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Safety, Health & EnvironmentalManagement System

Manual

MANUAL #

Owner of Manual _____________________________(print name)

BOOK COPY





Safety, Health & EnvironmentalManagement System

Manual

MANUAL #

By placing my signature below, I am attesting to thefact that I have read and understand the contents of thismanual. I will abide by all rules and regulations set forth inthis manual to the best of my ability.

PRINT NAME ________________________________

SIGNATURE _________________________________

DATE ______________________________________

FILE COPY





Moreno Group LLC and Subsidiaries

Safety, Health & Environmental Management System

Table of Contents

SECTION A

Safety, Health & Environmental Policy Statement

Safety, Health & Environmental Policy Statement ............................................................. 1 of 1

SECTION B

Safety, Health & Environmental Responsibilities

Safety, Health & Environmental Responsibilities ............................................................... 1 of 6

SECTION C

Audits and Assessments Audits and Assessments .................................................................................................. 1 of 11

Safety, Health & Environmental Management System Change

Procedure ........................................................................................................................... 1 of 2

SECTION D

Contractor Safety, Health and Environmental Program

Contractor Safety, Health and Environmental Program ................................................... 1 of 13

SECTION E

Emergency Preparedness

Emergency Preparedness ................................................................................................ 1 of 19

SECTION F

Employee Participation

Employee Participation ....................................................................................................... 1 of 2

STOP Work Authority ......................................................................................................... 1 of 5

SECTION G

Hazard Control

Job Safety and Environmental Analysis ............................................................................ 1 of 9

SECTION H

Incident Reporting and Investigation

Incident Reporting / Medical Attention Procedure .............................................................. 1 of 7

Incident Investigation Procedure ...................................................................................... 1 of 11





Table of Contents (continued)

SECTION I

Occupational Health

Occupational Health Program ............................................................................................ 1 of 5

Abrasive Blasting .............................................................................................................. 1 of 12

Aluminum Protection ........................................................................................................ 1 of 10

Asbestos Abatement ........................................................................................................ 1 of 18

Back Injury Prevention ........................................................................................................ 1 of 3

Benzene .............................................................................................................................. 1 of 6

Bloodborne Pathogens ....................................................................................................... 1 of 9

Cadmium Protection ......................................................................................................... 1 of 15

Fitness to Work ................................................................................................................. 1 of 11

Hazard Communication Program ....................................................................................... 1 of 7Hearing Conservation ......................................................................................................... 1 of 5

Heat Stress Management ................................................................................................... 1 of 5

Hexuvalent Chromium Protection ..................................................................................... 1 of 19

Hydrogen Sulfide H2S ......................................................................................................... 1 of 8

Lead Protection ................................................................................................................ 1 of 14

NORM Program ................................................................................................................ 1 of 42

Respiratory Protection ...................................................................................................... 1 of 21

SECTION J

Safe Work Practices

Air Tugger ......................................................................................................................... 1 of 22

Barricading.......................................................................................................................... 1 of 3

Confined Space Entry ....................................................................................................... 1 of 20

Crane Policy ..................................................................................................................... 1 of 37

Electrical Safety ................................................................................................................ 1 of 17

Energy Isolation Procedure (Lockout / Tagout) ................................................................ 1 of 11

Excavation and Trenching Procedure .............................................................................. 1 of 15

Fall Protection ................................................................................................................... 1 of 15

Fire Prevention Plan ........................................................................................................... 1 of 7Forklift Program .................................................................................................................. 1 of 8

Line Opening ...................................................................................................................... 1 of 6

Permit To Work ................................................................................................................. 1 of 12

Personal Protective Equipment .......................................................................................... 1 of 7

Powered Work Platform Safety ........................................................................................ 1 of 10

Scaffolding ........................................................................................................................ 1 of 10

Vehicle Safety ..................................................................................................................... 1 of 6





Table of Contents (continued)

Waterfront Safety Procedure .............................................................................................. 1 of 5

Welding, Burning, Cutting and Hot Work .......................................................................... 1 of 13

SECTION K

Safety, Health and Environmental Meetings

Safety, Health and Environmental Meetings ...................................................................... 1 of 5

SECTION L

Safety, Health and Environmental Performance Review

Safety, Health and Environmental Performance Review ................................................... 1 of 5

SECTION M

SH&E Training

New Employee Orientation / Safety, Health & Environmental Training ............................. 1 of 5

Short Service Employee Program ...................................................................................... 1 of 6

Sub Part “O” Training Plan ................................................................................................. 1 of 9





MORENO GROUP LLC AND SUBSIDIARIES SAFETY,

HEALTH AND ENVIRONMENTAL POLICY STATEMENT

Moreno Group LLC and Subsidiaries policy is to manage all operations that

embrace Safety, Health and Environmental performance as a coreorganizational value.

Moreno Group LLC and Subsidiaries will promote our SH&E ManagementSystem through proactive activities, which promote the eliminating of injuries,while providing safeguards to promote employee health and to protect theenvironment from harm.

Moreno Group LLC and Subsidiaries will accomplish our core value throughthe following systems:

Establishing an Incident and Injury Culture where our culture believes all incidentsare preventable

Advise each manager, supervisor and employee of Safety, Health andEnvironmental requirements and hold them accountable for performance.

Design and manage operations to provide work places free of recognized safetyhazards and to minimize environmental and human health impacts.

Comply with all laws and regulations governing Safety, Health and Environmentalprotection.

Recognize the importance of Safety, Health and Environmental factors wherethere is competition with economic factors.

Provide professional staff to support Safety, Health and Environmental efforts.

Monitor, evaluate and report performance in Safety, Health and Environmentalprotection.

Provide training needed to protect Human, Environmental and physical resources.

Participate in industry programs designed to enhance knowledge, improve

technology, and maintain conformance with current laws and regulations.

Michel Moreno

CEOJanuary 2010





Moreno Group LLC andSubsidiaries SH&E

Management System

Safety, Health &Environmental (SH&E)

Responsibilities

Page: 1 of 6Original: 01/01/2003Revised: 01/01/2008

B1.1

Safety, Health & Environmental (SH&E) Responsibilities

Purpose

The purpose of this procedure is to clearly define duties, responsibilities and lines ofauthority for Moreno Group LLC and Subsidiaries Safety, Health & Environmental(SH&E) program.

Scope

This procedure applies to all departments and areas at the Moreno Group LLC andSubsidiaries facility or work-site. This procedure provides a broad overview of eachemployee’s duties and responsibilities for SH&E in the workplace.

Responsibilities

The CEO and President or Designee is responsible for:

Holding facility managers and their subordinates accountable for a high levelof SH&E performance.

Monitoring the SH&E performance of Moreno Group LLC and Subsidiaries.

Approving of any newly developed or revised program.

Continually communicate to management and First Line Supervision theemployees’ responsibility, ability and obligation to use their “STOP WORK

Authority” without reprimand.

The Moreno Group Executive SH&E Team is responsible for:

Leading the development of an SH&E Management System that isrelevant and appropriate to the Business Units while focusing on thewelfare of the individual

Communicating expectations for SH&E performance for our organization

and stakeholders

Visibly demonstrating our personal commitment to achieve an Injury andIncident Free (IIF) work environment and seeking the same level ofcommitment from the entire organization

Challenging and empowering the Business Units to make SH&E happenthrough personal relationships and teamwork



B1.2

Ensuring that we have the resources necessary to achieve World ClassSH&E performance

Monitoring the organization’s SH&E performance to ensure we aredelivering on our IIF commitments

Implementing timely mid-course corrections, if necessary

Identifying and benefiting from Lessons Learned from other organizations,and our Business Units

Acknowledging and celebrating group and individual accomplishments

Communication SH&E incidents to the Organization and otherstakeholders

Providing assistance and support to our Business Unit Teams

Quarterly, as an executive SH&E Team audit a Business Unit’s facility

Discuss, declare and expedite proper course of action for undecidedsystems, procedures, ideas and/or situations identified at Business UnitManagement Teams

The Facility Manager or Designee is responsible for:

The overall SH&E program and the performance results achieved.

Assigning resources for implementation of the SH&E program.

Holding managers, first line supervisors, offshore superintendents and sub-

contractors accountable for a high level of SH&E performance.

Monitoring, measuring and managing the SH&E performance.

Authorizing the expenditures for SH&E.

Approving Safety, Health and Environmental policies as formulated by theSH&E staff or others.

Actively participating in the SH&E program to show interest.

Maintain communication with the SH&E Department concerning our SH&Eperformance.

Setting the example for all employees

Continually communicate to First Line Supervision the emp loyees’responsibility and authority to “STOP WORK” without reprimand.



B1.3

Asking SH&E related questions of management and supervisory personnel,on a regular basis, to demonstrate the importance of safety to management.

Reviewing and/or investigating the causes of all reported incidents, accidentsand injuries and approving corrective actions.

Participating and monitoring the company Behavioral Safety Process.

The Supervisory Personnel or Designee is responsible for:

Periodically inspecting work areas and equipment for compliance with workrules and SH&E standards.

Instructing employees on the hazards of the job, how to work safely andaccording to operating procedures, applicable SH&E policies and applicableSH&E regulations.

Maintaining a safe and healthy workplace, ensuring good housekeeping,proper illumination and ventilation, and the use of personal protectiveequipment as required for each job.

Seeing that all injuries are promptly reported and properly treated.

Analyzing all process, operations and facilities for hazards and makingchanges or recommendations to eliminate or control hazards.

Investigating the causes of all reported incidents, accidents and injuries,

completing the necessary reports and initiating control action as required.

Conducting employee safety, health and environmental meetings, newemployee job specific orientations and job / task hazard analyses.

Making each employee aware that violation of established safety, health andenvironmental rules will result in disciplinary action.

Complimenting safe workers publicly and counseling unsafe workersprivately.

Participating in the company Behavioral Safety Process.

Setting the example for SH&E by complying with the safety rules andprocedures and displaying a positive attitude toward the safety program.

STOP WORK anytime any employee identifies or feels a condition or situationis unsafe or not environmentally sound.



B1.4

The Engineering Personnel or Designee is responsible for:

Incorporating required safety features into the design of all equipment andprojects.

Maintaining knowledge of applicable safety regulations and standards andincorporating these requirements into all designs.

Maintaining knowledge hazards or potential hazards within their areas ofresponsibility and taking action to eliminate or control these hazards.

Serving as a resource to the organization providing engineering expertise asrequired to improve overall SH&E program.

Developing safe operating and maintenance procedures and correspondingtraining programs for new or modified equipment or processes.

Assisting in employee training on new or modified equipment / systems asnecessary.

Participating in workplace hazard assessments.

Coordinating selection and oversight management of contractors.


Communicate and involve the SH&E Department in any new equipment or

design changes to ensure the appropriate SH&E procedures are developed,training is performed so these procedures can be implemented.

The SH&E Department or Designee is responsible for:

The Corporate SH&E Manager will be the SH&E Management System Administrator.

Serving in a staff capacity as a Safety, Health and Environmental (SH&E)resource to the organization.

Coordinating facility and site SH&E activities.



B1.5

Assisting with implementation of the SH&E program by.

- Conducting new employee orientation / SH&E training programs.

- Assisting supervisory personnel with Safety Meetings.

- Conducting workplace observations, audits and inspections.

- Assisting management and supervisory personnel during incidentinvestigations.

- Helping determine appropriate corrective actions resulting fromincident investigations, SH&E inspection or audits.

- Coaching supervisory personnel and employees when at-risk behavioris observed.

Coordinating the facility and site first aid, medical and industrial hygieneprograms.

Maintaining and analyzing incident reports, injury and illness statistical dataand results of SH&E audits / inspections or observations.

Coordinating educational activities on SH&E for all management, supervisorypersonnel and employees.

Conducting activities for stimulating and maintaining employee interest in the

SH&E program.

Serving on the safety, health and environmental committee (if applicable).

Reviewing and approving incident investigation reports.

Directing and monitoring a program of supervisory SH&E inspections andaudits.

Keeping informed on applicable governmental SH&E standards and codes.

Providing education, measurements, support and participation in theBehavioral Safety Process.

Maintain communication with Management concerning SH&E performanceand/or issues.



B1.6

The Employee is responsible for:

“STOP WORK” anytime a condition or situation is unsafe or notenvironmentally sound.

Performing only those jobs on which they have been trained and / orauthorized.

Working in accordance with safe job practices and complying with companyand client SH&E policies and procedures.

Using required Personal Protective Equipment.

Reporting unsafe conditions, practices or incidents immediately to supervisorypersonnel. Shutdown work activity for an SH&E concern.

Serving on the safety committee, if asked.


Participating and co-operating in the Work Group Incident InvestigationProcess.

Attending and actively participating in all safety, health and environmentalmeetings, workplace hazard assessments and job safety & environmentalanalysis development.




Management System

Audits and AssessmentsPage: 1 of 11Original: 01/01/2003Revised: 09/01/2009

C1.1

Audits and Assessments

Purpose

The purpose of Safety Inspections is to provide a consistent method of identifying andevaluating the workplace environment for safety, health and environmental hazards.

Scope

This procedure applies to all Safety, Health and Environmental Audits and Assessment activities for Moreno Group LLC and Subsidiaries. This policy applies toall employees and area of operation for Moreno Group LLC and Subsidiaries.

Responsibilities

The Facility / Site Manager or Designee is responsible for:

Overseeing this procedure and ensuring all requirements are met.

Auditing the audits for compliance with this procedure.

Appointing facility / site supervisors / designees to be responsible for safetyaudits, inspections and housekeeping activities.

The First Line Supervisor / Offshore Superintendent is responsible for:

Understanding and complying with this procedure.

Assuring employees follow good housekeeping practices.

Informing management of suggested improvements in housekeeping efforts.

Participating in and assuring safety audits, inspections and housekeepingactivities are conducted on a scheduled basis.

Developing a process to correct deficiencies discovered during safety audits,inspections and housekeeping activities.

The Safety, Health and Environmental Department is responsible for:

Training, or coordinating the training of managers, supervisors and hourlyemployees on conducting audits and assessments.

Periodically auditing the quality of supervisors' weekly assessments.



C1.2

Par ticipating in the reviewing and commenting on audit’s and assessment’sfindings and corrective actions.

Providing support and resources to Management, First Line Supervision andemployees.


Understanding and complying with the safety audits, inspections andhousekeeping requirements.

Conferring with supervision regarding any suggestions for improving thesafety audits, inspections and housekeeping efforts.

Actively participating in safety audits, inspections and housekeepingprograms.

Keeping their work areas clean.

Requirements

Management and the Safety, Health and Environmental Department shall conductmonthly a work-site inspection. This inspection shall be documented on the MorenoGroup LLC and Subsidiaries Hazard Assessment Checklist (see Attachment 1).Moreno Group LLC and Subsidiaries’ monthly Stormwater Pollution PreventionInspection will be included within this monthly inspection.

Work-site Inspections shall be conducted weekly by at least one or two hourlyemployees with their First Line Supervisor or Superintendent. The inspection shall

be documented on following checklists:

Moreno Group LLC and Subsidiaries Hazard Assessment Checklist(shop)(see Attachment 2)

Moreno Group LLC and Subsidiaries Offshore Weekly Hazard AssessmentChecklist (see Attachment 3)

Weekly Hazardous Waste, Paint, Solvent, Fuel and Oil Storage AreaInspection Checklist (see Attachment 4)

Prior to or upon receiving client’s equipment into Moreno Group LLC andSubsidiaries facility the following checklist shall be completed:

Refurbish Equipment Checklist (see Attachment 5)

Prior to performing any work activities that may disturb the paint on equipmentidentified as containing Lead Base Paint, the following checklist shall be completed:

Lead Job Safety Checklist (see Attachment 6)



C1.3

Periodically SH&E Department will visit Jobsites. During this visit the SH&Epersonnel will perform a project assessment using the Moreno Group LLC andSubsidiaries Jobsite Hazard Assessment Checklist. (See Attachment 7)

Prior to any Offshore Tool House being sent offshore, an Offshore Tool HouseChecklist will be completed. A copy of this checklist will be sent offshore so thereceiving superintendent can review the checklist. (See Attachment 8)

During long duration jobs, the offshore superintendent will periodically inspect theirOffshore Tool House utilizing the Offshore Tool House Checklist.

Any unsatisfactory conditions that the supervisor is unable to correct will require awork order to be issued. A copy of the signed and dated checklist along with any joborders shall be forwarded to the Safety, Health and Environmental Department.

Additional inspections shall be required under the following circumstances:

Whenever new substances, processes, procedures, or equipmentare introduced into the work place that represent a new

occupational safety and health hazard.

Whenever the supervisor is made aware of a new or previouslyunrecognized hazard.

As a part of an incident investigation.

Note: For equipment inspection requirements refer to specific program.

All inspections, findings and recommendations shall be communicated to theemployees at their Daily Safety Meeting.

Annually Safety, Health and Environmental Department and Managementwill conduct an audit of the Moreno Group LLC and Subsidiaries Safety,Health and Environment Management Systems.

At a minimum the following SH&E programs shall be evaluated during theannual audit:

Confined Space Entry Program

Energy Isolation Procedure (Lockout/Tagout)

Respiratory Protection Program

Stormwater Prevention Plan

All checklists shall be maintained for a minimum of 3 years





C1.4

Attachment 1





Moreno Group LLC and Subsidiaries Facility Monthly ManagementHazard Assessment Checklist

C1.4.a.1

Date:Time:

Location:

INSPECTION TEAM: Facility Manager (Leader)

Legend:Safe – Check Mark

No – XNA - NA

A EXIT AISLES AND PASSAGEWAYS(1)

Shop

(2)

Yard

(3)

Paint(4) (5) (6)

A1 Are exits & aisles unobstructed?A2 Are walkways free of welding leads, hoses, material,

etc.?

A3 Are walkways free of slipping hazards?

A4 Are open holes identified and barricaded with 3/8”wire rope?

A5 Are materials/equipment stored such that sharpobjects will not interfere with the walkway?

A7 Are scaffolding boards secured with number 9 wire?

A8 Is the scaffolding floor at least 18 inches in width?

REMARKS:

B HOUSEKEEPING(1)

Shop

(2)

Yard

(3)

Paint(4) (5) (6)

B1 Yard and shop clean and free of debris?

B2 Are areas free of material spills and are dip pansclean?

B3 Adequate room to maneuver mobile equipment?B4 Trash (metal and waste) cans empty regularly?

B5 All material stacked securely?

REMARKS:



C1.4.a.2

C FACILITY SIGNS(1)

Shop

(2)

Yard

(3)

Paint(4) (5) (6)

C1 Material Safety Data Sheets (MSDS) and indexaccessible for all on-site chemicals?

C2 “Units Start Automatically” warning signs present?

C3 All portable containers properly labeled?

C4 “Hearing Protection Required” signs present wherenoise exceeds 85 dBA?

C5 All chemical drums properly labeled with lidssecured?

REMARKS:

D FIRE PROTECTION (1)Shop

(2) Yard

(3)Paint

(4) (5) (6)

D1 Fire extinguisher inspection within last 30 days?

D2 Fire extinguishers fully charged with seal and tags inplace?

D3 Fire extinguishers in designated location?

D4 Fire extinguishers unobstructed and in goodcondition?

D5 No Smoking by the flammable liquid cabinet or Yardstorage / usage area?

D6Ignition sources 35 ft. away from Flammable liquid

cabinet?

D7 Flammable liquids stored in “Flammable LiquidsCabinet”?

D8 All containers within Flammable Liquid cabinet orYard storage area sealed and labeled?

D9 Flammable Liquid cabinet or Yard storage area cleanand orderly?

REMARKS:

E ELECTRICAL (1)

Shop

(2)

Yard

(3)

Paint(4) (5) (6)

E1 Are lights operational?

E2 Is the conduit in good condition and all wiring inconduit?



C1.4.a.3

E ELECTRICAL (continued) (1)

Shop

(2)

Yard

(3)

Paint(4) (5) (6)

E3 Are all electrical control panels labeled as to functionand voltage?

E4 Area in front of circuit breakers clear 36 inches?

E5 Are electrical outlets not overloaded?

E6 Are outlets in good condition?

E7 Are cords on electrical tools in good condition?

E8 All 3-prong extension cords in good condition? (i.e. notape, cuts, burns, etc.)

E9 Are ground fault circuit interrupters (GFCI) providedon all temporary electrical equipment?

E10 Are portable electrical tools and cords inspected andissued with proper color tag for the month?

REMARKS:

F WELDING EQUIPMENT (1)

Shop

(2)

Yard

(3)

Paint(4) (5) (6)

F1Compressed gas and oxygen cylinders stored inupright position with protective caps, properlysecured?

F2 Oxygen and fuel gas cylinders separated (5 ft.noncombustible barrier or 20 ft. separation)?

F3 Are cylinders kept away from heat sources or stairs?F4 Are all cylinders secured?

F5 Are empty cylinders marked “Empty”?

F6 Are anti-flashback valves installed on cutting torchesand regulators?

F7 Are welding leads completely insulated?

F8 Are welding leads and torch hoses in good condition?

F9 Are welding screens in good condition?

F10 Are combustible and flammable materials stored 35 ft.

away from hot work area?

REMARKS:



C1.4.a.4

G HAND AND POWER TOOLS(1)

Shop

(2)

Yard

(3)

Paint(4) (5) (6)

G1 Bench grinder and wire brush wheel appropriatelyguarded (1/4” tongue)?

G2 Space between tool rest and wheel 1/8”?

G3 “Face Shield and Eye Protection Required” sign

present at bench grinder?G4 Is the wheel secure?

G5 Are guards on portable grinders, wire brush, etc?

G6 Are handles on portable grinders?

G7 Are guards enclosing all rotating and movingequipment to prevent physical contact?

G8 Are portable fans provided with full guards or screenshaving opening ½ inch or less?

G9 Are pneumatic and hydraulic hoses on poweroperated tools in good operating condition? (i.e. nodeterioration or damage)

G10 Are pneumatic hose safely connected together withsafety pins or whip checks?

G11

Are hand tools in good condition? (i.e. mushroomedheads, broken or fractured handles, bent or wornwrenches, handles wedged tightly in head of tools,etc.)

G12 Are cutting tools edges sharp so tool will movesmoothly without binding or skipping?

G13 Are tools stored in dry, secure locations?

G14 Are employees using the proper tool for the job?

G15 Is there evidence employees are inspecting hand andpower tools prior to their use?

REMARKS:

H EMERGENCY RESPONSE (1)

Shop

(2)

Yard

(3)

Paint(4) (5) (6)

H1 Emergency Preparedness and Hazardous WasteContingency plans available?

H2 Emergency phone numbers available?

H3 Visitor access controlled?

H4 Are Smoke Detectors and Emergency Lighting locatedin offices operational?

Offices

REMARKS:



C1.4.a.5

I PERSONAL PROTECTIVE EQUIPMENT (1)

Shop

(2)

Yard

(3)

Paint(4) (5) (6)

I1 Employees wearing Hard Hats, Safety Glasses, ProperClothing and Steel Toed Boots?

I2 Employees wearing face shields when applicable?

I3 Employees wearing hearing protection when needed?

I4 All respirators sanitized and properly stored?

I5 Employees wearing respirators when applicable?

I6 Employees using fall protection properly?

I7 PPE locker well maintained and organized?

I8 Paint Yard Supply Air System checked for CO? ___________Reading

REMARKS:

J PORTABLE LADDERS

(1)

Shop

(2)

Yard

(3)

Paint (4) (5) (6)

J1 Ladder rungs clean and in good condition? (i.e. loose,corroded, bent, cracked or etc.)

J2Ladder hinges in good working condition? (i.e. loose,bent, broken or etc.)

J3 Ladder locking mechanism working properly?

J4 Ladder side rails/legs in good condition?

J5 Does ladder sit properly when the ladder is in place orextended?

J6 Ladder safety shoes in good condition and in place?

REMARKS:

K CHECKLISTS(1)

Shop

(2)

Yard

(3)

Paint(4) (5) (6)

K1 “Tailgate Safety Meeting” conducted daily?

K2 “Daily Forklift Checklist” completed daily?

K3

“Daily Cherry Picker / Web Sling Checklist” completed

daily?

K4 “Weekly Chain Inspection Form” completed?

K5 “Aerial Lift pre use Checklist completed?

REMARKS:



C1.4.a.6

L YARD MOBILE EQUIPMENT(1)

Shop

(2)

Yard

(3)

Paint(4) (5) (6)

L1 Are crane and forklift operators operating equipmentproperly?

L2 Are mobile equipment operators obeying the 5 mphspeed limit?

L3 Are employees operating Aerial Lifts properly?

L4 Are employees operating Aerial Lifts wearing properFall Protection?

REMARKS:

M SCAFFOLDING SAFEAT

RISKN/A

M1 Does the scaffolding have a toprail, midrail, and toe boardsprotecting all edges?

M2 Are the toprail, midrail and toe boards installed properly?

M3 Are swing gates provided on scaffolding?

M4If there is a potential to drop material and/or equipment from thescaffolding, is the area beneath and around the scaffoldingbarricaded with red “Danger” tape?

M5 Has the scaffolding been inspected by a competent person who hassigned and dated the yellow tag?

M6

Does the yellow tag indicate 100% tie off/fall protection required or

indicated any other hazards associated with the scaffold (i.e.missing midrail, etc.) identified?

M7 Does the ladder extend 3 feet past the scaffolding landing? If not, isit identified on the scaffold tag as a hazard?

REMARKS:



C1.4.a.7

Environmental

EA STORMWATER DRAINAGE SYSTEM SAFEAT

RISKN/A

EA1 Is there accumulated sediment or debris in ditches, storm sewers orinlets?

EA2 Are potential pollutants stored or used nearby?

EA3 Is there evidence of pollution in or near stormwater drainagestructures?

REMARKS:

EB USED OIL / DIESEL STORAGE SAFEAT

RISKN/A

EB1 Is the Used Oil / Diesel storage tanks leaking?EB2 Are containers of used oil / diesel piled up around the tank?

EB3 Is there evidence of spills or leaks?

EB4 Is the tank clearly labeled “Used Oil”?

EB5Is the tank and its secondary containment clear of accumulatedliquids and debris?

EB6 Is the secondary containment in good condition?

EB7Is there evidence of overflow of pollutants from secondarycontainment onto the ground?

REMARKS:

EC HAZARDOUS WASTE STORAGE SAFEAT

RISKN/A

EC1 This area is inspected weekly. Check that inspections are beingdone and review the inspection forms.

REMARKS:



C1.4.a.8

ED DRUMMED PRODUCT DISPENSERS

(solvent dispenser, oil dispenser bank) SAFE

ATRISK

N/A

ED1 Is each drum clearly labeled?

ED2 Are drums stored off the ground?

ED3 Is there evidence of spills or leaks?

ED4 Are drip pans and or secondary containment clean and in goodcondition?

ED5 Are pumps or dispensing valves clean and not leaking?

ED6 Are tops of drums, drip pans and secondary containment free oftrash and debris?

ED7 Is the spill kit complete and in good condition?

REMARKS:

EE OPEN-TOP TRASH CONTAINERS SAFEAT

RISKN/A

EE1 Is there evidence of leakage of pollutants onto the surroundingground?

EE2 Is there trash on the ground around the containers?

REMARKS:

EF SOLVENT RECOVERY UNIT SAFEAT

RISKN/A

EF1 Are containers of used paints and solvents kept closed untilprocessing?

EF2 Is there evidence of spills or leaks?

EF3 Is the area kept neat and free of trash and debris?

EF4 Are waste paint solids not on the ground?

EF5

Is the satellite accumulation area drum clearly marked “Hazardous

Waste Paint Solids”?

EF6 Is the satellite accumulation area drum kept covered when not inuse?

EF7Is there more than one drum of hazardous waste in the satelliteaccumulation area? If so is it dated and no more than three daysfrom when it was filled and dated?

REMARKS:



C1.4.a.9

EG OUTDOOR PAINT AND SOLVENT STORAGE SAFEAT

RISKN/A

EG1 Are product containers in contact with the ground?

EG2 Is there evidence of spills or leaks?

EG3 Is there accumulated trash or debris?

EG4 Are paints and solvents stored away from drainage ways and

surface waters or otherwise isolated from them?EG5 Are there walkways for easy access to containers?

EG6 Is the area clean and neat?

EG7 Are containers tightly sealed?

EG8 Is there an over-accumulation of used paint, thinners and cleaningsolvents waiting for recycling?

EG9 Are used paint, thinner and cleaning solvents waiting to be recycledkept in tightly sealed and clearly labeled containers in a centralizedlocation?

REMARKS:

EH PAINT AND SOLVENT STORAGE TRAILER SAFEAT

RISKN/A

EH1 Is there evidence of spilled materials?

EH2 Is the trailer and surrounding area neat and free of trash anddebris?

EH3 Is the paint stored in a neat and orderly manner and out of trafficareas?

EH4 Are there unlabeled or clearly outdated products which should bedisposed or recycled?

EH5 Is the loading/unloading area clean and fully accessible?

REMARKS:

EI OUTDOOR FABRICATION AND REFURBISHING

AREAS SAFE

ATRISK

N/A

EI1 Are there concentrated accumulations of waste from metal grindingor welding activities on the ground?

EI2 Are there open liquids containers?

EI3 Is there trash or debris accumulation?

EI4 Are spent abrasives washing into the drainage network?



C1.4.a.10

EI OUTDOOR FABRICATION AND REFURBISHING

AREAS (continued) SAFE

ATRISK

N/A

EI5 Are there unmarked containers, product or waste?

EI6 Are materials containers in contact with the ground and subject tocorrosion?

EI7 Is paint being mixed outside of the designated paint mixing area?

EI8 Are cleaning solvents being used outside of the designated paintequipment cleaning area?

REMARKS:

EJ STRUCTURAL STEEL AND FABRICATED

STRUCTURE STORAGE AREAS

SAFEAT

RISKN/A

EJ1 Are storage areas neat and free of trash and debris?

EJ2 Is there evidence of spills or leaks?

EJ3 Is there evidence of concentrations of welding or grinding waste onthe ground?

REMARKS:

EK FABRICATION SHOP SAFEAT

RISKN/A

EK1 Is there evidence of spills, leaks, welding waste, floor sweepings,grinding waste, etc. on the ground surrounding the shop?

REMARKS:



C1.5

Attachment 2





Moreno Group LLC and Subsidiaries Facility Weekly HazardAssessment Checklist

C1.5.a.1

A EXIT AISLES AND PASSAGEWAYS SAFEAT

RISKN/A

A1 Are exits & aisles unobstructed?

A2 Are walkways free of welding leads, hoses, material, etc.?


A4 Are doors operating properly?

A5 Are open holes identified and barricaded with 3/8” wire rope?

A6 Are materials/equipment stored such that sharp objects will notinterfere with the walkway?

A7 Are scaffolding boards secured with number 9 wire?

A8 Is the scaffolding floor at least 18 inches in width?

REMARKS:

B HOUSEKEEPING SAFEAT

RISKN/A

B1 Yard and shop clean and free of debris?

B2 Are areas free of material spills and are dip pans clean?

B3 Adequate room to maneuver mobile equipment?

B4 Trash (metal and waste) cans dumped regularly?


REMARKS:

INSPECTION TEAM: Supervisor (Leader)

Date:

Time:

Location:



C1.5.a.2

C HAZARD COMMUNICATION SAFEAT

RISKN/A

C1 Material Safety Data Sheets (MSDS) and index accessible for allon-site chemicals?

C2 All portable containers properly labeled?

C3 All chemical drums properly labeled with lids secured?

REMARKS:

D FIRE PROTECTION SAFEAT

RISKN/A

D1 Fire extinguisher inspection within last 30 days?

D2 Fire extinguishers fully charged with seal and tags in place?

D3 Fire extinguishers in designated location?

D4 Fire extinguishers unobstructed and in good condition?

D5 No Smoking by the flammable liquid cabinet or paint storage /usage area?

D6 Ignition sources 35 ft. away from Flammable liquid cabinet?

D7 Flammable liquids stored in “Flammable Liquids Cabinet”?

D8 All containers within Flammable Liquid cabinet or paint storage areasealed and labeled?

D9 Flammable Liquid cabinet or paint storage area clean and orderly?

REMARKS:

E ELECTRICAL SAFEAT

RISKN/A

E1 Are lights operational?

E2 Is the conduit in good condition and all wiring in conduit?

E3 Are all electrical control panels labeled as to function and voltage?

E4 Area in front of circuit breakers clear 36 inches?

E5 Are electrical outlets not overloaded?

E6 Are outlets in good condition?E7 Are cords on electrical tools in good condition?

E8 Are all 3-prong extension cords in good condition? (i.e. no tape,cuts, burns, etc.)

E9 Are ground fault circuit interrupters (GFCI) provided on alltemporary electrical equipment?

E10 Are portable electrical tools and cords inspected and issued withproper color tag for the month?



C1.5.a.3

REMARKS:

F WELDING EQUIPMENT SAFEAT

RISKN/A

F1 Compressed gas and oxygen cylinders stored in upright positionwith protective caps, properly secured?

F2 Oxygen and fuel gas cylinders separated (5 ft. noncombustiblebarrier or 20 ft. separation)?

F3 Are cylinders kept away from heat sources or stairs?

F4 Are all cylinders secured?

F5 Are empty cylinders marked “Empty”?

F6 Are anti-flashback valves installed on cutting torches andregulators?

F7 Are welding leads completely insulated?F8 Are welding leads and torch hoses in good condition?


F10 Are combustible and flammable materials stored 35 ft. away fromhot work area?

REMARKS:

G HAND AND POWER TOOLS SAFEAT

RISKN/A

G1 Bench grinder and wire brush wheel appropriately guarded (1/4”tongue)?

G2 Space between tool rest and wheel 1/8”?

G3 “Face Shield and Eye Protection Required” sign present at benchgrinder?

G4 Is the wheel secure?

G5 Are guards on portable grinders, wire brush, etc?


G7 Are guards enclosing all rotating and moving equipment to preventphysical contact?

G8 Are portable fans provided with full guards or screens havingopening ½ inch or less?



C1.5.a.4


RISKN/A

G9 Are pneumatic and hydraulic hoses on power operated tools ingood operating condition? (i.e. no deterioration or damage)

G10 Are pneumatic hose safely connected together with safety pins orwhip checks?

G11 Are hand tools in good condition? (i.e. mushroomed heads, brokenor fractured handles, bent or worn wrenches, handles wedgedtightly in head of tools, etc.)

G12 Are cutting tools edges sharp so tool will move smoothly withoutbinding or skipping?



G15 Is there evidence employees are inspecting hand and power toolsprior to their use?

REMARKS:

H PERSONAL PROTECTIVE EQUIPMENT SAFEAT

RISKN/A

H1 Employees wearing Hard Hats, Safety Glasses, Proper Clothingand Steel Toed Boots?

H2 Employees wearing face shields when applicable?

H3Employees wearing hearing protection when needed?H4 All respirators sanitized and properly stored?

H5 Employees wearing respirators when applicable?

H6 Employees using fall protection properly?

H7 PPE locker well maintained and organized?

REMARKS:



C1.5.a.5

I PORTABLE LADDERS SAFEAT

RISKN/A

I1 Ladder rungs clean and in good condition? (i.e. loose, corroded,bent, cracked or etc.)

I2Ladder hinges in good working condition? (i.e. loose, bent, brokenor etc.)

I3 Ladder locking mechanism working properly?I4 Ladder side rails/legs in good condition?

I5 Does ladder sit properly when the ladder is in place or extended?

I6 Ladder safety shoes in good condition and in place?

REMARKS:

REMARKS:

K SCAFFOLDING SAFEAT

RISKN/A

K1 Does the scaffolding have a toprail, midrail, and toe boardsprotecting all edges?

K2 Are the toprail, midrail and toe boards installed properly?

K3 Are swing gates provided on scaffolding?

K4If there is a potential to drop material and/or equipment from thescaffolding, is the area beneath and around the scaffoldingbarricaded with red “Danger” tape?

K5

Has the scaffolding been inspected by a competent person who

has signed and dated the yellow tag?

K6Does the yellow tag indicate 100% tie off/fall protection required orindicated any other hazards associated with the scaffold (i.e.missing midrail, etc.) identified?

K7 Does the ladder extend 3 feet past the scaffolding landing? If not, isit identified on the scaffold tag as a hazard?

REMARKS:

J YARD MOBILE EQUIPMENT SAFEAT

RISK

N/A

J1 Are crane and forklift operators operating equipment properly?

J2 Are mobile equipment operators obeying the 5 mph speed limit?

J3 Are employees operating Aerial Lifts properly?

J4 Are employees operating Aerial Lifts wearing proper FallProtection?



C1.5.a.6

L SLINGS (Wire, Chain and Nylon) SAFE AT RISK N/A

L1 Is the identification tag attached to sling? RFSI

L2 Are there 10 randomly broken wires in one rope lay? RFSI

L3 Are there 5 broken wires in one strand in one lay? RFSI

L4 Is there wearing or scraping of original diameter of outside wire? RFSI

L5 Is there kinking, gouging, bird caging or other damage? RFSI

L6 Is there evidence of corrosion or heat damage? RFSI

L7 Are there end attachments that are cracked or deformed? RFSI

L8 Is the hook cracked? RFSI

L9Has the hook been opened more than 15% of normal throatopening measured at the narrowest point?

RFSI

L10Is the hook twisted more than 10 degrees from the plane of theunbent hook?

RFSI

L11 Are safety latches in good condition? RFSI

L12 Is there evidence of melting or charring of any of the sling surface? RFSI

L13 Is there evidence of acid, caustic or heat burns? RFSI

L14 Is there evidence of snags, punctures, tears, cuts or fraying? RFSI

L15 Is the RED stitch showing? RFSI

L16 Are rigging chains of Alloy Grade Lifting Chain RFSI

L17 Are all rigging hardware Crosby or equivalent? (i.e. hooks, padeSafe, etc.) If no, take out of service and replace with Crosby orequivalent.

RFSI

L18 Are slings stored in designated location?

L19 Are taglines returned to designated location?

L20 Are there taglines available at the designated location?

REMARKS: Note: "RFSI" - Remove From Service Immediately



C1.5.a.7

M CHAIN SLING INSPECTIONMinimum Allowable Chain Size at Any Point of Link

(Circle size of chain being inspected)

Chainsize,

inches

Minimumallowable

chain size,inches

Serial No.

Serial No.

Serial No.

___________ ___________ ___________

___

Serial No.

Serial No.

Serial No.

___________

___________

___________

______

¼ 1364

3/8 1964

½ 2564

5/8 3164

¾ 1932

OKREMOVE FROM

SERVICE

7/8 4 564

1 1316

1 1/829

32 1 ¼

1 3/8 1332

1 ½1631

1 3/4 11332

Inspection of Crane and Sling Hooks SAFE AT RISK

M2 Is hook cracked?

M3 Has the hook been opened more than 15% of the normal

throat opening measured at the narrowest point?M4 Has the hook been twisted more than 10 degrees from

the plane of the unbent hook?

M5 Is the safety latch in working condition?

M6 Are load and retain points secure?

M7 Is the chain corroded?





C1.6

Attachment 3





C1.6.a.1

Moreno Group LLC and Subsidiaries Jobsite WeeklyHazard Assessment Checklist

Date:

Time:

Superintendent:

Location:

INSPECTION TEAM:


RISKN/A

A1 Are work area exits & aisles unobstructed?

A2 Are walkways free of welding leads, hoses, material, etc.?


A4Materials/equipment stored such that sharp objects will notinterfere with the walkway?

A5 Are open holes identified and barricaded with 3/8” wire rope andhurricane fencing?

A6 Are barricades properly used?

A7 Are material storage areas barricaded by caution tape or othermeans?

REMARKS:


RISKN/A

B1 Are work areas clean and free of debris?

B2 Are work areas free of material spills and are dip pans clean?

B3 Adequate room to maneuver?

B4 Trash (metal and waste) cans dumped regularly?


REMARKS:



C1.6.a.2

C FIRE PROTECTION SAFEAT

RISKN/A

C1 Fire extinguisher inspection within last 30 days?

C2 Fire extinguishers fully charged with seal and tags in place?

C3 Fire extinguishers in designated location?

C4 Fire extinguishers unobstructed and in good condition?

C5 Ignition sources 35 ft. away from Flammable Materials?

C6Is there a trained fire watch designated during all Hot work activitiesand is there the appropriate number of fire watch (i.e. On each level,etc.)?

C7Is there a continuous gas detection meter calibrated and being usedby the fire watch?

C8 Does the fire watch remain on site 30 minutes after hot work is shutdown?

C9

Is platform shut-in at the SSV, if welding or burning is performedwithin 10’ of well bay or production area? If not, is the operator’sMMS Approved Welding and Burning Plan being followed? If not,Shut Down Hot Work!!!

C10 Are equipment containing hydrocarbon or flammable substancesrelocated 35’ horizontally from work area? If relocation isimpractical, is equipment shielded?

C11

Are equipment containing hydrocarbon or flammable substances atlower levels where slag sparks could fall, relocated 35’ horizontallyfrom point of impact? If relocation is impractical, is equipmentshielded?

REMARKS:

D LOCKOUT / TAGOUT SAFE

D1 Is a group lockout / tagout box provided in the toolhouse?

D2 Does the box contain adequate amount of Supervisor locks(S Series)?

D3 Does the box contain adequate employee locks for the size of crew (ESeries)?

D4 Are “DO NOT OPERATE” tagout tags provided in the group lock box?

D5 Are lockout / tagout procedures being followed per DII procedure?

REMARKS:



C1.6.a.3

E ELECTRICAL SAFEAT

RISKN/A

E1 All 3-prong extension cords in good condition? (i.e. no tape, cuts,burns, etc.)


E3 Cords on electrical tools in good condition?

REMARKS:

F WELDING EQUIPMENT SAFE ATRISK

N/A

F1 Compressed gas and oxygen cylinders stored in upright positionwith protective caps, properly secured?

F2 Oxygen and fuel gas cylinders separated (5 ft. noncombustible

barrier or 20 ft. separation)?F3 Cylinders kept away from heat sources or stairs?

F4 Empty cylinders marked “Empty”?

F5 Are anti-flashback valves installed on cutting torches andregulators?

F6 Are welding machines ESD’s identified?

F7 Welding leads completely insulated?

F8 Welding leads and torch hoses in good condition?


F10 Are welding machine frames grounded to platform if placed onwooden decks?

F11Is welding machine attached to the platform ESD system? If Safe,has the nut in the Versa Valve been removed?

F12 Is welding machines skid pan clean and plugged?

REMARKS:



C1.6.a.4


RISKN/A

G1 Are guards on portable grinders?


G3 Are guards enclosing all rotating and moving equipment toprevent physical contact?

G4 Are pneumatic and hydraulic hoses on power operated tools in

good operating condition? (i.e. no deterioration or damage)

G5 Are pneumatic hose safely connected together with safety pinsand whip checks?

G6 Are hand tools in good condition? (i.e. mushroomed heads,broken or fractured handles, bent or worn wrenches, handleswedged tightly in head of tools, etc.)

G7 Are cutting tools edges sharp so tool will move smoothly withoutbinding or skipping?



G10 Is there evidence employees are inspecting hand and power toolsprior to their use?

REMARKS:


RISKN/A

H1 Are employees wearing Hard Hats, Safety Glasses, Proper

Clothing and Steel Toed Boots? (i.e. clear safety glasses at night)

H2 Are employees wearing face shields when applicable (i.e. grinding,burning, welding, and buffing operations)?

H3 Are employees wearing hearing protection when needed?

H4 All respirators sanitized and properly stored?

H5 Are employees wearing respirators when applicable?

H6 Are employees using fall protection properly (i.e. anchor devices,100% tied off, etc.)?

H7 Are employees using hand protection?

H8 Is the PPE provided in tool house well maintained and organized?

H9 Are the employees inspecting their PPE?

H10Is there a Fall Protection Rescue System on location and is thelocation of the Rescue System identified on the JSEA? (If workingat elevated elevations or over the side, etc.)

H11 Are the Fall Protection Yo-Yo certifications current?

H12 Are only engineered horizontal life-lines used and is thereadequate clearance between lifeline and lower level?

H13 Are welders wearing Hard Hats while welding?



C1.6.a.5

REMARKS:

I PORTABLE LADDERS SAFE ATRISK

N/A



I3 Ladder locking mechanism working properly?

I4 Ladder side rails/legs in good condition?

I5 Does ladder sit properly when the ladder is in place or extended?

I6 Ladder safety shoes in good condition and in place?

I7 Are ladders secured to structure at top when in use?

REMARKS:

J RIGGING EQUIPMENT SAFEAT

RISKN/A

J1 Are Crosby or equivalent rigging hardware (i.e. shackles, hooks,etc.) provided? (i.e. Stamped or embossed Safe Working Load andManufacturer)

J2 Is the tool house pre-slung? Is sling tagged and in good condition?

J3

Are chain or wire rope slings being used tagged and meets API RP2d requirements? (i.e. kinking, broken wires, distortion, heatdamage, dent hooks, bad end attachments, metal corrosion ormetal loss)

J4 Are chain slings - Alloy Grade 80?

J5

Are nylon slings being used tagged and meets API RP 2drequirements? (acid or caustic burns, melting or charring, holes,tears, cuts, snags, broken or worn stitches, excessive abrasion orknots)

J6 Is air tugger in good condition? Is a manufacture eye provided?

J7 Does the crane operator have their certification on them?

J8 Do the riggers have their cards on them or does the superintendenthave their training documentation on location?

J9 Are taglines being used on all lifts? If so, are enough taglines beingused on the load?



C1.6.a.6

REMARKS: (IF At-Risk – Remove From Service Immediately)

K PAINTING / BLASTING JOBS SAFEAT

RISKN/A

K1 Are employees mixing paint wearing proper PPE (Long sleeves, Apron, Safety Glasses, Faceshield, Rubber Gloves, and ½ maskOV Respirator)?

