4/1/20101 Contractor Management of Change: Implementation of Vehicle and Equipment Spotting Pre-Task Analysis Card Start Date: May 2010 Texas Operations Freeport Site Target Implementation by: June 30, 2010

4/1/20102 Why Implement “Spotting” Pre- Task Analysis Card? Early in the morning on Friday, March 19, a fatality occurred at Louisiana Operations in Plaquemine. A contract employee died as a result of injuries sustained while spotting a truck within the site. Fatality at Port of Freeport within the past year from a similar incident Industry continues to have spotting related incidents year after year Spotting is a classic Line of Fire risk

4/1/20103  Several serious events including fatalities throughout the industry continue to occur when a spotter and driver have a breakdown in communications.  To address this issue a pre-task analysis process will be utilized when the need for a spotter has been identified.  The intent is to provide a review of expected behaviors and to create a dialogue between the spotter and driver immediately before executing the task of spotting a vehicle or equipment.  Be sure to read the exemptions identified for the use of the PTA card and vest.  This requirement does not define when a spotter should or should not be used. Scope and/or Basis for Change:

4/1/20104 Summary of Most Significant Changes  Minimum responsibilities identified for Spotter and Driver roles.  Minimum requirements for the use of a Vehicle or Equipment Spotter Pre- Task Hazard Analysis card to be used when the task of spotting is performed.  Second level Supervisor approval required before continuing with spotting task if minimum expectations cannot be met.  Definitions and boundaries of requirements identified. See the training presentation for exceptions.  Minimum of 8 ’ distance required for Spotter to stay clear of the vehicle or equipment being spotted.  Spotter must be in the line of sight of the driver and out of the line of fire.  Training for workers that may spot vehicles or equipment

4/1/20105 “Spotting” Pre-Task Analysis (PTA) Card The PTA card drives the necessary communication between the driver and the spotter Provides a review of expected behaviors between driver and spotter immediately before executing the task Requires second level approval if one or more responsibilities cannot be met Spotter “owns” the card and the communications covered within it due to the potential exposure to a vehicle line of fire hazard

4/1/20106 Definitions (Spotter & Vehicle/Equipment) Spotter: A person, outside of the vehicle, who is interacting with the driver of a vehicle or equipment while it is in motion Persons directing the driver of a vehicle or equipment or walking as an escort while performing atmospheric monitoring into a classified area Vehicles and Equipment: Trucks with more than 6 wheels Mobile equipment such as hoisting rigs, cranes, excavation equipment, forklifts, etc. Any vehicle or equipment with a trailer attached

4/1/20107 When to use the Vehicle or Equipment Spotting PTA Card If a spotter for a vehicle or equipment is utilized, the following requirements apply unless exempted as defined in the next slide: –Complete a Pre-Task Hazard Assessment using the “Vehicle or Equipment Spotting Pre-Task Hazard Assessment” or a similar card that contains all of the requirements identified on the card.“Vehicle or Equipment Spotting Pre-Task Hazard Assessment” or –Wear high visibility vest or clothing

4/1/20108 Exemptions for use of the PTA Card and Vest Exemptions: Spotting activities where the Spotter and Driver do not have to fill out the “Vehicle or Equipment Spotting Pre-Task Hazard Assessment” card or wear the high visibility vest: –Exempt: Spotting activities related to movement of fixed framed vehicles including personal, company or contractor cars/trucks with 6 wheels or less and the spotter is in the clear line of site of the driver, maintains 8 foot clearance from the vehicle and is not in the line of fire of the vehicle. –Exempt: Emergency response vehicles during emergency response situations. Note: Some departments or job plans may have requirements that are more stringent than the exemptions. Make sure the specific requirements are understood by your employees when working within these areas.

4/1/20109 Role Specific Implementation Actions Dow Emergency Services & Security –Will hand out spotting PTA’s to truck drivers coming into the Site for delivery or pick up until a training video is in place –Give PTA’s to truck drivers of all escorted loads (ongoing) Dow Regional Truck Mode Leader –Communicate spotting PTA requirement to all Core Carriers for Dow arranged shipments, customer pick-ups and raw material suppliers –Incorporate spotting video into Site annual safety video and test required for truck drivers doing delivery and pick up

4/1/ Role Specific Implementation Actions “ Continued ” Contractor Safety Contacts –If you have routine procedures related to spotting vehicles or equipment then update them to include the use of the PTA card and it’s requirements. –Make PTA cards available to workers. –Purchase high visibility vest(s) for workers that will be involved in the spotter role –Observe jobsites to insure workers are implementing the spotter PTA card and requirements correctly.

4/1/ Walk Through The driver and the spotter must walk through the route prior to performing the task to assess the following: Can the distance of reversing the vehicle be eliminated or minimized? Yes No Describe actions taken: ___________________________________________ ___________________________________________ Are there any hazards along the route that would interfere with safe completion of the job? Yes No Describe actions taken: ___________________________________________ Can the route be modified to make the task safer? Yes No Describe actions taken: ___________________________________________ Can the route be cleared of workers (pedestrians) within 8 feet of the moving vehicle? Yes No If not, do not proceed and get supervisor’s approval? Describe actions taken: ___________________________________________ Vehicle or Equipment Spotting Pre-task Hazard Analysis Card Do It Safely or Don’t Do It! Common Hand Signals Move this direction Slow down! Stop !!! Straight forward or straight back! Move this direction Front of Card Back of Card Vehicle or Equipment Spotting PTA Card

4/1/ Inside of Card Vehicle or Equipment Spotting PTA Card IF any of the following agreed upon communication plan or individual’s responsibilities are not met, STOP IMMEDIATELY! Obtain Second level (Supervisor) approval if ANY of the responsibilities CANNOT be met! Communication Plan  Apart from verbal communication, the driver and the spotter must agree to communicate via one of the following:  Hand signals (consider high visibility gloves)  Two-Way Radios (if allowed)  Lights  Hand held Air Horn  Other:__________________  Note: Verbal only communication is not an acceptable method!  Consider having only the spotter, or only the vehicle, moving at one time in order to maintain visual contact Spotter’s Responsibilities As the SPOTTER on this job I WILL:  Position myself to enable the driver to maintain visual contact with me  Never cross the path of travel of a moving vehicle  Maintain a minimum 8 ft distance from moving vehicle  Wear a high visibility vest  Wear the PPE requirements for the area  Communicate to the driver to STOP immediately if I spot any unexpected hazards  Never ride on the vehicle while it is moving  Keep the route free of people that don’t need to be there I understand the communication plan and my responsibilities Spotter’s Name:______________________________ Date:__________ Driver’s Responsibilities As the DRIVER on this job I WILL:  STOP immediately if I lose visual contact with the spotter  STOP immediately if instructed by the spotter  STOP immediately if anyone comes within 8 ft of my vehicle  Operate the vehicle so my speed does not exceed the walking pace of the spotter  Communicate the blind spots of the vehicle to the spotter  Turn my radio and any other distractions off in the cab of my vehicle  Make sure my window's are open to receive spotter communications  Make sure my windows and mirrors are clear to ensure good visibility I understand the communication plan and my responsibilities Driver’s Name: _____________________________ Date:__________ Cards will be available through the departments you are working in..

4/1/ High Visibility Vest No required specifications for vest have been identified at this time other than it must be high visibility. Make sure if you perform spotting your workers have these available.