NT & SA, 8, INDIA EXCHANGE PLACE m BANK o f AMERICA CALCUTTA 700 001 |x | This refers to our preliminary teletrahshnission advice of this credit.

INTEROFFICE MEMORANDUM TO: WOODROW W

GALLAGHER BASSETT SERVICES, INC.

^Six Becker Farm Road Roseland, New Jersey 07068-1743 Telephone: (201) 740-9400 LIBERTY MUTUAL MAY 2. 1994 ATTN : MS.

DATE, FILENAME NOTE: This draft, dated 18 October 2013, prepared by Naval Sea Systems Command, has not been approved and is subject to modification.

DEPARTMENT OF THE NAVY NAVAL RESEARCH LABORATORY 4555 OVERLOOK AVE SW WASHINGTON DC 20375-5320 So. ^ C . y 3905 ?

UNION CARBIDE CORPORATION 3a old rogebury road, oanbury, ct oeei 7-0001 November 13,1992 Mr.

"V B[bv3lf 'S >C * rVo Is wv (AV* -- I O |<| *st C% ) wn > tr 0 0 0 0 w l> O \o CO XV o yi < i2!

, "PLACARDED" FLAMMABLE GAS DXCHLORIDE, CHLOROFORM, CARBON TETRACHLO RIDE), I D , UN 1184 "PLACARDED" FLAMMABLE L IQ U ID L , UN 1 8 2 4 , RQ PLACARDED CORROSIVE I3!

G E 0 R b I ft G l i L F,- E H ID l-5O4-6gW!