K2 Are employees wearing proper PPE during painting operations(Long sleeves, safety glasses, supplied air respirator / hood andgloves?

K3 Are employees wearing proper PPE during blasting operations(Long sleeves, safety glasses, supplied air respirator / hood,hearing protection and gloves)?

K4 Are all ½ mask OV respirators provided by Moreno Group LLC andSubsidiaries (3M 5000 series with OV cartridge and pre-filter)?

K5 Are employees utilizing Blasthoods or Paint Hoods during spraypainting operations? (Employees may only utilize ½ mask OVrespirators with Project Managers or designees approval)

K6 Are all employees who wear respirators clean shaven?

K7 Is paint being mixed in drip pans?

K8 Is waste paint being poured into properly labeled waste drums?

K9 Do all paint cans, solvent cans and waste drums have covers inplace when not being emptied or filled?

K10 Is there evidence that equipment is being inspected? (Verifycondition of equipment)

K11 Are dead man controls operational on all blast hoses?K12 Are On/Off safety valves on air line hoses and are they in arms

reach of blast nozzle?

K13 Are On/Off safety valves turned off when blast nozzle is not inuse?

K14 Are pressure gauges on paint pots in good condition and readable(i.e. not covered with paint)?

K15 Is the cable on the air spider in good condition (manufactured eye,no broken wires, no arching)?

K16 Is the air spider frame in good condition? (i.e. not bent, etc.)

K17

Are air spiders being utilized properly (proper tie-off, proper anchor

point for spider and employee)?

K18 Is the air spider oil level within the oil lubricator adequate?

K19 Is the correct transfer cable being utilized on all spiders withcertification tag (i.e. transfer chain, certified transfer cable)?

K20 Are air compressors equipped with carbon monoxide sensors andproviding Grade D breathing air?

K21 Are CO2 monitor certification papers onsite and calibration recordsup to date?

K22 Are employees utilizing LOTO when needed?



C1.6.a.7

REMARKS:

L PAPERWORK SAFEAT

RISKN/A

L1 “SH&E Meeting” conducted daily? Is the Meeting content good?

L2 Has the crew been issued a work/hot work permit and is it current?

L3Is the Behavioral Safety Observation process being used? If so,are the cards being discussed in the SH&E Meeting and is theparticipation at an appropriate level?

L4 Did the Superintendent complete the “Short Service EmployeeMentor Form”?

L5 Are Short Service Employees identified with a SSE sticker on hardhats?

L6 Is the Short Service Employee’s Mentor providing them direction?

L7 Is the “Offshore Tool House Checklist” being used?

L8Verify condition of Offshore Tools House (i.e. neat, orderly, toolstagged out, etc.)?

L9 Is Crane Operator performing and documenting a daily craneinspection?

L10Does the Superintendent have the correct Moreno Group LLC andSubsidiaries Paperwork (i.e. incident reports, SH&E Meeting, WorkGroup Investigation, SH&E Training)

L11 Is the crew performing Weekly Hazard Assessments of their workarea?

L12 Is the Fitness for Duty Certificate / Medical Questionnaire beingcompleted at the first SH&E meeting?

REMARKS:



C1.6.a.8


RISKN/A

M1 Does the scaffolding have a toprail, midrail, and toe boardsprotecting all edges?


M3If there is a potential to drop material and/or equipment from thescaffolding, is the area beneath and around the scaffolding

barricaded with red “Danger” tape?

M4 Has the scaffolding been inspected by a competent person whohas signed and dated the yellow tag?

M5Does the yellow tag indicate 100% tie off/fall protection required orindicated any other hazards associated with the scaffold (i.e.missing midrail, etc.) identified?

M6 Does the ladder extend 3 feet past the scaffolding landing? If not,is it identified on the scaffold tag as a hazard?

REMARKS:

N TEAM WORK OF THE CREW SAFEAT

RISKN/A

N1 Is the crew members working together?

N2Is the crew members communicating to each other concerning jobtask, hazards, etc.?

N3 Is the crew providing proper communication to crane operator?

N4 Is the crew following the JSEA?

N5 Are the crews following all applicable Safe Work Practices (i.e.Lockout/Tagout, Line Opening, Crane Operations, Fall Protection,etc.)?

N6 Are the crews utilizing containment pan while opening processlines? If so, is the containment pan grounded and/or bonded to theprocess line?

N7While the employees are working, are they aware of theirsurroundings (i.e. pinch points, employees working next to them,etc.)?

REMARKS:



C1.7

Attachment 4





WEEKLY HAZARDOUS WASTE, PAINT, SOLVENT, FUEL & OILSTORAGE AREA INSPECTION CHECKLIST

C1.7.a.1

Date:

Time:

Location:


* If SAFE, provide location, remedial action taken and date of action in REMARKS.** If NO, document in REMARKS.

AHAZARDOUS WASTE CONTAINERS

STORAGE AREA CONTAINMENTSAFE

ATRISK

N/A

A1 Cracks or gaps in walls or base of containment area?

A2 Cracks or gaps in walls or base of containment area?

REMARKS:

B HAZARDOUS WASTE STORAGE AREA SAFE ATRISK

N/A

B1 Are hazardous waste containers properly marked and dated?

B2 Is each container ID readable easily from access area?

B3 Are dates of storage on any haz-waste containers 75 days fromtoday? (If SAFE, notify responsible person to arrange for containersremoval from facility.)

B4 Are the hazardous waste containers in good condition?

B5 Are access areas unobstructed and free of debris?

B6 Are all containers holding haz-waste closed and relief valves inplace?

REMARKS:



C1.7.a.2

C HAZARDOUS WASTE SATELLINE

ACCUMULATION AREA SAFE

ATRISK

N/A

C1 Is hazardous wash container properly marked?

C2 Is hazardous waste container in good condition?

C3 Is haz waste container closed except when adding waste?

C4If haz waste over 55 gallons, has overage container been marked

with date excess began accumulating?

C5 (If SAFE, container must be removed within 3 days of date on

container)

REMARKS:

D PAINT AND SOLVENT STORAGE AREA SAFE AT

RISKN/A

D1 Any evidence of leaking on base beneath containers? D2 Any spills or leaks evident on base beneath containers?

D3 All empty paint/solvent containers removed from storage area?

D4 If SAFE, were they removed during inspection?

D5 All paint/thinner/solvent containers properly capped?

D6 If SAFE, were they capped during inspection?

REMARKS:

E EMERGENCY EQUIPMENT SAFE AT

RISKN/A

E1Is fire equipment accessible and in good working condition? IfNO, why?

E2 Is a devise available able to summon emergency assistance?

E3 Is spill prevention equipment available?

E4 If SAFE, supplies in good condition?

REMARKS:



C1.7.a.3

F FUEL AND OIL STORAGE TANKS SAFE AT

RISKN/A

F1 Any spills, leaks, or corrosion evident on tanks?

REMARKS:

G PERSONAL PROTECTIVE EQUIPMENT SAFEAT

RISKN/A

G1 Employees wearing Hard Hats, Safety Glasses, Proper Clothingand Steel Toed Boots?

G2 Employees wearing face shields when applicable?

G3 Employees wearing hearing protection when needed?

G4 All respirators sanitized and properly stored?

G5 Employees wearing respirators when applicable?

REMARKS:

H EQUIPMENT SAFEAT

RISKN/A

H1 Are Deadman controls operational on Blast Hoses?

H2 Are Safety Pins and Whip Checks in place on all hoses?

H3 Are Items being blasted secured in place?

REMARKS:





C1.8

Attachment 5





MORENO GROUP AND SUBSIDIARIESREFURBISH DECK SAFETY CHECKLIST

C1.8.a.1

Date:Time:Location:


A SAFETY SAFEAT

RISKN/A

A1 Has paint samples been taken to analyze for lead content? *Ifpaint contains lead refer to Lead Job Safety Checklist

A2 Has deck been grounded prior to work? *If no, deck needs to begrounded prior to work.

A3 Are there any open holes or missing handrails? *If Safe, all holesand handrails must be corrected prior to work beginning.

A4 Are there adequate walkways going up on the deck?

A5Has the deck been checked for NORM content? *If Safe, copy ofNORM free certificate needs to be provided by customer. If no,deck needs to be checked for NORM.

A6 Has production equipment, pipes and etc. been cleaned andgassed free prior to any cutting or welding should be performed?

A7 Has deck been checked for hidden hazards such as items hiddenunderneath beams and flanges?

A8Has deck been checked for rusted handrails, stair treads, grating,and stairway handrails? *Rusted and damaged items need to berepaired with new grating or steel.

A9

Has production equipment such as skidpans and living quartersbeen checked for flammable or explosive material that could catchfire when hot work is being conducted? *If no, skids andmiscellaneous areas on deck that may contain flammable orexplosive material needs to be cleaned out.

A10

Have lifelines been installed on areas of deck where grating isbeing removed during demolition work? *Lifelines need to beinstalled on all areas where grating has been removed or there ispotential for a fall.

A11

Has scope of work been communicated to all involved parties?*Communication between crafts should be established before workoperations begin to prevent injuries from multiple job tasks beingperformed.

A12Have tarps and visqueen been installed on deck for any blastingoperations that may be performed on painted surfaces that containlead? *Enclosure of deck is required before blasting begins.



C1.8.a.2

REMARKS:

B ENVIRONMENTAL SAFE AT

RISKN/A

B1

Are there any containers or drip pans with liquids that have thepotential of spilling?

*If Safe, containers and drip pans need to be covered that nothingcan spill until containers are properly disposed of and drip pansare cleaned?

B2 Are there any unlabeled containers of liquid? *If Safe, Customer,Facility Manager and SH&E Department needs to be notified sothat containers can be properly disposed of.

REMARKS:

C EMERGENCY EQUIPMENT SAFE AT

RISKN/A

C1Is fire extinguisher accessible and in good working condition? *IfNo, ensure fire extinguishers are placed on platform beforestarting work.

REMARKS:



C1.9

Attachment 6





MORENO GROUP AND SUBSIDIARIESLEAD JOB SAFETY CHECKLIST

C1.9.a.1

This checklist must be completed prior to any work on deck containing lead and must beaintained during job and once job is completed.

Customer Name:______________________________ Job No. ______________________

Lead sample Results: ________________________________________________________

SAFE NO N/A PRIOR TO WORKING SAFE T RIS N/A

Has everyone that will beworking on the job been bloodlevel lead tested?

Has everyone that will beworking on the job has leadtraining within one year?

Has everyone one that will beworking on the job hadpulmonary function tests?

Has barricades been placedaround the job and theproper warning signsposted?

Has everyone that will beworking on the job been fittested for respirators?

Is Decon trailer setup prior towork?

SAFE NO N/A DURING JOB SAFE T RIS N/A

Has air monitoring beenperformed for all job functionsand around perimeters of thework area?

Make sure that no one issmoking anywhere insidethe barricade of the lead job?

Are all employees wearingproper PPE when working onthe lead surface? (respiratorsrequired anytime lead paint isdisturbed)

Has job specific leadprogram been completed?

SAFE NO N/A ENVIRONMENT SAFE T RIS N/A

Has wind breakers been setupto make sure that lead is not

leaving work area?

Has something been placedon the ground to capture all

of spent sand?

Has Decon trailer wastewaterbeen tested prior to beingdisposed of on the ground?(Until sample has been takenall waste water from Deconmust be stored in drums untilsample results indicate thatsample is safe to dispose of)

Has sand been tested priorto being hauled off site? (Allsand from a lead job mustbe hauled offsite, no matterif the results come backpositive or negative)

REMARKS:

INSPECTION TEAM:

Date:





C1.10

Attachment 7





Moreno Group LLC and Subsidiaries SH&E Department JobsiteHazard Assessment

Checklist

C1.10.a.1

Date:

Time:

Superintendent:

Location:

INSPECTION TEAM:


RISKN/A

A1 Are work area exits & aisles unobstructed?

A2 Are walkways free of welding leads, hoses, material, etc.?A3 Are walkways free of slipping hazards?

A4 Materials/equipment stored such that sharp objects will not interferewith the walkway?

A5 Are open holes identified and barricaded with 3/8” wire rope andhurricane fencing?

A6 Are barricades properly used?

A7 Are material storage areas barricaded by caution tape or othermeans?

REMARKS:


RISKN/A

B1 Are work areas clean and free of debris?

B2 Are work areas free of material spills and are dip pans clean?

B3 Adequate room to maneuver?

B4Trash (metal and waste) cans dumped regularly?


REMARKS:



C1.10.a.2

C FIRE PROTECTION SAFEAT

RISKN/A

C1 Fire extinguisher inspection within last 30 days?

C2 Fire extinguishers fully charged with seal and tags in place?

C3 Fire extinguishers in designated location?

C4 Fire extinguishers unobstructed and in good condition?

C5 Ignition sources 35 ft. away from Flammable Materials?

C6 Is there a trained fire watch designated during all Hot workactivities and is there the appropriate number of fire watch (i.e. Oneach level, etc.)?

C7 Is there a continuous gas detection meter calibrated and beingused by the fire watch?

C8 Does the fire watch remain on site 30 minutes after hot work isshut down?

C9

Is platform shut-in at the SSV, if welding a burning is performedwithin 10’ or well bay or production area? If not, is the operator’sMMS Approved Welding and Burning Plan being followed? If not,Shut Down Hot Work!!!

C10 Are equipment containing hydrocarbon or flammable substancesrelocated 35’ horizontally from work area? If relocation isimpractical, is equipment shielded?

C11

Are equipment containing hydrocarbon or flammable substancesat lower levels where slag sparks could fall, relocated 35’horizontally from point of impact? If relocation is impractical, isequipment shielded?

REMARKS:

D LOCKOUT / TAGOUT SAFEAT

RISKN/A

D1 Is a group lockout / tagout box provided in the toolhouse?

D2 Does the box contain adequate amount of Supervisor locks(SSeries)?

D3 Does the box contain adequate employee locks for the size ofcrew (E Series)?

D4 Are “DO NOT OPERATE” tagout tags provided in the group lockbox?

D5 Are lockout / tagout procedures being followed per DII procedure?

REMARKS:



C1.10.a.3

E ELECTRICAL SAFEAT

RISKN/A

E1 All 3-prong extension cords in good condition? (i.e. no tape, cuts,burns, etc.)


E3 Cords on electrical tools in good condition?

REMARKS:


RISKN/A

F1 Compressed gas and oxygen cylinders stored in upright position withprotective caps, properly secured?

F2 Oxygen and fuel gas cylinders separated (5 ft. noncombustible barrier or20 ft. separation)?

F3 Cylinders kept away from heat sources or stairs?

F4 Empty cylinders marked “Empty”?

F5 Are anti-flashback valves installed on cutting torches and regulators?

F6 Are welding machines ESD’s identified?

F7 Are mufflers and exposed hot surfaces insulated? (Welding Machines / AirCompressors)


F9 Welding leads and torch hoses in good condition?


F11 Are welding machine frames grounded to platform if placed on wooden

decks?

F12Is welding machine attached to the platform ESD system? If Safe, has thenut in the Versa Valve been removed?

F13 Is welding machines skid pan clean and plugged?

REMARKS:



C1.10.a.4


RISKN/A

G1 Are guards on portable grinders?


G3 Are guards enclosing all rotating and moving equipment to preventphysical contact?

G4 Are pneumatic and hydraulic hoses on power operated tools in goodoperating condition? (i.e. no deterioration or damage)

G5 Are pneumatic hose safely connected together with safety pins and whipchecks?

G6 Are hand tools in good condition? (i.e. mushroomed heads, broken orfractured handles, bent or worn wrenches, handles wedged tightly inhead of tools, etc.)

G7 Are cutting tools edges sharp so tool will move smoothly without bindingor skipping?



G10 Is there evidence employees are inspecting hand and power tools priorto their use?

REMARKS:



C1.10.a.5


RISKN/A

H1 Are employees wearing Hard Hats, Safety Glasses, Proper Clothing andSteel Toed Boots? (i.e. clear safety glasses at night)

H2 Are employees wearing face shields when applicable (i.e. grinding,burning, welding, and buffing operations)?

H3 Are employees wearing hearing protection when needed?

H4 All respirators sanitized and properly stored?

H5 Are employees wearing respirators when applicable?

H6 Are employees using fall protection properly (i.e. anchor devices, 100%tied off, etc.)?

H7 Are employees using hand protection?

H8 Is the PPE provided in tool house well maintained and organized?

H9 Are the employees inspecting their PPE?

H10Is there a Fall Protection Rescue System on location and is the location ofthe Rescue System identified on the JSEA? (If working at elevatedelevations or over the side, etc.)

H11 Are Fall Protection Rescue System Drills being conducted each hitch?

H12 Are the Fall Protection Yo-Yo certifications current?

H13 Are Fall Prevention techniques / fall elimination being utilized andaddressed? (ie. Scaffolding up to work area, ensuring proper worksurfaces)

H14 Are only engineered horizontal life-lines used and is there adequateclearance between lifeline and lower level?

H15 Are scaffold builders utilizing yo-yos attached to structural members duringscaffold erection, instead of tying off to the scaffold when available?

H15 Are welders wearing Hard Hats while welding?

REMARKS:

I PORTABLE LADDERS SAFEAT

RISKN/A



I3 Ladder locking mechanism working properly?

I4 Ladder side rails/legs in good condition?

I5 Does ladder sit properly when the ladder is in place or extended?I6 Ladder safety shoes in good condition and in place?

I7 Are ladders secured to structure at top when in use?

REMARKS:



C1.10.a.6

J RIGGING EQUIPMENT SAFEAT

RISKN/A

J1 Are Crosby or equivalent rigging hardware (i.e. shackles, hooks,etc.) provided? (i.e. Stamped or embossed Safe Working Lead andManufacturer)

J2 Is the tool house pre-slung? Is sling tagged and in good condition?

J3

Are chain or wire rope slings being used tagged and meets API RP2d requirements? (i.e. kinking, broken wires, distortion, heatdamage, dent hooks, bad end attachments, metal corrosion ormetal loss)

J4 Are chain slings - Alloy Grade 80?

J5

Are nylon slings being used tagged and meets API RP 2drequirements? (acid or caustic burns, melting or charring, holes,tears, cuts, snags, broken or worn stitches, excessive abrasion orknots)

J6 Is air tugger in good condition? Is a manufacture eye provided?

J7 Does the crane operator have their certification on them?

J8

Do the riggers have their cards on them or does the

superintendent have their training documentation on location?

J9 Are taglines being used on all lifts? If so, are enough taglinesbeing used on the load?

REMARKS:

K PAINTING / BLASTING JOBS SAFEAT

RISKN/A

K1 Are employees mixing paint wearing proper PPE (Long sleeves, Apron,Safety Glasses, Faceshield, Rubber Gloves, and ½ mask OVRespirator)?

K2 Are employees wearing proper PPE during painting operations (Longsleeves, safety glasses, supplied air respirator / hood and gloves?

K3 Are employees wearing proper PPE during blasting operations (Longsleeves, safety glasses, supplied air respirator / hood, hearing protectionand gloves)?

K4 Are all ½ mask OV respirators provided by Moreno Group LLC andSubsidiaries (3M 5000 series with OV cartridge and pre-filter)?

K5 Are employees utilizing Blasthoods or Paint Hoods during spray paintingoperations? (Employees may only utilize ½ mask OV respirators with

Project Managers or designees approval)K6 Are all employees who wear respirators clean shaven?

K7 Is paint being mixed in drip pans?

K8 Is waste paint being poured into properly labeled waste drums?

K9 Do all paint cans, solvent cans and waste drums have covers in placewhen not being emptied or filled?

K10 Is there evidence that equipment is being inspected? (Verify condition ofequipment)

K11 Are dead man controls operational on all blast hoses?



C1.10.a.7

K12 Are On/Off safety valves on air line hoses and are they in arms reach ofblast nozzle?

K13 Are On/Off safety valves turned off when blast nozzle is not in use?

K14 Are pressure gauges on paint pots in good condition and readable (i.e.not covered with paint)?

K15 Is the spider pre-use inspection checklist being completed prior to eachuse?

K16 Is the cable on the air spider in good condition (manufactured eye, no

broken wires, no arching)?K17 Is the air spider frame in good condition? (i.e. not bent, etc.)

K18 Are air spiders being utilized properly (proper tie-off, proper anchor pointfor spider and employee)?

K19 Is the air spider oil level within the oil lubricator adequate?

K20 Is the correct transfer cable being utilized on all spiders with certificationtag (i.e. transfer chain, certified transfer cable)?

K21 Are air compressors equipped with carbon monoxide sensors andproviding Grade D breathing air?

K22 Are CO2 monitor certif ication papers onsite and calibration records up todate?

K23 Are employees utilizing LOTO when needed?K24 Are air compressor mufflers and other exposed hot surfaces insulated?

REMARKS:

L PAPERWORK SAFEAT

RISKN/A

L1 “SH&E Meeting” conducted daily? Is the Meeting content good?

L2 Has the crew been issued a work/hot work permit and is it current?

L3Is the Behavioral Safety Observation process being used? If so,are the cards being discussed in the SH&E Meeting and is theparticipation at an appropriate level?

L4 Did the Superintendent complete the “Short Service EmployeeMentor Form”?

L5 Are Short Service Employees identified with a SSE sticker on hardhats?

L6 Is the Short Service Employee’s Mentor providing them direction?

L7 Is the “Offshore Tool House Checklist” being used?

L8 Verity condition of Offshore Tools House (i.e. neat, orderly, tools

tagged out, etc.)?L9 Is Crane Operator performing and documenting a daily crane

inspection?

L10Does the Superintendent have the correct Moreno Group LLC andSubsidiaries Paperwork (i.e. incident reports, SH&E Meeting, WorkGroup Investigation, SH&E Training)

L11 Is the crew performing Weekly Hazard Assessments of their workarea?

L12 Is the Fitness for Duty Certificate / Medical Questionnaire beingcompleted at the first SH&E meeting?



C1.10.a.8

N TEAM WORK OF THE CREW SAFEAT

RISKN/A

N1 Is the crew members working together?

N2 Is the crew members communicating to each other concerning job

task, hazards, etc.?N3 Is the crew providing proper communication to crane operator?

N4 Is the crew following the JSEA?

N5 Are the crews following all applicable Safe Work Practices (i.e.Lockout/Tagout, Line Opening, Crane Operations, Fall Protection,etc.)?

N6 Are the crews utilizing containment pan while opening processlines? If so, is the containment pan grounded and/or bonded to theprocess line?

N7While the employees are working, are they aware of theirsurroundings (i.e. pinch points, employees working next to them,

etc.)?REMARKS:

REMARKS:


RISKN/A

M1Does the scaffolding have a toprail, midrail, and toe boardsprotecting all edges?


M3If there is a potential to drop material and/or equipment from thescaffolding, is the area beneath and around the scaffoldingbarricaded with red “Danger” tape?

M4 Has the scaffolding been inspected by a competent person whohas signed and dated the yellow tag?

M5Does the yellow tag indicate 100% tie off/fall protection required orindicated any other hazards associated with the scaffold (i.e.missing midrail, etc.) identified?

M6 Does the ladder extend 3 feet past the scaffolding landing? If not,is it identified on the scaffold tag as a hazard?

REMARKS:



C1.10.a.9

O JSEA FORM EVALUATION SAFEAT

RISKN/A

O1Header Information:

Was all header information provided?

O2Sequence of basic job steps:

Are the job steps defined at an appropriate level of detail?

Is a pre-job safety meeting included?

Is a site inspection included?

Have any SSE been identified?

O3 Potential Accidents or hazards:Have potential accidents and hazards been identified?

Do they appear to be job-specific?

Was a checklist on back of the JSEA used to help identify hazards?

O4Recommended Safe Job Procedure:

Do job procedures appear to be job-specific?

Are job procedures clear and at appropriate level of detail?

Do procedures cover entire job from pre-job to post-jobrequirements?

Have mentors been assigned to any SSE personnel?

Are Responsible Parties identified for each step?

Were lockout/tagout requirements identified?

Were barricading requirements identified?

Were communications requirements identified?

O5 PPE Requirements

Have all required PPE been specified on the form?

Have all potential accidents or hazards been addressed either

through safe job procedures, PPE or both?O6 Other:

Has the JSEA form been signed by all employees involved in the job?

Was a Crane Lift Plan required? If so, was it prepared?

Were the crew, scope or conditions of the job changed during the job?

If so, was the JSEA form reviewed, modified, and re-signed asrequired?

Is the fall rescue plan on back of JSEA being utilized wheneveremployees are using fall protection?

REMARKS:



C1.10.a.10

P JSEA EMPLOYEE INTERVIEWP1 Tell me how the JSEA was communicated to you and the crew?

P2 What was your part in the developing of the JSEA, identifying of hazards andsetting Recommended Safe Procedures / Protection?

P3In addition to the information provided on the JSEA, would you like to seeanything added to the JSEA (i.e. form, JSEA for Task, etc.) If any, what hazards

did you feel were not identified on the JSEA?

P4 When did you receive JSEA training?

P5 What would you do if the conditions changed during your task? (i.e. productionemployees started pulling samples from a vessel?)

P6In identifying the hazards of the task was the checklist on back of the JSEA

utilized? If so, where did you conduct this checklist?



C1.10.a.11

Q JSEA SUPERVISOR INTERVIEWQ1 How was the task JSEA developed and communicated with your personnel?

Q2 How do you involve your personal in the development of the JSEA?

Q3 When did you receive JSEA Training?

Q4 Describe any barriers or successes you have experienced implementing theJSEA process?

Q5 If conditions change during a task, what do you expect your employees to do?Have you communicated your expectations to them?

Q6 In identifying the hazards of the task was the checklist on back of the JSEAutilized? If so, where did you conduct this checklist?



C1.10.a.12

R JSEA JOB OBSERVATIONR1 Were the proper people in attendance?

R2 Was there full involvement by personnel present? (Hourly through Supervisors,and representatives of all companies) Why, Why Not?

R3 Were the hazards of the job identified and properly addressed? If not, explain.

R4 Were there any observed difficulties implementing the JSEA process? Explain.

R5 Were there any changes in job scope, conditions or personnel? Were theyproperly addressed?

R6 Were responsibilities clear?

R7 Were safe job procedures defined and/or followed?



C1.10.a.13

JSEA Scoring Key:

1 = Almost Never (0-20%) 2 = Less than half the time (21-50%)3 = Most of the Time (51-80%) 4 = Almost All the Time (81-94%) 5 = Always (95-100%)

Add the score from each line item to get the….. Total Score: __________

Divide the Total Score by 70 (Max possible score) to get…. Percent: __________

S JSEA SCOREBOARD

1 2 3 4 5

S1 Pre Job Planning:

1.1 Appropriate personnel initiate JSEA in advance of the job.

1.2 The basic job steps are clearly written and includeappropriate level of detail.

1.3 Pre-job safety meetings and site inspections are conductedand include all persons involved in the job.

S2 Hazard Identification and Mitigation Planning:

2.1 Potential hazards are adequately identified and described.

2.2 Safe job procedures or PPE are specified to address allhazards which were identified.

2.3 Responsibilities for hazard mitigation are clearly defined.

2.4 All job personnel actively participate in Hazard Identification.

2.5 All employees involved in job sign off on JSEA form.

2.6 Was a jobsite inspection performed at site of task?

S3 Job Execution:

3.1 Jobs are conducted in accordance with the JSEA (job steps,safe job procedures, responsibilities, PPE).

3.2 Jobs are adequately supervised.

3.3 Changes to job scope, personnel, and/or site conditions areproperly managed.

S4 Employee Qualifications:

4.1 SSE employees are identified and mentors assigned.

4.2 Were the employees able to effectively communicate to youthe scope of their job and JSEA?





C1.11

Attachment 8





Moreno Group LLC and Subsidiaries Offshore Tool HouseInspection Checklist

Coatings Division

C1.11.a.1

Superintendent

Job Number

Job Location

Customer Name

Note: Moreno Group LLC and Subsidiaries Offshore Tool House Inspection Checklistprovides guidelines to the Tool Room Personnel when inspecting, preparing andorganizing offshore tool houses. The Offshore Superintendent upon receiving theirtool house should examine their tool house and this inspection checklist. Upon theirapproval this form shall be submitted to the Offshore Manager for review and filing.

INSPECTION TEAM:

A CHAIN COME ALONG SAFEAT

RISKN/A

A1 Chain Intact?

A2 Latch intact and hook not stretched?

A3 Is chain kinked or Arced?

REMARKS:

B GAUGES SAFEAT

RISKN/A

B1 Are gauges in good condition? (glass not cracked or broken,readable)

B2 Do gauges needles move freely?

B3 Is the calibration sticker affixed to gauge?

REMARKS:



C1.11.a.2

C HAND TOOLS SAFEAT

RISKN/A

C1 Are hand tools in good condition? (i.e. mushroomed heads,broken, fractured or bent handles, handles wedged tightly inhead of tools, etc.)

C2 Are cutting tools edges sharp so tool will move smoothly withoutbinding or skipping?

C3 Are tools stored in dry, secure locations?

C4 Are wrenches in good condition? (teeth not excessively worn orgears move freely)

C5 Are pinch bars excessively bent?

C6 Are pinch bars edges not broken?

C7 Are screwdrivers in good condition? (tips not dent and handleintact)

C8 Are channel locks in good condition? (teeth not excessivelyworn)

C9 Are the hacksaw blades sharp and intact?

REMARKS:

D AIR HOSE GENERAL SAFEAT

RISKNA

D1 Bull hose W/Boss clamps provided and in goodcondition?

D2 Blast hose in good condition?

D3 Paint lines in good condition?

D4 Hood line in good condition?

D5 Whip checks spring mechanism working properly?

D6 Are safety pins provided for air hose connections?

D7 Check for grommets on air hoses?

REMARKS:

E EXTENSION CORDS SAFEA

RISKN/A

E1 All 3-prong extension cords in good condition? (i.e. no tape,cuts, burns, etc.)


E3 Are temporary lights that are provided operational?

E4 Are guards on lights in place?

E5 Are all extension cords and/or electrical tools have a“Warning” Source of Ignition When in Use sticker place oneach cord or tool?



C1.11.a.3

REMARKS:

F PAINTING BLASTING & EQUIPMENT SAFEAT

RISKN/A

F1 Is list of MSDS (for paint and solvents) provided?

F2 Are containment pans provided for paint pots, mixing andstorage?

F3 Are paint screens and tarps in good condition ( no holes, nottorn)?

F4 Are dead man controls on blast nozzles working properly and ingood condition ( not corroded are jammed)?

F5Is a safety on/off valve provided on air line in arms reach of blastnozzle?

F6 Are blast hoods & aprons provided and in good condition?

F7 Are enough inner and outer shields provided?

REMARKS:

G PNEUMATIC TOOLS AND HOSES SAFEAT

RISKN/A


G2 Are pneumatic hose safely connected together or provided withsafety pins or whip checks?

G3 Are socket retainers provided?

G4 Are oilers installed on power tools?

REMARKS:

I PERSONAL PROTECTIVEEQUIPMENT SAFEAT

RISKN/A

I1 Is caution/hazard tape provided?

I2 Are safety glasses provided and in good condition? (clear andtinted)

I3 Are hard hats provided?

I4 Are face shields provided and in good condition? (clear andtinted)



C1.11.a.4

I PERSONAL PROTECTIVEEQUIPMENT (continued) SAFE

AT

RISKN/A

I5

Is fall protection in good condition?

Webbing – Cuts, Fraying, Abrasion, Burns, Chemical

Exposure

Buckles – Deformed, Corrosion, Rust, Chemical

Exposure

Snaps – Gate works freely, Double action works,Deformed,

corrosion, Rust Chemical Exposure

I6 Are 3M (5000 series) ½ mask OV respirators provided withpre-filters and in good condition?

I7 Are the brakes on the retractable lifelines operational?

I8 Are material handling gloves provided?

I9 Are chemical / impact goggles provided?

I10 Are tyvek suits provided?

REMARKS:

K SHACKLES SAFE ATRISK

N/A

K1 Is the cotter pin present?

K2 Is the capacity of the shackle indicated?

K3 Is the shackle in good condition?

K4 Are shackles Crosby or equivalent? If no, take out of serviceand replace with Crosby or equivalent.

REMARKS:

L FIRST AID KIT SAFEAT

RISKN/A

L1 Is the first aid kit an USCG Approved First Aid Kit?

L2 Is the kit in good condition?

L3 Is there a Bloodborne Pathogens kit available?

L4 Is the kit full?



C1.11.a.5

REMARKS:

M LOCKOUT / TAGOUT SAFEAT

RISKN/A

M1 Is a group lockout / tagout box provided in the

toolhouse?M2 Does the box contain Supervisor locks (S1 – S8)?

M3 Does the box contain adequate employee locks for the size ofcrew (E Series)?

M4 Are “DO NOT OPEN” tagout tags provided in thegroup lock box?

REMARKS:

N SLINGS (Wire, Chain) SAFE T RISK N/A

N1 Is the identification tag attached to sling?

N2 Are there 10 randomly broken wires in one rope lay?

N3 Are there 5 broken wires in one strand in one lay?

N4 Is there wearing or scraping of original diameter of outside wire?

N5 Is there kinking, gouging, bird caging or other damage?

N6 Is there evidence of corrosion or heat damage?

N7 Are there end attachments that are cracked or deformed?

N8 Is there evidence of melting or charring of any of the sling

surface?

N9 Is there evidence of acid, caustic or heat burns?

N10 Are rigging chains of Alloy Grade Lifting Chain

N11 Are clamps provided for cables?

N12 Are all rigging hardware Crosby or equivalent? (i.e. hooks, padeSafe, etc.) If no, take out of service and replace with Crosby orequivalent.

REMARKS:

O BEAM CLAMPS SAFEAT

RISKN/A

O1 Are beam clamps clearly marked and permanentlystamped with load rating?

REMARKS:



C1.11.a.6

P SCAFFOLDING / SCAFFOLD BOARDS SAFEAT

RISKN/A

P1 Are scaffold boards smooth and free of tripping hazards?

P2 Are there any cracks?

P3 Are the board warped?

P4 Are the boards stamped “OSHA Approved”?

P5 Are scaffolds free of rust and / or corrosion?

P6 Do pin latches work properly?

REMARKS:

Q AIR SPIDERS / AIR TUGGERS SAFEAT

RISKN/A

Q1 Are manufacture eSafe provided on Air Tuggers? (required)

Q2 Is wire rope on air tuggers in good condition? (see SectionM2-M6)

Q3 Is the brake on the air tugger operational?

Q4Is there evidence that the cable on the air spider has beenarched?

Q5 Is the air spider oil level within oil lubricator okay?

Q6 Is there a manufactured eye provided on the air spider?

Q7 Is the air spider frame in good condition? (not bent, etc.)

Q8Rub a glove hand along wire rope on drum assembles tocheck for broken wires? (see Section M Number M2-M6)

REMARKS:

R TOOL HOUSE INSPECTION SAFEAT

RISKN/A

R1 Is the tool house door hinges in good condition? (i.e. notcorroded, pitted, etc.)

R2 Is the tool house door in good condition? (i.e. not corroded,pitted, etc.)

R3 Is the tool house floor in good condition? (i.e. not corroded,pitted, etc.)

R4 Is the tool house lifting eSafe in good condition? (i.e. notcorroded, pitted, etc.)

R5 Is the internal shelving in good condition?

REMARKS:



C1.11.a.7

Superintendent ApprovalPrint Name:Signature:

Date:

NOTE: Fax back to offshore manager after approval.





Moreno Group LLC and Subsidiaries Offshore Tool HouseInspection Checklist

Construction Division

C1.11.b.1

Superintendent

Job NumberJob Location

Customer Name

Note: Moreno Group LLC and Subsidiaries Offshore Tool House Inspection Checklistprovides guidelines to the Tool Room Personnel when inspecting, preparing andorganizing offshore tool houses. The Offshore Superintendent upon receiving theirtool house should examine their tool house and this inspection checklist. Upon theirapproval this form shall be submitted to the Offshore Manager for review and filing.

INSPECTION TEAM:

A CHAIN WIRE COME ALONG SAFE AT

RISK

N/A

A1 Chain Intact?

A2 Latch intact and hook not stretched?

A3

Wire Not Damaged?

Are there 10 randomly broken wires in one rope lay?

Are there 5 broken wires in one strand in one lay?

Is there kinking, gouging, bird caging or other damage?

Is there evidence of corrosion or heat damage?

A4 Is chain kinked or Arced?

REMARKS:

B PIPE JACKS SAFE AT

RISK

N/A

B1 Pipe Jacks have not been welded on?

B2 Do Pipe Jacks operate smoothly?

B3 Is the washer present?

B4 Are pipe jack legs in good condition? (not dent or cracked)

B5 Are jack heads in good condition? (not dent, worn or cracked)

REMARKS:



C1.11.b.2

C HAND TOOLS SAFEAT

RISKN/A

C1 Are hand tools in good condition? (i.e. mushroomed heads,broken, fractured or bent handles, handles wedged tightly in headof tools, etc.)

C2 Are cutting tools edges sharp so tool will move smoothly withoutbinding or skipping?

C3 Are tools stored in dry, secure locations?

C4 Are wrenches in good condition? (teeth not excessively worn orgears move freely)

C5 Are pinch bars excessively bent?

C6 Are pinch bars edges not broken?

C7 Are screwdrivers in good condition? (tips not dent and handleintact)

C8 Are channel locks in good condition? (teeth not excessively worn)

C9 Are the hacksaw blades sharp and intact?

REMARKS:

D GRINDERS AND ELECTRICAL EQUIPMENT SAFEAT

RISKN/A

D1 Is the ground plug present, or is the tool double insulated?

D2 Is the cord of the tool in good condition? (not frayed)

D3 Is the guard in place? (required to be in place)

D4 Is the handle in place? (required to be in place)

D5 Is the RPM’s of blade equal to grinders RPM’s?

D6 Does the bevel machine chain move freely?

D7 Does each electrical tool have a “Warning” Source of IgnitionWhen in Use Sticker placed on it?

REMARKS:



C1.11.b.3

E EXTENSION CORDS / LIGHTS SAFEAT

RISKN/A

E1 All 3-prong extension cords in good condition? (i.e. no tape,cuts, burns, etc.)


E3 Are temporary lights that are provided operational?

E4 Are guards on lights in place?

E5Does each extension cords or non classified (Class 1, Div 1)lights have a “Warning” Source of Ignition When in Use stickerplace on it.

REMARKS:


RISK N/A

F1 Compressed gas and oxygen cylinders stored in uprightposition with protective caps, properly secured?

F2 Oxygen and fuel gas cylinders separated (5 ft. noncombustiblebarrier)?

F3 All cylinders secured?


F5 Welding leads in good condition?

F6 Are welding tarps in good condition?

F7 Do the welding machines start?

F8Does the Emergency Shutdown Device (ESD) on weldingmachines work?

REMARKS:

G PNEUMATIC TOOLS AND HOSES SAFEAT

RISKN/A


G2 Are pneumatic hose safely connected together or provided withsafety pins or whip checks?

G3 Are socket retainers provided?

G4 Are oilers installed on power tools?



C1.11.b.4

REMARKS:

H GAUGES SAFEAT

RISKN/A

H1 Are gauges in good condition? (gauge glass not cracked,scratched or broken)

H2 Do gauges needles move freely?H3 Is the calibration sticker affixed to gauge?

H4 Are anti flashback and check valves provided on regulators?

H5 Are regulators in working condition?

REMARKS:

I PERSONAL PROTECTIVE

EQUIPMENT SAFEAT

RISKN/A

I1 Are safety glasses provided and in good condition? (clear andtinted)

I2 Are hard hats provided?

I3 Are face shields provided and in good condition? (clear andtinted)

I4

Is fall protection in good condition?

Webbing – Cuts, Fraying, Abrasion, Burns, Chemical

Exposure

Buckles – Deformed, Corrosion, Rust, Chemical

Exposure

Snaps – Gate works freely, Double Lock works, Deformed,

corrosion, Rust Chemical Exposure

I5 Are anchor points provided? (anchor pads, beamers, handgrips, etc.)

I6 Are the brakes on the retractable lifelines operational?

I7 Are material handling gloves provided?

I8 Are chemical / impact goggles provided?

I9 Are tyvek suits provided?

REMARKS:



C1.11.b.5

J TORCHES SAFEAT

RISKN/A

J1 Are anti-flashback and check valves provided?

J2 Are torch tips in provided and in good condition?

J3 Are the torch tip orifice provided?

J4 Is an o-ring kit included?

J5 Are gas and oxygen hoses in good condition or repairedproperly?

REMARKS:

K SHACKLES SAFEAT

RISKN/A

K1 a. Is the cotter pin present?

K2 Is the capacity of the shackle indicated?

K3 Is the shackle in good condition?

K4 Are shackles Crosby or equivalent? If no, take out of serviceand replace with Crosby or equivalent.

REMARKS:

L FIRST AID KIT SAFEAT

RISKN/A

L1 b. Is the first aid kit an USCG Approved First Aid Kit?

L2 c. Is the kit in good condition?

L3 d. Is there a Bloodborne Pathogens kitavailable?

L4 e. Is the kit full?

REMARKS:



C1.11.b.6

M SLINGS (Wire, Chain and Nylon) SAFEAT

RISKN/A

M1 Is the identification tag attached to sling?

M2 Are there 10 randomly broken wires in one rope lay?

M3 Are there 5 broken wires in one strand in one lay?

M4Is there wearing or scraping of original diameter of outside

wire?M5 Is there kinking, gouging, bird caging or other damage?

M6 Is there evidence of corrosion or heat damage?

M7 Are there end attachments that are cracked or deformed?

M8 Is the hook cracked?

M9Has the hook been opened more than 15% of normal throatopening measured at the narrowest point?

M10Is the hook twisted more than 10 degrees from the plane of theunbent hook?

M11 Are safety latches in good condition?

M12 Is there evidence of melting or charring of any of the slingsurface?

M13 Is there evidence of acid, caustic or heat burns?

M14 Is there evidence of snags, punctures, tears, cuts or fraying?

M15 Is the RED stitch showing?

M16 Are rigging chains of Alloy Grade Lifting Chain

M17 Are all rigging hardware Crosby or equivalent? (i.e. hooks, padeSafe, etc.) If no, take out of service and replace with Crosbyor equivalent.

REMARKS:



C1.11.b.7

REMARKS:

O BEAM CLAMPS SAFEAT

RISKN/A

O1 Are beam clamps clearly and permanently stampedwith load rating?

REMARKS:

P SCAFFOLDING / SCAFFOLD BOARDS SAFEAT

RISKN/A

P1 Are scaffold boards smooth and free of trippinghazards?

P2 Are there any cracks?

P3 Are the board warped?

P4 Are the boards stamped “OSHA Approved”?

P5 Are scaffolds free of rust and / or corrosion?

P6 Do pin latches work properly?

REMARKS:

Q AIR SPIDERS / AIR TUGGERS SAFE T RISK N/A

Q1 Are manufacture eSafe provided on Air Tuggers? (required)

Q2 Is wire rope on air tuggers in good condition? (see Section M2-M6)

Q3 Is the brake on the air tugger operational?

Q4Is there evidence that the cable on the air spider has beenarched?

Q5 Is the air spider oil level within oil lubricator okay?

Q6 Is there a manufactured eye provided on the air spider?

Q7 Is the air spider frame in good condition? (not bent, etc.)

Q8 Rub a glove hand along wire rope on drum assembles to checkfor broken wires? (see Section M Number M2-M6)

N LOCKOUT / TAGOUT SAFEAT

RISKN/A

N1 Is a group lockout / tagout box provided in the toolhouse?

N2 Does the box contain Supervisor locks (S1 – S8)?

N3 Does the box contain adequate employee locks for the size ofcrew (E Series)?

N4 Are “DO NOT OPEN” tagout tags provided in the group lock

box?



C1.11.b.8

REMARKS:

R TOOL HOUSE INSPECTION SAFE NO N/A

R1Is the tool house door hinges in good condition? (i.e. notcorroded, pitted, etc.)

R2 Is the tool house door in good condition? (i.e. not corroded,pitted, etc.)

R3Is the tool house floor in good condition? (i.e. not corroded,pitted, etc.)

R4Is the tool house lifting eSafe in good condition? (i.e. notcorroded, pitted, etc.)

R5 Is the internal shelving in good condition?

REMARKS:



C1.11.b.9

Superintendent ApprovalPrint Name:Signature:

Date:

NOTE: Fax back to offshore manager after approval





Moreno Group LLCand Subsidiaries

SH&E ManagementSystem

SH&E Management SystemChange Procedure


C2.1

SH&E Management System Change Procedure

Purpose

The purpose of this procedure is to establish a method for Moreno Group LLC andSubsidiaries to develop, revise and distribute changes or additions to SH&EManagement System.

Scope

The scope of this procedure entails the controlled movement/distribution of alldocuments for SH&E Management.

Responsibilities

The Facility / Site Manager / Offshore Manager, First Line Supervisor / OffshoreSuperintendent or Designees is responsible for:

Understanding and complying with revisions to Moreno Group LLC andSubsidiaries’ SH&E Management System.

Approving of any newly developed or revised program.

Assuring SH&E Management System Manuals’ are updated with the revisions.

Implementing the changes or additions into the overall SH&E ManagementSystem.


The Corporate SH&E Manager will be the SH&E Management System Administrator.

Developing procedures to meet or exceed industry and / or regulatoryrequirements and / or standards.

To provide training to management and supervision pertaining to the changesor additions to the SH&E Management System.

Maintain an ongoing list of those individuals assigned a SH&E ManagementSystem Manual.



C2.2


Understanding and complying with the changes or additions to the SH&EManagement System.

