Gulfstream Permitting

Jobs Covered Grassroots/Greenfield Construction Zones are new construction work areas over 35 feet from any existing live operating unit or in-service pipe systems. All work currently listed in your extended duration permit in the Gulfstream Work permitting process: For example some listed below: HW outside of 35 feet of an operating unit crane lifts with exception of critical lifts Piling, Building foundation, erecting steel, equipment setting, pipe erection, cable pull and instrument connection, insulating, painting and scaffolding building There still will be permits issued for other task such as Confined Space Entry, Energized Electrical work, Critical lifts and there will be fall prevention plans for critical elevated work DOW RESTRICTED

As Is Process JEP/JSA/JHA (Job Execution Plan/Job Safety Analysis) Start of job developed by contractor Reviewed/approved by Dow Extended duration Safe work permits (EDP) Issued by Contractors Poly 5 and LHC9 (Poly 5 for contractors other than PCL Dow issues) Issued by Dow retirees and contractors at LAO Poly B & D Issued at the start of each work week for general work Issued by Dow in LHC 9 within 35 feet of the operating unit Issued per craft per area and/or by company depending on location General foremen accepts for the crafts/company Daily work crew rosters issued STAs (Safety Task Analysis) Foreman led PTAs (Personal Task Analysis) – Fluor is not using PTAs JEP/JSA/JHA EDP (SWP) Daily Work Crew Roster STA PTA DOW RESTRICTED

As Is Process JEP/JSA/JHA EDP (SWP) STA PTA Daily Work Crew Roster DOW RESTRICTED

Proposed Process JEP STA JEP STA - Daily Created at the start of Job Contractor develops Project CSL (Construction Safety Leader) approves (same as today) Reviewed weekly by crews (led by General Foreman or Foreman) in the field and will be kept current STA - Daily Foremen will lead crew through the document Owner team conduct field audits on a daily basis 20 percent and all STAs will be audited weekly to verify task Identified and controlled (we need to ensure we have folks in the field and not just doing paper work). Purpose of these audits is to go out in the field and look at the jobs to compare what hazards are present and what safeguards have been implemented to address those hazards. Audit findings will be documented, analyzed for improvement in contractor performance or improving training material THE STA audits (focusing on excution) are to ensure it is in alignment with the JEP On site inspection by field safety techs every day for every job During onsite inspection or STA audits if it is identified that there has been a change in the JEP work  Dow Construction rep shall be consulted to let the JEP by corrected by the contractor ASAP  In case of a serious or life threatening event  The activity must be stopped by the observer/auditor And Construction Manager will be informed directly who must come to the spot and corrective measures will be taken  Need to be specific how we are going to handle the scope change/creep When the event has been mitigated Construction Management will be advised and the contractor will be required to develop a mitigation plan which will address the immediate issue and prevent reoccurrence. JEP STA DOW RESTRICTED

Pilot JEP STA DOW RESTRICTED

Next Steps Once approved by Sponsors We need to complete the required document changes and conduct MOC Pilot the process at LAO in January Depending on findings from Pilot make necessary changes Roll out to the rest of Gulf Stream once all MOCs are complete DOW RESTRICTED

Pilot Notes Time taken to issue permits: Cajun (old process) – 1 ½ hours a day Performance (new process) – 1st day – 45 minutes, rest of week time is spent performing JSA/STA with crew members Comments from workers in the field                 This is what we are used to for Greenfield projects                 Doing the JSA/STA with the crew is better since the workers do not have to do a PTAC                 Allows more interaction during JSA/STA with crew                 Workers bring up concerns and suggestions while performing the JSA/STA Performance (Project Manager) project they will be able to save 1 ½ hours a day for 12 people not having to do the daily crew roster (abbreviated permit). This equates to 18 hours a week that folks will have to be in the field to conduct job audits. First Day – POLY D project site walk begun at 5:30 AM.  Job Execution Permit issued by 6:20 AM prior to mass safety meeting.  Performance was able to have field walk complete, permit issued, mass safety meeting and workers going to filed by 6:45.  Monday mass safety meeting was well received and core job scope and hazards discussed.  Good accountability for employees.  Good process in place to capture those not in attendance on Monday. DOW RESTRICTED

Poly D Construction Permits & Paperwork the week of January 18th DOW RESTRICTED

Poly D Construction Permits & Paperwork the week of January 25th DOW RESTRICTED