2.  Company with production plants in multiple countries with differing requirements  Agrium has high risk operations that require Emergency Response capability  Capability costs serious money  Money decision responsibility of site or regional management

3.  Two Industrial Pumpers up for replacement  Estimate 1 million plus range  This was just the current issue in a long list of future capital items for Emergency Response  Reluctance to commit because no standard in place that said you had to do it  The issue was stalled  Required a process to break the stalemate and manage the issue

4.  Response equipment competes for money against operations and other needs  People will make difficult choices if you make it easy for them to do so  Provide the decision maker with the supportive argument they need to make their boss agree  People usually are comfortable following; ▪ A standard ▪ Regulations ▪ Common practice of like industry

5.  Emergency Preparedness Element identifies specific requirements that must be followed E:\Emergency Preparedness EMS 3.12.01 Element.docx  Production plants are audited regularly to ensure compliance with the EP element  The Manufacturing Management System uses a specific format that employees are familiar with  Non compliance is reported to Senior Executive levels and the Board Of Directors

6.  Looked for tools already being used internally  Assessed them to see what would apply  Looked for a format that was;  Commonly used  Had weight/importance with management  Easily understood  Easy to explain and support

7.  Step 1 - Developed a background study that covered; E:\Agrium Wholesale Site Emergency Response Capability Study SCN 2010.docx E:\Agrium Wholesale Site Emergency Response Capability Study SCN 2010.docx  Primary risks that require large capacity pumps  Issues/limitations involved in exclusively relying on local fire departments  NFPA standards and recommendations  Regulatory standards and requirements  Staffing required to operate large capacity pumps

8.  Step 2 - Focused on Process Hazard Analysis  common tool used to determine industry risk  Engineering/managerial staff instantly recognize and trust the PHA process E:\ER Equipment Best Practice ver 14.docx E:\ER Equipment Best Practice ver 14.docx  Step 3 - Focused on Regulatory requirements  Allows quantification of risk  Hard to argue against regulations  Step 4 - Combined the PHA and Regulatory requirements into a “Best Practice” using the internal MMS format that people were familiar with

9.  Item 5.1 thru 6.4 specify the requirements of the Best Practice E:\ER Equipment Best Practice ver 14.docx E:\ER Equipment Best Practice ver 14.docx  A production plant must conduct a PHA and conform to the results if they have risks such as;  Chemical volumes over the threshold  If they have population densities over 5000 within 5 Kilometres

10.  If relying on local fire departments for primary emergency response capability you must verify their capability (6.0) E:\ER Equipment Best Practice ver 14.docxE:\ER Equipment Best Practice ver 14.docx  Pump capacity, response time, minimum crew, appropriate skill sets  Review must be done annually  Local General Manager must approve reliance on local fire department

11.  PHA must be conducted E:\ER Equipment Best Practice ver 14.docx E:\ER Equipment Best Practice ver 14.docx  When new production plant is being designed  Current pump capability reaches 20 year vintage  Table 1 chemicals added to site inventory  When Table 1 chemical volumes meet or exceed table thresholds

12.  Once process was approved;  Quickly gained approval for 2011 capital  Moved 2012 capital items forward  Executive levels want the system developed to cover off “other” ER requirements;  Rescue/Command, Medical, Haz Mat units  Fire water systems  Fire Halls  Training equipment  PPE

13.  Work required to build the process  Once in place it can be used again & again  Allows for calm rational discussion as the process is easy to follow and support  Senior Management comfortable with outcome  Eliminates the “bloody nose” when requesting funding