Requirements

The SH&E Department will develop and / or revise the SH&E Management Systemwith management’s approval. The SH&E Management w ill be revised due to any ofthe following situations:

New or Revised Regulatory Requirements

New or Revised Industry Standards

Deficiencies identified during an Audit or Assessment of SH&E Management

System

The addition of a new system or product or service line.

Upon the completion of the development of the revision, the SH&E Department willissue the revisions to all SH&E Management System Manual owners.

Once manual’s owners have time to read and understand the SH&E ManagementSystem revision, the SH&E Department will conduct an orientation to address therevision.

After this orientation, Management and Supervision will be expected to implementthe revisions.




Management System

Contractor Safety, Healthand Environmental

Program


D1.1

Contractor Safety, Health and Environmental Program

Purpose

The purpose of this program is to provide guidelines to evaluate Moreno Group LLCand Subsidiaries Contractor’s Safety, Health and Environmental performance and tocommunicate the minimum safety, health and environmental requirements for theprotection of Company and Contractor employees, property and the environment.

Scope

The scope of this program describes procedures for implementing Moreno GroupLLC and Subsidiaries Contractor Safety, Health and Environmental ManagementProgram. This program contains the necessary elements of a Contractor Safety,

Health and Environmental Management Program to serve a variety of end users.

This program requires Contractors (including Subcontractors) to abide by MorenoGroup LLC and Subsidiaries and their Clients Safety, Health and Environmentalpolices and procedures, applicable government regulations as well as recognizedindustry standards and practices.

Responsibilities

The Facility Manager / Offshore Manager or Designee is responsible for:

Providing the appropriate resources to implement this program.

Communicating to contractors Moreno Group LLC and Subsidiaries Safety,Health and Environmental expectations and requirements.

The Yard Foreman / Offshore Superintendent is responsible for:

Utilizing those contractors who have completed Moreno Group LLC andSubsidiaries’ Contractor Safety, Health & Environmental evaluation process.

Conduct or coordinate the Contractor SH&E Orientation.

Monitor the Contractor’s Safety, Health and Environmental performance duringthe project.

Audit Contractor’s jobsites while performing Moreno Group LLC and Subsidiariesdesignated hazard assessments. Ensure Contractors are developing and utilizinga job specific Job Safety and Environmental Analysis for their job tasks.



D1.2

Communicate issues to the Facility Manger or Offshore Manager as soon aspossible.

The Project Manager is responsible for:

Submitting to contractors Moreno Group LLC and Subsidiaries Generic Safety,Health and Environmental Questionnaire.

Utilizing those contractors who have completed this Contractor Safety, Health &Environmental evaluation process.

Tabulate and provide to the SH&E Department the man hours accumulated bycontractors.


Evaluating Moreno Group LLC and Subsidiaries Contractor’s Generic Safety,Health and Environmental Programs per this program.

Assisting Facility Management in communicating Moreno Group LLC andSubsidiaries Safety, Health and Environmental Programs expectations and

requirements.

Assisting the Yard Foreman or Offshore Superintendent in conducting orcoordinating Moreno Group LLC and Subsidiaries Contractor Safety, Health andEnvironmental Orientation and hazard assessments.

Holding Subcontractor accountable for their SH&E Performance

Obtain from Project Managers man hour accumulated by subcontractors andprovide to our clients upon request.

Requirements

Evaluation Requirements

To ensure that Contractors are capable of effectively managing the safety, healthand environmental requirements of proposed work/projects in accordance withMoreno Group LLC and Subsidiaries’ or Client’s requirements, all Contractors will

undergo a qualification evaluation prior to beginning work at any Moreno Group LLCand Subsidiaries or Client location. Contractors that work onsite and have significantexposure to risk due to the type of jobs or number of personnel on location may besubject to a more comprehensive evaluation.

In addition, Contractors will be held accountable for the safety, health andenvironmental performance of their Subcontractors. Subcontractors must also meetthe requirements of this plan and undergo a performance evaluation. Theperformance of the Subcontractors will be reflected in the Contractor’s performanceevaluation.



D1.3

Qualification

Pre-qualification

Safety, Health and Environmental performance are important parameters in theContractor selection process. The pre-qualification process consists of the review ofthe Contractor’s SH&E statistical performance.

Statistical Performance

To initiate an evaluation of a prospective Contractor’s safety, health andenvironmental performance, Moreno Group LLC and Subsidiaries will request that allContractors complete a Generic Safety, Health and Environmental Questionnaire(see Attachment 1).

The questionnaire is designed to collect relevant information on historical safety,health and environmental performance. The acquired information will be utilized tocompare the prospective Contractors performance to that of other Contractors within

the similar work classifications.

Pre-qualification criteria information

The following selection criteria will be utilized for this initial pre-qualification stage:

Experience Modification Rate (EMR) for the past three years (NCCI rate)

Total recordable incident rates for injuries and illnesses for the past three yearsfor the business unit or region that the Contractor is operates from;

Number of fatalities experienced in the past three years for the business unit orregion that the Contractor operates from; and

Number of regulatory/legal citations, penalties and/or sanctions issued againstthe Contractor within the past three years for the business unit or region that theContractor operates from.

Pre-qualification performance cut-off

Current EMR should not exceed 1.00, or the previous three-year average shouldnot exceed 1.25

And

The average of the last two of the previous three years’ total recordable incidentrate should not exceed the most current national BLS rate for the correspondingbusinesses.

If the Contractor fails to qualify within the above restrictions, the Contractorqualification process will be terminated until such a time that the Contractor meetswith Moreno Group LLC and Subsidiaries and provide sufficient information to



D1.4

indicate a significant improvement in their SH&E program. The Contractor will beformally notified regarding rejection from the qualification process and the reason(s)thereof. If the Contractor meets the above criteria, proceed with the qualificationprocess.

The incident rates will be determined from the most current edition of the U.S.Bureau of Labor Statistics publication.

Safety, Health and Environmental Management System Assessment

Moreno Group LLC and Subsidiaries or designated representative may conductinterviews with the prospective Contractors safety, health and environmental andmanagement personnel regarding the management of their Safety, Health andEnvironmental program (see Attachment 2). A relative score regarding the results ofthis assessment shall be assigned to the Contractor. (see Attachment 4)

Contractor Facility or Jobsite Assessment

When warranted, Moreno Group LLC and Subsidiaries or designatedrepresentative(s) may conduct a visual (on-site) audit of the prospective Contractor’soperating facilities and/or Jobsite (see Attachment 3). In the event that it is notpossible to conduct the site assessment within this phase of the evaluation process,the Contractor shall be conditionally accepted for work pending the completion of asite assessment. A site assessment shall be completed during the Contractors initial

job assignment and forwarded to the Contractor Administrator for evaluationcompletion. The Contractor may not be allowed to perform any other jobs until theevaluation is completed and the Contractor is assigned their rating status.

A relative score shall be assigned to the Contractor regarding the results of this

assessment and shall be used to help determine the prospective Contractor’s rating(see Attachment 4).

Contractors that can not be evaluated via a site assessment, i.e. Contractors thatprovide only personnel to Moreno Group LLC and Subsidiaries, will be required toprovide alternative information in support of their performance qualifications.Information in addition to that provided by the Contractor may also be obtainedthrough the following processes;

Interviews with Contractor Management

Letters of commendation from other companies for which the Contractor is or hasworked

Interviews with Contractor personnel

Review of resources available to the Contractor to meet Moreno Group LLC andSubsidiaries, government and Industry requirements



D1.5

Contractor Safety, Health and Environmental Program Rating

The data acquired from the Generic Safety, Health and EnvironmentalQuestionnaire, Safety, Health and Environmental Management System and Facility

Assessments may be used to develop a composite qualification score for theprospective Contractor. An applicable score shall be given to the Contractor for eachcriteria component. (See Attachment 4)

PRE-QUALIFICATION COMPOSITE SCORE TABLE _

Criteria Range Scores================================================

TRIR 50% of BLS Avg. +25

(previous year) 50% to BLS Avg. +15

EMR < 1.0 +15(previous year) >1- 1.25 +10

Site Assessment Maximum +15

SH&E Mgmt. Maximum +45Process

Assessment

Fatality Within past year - 15Within past 2 years - 10Within past 3 years - 5

[Maximum allowable score is 100]

Feedback & Expectations

When it has been determined that a Contractor has met all of Moreno Group LLCand Subsidiaries or Client qualification requirements, the Contractor may then beadded to a list of accepted Contractors.

Accepted Contractors (approved, conditional) may perform work requiring immediateattention, provided that a current contract or master service agreement is on file. .

All accepted Contractors shall be forwarded a copy of the requirements as outlined

in Moreno Group LLC and Subsidiaries’ Safety, Health and EnvironmentalHandbook.

Contractors that fail to meet Moreno Group LLC and Subsidiaries’ pre-qualificationrequirements shall be formally notified regarding the reason(s) for rejection andassociated restrictions as defined by the Facility Management.

Contractor Safety, Health and Environmental Qualification Review

All accepted Contractors safety, health and environmental performance shall be



D1.6

re-evaluated at determined intervals. The scope of the review shall be as follows:

Contractors rated as “Accepted”

Submission of PQF every three years unless warranted

Three years comprehensive re-assessment (qualification)

Contractors rated as “Conditional”

Annual Pre-qualification Form (PQF) or equivalent

At a minimum, Annual comprehensive re-assessment (qualification)

At any time that a Contractor’s Safety, Health and Environmental performancedeteriorates significantly a comprehensive re-qualification may be requested byMoreno Group LLC and Subsidiaries Facility Management.

Contractors rated as “Rejected” (red)

Two years from current assessment date, “Rejected” contractor may appeal toMoreno Group LLC and Subsidiaries for a re-assessment (qualification).

Note: Should a “Rejected” contractor be used due to an existing contract and/orequipment at our facilities, the Facility Manager must approve the use of saidcontractor in writing. The Yard Manager / Offshore Superintendent or designee willmonitor the contractor’s performance on a continual base while they are on MorenoGroup LLC and Subsidiaries’ or our Client’s location.

Intervention Use

In an emergency situation, it may not be feasible to pre-qualify a Contractor prior toselection. In such cases, it is recommended that the Facility Manager attempt toacquire a completed PQF (or equivalent) and a copy of the Safety, Health andEnvironmental Management Program of the prospective Contractor. The MorenoGroup LLC and Subsidiaries Facility Manager, Yard Manager and SH&EDepartment Representative should review the acquired information. Once the teamagrees to use the Contractor, they should outline the project task and theContractor’s performance expectations. Upon the completion of this process the

Facility Manager must authorize the initiation of work in writing. Moreno Group LLCand Subsidiaries should have company supervision during the duration of thiscontractor’s project.

Examples of intervention work are:

Environmental Releases

Fire & Explosions

Evacuation Situations

Other critical activities as approved by Facility Management



D1.7

Safety, Health and Environmental Orientation

The Moreno Group LLC and Subsidiaries Yard Foreman / Offshore Superintendentor designee shall conduct or coordinate a Contractor Safety, Health andEnvironmental Orientation for all the contractor’s employees. The orientation shouldbe conducted prior to beginning work and include the following information:

Confirm SH&E Training Documentation is on-site (see attachments).

Instructions to the Contractor to report any unique hazards that may developfrom their work activities to the Moreno Group LLC and Subsidiaries YardForeman, First Line Supervisors or Offshore Superintendents.

Instructions to the Contractor to report any hazards identified by them and allincidents to the Moreno Group LLC and Subsidiaries Yard Foreman, First LineSupervisors or Offshore Superintendents

Requirements to conduct Daily SH&E Meetings and/or Job Safety &

Environmental Analysis.

Work-in-progress Activities

The purpose of work-in-progress activities are to ensure that Safety, Health andEnvironmental objectives are being achieved and managed.

The Yard Foreman / Offshore Superintendents or designee shall monitor theContractor’s job performance and conformance with SH&E requirements. Work-in-progress audits will be incorporated into the Weekly or Monthly Hazard Assessmentprocesses. Upon completion of the work-in-progress audits, the Yard Foreman /

Offshore Superintendent or designee should provide counseling to the Contractorand/or take action as required. This counseling shall be documented and retainedand forwarded to the Project Manager of the project to discuss with the ContractorsManagement.

As part of the Work-in-progress processes documentation may be requested toverify that Contractors are conducting daily tailgate meetings, and new workerorientation. This shall be documented during Moreno Group LLC and SubsidiariesHazard Assessments Checklist (Weekly).

Moreno Group LLC and Subsidiaries Inc. Project Managers will tabulate and provide

to the SH&E Department on a quarterly bases the man hours accumulated by thesubcontractors on our projects. The SH&E Department will provide these man hoursto our clients upon request.

Trade Secrets

Employers shall make all information necessary to those persons responsible forcompiling the process safety information required by CFR 1910.119(d) withoutregard to trade secrets status of such information:



D1.8

Assisting in the development of the process hazard analysis (required byparagraph (e) of the standard

Responsible for developing the operating procedures required by paragraph(f)

Involved in incident investigations required by paragraph (m)

Emergency planning and response required by paragraph (n) and

Compliance audits within paragraph (o).

Nothing in this paragraph shall preclude the employer from requiring the personto whom the information is made available under paragraph (p)(1) of 1910.119 toenter into a confidentiality agreement not to disclose the information as set forthin 29 CFR 1910.1200.

Pre and Post Job Meetings

As required all Contractors and Subcontractors will be expected to participate in allPre and Post Job Meetings. Pre meetings may be used to communicate SH&EExpectations, Scheduling of Personnel, Materials and Project, and Review of ProjectScope. Post Job meetings may be utilized to review project performance. At aminimum the following areas shall be reviewed: SH&E Performances (lagging andleading indicators), the meeting of project schedule requirements, and any lessonlearned during the project.



D1.9

Attachment 1





D1.9.a.1

SAFETY, HEALTH AND ENVIRONMENTAL GENERIC QUESTIONNAIRE

(Form: SSQ 1.0)

NAME OF COMPANY AND ADDRESS: Date: ______________________________

__________________________________ Contact: ____________________________

__________________________________ Form Completed by: __________________

__________________________________ Phone #: ___________________________

__________________________________ Fax #: _____________________________

__________________________________ SIC # _____________________________

Please describe the services your company provides:

Please see attached cover letter.

The information requested must be for the local Division, District, Branch, etc. of yourcompany. We are not interested in overall statistics at a national or internationallevel. All Information must be documented.

1. Please describe the area or region this questionnaire applies (i.e. local Division,District, Branch).

2. In the table below, provide the three most recent full years of incident information foryour company. See "Attachment 1, Definition of Terms" for details.

In addition to completing the tables, attach copies of your company's OSHA 300log for the last three full years. If your company is not required to complete an

OSHA 300 log, provide copies of other appropriate industry-relateddocumentation, e.g. ADC, etc. We require verification of the EMR/discount rateinformation, see "Attachment 1" for details.

Year AverageNumber ofEmployees

Exposureor

EmployeeHours

Number ofRecordable

Cases

IncidenceRate of

RecordableCases

Number ofLost

WorkdayCases

IncidenceRate of

LostWorkdayCases

Number ofLost

WorkdaysSeverity

RateEMR

Number ofFatalities

3. Specify the basis for exposure or employee hours (8 hr shifts, 12 hr shifts, 24 hrs, etc.)

4. If your company is self-insured, what is your discount rate?

Comments _________________________________________________________ __________________________________________________________________ __________________________________________________________________ __________________________________________________________________



D1.9.a.2

5. Has your company received any inspections from a regulatory agency during the lastthree years?

Yes____ No____

If yes, please provide details: ____________________________________________ ___________________________________________________________________

6. Has your company received any citations from a regulatory agency during the last

three years?

Yes____ No____

If yes, please provide details: ____________________________________________ ___________________________________________________________________

7. Are all documents, pertaining to this questionnaire, available for auditing?

Yes____ No____

If no, please explain: ___________________________________________________

___________________________________________________________________

8. Please respond to ALL items with "Yes ,No, or N.A." Do not leave any itemsunanswered. (Estimated Percentage of Employees should reflect the percentage ofemployees who are required to have the training - not the percentage of the totalnumber of employees in your organization):

PROGRAMS/TRAINING Reference

Source

Program

Documentedand Written

Yes/No/NA

Estimated

Percentage of

Employees

Receiving

Training

Frequency ofTraining forIndividual

Employees

Individual

EmployeeTraining

Documented

Yes/No/NA API T-1 API RP T-1

Bloodborne PathogensOSHA 29 CFR

1910.1030(g)(2)

Confined Space Entry -Entrant Level

OSHA 29 CFR1910.146(g)

Confined /space Entry - Attendant Level

see above

Confined Space Entry -Supervisor Level

see above

Confined Space Entry –

Rescuer see above

Cranes API RP 2D

Defensive Driving OSHA Proposed

DOT HM-126F HazmatEmployee

DOT 49 CFR172.704

Drug AwarenessDOT 46 CFR

16.401 & 391.119



D1.9.a.3


Source

ProgramDocumentedand Written

Yes/No/NA

EstimatedPercentage of

Employees

ReceivingTraining

Frequency ofTraining forIndividual

Employees

IndividualEmployeeTraining

Documented Yes/No/NA

Electrical SafetyOSHA 29 CFR

1910.332

Emergency Response OSHA 29 CFR1910.38(a)

First Aid/CPROSHA 29 CFR

1910.151(b)

ForkliftsOSHA 29 CFR

1910.178(l)

Generic Safety OrientationOSHA 29 CFR1910.119(h)(3)

H2SMMS 30 CFR

250.67

HAZCOMOSHA 29 CFR1910.1200(h)

Hazwoper - Awareness LevelOSHA 29 CFR

1910.120

Hazwoper 8 Hour see above

Hazwoper 24 Hour see above

Hazwoper - 40 Hour see above

Hazwoper Supervisor 8 hour see above

Hearing ConservationOSHA 29 CFR

1910.95

Incipient Fire FightingOSHA 29 CFR

1910.157(g)

Lead WorkerOSHA 29 CFR

1926.62(l)

Lead Supervisor see above

Lockout/Tagout - AuthorizedPerson

OSHA 29 CFR1910.147(c)(7)

Lockout/Tagout -AffectedPerson

see above

Lockout/Tagout - Other see above

Personal Protective Equip.OSHA 29 CFR

1910.132(f)

Process Safety Mgmt.OSHA 29 CFR1910.119(g)(1)

Production Safety Systems T-2MMS 30 CFR

250.214

Respiratory ProtectionOSHA 29 CFR1910.134(e)(5)

Welding and Burning

OSHA 29 CFR1910.252(a)(2)(xii)

(c)MMS 30 CFR

250.52



D1.9.a.4


Source

ProgramDocumented

and Written

Yes/No/NA

EstimatedPercentage of

EmployeesReceiving

Training

Frequency ofTraining for

IndividualEmployees

IndividualEmployee

TrainingDocumented

Yes/No/NA

WellControl/Completion/Workover

MMS 30 CFR250.212-213

Manual Lifting Techniques N/A

Rigging/Material Handling N/A

Supervisory Skills N/A

Survival Craft N/A

Total Quality Management N/A

Water Survival (classroom) N/A

Water Survival (practical) N/A

Work/Post Injury Management N/A

9. Please provide any additional information on other industry-specific programs or

training, including written procedures, which your company provides to employees: ___________________________________________________________________

10. Does your company comply with the Process Safety Management provisions found in29 CFR 1910.119 and/or API RP 75?

Yes____ No____

Comments: __________________________________________________________

___________________________________________________________________

11. Does your company have scheduled documented employee safety meetings?

Yes____ No____

If yes, how often: _____________________________________________________

12. Who conducts the safety meetings? Job Title:

13. What managers/supervisors participate in the safety meetings?

JobTitles: ___________________________________________________________

14. Are meetings reviewed and critiqued by manager/supervisors? Yes____ No____

15. What were the topics or issues discussed at the last two safety meetings?

Topics/Issues: Meeting Date:________________________

Topic/Issues: Meeting Date:________________________



D1.9.a.5

16. Does your company hold on-site (tailgate/toolbox/pretour) safety meetings?

Yes____ No____

If yes, how often? _____________________________________________________

17. Who conducts these safety meetings? Job Title: ____________________________

Is documentation available? Yes____ No____

18. Does your company perform Job Safety Analysis (JSA)? Yes____ No____

19. Does your company provide/require the following personal protective equipment: ___________________________________________________________________

___________________________________________________________________

___________________________________________________________________

___________________________________________________________________

COMPANY COMPANYPROVIDED REQUIRED

Hard hats(ANSI-Z89.1)(29 CFR 1910.135) NA___ Yes___No___ Yes___No___

Safety shoes(ANSI-Z41.1)(29 CFR 1910.136) NA___ Yes___No___ Yes___No___

Eye protection(ANSI-Z87.1)(29 CFR 1910.133) NA___ Yes___No___ Yes___No___

Hand protection(29 CFR 1910.132) NA___ Yes___No___ Yes___No___

Hearing protection(29 CFR 1910.95) NA___ Yes___No___ Yes___No___

Fall protection(29 CFR 1910.129) NA___ Yes___No___ Yes___No___

Respiratory protection(29 CFR 1910.134) NA___ Yes___No___ Yes___No___

Personal Flotation Devices(33 CFR 142.45) NA___ Yes___No___ Yes___No___

20. In addition to regulatory required the Personal Protective Equipment , what other PPEis required or supplied? _______________________________________________

___________________________________________________________________



D1.9.a.6

21. If any, please describe or list: ____________________________________________

___________________________________________________________________

22. Does your company have a written policy regarding drug screening or testing of youremployees?

Yes____ No____ Comments: ___________________________________________

___________________________________________________________________

23. Does your drug testing program conform to DOT requirements?

Yes____ No____

Comments: _________________________________________________________

___________________________________________________________________

If yes, which set of DOT regulations is your drug testing program designed to satisfy?

Federal Aviation Administration Yes____ No____

United States Coast Guard Yes____ No____

Research and Special Projects Administration - Pipeline Yes____ No____

Federal Railroad Administration Yes____ No____

Federal Highway Administration Yes____ No____

24. Indicate the circumstances in which your company's employees may be subject to

drug screening.

( ) Employment ( ) Probable Cause ( ) Periodic( ) Random ( ) Post Accident Other:

25. Does your company have policy requiring written accidents/incident reports (spills,injuries, property damage, etc.)?

Yes____ No____

26. Does your company conduct accident/incident investigations? Yes____ No____

If yes, please attach a brief outline of procedures: ___________________________

___________________________________________________________________

27. Does your company document, investigate, and discuss near miss accidents?

Yes____ No____

If yes, is documentation available? Yes____ No____



D1.9.a.7

28. Are accident/incident reports reviewed by managers/supervisors? Yes____ No____

29. Does your company use subcontractors? Yes____ No____

If yes, explain: ________________________________________________________

___________________________________________________________________

30. Does your company review the safety management systems of subcontractors?

Yes____ No____

31. Does your company verify that subcontractors meet or exceed your safety and trainingrequirements?

Yes____ No____

If no, explain: ________________________________________________________

___________________________________________________________________

32. Describe the programs utilized to monitor the safety performance of your company todetermine progress (for example, management meetings, safety committee/team,statistical reports, etc.):

___________________________________________________________________

___________________________________________________________________

___________________________________________________________________

___________________________________________________________________

33. Does your company have a safety manual with a clearly written safety policyendorsed by upper management?

Yes____ No____ Comments: ___________________________________________

34. Does your company perform safety audits/reviews? Yes____ No____

If yes, are safety audits documented? Yes____ No____

35. Who reviews the safety audit/review and how often? Job Title:

Comments: ________________________________________________________

36. Does your company involve its employees in health, safety, and environmentalawareness programs? Yes____ No____

If yes, describe how they are involved: ____________________________________



D1.9.a.8

37. Who in your company is responsible for coordinating your health, safety andenvironmental program? Job Title:

Is safety a full time responsibility for this position? Yes____ No____

If no, list the percentage of time devoted to safety:

38. Does your company have a Safety Incentive/Recognition Program. Yes____ No____

If yes, please describe: ________________________________________________

39. Does your company have a written environmental program? Yes____ No____

If yes, describe the training and documentation aspects of the program:

__________________________________________________________________

40. Is your company required to have any Federal, state, or local licenses or permits toperform your service(s) (for example, NORM, asbestos, DOT, etc.)?

Yes____ No____

List types of licenses/permits and state of issue:

__________________________________________________________________

Having completed this survey, do you have any additional comments or questions todiscuss? __________________________________________________________________

__________________________________________________________________



D1.9.a.9

DEFINITION OF TERMS

Year List the three most recent full calendar years. Specify months, if less than a fullyear.

Average Number of Employees List the average number of employees worked during the year. An employee shall

be defined as any person engaged in activities for an employer from whom directpayment for services is received. Included are working owners and officers.

Exposure or Employee Hours

List the total number of hours worked during the year by all employees, includingthose in operating, production, maintenance, transportation, clerical, administrative,sales, and other activities.

Number of Recordable Cases List the total number of recordable cases that occurred during the year. A

recordable case will be defined as any work-related injury case requiring more thanfirst aid, and all occupational illnesses. Recordable cases include all occupationalillnesses, and all occupational injuries resulting in lost workdays - either days awayfrom work or days of restricted work activity, medical treatment other than first aid,loss of consciousness, restriction of work or motion, temporary or permanenttransfer, or the termination of an injured or ill employee.

Incidence Rate of Recordable Cases = Number of recordable cases X 200,000Exposure or employee hours

Number of Lost Workday Cases List the total number of lost workday cases that occurred during the year. A lost

workday case will be defined as any recordable case that results in death or lostworkdays with days away from work. For the purposes of this questionnaire,recordable cases that result in lost workdays with restricted activity should not beadded in this column. Only recordable cases that result in one or more days awayfrom work should be counted.

Incidence Rate of Lost Workday Cases = Number of lost workday cases X 200,000Exposure or employee hours

Number of Days Away from Work

List the total number of lost workdays experienced by all employees during the year.For the purposes of this questionnaire, lost workdays with restricted activity shouldnot be added in this column. Only recordable cases that result in one or more daysaway from work should be counted.

Severity Rate = Total number of lost workdays X 200,000Exposure or employee hours



D1.9.a.10

EMR - Experience Modification Rate

We require verification for the EMR and discount rate data requested in thequestionnaire. Any of the following methods would be acceptable:

A letter from your insurance agent, insurance carrier, or state fund (on theirletterhead) verifying the EMR or discount rate data listed above; or

A copy of the last three years' Experience Rating Calculation Sheets, whichyour insurance carrier should forward to you annually; or

A copy of the page of your last three years' insurance policies that show themodification rate and the coverage period.

Number of Fatalities

List the total number of fatalities that result from occupational injuries or illnesses.Deaths, which occur in the workplace but are not the result of occupational injuriesor illnesses should not be included.

Additional Information

Additional information concerning injury and illness recordkeeping can be found in29 CFR 1904 and OSHA's "Recordkeeping Guidelines for Occupational Injuries andIllness" booklet.



D1.10

Attachment 2





D1.10.a.1

CONTRACTOR SAFETY, HEALTH AND ENVIRONMENTALMANAGEMENT SYSTEM ASSESSMENT

Contractor Name: ________________________________________________________________

Location: _______________________________________________________________________

SH&E System Component Acceptable Needs Improvement Not Acceptable

SH&E Plan

SH&E Staff

SH&E Work Procedures

Substance Abuse & Contraband

Audits & Inspections

Employee Training

New Hires

Continuous

Management

Records Management

Hazard Control


Sub-Contractors N/A

SH&E Manual

Incident Reporting & Investigation

SH&E Meetings

Acceptable Components: ________ X 3 = _______

Needs Improvement ________ X 1 = _______

Total Score _______ Transfer total score to ContractorComposite Score Worksheet

Conducted by: ___________________________________________________________________

Date: __________________________________________________________________________





D1.11

Attachment 3





D1.11.a.1

CONTRACTOR FACILITY ASSESSMENT CHECKLIST

Contractor Name: _________________________________________________________________

Location: _______________________________________________________________________

Activity Observed: ________________________________________________________________

Acceptable Needs Not N/AImprovement Acceptable

HOUSEKEEPING

Are aisles clear and unobstructed?

Are waste containers emptied?

Are work areas clean and organized?

Are work areas adequately illuminated?

TOOLS & EQUIPMENT

Are tools/equipment in good condition?

Are the correct tools/equipment being used?

PERSONAL PROTECTION EQUIPMENT

Is the necessary PPE available and being used:

Hard Hats

Eye Protection

Face Protection

Respiratory Equipment

Foot Protection

Hand Protection

Proper Work Clothing

Hearing Protection

Personal Floatation Devise



D1.11.a.2

Acceptable Needs Not N/AImprovement Acceptable

WORK PRACTICES

Are employees working in a safe manner?

Are employees obeying posted warning signs?

Did the company conduct a pre-job meeting?

Are items properly locked and tagged?

Are work permits completely fi lled out?

Are work permits posted?

Are containers properly labeled?

Are MSDS readily available?

Is material handing equipment being

properly operated?

Is material handling equipment being

inspected?

Is machinery adequately guarded?

Is adequate fire protection

equipment on location?

Are fall hazards adequately controlled?

Are flammable substances properly stored?

Is spill containment provided for chemicaldistribution areas?

Are adequate first aid facilities provided?

Acceptable Components: ________ X 0.5 = _______ [N/A’s will be credited for 0.5 point]

Needs Improvement: ________ X 0.25 = _______

Total Score _______ Transfer total score to Contractor

Composite Score Worksheet

Conducted by: ___________________________________________________________________

Date: __________________________________________________________________________



D1.12

Attachment 4





D1.12.a.1

CONTRACTOR COMPOSITE SCORE WORKSHEET

Contractor: ________________________________________________________

Incident Rates _________

EMR _________

SH&E Management Systems Assessment _________

Site Assessment _________

Sub-total _________

Deductions

Fatalities _________

Sub-total _________

TOTAL SCORE _________

RATING

Approved 80 - 100

Conditional 60 - 79

Non-Acceptable < 60

Performed by: _____________________________________________________

Date: ____________________________________________________________





D1.13

Attachment 5





D1.13.a.1

Below are minimal requirements for Moreno Group LLC and Subsidiaries Facilities






Management System

EmergencyPreparedness

Page: 1 of 19Original: 01/01/2001

Revised: 01/01/2010

E1.1


Purpose

The purpose of the emergency preparedness plan is to provide methods ofevacuation of Moreno Group LLC and Subsidiaries facilities during emergencysituations.

Scope

To provide minimum requirements for safe evacuation of Moreno Group LLC andSubsidiaries Facilities for potential emergency situations.

Responsibilities

The Facility / Facility Manager or Designee is responsible for :

Providing the necessary leadership and resources to execute this procedure

Develop, implement and continuously evaluate a Facility / Office Site SpecificEmergency Evaluation Procedure.

Assuring evacuation routes are established and clearly marked

Establishing a head count procedure

The First Line Supervisor or Sub-Contractor is responsible for:

Understanding and complying with their Facility’s Emergence Evacuation Plan.

Overseeing the activities of personnel to ensure emergency reporting andresponse procedures are followed.

Conduct a head count of their personnel upon arriving to the designatedassembly area.

Updating and answering their employees’ questions pertaining to this plan.


Provide assistance to Facility Management and the First Line Supervision in thedevelopment, implementation and continuous improvement of their Site SpecificEmergency Evacuation Plan.

Coordinating and conducting Emergency Preparedness Training.



E1.2


Under standing and complying with their Facility’s Emergency Evacuation Plan.

Completing the required training on this procedure.

Conferring with supervision as to any suggestions to improve emergencyreporting and response procedures.

Responding to emergencies to the extent of their abilities and training.

Definitions

Conditions - Indicates that winds, surges or waves, flooding or any combination ofthose typical of a hurricane or a tropical storm are possible.

Convection - Atmospheric motions that are predominately vertical, resulting in the

transport of properties such as heat and moisture vertically. Cumulus clouds andthunderstorms are examples of phenomena associated with convection.

Designated Assembly Area - An area that employees for the facility will assemble atduring an emergency. The Facility Manager or designee will determine the facilityDesignated Assembly Area.

Hurricane Hunters - A reserve group of the U.S. Air Force that flies reconnaissanceflights into tropical disturbances, tropical storms and hurricanes to gather data, whichaids in tracking and forecasting tropical weather systems.

Hurricane Rain / Flooding - Hurricanes and weaker tropical cyclones can causetremendous rainfall and result in massive flooding. Historically, most deaths intropical cyclones are associated with fresh water flooding.

Storm Surges - Increase in sea level water height from the average water height withno hurricane. Some hurricane deaths are associated with storm surges, but farfewer than in the past because widespread evacuations have been implemented.Typically, the stronger the hurricane winds, the greater the storm surge height.

Tornado - Recognized as a funnel-shaped cloud that spins rapidly and extendstowards the ground from the base of a thundercloud.

Tropical Cyclone - A warm-core low-pressure system which develops over tropicaland sometimes sub-tropical waters and has an organized circulation.

Tropical Depression - A tropical cyclone in which maximum sustained surface windsare 38 mph (38 knots) or less. Tropical depressions characteristically have one ormore closed isobars.

Tropical Disturbance - A discrete system of organized convection that originates inthe tropics and maintains its identity for 24-hours or more.



E1.3

Tropical Storm - A tropical cyclone in which maximum sustained surface winds are39 mph to 73 mph. Tropical storms are given names. The same names continues ifthe circulations happen to strengthen to hurricane intensity.

Requirements

Each Facility / Office Manager shall develop and implement a site specific

Emergency Evaluation Plan for their facility. Attachment 1 contains a generic officebuilding Emergency Evacuation Plan that may help facilitate in the development ofthe Site Specific Plan for Office Buildings.

Prior to the development of any office Site Specific Emergency Evacuation Plan, theoffice manager shall ensure our plan does not conflict with the evacuation plandeveloped by the building owner and/or Management Company. The plan shouldeither be posted in the facility or made readily available for the employees to review.

Coordinator of Emergency Action Plan

All Supervisors shall be responsible for updating, answering any questions andexplaining employee’s responsibilities under this plan.

Decision to Evacuate

In the event of fire, explosion, bomb threats or bad weather it may be necessary toevacuate the site or an area of the facility. If the need arises, the Facility Manager orhis designee should make the decision. Evacuation should be ordered if a situationcould endanger life or health of the personnel.

Evacuation Alert Procedure

The Facility Manager or his designee who orders the evacuation will make anannouncement over the public address system that the site must be evacuated dueto an emergency situation. If the public address is not working, alert otheroccupants by word of mouth and/or by radio. If an area is to evacuate, anannouncement will be made indicating said area is to be evacuated and closed off.Do not enter that area until the barricades are removed. After the evacuation alerthas been made, the person ordering the evacuation will call the local emergencyagency or 911, if needed.

Evacuation Procedure

Fabrication Yards

Upon hearing the announcement or alarm, all personnel on site will stop whateverthey are doing. All equipment, tools and power sources should be turned OFF beforeevacuating facility (provided it is safe to do so). Personnel working in offices willclose office doors, windows, and other doors on the way out and proceed directly todesignate emergency exits. Department managers shall ensure that all occupants intheir area are out of their offices and conference rooms and that their area iscompletely vacated. Turn off the lights in each office and close the doors. Notify the



E1.4

Facility Manager that your area is vacated and proceed to evacuate yourself.Evacuation routes shall be located in strategic locations throughout the facility.

While employees are evacuating, they shall try not to walk through smoke or vaporclouds. If employees are caught in such a situation, they shall make notice of windsocks to determine wind direction; they shall then walk at right angles to the winddirection to exit the cloud and to find an upwind evacuation route. Wind socks are

located at the top of the east and west ends of both fabrication buildings and the topof the pile rack.

The evacuation route plan will show the evacuation route; emergency exits. Afterexiting shops, work areas or buildings, all personnel will exit the site by the nearestexit. All personnel will meet at Designated Assembly Area for a head count. TheFacility Manager and/or the SH&E department will be the last to evacuate. They willthen proceed to the Designated Assembly Area. After the site has been evacuated,a decision will be made if further steps must be taken.

If handicapped or disabled personnel are in the group being evacuated, a two-man

team is to be designated by the department manager to assist. The two-man teamand the disabled person shall be the last to evacuate, to avoid the possibility ofbeing shoved by individuals coming from behind them. The team is to inform theFacility Manager that the disabled persons are evacuated.

Support Offices within Fabrication Facilities

Upon hearing the announcement or alarm, all personnel will stop whatever they aredoing. Personnel working in buildings will close windows, doors and all doors on theway out. They will proceed directly to designate emergency exits.

Department managers shall ensure that all occupants in their area are out of theiroffices and conference rooms and that their area is completely vacated. Turn off thelights in each office and close office doors. Notify the Facility Manager that your areais vacated and proceed to evacuate yourself. Evacuation routes shall be located instrategic locations throughout the facility.

The evacuation route plan will show the evacuation route, emergency exits and fireextinguisher locations. After exiting the buildings, all personnel will exit the site to theappropriate Designated Assembly Area for a headcount.

The Facility Manager and/or designee will be the last to evacuate. They will then go

to the Designated Assembly Area.

If handicapped or disabled personnel are in the group being evacuated, a two-manteam is to be designated by the Facility Manager to assist. The two-man team andthe disabled person should be the last people to evacuate, to avoid the possibility ofbeing shoved by individuals coming from behind them. The team is to inform theFacility Manager that the disabled persons are out.



E1.5

Procedure to account for personnel

Upon arriving to the designated assembly area, each supervisor or designee shallaccount for their personnel. Upon completion of the head count, the supervisor shallnotify the Facility Manager or his designee of the total number of personnel presentand total number missing. The receptionist(s) shall use the visitor logbook accountfor all visitors.

Training / Bi-Annual Drills

During the initial Facility Orientation employees and visitors shall receive training onthis procedure. In addition to the initial facility orientation, employees shall receivedadditional training on their assigned responsibilities (Fire Warden, etc.) under thisplan anytime these responsibilities change or this plan changes. Each facilityevacuation plan shall be kept in writing, maintained and available to all employeesand visitors to review. Any questions or concerns shall be addressed to the FacilityManager or designee.

Bi-Annual Drills are to be conducted by Facility Management. All departmentmanagers are to be notified as to the timing of these drills.

Participation in the drills is mandatory for all Facility occupants (whether employeesor visitors).

After the drill has been conducted Facility Management, Supervision and the SH&EDepartment shall meet to critique the drill. Minutes of this critique meeting should bekept and maintained.

Extinguishing Fires

If it is determined that the fire can be controlled with fire extinguishers, anothermember of the staff must be alerted of the fire emergency to assist withextinguishing the fire and to alert the Facility Manager or his designee of the fireemergency. If the fire cannot be controlled with fire extinguishers, the Local FireDepartment must be called and the site evacuated.

In Case of Fire or Fire Alarm (simple procedure)

Notification

If you see smoke, flames, smell smoke, or hear a fire alarm, immediately call theLocal Fire Department (911).

If you think you smell a peculiar or unfamiliar odor, immediately call the Local FireDepartment (911):

Information to be given to the Fire department:

What is on fire



E1.6

Address

Type of occupancy

Telephone number

Listen to dispatcher; always let dispatcher hang up first.

Emergency procedures if you see smoke, flames or smell something burning:

Isolate fire (close door, if possible)

Call the fire department

Make announcement on PA system

Evacuate

Extinguish fire

Emergency procedures in the event of an alarm only:

Notify fire departmentMinimum procedures: proceed to Designated Assembly Area for furtherinstruction and head count.

Important Things to Know

When the Fire Department arrives, the officer is in charge

Special Instructions for the Mobility Impaired

Individuals having any mobility impairment need to be considered prior to anyneed for evacuation. It is necessary for department managers to ensureassistance is available for any mobility-impaired employee that may requirespecial assistance in the event of an evacuation. A list of these employeesshall be kept with this plan.

After Hours

If you see smoke, flames, smell smoke, or hear a fire alarm, do the following:

Isolate the fire by closing the door.

Notify the fire department by calling 911.

NEVER assume that someone else has called the Local Fire Department.

Threats

If anything suspicious occurs (such as threatening phone calls), remain calm, andget as much specific information as possible (i.e. location of bomb or intentions), tryto keep the person on the phone, and notify the Facility Manager immediately. Tryto get as much information from the caller as possible as to the nature and details ofthe threat.



E1.7

Keep all written threats, notes on threatening calls or unusual occurrences so thatthe Facility Manager can evaluate the threat.

The Facility Manager is to notify the Safety, Health and Environmental Departmentfor instructions in the event of any threatening calls or situations.

Violent Disturbances

Workplace violence can be of various types and origins. Upon Notification of aviolent act or disturbance, which threatens the facility or employees, the FacilityManager or designee will immediately, contact local authorities?

Any employee may make this initial notification once that employee is secured in asafe area.

The following information should be obtained:

Location of disturbanceNumber of distracters

Distracters activities

Identification of distracters

The Facility Manager or designee will asses the situation and determine theappropriate course(s) of action based upon the available information. If necessary,public address notification of the disturbance will be communicated to all personnel.

Employees are to remain clear of disturbance and should not attempt to resolve theconflict. Local authorities may be contacted to address appropriate situations.

The Facility Manager or designee shall secure the area of a violent disturbance topreserve anything that maybe considered evidence and must not allow any items tobe removed or disturbed unless directed by Law Enforcement Authorities.

The Facility Manager or designee should lock down the facility and not allow anyoneto enter the facility without prior approval from the Facility Manager or designee.

The Facility Manger or designee shall also work with authorities to secure anywitness statements.

Be alert to any suspicious personnel, visitors or objects.

Medical Emergencies

Personnel: Call the immediate supervisor and the SH&E Department

Call 911, if an ambulance is needed.

Supervisor: Call your immediate manager to report the injury or illness



E1.8

If the injured/ill person is sent to the hospital, the employee’s immediate supervisor or designated individual should accompany him/her to assist at thehospital until relatives arrive.

Designated Company Physicians:

New Iberia, La./ Lafayette La.

Med Xcel Iberia General Hospital

106 Heritage Parkway 2315 E. Main St.

Broussard, LA 70518 New Iberia, LA 70560

(337) 856-7500 (337) 364-0441

Our Lady of Lourdes

611 St. Landry Dr.

Lafayette, LA 70506

(337) 289-2000

Harvey, La.

Dr. David Reiss West Jefferson Medical Center

Elmwood Industrial Medical Center 1101 Medical Center Blvd.

5800 Plauche Center Marrero, LA 70072

Harahan, LA 70123 (504) 347-5511

(504) 733-5885

J. Serio, M.D.

Health South7772A Highway 23Belle Chasse, La. 70037

(504) 349-6363

Dr. Neil Notaroberto (Eye Doctor)

1939 Hicory Avenue Suite 101

Harahan, La.

(504) 737-3456

Houma, La.Occupational Medical Services Terrebonne General Medical Center

Dr. Sweeny or Dr. Davis 8166 Main Street

144 Valhi Lagoon Crossing Houma, LA 70360

Houma, La 70360 (985) 873-4141

(985) 223-0032



E1.9

Lake Charles, La

Business Health Partners Lake Charles Memorial Hospital

299 B Cities Service Highway 1900 W Gauthier Rd,

Sulphur, La. 70663 Lake Charles, LA 70605

(337)626-1011 (337) 480-7000

Fax : (337) 626-0656Christus St Patrick Hospital

8559 Gulf Hwy,

Lake Charles, LA 70607

(337) 474-7238

Port Sulphur, La

Plaquemines Medical Center

374 Civic Drive

Port Sulphur, la 70083(985) 564-3344

Mobile, Al.

Infirmary Health System

Doug Daniel (contact)

305 N. Water Street

Mobile, Al.

(251) 431-5800

Baytown, TX

Bay Coast Medical Ctr. San Jacinto Methodist Hospital

2610 S Highway 146 4401 Garth Rd.

Baytown, TX Baytown, TX

(281) 420-6100 (281) 420-8600

Bay Coast Medical Ctr. San Jacinto Methodist Hospital

Corpus Christi, TX

Bay Area-Corpus Christi Med Columbia Bay Area Medical Ctr.

7101 S Padre Island Dr. 7101 S Padre Island Dr.Corpus Christi, TX Corpus Christi, TX

(361) 761-1200 (361) 985-1200



E1.10

Columbia Doctors Regional Med Heart Hospital

3315 S. Alameda St. 7002 Williams Dr.

Corpus Christi, TX Corpus Christi, TX

(361) 857-1400 (361) 761-6800

Emergency Room Northwest Regional Hospital

2606 Hospital Blvd. 13725 Fm 624

Corpus Christi, TX Corpus Christi, TX

(361) 902-4151 (361) 241-4243

Spoh Hospital Thomas Moloney

600 Elizabeth St. Nueces Occupational Med. Clinic

Corpus Christi, TX 7406 Up River Road

(361) 885-0854 Corpus Christi, Tx. 78409

(361) 289-2890

(361) 289-2963 (fax)

Galveston, TX

University of Texas Med. Ctr.

301 University Blvd.

Galveston, TX 77555

(800) 335-0065

Houston, TX

Patricia Janki, M.D.

12080 East Freeway

Houston, TX 77029

(713) 330-4325

(713) 330-1910 (fax)



E1.11

Pasadena, TX Harris County Hospital Dist.

Bayshore Medical Ctr. 925 Shaw Ave.

4000 Spencer Hwy. Pasadena, TX

Pasadena, TX (713) 740-8180

(713) 944-6666

Kirkwood Medical Associates Memorial Hospital Pasadena

Occupational Clinic 908 Southmore Ave #370

4001 Preston, Suite 100 Pasadena, TX

Pasadena, Texas 77505 (713) 475-5803

(281) 249-2244

(281) 249-2281 fax

Occupational Medical Care

Louis F. Puig, M.D.3692 E. Sam Houston Pkwy. S.

