisions of the Trade Secret Program. Report any difficulties in obtaining BPSMS information to a contract associate supervisor or Company XYZ Plant Manager/PSM coordinator 

Procedure (General): Employee Participation Program Company XYZ Cadet encourages participation by: y

y y

y y

Consulting with associates on the dev elopment of the various requirements of BPSM including PHAs, Incident Investigations, SOPs, etc. Providing associates with access to information developed under this rule. Involving associates in complying with the various elements based upon their knowledge, skills, and experience. Encouraging associates to submit safety suggestions via CAR, PAR and management of change systems. Participating on the teams to ensure associates are completing daily tasks in a safe manner.

PROCESS SAFETY INFORMATION Associates participate in the process safety information element by: y y y

y

y

Assisting in collecting and v erifying existing information. Assisting in keeping required information continually up to date. Documenting and providing input on changes to P&IDs, loops, and equipment drawings etc. which fall out of normal work processes. Communicating observations during normal conduct of work specifically those that reflect operational issues. Viewing and utilizing PSI as needed.

PROCESS HAZARD ANALYSIS (PHA) The results of PHAs are shared with all affected associates and final PHA reports are located in the Computer room and are available on line in the BQS system. Associates participate in the process hazard analysis element by: y y y

Participating as team members in PHAs and revalidations. Understanding the results of the PHA and revalidations and resolution of recommendations. Participating in the implementation efforts, as result of changes brought about by the PHA.

OPERATING PROCEDURES Associates participate in the operating procedures element by: y y

y

Performing operations task in accordance with operating procedures. Consulting during procedure development/implementation to determine if the procedure adequately affects what is really done and what needs to be done to better reflect what steps are necessary to attain the desired results in a safe and environmentally responsible manner. Actively communicate to management any changes that are recommended to the operating procedure as opportunities for improvements are identified.

TRAINING Associates participate in the training element by:

y

y y y

Assisting with the development of customized training based upon associate need which allows for input regarding course material, training frequency, and evaluation methods. Receiving and understanding initial and refresher training for all associates. Providing on the job training for other associates. Raising safety concerns during t raining sessions.

CONTRACTORS Associates participate in the contractor element by: y y

y y y

Ensuring that contractors follow the required safe work practices and safety rules. Verifying that contractor safety requirements are c onsistent with requirements that Company XYZ Cadet has for its own associates when performing similar tasks. Having a questioning attitude and reporting at risk contractor actions. Suggesting new/revised contractor safety requirements based on ex perience and lessons learned. Preparing equipment so contractors can work on equipment safely and to monitor contractor activities.

PRE-STARTUP SAFETY REVIEW (PSSR) Associates participate in the pre-startup safety review element by: y y y

Participating in pre-start up reviews on ne w and/or modified processes and equipm ents. Ensuring that all departments concur that the equipment is fit for service and ready for startup. Having a questioning attitude, completing informal pre-startup safety reviews on their own, and initiating dialogue on identified concerns.

MECHANICAL INTEGRITY Associates participate in the mechanical integrity element by: y

y y y

Ensuring that maintenance associates are involved in developing and updating procedures that implement the safe work practice and mechanical integrity requirements of the BPSM program. Providing input for equipment history and recording observed data. Assisting in the development of i nspections, test and preventative maintenance plans f or equipment items. Performing maintenance and inspection/test task in accordance with defined schedules and procedures.

HOT WORK PERMIT (SAFE WORK PRACTICES) Associates participate in the hot work element by: y y y y

Assisting in developing the format and content of safe work practices and safety policies. Following safe work practice and policies and ensuring that others are doing the same. Suggesting revisions/additions and updates to safe work practices and policies as appropriate. Participating in the review of safe work practices procedures through involvement in safety meeting discussions and safety committees.

MANAGEMENT OF CHANGE Associates participate in the management of change element by: y

y y

Identifying changes where appropriate associated with job tasks and/or equipment and initiating management of change reviews. Assisting in reviews of proposed changes as appropriate. Receiving and understanding training/communication of changes, including changes to BPSM programs.

INCIDENT INVESTIGATION Associates participate in the incident investigation element by: y

Identifying and reporting incidents that occur and initiating investigations.

y y y

Identifying and reporting near-miss and process saf ety incidents that occur and initiating investigations. Participating as team members during investigations. Participating in discussions concerning the report findings during safety meetings.

EMERGENCY PLANNING AND RESPONSE Associates participate in the emergency planning and response element by: y y y

y y

Identifying and reporting emergency situations. Performing appropriate response actions in the event of an emergency and in emergency drills. Providing information to emergency planners about unique hazards, response, and evacuation issues in plant areas. Participating in emergency action plan and hazardous waste and emergency operations training. Participating in critiques as the result of drills and actual i ncidents to elicit comments and observations, identify learnings, identify opportunities for performance improvement and improve both emergency response planning and responder performance.

COMPLIANCE AUDITS Associates participate in the compliance audit element by: y y y y

Reviewing and commenting on audit protocols if needed. Participating as team members in audits, as applicable. Serving as interviewees as part of audits and providing information as necessary to support audits. Receiving and understanding the results of the audits and resolution of audit findings/observations.

TRADE SECRETS Associates participate in the trade secret element by: y

Observing the limitations of confidentiality agreements in the use of BPSM information

Authorization:

Plant Manager 

Date

Process Safety Coordinator 

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S/H/E Stewardship Manager 

Date