ABD00027762 CONDEA VISTA COMPANY CORPORATE SAFETY, HEALTH & ENVIRONMENT STANDARDS Subject: Issue Date: Supersedes: Approved By: Process Safetv Manaaement - Trainma March 22. 1996 Auaust 18. 1995 (Final Draft) Harrv D Garrison Manager Safety, Health & Environment 1 0 SCOPE This standard applies to CONDEA Vista Company facilities covered by OSHA Process Safety Management It addresses the training requirements specified in the OSHA Process Safety Management regulation 29 CFR 1910 119(g) which is specific to employee and contract operator training Training specified by 1910 119(j), Mechanical Integrity, 1910 119(1), Management of Change and 1910 119(h), Contractors are not addressed by this standard unless the facility uses contract operators in which case, this standard applies 2 0 PURPOSE This standard specifies the minimum requirements that each covered facility must incorporate into their local training standard for Process Safety Management The training required by this standard can be performed as part of training to meet other regulatory requirements, but the facility's training program documentation should specifically make note of that fact 3 0 PSM REQUIREMENTS SPECIFIC TO OPERATOR TRAINING 3 1 Initial Training Prior to beginning work or prior to assuming the duties of a new assignment in a covered process in a solo capacity (without direct supervision or assistance from a fully qualified and competent trainer or supervisor), operators must be initially trained and successfully complete the minimum training requirements specified by the operating procedures requirements of 1910 119(f) for their position Training must include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's job task PSM-006 Page 1 of 4 This Document is UNCONTROLLED unless one of the following appears Red Stamp stating "Controlled Document" or Blue "CONDEA Vista Controlled Copy" on the right of the page ABD00027763 CONDEA VISTA COMPANY CORPORATE SAFETY, HEALTH & ENVIRONMENT STANDARDS Subject: PSM-Training Issue Date: March 22, 1996 3 2 Refresher Training 321 Each facility must ensure that employees (CONDEA Vista and contractor) involved in operating a covered process understands and adheres to the current operating procedures of the process and must provide refresher training at least every three years, or more frequently if necessary 3 2 2 The appropriate frequency and scope of refresher training shall be determined through consultation between the facility management and the employees (CONDEA Vista and contractor) involved in operating the process Such determinations should be based on observed or reported deviations from standard operating procedures, recent incidents, incident investigation recommendations, apparent deficiencies in training, audits, etc A record of this consultation and the resulting determination shall be maintained indefinitely or until subsequent consultation/ determinations occur Each facility shall specify in their standard the job title(s) of the person(s) who will be responsible for maintaining this documentation 3 2 3 The time period for refresher training of an employee involved in operating a covered process is to be measured from the date of the employee's last training required by this standard or May 26, 1992 if "grandfathered" as permitted by 1910 119 (g)(1)(n), whichever is later 3 2 4 The content of the refresher training shall parallel that required for initial training such that it includes the following applicable to the employee's job task a specific safety and health hazards, b emergency operations including shutdown, PSM-006 Page 2 of 4 This Document is UNCONTROLLED unless one of the following appears Red Stamp stating "Controlled Document" or Blue "CONDEA Vista Controlled Copy" on the nght of the page ABD00027764 CONDEA VISTA COMPANY CORPORATE SAFETY, HEALTH & ENVIRONMENT STANDARDS Subject: PSM-Training Issue Date: March 22, 1996 c safe work practices, and d special emphasis on additions or changes to information or procedures made since the last initial or refresher training Note Refresher training is considered an independent training requirement in addition to other training requirements of the OSHA PSM standard, therefore, training under "Management of Change" does not normally satisfy the refresher training requirement of this standard unless the refresher training covers the entire procedure -- not just the change An example might be training provided following a new expansion or or process change where the training provided for the change parallels that one would receive for initial training When this occurs, it is strongly recommended that the training be documented as both - MOCA and Refresher or Initial training 4 0 DOCUMENTATION AND RECORDKEEPING 4 1 Each facility shall, through some affirmative means ascertain that each employee (CONDEA Vista and contractor) involved in operating a covered process has received and understood the training required under this standard This could include the administration of written tests, but may also include on-the-job demonstrations, or other methods as long as they are adequately documented 42 Documentation shall include 4 2 1 The identity of the employee (or contractor), 4 2 2 The date of training, 4 2 3 The means used to verify the employee understood training, 4 2 4 The identity of the person(s) conducting the training and/or administering the verification of understanding, 4 2 5 Results of testing, field demonstrations, etc PSM-006 Page 3 of 4 This Document is UNCONTROLLED unless one of the following appears Red Stamp stating "Controlled Document" or Blue "CONDEA Vista Controlled Copy" on the right of the page ABD00027765 CONDEA VISTA COMPANY CORPORATE SAFETY, HEALTH & ENVIRONMENT STANDARDS Subject: PSM-Training Issue Date: March 22, 1996 4 2 6 Copies of course outlines, field demonstration requirements, blank tests or checklists, etc as appropriate to evidence the content of the training and verification, and 4 2 7 Any other documentation deemed pertinent by the facility 4 3 Training records for items 4 2 1 through 4 2 5 above as a minimum shall be maintained in a data base for the term of the person's employment 4 4 Documents in items 4 2 6 and 4 2 7 above shall be retained not more than five years 4 4 Each facility shall develop a Training compliance document that a Defines the job positions of employees involved in the operation of the process that are subject to the training requirements of this standard b Describes the process that will be used to ensure that all training required by this standard occurs in the time frame(s) specified c Specifies who (by job title) will be responsible for various aspects of the training requirements including but not limited to maintenance of training records, advance notification that training is required, preparation of training materials, actual training, and verification of comprehension d Specifies where training records are located for inspection PSM-006 Page 4 of 4 This Document is UNCONTROLLED unless one of the following appears Red Stamp stating "Controlled Document" or Blue "CONDEA Vista Controlled Copy" on the right of the page

p 7EST-PAINE JgJ)OlltoUA INC., 7978 GSRI AVE.

EST-PAINE Jaboyzt&ueA inc. m AVE.

Louisiana Division Consolidated Assessment LOSS PREVENTION / FIRE PLANT: PQWEBJAUILITJESL____________ _______ BUILDING: 1801 _____________ REVIEW DATE & TIME: March 11, 1992 8:00 A.M.

SENT BY'-PATTON BOGGS, L.L.P. ;11- 5-96 ; 6:00PM ;rAJiOiN uuuua, L.ur.- 01/ OOO 0030# o/ O HAP TASK FORCE November 12, 1996 9:30 a.m, to 2:00 p.m.