Suite 100

Pasadena, TX

(281) 998-2323

(281) 998-2329

Texas City, TX

Mainland Medical Ctr.

6801 Emmett F Lowry ExpyTexas City, TX

(409) 938-5000

International

Cabinda, Angola

Ludmed, Ida.

Rau de Macau

Cabinda, Angola

Phone: +244-2312-24755

Fax: +224-2312-23358



E1.12

Luanda, AngolaTalatona ClinicRua S10 Sector Talatona Zona CCB2proximo ao Belas shoppingTelephone:923 330 843Fax: 222 399263

Emergency after Hours: 923 330 845

Air Ambulance ServiceInternational SOS Assistance(Pty) LtdOpen 24 hours a dayTelephone:27(11) 541 1300 / 1350

Fax: 27 11 541 1076

Ilha Clinic

Rua Murtala Mohamed - ClinicaSagrada EperançaTelephone:923 330 845 / 917 485 834Fax: 222 309 033

Attn: International SOS Angola, Lda

Port of Spain, TrinidadPort of Spain General HospitalCharlotte Street, Port of SpainTrinidad, West IndiesTelephone: +1 809 623 2951

Couva District HospitalCouva, Central Trinidad, WITelephone: +1 809 636 2411

Serpentine Road Family Clinic/Dermatology/Physiotherapy4 Serpentine RoadSt. ClairPort of SpainTelephone: 868-622-4331

Princes Town District HospitalPrinces Town, Trinidad, WITelephone: +1 809 655 2255

655-2255 (Tel)

Puerto Ordaz, VenezuelaCeciamb Clinic

Avenida Atlantico, Edificio CCCCD,Local Pt-1, Urbanization Rio CauraPuerto Ordaz City, Bolivar State,Venezuela Phone Number: 00-58-286-9522658

Fax Number: 00-58-286-9519383

Uyapar HospitalJardin Levante, AltaVista SurPuerto Ordaz City, Bolivar State,VenezuelaPhone: 00-58-286-9622072 or00-58-286-9625159



E1.13

Hurricane Procedures

Hurricane season is from June through November, with the majority of hurricanesoccurring during August and September. The best defense against storm damage isalertness and prior preparation. For instructions covering hurricane preparednessand evacuation procedures, personnel should become familiar with their localhurricane preparedness plans that are specific to that region, district or area.

Hurricane Alerts Categories

Tropical Storm Watch - Tropical Storm conditions are possible in your area withinthe next 36-hours.

Tropical Storm Warning - Tropical Strom conditions are expected in your area within24-hours.

Hurricane Watch - Hurricane conditions are possible in your area within the next 36-

hours.

Hurricane Warning - Hurricane conditions are expected in your area within 24-hours.

Saffir-Simpson Scale

Hurricanes vary in wind strength, central barometric pressure, size storm surgeheight and destructive potential. A classification scale, which includes Categories 1to 5, commonly used rate the damage potential of a hurricane is called the Saffir-Simpson Scale.

Category Winds (MPH) Storm Surge5 > 155 > 18’

4 131 -155 13’ - 18’

3 111 - 130 9’ - 12’

2 96 - 110 6’ - 8’

1 74 - 94 4’ - 5’

Phases of Hurricane Evacuation Plan

Phase I (General Hurricane Season Precautions) - Automatically will go into effecton June 1 and will remain in effect throughout hurricane season (June 1 through

October 31).

Phase II (Pre-Hurricane Procedure) - Automatically go into effect whenever ahurricane or tropical storm enters into or threatens to form anywhere in the Gulf ofMexico.

Phase III (Securing for Hurricane and Preparing for Evacuation) - Will only go intoeffect upon orders from the Facility Manager or designee. The decision to place afacility in Phase III status will be based upon evaluating the intensity, position andforward speed of the storm; the wind and sea conditions in each area; the location,



E1.14

condition and accessibility of each facility and decisions of Local and/or Stateauthorities.

Phase IV (Facility Evacuation) - Will go into effect upon orders from the FacilityManager or designee but can be expected to automatically follow Phase III. It maybe applied to a facility, but not necessarily our entire operations simultaneously.

Phase I (General Hurricane Season Precautions)

During Phase I, all workplace assessments shall be performed per the Auditand Assessment section of this manual. Deficiencies are to be documented, awork-order developed and issued to the supervisor to be repaired promptly.

All loose material and equipment on facility are to be properly stored andmaintained in a secure manner.

All junk items to be classified as such and sent for disposal or scrap recycler.

All facilities must verify that they have an ample supply of rope, tarpaulin orclear, heavy, plastic wrap available.

All Supervisors and Facility Managers are to maintain and keep in theirpossession a current list of correct addresses and telephone numbers topersonnel under their authority.

Phase II (Pre-Hurricane Procedure)

Secure all loose material and / or equipment

Make sure all Diesel tanks and filled.

Make sure all Used Oil tanks are pumped out.

Make sure all containment and drip pans are pumped out.

Make sure any Hazardous Waste generated at facility is scheduled forimmediate pick-up by Approved Hazardous Waste Disposal Company (seeProcess Specific Waste Management Plan within the Hazardous Controlsection of this manual).

Phase III (Securing for Hurricane and Preparing for Evacuation)

Stop all compressors.

Secure all equipment and buildings.

Collect all hand held radios and place in a safe but secure location.

Move all unsecured portable fire extinguishers to tool room.



E1.15

Move all gas cylinders into secured racks or firmly secured to building orstructure.

Move all mobile equipment to safe and secure location of facility. TheOperator shall provide the key to the equipment to their Supervisor.

Lower and secure all booms to aerial lifts, cherry pickers and cranes.

Ensure all paints, solvents, lube oils, etc. are placed within a securedbuildings or containment area.

Ensure all hazardous materials within containment area are properly securedwithin containment.

All files on company computers’ shall be backed up. Back-up tapes shall beprovided to employees Supervisor. The Supervisor shall place the back-uptapes within a safe and secure location.

Notify Supervisor upon completion of securing operations. Wait for facilityevacuation orders from Facility Manager or designee.

Phase IV (Facility Evacuation)

Notify Supervision to order employees to evacuate facility in an orderlyfashion.

Facility Manager or designee will turn off the electricity to facility andimplement Moreno Group LLC and Subsidiaries Energy Isolation Procedure(Lockout / Tagout). Electricity should not be turned off until all employees

have left the facility.

Ensure all gates and entrances to facility and buildings are locked.

Returning to Facility after Storm

Facility Manager or designee and SH&E Department will perform an Auditand Assessment to determine if facility is safe for employees to enter.

Assign facility electrician to evaluate and determine if it is safe to turn onfacility electricity.

Prior to Facility Manager or designee removing their lock and tag on facilityelectricity and turning on electricity, the entire facility shall be notifiedelectricity will be turned on.

Thunder Storm or Tornado Procedures

Lightning can strike as far as 10 miles from the area where it is raining. That’s about



E1.16

the distance you can hear thunder. According to the National Weather Service, ifyou can hear thunder, you are within striking distance.

All fabrication facilities utilize Weather Sentry Construction Pro to makedeterminations regarding lightning & or severe weather conditions.

In the event lightning is visible or thunder is audible, Weather Sentry will provide

data relevant in making recommendations for the best interest of employee safety. All facilities will adhere to the following when making a recommendation:

- Once it has been determined that lightning is within a 20 mile radius, analert will be issued within the facility.

- After it has been determined that lightning is within a 10 mile radius, theSH&E Department will advise Facility Management to shut down alloutdoor activities

Tornadoes most frequently occur in the Midwestern, southern, and central states

between the months of March and September.

Tornado Alert Categories

Tornado Watch - Indicates that the weather conditions could result in a tornado.

Tornado Warning - Indicates that a tornado has been sighted or detected by radar.

Thunder Storm or Tornado Preparation and Evacuation

During a tornado watch, listen to the radio or television for current information.

DO NOT tie up telephone lines by calling the weather bureau, except to reporta tornado.

During a tornado warning, be prepared to take immediate cover for protection.

During a thunder storm remove employees from all structures within facility,when time allows lay down all aerial lift’s, cherry picker’s and crane’s boom,turn off mobile equipment and remove yourself from the equipment.

Remain calm. Go to the closest building and remain against an inside wall ofthe lowest floor. Remain away from windows and stay inside during the storm.

If the building is occupied during a thunder storm or a tornado is sighted in thevicinity, stay away from the perimeter of the building and areas where glass ispresent.

Leave your office and close the door, proceed to the first floor, stay in thehallways or rooms with no glass. If the tornado is very close, sit or kneeldown in the hallway or a low laying area within the facility, place your head asclose to your lap as possible and protect your head and neck with your handsand arms.



E1.17

Do not attempt to evacuate the building, unless the Facility Manager ordesignee instructs you to.

Emergency Preparedness Plan Review and Training

This procedure and/or the site specific emergency evacuation procedure should bereviewed with the employees should one of the following occur:

When the plan is developed or the employee is assigned initially to a job.

When the employee’s responsibilities’ under the plan changes

Or should this plan change

Employees will receive emergency evacuation training upon hire. Bi-annual Drillsare used to reinforce this training and to identify any opportunities for improvement

within the plan.





E1.18

Attachment 1





E1.18.a.1

Generic Office Building Emergency Evacuation Plan

(i) TABLE OF CONTENTS

1.0 FIRE NOTIFICATION AND RESPONSE

2.0 EMERGENCY PROCEDURE PRIORITIES

3.0 FIRE WARDENS

4.0 EMERGENCY EVACUATION RESPONSE

5.0 FIRST-AID INCIDENCE RESPONSE

6.0 MEDICAL EMERGENCY RESPONSE

7.0 TERRORISM / BOMB THREAT RESPONSE

8.0 SEVERE WEATHER RESPONSE

9.0 REFERENCE DATA



E1.18.a.2

1.0 FIRE NOTIFICATION AND RESPONSE

A. If the following is reported to you, or if you see smoke, or flames, orsmell something burning, or hear a Fire Alarm, IMMEDIATELY:

Call the Fire DepartmentDIAL 9, 911

Call the building SH&E Representative or Management: (PhoneNumber)

Activate the Fire Alarm Pull Station – if Alarm is not sounding.

Report any change in conditions to the Fire Department and theBuilding Fire Safety Director.

B. If you think you smell a peculiar or unfamiliar odor, IMMEDIATELY:

Call the Building Fire Safety Director or Management: (PhoneNumber)

C. Information to be given to the Fire Department:

What is the Emergency? (Alarm, Smoke, Flames, etc.)

Address

Type of Occupancy: (High Rise Office Building)

What Floor:______Room#______Telephone # calling from_____

(Let The Dispatcher Hang Up First!)

1.0 EMERGENCY PROCEDURE PRIORITIES

A. If the following is reported to you, or if you see Smoke, or Flames, orsmell something burning, IMMEDIATELY (If SAFE to do so):

Isolate the Fire by closing the door to your office or conferenceroom!

Call the Fire Department, building Fire Safety Director, and activatethe Fire Alarm Pull Station, if the Alarm is not sounding.

Evacuate – Using EXIT Stairwells to a safe area. Relocation tothree or more levels below the fire floor is generally adequate.

Fire Extinguishment (is optional and only if all of the above hasbeen completed, you have been properly trained to use a fireextinguisher, and would be using the extinguisher ONLY for“incipient stage” fire fighting purposes in a life saving event.)

NOTE: The recommended action is to Evacuate and let the FireDepartment take care of the fire.



E1.18.a.3

B. Emergency procedures – In the event of an ALARM ONLY:

Minimum procedure: Prepare to evacuate by going to the EXITstairwell door, if there is any evidence of fire, evacuate the floor to asafe area (three or more floors below the fire).

When safe to do so, report any condition changes noted to the FireDepartment and the Building Fire Safety Director.

3.0 FIRE WARDENS

3.1 Each floor of a building shall be under the direction of the FireWardens for the evacuation of occupants in the event of a fire or firealarm.

3.2 Each Fire Warden shall be familiar with the Fire Safety Plan, thelocation of exits and the location and how to activate the fire alarm.

3.3 In the event of a fire or fire alarm the Fire Warden (when it can bedone safely), shall:

3.4 Notify the fire department as specified in the approved Fire SafetyPlan.

3.5 Shall see that all occupants are notified of the fire or fire alarm, andshall instruct occupants as per the Fire Safety Plan.

3.6 Direct the evacuation of the floor in accordance with directionsreceived and the following guidelines:

Fire Wardens shall notify the Facility Manager of all mobility-impaired

occupants that may require special assistance in the event of anevacuation. Occupants not requiring assistance will evacuate first. Thisavoids the possibility of the person(s) in need of assistance beingbumped and/or falling down, thus slowing evacuation and/or causinginjury.

If there is evidence of fire, the person(s) having mobility impairmentshould be positioned near the fire exit stairwell that is located farthestaway from the fire. If fire conditions pose a personal threat, the FireWarden or person assisting should enter into the fire exit stairwell withthe person(s) needing special assistance and wait for the Fire

Department.

If fire conditions pose a personal threat in the stairwell, the Mobility-Impaired person(s) should be evacuated to a safe location. FireWardens shall have someone notify the fire department of all Mobility-Impaired occupants that have required special assistance inevacuating the affected areas of their location.



E1.18.a.4

4.0 EMERGENCY EVACUATION RESPONSE

When an emergency is announced by the building’s Public Address (PA)

system, Fire Wardens, or activated “Strobe Lights” on your floor, THE

ORDERLY EVACUATION OF PERSONNEL SHALL BE AS FOLLOWS:

A. CALMLY PROCEED (WALK) TO THE NEAREST SAFE EXITSTAIRWELL

KEEP TO THE RIGHT IN HALLWAYS IF PATH TO EXIT IS BLOCKED, PROCEED TO ANOTHER EXIT DO NOT USE ELEVATORS

B. FOLLOW FIRE WARDEN INSTRUCTIONS

NOTE: IF NO FIRE WARDEN IS PRESENT, FOLLOW THEINSTRUCTIONS BROADCAST OVER THE PA SYSTEM.

C. DO NOT ENTER THE STAIRWELL UNTIL ADVISED!

D. HOWEVER, if there are no instructions and unsafe conditions exist, THENEVACUATE to at least three floors below the Floors affected by fire orsmoke.

E. And, if you see FIRE, SMOKE or smell something burning on your floor,THEN EVACUATE to at least three floors below the Floors affected by fireor smoke.

F. WHEN ENTERING THE STAIR WELL:

ENTER THE STAIRWELL (in a single line) KEEP TO THE RIGHT DOWN THE STAIRS (merge with others) FOLLOW FIRE WARDEN OR PA SYSTEM INSTRUCTIONS TO

EITHER: Evacuate three floors below the Floors affected by fire or smoke, or Evacuate the building

SHOULD YOU BE REQUIRED TO EXIT THE BUILDING, PROCEED TOTHE PARKING LOT – (Prov ide Specif ic Directio ns)

USE CARE CROSSING THE STREET!

NOTE: DO NOT RETURN TO YOUR OFFICE or Leave the area until the FireWardens have given the “All Clear” to either return to offices or depart thearea.



E1.18.a.5

G. STAIRWELL RE-ENTRY POINTS

When attempting to evacuate at least three floors below the involved firefloors, it will be necessary to find a re-entry floor. Unfortunately all floorscannot be re-entered as some doors are locked out by the occupant.

Also, re-entry points are different for each stairwell as show in the chartbelow:

Stairwell Re-Entry Chart

Stairwell Entry / Re-entry Diagram

North Tower South Tower

Floor Stair "A" Stair "B" Stair "C" Stair "D" Floor

RoofAccess

RoofAccess

No RoofAccess

RoofAccess

12 12

11 11

10 10 9 9

8 8

7 7

6 6

5 5

4 4

3 3

2 2

1 Outside only 1

Re-entry doors to the 1st floor and they exit to the

outside

No Stairwell Re-Entry

Stairwell Re-entry

5.0 FIRST AID

In the event of a first-aid incidence, personnel should IMMEDIATELY notifytheir First Line Supervisor and/or Manager. First Aid will be provided asneeded by qualified individuals per our Incident Reporting / Medical AttentionProcedure within our SH&E Management System.

First-Aid and Emergency Response kits are located as indicated in theEmergency Evacuation Plot Plan.



E1.18.a.6

6.0 MEDICAL EMERGENCY RESPONSE

Emergency response assistance may include, but may not be limited toperforming the following:

A. In the event of a medical emergency, personnel should IMMEDIATELY

CALL / Notify 9, 9 1 1 for Emergency Response.

Notify the nearest COMPANY First-Aid Responder (see Section 5above) and be prepared to assist First-Aid Responder as directed.

NOTE: First-Aid and Emergency Response kits are located asindicated on the Emergency Evacuation Plan.

B. Provide all primary information to the 9-1-1 dispatchers regarding:

Your name

COMPANY Name, address and telephone number (see below)

Nature of emergency

C. Follow any instructions as directed by the 9-1-1 dispatchers.

Notify COMPANY management personnel (see Section 9)

Notify building Manger or Security (after hours)

7.0 TERRORISM / BOMB THREAT RESPONSE

7.1 Terrorism

In the event that a terrorist act is perceived or is actually committed in thisfacility, all personnel should use their own judgment in following theseprocedures.

These procedures are only guidelines and should be followed ONLY if it isSAFE TO DO SO:

EVACUATE THE BUILDING IMMEDIATELY!

DIAL 9, 911 (as soon as possible) and that may befrom an outside telephone or your Cell Phone

Also, if possible, activate the nearestFire Alarm Box as you leave the building

NOTE: When evacuating the building, DO NOT gather in groups outside thebuilding as the safest procedure for evacuation during a Terrorist Threat is toscatter as far away from the building as quickly as you can.



E1.18.a.7

7.2 BOMB THREAT

In the event of a bomb threat received by telephone, personnel shouldconsider gathering as much information as possible from the threateningcaller. If possible (and safe to do so) alert your supervisor or one of themanagement staff while the caller is on the line.

The Bomb Treat checklist (see Attachment 1) and the following guidelines are

offered to assist personnel in obtaining as much information as possible fromthe threatening caller.

Be calm, courteous and listen carefully.

Get as much information as possible from the caller, but avoid theimpression you are working from a checklist.

Take notes; try to get the caller’s remarks “word for word”.

It is very important to obtain answers to these questions:

When is the bomb going to explode?

Where is the bomb right now? What does the bomb look like?

What is the bomb made of? (Obtain details about its parts)

What will cause the bomb to explode?

Who placed the bomb? Why?

What is your name? Where are you now?

Try to keep the caller talking. If necessary, pretend difficulty with yourhearing. Try to weave these general questions into the conversation:

What did you say? I’m sorry I didn’t understand what you said.

How do I know this is not a joke?

What group do you represent?

Why are you doing this?

After the call has been terminated, IMMEDIATELY NOTIFY Companymanagement personnel and building management personnel. Be prepared toprovide your notes and checklist.

NOTE: It may NOT be best to INFORM other personnel of the threat.

Company management and building management staff will notify the propermunicipal authorities, at which time, an emergency evacuation responseand/or building search may result.



E1.18.a.8

8.0 SEVERE WEATHER RESPONSE

An Automatic Severe Weather Warning Radio is located at the main receptiondesk in 700 – N. This alert system will provide early warning when severeweather or other hazardous event is immanent.

In the event of severe weather such as hurricanes or tornados, personnelshould employ practical means to secure their work area and ensure their

personal safety.

We are generally offered time for preparation in anticipating hurricaneconditions, whereas tornado conditions may require an emergency response.See Emergency Preparedness Section of SH&E Management System.

A. At a minimum, preparations for hurricane conditions should include:

Close window blinds.

Power-down all electrical components in your work area.

If possible, relocate all electrical components (computers, printers,etc.) away from windows.

Secure the document contents of your work area (desk contents,files etc.) and relocate away from windows.

All lighting should be off and all interior doors should be closed priorto vacating the facility.

B. Tornado condition response should include:

Following the guidelines in the MORENO GROUP LLC ANDSUBSIDIARIES Emergency Preparedness Plan location within ourSH&E Management System in addition to but is not limited to:

Closing window blinds (if safe to do so).

Power-down all electrical components in your work area (if timepermits).

Gather in an area of the building that is safe from shatteredwindows and flying objects.

If Emergency Evacuation of the building is required, evacuate to asafe area away from the hazards of falling glass, fallen liveelectrical lines, and find shelter from the hazards of flying or fallingobjects until the storm has subsided.



E1.18.a.9

9.0 EMERGENCY RESPONDER CONTACT INFORMATION

9.1 Fire Wardens

Fire Warden Contacts

9.2 Building Management Personnel

Building Management Contacts

Fire Warden Title Location Ext.No.

Alternate FireWardens

Ext.No.



E1.18.a.10

9.3 Company Management Personnel

Manager Ext. No. Location

9.4 Emergency Evacuation / Fire Warden Area Maps are located in alloffices and contain the following information:

Location of EXIT Stairwells

Location Fire Hoses & Extinguishers (to be used only bythe Fire Dept.)

Fire Alarm Pull Boxes

Fire Alarm Strobe Lights

First/CPR Kits

Fire Wardens and Alternate Fire Wardens

Room Numbers and Conference Room Locations

The names, locations, and telephone numbers of Emergency

Responders.



E1.19

Attachment 2





E1.19.a.1

BOMB THREAT CHECKLIST

The caller was most probably:

Male Female Child Teenager

Young Adult Middle-Aged Older Person

The caller seemed to be:

Sober Drunk Mentally Disturbed Nervous

Calm Excited Angry Emotional

Rational Irrational Coherent Incoherent

Sincere Righteous Determined Laughing

Joking

The caller talked:

Loud Soft With a high pitch

A deep voice Raspy With a nasal sound

Fast Slow Slurred

With a lisp With a stutter Pleasant

With good pronunciation With a disguised voice With an undisguised voice

The caller’s language was: Highly Educated Good Poor Profane

Full of slang words or expressions (Please include them in comments).

The caller had an accent that I would say was:

Local Not local (where?___________) Foreign (where?_________)

The caller seemed to be familiar with Company?

Building Equipment Plans Operations Personnel

In the background I could hear

Party Noises Bar Sounds Another person or persons

Music House Sounds Animal Sounds

Street Sounds Airport Sounds TrainsFactory Machines Office Machines Other: ________________

Voices Quiet

The origin of the call seemed to be:

Local Long Distance Car Phone From within the building

Caller’s remarks, “word for word” where possible: _________________________________________






Management SystemEmployee Participation

Page: 1 of 2Original: 01/01/2003Revised:

F1.1

Employee Participation

Purpose

It is the purpose of the Safety, Health and Environmental Management System toinvolve employees in the identifying, evaluating and eliminating safety, health andenvironmental hazards and “at-risk” behaviors in the workplace.

Scope

The scope of this program is to identify those processes that promote employeeinvolvement within Moreno Group LLC and Subsidiaries Safety, Health andEnvironmental Management System.

Responsibilities


Reviewing all Incident Reports and Work Group Investigations

Participating in Supplemental Incident Investigations.

Reviewing all Hazard Assessments Checklists (weekly)

Coordinate and Participate in Monthly Management Hazard Assessments

Provide resources to First Line Supervisors so items identified on the Hazard Assessment Checklist can be corrected.

Attending and participating at all monthly SH&E Management meetings.

Attending and participating in Monthly Supervisor Meetings.

Participating in team-based behavioral safety observations.

The First Line Supervisors / Offshore Superintendent is responsible for :

Coordinating and Conducting Incident Reporting and Work Group Investigations

Perform at least once per week the Hazard Assessment Checklist.

Facilitate the correction of those items identified on Hazard Assessment Checklist.

Conduct a daily SH&E meeting.



F1.2

Attending and participating in Monthly Supervisor Meetings.

Coordinate and participate at least one team-based behavioral safetyobservation per week.

The SH&E Department is responsible for:

Assist supervision with Incident Reporting and Work Group Investigation

processes.

Auditing Hazard Assessment Checklists.

Participating in the Monthly Management Hazard Assessment.

Coordinating and participating in Monthly SH&E Management meetings.

Participating in the team-based behavioral safety observations.

Conduct and Coordinate required SH&E training.


Participate in the Incident Reporting process and Work Group Investigationprocess.

Participate in Hazard Assessment as requested.

Attend and participate in SH&E meetings.

Attend and participate in required SH&E training.

Participate in the behavioral safety observation process.




SH&E Management System

Stop Work AuthorityPage: 1 of 5Original: 01/01/2005Revised:

F2.1

Stop Work Authority

Purpose

The purpose of this program is to formally establish Moreno Group LLC andSubsidiaries employees’ and contractors’ right to utilize their “Stop Work Authority”without any repercussions.

Scope

The scope of this program is to outline the protocols Moreno Group LLC andSubsidiaries employees’ and contractors’ are to utilize to suspend individual tasks orgroup operations when the control of SH&E risk is not clearly established or

understood.

It is the policy of Moreno Group LLC and Subsidiaries that:

All employees and its contractors have the authority and obligation to stopany task or operation where concerns or questions regarding the control ofSH&E risk exist,

No work will resume until all stop work issues and concerns have beenadequately addressed, and

Any form of retribution or intimidation directed at any individual or companyfor exercising their authority as outlined in this program will not be tolerated.

As with any policy, accountability for non-compliance will follow establishedCompany procedures or contract requirements.

Roles and Responsibilities


Establishing clear expectation to exercise “Stop Work Authority”.

Maintaining a culture where “Stop Work Authority” is exercised freely.

Resolve “Stop Work Authority” conflicts when they arise and hold thoseaccountable that chose not to comply with established Safe Work Practices orStop Work Authority policies.

Reviewing of Behavioral Safety Observations for “Stop Work Authority”



F2.2

Maintain communication with SH&E Department concerning SH&Eperformance.


Create and maintain a culture within their workgroup to exercise “Stop Work Authority” freely.

Honor their employees request for “Stop Work”.

Ensure all “Stop Work Authority” issues are fully resolved prior to starting work again.

Supports those employees who utilizes their “Stop Work Authority” and ensures the “Stop Work Authority” is properly reported and reviewed.

Reviewing of Behavioral Safety Observations for “Stop Work Authority”.

Proactively recognize employee’s participation within the “Stop Work Authority” process.


Monitoring compliance with the requirements of this program.

Maintaining of associated documents, processes and training materials.

Reviewing of Behavioral Safety Observations and identification of “Stop Work Authority”.

Identification of trends, sharing of learning’s and publication of requiredinformation.

Maintain communication with Management concerning SH&E performanceand/or issues


Initiating “Stop Work Authority” when they feel it is warranted.

Notify their Supervisor upon utilizing their “Stop Work Authority”.

Support fellow employees who initiate their “Stop Work Authority”.

Ensure reason for their use of “Stop Work Authority” is resolved completelyprior to resuming work.

Reporting the use of their “Stop Work Authority” on a Behavioral SafetyObservation Card.



F2.3

Requirements

Intervention Protocol

In general terms, the “Stop Work Authority” process involves a stop, notify, correctand resume approach for the resolution of a perceived unsafe work actions orconditions.

The following steps should be utilized as the framework for employees to initiatetheir “Stop Work Authority”.

Step Protocol Instruction

1 When a person identifies a perceived unsafe condition, act, error,omission, or lack of understanding that could result in an undesirableevent, a “Stop Work Authority” shall be immediately initiated with theperson(s) potentially at risk.

2 If the supervisor is readily available and the affected person(s) are not in

immediate risk, the “Stop Work Authority” should be coordinated throughthe supervisor. If the supervisor is not readily available or the affectedperson(s) are in immediate risk, the “Stop Work Authority” shall beinitiated directly with those at risk.

3 “Stop Work Authority” should be initiated in a positive manner by brieflyintroducing yourself and starting a conversation with the phrase “I amusing my Stop Work Authority because…”. Using this phrase will clarifythe users intent and set expectations as detailed in this procedure.

4 Notify all affected personnel and supervision of the “Stop Work Authority”

issue. If necessary, stop associated work activities, remove person(s)from the area, stabilize the situation and make the area as safe aspossible.

5 All parties shall discuss and gain agreement on the “Stop Work Authority”issue.

6 If determined and agreed that the task or operation is OK to proceed as is(i.e., the “Stop Work Authority” initiator was unaware of certain facts orprocedures) the affected persons should thank the initiator for theirconcern and proceed with the work.

7 If determined and agreed that the stop work issue is valid, then everyattempt should be made to resolve the issue to all affected person’ssatisfaction prior to the commencement of work.



F2.4

8 If the “Stop Work Authority” issue cannot be resolved immediately, workshall be suspended until proper resolution is achieved. When opinionsdiffer regarding the validity of the “Stop Work Authority” issue or adequacyof the resolution actions, the Manager over the First Line Supervisor shallmake the final determination. Details regarding differences of opinion andresolution actions should be included in the documented report.

9 Positive feedback should be given to all affected employees regardingresolution of the stop work issue. Under no circumstances shouldretribution be directed at any person(s) who exercise in good faith theirStop Work Authority as detailed in this program.

10 All “Stop Work Authority” and associated detail shall be documented andreported on a Behavioral Safety Observation Card.

Reporting

All “Stop Work Authority” exercised under the authority of this program shall bedocumented on Moreno Group LLC and Subsidiaries Behavioral Safety ObservationCard. The employee will be responsible for checking the “Stop Work Authority Usedbox on the front of the card. The description of the “Stop Work Authority” issue andused shall be written on the back of the observation card within the Safe, Stop – Work or At - Risk Comment section. Behavioral Safety Observations shall be reviewed by the First Line Supervisorduring the pre-shift SH&E Meeting. Cards indicating “Stop Work Authority” shall be reviewed during this meeting in order to:

Measure participation

Determine quality of interventions and follow-up

Trend common issues and identify opportunities for improvement

Facilitate sharing of learning’s

Feed recognition programs.

The SH&E Department will regularly publish details regarding the number of “Stop

Work Authority” actions reported by location as well as details regarding commontrends and learning’s.



F2.5

Follow-up

It is the desired outcome of any “Stop Work Authority” that the identified safety,health or environmental concern(s) be addressed to the satisfaction for all involvedindividuals prior to the resumption of work. Although most issues can be adequatelyresolved in a timely fashion at the job site, occasionally additional investigation andcorrective actions may be required to identify and address root causes.

“Stop Work Authority” issues that required additional investigation or follow-up will behandled utilizing existing protocols and procedures for incident investigation andfollow-up.

Recognition

The First Line Supervisor should informally recognize individuals when they exercisetheir authority to “Stop Work Authority” or demonstrate constructive participation in a“Stop Work Authority” intervention. This informal recognition need be no more thanan expression of appreciation for a job well. Additionally, formal recognition ofselected examples of “Stop Work Authority” and those responsible should be made

during regularly scheduled safety meetings.

For those employees, the First Line Supervisor feels has demonstrated excellentSH&E Participation may nominate them to their Manager for an Above and BeyondSafety Award.

Training

Training regarding this “Stop Work Authority” Policy and Program will be conductedas part of Moreno Group LLC and Subsidiaries’ New Employee Orientation / SH&ETraining. Additionally, a review of the “Stop Work Authority” shall be completed as

part of all field location safety briefings and regularly in safety meetings.

Documentation of all training and reviews shall be maintained as per establishedprocedures.






SH&E Management System

Job Safetyand Environmental Analysis

(JSEA)


G1.1

Job Safety and Environmental Analysis (JSEA)

Purpose

The purpose of this procedure is to establish a formal process for evaluating andcontrolling existing or potential workplace hazards, and to ensure the information iscommunicated to all affected personnel.

Scope

It is the policy of Dynamic Industries, Inc. for the task First Line Supervisor orOffshore Superintendent to undertake formal workplace hazard assessments to:

A. Identify hazards and risks of the workplace and provide information to allaffected personnel.

B. Provide information to all affected personnel.C. Eliminate, control and/or minimize hazards in the workplace.D. Satisfy client and/or regulatory requirements.

Routine tasks such as but not limited too rolling up hoses or leads, moving a bucketor general clean up activities may or may not be incorporated into JSEA’s.

The Facility / Site Manager / Offshore Manager or Designee is responsible for :

Provide the needed leadership, commitment, employee empowerment, and holdpersonnel accountable for the implementation of this procedure.

Communicating to work force their commitment to the stopping of work, if anyunsafe condition or situation is present.

Auditing compliance with this procedure.

Including JSEA development within Performance Measures


Facilitating the development, review, and documenting of Job Safety andEnvironmental Analysis with their personnel per this policy.

Utilizing the Job Safety and Environmental Analysis within their Daily SH&EMeeting with their personnel.



G1.2

Jointly performing and periodically reviewing with their personnel andcommunicating with affected personnel the Job Safety and Environmental

Analysis.

Incorporating the results of Job Safety and Environmental Analysis intoapplicable Safe Work Procedures.

Upon notification of changes with condition(s) or situation(s) related to the currenttask, develop a new Job Safety and Environmental Analysis or revise the priorJob Safety and Environmental Analysis to meet the changes.

Audit JSEA process to ensure employees are following Job / Task steps asoutline in JSEA.


Training or coordinating the training of managers, supervisors and hourlyemployees on developing and documenting Job Safety and Environmental

Analysis.

Periodically auditing the quality of First Line Supervisor’s or OffshoreSuperintendent’s Job Safety and Environmental Analysis and provide feedbackto them during SH&E Meeting, Safety Alerts or SH&E Training.

Participating in the development in Job Safety and Environmental Analysis.


Actively participating in the development and reviewing of Job Safety and

Environmental Analysis.

Incorporating the results of the Safety, Health and Environmental meeting andJob Safety and Environmental Analysis into their daily activities.

Completing assigned activities as coordinating party per the JSEA.

Advising their supervisor when the conditions or situations of the current taskchanges.

Requirements

Job Safety and Environmental Analysis (JSEA) is the process ofidentifying/evaluating hazards and implementing control measures to eliminateand/or reduce the potential for an incident.

The First Line Supervisor or Offshore Superintendent and their crew shall perform apre-task hazard review prior to developing the JSEA. The back of the JSEA shall beused to perform this review. Any hazards identified during this process shall beidentified in the Potential SH&E Concerns section of the JSEA. Within the



G1.3

Recommended Safe Procedure/Protection Section shall identify how the hazards willbe either eliminated or how exposure to the hazard(s) will be minimized.

Job Safety and Environmental Analysis shall be developed daily for tasksconducted. JSEA preparation is a group activity coordinated by the First LineSupervisor or Offshore Superintendent. The supervisor will complete the first draftof the JSEA form. The supervisor or task leader will be responsible for engaging allemployees working on the job in the review process:

reviewing the proposed sequence of job steps,

identifying hazards

determining the necessary safeguards.

assigning responsible individual(s)

The JSEA review meeting shall be held immediately preceding the work, so that the

actual work environment will be known and the JSEA can be used to familiarize thecrew with the job. The completed JSEA form must be reviewed and signed by allwho will work on the job and posted at the jobsite. The job supervisor shallcommunicate the JSEA to affected personnel within work area.

Note: At anytime a new task is started or the current task’s condition(s) orsituation(s) change work must “STOP” and the JSEA must be updated or rewritten.

Monitoring the JSEA Process

Management is accountable for ensuring that periodic audits of the JSEA process

are conducted. Audit findings should be documented and communicated to thoseresponsible for implementing the process. Improvement actions should be identifiedand implemented to address any shortfalls identified in the audit process.

Routine Monitoring

On-site supervisors shall routinely monitor the JSEA process on their jobs. Theyshould check to see that:

the process is being applied effectively,

safety and environmental hazards are being identified and addressed

the right people are involved in JSEA preparation

JSEA’s are followed once the job commences

Jobs are suspended and JSEA’s modified when conditions change.

Shortfalls identified during routine monitoring should be corrected immediately at thelocal level. If this is not possible, the next level of supervision should be engaged.



G1.4

Documentation

The Hazard/Risk Assessment should be documented using the Job Safety andEnvironmental Analysis form (see Attachment 1-Offshore and/or (see Attachment 2-Dynamic facilities) (see Attachment 3 - JSEAs for loading and unloading Trucks)

Job Safety and Environmental Analysis Steps

The basic steps in completing a Job Safety and Environmental Analysis are: (see Attachment 4 for Job Safety and Environmental Analysis Flow Chart)

Step 1: Select the Job for Analysis

First, define the job to be analyzed. Large work packages should be divided intosmaller jobs or tasks, and these should be analyzed using the JSEA process.

Jobs suitable for JSEA can be performed in a day or less. JSEA shall be written indetail to the way the job shall be performed. Examples include:

Operating a piece of machinery

Making an equipment repair

Installing Piping

Perform a jobsite Hazard Review utilizing the Pre-task Hazard AssessmentInspection Checklist on back of JSEA.

Step 2: Break the Job down into Steps (Basic Job Steps)

The job should be broken down into a sequence of steps, or actions, required toperform the job. The breakdown should not be so detailed that an unnecessarilylarge number of steps result, or so general that basic steps are not recorded.

To determine the basic job steps, ask:

“What action starts the job?”, then

“What must be done next?”

And so on, until the entire job is described.

Note: Consider if simultaneous activities may affect the operation of this task?

The description of each step should begin with an action word, like “Remove”,“Open”, “Weld”, “Secure”, etc.

Pre-job preparations (inspections, lock-out / tag-out, etc.) and post-job requirements(clean-up, removal of locks and tags, etc.) should be included in the job steps.



G1.5

The job steps should be reviewed with experienced employees and those who willdo the work to be sure that the order is correct and no steps have been left out.

Step 3: Identify Hazards and Potential Accident Causes (Potential SH&E Concerns)

The purpose of this step is to identify all potential hazards associated with each step.Hazards introduced by the work environment and the job tasks should both beconsidered. Any hazards identified on the Pre-task Hazard Assessment InspectionChecklist (back of JSEA) shall be identified within this portion of the JSEA.

The following questions can be used to help identify hazards:

Is there a danger of striking against, being struck by, or making otherundesired contact with an object or machinery?

Can an employee be caught in, by, or between objects or machinery?

Is there potential for a slip, trip or fall on the same level or to another?

Can employees strain themselves by pushing, pulling, lifting, bending, ortwisting?

Are all energy sources (electrical, mechanical, and process) controlled forprotection?

Are there hazards associated with simultaneous activities, which may affectthis task?

Other resources, such as Hazard Assessments, Work Permits or etc., can also beused to identify hazards.

Record the hazards identified in the “Potential SH&E Concerns” column of the JSEAform using the following format: “Undesired result + hazard”. For example, “Struckby hammer”, “Slip on wet floor”, “Shocked by electric motor”, “Burned by hot metal”,“Fall from elevated work platform”.

Step 4: Develop Solutions (Recommended Safe Procedure / Protection)

Next, those involved in the job must recommend safe job procedures, or protection,

to prevent the “Potential SH&E Concerns” identified in Step 3. Potential solutionsmust be “observable acts” and may include:

Find a new way to do the job.

Change the physical condition that creates the hazard

Change the work procedure

Use proper safety equipment or safe practices



G1.6

Reduce the task frequency (particularly helpful in maintenance and materialhandling)

A solution must be developed for each hazard identified. Solutions should berecorded in the “Recommended Safe Procedure / Protection” column of the JSEAform. Precisely state what to do and how to do it. Job Steps should be modified, if

necessary. If steps are modified, they should be reviewed again to see if any newhazards have been introduced.

Required safety equipment and PPE should be recorded on the JSEA form.

Note: Assign specific individual(s) the responsibility for implementing the safeprocedures or protection required. Identify this individual(s) within the “CoordinatingParty” column of the JSEA.

Step 5: Review and Buy-in

All workers should review the completed JSEA form. They should indicate theiragreement with the Job Steps to be performed and the safety precautions to betaken by signing the form. At this point, work may begin.

Any other people or groups that may be impacted by the work described on theJSEA should be made aware of the planned work and associated hazards orinterface concerns. This can be accomplished through the location’s Permit to WorkSystem, planning meetings or other site-specific methods of communication.

At this point, work may begin.

Step 6: Modify JSEA If Conditions Change

The job must be suspended (stopped) and the JSEA must be reviewed if theconditions surrounding the job change, for example:

The work environment changes due to simultaneous activities, weather, orother causes

The personnel on the job change

The tools or equipment to be used change

Before work can resume:

The JSEA must be modified to reflect changes

Changes must be communicated to all involved and affected personnel

The workers must sign off on the modified form



G1.7

Attachment 1





COATINGS DEPARTMENTJOB SAFETY AND ENVIRONMENTAL ANALYSIS

G1.7.a.1DII SAFETY 018 1F SEGURA’S RAPID PRESS 337-365-0749

This document certifies as a hazardous a ssessment for Personal Protective Equipment. Hot Work Activities require the review of the Gas Cutting/Welding Safety Guidelines prior to commencement

of work activities.

Job # Customer Location Date Page of New JSEA: Y or N

Revised JSEA: Y or N

Job or Task

# Detailed Job Steps Potential SH&E Concerns Recommended Safe

Procedures/Protection

Responsible Party

1 Conduct Inspection of worksite Employees not familiar with worksite or potential hazards of task

All employees involved in task inspect worksite using

the inspection form on back of JSEA Yes No

Everyone involved in task

2 Conduct Pre-Task JSEA Development /

Review Meeting, and Inspection ofRequired PPE and tools/equipment

-Unfamiliar with task to be performed

-SSE involved in task N/A1. ___________

2. ___________

3. ___________

4. ___________

- Employees can not speak English

- Communication

- Defective tools / equipment / PPE

- Using unapproved or home made tools or

lifting devices

- Review JSEA and Post at site

- Assign mentor with SSE N/A- Identify communication process to be used

__________________________

- Bilingual employees will cover entire JSEA with nonEnglish speaking employees

- Bilingual employees will work with non English

speaking employees

- Repair or replace d efective tools / equipment / PPE

-Use only approved tools or lifting devices

- Identify method and location of Fall Protection Rescue

Method____________ Location___________


Mentor’s Name ______________

3 Receive applicable permits fromOperations

Not authorized to perform work (i.e. permitwork, hot work, line opening, etc.)

Receive Permit(s) from Operations Superintendent/Supervisor

4 Utilize STOP WORK Authority if

conditions change or any otheruncertainty in job task.

- Job steps change

-New employee for task

-Employee identify new hazard or feels

uncomfortable or does not understand task steps

-STOP WORK, notify supervisor and resolve all reasonsfor STOP WORK before restarting task-Review and/or revise JSEA


5. Discuss Hand Placement within task –

Ensure to address hand placement

within each job task step in addition to

this review

-No gloves or wrong gloves worn

- Rings being worn

- Hands placed in between items that could

move- Hands placed on tools in non designated

location

-Ensure proper gloves are worn

- No rings to be worn during task

1_____________________________

2_____________________________3_____________________________

4

Safety Equipment Required for this Task (Check all applicable). Inspect all PPE Prior to beginning Task. Employee Review and Approval Signatures

Hard Hats: Work Vest (PFD): Fire Extinguishers/Firewatch: 1. 6.

Safety Shoes: Face Shields: LockOut / TagOut: 2. 7.

Safety Glasses: Chemicals/Impact Goggles/Gloves: Work Permit Required: 3. 8.

Leather, Cotton or Nitrile Gloves: Hearing Protection: Scaffolding: 4. 9.

Safety Harness & Anchor Device 100%: Fall Protection Rescue System: Gas Detection Meter: 5. 10.



G1.7.a. 2 DII SAFETY 018 1B SEGURA’S RAPID PRESS 337-365-0749



COATINGS DEPARTMENT

JOB SAFETY AND ENVIRONMENTAL ANALYSIS

G1.7.a. 2 DII SAFETY 018 2F SEGURA’S RAPID PRESS 337-365-0749



G1.7.a. 2 DII SAFETY 018 2B SEGURA’S RAPID PRESS 337-365-0749



CONSTRUCTION DEPARTMENT


DII SAFETY 016 1F SEGURA’S RAPID PRESS 337-365-0749 G1.7.a.5

Job# Customer Location Date Page of New JSEA: Y or N

Revised JSEA: Y or N

Job or Task



Responsible Party

1 Conduct Inspection of worksite Employees not familiar with worksite or potentialhazards of task

All employees involved in task inspect worksite using

the inspection form on back of JSEA Yes No


2 Conduct Pre-Task JSEA Development /

Review Meeting, and Inspection ofRequired PPE and tools/equipment


-SSE involved in task N/A

1. ___________

2. ___________

3. ___________

4. ___________

- Employees can not speak English

- Communication


- Using unapproved or home made tools or lifting

devices


- Assign mentor with SSE N/A

- Identify communication process to be used __________________________

- Bilingual employees will cover entire JSEA withnon English speaking employees

- Bilingual employees will work with non English

speaking employees

- Repair or replace defective tools / equipment / PPE

- Use only approved tools or lifting devices

- Identify method and location of Fall Protection

Rescue Method____________ Location___________


Mentor’s Name ______________

3 Receive applicable permits from

Operations

Not authorized to perform work (i.e. permit work,

hot work, line opening, etc.)


4 Utilize STOP WORK Authority ifconditions change or any other

uncertainty in job task.

- Job steps change



uncomfortable or does not understand task steps

-STOP WORK, notify supervisor and resolve all

reasons for STOP WORK before restarting task-Review and/or revise JSEA


5. Discuss Hand Placement within task – Ensure to address hand placement within

each job task step in addition to thisreview

-No gloves- Rings being worn

- Hands placed in between items that could move- Hands placed on tools in non designatedlocation

-Ensure proper gloves are worn- No rings to be worn during task

1_____________________________2_____________________________3_____________________________

4

Safety Equipment Required for this Task (Check all applicable). Inspect all PPE Prior to beginning Task. Employee Review and Approval Signatures

Hard Hats: Work Vest (PFD): Fire Extinguishers/Firewatch: 1. 6.

Safety Shoes: Face Shields: LockOut / TagOut: 2. 7.

Safety Glasses: Chemicals/Impact Goggles/Gloves: Work Permit Required: 3. 8.

Leather, Cotton or Nitrile Gloves: Hearing Protection: Scaffolding: 4. 9.

Safety Harness & Anchor Device 100%: Fall Protection Rescue System: Gas Detection Meter: 5. 10.

This document certifies as a hazardous assessment for Personal Protective Equipment. Hot Work Activities require the review of the Gas Cutting/Welding Safety Guidelines prior tocommencement of work activities



G1.7.a.6 DII SAFETY 016 1B SEGURA’S RAPID PRESS 337-365-0749



CONSTRUCTION DEPARTMENT


DII SAFETY 016 2F SEGURA’S RAPID PRESS 337-365-0749 G1.7.a.5



G1.7.a.6 DII SAFETY 016 2B SEGURA’S RAPID PRESS 337-365-0749





G1.8

Attachment 2






DII SAFETY 013F SEGURA’S RAPID PRESS 337-365-0749 G1.8.a.1

Job# Customer Location Date Page 1 of 2 New JSEA: or N

Revised JSEA: or N

Job or Task Loading Equipment and/or material onto Truck’s Trailer or Bed

# Detailed Job Steps Potential SH&E Concerns Recommended Safe Procedures/Protection Responsible Party

1 Conduct Inspection of truck’s

trailer or bed, surrounding area,lifting equipment, equipment

and/ or material to be loaded.

- Employees not familiar with worksite or

potential hazards of task- Holes in the surface trailer or bed

- Truck not in designated loading area- Poor lighting

- Poor surface around truck- Weight of equipment or material unknown- Lifting equipment over capacity of lifting

equipment.- Equipment not designed to be lifted byforklift

- Forks too small for equipment to beloaded or offloaded

- The weight of the equipment or material isover the capacity of the equipment at the liftangle

- Defective Lifting Equipment- Lifting Equipment Capacity is under theweight of the equipment or material to be

loaded

- All employees to inspect the truck’s trailer or bed

- If holes in surface of the truck’s trailer or bed STOP WORK ,

Refuse to load the truck.- Move truck to designated loading area

- Move truck into a well lighted area

- Move truck to area with a more even surface- Identify weight of equipment or material before lifting.-Utilize lifting equipment that’s lifting capacity is greater than the

weight of the equipment to be lifted- Utilize lift equipment that is designed to lift the equipment ormaterial

- If forks are too small to lift equipment, utilize cherry picker /

crane- Ensure capacity of lifting equipment is over the weight ofequipment / material to be lifted, if not, reposition lift equipment,

change lift equipment, if neither will work STOP WORK andnotify First Line Supervisor- Perform Pre-use Inspection of Lifting Equipment


2 Conduct Pre-Task JSEADevelopment, JSEA Review /

Pre-lift Meeting, and Inspection

of Required PPE, Tools, Lifting

Equipment and Rigging

-Unfamiliar with task to be performed-SSE involved in task N/A

- Poor Communication


- Time of Day

- Review JSEA and Post at site- Assign mentor with SSE N/A

- Identify communication process to be used:

___________________________________________

- Repair or replace d efective tools / PPE- Perform Pre-use inspection of lifting equipment and rigging,

remove from service accordingly- No loading or unloading of equipment or material will occurduring night time hours without management’s approval

Everyone involved in taskMentor’s Name ______________

3 Receive applicable permits

from Operations

Not authorized to perform work (i.e. permit

work, hot work, line opening, etc.)


4 Utilize STOP WORK

Authority if conditions changeor any other uncertainty in job

task.

- Job steps change



uncomfortable or does not understand tasksteps

-STOP WORK, notify supervisor and resolve all reasons for STOPWORK before restarting task

-Review and/or revise JSEA


5 Discuss Hand Placement withintask – Ensure to address hand

placement within each job task

step in addition to this review

-No gloves- Rings being worn- Hands placed in between items that could

move- Hands placed on tools in non designatedlocation

-Ensure proper gloves are worn- No rings to be worn during task1_____________________________

2_____________________________3_____________________________4



G1.8.a.2 DII SAFETY 013B SEGURA’S RAPID PRESS 337-365-0749

6 Have Driver turn the truck’s engine off before identifying the location whereequipment and/or material shall be

placed onto the trailer or bed.

- Driver moving truck- Weight of equipment is not distributed

properly on trailer or bed

- Driver to turn off engine before unsecuring his load- Driver will instruct Equipment Operator where to placeequipment and/or material

- Designate a Signal Person- Identify Sequence in which equipment / material

will be Loaded.

1. ________________________________

2._________________________________

3._________________________________

4._________________________________

5._________________________________

6._________________________________

7._________________________________

8._________________________________9._________________________________

Driver and Equipment Operator(s)

Designated Signal Person is:

1.________________

7 Have Driver remain in a protective area

away from the operations until loading process is over.Protective Area

:________________________

- Driver approaches operations

- Driver starts engine while loading

- STOP Loading Process and report situation to First

Line Supervisor

Equipment Operator(s) and Riggers

8 Loading of Truck trailer or bed - Driver steps out of protective area- Load is not stable

- Load shifts unexpected- Rigging fails- Personnel places himself between load and

other equipment or material- Improper hand signals- Load is not in control

- Load swings

- Rigging too high to remove from block

- If driver exits protective area STOP WORK and NotifyFirst Line Supervisor.

- Ensure block is over the load- Use adequate number of taglines- Do not place yourself in between in the load and other

equipment, or material- Use proper hand signals- Watch the load at all times do not turn your back to the

load.

- Utilize ladder to remove rigging from block withanother employee holding ladder


9 Allow driver out of protective area to Tie

down his load

- Drive does not have correct PPE

- Another piece of equipment or materialneeds to loaded

- Straps / Binders Fail

- Driver to wear all required PPE

- Ask Driver to return to the protective area beforeloading additional equipment and/or material

-Inspect straps/binders and stand clear while tightening

Equipment Operator and Driver

Employee Review and Approval Signatures Individuals Involved with Task Signature Individuals Involved with Task Signature

Hard Hats: Required 1. 2.

Safety Shoes: Required 3. 4.

Safety Glasses: Required 5. 6.

Cotton Gloves / Leather Gloves: Required 7. 8.

Hearing Protection: Required for Equipment Operators 9. Driver’s Signature:






Revised JSEA: or N

Job or Task: Off Loading Equipment and/or material from Truck’s Trailer or Bed



Responsible Party

1 Conduct Inspection of truck’strailer or bed, surrounding area,

lifting equipment, equipmentand/ or material to be off loaded.

- Employees not familiar with worksite or potential hazards of task

- Holes in the surface trailer or bed- Truck not in designated loading area

- Poor lighting- Poor surface around truck- Weight of equipment or material unknown

- Lifting equipment over capacity of lifting

equipment.- Equipment not designed to be lifted byforklift

- Forks too small for equipment to beloaded or offloaded- The weight of the equipment or material is

over the capacity of the equipment at the liftangle- Defective Lifting Equipment

- Lifting Equipment Capacity is under theweight of the equipment or material to be

loaded

- All employees to inspect the truck’s trailer or bed

- If holes in surface of the truck’s trailer or bed STOP WORK ,

Refuse to load the truck.- Move truck to designated loading area

- Move truck into a well lighted area

- Move truck to area with a more even surface

- Identify weight of equipment or material before lifting.-Utilize lifting equipment that’s lifting capacity is greater than

the weight of the equipment to be lifted- Utilize lift equipment that is designed to lift the equipment ormaterial

- If forks are too small to lift equipment, utilize cherry picker /crane- Ensure capacity of lifting equipment is over the weight of

equipment / material to be lifted, if not, reposition lift equipment,change lift equipment, if neither will work STOP WORK andnotify First Line Supervisor

- Perform Pre-use Inspection of Lifting Equipment


2 Conduct Pre-Task JSEA

Development, JSEA Review /Pre-lift Meeting, and Inspectionof Required PPE, Tools, Lifting

Equipment and Rigging


-SSE involved in task N/A- Poor Communication- Defective tools / equipment / PPE

- Time of Day


- Assign mentor with SSE N/A- Identify communication process to be used:

___________________________________________

- Repair or replace defective tools / PPE- Perform Pre-use inspection of lifting equipment and rigging,remove from service accordingly- No loading or unloading of equipment or material will occur

during night time hours without management’s approvals.

Everyone involved in taskMentor’s Name ______________

3 Receive applicable permits fromOperations

Not authorized to perform work (i.e. permitwork, hot work, line opening, etc.)


4 Utilize STOP WORK Authorityif conditions change or any other

uncertainty in job task.

- Job steps change



uncomfortable or does not understand task

steps

-STOP WORK, notify supervisor and resolve all reasons for

STOP WORK before restarting task-Review and/or revise JSEA


5 Discuss Hand Placement within

task – Ensure to address hand placement within each job taskstep in addition to this review

-No gloves

- Rings being worn- Hands placed in between items that couldmove

- Hands placed on tools in non designated

location

-Ensure proper gloves are worn

- No rings to be worn during task1_____________________________2_____________________________

3_____________________________

4




6 Have Driver turn the truck’s engine off before removing is securing devices,

before we identify equipment numbers

- Driver moving truck while someone ison top of trailer or bed.

- Tie downs are thrown over equ ipmenthitting someone.- Tie down device pops unexpected hitting

driver.

- Driver to turn off engine before unsecuring his load

- Driver shall position himself to ensure secure device

does not hit him when unsecuring

- Designate a signal person

- Identify Sequence in which equipment / material

will be Off Loaded.

1._____________________________2._____________________________3._____________________________4._____________________________5._____________________________6._____________________________7._____________________________

8._____________________________9._____________________________

Driver and Equipment Operator(s)

Designated Signal Person is:

1.___________________

7 Have Driver remain in a protective area

until loading process is over.Protective Area:

________________________

- Driver starts engine while loading

- Driver approaches operations

- STOP Loading Process and report situation to First

Line Supervisor


8 Off Loading of Truck trailer or bed - Driver steps out of protective area- Load is not stable- Load shifts unexpected

- Rigging fails- Personnel places himself between loadand other equipment or material

- Improper hand signals- Load is not in control

- Load swings- Rigging too high to remove from block

- Hole is identified after removing someequipment or material from trailer or bed

- If driver exits protective area, STOP WORK and Notify First Line Supervisor.- Ensure block is over the load

- Use adequate number of taglines- Do not place yourself in between in the load andother equipment, or material

- Use proper hand signals- Watch the load at all times do not turn your back to

the load.- Utilize ladder to remove rigging from block with

another employee holding ladder- If hole in trailer or bed is identified during the offloading of equipment or material STOP WORK and

notify First Line Supervisor


9 Allow driver out of protective area to

Tie down his load

- Drive does not have correct PPE

- Another piece of equipment or materialneeds to loaded

- Driver to wear all required PPE

- Ask Driver to return to protective area before loadingadditional equipment and/or material-Inspect straps/binders and stand clear while tightening

Equipment Operator and Driver


Hard Hats: Required All Task Personnel 10. 11.

Safety Shoes: Required All Task Personnel 12. 13.

Safety Glasses: Required All Task Personnel 14. 15.

Cotton Gloves / Leather Gloves: Required All Task Personnel 16. 17.

Hearing Protection: Required for Equipment Operator(s) 18. Driver’s Signature:






Revised JSEA: or N

Job or Task Loading / Offloading Material from Closed In Truck Trailer

# Detailed Job Steps Potential SH&E Concerns Recommended Safe Procedures/Protection Responsible

Party

1 Conduct Inspection of truck’s traileror bed, surrounding area, lifting

equipment, equipment and/ ormaterial to be loaded / offloaded.

- Employees not familiar with worksite or potentialhazards of task- Holes in the surface trailer or bed- Truck not in designated loading area- Poor lighting- Poor surface around truck- Hazardous Materials- Weight of equipment or material unknown- Lifting equipment over capacity of liftingequipment.- Equipment not designed to be lifted by forklift- Forks too small for equipment to be loaded oroffloaded- The weight of the equipment or material is overthe capacity of the equipment at the lift angle- Defective Lifting Equipment- Lifting Equipment Capacity is under the weightof the equipment or material to be loaded

- All employees to inspect the truck’s trailer or bed - If holes in surface of the truck’s trailer or bed STOP WORK , Refuseto load the truck.- Move truck to designated loading area- Move truck into a well lighted area- If hazardous materials, ensure MSDS are reviewed and precautionsidentified on MSDS are followed.- Move truck to area with a more even surface- Identify weight of equipment or material before lifting.-Utilize lifting equipment that’s lifting capacity is greater than theweight of the equipment to be lifted- Utilize lift equipment that is designed to lift the equipment or material- If forks are too small to lift equipment, utilize cherry picker / crane- Ensure capacity of lifting equipment is over the weight of equipment /material to be lifted, if not, reposition lift equipment, change liftequipment, if neither will work STOP WORK and notify First LineSupervisor- Perform Pre-use Inspection of Lifting Equipment

Everyone involved intask

2 Conduct Pre-Task JSEADevelopment, JSEA Review / Pre-

lift Meeting, and Inspection of

Required PPE, Tools, LiftingEquipment and Rigging

Determine if driver will be assistingwith the offloading process (ie.

Using pallet jack, dolly, etc.)

-Unfamiliar with task to be performed-SSE involved in task N/A

- Poor Communication

- Defective tools / equipment / PPE- Time of Day

- Review JSEA and Post at site- Assign mentor with SSE N/A

- Identify communication process to be used:

___________________________________________- Repair or replace defective tools / PPE- Perform Pre-use inspection of lifting equipment and rigging, remove

from service accordingly- No loading or unloading of equipment or material will occur during

night time hours without management’s approval


Mentor’s Name ______________

3 Receive applicable permits from

Operations

Not authorized to perform work (i.e. permit work,

hot work, line opening, etc.)

Receive Permit(s) from Operations Superintendent/Superv

isor

4 Utilize STOP WORK Authority ifconditions change or any otheruncertainty in job task.

- Job steps change


-Employee identify new hazard or feelsuncomfortable or does not understand task steps

-STOP WORK, notify supervisor and resolve all reasons for STOPWORK before restarting task

-Review and/or revise JSEA


5 Discuss Hand Placement within task – Ensure to address hand placementwithin each job task step in addition

to this review

-No gloves- Rings being worn- Hands placed in between items that could move

- Hands placed on tools in non designated location

-Ensure proper gloves are worn- No rings to be worn during task1_____________________________

2_____________________________3_____________________________4




6 Have Driver turn the truck’s engine - Driver moving truck- Sequence in which equipment / material will be off

loaded.

- Driver to turn off engine before unsecuring his load- Designate a Signal Person

- Identify Sequence in which equipment / material will be

Off Loaded.

1. ________________________________

2._________________________________

3._________________________________

4._________________________________

5._________________________________

Driver and EquipmentOperator(s)

Designated Signal

Person is:

1._____________

7 Equipment / Material removed fromtruck trailer:

Identify Method for getting material /equipment out of truck trailer:

________________________________

________________________________

________________________________

________________________________

________________________________

________________________________

________________________________

________________________________

________________________________

- If Driver is assisting if the offloading of truck trailer:- Driver places himself in a pinch point.

- Using strap / rigging and forklift to slide material to

back of trailer so it can be removed.- Strap / rigging failure.- Load gets hung up

- Load tips over.-- Driver steps out of protective area

- Load is not stable- Load shifts unexpected- Rigging fails

- Personnel places himself between load and otherequipment or material- Improper hand signals

- Load is not in control

- Load swings

_______________________________________

_______________________________________

_______________________________________

_______________________________________

- List specific pinch points and where driver / personnel needto be positioned.

__________________________________________

__________________________________________

- Have driver bring material to back of trailer and then returnto front of trailer before load is taken out of trailer.

- If driver will not be assisting in the offloading, driver needsto be removed from truck trailer and placed in a protectivearea.

- If using strap / rigging and forklift to slide material to backof trailer so it can be removed, make sure no one is in trucktrailer during the operation.

- Inspect all rigging equipment to be used.

- Inspect load to ensure it will not get hungup while being skidded.

- Identify where rigging needs to be placed

to ensure load will not tip over.- If driver exits p rotective area STOP WORK and Notify FirstLine Supervisor.

- Ensure block is over the load- Use adequate number of taglines

- Do not place yourself in between in the load and otherequipment, or material- Use proper hand signals

- Watch the load at all times do not turn your back to the load.

Equipment Operator(s)and Riggers

8 Setting equipment / material down inyard

- Personnel in the area of the operation.- Material not properly stacked.

- Load shifts unexpectedly.- Personnel being pinned by load if material tips

over.

- Remove all non-essential personnel from the area.- If stacking material, ensure stack is stable.

- Use adequate number of taglines to stabilize load.- Ensure everyone remains clear of load when it is set

down.

Equipment Operator(s)and Riggers

9 Allow driver out of protective area toclose the trailer.

- Drive does not have correct PPE- Another piece of equipment or material needs to

loaded- Straps / Binders Fail

- Driver to wear all required PPE- Ask Driver to return to the protective area before loading

additional equipment and/or material-Inspect straps/binders and stand clear while tightening

Equipment Operator andDriver


Hard Hats: Required 19. 20.

Safety Shoes: Required 21. 22.

Safety Glasses: Required 23. 24.

Cotton Gloves / Leather Gloves: Required 25. 26.

Hearing Protection: Required for Equipment Operators 27. Driver’s Signature:



G1.9

Attachment 3





G1.9.a.1

Sr. Mgmt.

Supervisor

Task

Leader

Crew

Customer

JSEA PROCESS MAP

Select

Job forAnalysis

(Step 1)

Review JSEA

w/ Crew

(Step 5)

Prepare Draft

JSEA *(Steps 2-4)

Steps refer to the Process Description in the JSEA Program

* Modify existing JSEA’s for similar tasks, if available (Steps 2-4)

** If Job Scope, Personnel or Work Environment change, modify JSEA as needed. (Step 6)

Review JSEA /

Give Feedback

(Step 5)

Changes?

(Step 5)

Sign JSEA

Form to

indicate

Agreement

(Step 5)

Post JSEA

at Job Site

and

Conduct Job

as described

in JSEA

Participate

As

Appropriate

Monitor

Job

Modify JSEA

to address

changes

Job

Changes?

**

(Step 6)

Routinely Monitor Jobs to verify

JSEA process is being implemented properly. Communicate JSEA with

other affected ersonnel.

Keep JSEA’s on

file for future

Periodically Audit the JSEA Process and Communicate Audit Findings (As part of SH&E MS)

Y

N

Y

N

Notes:

Perform

JobsiteHazard

Review






Management Systems

Incident Report / MedicalAttention Procedure

Page 1 of 7Original: 01/01/2001 Revised: 01/01/2010

Incident Reporting / Medical Attention Procedure

Purpose

The purpose of this program is to provide guidelines for reporting incidents toMoreno Group LLC and Subsidiaries.

Scope

This program addresses the responsibilities of the supervisor upon the notification ofan incident.

Responsibilities


Providing support and resources to implement this program.

Providing emergency contact numbers, approved first aid kits and bloodbornepathogens kits at all job sites.

The Yard Foreman / Offshore Manager is responsible for:

Arrange proper transportation of injured employee to medical facility.

Notifying Safety, Health and Environmental Department of incident.

Providing medical facility approval for Medical Treatment, if Safety, Healthand Environmental Department is unavailable.

The First Line Supervision / Offshore Superintendent is responsible for:

Communicating to employees to report all incidents.

Notifying Yard Foreman or Offshore Manager of all incidents.

Provide needed information to Yard Foreman or Offshore Manager fortransportation to medical facility.

Providing to Yard Foreman or Offshore Manager completed incident reports.




Inspecting and maintain facilities’ first aid kits.

Providing assistance to operations in the transporting of injured party.

Post Injury Management of the incident and appropriate record all injuries.

The Tool Room is responsible for:

Providing United States Coast Guard (USCG) approved first aid kits andbloodborne pathogens kits in all offshore tool houses.


Reporting all incidents, no matter how minor, including Near Missesimmediately to their First Line Supervisor or Superintendent.

Requirements

All incidents (i.e. Injury, Illness (Occupational), Property Damage, Fire, CraneIncident, Information Only (Non Occupational) Vessel Collision no matter how minorincluding shall be reported immediately to the employees’ supervisor (see

Attachment 1 The First Line Supervisor shall complete the “First Report of Injury orOccupational Illness / Property Damage Report” (see Attachment 2).

Incident Reporting

Upon notification of an incident, the supervisor’s initial duty is to confirm that

the employee is not injured and does or does not need medical attention. Anytime there is doubt; medical attention shall be sought.

If the employee does not require medical attention, the supervisor shallcompletely fill out the “First Report of Injury or Occupational Illness / PropertyDamage Report” (see Attachment 2) and Moreno Group LLC andSubsidiaries Work Group Investigation Form (see Incident InvestigationProcedure). Near Miss Incidents shall be reported on the Moreno Group LLCand Subsidiaries Observation/Near Miss Card. The First Line Supervisor orSuperintendent and their Manager should determine if a Near Miss shouldhave a Work Group Investigation conducted. The supervisor shall obtain a

copy of any Third Party Accident Reports and attach these reports to theincident documents.

The supervisor shall notify their immediate Manager.

The Manager will notify the SH&E Department of the incident.

The supervisor shall forward to their immediate Manager the completedincident reports within 24 hours.



Upon receiving incident documents the Manager shall review and forward tothe SH&E Department.

Medical Attention Required:

Should the injured employee require medical attention, the supervisor shall

notify his immediate Manager.

Prior to notifying the SH&E Department the Manager shall arrangetransportation to closest company designated medical facility. If the SH&EDepartment is unable to arrive at the medical facility prior to the injuredparty’s arrival, the Manager shall Fax the “Approval for Medical Attention”(see Attachment 3) to the medical facility.

The supervisor shall complete the “First Report of Injury or OccupationalIllness / Property Damage Report” (see Attachment 2).and the Moreno GroupLLC and Subsidiaries Work Group Investigation (see Incident Investigation

Procedure). The supervisor shall obtain a copy of any Third Party AccidentReport and attach these reports to the incident documents.

The supervisor shall forward to their immediate Manager the completedincident reports within 24 hours.

Upon receiving the incident documents, the Manager shall review, approveand forward documents to the SH&E Department.

First Aid

All Moreno Group LLC and Subsidiaries facilities will have readily available approvedfirst aid kit located in the Safety, Health and Environmental Department. All Offshoretool houses will be provided with a USCG Approved First Aid Kit and BloodbornePathogens Kit.

Inspection of First Aid Kits

Weekly the Facility Management and the Safety, Health and EnvironmentalDepartment shall be responsible for checking and maintaining the First Aid Kitslocated at each facility. The tool room shall be responsible for providing fully stockedUSCG first aid kits which is a weather proof container with sealed packages of each

type of item in all offshore tool houses prior to sending the offshore tool houseoffshore.

Training

First Line Supervisors, Offshore Superintendents and the Safety, Health andEnvironmental Department shall be trained in American Heart CPR, First Aid andBloodborne Pathogens. Retraining will be annual for American Heart CPR andBloodborne Pathogens and every two years for First Aid. These records will bemaintained by the Safety, Health and Environmental Department.



Emergency Eye / Body Wash Stations

Emergency eye / body wash stations should be provided with in 10 feet of thoseareas where corrosive materials are being handled and/or stored.

Emergency Contact Numbers

Facility Manager shall be responsible for posting emergency contact numbers.These numbers should include following contacts:

Medical Facilities

Fire Departments

Spill Response Companies

Police Department

All emergency numbers shall be established prior to commencement of a project toensure timely response for an emergency situation.

Incident Involving Subcontractor

All incidents involving of a Subcontractor Company’s or their employee’s shall bedocumented on our “First Report of Injury or Occupational Illness / Property DamageReport” (see Attachment 2).

Reporting procedures for Subcontractor Company’s incidents shall be performed

using our Incident Reporting procedures (see Attachment 1).

Recording of Injuries

All injuries will be classified and recorded in accordance with the OSHARecordkeeping Guidelines.



Attachment 1





Moreno Group LLC and Subsidiaries’ Incident Reporting Procedure Flow Chart

Incident

Employee NotifiesSupervisor

Supervisor confirmsemployee’s need for

medical attention

NO

Medical AttentionNeeded

YES

Supervisor Notifies DivisionManager to arrange

transportation to medical facility

Division Manager notifies SH&E

Department

SH&E representativearrives at medical

facility prior to injuredemployee

NO

Supervisor completesIncident Report &Incident Investigationforms and faxes toDivision Manager

Supervisor completes IncidentReport & Incident Investigation

forms and faxes to DivisionManager

Supervisor Notifies DivisionManager

Division Manager Notifies andprovides forms to SH&E

Department

SH&E Department notifies uppermanagement

Division Managerreviews with andprovides forms toSH&E Department

Division Manager faxes Approvalfor Medical Attention to medical

facility

SH&E representativeperforms Post Injury

Management

YES

SH&E Departmentnotifies Division

Manager and UpperManagement of

employee condition

SH&E representative meets injuredemployee at medical facility and

performs Post Injury Management

Supervisor notifiesClient of Incident





Attachment 2





1

FIRST REPORT OF INJURY OR OCCUPATIONAL ILLNESS /PROPERTY DAMAGE REPORT

Typeof

Incident

Injury Occupational Illness Information Only Fire(Non-Occupational) Moreno employee

Property Damage Crane Incident Vessel Collision Subcontractor InjuredParty

L. Name: ________________________ FI: ______ MI: ______ SSN: __________________

Address: __________________________City: _______________ State: _______ Zip: _______Birthday: ___\___\___ Age: ____ Sex: ___ Years Experience: ___ Occupation:_______________

Phone No.: _________________________ Alt. Phone No.: _______________________________

When

When Injury/Illness Occurred: Employee Injured During Working Hours: Yes ___ No ___

Date: ___\___\___ Did Employee Stop Work: Yes ___ No___

Time (24-hour format HH:MM): ___________Date Reported to Moreno Group LLC and Subsidiaries: ____\____\___

Facility

Information

Facility Name: ____________________________ Parish: ________________________________

Facility Owner: ___________________________ State: _________________________________

City / Town: ______________________________ Phone No.: ____________________________

Contact Person: __________________________ Job No.: _______________________________Vessel

Informa-

tion Vessel Name: ______________________________ Vessel Owner: _________________________

Contact Person: ____________________________ Contact Phone No. ______________________BodyPart

Head Face Ear (L/R) Eye (L/R) Nose Mouth Tooth

Neck Shoulder (L/R) Arm (L/R) Elbow (L/R) Wrist (L/R)

Hand (L/R) Finger or Toe Torso Internal Back

Hip (L/R) Leg (L/R) Knee (L/R) Ankle (L/R) Foot (L/R)Description

ofIncident

Property

Damage

Owner Name: __________________________________ Contact No.: _______________________

Address: _____________________________ City: _______________ State: _______ Zip: _______

Describe the Property and Damage: ___________________________________________________

________________________________________________________________________________

Witnesses

Name: _______________________________________ Phone No.: _________________________

Address: ___________________________ City: _______________ State: _______ Zip: _________

Name: ______________________________________ Phone No.: __________________________

Address: ___________________________ City: _______________ State: _______ Zip: _________

Signature

Supervisor's Signature: _____________________________________ Date: ______/______/______

MedicalInformation

Medical Attention Authorized: Yes _____ No _____ Date of Authorization: _____/_____/______

Name: ____________________________________ Phone No.: ___________________________

Address: ____________________________ City: _______________ State: _______ Zip: ________

Did Doctor Release Employee for Work: Yes ____ No ____ Full Duty ____ Restricted Duty ____

Describe restrictions if any: _______________________________________________________________________________

Return to work within 24 hours: Yes ____ No____ Within 72 hours: Yes ____ No ____

COVERAGE: STATE OF ___________ LONGSHORE____________ INTERNATIONAL__________





Attachment 3





1

MORENO GROUP LLC AND SUBSIDIARIES APPROVAL FOR MEDICAL ATTENTION

Date

Medical Facility

Address

Please render medical attention to _______________________, which is an employee of Moreno

Group LLC and Subsidiaries Nature of injury: _________________________________________

Authorized By: _________________________________________________________________

Title: _________________________________________________________________________

Please send all reports and bills to: Moreno Group LLC and SubsidiariesP.O. Box 9406New Iberia, La. 70562

Attn: SH&E Department

Doctor’s Statement

Name of injured employee

Date of Treatment

Will the employee’s physical condition allow him or her to return towork

Yes No

Should physical condition permitemployee to return to work, is the work

Regular Duty Restricted Duty

If restricted, Please state the reason(s) for Restricted Duty:

Date to return for follow-up treatment:_______________________________________________

Date:___________________ Attending Physician:____________________________________






Management System

Incident InvestigationProcedure


H2.1

Incident Investigation Procedure

Purpose

The purpose of this document is to provide a uniform method for investigatingincidents to promote the following:

Prevent incident recurrence.Identify conditions that could cause a similar incident.Recognize areas for improvements within management systems.Demonstrate commitment to workplace safety.Increase employee confidence in workplace safety.

Scope

The scope of Moreno Group LLC and Subsidiaries incident investigationprocedure is to investigate Safety, Health and Environmental related incidentswith the intent of identifying causes and taking proper corrective actions.Investigations will be conducted with the objective of finding the causes and notplacing blame.

No Disciplinary action will be imposed as a result of the information providedduring an investigation, unless there is a clear, verifiable evidence of negligenceor disregard of a company safety rule or procedure or misrepresentation of thefacts.

Responsibilities

The Facility Manager/ Offshore Manager/ Yard Foreman or Designee isresponsible for:

Providing necessary resources for investigation including staff supportwhen requested.

Evaluate incident information gather during the Workgroup IncidentInvestigation and assign a risk valve for this incident.

Conducting Supplemental Incident Investigations (see Attachment 2).

Reviewing and approving investigation reports and any control items.

Providing resources necessary for the completion of approvedrecommendations and any control actions.



H2.2

Retention of incident reports and supporting documentation for five (5) years.

Conducting a 30-day follow-up on all outstanding recommendations andproviding management with a monthly exception list of all overdue actionitems.

Overseeing this policy and insuring all requirements are met.

Auditing compliance with this policy.

Understanding and complying with this policy / procedure.

Timely notification of management and Safety Department concerningincidents occurring in their areas of responsibilities

Preservation of the incident scene until released to the investigation team.

Investigating or participating in the investigation of all job related accidents,injuries, illnesses or near-miss events that occur in their area(s).

Completing the Workgroup Incident Investigation (Attachment 1).

Assuring adequate short-term interim measures are taken to allow saferesumption of work.

Completing any assigned report recommendations.

Communication of report findings and corrective actions to subordinates.

Documentation of investigation findings and corrective actions and submittingto the Facility / SH&E Department / designee for filing.

Issuing the Workgroup Incident Investigation Form to the Facility / SiteManager within 24 hours.


Reviewing all completed Workgroup Incident Investigation Forms and

Witness Statements.

Participating in the actual investigation of accidents or incidents with thepotential for serious personal injury, property damage or damage to theenvironment.

Assignment of a unique report number that will be entered on all reports,attachments and / or evidence.



H2.3

Providing Incident Investigation Training to Management and First LineSupervision.

To develop Safety Alerts pertaining to the incident to ensure lesson learnedfrom the Workgroup Investigation is communicated throughout theorganization and implemented.



Reporting all incidents to their Supervisor / designee immediately.

Completing the Employee / Witness Statement (Attachment 3) when he orshe is involved in or witnesses an accident or injury.

Participating on investigation teams as required.

Definitions

Incident – an event that causes, or could cause, personnel injuries and/or propertyloss. Incident examples include the following: all personnel injuries (regardless ofseverity), spills or releases of hazardous materials, fires, explosions, and vehicleaccidents.

Incident Category -- A classification system, used by the Safety Department, basedon Bureau of Labor Statistics and Company guidelines to determine the incidenttype for recordkeeping, statistical, and investigation purposes.

Near Miss – a condition, situation, or event having the potential to cause personnelinjuries and/or property loss.

Root Cause – a specific action, non-action, event, condition, etc that is thefundamental or underlying basis for an incident occurrence.

Work Group – An investigation team composed of the affected employee(s), theaffected employee(s), and at least one or more peer employees.

Requirements

Personnel shall report all incidents immediately to their supervisor.

All incidents, may be investigated using this procedure. The Work GroupInvestigation (see procedure) shall be conducted the same day the incidentoccurred.

A Supplemental Investigation is required for all OSHA “Days Away From Work”incidents. The Supplemental Investigations shall be conducted as soon as therequired investigation team can be assembled. The following is a list of numericalrisk factors and recommended Supplemental Investigation Team members:



H2.4

Vice President (Chair Person)Offshore Manager (Offshore incident)

Yard Foreman (Onshore incident)Offshore Superintendent (Offshore incident)(if possible)Supervisor (Onshore incident)Safety, Health and Environmental Department Representative

Work Group Investigation Team (if possible)

Applicable Documents and Forms

Work Group Investigation Report From – all work-group investigations shallbe conducted using the Moreno Group LLC and Subsidiaries Work GroupInvestigation Report Form (see Attachment 1). A detailed narrative may beattached to the report form if additional space for documentation is necessary.The Original form is forwarded to the Yard/Offshore Managers following theinvestigation (see Attachment 1). If a supplemental investigation is to beconducted, a copy of the Work Group Investigation Report should be attached

to the Supplemental Investigation Form. Copies of the completed WorkGroup Form shall be forwarded to the Safety, Health and EnvironmentalDepartment and all members of the investigation team.

Supplemental Investigation Report Form – all supplemental investigationsshall be conducted using the Supplemental Investigation Report Form (see

Attachment 2). The original Work Group Investigation Report is used aspreliminary information. A copy of the Work Group Report should be attachedto the Supplemental Investigation Report Form. A detailed narrative may beattached to the report form if additional space for documentation is necessary.Copies of the completed Supplemental Investigation Report Form shall be

forwarded to all members of the investigation team. The original form isforwarded to the Safety Department following the investigation.

Document Recordkeeping – the original Work Group Investigation ReportForm and the original Supplemental Investigation Report Form shall bereturned to the Safety, Health and Environmental Department forrecordkeeping. All incident investigation reports shall be retained by theSafety, Health and Environmental Department for five years.

Procedures

Incidents are reviewed using a two-part system starting with an investigationconducted by the immediate work group involved with the incident and, ifapplicable, progressing to an investigation involving additional members ofmanagement, employee representatives, and safety representatives.

Work Group Investigation – All incidents may be investigated by aWork Group Investigation Team the same day the event occurs. TheWork Group Investigation Team consists of the affected employee(s),affected employee(s) supervisor/offshore superintendent (chairperson)and all available members of the immediate work group. If the affected



H2.5

employee is not able to attend the investigation, the work group shallmeet the day of the incident to gather information and conclude theinvestigation when the affected employee is available. In some cases,more than one work group may be included in the Work GroupInvestigation.

Use the Work Group Investigation Form to document team findings

and recommendations (see Procedure Section for guidelines forconducting a Work Group Investigation). The completed investigationform is forwarded to the Yard Foreman/Offshore Manager who shallreview the work group investigation. The Yard Foreman/OffshoreManager will arrange for a supplemental investigation (if required) orforward the form to their Facility Manager for review and approval thenthe Safety, Health and Environmental Department for tracking andfollow-up.

Supplemental Investigation – All incidents involving an OSHA “Days Away From Work” incidents shall receive a supplemental investigation.

The Yard/Offshore Manager who reviewed the Work GroupInvestigation has the responsibility to arrange for the SupplementalInvestigation. Use the Supplemental Investigation Form to documentteam findings and recommendations. The purpose of thesupplemental investigation is to involve the appropriate level ofmanagers and employee representatives in the more-serious incidentreviews to aid with identifying underlying causes, corrective actions,and assign action-item responsibilities. Use the Work GroupInvestigation Report as preliminary information for the supplementalinvestigation. A copy of the completed Work Group Investigation formshall be attached to the Supplemental Investigation Form.

Conducting a Work Group Investigation

The following guidelines are provided to promote consistent incidentinvestigation methods using the Work Group Investigation Form. Elements ofeach section of the Work Group Investigation Form are included along withsuggested items for discussion.

Information Block – Print the employee’s name, date and time of theincident, job classification, area or work unit where the incidentoccurred, specific incident location, the date and time the incident was

reported, and the employee’s supervisor.

Investigation Team Members – Print the names of all team memberspresent during the Work Group Investigation. This is not a signatureblock.

Incident Information

Incident Description – Print or write legibly a completedescription of the incident, i.e. What happened, who was



H2.6

involved, materials, vessel numbers or equipment, etc.Include a map or hand drawn diagram of vehicle, equipment,or personnel locations if applicable.

Witness (es) – enter the names of persons who saw theevent. (see Attachment 3

Immediate Corrective Actions – What actions (such asbarricading, personnel notifications, instructions, equipmentrepair, etc.) were taken to abate any unsafe conditions?

Contributing Factors

Material, Equipment, Personal Protective Equipment (PPE),and Environment – What materials (i.e. Forms, lumber, fuels,scaffolds, etc.), and environmental factors (i.e. Sitecondition, weather, time-of-day, etc.) may have contributedto the incident? The type of equipment, condition, and

specific parts involved are important. PPE use, or non-use,that may have contributed to the incident should be listed(i.e. Not wearing hardhat, gloves, faceshield, safety glasses,fall protection, etc.).

Training – Were the affected employees trained in the tasksbeing performed? Does new training need to be developedor does present training need revised? (Safety Department

– confirm that applicable training is documented and currentafter the investigation is completed).

Safety Systems – Were any permits or approvals requiredfor the task? If yes, were they properly completed? (SafetyDepartment – Is the task covered by an auditing system?Does one need to be developed?

Human Factors/Ergonomics –What shift was the affectedemployee working and what part (beginning, middle, end) ofthe shift did the incident occur? Was the person trying tosave time or effort? Did the person have a deadline tomeet? Was it inconvenient for the person to obtainnecessary safety equipment? Did the design of tools or

workstations contribute to the incident?

Task Instructions – Was there a Work Order associated withthe job? If yes, list the number and attach a copy to theinvestigation form. Were job instructions given for the task?Was there an unclear or conflicting assignment ofresponsibility? Rules and Procedures – Review establishedsafety rules and/or procedures that apply to the incident?Were they adequate? Were the rules followed? If not, listdeficiencies. Does a new rule or procedure need to be



H2.7

developed or a present one revised to address incidentconcerns? (Some suggested documents to review wouldinclude Safety Manual, applicable JSEA’s)

Other – List any applicable events or circumstances whichdo not fit the above categories.

Root Causes

Use analysis of the Incident Information and ContributingFactors as aids in determining the root causes of the incident.

Preventive Actions/Recommendations

Use this block to list actions or recommendations which theteam views will correct current conditions or prevent futureincidents. Indicate the person responsible for completing therecommendation and the target date to be entered in the

tracking system.

Yard Foreman/Offshore Manager Review

Supplemental Investigation – Required if for all OSHA “Days Away From Work” incidents.

Sign-off – The Supervisor/Offshore Superintendent, YardForeman/Offshore Manager, Safety, Health andEnvironmental Department representative and VicePresident of respected area must sign and date the form

following their review.

Distribution – Send the original (Record Copy) to the Safety,Health and Environmental Department. All investigationteam members should receive a copy of the investigationreport as well as individuals assigned action-itemresponsibilities.

Conducting a Supplemental Investigation

The following guidelines are provided to promote consistent supplemental

investigation methods using the Moreno Group LLC and SubsidiariesSupplemental Investigation Form. Details of each section of theSupplemental Investigation Form are included along with suggested items fordiscussion.

Information Block – Print the date of the Supplemental Investigationand names of the Team Members. This is not a signature block.

Review of Work Group Investigation – The Supplemental Team willreview the Work Group Investigation for preliminary information.



H2.8

Supplemental Incident Information – List information thatmay have been revealed after the Work Group Investigationwas completed.

Supplemental Contributing Factors – List contributingfactors, which may have not been included in the Work

Group Investigation.

Supplemental Root Causes – List the root causes which theSupplemental Investigation Team has formulated.

Management Systems

Administrative Controls – Was inadequate staffing or timeallotment a factor? Were priorities unclear or conflicting?

Engineering Controls – Were standards, specifications,and/or design adequate? Were Management of Changeprocedures followed?

Preventative Maintenance/Inspection – Was the workscheduled properly? Were the proper parts used? Was animproper extension of service life/inspection period made?

Other – List applicable management systems not includedabove.

Additional Preventive Actions/Recommendations – Listpreventive actions or recommendations, which were notincluded in the Work Group Investigation.

Incident Investigation Training

The SH&E Department will provide Incident Investigation Training to allManagement, First Line Supervision / Offshore Superintendents and/or anydesignated individuals responsible for incident investigations. This training shouldinclude incident investigation techniques, tools to be use (i.e. cameras, drawings,etc.) during the investigation and Dynamic Industries, Inc. Incident Investigation

process / procedure to help ensure contributing factors and root causes that areassociated with the incident are appropriately identified and preventive actions /recommendations are recommended and implemented to completion to prevent anyreoccurrence.



H2.9

Attachment 1





MORENO GROUP LLC AND SUBSIDIARIES’ WORK GROUP INVESTIGATION

EVERY EFFORT SHOULD BE MADE TO ACCURATELY AND COMPLETELY FILL OUT THIS DOCUMENT. ADDITIONALINFORMATION PERTINENT TO THE INVESTIGATION MAY BE AVAILABLE AT A LATER DATE; THEREFORE, THISDOCUMENT CANNOT BE CONSIDERED AS ALL INCLUSIVE.

Employee’s Name Date/Time of Incident Job Classification Incident Site

Location of Incident (Be Specific) Date/Time Reported Employee’s Supervisor

INVESTIGATION TEAM MEMBERS (Print name legibly) Investigation Date:

Supv. 4. 7.

2. 5. 8.

3. 6. 9.

INCIDENT INFORMATION

Incident Description (What happened and Where):

Witness(es):

Immediate corrective actions:

CONTRIBUTING FACTORS – Did any of the following factors contribute to the Incident (Check Yes/No – If

yes, explain)

Material, Equipment, Personal Protective Equipment and Environment: Yes No

Training: Yes No

Safety Systems: Yes No

Human Factors/Ergonomics: Yes No

Task Instructions: Yes No

Rules and Procedures: Yes No

Other: Yes No



ROOT CAUSES

PREVENTIVE ACTIONS/RECOMMENDATIONS (Attach additional forms as necessary)

Preventive Actions/RecommendationsPerson Responsible for

CompletionTarget Completion

Date

1.

2.

3.

4.

5.

6.

7.

8.

9.

10.

11.

12.

13.

14.

15.

YARD FOREMAN/OFFSHORE MANAGER REVIEW

SUPPLEMENTAL INVESTIGATION

REQUIRED (OSHA “Days Away From Work” Incident) – ATTACH THIS FORM TO THE SUPPLEMENTAL

INVESTIGATION

NOT REQUIRED – COMPLETE DISTRIBUTION

SIGN-OFF

Offshore Supt/Supervisor Date:

Yard Foreman/Offshore Manager Date:

Safety Manager/Safety Representative Date:

Vice President Date:



H2.10

Attachment 2





H2.10.a.1

Moreno Group LLC and Subsidiaries’ Supplemental Investigation

INVESTIGATION TEAM MEMBERS (Print name legibly) Investigation Date:

Chair. 4. 8.

1. 5. 9.

2. 6. 10.

3. 7. 11.

REVIEW OF WORK GROUP INVESTIGATION

SUPPLEMENTAL INCIDENT INFORMATION

SUPPLEMENTAL CONTRIBUTING FACTORS

SUPPLEMENTAL ROOT CAUSES



H2.10.a.2

ROOT CAUSES

PREVENTIVE ACTIONS/RECOMMENDATIONS (Attach additional forms as necessary)

Preventive Actions/RecommendationsPerson Responsible for

CompletionTarget Completion

Date

1.

2.

3.

4.

5.

SIGN-OFF

INVESTIGATION TEAM MEMBERS:

1. Date:

2. Date:

3. Date:

4. Date:

5. Date:

6. Date:

7. Date:

8. Date:

9. Date:

10. Date:



H2.11

Attachment 3





H2.11.a.1

Incident Investigation Employee / Witness Statement

Employee Name:

Employee Address:

Company:

Employee Supervisor:

Employee SSN:

Incident Date:

Incident Time:

Incident Location:

To the employee involved or the employee who witness the incident- Briefly explain in your ownwords the circumstances that led to the incident occurring. Also include your involvement in theincident. Your comments are important to help determine the causes of the accident and correct anyunsafe conditions. Thank you.

I have written the above statement and certify that it is true to the best of my knowledge.

Employee / Witness Signature:

Date of Signature:

Supervisor’s Signature:

Date of Signature:





Moreno Group LLCand Subsidiaries SH&EManagement System

Occupational HealthProgram

Page 1 of 5Original: 01/01/2001Revised: 05/01/2008

I1.1

Occupational Health Program

Purpose

The purpose of this program is to provide a systematic method for identifying,evaluating and controlling worker’s exposures to harmful substances.

Scope

The scope of this program is to protect the health of personnel working at MorenoGroup LLC and Subsidiaries by preventing or minimizing exposures to harmfulsubstances. An Industrial Hygiene exposure assessment will be conducted. Basedon the assessment findings Moreno Group LLC and Subsidiaries will take theappropriate corrective action to eliminate or reduce the amount of the known

exposure. Contract employees may also be included with respect to certain jobtasks: however, routine employee exposure monitoring for contract workers will bethe responsibility of the contractor.

Responsibilities

The Facility Manager or Offshore Manager or Designee is responsible for:

Providing the support and/or resources to the appropriate departments toimplement occupational health hazard assessments to identify occupationalhealth hazards and manage the hazards per this program.


Providing assistance and support to appropriate departments to conductoccupational health hazard assessments

Implementing Safe Work Procedures outline in Moreno Group LLC andSubsidiaries’ Safety, Health and Environmental programs to minimizepotential health exposure to employees


Coordinating the applicable industrial hygiene monitoring.

Communicating industrial hygiene monitoring reports to employees involvedin monitoring.

Coordinating the applicable training

Coordinating applicable evaluations per this program



I1.2

The Human Resource Department is responsible for:

Maintaining employee records within employee’s medical record files.

Providing to an employee representative, access to medical records uponwritten request to obtain employee’s medical records.


Completing the necessary training as prescribed by the applicable regulatoryrequirements.

Adhering to the requirements of this procedure and the safe work practicesoutlined in Moreno Group LLC and Subsidiaries Safety, Health andEnvironmental programs.

Requirements

The industrial hygiene hazard assessment is to identify, evaluate and controlemployee exposures within Moreno Group LLC and Subsidiaries’ operations. TheSafety, Health and Environmental Department will oversee hazard assessmentactivities to ensure workers are provided a safe and healthful work environment.Material Safety Data Sheet’s (MSDS’s), process flow diagrams and standardoperating procedures shall be reviewed during this assessment to fully evaluate thepotential for exposure. From experience it is known that the following list of harmfulsubstances may be associated with upstream exploration and production activities inthe Oil and Gas Industry and downstream operations:

- Noise - NORM

- Lead - H2S

- Heat/Cold exposure - Silica

Should a Hazard Assessment identify a potential work place exposure, MorenoGroup LLC and Subsidiaries will conduct adequate sampling to statistically supportthe data findings to reflect true personnel exposure. As a result of this data, MorenoGroup LLC and Subsidiaries will assess potential worker exposures’ Company wideby developing an exposure profile for each target job. Exposure criteria as definedby OSHA.



I1.3

In addition to specific exposure programs, Moreno Group LLC and Subsidiaries willimplement the following general programs:

- Hazard Communication - Personal Protective Equipment

- Hearing Conservation - Bloodborne Pathogens

- NORM - Respiratory Protection

- Lead - Asbestos

- H2S - Benzene

An industrial hygiene hazard assessment will be conducted once every five years forall facilities and shall be consistent with the hazard analysis requirements of thecompanies Safety, Health and Environmental Policies. The results of theseassessments will be included into the facility hazard assessments in accordancewith the Moreno Group LLC and Subsidiaries Safety, Health and Environmental

Management System.

Exposure Control Measures

The measures to be utilized to control worker exposure will be determined by thenature of the chemical or physical agents and the level of exposure identified by thehazard assessment. The following outlines the various methods of control measures(but not limited to) available to Moreno Group LLC and Subsidiaries to eliminate orreduce the worker exposure time or the reduction of contaminant the worker isexposed to.

Process or Material Changes

The substitution of a hazardous material for one that is less harmful tohealth

Change or alteration of a process or operating procedure

Engineering Controls

Isolation or enclosure to reduce the number of employees exposed

Isolation or enclosure of a worker in a control booth or area

Wet methods to reduce the generation of dust

Local exhaust ventilation at the point of generation or dispersion ofcontaminants

General or dilution ventilation

Shielding devices



I1.4

PPE Controls

Personal protective equipment

Good housekeeping and maintenance

Administrative Controls

Adjusting work schedules, rotating job assignments, etc.

Medical surveillance to detect evidence of exposures

Personnel Training

Training and education to supplement all the above

A combination of the methods may be necessary to effectively control the worker’s

exposure to the chemical or physical agents. Management is responsible forproviding the needed training, facilities, equipment and products to provide theworker with a safe and healthful work place.

Monitoring Plan

Moreno Group LLC and Subsidiaries will utilize one or more of the following methodsto assist them in the hazard assessment. The Moreno Group LLC and Subsidiaries’Occupational Health Programs and Management of Change process will determinethe frequency and timing of required monitoring.

Personal – Personal monitoring is the measurement of worker specific exposure to apotentially hazardous substance identified by each specific program and theprograms’ exposure profile for each target job. The monitor will be placed as closeas possible to the site at which the contaminant enters the body. For instance, whensampling for noise the device will be place as close to the ear as possible. Whensampling for respirable contaminates the monitoring or capture device will be placedas close to the worker’s breathing area as possible without affecting his comfort.

Environmental – Environmental monitoring is used to monitor the concentrations of acontaminant in a general area of the workplace as close to the worker as possible.

Biological – Biological monitoring measures the changes in composition of bodyfluid, tissues or expired air to detect the level of contaminant absorption. Forinstance, Personnel placed in a lead exposure abatement program will have bloodanalyzed for lead content.



I1.5

Medical – Medical examinations are used to evaluate the physiological andpsychological response to a contaminant. These types of examinations mayinclude, medical and work history, x-rays, blood and urine tests, pulmonary functiontests, audiometric exams, vision etc.

Administrative

Employee Notification – The Safety, Health and Environmental Department will beresponsible for notifying an employee as required by the specific OccupationalHealth Program in which the employee may be covered under.

Medical Surveillance – The Safety, Health and Environmental Department will beresponsible for identifying employees who shall be placed into a medicalsurveillance program. The examination criteria shall be outlined in the specificOccupational Health Program applicable.

Recordkeeping – The results of all exposure monitoring and medical evaluations areconfidential and will be maintained in the employee’s medical file. This file shall be

located in the Human Resource Department. Access to these documents shall bein accordance with 29 CFR 1910.1020 “Access to Employee Exposure and MedicalRecords.”






Management SystemAbrasive Blasting


I2.1

Abrasive Blasting

Purpose

The purpose of this procedure is to establish a formal process for blasting operationsand to give a basic outline of expectations and procedures.

Scope

This is intended to be a minimum standard for Moreno Group LLC and Subsidiariesfacilities for the safe work practices and procedures while performing abrasiveblasting.

The Facility / Site Manager / Offshore Manager or Designee is responsible for :

Provide the needed leadership, commitment, employee empowerment, and holdpersonnel accountable for the implementation of this procedure.



Being knowledgeable of the applicable safety and health regulations associatedwith this program.



Ensuring that all employees are working safely while blasting operations arebeing conducted and perform a pre-job check of all equipment and PPE beforework commences.

Conduct pre- job safety meetings and JSEA’s with all affected personnel toidentify scope of work, associated job hazards involved, proper precautions for

work planned and PPE.

If scope of work changes, Stop All Work and relate information to all affectedpersonnel by means of safety meeting and JSEA.

Continually communicate employee’s responsibility to use their Stop Work Authority.



I2.2


Training or coordinating the training of managers, supervisors and hourlyemployees on the Abrasive Blasting procedure.

Periodically auditing the quality of checklists, JSEA’s and safety meeting forms

to ensure they reflect safe practices.

Periodic auditing of abrasive blasting operations to ensure that all applicableprecautions indicated on the JSEA are being implemented and that all safe workpractices are being followed.

Participating in pre-job safety meetings and JSEA’s on a periodic basis to ensurecompliance.

Performing/coordinating IH monitoring as needed.


Actively participating in the development and review of the Abrasive Blastingprogram.

Performing pre-job check of all equipment and PPE to ensure that they are in asafe condition.

Ensuring that all safe work practices are being implemented while performingblasting tasks and report all incidents associated with blasting operations.Employees are also responsible for using Stop Work Authority anytime a

condition arises that is potentially unsafe.

Completing assigned activities in a safe manner.


Definitions

Abrasive Blasting - the forcible application of an abrasive to a surface by pneumaticpressure, hydraulic pressure, or centrifugal force.

Abrasive Blasting Respirator - a continuous flow airline respirator constructed so thatit will cover the wearers head, neck, shoulders and upper torso to protect him fromrebounding abrasive.

Silicosis - is characterized by shortness of breath, fever and bluish skin. It could bediagnosed as pulmonary edema (fluid in lungs), pneumonia or tuberculoses. Silicadust causes severe fungal infections, to develop this condition could be fatal



I2.3

Requirements

The Abrasive Blasting program is to implement Safe Work Practices and controlswhen working with abrasive blasting material and equipment. Exposure can be theresult of operations that are being performed with abrasive blasting and can includethe following:

1. Respiratory implications from improper use of personal protective equipment.

2. Exposure to affected employees in adjacent areas to those where abrasiveblasting tasks are being performed.

3. Hearing conservation when working with abrasive blasting equipment oraround areas where abrasive blasting operations are being conducted.

4. Risk of injury from malfunctioning of blasting equipment or from impropermaintenance of such, or as the result of blasting operations.

5. Exposure to substances such as lead on painted material that is blasted.

The Painting and Blasting Foreman is responsible for the implementation andenforcement of this procedure, as well as other procedures that pertain to the scopeof work being performed.

The SH&E Department shall assist in routine auditing of the procedure andimplementation of the procedure to ensure that the procedure is being compliedwith.

Employees performing work must comply with the provisions of this procedure asper training and instructions received, and wear all protective equipment required.

Hazards

A respiratory hazard, called silicosis, is the prevalent hazard. There are 3 types ofsilicosis:

1. Chronic/classic: The most common, usually occurring after 10 years ofexposure to low concentrations. Symptoms may or may not be obvious.Some symptoms in late stages of silicosis may include fatigue, shortness ofbreath, chest pain or respiratory failure.

2. Accelerated silicosis: Can occur after only 5-10 years of high exposure torespirable crystalline silica.

3. Acute silicosis: Occurs after a few weeks to a few years following exposure toextremely high concentrations of crystalline silica.

Exposure occurs during many different construction activities. The most severeexposures have occurred during abrasive blasting with sand to remove paint andrust from surfaces. Silica dust causes severe fungal infections to develop; thiscondition could be fatal.



I2.4

Methods of Compliance

Methods of compliance that reduce or eliminate the risk of exposure includeEngineering Controls, Administrative Controls, Safe Work Practices and Training.


Engineering Controls, methods of isolating or removing a hazard from theworkplace, are one of the most effective methods of hazard reduction. Engineeringcontrols will be utilized to eliminate and / or reduce the exposures of respiratoryhazards associated with abrasive blasting below the PEL. Examples of theengineering controls to be utilized is:

Ventilation

Containing of area utilizing screens or heavy canvas

The use of alternative blast media

Recovery Systems

Blasting Rooms or cabinets

Deadman controls on airlines.

Personal and area air sampling will be performed per Moreno Group LLC andSubsidiaries Occupational Health section of this manual. Air monitoring resultsshould confirm that the engineering controls, administrative controls, Safe Work

Practices and Personal Protective Equipment being utilized are protecting theemployee from hazards related to abrasive blasting. Should air monitoring resultsindicate the hazards are not controlled under the NIOSH PEL, the abrasive blastingprocess will be stopped until appropriate controls are reevaluated and implemented.

The following minimum Personal Protective Equipment shall be worn at all timesduring the abrasive blasting process:

Respiratory Protection (Supplied-Air Respirator helmet or bullet hood withinner shield)

Hearing Protection

Gloves (leather)

Steel toed shoes

When needed, Tyvek Suit to be worn over work clothes



I2.5

The main type of respiratory protection for personnel using blast equipment will be aSupplied- Air Respirator (SAR) otherwise known as a helmet or “bullet hood”. Thisprotects the user by protecting his head, respiration, neck, and shoulders. Theregulator is carried on the waist normally, using a belt clip. The hood constantlyblows breathing air on the user, which keeps the hood at a slight positive pressureabove ambient atmospheric pressure. This pressure will prevent contaminants fromentering the hood, since air is escaping out.

The air used for Supplied Air Respirators shall be of Grade D breathing air, which isair of high purity. Grade D breathing air must meet the following standards:

Oxygen 19.5%-23.5%

Hydrocarbons - 5 mg per cubic meter or less

Carbon Monoxide - 10ppm or less

Carbon Dioxide - 1000ppm or less

Lack of noticeable odor

Suitable in-line air purifying sorbent beds and filters shall be used to ensurebreathing air quality. Sorbent beds and filters shall be maintained and replaced orrefurbished periodically following the manufacture’s recommendations.

If oil lubricated compressor is providing air to the airline respirator, the followingconditions shall be confirmed:

High temperature or carbon monoxide alarm or both, to monitor carbon

monoxide levels. If only high temperature alarms are used, the air supplyshall be monitored at intervals (i.e. at least daily) sufficient to prevent carbonmonoxide in the breathing air from exceeding 10 ppm.

Air lines and fittings that supply respirable air shall not be interchangeable to otherservices.

All respirators shall be cleaned in warm water with a mild detergent or with a cleanerrecommended by the manufacturer and properly stored after each use.


Administrative controls will be utilized when the Facility Manager or designeedetermines or is advised that engineering controls are not providing adequateprotection. Administrative controls can consist of the following:

Scheduling of the abrasive blasting process

Rotating Job Assignments

Medical Surveillance



I2.6


All employees who run the risk of coming in contact with airborne silica dust will gothrough the following procedures:

Pre-employment physical with a physician. This will include a medical &

occupational history to collect data on a worker’s past exposure.

Pulmonary function test (PFT) and evaluation by medical personnel for pre-employment and annually there after.

Respirator Protection Questionnaires to be filled out be employees andevaluated by medical personnel.

Chest X-rays for pre-employment physical and every three (3) years thereafter.

Quantitative or Qualitative fit test to assess the adequacy of respirator fit pre-employment and annually there after. Note: all personnel taking either fittest must be clean-shaven!

More frequent examinations may be necessary for workers at risk or acute oraccelerated silicosis. Exams should include at least the following:

Medical and Occupation history to collect data on worker exposure

Chest X-ray

Pulmonary Function Testing

Annual Evaluation for Tuberculosis

The utilization of personal air monitoring and medical evaluations by the CompanyPhysician will determine if more frequent examinations should be conducted.

Anytime an employee is diagnosed with silicosis, the State Health Department andOSHA will be notified. All cases of silicosis are recordable under the OSHARecordkeeping guidelines.

Safe Work Practices

Methods that reduce the exposure during a task or procedure will be used tominimize exposure. All employees who have the potential of coming in contact withblasting operations shall follow the following Safe Work Practices:

Know which work operations can lead to silica exposure. Signage will beutilized to identify these areas within the facility.



I2.7

Employees should employ the use of hand-washing and hygiene facilitiesbefore eating, drinking or smoking and after a job has been completed.

Do not eat, drink, use tobacco, products, or apply cosmetics in areas wherethere is dust containing crystalline silica.

Wash hands and face before eating, drinking, smoking, or applying cosmetics

outside of the exposure area.

If possible, change into disposable or washable work clothes at the worksite;shower (where available) and change into clean clothing before leaving theworksite.

All PPE should be thoroughly cleaned or disposed of, if applicable. (see Attachment 1)

Areas adjacent to blasting operations shall be properly protected with the useof sand screens to prevent emissions to areas other than blasting areas.

Tarps or screens should be installed whenever airborne emissions becomean irritant to adjacent work areas where employees are working, or wherethere is a safety issue, as in blasting on lead painted surfaces. Tarps orscreens that are installed on lead painted structures that will be blasted will beapproved by the SH&E Department prior to any blasting activities beginning.

Employees shall follow the procedure for hooking up blast hoses. (See Attachment 2)

Housekeeping

Good housekeeping involves a regular schedule of housekeeping activities toremove accumulations of dust and debris. The schedule should be adapted toexposure conditions at a particular worksite.

Supervision

Good supervision is another important work practice. It provides neededsupport for ensuring that workers follow proper work practices. By directing aworker to position the exhaust hood properly or to improve work practice, asupervisor can do much to minimize unnecessary employee exposure to

airborne contaminants.

Various types of blasting media may be used, depending on clientspecifications. Precautions should be made with each media type and safework practices implemented as such.

Material safety data sheets are to be referenced for each blasting media to beutilized and all appropriate precautions should be taken as indicated in datasheets regarding safety, health and environmental concerns.



I2.8

Blasting nozzles are equipped with dead-man controls to allow the operator tostart and stop blasting with one hand.

Dead-man controls shall never be taped or wired open. This would not allowthe operator to shut down blasting rapidly, should the need occur.

Pressure pots (i.e. sand pots) shall meet the most current ASME Boiler andPressure Vessel Code requirements

Pressure pots shall have all associated equipment (i.e. locking valves,gauges, etc) identified within attachment 2.

Energy Isolation Procedures (i.e. Lockout / Tagout) shall be followed prior andduring the loading of all pressure pots (i.e. sand pots). Only the OffshoreSuperintendent or designated Foreman shall open sand pots.

Machines, hoses and equipment (i.e. deadman controls, sand pots, etc.) must

be inspected daily with deficiencies logged down. Defective equipment mustbe replaced immediately before work is resumed.

All hoses shall have safety pins and whipchecks on the connectors to preventinadvertent disconnection.

Never adjust nozzle with the abrasive f lowing .

Respirators shall be inspected before each use and during cleaning, and shallbe cleaned after each use. Respirator inspection shall include the following:

o Check for function, tightness of connections, and the condition of thedifferent parts including, but not limited to, the face piece, head straps,valves, connection tube, cartridges, and filters.

o Check plastic and rubber parts for pliability and signs of deterioration.

o All inspections shall be done per manufacturer’s specifications.

o If using respirators, do not alter the respirator in any way.

All areas that are adjacent to blasting operations shall be properly guarded

against sand emissions by the use of blasting screens or tarpaulin. Noblasting shall be conducted until all areas are appropriately guarded and allareas are protected.

All vehicles should be parked in designated areas and not withincontaminated areas.

The SH&E Department shall make final approval prior to blasting on surfacesthat contain lead based paint.



I2.9

Training

All employees subject to potential silica exposures shall be provided informationabout adverse health effects, work practices, Hazard Communication, Safe WorkPractices and use and care of personal protective equipment. The following trainingtopics will perform as part of Moreno Group LLC and Subsidiaries New Employee

Orientation / SH&E Training and as needed there after:

Signs and Symptoms of silicosis

Hazards associated with abrasive blasting.

Methods and equipment used for personnel protection including respiratoryprotection.

Safe Work Practices to be utilized for abrasive blasting operations.

Personal hygiene practices associated with blasting operations.

Inspection, care, proper use and storage of personal protective equipmentand respiratory equipment.





I2.10

Attachment 1





I2.10.a.1





I2.11

Attachment 2





I2.11.a.1

PROCEDURE FOR HOOKING UP

BLAST HOSE AND TWIN LINE

The following is a procedure for hooking up the blast hose and the twin lines to prevent twin lines from getting

crossed over to another blast hose.

1) Each section of blast hose will be laid out with its twin lines. The blast hose and twin lines will betaped together.

2) When connecting sections of blast hose and twin lines, the blast hose will have a safety pin in the

crowfoot connection and a whip check will be installed on both ends of the blast hose connections.

3) A “deadman” is connected to the end of the twin line once the needed length of blast hose and twin

lines has been connected together. Note: The twin line that connects to the “deadman” MUST have a

safety shutoff valve in the “Supply Air” line.(Refer to Picture 1)

Picture 1

4) When connecting the twin lines to the control valves on the sand pot a qualified employee will connect

the “Supply Airline” of the twin lines to the “Supply Air Fitting” on the control valve of the sand pot.

(Refer to picture 2)

Picture 2

5) The “Return Airline” coming from the “deadman” to the control valve on the sand pot will not be

hooked up to the control valve on the sand pot at this time.

6) The qualified employee will open the valve to supply air to the control valves. He will hold the “return

airline” and have the blaster activate the “deadman”. If air comes out of the “return line” then he will

have the blaster release the “deadman”. This verifies that this twin line is connected to the correct

“deadman”. (refer to picture 3)

“Supply Air Fitting” to deadman

Safet Shutoff Valve

Deadman



I2.11.a.2

Picture 3

7) The qualified employee will connect the “return airline” to the “pilot valve”. (refer to picture 4)

Picture 4

8) The qualified employee will then label the control valve. Labeling can be color tape, duct tape labeled with a

number or duct tape with the blaster’s name. The blaster will label the “deadman” the same as the control valve

on the sand pot. (Refer to picture 5 &6)

Picture 5 Picture 6

Valve to supply air

to the control valves

“Pilot Valve” for the“return airline” from

the deadman



I2.12

Attachment 3





I2.12.a.1

Revised Abrasive Pot IllustrationNever Open Hatch Cover on Top of Pot Without Reviewing all

JSEA’s & DII Policies & Procedures Required for Job Task.

AluminumCam Lock Lid – Lock Out

DeviceLower Rack &Insert PinsBefore Travel

Pressure ReliValve, SecondPressure GauSecondary Bl

Off Valve

PrimaryPressureGauge

Auto AirValve PilotValve 1 ¼” Choke Valve

Air Inlet, 2” Locking BallValve – Apollo Part # 70-108-01Manufacturer (Conbraco Ind.,

Inc.Lock Out / Tag Out HardwareRequired!

InspectionPlate

Top Hatch & Cam Lock Assembly Beneath CamLock Lid (Insure that the Vessel is not pressurized

prior to Releasing Cam Locks.

Primary BleedOff Valve. 1 ¼” Locking BallValve. ApolloPart # 70-106-01

Manufacturer(Conbraco Ind.,Inc.) Lock Out /Tag OuthardwareRequired.Ventura BleedOff to eliminate

ice plugging.

Insert Pin beforetravel & Removal

1 ¼” Ball ValvesThompson’sValves






Aluminum ProtectionPage: 1 of 10Original: 01/12/2005Revised: 05/01/2008

I3.1

Aluminum Protection

Purpose

The purpose of this program is to establish and implement practices and proceduresfor protecting the health of Moreno Group LLC and Subsidiaries employees whomay be exposed to aluminum on the job. This program also establishes methods forcomplying with the OSHA Construction Industry Air Contaminants, 29 CFR1910.1000.

Scope

The scope of this program applies to all Moreno Group LLC and Subsidiaries

projects and employees involved with aluminum construction projects and activities.

This program also applies to all subcontractors, working under the direct control ofMoreno Group LLC and Subsidiaries, involved with aluminum construction projectsand activities. Subcontractors must provide all manpower, supplies, equipment,training, and medical examination and testing necessary to comply with thisprogram.

Responsibilities

The Facility Manager / Yard Foreman or designee is responsible for:

Informing the SH&E Department of the any upcoming project that may havethe potential of containing aluminum exposure.

Inform any subcontractors that may be working on the project that aluminumexposure may be possible.

Ensure that subcontractors understand and comply with this policy.

The First Line Supervisor is responsible for


Designating employees for the project and ensuring that a list of employees isprovided to the SH&E Department to report to the Medical Review Officer tobe placed in a medical surveillance program and receive all necessarysurveillance prior to job commencing, such as Pulmonary Function Testingand questionnaire, as well as chest X-rays.



I3.2

Coordinate with the SH&E Department to see if all designatedemployees have received aluminum training and / or up to date. Iftraining is needed, coordinate with the SH&E Department date andtime for which training will take place.

Ensuring that barricade and applicable warning signs have beenposted prior to the startup of the project.

Ensuring that all safety measures are being followed throughout theproject.

Performing with and without the SH&E Department a pre-jobinspection and continuous monitoring of jobsite to ensure that all safework practices are being done.

Coordinating with the SH&E Department at the end of the project orwhen any employee is removed from the project that those employeesall go to the Medical Review Officer and receive chest X-rays.

The Safety, Health and Environmental Department is responsible for

Coordinating with First Line Supervisor to determine which projectsand employees will be working with aluminum and have potentialexposure.

Perform any training, such as respiratory training and fit testing, as wellas pre-job aluminum training, for all employees that need this training.

Coordinating and performing any air monitoring which may be

required, as well as coordinating any medical surveillance needed withthe Human Resources Department.

Daily audit jobsites, along with First Line Supervisors, to ensurecompliance with this procedure.

Scheduling of third party air monitoring and notifying personnel ofmonitoring results.

The Human Resources Department is responsible for

Authorizing all employees to go to the Medical Review Officer andreceive any medical surveillance that is needed for aluminum projects.

Maintaining all medical records for all employees that will work on theproject.



I3.3

Informing the SH&E Department of any employee that is unsuitable towork on the project due to problems with chest X-rays or medicalconditions that do not allow employee to wear a respirator.

Authorizing all employees to return to the Medical Review Officer for afollow-up medical surveillance once project is complete or if employeehas been removed from the project.

The Employee is responsible for

Understanding and complying with this policy/procedure.

Immediately reporting to his immediate supervisor any problem, whichmay arise, or any symptoms of aluminum exposure.

DEFINITIONS

8-hour TWA Concentration - 8-hour Time-Weighted Average concentrations

for airborne contaminants - common units for reporting daily airbornealuminum exposures. This is the aluminum exposure received per dayexpressed as a constant exposure for eight (8) hours at a steady stateconcentration.

Aluminum - Aluminum is the most abundant metal and the third mostabundant element, after oxygen and silicon, in the earths crust. It is widelydistributed and constitutes approximately 8 percent of the earth’s surfacelayer. However, aluminum is a very reactive element and is never found asthe free metal in nature. It is found combined with other elements, mostcommonly with oxygen, silicon, and fluorine. Aluminum metal is light in

weight and silvery-white in appearance. Since pure aluminum is very soft,aluminum is often mixed with small amounts of other metals to form aluminumalloys, which are stronger and harder.

Competent Person - One who is capable of identifying existing andpredictable aluminum hazards in the surroundings or working condition andwho has authorization to take prompt corrective measures to eliminate them.

HEPA filter - High Efficiency Particular Air filter - Filters that remove 99.97%of all particulate 0.3 microns or greater in diameter.

mg/m - Milligrams per cubic meter of air. Common units for reportingairborne concentration of aluminum.

NIOSH/MSHA - National Institute of Occupational Safety and Health/MineSafety and Health Administration - Federal agencies which conduct researchon safety and health issues and test and certify respirators.



I3.4

PEL - OSHA requires employers of workers who are occupationally exposedto aluminum to institute engineering controls and work practices to reduceand maintain employee exposure at or below permissible exposure limits(PEL's). The employer must use engineering and work practice controls, iffeasible, to reduce exposures to or below an 8-hour time-weighted average

(TWA) of 15 mg/m for total aluminum or 5 mg/m for respirable fractions.

REQUIREMENTS

PERMISSIBLE EXPOSURE LIMIT

The Permissible Exposure Limit (PEL) for airborne aluminum exposure is

fifteen (15) mg/m , as an 8-hour TWA concentration. This is the maximum 8-hour average concentration of total aluminum that an employee may beexposed to during each work day.

Whenever worker’s airborne total aluminum exposures exceed or areexpected to exceed the PEL, the following will be implemented for the work

project:

Competent person

Employee information and training

Employee medical surveillance

Airborne respirable aluminum exposure monitoring

Record keeping

PPE / Housekeeping

No employee will be exposed to airborne aluminum above the PEL withoutproper protection.

The following methods will be used, as feasible and effective, for maintainingairborne aluminum exposures below the PEL:

Engineering controls, such as general area ventilation forcontainments, local exhaust ventilation for spot removal, vacuum

blasting or vacuum equipped power tools. When ventilation forcontainments is used, manometers and/or velometers, will be used toevaluate the mechanical performance of the ventilation system

Warning signs

Hygiene facilities and practices



I3.5

Protective work clothing and equipment

Respiratory protection

Housekeeping

During the period that respirators are worn, the protection factor of the

specific respirator may be used to determine employees’ exposure toairborne aluminum and to achieve compliance with the PEL.

COMPETENT PERSON

All work activities where employee airborne aluminum exposures may exceedthe PEL will include a competent person in both the planning and performingstages of projects involving aluminum exposure.

The competent person will be a person with training and experience inconducting jobs involving airborne aluminum exposure. The competent

person will have the capability of identifying hazards and the authority to takeimmediate action to eliminate them.

The competent person will be at the work site at all times while airbornealuminum exposure activities are in progress. They may have other jobduties, but must be able to monitor work continuously for hazards ordeficiencies, and the authority to take immediate corrective action.

EMPLOYEE INFORMATION AND TRAINING

All employees who work on projects where airborne aluminum exposures are

known to or expected to be at or above the PEL will be provided informationand training on the hazards of airborne aluminum and measures forcontrolling these hazards and protecting health.

Employees will receive initial comprehensive airborne aluminum trainingbefore performing work that may involve airborne lead exposure. Thistraining will be repeated annually as a refresher course.

The content of airborne aluminum training will include:

The specific nature of activities or operations that may result in

airborne aluminum exposure above the Action Level

The health effects and risks of airborne aluminum exposure

OSHA standards and guidelines for airborne aluminum exposure

Engineering controls, including containments and ventilation systems



I3.6

Work practices for controlling airborne aluminum exposure, includinginformation, warning signs, housekeeping, protective clothing andproper hygiene facilities and practices

Respiratory protection for controlling airborne aluminum exposure,including fit testing

Methods for monitoring airborne aluminum concentrations andexposures

The medical surveillance program including medical removal

When conducting airborne aluminum exposure activities on a multi-employerwork site, Moreno Group LLC and Subsidiaries will notify other employers ofthe nature of the aluminum exposure system in effect, and the potential needto take measures to protect their employees. Notification to other employerswill contain the following: NOTICE - MORENO GROUP LLC ANDSUBSIDIARIES IS PERFORMING ACTIVITIES AT THIS JOB SITE THAT

MAY CREATE AIRBORNE ALUMINUM . ALL CONTRACTORS AT THISJOB SITE SHALL REMAIN CLEAR OF ANY ALUMINUM EXPOSUREAREA. ACCESS INTO ALUMINUM EXPOSURE AREA IS CONTROLLEDBY THE MORENO GROUP LLC AND SUBSIDIARIES JOB FOREMAN.ONLY TRAINED, QUALIFIED WORKERS ARE PERMITTED TO ENTERALUMINUM EXPOSURE AREAS AND MUST WEAR RESPIRATORS ANDPROTECTIVE CLOTHING.

MEDICAL SURVEILLANCE

All employees who may be exposed to airborne aluminum above the PEL or

who may be required to wear a respirator will be provided initial and periodicmedical examinations.

All employees who may be exposed to airborne aluminum above the PEL willbe provided with initial and periodic biological monitoring in the form of bloodsampling and analysis of aluminum. Employees will be tested both pre andpost-job to determine blood serum amounts of aluminum and to ensure thatlevels are below twenty-four (24) micrograms/cubic meter.

All employees who are temporarily removed from aluminum exposure due toelevated blood aluminum levels or at the recommendation of a physician may

be reassigned other job duties at the site that do not involve exposure toairborne aluminum above the PEL.

Chest X-rays will be performed on all employees that are required to work onaluminum projects to ensure lung capacity in performing these tasks. ChestX-rays will be performed on all employees both pre and post-job.



I3.7

WARNING SIGNS

Warning signs will be posted in the work area around activities whereairborne aluminum exposures may exceed the PEL. The work area can bedemarcated by Yellow Caution tape.

Signs will be posted at every accessible side of the work area. These signs

will be easily visible from a distance so that employee can read the sign andtake necessary protective measures before entering the work area. Signs willread as follows: WARNING, ALUMINUM WORK AREA.

The competent person will control access of persons into work area.

All persons entering work areas will wear protective clothing and respirators.

Eating, drinking, smoking, and chewing is prohibited in work areas and anyarea where airborne aluminum exposure may exceed the PEL.

CONTAINMENTS

Where required by federal, state, or local regulation, the project sponsor, orthe project owner, containments will be constructed and used as specified.

The purpose of containments is to restrict or prevent the spread of airbornealuminum or debris to surrounding areas or the environment. While theproper use of containments can help protect the public and the environment,they generally cause a significant increase in airborne aluminumconcentrations in the work area. Containments may increase the potential forhigher employee aluminum exposures. Therefore, the use of well designed

exhaust ventilation and the use of more protective respirators may benecessary to properly protect workers.

Containments may include any of the following:

Rigid or flexible barriers or sheets surrounding the work area

Complete unventilated enclosures built around the work area

Complete enclosures maintained under negative pressure by exhaustventilation with exhaust air filtration

Containments may also require the construction and use of platforms orscaffolding. These may be stationary or movable, ground supported orsuspended.



I3.8

PERSONAL HYGIENE PRACTICES

All employees whose airborne aluminum exposures may exceed thePermissible Exposure Limit will, at a minimum wash, their hands and facebefore breaks, at lunch and at the end of each work shift.

An adequate number of clean lavatory and hand washing facilities will be

provided. These will comply with the OSHA Standard, 29 CFR 1926.51,Sanitation.

PROTECTIVE CLOTHING AND EQUIPMENT

Protective clothing and equipment will be worn by all employees whoseairborne aluminum exposures may exceed the Permissible Exposure Limit.Protective clothing and equipment will be provided at no cost to theemployee.

Protective clothing will include disposable full body coveralls. Other

protective equipment will include faceshields, hats, gloves, shoes ordisposable shoe covers, eye protection, and hearing protection asappropriate.

Disposable protective clothing will be used for no more than one (1) work day.They will be disposed of properly. Protective clothing and equipment will beworn by all employees performing the following activities where aluminumemissions are present unless exposure monitoring proves otherwise: Whenabrasive blasting, cleanup of expendable abrasives, abrasive blastingenclosure construction, movement and removal, power tool cleaning with andwithout dust collection systems, manual scraping, manual sanding, manual

demolition of structures, heat gun applications, welding, cutting, torch burning,chemical stripping and lead contamination/emergency clean-up activities.

All employees involved in welding on aluminum structures will be required towear long sleeved shirts, chaps, neck protection, etc. to prevent exposure toultraviolet radiation and prevention of flash-burns from welding arc. Twoforms of eye protection (glasses and faceshield / welding shield) will berequired during any cutting or welding operations. Additionally, handprotection will be worn at all times to prevent burns, cuts, etc.

RESPIRATORY PROTECTION

Respiratory protection will be used in combination with engineering controlsand work practices to maintain employee airborne aluminum exposures belowthe Permissible Exposure Limit.

Respirators will be worn by all employees, other contractors, inspectors, orobservers who may be exposed to airborne aluminum at or above thePermissible Exposure Limit.



I3.9

The selection, use, maintenance, and inspection of respirators will beaccording to Moreno Group LLC and Subsidiaries Respiratory ProtectionProgram. Qualifications for respirator users are also contained in thisprogram. Below is the type of respirator that will be utilized when aluminumexposure is above the Permissible Exposure Limit:

3M 6000 Series ½ face respirator w/ P100 particulate filters

P95 particulate irritant facemask

In additional to respiratory protection, Moreno Group LLC and Subsidiarieswill implement both general and specific ventilation to ensure that allexposure is minimized while employees are working on aluminum structures.Ventilation will be setup as to not impact surrounding areas and in such amanner to adequately ventilate the work area to exposures below PEL, ifpossible. If ventilation fails to achieve the goal of lowering exposure to belowPEL, respiratory protection will be implemented, as well as continuousventilation.

EXPOSURE MONITORING

For each work project, personal air samples will be collected to determineairborne aluminum exposures to employees performing tasks involvingaluminum exposure. Full shift (at least 7 hours) air samples will be collectedfor each job classification in each work area. The air samples will be takenfor the shift with the highest expected exposure level. Moreno Group LLCand Subsidiaries will implement employee protective measures until resultsof the employee exposure assessment are received. The competent personwill be responsible to ensure that exposure monitoring is performed.

Where initial monitoring indicates that aluminum exposures are below thePEL, and where work activities and conditions will remain the same as at thetime of initial sampling, additional monitoring need not be repeated for thatwork project. A written record of the air monitoring data will be kept at the jobsite.

Where initial monitoring indicates that airborne aluminum exposures arebelow the PEL, additional representative exposure monitoring will beconducted at least once every six (6) months for that work project. Whereinitial monitoring indicates that aluminum exposures are above the PEL,

additional representative exposure monitoring will be conducted at least onceevery three (3) months. Representative monitoring should be conductedduring the beginning of each different phase of the project or when changesoccur to determine range or exposures for aluminum removal and clean-upactivities.

All air samples will be collected and analyzed according to NIOSH 7082Method or equivalent. All samples will be analyzed by laboratories accredited



I3.10

under the Laboratory Accreditation Program of the American IndustrialHygiene Association for metals analysis.

All exposed employees will be notified in writing of the monitoring resultswithin five (5) days after receiving these results.

Initial exposure monitoring may not be required when previously collected

data has conclusively determined that current job condition exposure levelswill be less than the PEL.

HOUSEKEEPING

Accumulations of aluminum-containing dust and debris generated by workactivities will be removed and cleaned daily.

All persons doing the clean-up will be trained in performing aluminumactivities, respirator qualified, and participate in the medical surveillanceprogram. Respirators and protective clothing will be worn by all persons

doing the cleanup unless exposure monitoring proves otherwise.

Wherever feasible, HEPA-filtered vacuum cleaners will be used forhousekeeping.

All aluminum-containing dust and debris will be collected into sealedcontainers. The waste will be tested to determine whether it will be disposedas hazardous or non-hazardous waste.

RECORDKEEPING

All records relating to training, medical examinations, blood aluminummonitoring, exposure monitoring, and project specific requirements will bemaintained by Moreno Group LLC and Subsidiaries, for the employees lengthof employment plus 30 years.

OTHER RELEVANT INFORMATION

The compliance program will be kept available at the work site forexamination by an affected employee or authorized person/agency.

The compliance program will be revised and updated at least annually.




AsbestosPage: 1 of 18Original: 01/01/2008Revised: 06/01/2009

I4.1

Asbestos Program

Purpose

The purpose of this program is to provide for Moreno Group LLC and Subsidiariesemployees and contractors an acceptable method for managing an environment thatshows potential for employee exposure to asbestos that is at or above the PermittedExposure Level. (PEL)

Scope

The scope of this document will be to describe methods of eliminating orminimizing exposures to Asbestos by the following methods:

Asbestos Identification,

Engineering Controls and Procedures,

Personal Protective Equipment (PPE),

Employee Training Requirements,

Employee Medical Requirements,

Administrative Control.

Moreno Group LLC and Subsidiaries will make every reasonable effort to ensurethat no employee is exposed to an airborne concentration of asbestos in excess ofthe current PEL, but provides contingency for exposure that includes, at a minimum,medical surveillance.

This program applies to all work where one of our employees may be occupationallyexposed to asbestos. All work related to abatement, construction, alteration, orrepair, including painting and decorating, during the removal of Asbestos Containing

Material (ACM) within dry walls, insulation, floor tile, etc. The Moreno Group LLCand Subsidiaries, Facility Manager is responsible for its implementation, and copiesof this written program may be obtained from this person.



I.4.2

Responsibilities

The Facility Manager / Site Manager or Designee is responsible for:

Understand and comply with the requirements of this procedure. Ensure thatpersonnel with potential for exposure to asbestos are placed into anymandated medical surveillance program

Ensure that all work activities and documentation of this program aremaintained on site, during the course of activities that have potential toprecipitate employee possible exposure to asbestos.

Ensure that personnel performing asbestos monitoring are qualified to do so,and are adequately trained to the degree that monitoring results can beconsidered reasonably accurate.

Audit compliance with the procedure.

The First Line Supervisor or Designee is responsible for:

Understand and comply with the procedure.

Confer with Facility/Site Mgr., SH&E Dept., or Designee as to any potential orsuspected asbestos exposure.

Ensure that personnel assigned to tasks that involve potential asbestosexposure are placed into any mandated medical surveillance program that isappropriate for asbestos

Ensure that employees performing tasks with potential for asbestos exposureare adhering to all rules set out in the Job Safety and Environmental Analysis(JSEA), including use of all appropriate PPE.

Make suggestions to Management and/or other appropriate individualsconcerning improved asbestos management techniques or procedures.

Initiate resolution of any situation in which an employee has exercised his/herStop Work Authority.

The SH&E Department or designee is responsible for:

Understand and comply with procedure.

Coordinate and conduct (or cause to be conducted) all asbestos relatedtraining, (to include, but not limited to) all elements of appropriate RespiratoryProtection Program.



I4.3

Coordinate placement of employees into any mandated Medical SurveillanceProgram as per OSHA Standard, or Company Physician recommendation.

Coordinate training on Instrumentation and Procedure for all relevant aspectsof our asbestos monitoring program.

Make suggestions to Management and/or other appropriate individuals

concerning improved asbestos management techniques or procedures.

Provide to HR Dept. any Personal Monitoring Result that is considered to bea potential for exposure, for placement into employee’s medical file.

Provide to employee written notification of his/her asbestos exposure.

The Human Resource Department or designee is responsible for:

Understand and comply with procedure.

Maintain records of employee’s exposures, and subsequent medicalexaminations performed by Moreno Group LLC and Subsidiaries ApprovedPhysicians.

Assist in placement of employees, who are required to do so, into a medicalsurveillance program that is appropriate for possible asbestos exposure.


Understand and comply with this procedure.

Understand that Stop Work Authority is their duty should they observe anunsafe condition or activity , and that the Stop Work Authority will not beoverridden until such time that the problem(s) have been remediated, or untilsuch time that supervision determines that the condition or activity is not unsafe.

Abide to all posted signs and labels identifying Asbestos Containing Materialand / or Presumed Asbestos Containing Material and do not disturb thismaterial unless authorized by a Competent Person and trained to do so.

Understand and follow all task specific Job Safety and Environmental

Analysis (JSEA) evaluations, including use of all required PPE.

Notify their supervisor immediately should they observe a condition that maylead to an exposure to asbestos.



I.4.4

The Host Facility is responsible for :

Host facilities are responsible for posting warning signs and labels on vessels,lines, bulkheads, or other fixtures that contain or are otherwise associatedwith asbestos.

Responsible for providing a site-specific Training/Orientation.

Definitions

Acute effect means an adverse effect on the human body with symptoms ofhigh severity coming quickly to a crisis. Acute effects are normally the resultof short-term exposures and short duration.

Acute exposure means a single exposure to a toxic substance that result insevere biological harm or death. Acute exposures are usually characterizedas lasting no longer than a day.

Asbestos includes chrysotile, amosite, crocidolite, tremolite asbestos,anthophyllite asbestos, actinolite asbestos, and any of these minerals thathave been chemically treated and/or altered.

Asbestos-containing material (ACM) means any material containing morethan 1% asbestos.

Assistant Secretary means the Assistant Secretary of Labor forOccupational Safety and Health, U.S. Department of Labor, or designee.

Authorized person means any person authorized by the employer andrequired by work duties to be present in regulated areas.

Building/facility owner is the legal entity, including a lessee, whichexercises control over management and record keeping functions relating to abuilding and/or facility in which activities covered by this standard take place.

Certified Industrial Hygienist (CIH) means one certified in the practice ofindustrial hygiene by the American Board of Industrial Hygiene.

Chronic means an adverse effect on the human body with symptoms that

develop slowly over a long period of time or that frequently recur. Chroniceffects are the result of long-term exposure and are of long duration. Chronichealth concerns include lung cancer, asbestosis, mesothelioma and cancer tothe stomach and colon.

Competent Person is a person who is capable of identifying existingexposure hazards in the workplace, and selecting appropriate controlstrategy(s) to address them, and who has authority to take prompt correctivemeasures to eliminate them.



I4.5

Director means the Director of the National Institute for Occupational Safetyand Health, U.S. Department of Health and Human Services, or designee.

Employee exposure means that exposure to airborne asbestos that wouldoccur if the employee were not using respiratory protective equipment.Exposure to asbestos has shown but may lead to but not limited to lungcancer, asbestosis, mesothelioma, and cancer of the stomach and colon.

Fiber means a particulate form of asbestos 5 micrometers or longer, with alength-to-diameter ratio of at least 3 to 1.

Friable means material that can be crumbled with hand pressure and istherefore likely to emit fibers.

High-efficiency particulate air (HEPA) filter means a filter capable oftrapping and retaining at least 99.97 percent of 0.3 micrometer diametermono-disperse particles.

Homogeneous area means an area of surfacing material or thermal systeminsulation that is uniform in color and texture.

Industrial hygienist means a professional qualified by education, training,and experience to anticipate, recognize, evaluate and develop controls foroccupational health hazards.

Non-Friable means a material that generally does not emit airborne fibersunless subjected to sanding or sawing operations.

PACM means presumed asbestos containing material.

Presumed asbestos containing material means thermal system insulationand surfacing material found in buildings constructed no later than 1980. Thedesignation of a material as "PACM" may be rebutted pursuant to paragraph(j)(8) of this section.

Regulated area means an area established by the employer to demarcateareas where airborne concentrations of asbestos exceed, or there is areasonable possibility they may exceed, the permissible exposure limits.

Surfacing ACM means surfacing material which contains more than 1percent asbestos.

Surfacing material means material that is sprayed, troweled-on or otherwiseapplied to surfaces (such as acoustical plaster on ceilings and fireproofingmaterials on structural members, or other materials on surfacesfor acoustical, fireproofing, and other purposes).



I.4.6

Thermal System Insulation (TSI) means ACM applied to pipes, fittings,boilers, breeching, tanks, ducts or other structural components to preventheat loss or gain.

Thermal System Insulation ACM means thermal system insulation whichcontains more than 1 percent asbestos.

Exposure Assessment and Monitoring

Ini t ia l Expos ure Assessment

Competent Moreno Group managers or supervisors will evaluate all asbestosoperations (some exceptions exist only when we are involved in Class IV work) forthe purpose of predicting whether exposure levels during the planned asbestos workcan be expected to exceed the PELs, and thus whether additional monitoring, andother precautions are required.

Our competent person will conduct all initial exposure assessments.

In known PACM or ACM work environments we will presume that our employees areexposed in excess of the TWA and excursion limit and implement the necessaryprotective measures, until we conduct exposure monitoring and determine thatworkers will not be exposed in excess of the PEL of .1 fiber per cubic centimeter ofair as an eight (8) hour time-weighted average (TWA), or make a negative exposureassessment.

The initial exposure assessment requirement can be satisfied by two methods:

A negative exposure assessment demonstrating that the activity involving

the asbestos material is unlikely under all foreseeable conditions to result inconcentration above the PEL.

Initial exposure monitoring determined from breathing zone air samples thatare representative of the 8-hour TWA and 30-minute short-term exposures.

Monitor ing

Third party monitoring firms will be used for personnel exposure and area monitoringthat complies with all OSHA requirements.

Employ ee Noti f icat ion

Employees will be notified as to the monitoring results, in a manner that is consistentwith current privacy laws, mandated by federal guidelines and regulations.



I4.7


A medical surveillance program will be instituted for all employees who for acombined total of 30 or more days per year are engaged in Class I, II, and III work orare exposed at or above the PEL.

When our employees are required by the standard to wear a negative pressure

respirator, we make sure those employees are physically able to perform the workand use the equipment as determined by a physician. Documentation of pulmonaryfunction tests, fit tests, and respirator training is available through the SH&EDepartment.

We ensure that all medical examinations and procedures are performed by or underthe supervision of a licensed physician, and are provided at no cost to the employeeand at a reasonable time and place.

Our medical surveillance program includes the following:

1. Medical examinations and consultations

Medical examinations and consultations are available to each employee asrequired by the OSHA Standard. .

When our employee is assigned to an area where exposure to asbestos maybe at or above the PEL for 30 or more days per year, or engage in Class I, II,or III work for a combined total of 30 or more days per year, a medicalexamination must be given within 10 working days following the thirtieth dayof exposure; and at least annually thereafter.

2. Information provided to the physician

The following information will be provided to the examining physician:

A copy of the asbestos standard including Appendices D, E, and I. (asrequested)

A description of affected employees' duties as they relate to their exposure.

The employees' representative exposure level or anticipated exposure level.

A description of any personal protective and respiratory equipment used or tobe used.Information from previous medical examinations that is not otherwiseavailable to the examining physician.

3. Physician's written opinion

The written opinion of the examining physician should minimally contain theresults of the medical examination and diagnostic procedures.



I.4.8

Recordkeeping

Data

Where we rely on IH Monitoring and Product Sampling that demonstrates thatproducts made from or containing asbestos or the activity involving such products ormaterial are not capable of releasing fibers of asbestos in concentrations at or above

the permissible exposure limit and/or excursion limit under the expected conditionsof processing, use, or handling, the product data will minimally include:

The testing protocol, results of testing, and/or analysis of the material for therelease of asbestos.

A description of the operation exempted and how the data support theexemption.

Other data relevant to the operations, materials, processing, or employeeexposures covered by the exemption.

We maintain this record for the duration of the employer's reliance upon such data.

Exposu re Measurements

An accurate record of all measurements taken to monitor employee exposure toasbestos as prescribed by the OSHA Standard will be maintained.

Note: We may utilize the services of competent organizations such as industry tradeassociations and employee associations to maintain the records required by thissection.

This record includes at least the following information:

The date of measurement.

The operation involving exposure to asbestos that is being monitored.

Sampling and analytical methods used and evidence of their accuracy.

Number, duration, and results of samples taken.

Type of protective devices worn, if any.

Name, social security number, and exposure of the employees whoseexposures are represented.

We will maintain this record for at least thirty (30) years.



I4.9

Medical Surv ei l lance

We have established and do maintain an accurate record for each employee subjectto medical surveillance.

The record includes at least the following information:

The name and social security number of the employee.

A copy of the employee's medical examination results, including the medicalhistory, questionnaire responses, results of any tests, and physician'srecommendations.

Physician's written opinions.

Any employee medical complaints related to exposure to asbestos.

We make sure that this record is maintained for the duration of employment plus

thirty (30) years.

Training and Training Records

Training will be provided to all employees who maybe potential exposed to AsbestosContaining Material prior to their initial assignment and annually thereafter ifrequired. All employee training records will be kept for one (1) year beyond the lastdate of employment.

Data to Rebut PACM

Where the building owner and we have relied on data to demonstrate that PACM isnot asbestos-containing, we maintain such data for as long as they are relied uponto rebut the presumption.

Competent Person Requirements

At the worksite covered by this plan, we have designated Moreno Group LLC andSubsidiaries Construction Manager, and Moreno Group LLC and SubsidiariesEnvironmental Manager, or their qualified agent as our competent person, havingthe qualifications and authorities for ensuring worker safety and health.

Inspect ions

In addition to our initial inspection, the designated competent person will visit the jobsites to supervise the following:

For Class I jobs, on-site inspections are made at least once during each work shift,and at any time an employee requests one.



I.4.10

For Class II, III, and IV jobs, on-site inspections are made at intervals sufficient toassess whether conditions have changed, and at any reasonable time an employeerequests.

On all worksites where our employees are engaged in Class I or II asbestos work,our competent person will perform or supervise the following duties, as applicable:

Set up the regulated area, enclosure, or other containment.

Ensure (by on-site inspection) the integrity of the enclosure or containment.

Set up procedures to control entry to and exit from the enclosure and/or area.

Supervise all employee exposure monitoring required by this section andensure that it is conducted as required by paragraph (f) of this section.

Ensure that employees working within the enclosure and/or using glove bagswear respirators and protective clothing as required.

Ensure through on-site supervision, that employees set up and use,engineering controls, use work practices and personal protective equipmentin compliance with all requirements

Ensure that employees use the hygiene facilities and observe thedecontamination procedures.

Ensure that through on-site inspection, engineering controls are functioningproperly and employees are using proper work practices.

Competent Person Training

Our competent person has received the following training for Classes I and IIasbestos work:

1. All aspects of asbestos removal and handling, including: abatement, installation,removal and handling.

2. The contents of the asbestos rule.

3. The identification of asbestos.

4. Removal procedures where appropriate.

5. Other practices for reducing the hazard.

6. All PPE Requirements.

Our competent person has received the following training for Classes III and IVasbestos work in addition to the above.



I4.11

1. Aspects of asbestos handling appropriate for the nature of the work, to includeprocedures for setting up glove bags and mini- enclosures.

2. Practices for reducing asbestos exposures.

3. Use of wet methods.

4. The contents of this standard.

5. The identification of asbestos.

This training includes successful completion of a course that is consistent with EPArequirements for training of local education agency maintenance and custodial staff.

Regulated areas

Operations, where airborne concentrations of asbestos exceed or there is areasonable possibility they may exceed a PEL, are conducted within a regulated

area. All regulated areas shall be identified by the OSHA required signs and labels.

Demarcat ion

The regulated area is demarcated in a manner that minimizes the number ofpersons within the area and protects persons outside the area from exposure toairborne asbestos. When critical barriers or negative pressure enclosures are used,they may demarcate the regulated area. Warning signs are posted stating theparticular hazard(s), as well as access requirements or limitations such as PPErequirements.

Access

Access to regulated areas is limited to authorized persons and to persons authorizedby the OshAct or federal regulations.

Respirators

All persons entering a regulated area where employees are required to wearrespirators are supplied with an appropriate respirator. Third Party air monitoringshall help identify the appropriate NIOSH approved respirator for the tasks.Respirators will be provided at no cost to the employee per the Moreno Group, LLC

and Subsidiaries Respiratory Protection Program.

Prohibi ted A ct iv i t ies

We make sure that our employees do not eat, drink, smoke, chew tobacco or gum,or apply cosmetics in a regulated area.



I.4.12

Competent Persons

Our competent person will supervise all asbestos work performed within regulatedareas.

Communication of Hazards:

We understand the importance of communicating asbestos hazard information atthis job site, and will do so in all necessary manners. Areas where an asbestosexposure hazard maybe present the regulated area shall be identified by signs andlabels that meeting the OSHA requirements.


Our methods of compliance set operation-specific and exposure-triggered workpractices for conducting asbestos work. Each job is specific and the methods ofcompliance will include the following required and optional procedures.

The following basic engineering controls and work practices are a part of allasbestos operations at this jobsite regardless of the levels of exposure.

1) Vacuum cleaners equipped with HEPA filters to collect all debris and dustcontaining ACM or PACM.

2) Wet methods, or wetting agents, to control employee exposures during asbestoshandling, mixing, removal, cutting, application, and cleanup, except where wedemonstrate that the use of wet methods is infeasible due to for example, thecreation of electrical hazards, equipment malfunction, and, in roofing.

3) Prompt clean-up and disposal of wastes and debris contaminated with asbestosin leak-tight containers.

In addition to the requirements noted above for all asbestos operations we use thefollowing control methods to achieve compliance with the TWA permissible exposurelimit and excursion (STEL) limit.

Local exhaust ventilation equipped with HEPA filter dust collection systems.

Enclosure or isolation of processes producing asbestos dust.

Ventilation of the regulated area to move contaminated air away from thebreathing zone of employees and toward a filtration or collection deviceequipped with a HEPA filter.

Wherever the feasible engineering and work practice controls describedabove are not sufficient to reduce employee exposure to or below thepermissible exposure limit and/or excursion limit we will use them to reduceemployee exposure to the lowest levels attainable by these controls and shallsupplement them by the use of respiratory protection.



I4.13

Prohibi t ions

We never use the following work practices and engineering controls for work relatedto asbestos or for work which disturbs ACM or PACM, regardless of measured levelsof asbestos exposure or the results of initial exposure assessments:

High-speed abrasive disc saws that are not equipped with point of cut

ventilator or enclosures with HEPA filtered exhaust air.

Compressed air to remove asbestos, or materials containing asbestos, unlessthe compressed air is used in conjunction with an enclosed ventilation systemdesigned to capture the dust cloud created by the compressed air.

Dry sweeping, shoveling, or other dry clean-up of dust and debris containing ACM and PACM.

Employee rotation as a means of reducing employee exposure to asbestos.

Class I and II Requirements

All Class I and Class II work, including the installation and operation of the controlsystem is supervised by our competent person.

For all indoor Class II jobs, where we have not produced a negative exposureassessment, or where during the job changed conditions indicate there may beexposure above the PEL, or where we do not remove the ACM in a substantiallyintact state, we will use adequate methods and practices to ensure that airbornecontaminates do not exit the regulated area.

Class III Requiremen ts

We conduct Class III asbestos work using engineering and work practice controlswhich minimize the exposure to our employees performing the work and tobystander employees. We will use:

Wet methods.

When feasible, local exhaust ventilation.

Where the disturbance involves drilling, cutting, abrading, sanding, chipping,

breaking, or sawing of thermal system insulation or surfacing material wewill use impermeable dropcloths, and will isolate the operation using mini-enclosures or glove bag systems or another isolation method.

Where we do not have a "negative exposure assessment," or wheremonitoring results show the PEL has been exceeded, we will contain thearea using impermeable dropcloths and plastic barriers or their equivalent,or shall isolate the operation using another control system.



I.4.14

Our employees performing Class III jobs, involving the disturbance ofthermal system insulation or surfacing material, or where we do not producea "negative exposure assessment" or where monitoring results show a PELhas been exceeded, wear respirators selected, used and fitted inaccordance with our Respiratory Protection Program

Class IV Requiremen ts

Employees trained in our asbestos awareness training program will be allowed towork Class IV asbestos jobs.

Respiratory Protection

We provide respirators and ensure they are used in the following circumstances:

During all Class I asbestos jobs.

During all Class II work when the ACM is not removed in a substantially intact

state.

During all Class II and III work not performed using wet methods, except forremoval of ACM from sloped roofs when a negative exposure assessmenthas been made and the ACM is removed in an intact state.

During all Class II and III asbestos jobs where we do not conduct a negative-exposure assessment.

During all Class III jobs where TSI or surfacing ACM or PACM is beingdisturbed.

During all Class IV work performed within regulated areas where employeesperforming other work are required to wear respirators.

During all work covered by this section where employees are exposed abovethe TWA or excursion limit.

In emergencies.

Respirator Selectio n

Where respirators are used we select and provide, at no cost to out employees, theappropriate respirator. We ensure that the employee uses the respirator provided.We provide a tight fitting powered, air-purifying respirator in lieu of any negative-pressure respirator specified in Table 1 whenever: (a) an employee chooses to usethis type of respirator, and (b) this respirator will provide adequate protection to theemployee. In addition, we provide a half-mask air purifying respirator, other than adisposable respirator, equipped with high efficiency filters whenever our employeesperform:



I4.15

Class II and III asbestos jobs where we do not conduct a negative exposureassessment.

Class III jobs where TSI or surfacing ACM or PACM is being disturbed.

Selection criteria when employees are in regulated area where Class I work isbeing performed, a negative exposure assessment of the area has not been

produced, and the exposure assessment of the area indicates the exposurelevel will not exceed 1 f/cc as an 8-hour time weighted average, we providethe employees with one of the following respirators:

(A) A tight-fitting powered air-purifying respirator equipped with high efficiencyfilters;

(B) A full facepiece supplied-air respirator operated in the pressure demandmode equipped with HEPA egress cartridges; or

(C) A full facepiece supplied-air respirator operated in the pressure demand

mode equipped with an auxiliary positive pressure self-containedbreathing apparatus. A full facepiece supplied-air respirator operated inthe pressure-demand mode equipped with an auxiliary positive pressureself-contained breathing apparatus must be provided under suchconditions when the exposure assessment indicates exposure levelsabove 1 f/cc as an 8-hour time weighted average.

Respirator Program

We have developed a respiratory protection program to satisfy the requirements ofan asbestos related project.

Respirator Fit Testing

We make sure that the respirator issued to each employee exhibits the leastpossible facepiece leakage and that the respirator is fitted properly. We performeither quantitative or qualitative face fit tests:

Before any of our employees are required to use any respirator with anegative or positive pressure tight-fitting facepiece;

Whenever a different respirator facepiece (size, style, model, or make) is

used;

At least annually;

Whenever the employee reports, or our company, the physician or otherlicensed health care professional (PLHCP), supervisor, or Program

Administrator makes visual observations of, changes in the employee'sphysical condition that could affect respirator fit. Such conditions include, but



I.4.16

are not limited to, facial scarring, dental changes, cosmetic surgery, or anobvious change in body weight; and

When the employee, subsequently after passing a qualitative or quantitativefit test, notifies the company, Program Administrator, supervisor, or PLHCPthat the fit of the respirator is unacceptable. That employee will be retestedwith a different respirator facepiece.

See the Moreno Group, LLC and Subsidiaries Respiratory Protection Program forDetails.

Protective Clothing

We provide and require the use of protective clothing, such as coveralls or similarwhole-body clothing, head coverings, gloves, and foot coverings for:

Any employee exposed to airborne concentrations of asbestos that exceedthe TWA and/or STEL.

This site when a required negative exposure assessment is not produced.

Any employee performing Class I operations which involve the removal ofover 25 linear or 10 square feet of TSI or surfacing ACM and PACM.

Launder ing

We ensure that laundering of contaminated clothing is done so as to prevent therelease of airborne asbestos in excess of the TWA or STEL.

Contaminated Clothing

Contaminated clothing is transported in sealed impermeable bags, or other closed,impermeable containers, and be labeled.

Inspect ion of Protect ive Clothing

Our competent person examines work suits worn by our employees at least onceper work shift for rips or tears that may occur during performance of work. When ripsor tears are detected while an employee is working, they will be immediatelymended, or the work suit shall be immediately replaced.

Hygiene Facilities and Practices for Employees

Our hygiene facilities and practices requirements for this job are as required byOSHA regulations.

Smok ing in Work Areas

We ensure that employees do not smoke in regulated work areas where they haveincreased potential for exposure to asbestos because of activities in that work area.



I4.17

Housekeeping

Vacuuming

When we select vacuuming methods we always use HEPA filtered vacuumingequipment. The equipment is used and emptied in a manner that minimizes thereentry of asbestos into the worksite.

Waste Disposal

Asbestos waste, scrap, debris, bags, containers, equipment, and contaminatedclothing will be collected and disposed of in sealed, labeled, impermeable bags orother closed, labeled, impermeable containers.

Care of Asb estos-Containing Floor ing Mater ial

Waste and debris and accompanying dust in an area containing accessible thermalsystem insulation or surfacing ACM/PACM or visibly deteriorated ACM:

Is not dusted or swept dry, or vacuumed without using a HEPA filter.

Is promptly cleaned up and disposed of in leak tight containers.

Specifically:

We assess all asbestos operations for their potential to generate airbornefibers.

Our designated competent person conducts an initial exposure assessment

immediately before or at the initiation of an operation to document expectedexposures, and that the assessment is completed in time to comply withrequirements triggered by exposure data or the lack of a "negative exposureassessment."

We perform periodic monitoring and additional monitoring when required.

When required, we implement a medical surveillance program for allemployees when for a combined total of 30 or more days per year engage inClass I, II, or III work or are exposed at or above the PEL, or when employeesare required to wear negative-pressure respirators.

We maintain objective data, monitoring, medical surveillance, training, andbuilding owner notification records when required and for the time periodsindicated in the asbestos rule.

Our asbestos competent person is qualified, authorized, and has the propertraining to ensure worker safety and health.

Our respirator program is in place.



I.4.18

Our Class I, II, and III asbestos work, and all other operations where airborneconcentrations of asbestos exceed or there is a possibility the may exceed aPEL, are conducted within regulated areas.

We understand that the communication of asbestos hazards is vital to preventfurther overexposure and that we have specific duties under the asbestos rule

to communicate those hazards through written notifications, signs, labels andemployee information and training.

Multi-employer worksites

We Wil l :

Inform other employers on the site of the nature of our work through SH&EMeetings and/or Site Orientations.

Relay information of the existence of regulated areas.

Take correct measures to ensure personal working adjacent to regulated

areas are removed from the affected area until any breach within thecontainment is repaired or perform an initial exposure assessment isperformed per OSHA 1926.1101(f).





Back Injury PreventionPage 1 of 4Original: 05/06/2003Revised: 02/01/2010

I5.1

Back Injury Prevention

Purpose

The purpose of this program is to provide a method for identifying, evaluatingand controlling worker’s exposures to manual lifting hazards.

Scope

The scope of this program is to identify potential manual lifting hazards,identify proper manual lifting techniques, and identify when alternative liftingmeans need to be utilized.

Responsibilities


Providing the leadership and resources needed to implement thisprogram to minimize workers exposures to manual lifting hazards atMoreno Group LLC and Subsidiaries facilities and customer facilities.

Understanding and complying with the requirements of this procedure.

Ensure all new operations are evaluated to eliminate manual lifting

hazards



Ensuring that employees comply with the requirements of thisprocedure.

Planning and providing alternative lifting means anytime the needarises.

Periodically evaluate worksite for potential hazards and unsafe actsinvolving manual lifting techniques.

Correct or train employees on proper lifting techniques



I5.2


Coordinating or conducting training for all personnel in proper liftingtechniques and potential lifting hazards.

Evaluating Program to ensure compliance


Communicating to management when certain employees cannot meetthe requirements of this plan.



Communicating to supervisors any suggestions or concerns related tothis procedure.

Reporting any injury, incident or near miss to the Supervisor or Safety,Health and Environmental Department.

Requirements

Moreno Group LLC and Subsidiaries will establish a Recommended WeightLimit (RWL) not to exceed 75 pounds for all manual lifting. This limit maydecrease for awkward objects (i.e. long loads, unbalanced loads, etc.) orrepetitive (i.e. repeating) lifting.

Manual Lifting Guidelines

Anytime manual lifting is performed, employees must use the followingguidelines:

Inspect the work area and ensure that you have a clear path to carrythe load, and a place to set it down.

Size up the load before lifting. Test by lifting one of the corners orpushing.

Center the body above the load to be lifted.

Bend at the knees. Note: This item is the single, most important aspectof lifting.

Ensure that you have a firm grip on the load to be lifted.

Lift straight up, smoothly and let your legs do the work, not your back!



I5.3

Do not twist or turn your body once you have made the lift.

Bend at the knees to set the load down.

Minimize the amount of lifts as much as possible.

Alternative Lifting Methods

For objects that exceed 75 pounds, or for any awkward (i.e. not proportional)or long loads (extends beyond ones body), the following methods should beutilized to be prevent possible injuries:

Utilizing two or more employees for a lift. It is critical that whenevermultiple employees are involved in a single lift, everyonecommunicates to each other, and the load is balanced out between theemployees.

Mechanical lifting devices (Cranes, forklifts, dollies, chain falls, come-a-longs, etc.) should be utilized for loads exceeding the RWL per

employee.



I5.4

Load Chart

Load Estimated Weight

Can of Welding Rods 50 pounds

Welding Wire Spool 44 pounds

Fluxcore feeder without wire 30 pounds

Fluxcore feeder with wire 74 pounds

Roll of submerged arc wire 60 pounds

1 foot 6” XX pipe 54 pounds1 foot 4” schedule 80 pipe 15 pounds

1 foot 4” XX pipe 40 pounds

1 foot 2” schedule 80 pipe 5 pounds

1 foot 2” XX pipe 9 pounds

1 foot 8” schedule 80 pipe 44 pounds

1 foot 12” x50 I-beam 50 pounds

1 foot 4” x 13 I-beam 13 pounds



20’ joint handrail pipe 55 poundsSteel Grating (1”) 7.34 pounds per ft

6” 600 pound flange 73 pounds

4” 150 pound flange 16.5 pounds

8 Foot Section Handrail (3posts)

120 pounds

3’ x 20’ x 1” Sheet of Grating 440 Pounds

5 gallon bucket paint 75 pounds (Average)

2.5 gallon pale of zinc powder 100 pounds

Paint Pot empty 58 pounds

Paint Pot with Paint 88 pounds

Blasting sand in bag 100 pounds1 k tugger 120 pounds

Scaffold Board 20 pounds

Aluminum Peg Board 20’ 130 pounds

Aluminum Peg Board 12’ 70 pounds

50 foot of welding lead 60 pounds

6 ton chain fall (Jet) 55 pounds

3 ton chain fall (Budgit) 80 pounds

12 ton snatch block 55 pounds

6 ton Come-A-Long 60 pounds

35 Ton Shackle 45 pounds

55 Ton Shackle 90 poundsMag drill 40 pounds

Sheet of ¾” plywood 50 pounds

Beam Clamp 45 pounds

Tripod 35 pounds

Pipe Jack 18 pounds




Benzene ProcedurePage: 1 of 6Original: 01/01/2005Revised: 01/01/2007

I6.1

Benzene Procedure

Purpose

The purpose of this standard is to communicate to employees the potential hazardwhen exposed to Benzene and to establish uniform procedures to be followed byMoreno Group LLC and Subsidiaries employees for benzene exposures. It is basedon 29 CFR 1910.1028 requirements.

Scope

Moreno Group LLC and Subsidiaries employees may be potentially exposed tobenzene while working at a host contractor facility or while working on pipelines andaround crude oil. As part of the Hazard Communication standard and other

regulations under, such as Process Safety Management, the Host Company willrelay the potential exposure information to management officials prior to start of the

job.

Responsibilities

The Facility Manager / Site Manager or Designee is responsible for


Ensuring that personnel with potential exposures to benzene are placed

within a medical surveillance program that includes respiratory protection andtrained.

Ensure that all work activities and documentation of this program is kept on-site during the course of activities with potential exposures to benzene.

Ensuring that personnel performing benzene monitoring at work locations aretrained in the use of monitoring equipment.


The First Line Supervisor or Designee is responsible for:


Conferring with Facility / Site Manager or designee or SH&E Department asto any potential benzene exposure.



I6.2

Ensuring personnel assigned to task with potential benzene exposures havebeen place within a medical surveillance program that includes respiratoryprotection and are trained.

Ensuring employees performing tasks with potential benzene exposures arefollowing the Job Safety and Environmental Analysis (JSEA) and utilizing allappropriate Personal Protective Equipment for the task.

Notify Facility / Site Manager or designee and the SH&E Department of anysuggestions to improve job task that will reduce potential exposure tobenzene.

Resolve any situation in which an employee utilizes their Stop Work Authoritydue to an unsafe condition or exposure.

The SH&E Department is responsible for:


Coordinating or conducting Benzene and Respiratory Protection Training.

Coordinating the placement of employees within a medical surveillanceprogram that includes respiratory protection.

Coordinating or conducting training on the monitoring equipment to be utilizedfor benzene monitoring.

Advise Facility / Site Manager or designee or First Line Supervisor of anysuggestions to minimize employees’ exposure to potential benzene

exposures.

Obtain and provided to the Human Resource Department any personalmonitoring results for benzene exposures so they can be placed within theemployee’s medical records file.

Notify in writing all employees of their results from the personal monitoring.



Coordinating the placement of employees within a medical surveillanceprogram that includes respiratory protection.

Maintaining medical records of employees’ potential exposures andexaminations performed by Moreno Group LLC and Subsidiaries ApprovedPhysicians



I6.3


Understanding and complying with this procedure. If a hazardousconcentration of benzene is detected, notify your supervisor immediately.

Utilizing Stop Work Authority anytime they feel at risk.

Notify their immediate First Line Supervisor of the need to Stop Work and donot begin until reason to Stop Work is resolved.

Following the task specific Job Safety and Environmental Analysis (JSEA)and wearing all required Personal Protective Equipment at all times.

Employees shall be knowledgeable of these requirements and shall complywith them. If a hazardous concentration of benzene is detected, notify yoursupervisor immediately.

The Host Facility is responsible for:

Host facilities are also responsible for posting warning signs and labels onvessels and lines that contain benzene, and providing other types ofinformation as appropriate.

Responsible for providing a Site Specific Training / Orientation.

Requirements

General Information

Benzene (C6H6, CAS Registry Number 71-43-2) is a highly toxic, flammable liquidor gas that is extremely dangerous even in low concentrations. In a liquid state,Benzene is a colorless to light-yellow with an aromatic odor.

Benzene can enter the body by skin contact, inhalation, and sometimes ingestion.Short term exposures can cause irritation to the eyes and respiratory tract, and maycause giddiness, breathlessness, euphoria, and perhaps a headache. Long-term(chronic) exposures will cause various blood disorders ranging from anemia toleukemia, an irreversible, fatal disease. OSHA regulates benzene as a cancerhazard.

Permissible Exposure Limit

The permissible exposure limit (PEL) established by OSHA for benzene is 1 part permillion (ppm) for eight (8) hours, which is the concentration to which a normal,healthy adult can be exposed for eight hours without harm. For short term situations,OSHA allows exposures averaged to 5 ppm for any 15-minute period. The standardalso establishes an "Action Level" (AL) of 0.5 ppm over the 8-hour day, which mayrequire certain "action" - such as wearing of respirators, etc. to take place



I6.4

Precautions

All employees must realize the hazard of benzene and acquire a thoroughknowledge of this poisonous material. Moreno Group LLC and Subsidiaries and / orhost facility will conduct air monitoring to determine the concentrations of benzeneroutinely present or where it may be present, and for those areas that exceed theOSHA PEL, establish regulated work areas - designed to control who enters the

area and what types of protective equipment are required. Extreme care must beused when working in regulated areas or on piping or equipment, such as operatingany valve, line, bleeder, etc., which may contain benzene. Where benzene ispresent, engineering controls such as isolation, or administrative controls will beutilized first to protect the workers. In certain circumstances, however, personalprotective equipment may be required. This has been addressed in the chapter ofthis manual for PPE, and may require respirators, protective clothing, eye, face, andsplash protection, etc.

Monitoring

The presence of benzene may be determined with portable detection devices thatare available for use. These devices will primarily include direct reading instruments,such as Draeger colorimetric tubes and pump, or others that are available throughequipment rental agencies.

These detection devices are available by contacting the Facility Manager orDesignee, and / or the SH&E Department. In addition, our consultant AESI oranother third party to determine the concentration of benzene that may be presentduring certain operations may conduct air monitoring for exposure assessment.These records will be kept in accordance with OSHA regulations

Based on exposure monitoring results, Moreno Group LLC and Subsidiaries willdevelop and implement engineering and I or work practice plan to minimizeexposures. This plan will be developed and maintained by the Facility Manager orDesignee, Human Resources and Safety, Health and Environmental Department.The plans will be reviewed and revised as necessary and appropriate based on themost recent exposure monitoring data.

Monitoring Devices

Portable Benzene Detection Devices

These devices may be used when fixed systems are not adequate or not present.These units will be rented from Total Safety, Inc. or another vendor, and will give anaudible alarm at a pre-determined level of benzene, usually 0.5 ppm. They aremaintained and calibrated before each use by the Rental Company or the SafetySupervisor, which will use a calibration gas.

Medical Monitoring

Moreno Group LLC and Subsidiaries employees who are exposed at or above the Action Level of 0.5 ppm for 30 or more days per year, medical monitoring is provided



I6.5

free of charge. Moreno Group LLC and Subsidiaries’ Approved Medical Facilities willbe provided a copy of the OSHA standard. These facilities will perform medicalexaminations and tests to monitor the health of Moreno Group LLC and Subsidiariesemployees during the time they have a potential for an exposure at or above the

Action Level.

Training

The host facility will be responsible for providing site specific training to ourpersonnel. In addition to the host facility site specific training, Moreno Group LLCand Subsidiaries will also train our employees as to the hazards of benzene duringour Hazard Communication training and prior to any potential exposure to benzene.

As part of employee training for each job, this information will be relayed to ouremployees, so they are aware of the location and hazards associated with benzene,as well as methods used to reduce or control exposures.

At host facilities, regulated areas are established where the PEL can or may be

exceeded. A detailed copy of the OSHA regulation governing benzene can bereviewed by any employee or their designated representative in the Site Office,available from the Facility / Site Manager or designee, and / or the SH&EDepartment. This is also the source for additional exposure information and otherpertinent written plans and programs

Personal Protective Equipment (PPE) and Respiratory Protection

The level of Personal Protective Equipment (PPE) shall be determined during theinitial job planning process and/or during the development of the task Job Safety andEnvironmental Analysis (JSEA). PPE may include but not limited to Chemical

Goggles, Face Shield, Aprons, Chemical Suits, Chemical Gloves and ChemicalBoots.

Respiratory protective equipment is to be utilized when exposed to hazardousconcentrations of benzene. Only approved respiratory protection will be used. Forexposures up to 10 ppm, half face air purifying respirators with organic vaporcartridges (black) can be used. Supplied air respiratory equipment, such as airlinerespirators with escape bottles or self-contained breathing apparatuses (SCBAs)shall be utilized for escape or emergency conditions. Refer to the Moreno GroupLLC and Subsidiaries Respiratory Protection Program within our SH&E ManagementSystem Manual for additional information.

No one is permitted to wear a respirator unless they have been properly trained, fit-tested, and received medical clearance, and only NOISH-certified respirators can beused.

Evacuation I Escape I Emergency Procedures

Prior to entry on to the site where benzene may be present, check with the owner I

operators to determine what their specific emergency plans address and always



I6.6

follow their requirements. They may assign a coordinator to assist with thesematters.

Whenever an unsafe level of benzene is detected, do not panic. The followingescape method will be followed:

1. Put on a 5 minute escape air pack (if available).

2. Evacuate cross wind then upwind of the emission to a safe area.

3. Alert others of hazard.

4. Call your supervisor from a safe area. Stand by in safe area for instructions fromyour supervisor and return to work area only when it has been determined that itis safe to return.

Equipment Opening

Maintenance

Anytime process equipment, i.e., piping, vessels, instruments, drain lines, blinds,etc., which may contain benzene is entered or opened in any area, or if work is to beperformed where benzene may be present, those involved must wear theappropriate level of Personal Protective Equipment and Respiratory Protection whileperforming the work. All line opening or equipment opening shall be performed inaccordance of our line opening procedures.





Bloodborne PathogensPage: 1 of 9Original: 06/08/1998

Revised: 05 /01/2008

I7.1

Bloodborne Pathogens

Purpose

Moreno Group LLC and Subsidiaries seeks to limit employee exposure to blood andother infectious materials in compliance with OSHA 29 CFR 1910.1030. Thisprogram identifies those employees who are occupationally exposed, and addressesboth the means by which the exposure can be reduced or eliminated and theprocedure for evaluating an exposure incident.

Scope

Safety, Health and Environmental Department Representatives, depending upon

their work assignments, may be occupationally exposed to bloodborne pathogensincluding human immunodeficiency virus (HIV) and the Hepatitis B Virus (HBV). TheOccupational Exposure to Bloodborne Pathogens Standard (29 CFR 1910.1030)addresses this risk and aims to reduce occupational exposure.

Responsibilities



Ensuring that personnel are informed of bloodborne pathogen safeguards.

Offering Hepatitis B Vaccine (HBV) to all personnel whom may be exposed.




Conferring with Facility Management or SH&E Department as to anypossible bloodborne pathogen exposure

Advising Facility Management of any suggestions to improve theBloodborne Pathogen Procedure.





I7.2

Coordinating or conducting Bloodborne Pathogens training for personnel.

Communicating to the Company Physician to establish any BloodbornePathogen exposure has occurred.




Conferring with First Line Supervisor or Offshore Superintendent as to anypossible bloodborne pathogen exposure.

Advising First Line Supervisor or Offshore Superintend of any suggestionsto improve the Bloodborne Pathogen Procedure.

Requirements

Exposure Determination

Category I Employees

Employees in the following job classification(s), because of the nature of their jobduties, have been determined to be occupationally exposed to blood or otherpotentially infectious materials without regards to the use of personal protectiveequipment:

Safety, Health and Environmental Department Representatives

Hereafter, employees of this type will be identified as Category I employees.Exposure may be anticipated from such tasks as cleaning and dressing wounds,burn care, and disposing of contaminated objects or fluids. These employees shallreceive training annually on Bloodborne Pathogens.

Category 2 Employees

Other employees, who render first aid or CPR, not in the normal scope of their jobduties but as a collateral duty, may be exposed to blood or other potentiallyinfectious materials without regards to the use of personal protective equipment.

Hereafter, employees of this type will be identified as Category 2 employees.


Methods of compliance that reduce or eliminate the risk of exposure includeUniversal Precautions, Engineering Controls, Work Practice Controls, and the use ofpersonal protective equipment (i.e. gloves, ventilation shield or mask, etc.).



I7.3

Universal Precautions

All blood and certain body fluids are to be treated as if they are infectious for HIV,HBV, or any other bloodborne pathogen. This method of infection control, known asUniversal Precautions, will be utilized in any situation that involves potentialexposure to blood or other potentially infectious materials.

Engineering Control

Engineering Controls, methods of isolating or removing a hazard from theworkplace, are one of the most effective methods of hazard reduction. Engineeringcontrols should be employed first and, if the hazard remains, personal protectiveequipment will also be used. Engineering controls include the use of sharpsdisposal containers, disposable airway equipment or resuscitation bags, and pocketmouth-to-mouth resuscitation devises for CPR. These controls should be examinedand maintained or replaced on a regular schedule to ensure their effectiveness.

Work Practices

Methods that reduce the exposure during a task or procedure will be used tominimize exposure. Hands and other skin surfaces, which come in contact withblood or other potentially infectious materials, must be washed immediately withsoap and water. In the event that running water is unavailable, antiseptic towelettesmay be used. Hands will be washed with soap and water as soon as possible.

Contaminated needles and sharps will be disposed of into a sharp container withoutrecapping. Sharps may only be recapped using a one-handed technique inemergency situations.

Puncture coded, resistant, color and leak proof containers will be utilized for disposalof contaminated sharps.

Eating, drinking, smoking, applying cosmetics, and handling contact lenses is prohibited in areas where exposure is likely to occur.

Food and drink will not be stored in or on refrigerators, cabinets, shelves, or countertops where blood or other potentially infectious materials are present.

All procedures involving blood or potentially infectious materials shall be handled ina way which minimizes splashing, spraying, and spattering.

Specimen containers for blood or other potentially infectious materials will be placedin leak-proof and puncture resistant containers and labeled with the appropriatebiohazard label.



I7.4

Labels/Signs

Biohazard warning labels of florescent orange or orange-red letters, identified in theappendix, will be used to identify blood or other potentially infectious materials.Color-coded red containers. or bags may be used in place of labels. Specifics onlabeling requirements can be found in the appendix.

Personal Protective Equipment

Personal protective equipment will be utilized at all times to prevent contaminatedmaterials from passing to the employee's clothing, skin, eyes, mouth or mucousmembranes. Latex gloves are provided and will be worn when contact with thehands is anticipated. Gloves will be disposed of in the appropriate container afteruse. Masks, goggles, and face shields will be worn whenever splashing, spraying,or splattering is anticipated. Gowns, aprons, and other protective clothing should beused if a large contamination is possible.

All personal protective equipment is to be removed when leaving the work area or

emergency scene and disposed of in an appropriate container.

Regulated Waste

All contaminated items including sharps, disposable linens, disposable equipment,broken glass, and disposable personal protective equipment are consideredregulated waste.

All contaminated sharps will be placed in closeable, puncture resistant, leak proofand color-coded containers.

All other regulated waste and full sharps containers will be placed in a regulatedwaste container for disposal in accordance with local, state, and federal regulations.Records Will be kept as required.

Contaminated Laundry

Disposable linens including sheets, pillowcases, and towels will be used to eliminatethe need for laundering. Contaminated items will be placed in a regulated wastecontainer as specified in the section on Regulated Waste.

Housekeeping

All contaminated reusable equipment, work surfaces, and environmental areas willbe cleaned as soon as possible with an appropriate disinfectant such as a 1 to 10concentration of bleach to water. Instruments, which may rust, may be placed in anappropriate solution such as Cidex for disinfecting.

Appropriate personal protective equipment will be worn during decontaminationprocedures.



I7.5

Broken glassware will be picked up using mechanical means such as tongs, orbrush and dustpan.

Hepatitis B Vaccination

The Hepatitis B Vaccination series will be offered (see attachment 1) without chargeto all Category I employees following training on the efficiency, safety, method of

administration and benefits of the vaccine shall be obtained within 10 days ofassignment unless documentation of previous receipt of the vaccination series isprovided, antibody testing reveals immune status, or medical reasons preventvaccination.

Employees may refuse the vaccination and must sign the declination statement.(see Attachment 2)

Moreno Group LLC and Subsidiaries will keep documentation of employeevaccination status and/or declination statements.

Category 2 employees will be offered the immunization series within 24 hours ofrendering first aid in a situation involving the presence of blood or other potentiallyinfectious materials by notifying the Safety, Health and Environmental Department.

Notification of Incident

An employee who has an occupational exposure to blood or other potentiallyinfectious materials should report the occurrence immediately to his/her supervisorand the Safety Coordinator.

Incident Assessment

During Supervisor's initial assessment of the incident, determination needs to bemade concerning potential exposure to bloodborne pathogens. To assist supervisorin the determination, the following may be contacted:

Local Company approved physician

Safety, Health and Environmental Department

The following situations, which may occur during first aid response, are exposures,which should be considered significant risks for communicable disease transmission

(Defined "Exposure Incidents"):

Injuries such as needle sticks, cuts, or puncture wounds with objects thathave been contaminated by blood

Contamination of open wounds or mucous membranes by blood or bodyfluids, such as blood splashed in the eye; or direct contact with bloodduring mouth-to-mouth resuscitation without a barrier mask

Extensive and/or prolonged contamination of intact skin with blood



I7.6

Based on information developed during management of the incident, a preliminarydetermination needs to be made: There was "No Exposure", a "Potential Exposure",or a defined "Exposure incident". This determination and the basis for it, needs tobe explained to the employee, and documented by supervisor.

Exposure Evaluation Follow-Up

"No Exposure"

Supervisor needs to document in local files the information related to the incident.

If the preliminary assessment of the incident indicates a "Potential Exposure" or adefined "Exposure Incident" occurred, the exposed employee must be offeredHepatitis B Vaccination series, as a post-exposure preventative, within 24 hours ofthe incident, unless the employee has previously received the complete Hepatitis BVaccination series; or Antibody testing has revealed that the employee is immune; orthe vaccination is not advised for medical reasons.

Employee will complete a "Consent" or "Declination" form depending on acceptancechoice.

Hepatitis B Vaccination program will be administered by a licensed, registerednurse, or licensed physician knowledgeable of the bloodborne pathogens standard.

"Exposure Incident"

If it is determined by management or a medical professional that a defined"Exposure Incident" has occurred, then a confidential medical evaluation and follow-up of the incident will be made by a physician or Safety Coordinator.

Medical counseling will be made available to any employee who has been exposed.Request for clinical evaluation and testing will be referred to the company’sphysician.

Awareness Sessions

During the New Employee Orientation / SH&E Training, new employee will receiveawareness information on preventive controls and procedures for avoiding contactwith bloodborne pathogens.

Recordkeeping

Moreno Group LLC and Subsidiaries will retain all records associated with thisguideline including employee training, hepatitis B vaccination documentation andpost exposure medical records.

The Human Resource Department shall maintain all medical records. These recordswill be maintained in a confidential manner for the duration of employment plus 30



I7.7

years within. Employees or their representative may access these records byproviding this department with a written request. The transfer of these records shallcomply with the requirements of 29 CFR 1910.1020(h).

The Safety, Health and Environmental Department will maintain all training recordsfor a minimum of three years.





I7.8

Attachment 1





I7.8.a.1

Moreno Group LLC andSubsidiaries

TO:

FROM: Facility Manager.

RE: Hepatitis Vaccine

DO NOT DISCARD THIS FORM ROUTE TO OPERATIONS DEPARTMENT.

ON COMPLETION OF VACCINATION PROCESS

Thank you for making one of the most important decisions of yourcareer! This vaccine will offer you protection from Hepatitis B for aboutfive years. After that time you should consider getting an antibody testsince the exact length of effective immunization is not currently known.

Please follow these instructions for your current vaccination.

1. The vaccine should remain refrigerated at all times. (Fortransport it may remain out no more than 2 - 3 hours.)

2. The vaccine must be given in the Deltoid muscle.

3. Each vial contains a single dose (I ml).

4. It is extremely important that the injections be received on time.Your schedule is written in below.

INJECTION 1: DATE: BY:



Please remember to properly dispose of syringes and other sharp

objects.





I7.9

Attachment 2





I7.9.a.1

HEPATITIS B VACCINATIONDECLINATION FORM

An employee who chooses not to accept the vaccine must sign the followingstatement of declination of hepatitis B vaccination. This statement can only be

signed by the employee following appropriate training regarding hepatitis B, hepatitisB vaccination, the efficacy, safety, method of administration, and benefits ofvaccination, and that the vaccine and vaccination are provided free of charge to theemployee. The statement is not a waiver; employees can request and receive thehepatitis B vaccination at a later date if they remain occupationally at risk forhepatitis B.

DECLINATION STATEMENT

I understand that due to my occupational exposure to blood or other potentiallyinfectious materials I may be at risk of acquiring Hepatitis B virus (HBV) infection. Ihave been given the opportunity to be vaccinated with hepatitis B vaccine, at nocharge to myself. However, I decline hepatitis B vaccination at this time. Iunderstand that by declining this vaccine I will continue to be at risk of acquiringhepatitis B, a serious disease. If in the future I continue to have occupationalexposure to blood or other potentially infectious materials and I want to bevaccinated with hepatitis B vaccine, I can receive the vaccination series at no chargeto me.

Employee Signature Witness Signature

Employee Name (Print) Witness Name (Print)

Date Signed Date Signed







Cadmium ProtectionPage: 1 of 15Original: 01/01/2007Revised: 05/01/2008

I8.1

Cadmium Protection

Purpose

The purpose of this program is to establish and implement practices and proceduresfor protecting the health of Moreno Group LLC and Subsidiaries employees whomay be exposed to Cadmium on the job. This program also establishes methods forcomplying with the OSHA Construction Industry Cadmium Standard, 29 CFR1926.1127, 29 CFR 1910.1027.

Scope

The scope of this program applies to all Moreno Group LLC and Subsidiaries

projects and employees involved with potential Cadmium/Cadmium compound (ZincGalvanized) exposure when such work involves construction, alterations, andrepairs. The activities include, but are not limited to, wrecking, demolishing, andsalvaging structures where cadmium or cadmium-containing materials are present;cutting, brazing, grinding, or welding (Flux on welding rods can contain cadmiumcompounds), on surfaces that are painted with cadmium-containing paints (usuallyhigh-heat pipes or vessels); and transporting, storing, and disposing of cadmium orcadmium-containing materials on the site or location where construction activitiesare performed.

Cadmium coatings are sacrificial corrosion protection coatings widely used on steel

and aluminum especially when exposed to alkaline and salt water environments.They also possess a very low coefficient of friction and low electrical resistivity whichmakes them ideal for corrosion protection coatings on threaded fasteners orelectrical connectors. These are most often used in critical or safety relatedapplications in the aerospace, electrical connector, defense, mining, nuclear, andoff-shore oil and gas industries.

This program also applies to all subcontractors, working under the direct control ofMoreno Group LLC and Subsidiaries, involved with Cadmium/Cadmium Compoundprojects and activities. Subcontractors must provide all manpower, supplies,equipment, training, and medical examination and testing necessary to comply with

this program.

Responsibilities

The Facility Manager/Site Manager/Yard Foreman or Designee is responsible for:

Informing the SH&E Department of the any upcoming project that may havethe potential of containing Cadmium..



I8.2

Inform any subcontractors that may be working on the project that the projectcontains Cadmium.

Ensure that subcontractors understand and comply with this policy as well asthe Cadmium Employee Project Specific Protection Plan.


Understanding and complying with this policy/ procedure as well as theCadmium Employee Project Specific Cadmium Protection Program.

Designating employees for the project and ensuring that those employees allgo to the Human Resources Department to get an authorization to go to theMedical Review Officer and receive initial blood Cadmium levels prior toperforming any work on the project.

Coordinate with the SH&E Department to see if all designated employeeshave received Cadmium training and or up to date. If training is needed

coordinate with the SH&E Department date and time for which training willtake place.

Ensuring that barricade and applicable warning signs have been posted priorto the startup of the project.

Ensuring that all safety measures are being followed throughout the project.

Performing with the SH&E department the Cadmium Job Checklist andperforming this checklist throughout the project.

Coordinating with the Human Resources Department at the end of the projector when any employee is removed from the project that those employees allgo to the Medical Review Officer and receive blood Cadmium levels.


Coordinating paint samples to have analyzed to determine if project containsCadmium.

Informing Facility Manager/Offshore Manager/Yard Foreman or designee ofthe outcome of the sample analysis.

Perform any Cadmium training, any respiratory training and fit testing for allemployees that need this training.

Coordinating and performing any air monitoring which may be required.

Developing Cadmium Employee Project Specific Protection Plan.



I8.3


Authorizing all employees to go to the Medical Review Officer and receive aninitial blood/urine Cadmium testing as well as a respiratory analysis if needed.

Maintaining all medical records for all employees that will work on the project.

Informing the SH&E department of any employee that is unsuitable to work onthe project due to high Cadmium levels or medical conditions that do notallow employee to wear a respirator.

Authorizing all employees to return to Medical Review Officer for blood/urineCadmium levels once project is complete or if employee has been removedfrom project.


Understanding and complying with this policy/procedure as well as the

Cadmium Employee Project Specific Protection Plan.

Reporting to his immediate supervisor any problem, which may arise, or anysymptoms of Cadmium exposure.

Definitions

Authorized Person – Any person who is authorized by the employer and required bywork duties to be present in regulated areas or any person authorized by the OSH

Act or regulations issued under it to be in regulated areas.

Cadmium - In its elemental form, cadmium is either a blue-white metal or a grayish-white powder found in lead, copper, and zinc sulfide ores, but most cadmiumcompounds are highly colored from brown to yellow and red. Some of Cadmium’suses are: an electrode component in alkaline batteries, a stabilizer in plastics (PVC).

8-hour TWA Concentration - 8-hour Time-Weighted Average concentrations forairborne contaminants - common units for reporting daily airborne Cadmiumexposures. This is the Cadmium exposure received per day expressed as aconstant exposure for eight (8) hours at a steady state concentration.

HEPA filter - High Efficiency Particular Air filter - Filters that remove 99.97% of all

particulate 0.3 microns or greater in diameter.

g/m - Micrograms per cubic meter of air. Common units for reporting airborneconcentration of Cadmium.

g/100g - Micrograms per 100 grams of whole blood. Common units for reporting

concentrations of Cadmium in blood samples. Also reported as g/dl (microgramsper deciliter) of whole blood.



I8.4

NIOSH/MSHA - National Institute of Occupational Safety and Health/Mine Safetyand Health Administration - Federal agencies which conduct research on safety andhealth issues and test and certify respirators.

Action Level

The Action Level means employee exposure, without regard to the use of

respirators, to an airborne concentration of Cadmium of 2.5 g/m , calculated as an8-hour TWA.

Whenever workers’ airborne Cadmium exposures exceed or are expected to exceedthe Action Level, a written compliance program containing the following will beimplemented for the work project:

Authorized person



Airborne Cadmium exposure monitoring per the exposure monitoring sectionof this policy

Record keeping

The Action Level may be exceeded where Cadmium-containing compounds arepresent and the following activities are performed: cadmium refining, casting,melting, oxide production, sinter plant; crushing, milling, blending and all otherprocesses; mechanical plating, manual demolition of structures, welding, cutting,

torch burning, installation, removal, or demolition of Cadmium containing materials,Cadmium burning and Cadmium contamination/emergency cleanup operations.


The Permissible Exposure Limit (PEL) for airborne Cadmium exposure is five (5)

g/m , as an 8-hour TWA concentration. This is the maximum 8-hour averageconcentration of Cadmium that an employee may be exposed to during each workday.

No employee will be exposed to airborne Cadmium above the PEL without proper

protection.

The following methods will be used, as feasible and effective, for maintainingairborne Cadmium exposures below the PEL:

Engineering controls, such as general area ventilation for containments, localexhaust ventilation for spot removal, vacuum blasting or vacuum equippedpower tools. When ventilation for containments is used, manometers and/orvelometers, will be used to evaluate the mechanical performance of theventilation system



I8.5

Warning signs




Housekeeping

During the period that respirators are worn, the protection factor of the specificrespirator may be used to determine employees’ exposure to airborne Cadmium andto achieve compliance with the PEL. The protection factors listed in the respiratorselection table of Moreno Group LLC and Subsidiaries Respiratory ProtectionProgram. For example:

Measured airborne Cadmium concentrations at the workers breathing zone:

30 g/m ,8-hour TWA

Half-mask, air-purifying, negative pressure respirator with HEPA filters wornall day: protection factor of 10

Employees daily Cadmium exposure: 3 g/m

Authorized Person

All work activities where employee airborne Cadmium exposures may exceed the Action Level will include an Authorized person in both the planning and performing

stages of projects involving Cadmium exposure.

The Authorized person will be a person with training and experience in construction jobs involving Cadmium exposure. The Authorized person will have the capability ofidentifying hazards and the authority to take immediate action to eliminate them.

The Authorized person will be at the work site at all times while Cadmium exposureactivities are in progress. They may have other job duties, but must be able tomonitor work continuously for hazards or deficiencies, and the authority to takeimmediate corrective action.

Employee Information and Training

All employees who work on projects where airborne Cadmium exposures are knownto or expected to be at or above the Action Level will be provided information andtraining on the hazards of Cadmium and measures for controlling these hazards andprotecting health.

Employees will receive initial comprehensive Cadmium training before performingwork that may involve airborne Cadmium exposure. This training will be repeated



I8.6

annually as a refresher course. Training records will indicate employee’s name, dateof the training and name of the person who conducted the training. Training recordswill be kept minimum 1 year.

The content of Cadmium training will include:

The specific nature of activities or operations that may result in airborne

Cadmium exposure above the Action Level

The health effects and risks of Cadmium exposure

OSHA standards and guidelines for Cadmium exposure


Work practices for controlling Cadmium exposure, including information,warning signs, housekeeping, protective clothing and proper hygiene facilitiesand practices

Respiratory protection for controlling Cadmium exposure, including fit testing

Methods for monitoring airborne Cadmium concentrations and exposures


Precautions for female employees who are pregnant.

Instructions to employees that chelating agents should not be used to removeCadmium from their bodies

When conducting Cadmium exposure activities on a multi-employer work site,Moreno Group LLC and Subsidiaries will notify other employers of the nature of theCadmium exposure system in effect, and the potential need to take measures toprotect their employees. Notification to other employers will contain the following:NOTICE - MORENO GROUP LLC AND SUBSIDIARIES IS PERFORMINGACTIVITIES AT THIS JOB SITE THAT MAY CREATE AIRBORNE CADMIUMDUST. ALL CONTRACTORS AT THIS JOB SITE SHALL REMAIN CLEAR OFANY CADMIUM EXPOSURE AREA. ACCESS INTO CADMIUM EXPOSUREAREA IS CONTROLLED BY THE MORENO GROUP LLC AND SUBSIDIARIESJOB FOREMAN. ONLY TRAINED, QUALIFIED WORKERS ARE PERMITTED TO

ENTER CADMIUM EXPOSURE AREAS AND MUST WEAR RESPIRATORS ANDPROTECTIVE CLOTHING.


All employees who may be exposed to Cadmium at or above the Action Level for 30or more days per year; or who may be required to wear a respirator will be providedinitial and periodic medical examinations.



I8.7

All employees who may be exposed to Cadmium at or above the Action Level for 30or more days per year will be provided with initial and periodic biological monitoringin the form of blood and urine sampling and analysis of Cadmium levels and Beta-2-microglobulin in urine (B(2)-M), a low molecular weight protein.

All employees who are temporarily removed from Cadmium exposure due toelevated blood Cadmium levels or at the recommendation of a physician may be

reassigned other job duties at the site that do not involve exposure to Cadmiumabove the Action Level.

The specific components, requirements, and frequencies of medical examination,blood Cadmium test, and medical removal protection benefits are provided inMoreno Group LLC and Subsidiaries Medical Surveillance / Examination Programfor Cadmium Exposure and Respirator Use (see Attachment 1)

Warning Signs

Warning signs will be posted in the work area around activities where Cadmium

exposures may exceed the Permissible Exposure Limit. The work area can bedemarcated by Yellow Warning Tape.

Signs will be posted at every accessible side of the work area. These signs will beeasily visible from a distance so that employee can read the sign and takenecessary protective measures before entering the work area. Signs will read asfollows: DANGER, CADMIUM CANCER HAZARD CAN CAUSE LUNG ANDKIDNEY DISEASE, AUTHORIZED PERSONNEL ONLY, RESPIRATORSREQUIRED IN THIS AREA.

The Authorized person will control access of persons into work area.


Eating, drinking, smoking, and chewing is prohibited in work areas and any areawhere Cadmium exposure may exceed the Permissible Exposure Limit.

Containments

Where required by federal, state, or local regulation, the project sponsor, or theproject owner, containments will be constructed and used as specified.

The purpose of containments is to restrict or prevent the spread of Cadmium-containing dust or debris to surrounding areas or the environment. While the properuse of containments can help protect the public and the environment, they generallycause a significant increase in airborne Cadmium concentrations in the work area.Containments may increase the potential for higher employee Cadmium exposures.Therefore, the use of well designed exhaust ventilation and the use of moreprotective respirators may be necessary to properly protect workers.



I8.8




Complete enclosures maintained under negative pressure by exhaust

ventilation with exhaust air filtration

Containments may also require the construction and use of platforms or scaffolding.These may be stationary or movable, ground supported or suspended.

Personal Hygiene Facilities and Practices

Clean change areas will be provided for all projects where employee airborneCadmium exposures may exceed the Permissible Exposure Limit. These cleanchange areas will be equipped with storage facilities for street clothing and aseparate area for the removal and storage of Cadmium-contaminated clothing and

equipment. This change area will be designed and used so that contamination ofstreet clothing does not occur. Airborne Cadmium exposures in the change area willbe maintained below the Action Level.

Shower facilities will be provided for all projects where feasible when employeeCadmium exposures exceed the Permissible Exposure Limit. Shower facilities willcomply with the OSHA Standard, 29 CFR 1926.51, Sanitation. All employee whoseairborne Cadmium exposures may exceed the Permissible Exposure Limit willshower or at a minimum wash their hands and face at the end of each work shift.Employees required to shower will not leave the workplace wearing any clothingworn while performing Cadmium exposure activities.

Clean lunch areas will be provided for all projects where employee airborneCadmium exposures may exceed the Permissible Exposure Limit. Employee willremove or clean their protective clothing and wash their hands and face beforeeating, drinking or smoking. Airborne Cadmium exposures in the lunch area will bemaintained below the Action Level.

An adequate number of clean lavatory and hand washing facilities will be provided.These will comply with the OSHA Standard, 29 CFR 1926.51, Sanitation.

Where required by federal, state, or local regulation; the project sponsor; or the

project owner; decontamination units will be constructed and used as specified.These generally are maintained under negative pressure and contain clean changerooms, showers and dirty equipment rooms.

Protective Clothing and Equipment

Protective clothing and equipment will be worn by all employees whose airborneCadmium exposures may exceed the Permissible Exposure Limit. Protectiveclothing and equipment will be provided at no cost to the employee.



I8.9

Protective clothing will include washable or disposable full body coveralls. Otherprotective equipment will include faceshields, hats, gloves, shoes or disposable shoecovers, eye protection, and hearing protection as appropriate.

Disposable protective clothing will be used for no more than one (1) work day. Theywill be disposed of as Cadmium-contaminated waste.

Reusable coverall will be collected at the end of each work day in closed containers.Contaminated clothing will be cleaned by authorized laundries according to allapplicable federal, state, or local regulations pertaining to Cadmium-contaminatedlaundry and water discharge. All containers of Cadmium-contaminated laundry willbe labeled as follows: CAUTION: CLOTHING CONTAMINATED WITH CADMIUM.DO NOT REMOVE DUST BY BLOWING OR SHAKING. DISPOSE OF CADMIUMCONTAMINATED WASH WATER IN ACCORDANCE WITH APPLICABLE LOCAL,STATE OR FEDERAL REGULATIONS.

Reusable protective clothing (coveralls) worn where the exposure was above theaction level, will be laundered at least weekly, and clean coveralls provided daily to

employees

Protective clothing and equipment will be removed in the contaminated section ofthe change area and will not be worn into any clean areas not contaminated withCadmium.

Protective clothing and equipment will be worn by all employees performing thefollowing activities where Cadmium-containing compounds are present unlessexposure monitoring proves otherwise: When abrasive blasting, cleanup ofexpendable abrasives, abrasive blasting enclosure construction, movement andremoval, power tool cleaning with and without dust collection systems, manual

scraping, manual sanding, manual demolition of structures, heat gun applications,welding, cutting, torch burning, chemical stripping and Cadmiumcontamination/emergency clean-up activities.

Emergency situations

In the event of emergency situations involving substantial releases of airbornecadmium, the use of appropriate respirators and personal protective equipment willbe utilized. In addition, employees not essential to correcting the emergencysituation shall be restricted from the area and normal operations halted in that areauntil the emergency is abated. Emergency plans shall be noted on Project Specific

Requirements (Attachment 2).


Respiratory protection will be used in combination with engineering controls andwork practices to maintain employee airborne Cadmium exposures below thePermissible Exposure Limit.



I8.10

Respirators will be worn by all employees, other contractors, inspectors, orobservers who may be exposed to airborne Cadmium at or above the PermissibleExposure Limit.

The selection, use, maintenance, and inspection of respirators will be according toMoreno Group LLC and Subsidiaries Respiratory Protection Program. Qualificationsfor respirator users are also contained in this program. Select respirators from the

types listed below in Table 1. Any respirator chosen must be approved by the MineSafety and Health Administration (MSMA) or the National Institute for OccupationalSafety and Health (NIOSH).



I8.11

Table 1 – Respiratory Protection for Cadmium Aerosols

Airborne Concentration of Cadmium orCondition of Use

Respirator Required

Not in excess of 50 ug/m ½ mask air purifying respirator withHEPA filters2,3

½ mask supplied air respirator

operated in demand (negativepressure mode.)

Not in excess of 125 ug/m Loose fitting hood or helmetpowered air-purifying respiratorwith HEPA filters.3

Hood or helmet supplied airrespirator operated in continuousflow mode that is type CE abrasiveblasting respirators operated incontinuous flow mode.

Airborne Concentration of Cadmium or

Condition of Use

Respirator Required

Not in excess of 250 ug/m Full facepiece air purifyingrespirator with HEPA

3

Tight fitting powered air-purifyingrespirator with HEPA

Full facepiece supplied airrespirator operated in demandmode.

½ mask or full facepiece suppliedair respirator operated in acontinuous-flow mode.

Full facepiece self-containedbreathing apparatus (SCBA)operated in demand mode.

Not in excess of 5,000 ug/m ½ mask supplied air respiratoroperated in pressure demand orother positive-pressure mode.

Not in excess of 10,000 ug/m Full facepiece supplied airrespirator operated in pressuredemand or other positive pressuremode, that is, type CE abrasiveblasting respirators operated in a

positive-pressure mode.Greater than 10,000 ug/m3 , knownconcentration, or fire fighting

Full facepiece SCBA operated inpressure demand or other positivepressure mode.

1Respirators specified for higher concentrations can be used at lower concentrationsof Cadmium.

2 Full facepiece is required if the Cadmium aerosols cause eye or skin irritation at theuse concentration.

3 A high efficiency particulate filter (HEPA) means a filter that is 99.97 percentefficient against particles of 0.3 microns size or larger.



I8.12

Exposure Monitoring

For each work project, personal air samples will be collected to determine airborneCadmium exposures to employees performing tasks involving Cadmium exposure.Full shift (at least 7 hours) air samples will be collected for each job classification ineach work area. The air samples will be taken for the shift with the highest expectedexposure level. Moreno Group LLC and Subsidiaries will implement employee

protective measures until results of the employee exposure assessment arereceived. The Authorized person will be responsible to ensure that exposuremonitoring is performed.

Where initial monitoring indicates that Cadmium exposures are below the ActionLevel, and where work activities and conditions will remain the same as at the timeof initial sampling, additional monitoring need not be repeated for that work project.

A written record of the air monitoring data will be kept at the job site.

Where initial monitoring indicates that Cadmium exposures are at or above the Action Level but at or below the PEL, additional representative exposure monitoring

will be conducted at least once every six (6) months for that work project. Whereinitial monitoring indicates that Cadmium exposures are above the PEL, MorenoGroup LLC and Subsidiaries shall include in the written notice a statement that thePEL has been exceeded and a description of the corrective action being taken bythe employer to reduce employee exposure to or below the PEL.

Additional monitoring shall be conducted whenever there has been a change in theraw materials, equipment, personnel, work practices, or finished products that mayresult in additional employees being exposed to cadmium at or above the actionlevel or in employees already exposed to cadmium at or above the action level beingexposed above the PEL, or whenever the employer has any reason to suspect that

any other change might result in such further exposure.

All air samples will be collected and analyzed according to NIOSH 7082 Method orequivalent. All samples will be analyzed by laboratories accredited under theLaboratory Accreditation Program of the American Industrial Hygiene Association formetals analysis.

All exposed employees will be notified in writing of the monitoring results within five(5) days after receiving these results.

Initial exposure monitoring may not be required when previously collected data has

conclusively determined that current job condition exposure levels will be less thanthe Action Level.

Housekeeping

Accumulations of Cadmium-containing dust and debris generated by work activitieswill be removed and cleaned daily.

All persons doing the clean-up will be trained in performing Cadmium activities,respirator qualified, and participate in the medical surveillance program. Respirators



I8.13

and protective clothing will be worn by all persons doing the cleanup unlessexposure monitoring proves otherwise.

Wherever feasible, HEPA-filtered vacuum cleaners will be used for housekeeping.

All Cadmium-containing dust and debris will be collected into sealed containers.The waste will be tested to determine whether it will be disposed as hazardous or

non-hazardous waste. Containers will be labeled as follows: DANGER CONTAINSCADMIUM, CANCER HAZARD, AVOID CREATING DUST, CAN CAUSE LUNG

AND KIDNEY DAMAGE

Employees will not be permitted to remove Cadmium-containing dust from protectiveclothing or equipment by blowing, shaking, or by any other means which dispersesCadmium in the air.

Project Specific Requirements

The specific worker Cadmium protection requirements for each Cadmium-removal

project will be determined by Moreno Group LLC and Subsidiaries, the projectsponsor, and the project owner. The job specific requirements will be placed in

Attachment 2 - Cadmium Removal Project Specific Requirements. Enough detailwill be provided as to accurately outline the job specific requirements. Thisattachment will be posted at the job site and maintained with the work records of theproject.

Recordkeeping

All records relating to training, medical examinations, blood Cadmium monitoring,exposure monitoring, and project specific requirements will be maintained by

Moreno Group LLC and Subsidiaries, for the employees length of employment plus30 years.

Other Relevant Information

The compliance program will be kept available at the work site for examination by anaffected employee or authorized person/agency.






I8.14

Attachment 1





I8.14.a.1

Medical Surveillance/Examination Program ForCadmium Exposure And Respirator Use

Purpose

To establish and implement a program that meets, in substance, the medicalsurveillance requirements of the OSHA Construction Industry Cadmium Standard,

29 CFR 1926.63 and by the OSHA Respiratory Protection Standard, 29 CFR1926.103.

Scope

This program applies to all Moreno Group LLC and Subsidiaries, employees whomay be exposed to Cadmium in the course of their work and who are required towear respirators.

This program also applies to all subcontractors working under the direct control ofMoreno Group LLC and Subsidiaries Subcontractors must provide all manpower,

medical examination and testing, and other resources necessary to comply with thisprogram.

This program combines the medical surveillance and examination requirements ofthe OSHA Construction Industry Cadmium Standard and the Respiratory ProtectionStandard into one unified program.

Requirements

All medical examination will be conducted by or under the supervision of a licensedphysician.

All medical examination will be provided at no cost to the employee and at areasonable time and place.

Moreno Group LLC and Subsidiaries will provide the following information to theexamining physician:

A copy of the OSHA Construction Cadmium Standard, 29 CFR 1926.63,including all Appendices.

A description of the employee’s duties as they relate to Cadmium exposure.

The employee’s representative or anticipated exposure level to Cadmium andany other toxic substance they may be exposed to at work.

A description of any protective clothing and respirators to be used.

Information from previous examination(s) performed for Cadmiumexposure or respirator use, including past blood Cadmium results,including all prior written medical opinions concerning the employee,



I8.14.a.2

that may be in the possession or control of Moreno Group LLC andSubsidiaries.

Medical examinations provided by other employers or groups may be accepted byMoreno Group LLC and Subsidiaries provided the following conditions are met:

The employee agrees to release all medical record of these examinations and

tests to Moreno Group LLC and Subsidiaries or their medical examinationprovider.

All medical examinations and tests specified in this program were performed.

The physician’s medical opinion is reviewed by Moreno Group LLC andSubsidiaries medical provider or an additional medical opinion is provided.

Records of medical examinations and tests are confidential medical records. Access to these records by employees, their designated representatives, or otherparties will be according to 29 CFR 1926.63, Access to Employee Exposure and

Medical Records.


All medical surveillance will be performed by or under the supervision of a licensedphysician.

Initial Examination

Moreno Group LLC and Subsidiaries shall provide an initial (preplacement)examination to all employees covered by the medical surveillance program required

in 29CFR1910.1027 (l)(1)(i) . The examination shall be provided to those employeeswithin 30 days after initial assignment to a job with exposure to cadmium or no laterthan 90 days after the effective date of this section, whichever date is later.

Initial Exams will include the following:

A detailed medical and work history, with emphasis on: past, present, andanticipated future exposure to cadmium; any history of renal, cardiovascular,respiratory, hematopoietic, reproductive, and/or musculo-skeletal systemdysfunction; current usage of medication with potential nephrotoxic side-effects; and smoking history and current status; and

Biological monitoring that includes, Cadmium in urine (CdU), standardized tograms of creatinine (g/Cr); Beta-2 microglobulin in urine (B(2)-M),standardized to grams of creatinine (g/Cr), with pH specified, as described in

Appendix F of the Satndard; Cadmium in blood (CdB), standardized to litersof whole blood (lwb).



I8.14.a.3

Recent Examination

An initial examination is not required to be provided if adequate records show thatthe employee has had an Initial Exam as outlined above within the past 12 months.In that case, such records shall be maintained as part of the employee's medicalrecord and the prior exam shall be treated as if it were an initial examination.

Periodic Examinations

For currently exposed employees, who are subject to medical surveillance under29CFR1910.1027 (l)(1)(i)(A), Moreno Group LLC and Subsidiaries shall provide theminimum level of periodic medical surveillance which consists of periodic medicalexaminations and periodic biological monitoring. A periodic medical examinationshall be provided within one year after the initial examination and thereafter at leastbiennially. Biological sampling shall be provided at least annually, either as part of aperiodic medical examination or separately as periodic biological monitoring.

Periodic Medical Exams will include the following:

A detailed medical and work history, or update thereof, with emphasis on:past, present and anticipated future exposure to cadmium; smoking historyand current status; reproductive history; current use of medications withpotential nephrotoxic side-effects; any history of renal, cardiovascular,respiratory, hematopoietic, and/or musculo-skeletal system dysfunction; andas part of the medical and work history, for employees who wear respirators,questions 3-11 and 25-32 in Appendix D;

A complete physical examination with emphasis on: blood pressure, therespiratory system, and the urinary system;

A 14 inch by 17 inch, or a reasonably standard sized posterior-anterior chestX-ray (after the initial X-ray, the frequency of chest X-rays is to be determinedby the examining physician);

Pulmonary function test of forced vital capacity and forced expiratory volume.

Tests for blood pressure and resting heart rate.

Blood sample and analysis for Cadmium level; Cadmium in urine (CdU),standardized to grams of creatinine (g/Cr); Beta-2 microglobulin in urine

(B(2)-M), standardized to grams of creatinine (g/Cr), with pH specified, asdescribed in Appendix F of the standard; and Cadmium in blood (CdB),standardized to liters of whole blood (lwb).

Blood analysis, in addition to the analysis required under paragraph(l)(2)(ii)(B), including blood urea nitrogen, complete blood count, and serumcreatinine;



I8.14.a.4

Urinalysis, in addition to the analysis required under paragraph (l)(2)(ii)(B),including the determination of albumin, glucose, and total and low molecularweight proteins;

For males over 40 years old, prostate palpation, or other at least as effectivediagnostic test(s); and

Any additional tests deemed appropriate by the examining physician.

Currently Exposed EmployeesFor currently exposed employees, who are subject to medical surveillance under29CFR1910.1027 (l)(1)(i)(A), Moreno Group LLC and Subsidiaries shall provide theminimum level of periodic medical surveillance as outlined above.

Emergency Examinations

In addition to the medical surveillance program in this section, Moreno Group LLCand Subsidiaries shall provide a medical examination as soon as possible to any

employee who may have been acutely exposed to cadmium because of anemergency. The examination shall include the requirements listed above, withemphasis on the respiratory system, other organ systems considered appropriate bythe examining physician, and symptoms of acute overexposure; symptoms mayinclude mild irritation of the upper respiratory tract, a sensation of constriction of thethroat, a metallic taste and/or a cough.

A period of 1-10 hours may precede the onset of rapidly progressing shortness ofbreath, chest pain, and flu-like symptoms with weakness, fever, headache, chills,sweating and muscular pain. Acute pulmonary edema usually develops within 24hours and reaches a maximum by three days.

Termination of employment examination

At termination of employment, the employer shall provide a medical examination inaccordance with the Periodic Examination section of this policy, including a chest X-ray, to any employee to whom at any prior time the employer was required toprovide medical surveillance. However, if the last examination satisfied therequirements of the Periodic Examination section of this policy and was less than sixmonths prior to the date of termination, no further examination is required unlessother actions were triggered in Initial Biological Monitoring or Medical Examinations.

For employees previously exposed, if the employer has discontinued all periodicmedical surveillance, no termination of employment medical examination is required.

Blood Cadmium Monitoring

Along with the initial and annual medical examinations have been addressed,Moreno Group LLC and Subsidiaries will provide periodic biological monitoring forCadmium levels to each employee exposed to Cadmium above the Action Level.



I8.14.a.5

Blood Cadmium analysis will be performed by laboratories licensed by the USCenter for Disease Control (CDC) or which has received a satisfactory grade inblood Cadmium proficiency testing from the CDC in the prior twelve (12) months.

If the employee's levels of CdU did not exceed 3 ug/g Cr and CdB did not exceed 5ug/lwb, and B(2)-M did not exceed 300 ug/g Cr in the initial biological monitoringtests, and if the results of the followup biological one year after the initial

examination confirm the previous results, the employer may discontinue all periodicmedical surveillance for that employee.

If the initial biological monitoring results for CdU, CdB, or B(2)-M were in excess ofthe levels specified in (l)(3)(i), but subsequent biological monitoring results requiredby (l)(3)(ii)-(iv) show that the employee's CdU levels no longer exceed 3 ug/g Cr,CdB levels no longer exceed 5 ug/lwb, and B(2)-M levels no longer exceed 300 ug/gCr, the employer shall provide biological monitoring for CdU, CdB, and B(2)-M oneyear after these most recent biological monitoring results. If the results of thefollowup biological monitoring, specified in this paragraph, confirm the previousresults, the employer may discontinue all periodic medical surveillance for that

employee.

However, if the results of the follow-up tests indicate that the level of the employee'sCdU, B(2)-M, or CdB exceeds these same levels, the Moreno Group LLC andSubsidiaries will provide annual medical examinations until the results of biologicalmonitoring are consistently below these levels or the examining physiciandetermines in a written medical opinion that further medical surveillance is notrequired to protect the employee's health.

A routine, biennial medical examination is not required to be provided if adequatemedical records show that the employee has been examined within the past 12

months.

In that case, such records shall be maintained by the employer as part of theemployee's medical record, and the next routine, periodic medical examination shallbe made available to the employee within two years of the previous examination.

Employee will be informed in writing of their blood test results within five (5) workingdays after receiving results. A statement that the physician has clearly and carefullyexplained to the employee the results of the medical examination, including allbiological monitoring results and any medical conditions related to cadmiumexposure that require further evaluation or treatment, and any limitation on the

employee's diet or use of medications. Moreno Group LLC and Subsidiaries shallpromptly obtain a copy of the results of any biological monitoring provided by themto an employee independently of a medical examination and, in lieu of a writtenmedical opinion, an explanation sheet explaining those results. Moreno Group LLCand Subsidiaries shall instruct the physician not to reveal orally or in the writtenmedical opinion given to the employer specific findings or diagnoses unrelated tooccupational exposure to cadmium.



I8.14.a.6

Medical Removal Program

Employees shall be temporarily removed from work where there is excess exposureto cadmium on each occasion that medical removal is required by actions triggeredby initial biological monitoring; periodic medical surveillance, or examination forrespirator use and on each occasion that a physician determines in a written medicalopinion that the employee should be removed from such exposure. The physician's

determination may be based on biological monitoring results, inability to wear arespirator, evidence of illness, other signs or symptoms of cadmium-relateddysfunction or disease, or any other reason deemed medically sufficient by thephysician.

Employees temporarily removed from Cadmium exposure activities may beassigned to other duties on-site that do not involve Cadmium exposure above the

Action Level.

For any employee who is medically removed from cadmium exposure activities,Moreno Group LLC and Subsidiaries shall provide follow-up biological monitoring at

least every three months and follow-up medical examinations semi-annually at leastevery six months until in a written medical opinion the examining physiciandetermines that either the employee may be returned to his/her former job status orthe employee must be permanently removed from excess cadmium exposure.

Respirator UseRespirator Requirements. Respirators will be provided whenever an employee’sexposure to Cadmium exceeds the Permissible Exposure Level, in work situations inwhich engineering controls and work practices are not sufficient to reduce exposuresto or below the PEL, and whenever an employee requests a respirator.

Respirators will be selected from those approved for protection against Cadmiumdust, fume, and by the Mine Safety and Health Administration and the NationalInstitute for Occupational Safety and Health.

Respirators or combinations of respirators that will provide adequate protection tothe employee will be chosen by the Authorized person based on OSHA IndustryCadmium Standard 29 CFR 1910.1027.

Each employee will be required to wear a half-mask, negative pressure respiratorwill be qualitatively fit tested every six (6) months on the specific respirator that willbe used. Fit test procedures specified in the OSHA Construction Industry Cadmium

Standard, 29 CFR 1926.63, Appendix C will be followed. Full facepiece negativepressure respirator will be quantitatively fit tested in accordance with Appendix C ofthe standard.

Medical Exam - Requirements for respirator users will include examinations andtests as deemed necessary by the examining physician to ensure the ability to wearand utilize respiratory protection. These tests will be provided annually toemployees assigned to wear a respirator.



I8.14.a.7

Physician’s Written Opinion - Medical Examinations

For each examination, Moreno Group LLC and Subsidiaries will obtain a writtenopinion from the examining physician that contains the following:

Whether the employee has a detected medical condition that places them atan increased risk or health effects from exposure to Cadmium

Any special protective measures to be provided to the employee or limitationsto be placed on the employee’s exposure to Cadmium

Whether the employee is medically qualified to wear a respirator and anylimitations of use, especially concerning negative pressure respirators

A statement that the employee has been informed by the physician of theresults of the medical examination, blood tests, urine tests, and of anymedical conditions that may result from Cadmium exposure

Moreno Group LLC and Subsidiaries will provide a copy of the examination and testresults and the physician’s written opinion to the employee immediately after itsreceipt.

Medical records of examinations and tests will be retained by Moreno Group LLCand Subsidiaries for the employee’s length of employment plus 30 years.





I8.15

Attachment 2





I8.15.a.1

Moreno Group LLC and Subsidiaries Cadmium ExposureProject Specific Requirements

PROJECT _______________________________________________________________

LOCATION ______________________________________________________________

DATES _________________________________________________________________

SITE AUTHORIZED PERSON _______________________________________________

DESCRIPTION OF EACH ACTIVITY EMITTING CADMIUM ________________________

_________________________________________________________________________

EQUIPMENT USED _______________________________________________________

_________________________________________________________________________

WORKER TRAINING REQUIRED ____________________________________________

MEDICAL SURVEILLANCE REQUIRED _______________________________________

MECHANICAL VENTILATION EFFECTIVENESS ________________________________

_________________________________________________________________________

CADMIUM WORK AREA LOCATIONS ________________________________________

WARNING SIGNS NEEDED _________________________________________________

HYGIENE FACILITIES _____________________________________________________

EXPOSURE ASSESSMENT CONDUCTED _____________________________________

EXPOSURE ASSESSMENT RESULTS ________________________________________

ADEQUATE RESPIRATORY PROTECTION ____________________________________

RESPIRATORY FIT TEST REQUIRED ________________________________________

RESPIRATORY FIT TEST PERFORMED ______________________________________

PROTECTIVE CLOTHING __________________________________________________

HEPA VACUUMS NEEDED _________________________________________________

EMPLOYEE JOB RESPONSIBILITIES _________________________________________

_________________________________________________________________________

_________________________________________________________________________



I8.15.a.2

OPERATING PROCEDURES FOR WORKER DECONTAMINATION, DISPOSAL OF

PROTECTIVE CLOTHING, CLEANING EQUIPMENT, ETC... _______________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

EMPLOYEE NAME(S) _____________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

JOB DURATION AND EXPOSURE LEVELS ____________________________________

_________________________________________________________________________

OTHER CADMIUM REDUCTION ADMINISTRATIVE CONTROLS ___________________

_________________________________________________________________________

_________________________________________________________________________



I8.15.a.3

ALL CONTRACTORS ON SITE INFORMED OF POTENTIAL CADMIUM EXPOSURE

A DESCRIPTION OF THE SPECIFIC MEANS THAT WILL BE EMPLOYED TO ACHIEVE

OSHA COMPLIANCE. IF ENGINEERING CONTROLS ARE REQUIRED, LIST THE

ENGINEERING PLANS AND STUDIES USED TO DETERMINE THE METHODS

SELECTED FOR CONTROLLING EXPOSURE(S) TO CADMIUM ____________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

LIST THE TECHNOLOGY CONSIDERED IN MEETING THE PEL ___________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

SCHEDULE FOR IMPLEMENTATION OF THE COMPLIANCE PROGRAM ___________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

EMERGENCY PLANS ______________________________________________________

_________________________________________________________________________

_________________________________________________________________________

CONSTRUCTION CONTRACTS/PURCHASE ORDERS __________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________







Fitness to WorkPage: 1 of 11Original: 01/01/2006Revised: 02/01/2010

I9.1

Fitness to Work

Purpose

The purpose of this standard is to assure that employees are and remain able tosafely perform the essential functions of their jobs and arises out of concern that anemployee may have a health problem which could impact his or her ability to safelyand environmentally friendly perform the essential functions of his or her job and toestablish requirements and recommendations related to employee fitness tocontinue work under such circumstances or return to work after illness or injurywhich can reasonably be anticipated to affect the employee’s ability to perform theessential functions of his or her job. This standard is intended to further bothoffshore and onshore safety while complying with all state and federal laws such as

the Family Medical Leave Act and Americans with Disabilities Act.

Scope

The scope of this program describes the implementation of Moreno Group LLC andSubsidiaries Fitness to Work Evaluations. The Fitness to Work Evaluations willinclude both salary and hourly employees.

Responsibilities

The Facility Manager / Offshore Manager or designee is responsible for:


Ensuring that personnel are informed of Moreno Group LLC and SubsidiariesFitness to Work Evaluations.

Verifying need for Fitness to Work when the employee has taken prescriptionmedicine or experienced an off the job injury, accident or sickness which canreasonably be anticipated to affect the employee’s ability to perform the essential functions of his or her job.

Informing the Human Resource Department of an employee’s need for aFitness to Work Evaluation under this program.

Consulting with the Human Resource Department and / or the SH&EDepartment as necessary concerning employees taking prescriptionmedicine.

Approving or disapproving of work that exceeds the ―2-hour extension‖ or ―3consecutive days‖ limits.



I9.2

The First Line Supervisor / Offshore Coordinator / Offshore Superintendent ordesignee is responsible for:


Verifying when employees are taking prescription medicine, experienced anoff the job injury, accident or sickness.

Conferring with Facility Management / Offshore Management as to theiremployees taking prescription medicine and / or experiencing an off the jobinjury, accident or sickness which can be reasonably anticipated to affect theirability to perform the essential function of their jobs.

For observing and monitoring employees physical and mental abilities toperform the essential function of their jobs.

Notifying of the Facility Manager or Offshore Manager if employee’s workactivities will exceed the 2-hour work extension (i.e. greater than 16 hours) or

―3 consecutive days of 16 hours.


Providing assistance to the Facility Manager / Offshore Manager or designeeand the Human Resource Department through communication with MorenoGroup LLC and Subsidiaries’ Company Physician to the extent necessary tocomply with or implement this policy.

Providing assistance to the Human Resource Department in determining whatmedical examinations are required and at what frequency.


Establishing protocols with Moreno Group LLC and Subsidiaries CompanyPhysician concerning Fitness to Work Evaluations including the establishmentof a Cautionary Prescription Medication List.

Requesting Company Physician’s verification of employees ability to continueor return to work while taking prescription medicine or upon the employee’sreturn to work following an illness or injury which can reasonably beanticipated to affect the employee’s ability to perform the essential functions

of his or her job.

Maintaining all records as required by applicable laws and regulations.



I9.3


Prior to starting or accepting an offshore job, or coming to work foronshore workers, and for the duration of employment shall notify theirOffshore Superintendent or Offshore Coordinator / First Line Supervisor thathe or she is taking prescription or over the counter medication or hasexperienced an on or off the job injury, accident or illness which he or she

reasonably believes might affect his or her ability to perform the essentialfunctions of his or her job.

Requirements

Under Moreno Group LLC and Subsidiaries Fitness to Work program evaluations willbe performed by our Company Physician under the following situations:

Post Job Offer and Acceptance

An applicant who has been offered and has accepted employment contingent upon

the successful completion of medical examination is required to meet all applicableFitness to Work Evaluations requirements (see Attachment 1) identified for his or herprospective job assignment.

Change in Working Conditions of Job Assignment

An employee who has a substantial change in working conditions or job assignmentis required to meet all applicable Fitness to Work Evaluation requirements identifiedfor his or her prospective job assignment.

Substantial Change in Health Status

An employee who has experienced an off the job injury, accident or illness (but notlimited to fractures to bones, back injuries, sprains, significant car accidents, heartattack, etc.) which can reasonably be anticipated to affect the employee’s ability toperform the essential functions of his or her job.

Performance-Initiated Review

When First Line Supervisor / Offshore Superintendent or Offshore Coordinator orother supervisory personnel have observed and identified failing or unsafe jobperformance which is believed to be related to an employee’s taking prescription or

over the counter medication or otherwise related to the physical or mental which canbe anticipated to further affect the employees ability to perform the essentialfunctions of his or her job.

Continuing Impairment

When an employee remains absent from work for a prolonged period and must bereassessed to update disability status for short term / long term disability, FamilyMedical Leave Act and other similar leaves or absence.



I9.4

Return to Work

Before an employee’s return to work following any substantial illness, injury orabsence (but not limited to fractures to bones, back injuries, sprains, significant caraccidents, heart attack, etc.) which can reasonably be anticipated to affect theemployee’s ability to safely perform the essential functions of his or her job.

Overseas Assignments

Before an employee may accept an overseas assignment, they must first beevaluated by the Company Physician to ensure the employees health is acceptablefor an overseas assignment.

Upon passing the physical for their overseas assignment, the employee will berequired to start the appropriate Immunizations for the country they will be travelingto and working. These vaccines are recommended to protect travelers from illnessespresent in other parts of the world and to prevent the importation of infectiousdiseases across international borders.

Vaccinations needed depends on a number of factors including destination, whetherour employees will be spending time in rural areas, the season of the year, theemployee’s age, the employee’s health status, and previous immunizations.

The vaccinations required for the destination will be confirmed by the CompanyPhysician and utilizing the CDC website (www.cdc.gov).

Other situations a Fitness to Work Evaluation may be required

When the employee's First Line Supervisor / Offshore Superintendent or Offshore

Coordinator observes and identifies or otherwise becomes aware of any medicalcondition which can be anticipated to further affect the employee’s ability to safelyperform the essential functions of his or her job (e.g. such as the employee beingsubject to unpredictable sudden unconsciousness in a hazardous situation). Whenthe employee’s observed and identified physical or mental condition can beanticipated to subject the employee, co-worker’s, or the public to a substantial risk ofharm.

Procedure for Fitness to Work Evaluations

1) Human Resources Department is to obtain completed medical questionnaire

from all prospective employees and current employees who meet terms forFitness to Work Evaluations.

2) Human Resources Department is to arrange Substance Abuse Screening Testfor all prospective employees in adherence to Moreno Group LLC andSubsidiaries Drug and Alcohol Policy.

3) Human Resources Department to arrange Medical Examination as part of theconditional job offer acceptance process and for current employees who meetterms for Fitness to Work Evaluations.

http://www.cdc.gov/

http://www.cdc.gov/

http://www.cdc.gov/



I9.5

4) Human Resources Department is to arrange a specific fitness, strength, and /or other tests for any prospective employees that may merit further evaluationbased on observed or disclosed physical or mental conditions which canreasonably be anticipated to affect the employee’s ability to perform theessential functions of his or her job. Such test may include requesting theprospective employee to describe or demonstrate how the employee can

perform specific and essential job related tasks with or without reasonableaccommodation.

Supervisor shall be aware of situations that indicate that an employee is not fit forwork. Some examples may include the following:

Failure to meet and/ or safely perform the essential functions of the job or therequirements set forth in this Standard.

Physical inability to obtain or failure to maintain their certification for theapplicable job function.

Physical inability to evacuate per a location’s emergency evacuat ionprocedure, and/or inability to fit or mobilize into an offshore platform’semergency evacuation equipment.

Failure of Respirator Questionnaire, Pulmonary Function Exam, Chest X-Rays, Blood Work, etc.) for employees whose use of respirators is a requiredaspect of their job (i.e. work in H2S environments, sand blasting and paintingoperations, tank cleaning operations, certain welding operations, rescueservices, etc.).

Inability to physically perform duties as Rescue team member or other dutiesplacing unique physical demands on the employee.

First Line Supervisors, Offshore Superintendents or Offshore Coordinators shalladdress Fitness to Work issues and situations by discussing them with theirimmediate Manager, the Human Resources Department and SH&E Department asnecessary to ensure that the Fitness to Work issue is job related and necessary forthe employee’s performance of the essential functions of his job (within ADACompliance).

The issue should first be discussed with the involved employee and then with the

appropriate Management.

When discussing the issue the following aspects of ―American with Disabilities Act‖(ADA) should be taken into consideration:

ADA prevents us from requiring medical exams and from asking disability-related questions of the general employee population.

Medical examinations and disability-related questions may be asked on acase-by-case basis in ―for cause‖ situations where the employee’s supervisor



I9.6

has reliable and objective evidence indicating there may be a fitness-relatedproblem with an employee that poses a substantial risk of injury to theemployee, co-workers or assets.

ADA generally allows non-disability-related questions, e.g.:

- Can you perform these job functions?-

How are you feeling?- Have you recently consumed alcohol? etc.

It also allows us to ask employees to perform tests that are not considered to bemedical evaluations, such as a drug tests and physical agility test when job relatedand consistent with business necessity.

Fatigue Management

All individuals shall meet the following requirements for managing the risksassociated with fatigue:

Work shall be planned such that no one is scheduled to work for more than14 continuous hours, including breaks. When unforeseen circumstancesrequire an employee to work beyond this limit the following requirements mustbe met:

First Line Supervisors or Offshore Superintendents may be allowed a 2-hourextension, after ensuring controls are in place to recognize and managefatigue.

Should the work activities exceed the 2-hour extension, the First LineSupervisor or Offshore Superintendent must immediately notify their Facility

Manager or Offshore Manager for approval to continue their work activities.No work activities shall exceed 18 hours unless prior approval is obtainedfrom the Vice President of the Division performing the work.

No employee shall continue work activities in excess of 16 continuous hoursincluding approvals or more for 3 consecutive days. Should the work activitiesexceed this requirement, the First Line Supervisor or Offshore Superintendent mustimmediately notify their Facility Manager or Offshore Manager for specific approvalto continue their work activities. After 3 consecutive days a 12 hour shift should beworked.

Facility Manager / Offshore Manager approval is required if the ―2 -hourextension‖ or ―3 consecutive days‖ limits are to be exceeded. Should the ―2 -hour extension‖ need to be exceeded to finish a task, prior approval from theVice President over the Division shall be required.

All DOT Hazmat Drivers, Truck Drivers shall be limited to the DOT Regulationfor hours of service. Each driver will be responsible for maintaining theirindividual trip logs to verify compliance with DOT regulations.



I9.7

The table below outlines the hours of service a DOT Covered Drivers my work/drive:

1. Drivers may drive up to 11 hours in the 14-hour on-duty window after theycome on duty following 10 or more consecutive hours off duty.

2. The 14-hour on-duty window may not be extended with off-duty time formeal and fuel stops, etc.

3. The prohibition on driving after being on duty 60 hours in 7 consecutive

days, or 70 hours in 8 consecutive days, remains the same, but drivers can"restart" the 7/8 day period anytime a driver has 34 consecutive hours offduty.

4. CMV drivers using the sleeper berth provision must take at least 8consecutive hours in the sleeper berth, plus 2 consecutive hours either inthe sleeper berth, off duty, or any combination of the two.

The table below outlines the hours of service for a passenger carrying vehicles:

Moreno Group LLC and Subsidiaries shall permit or require any driver used todrive a passenger-carrying commercial motor vehicle, nor shall any such driver

drive a passenger-carrying commercial motor vehicle:

1. More than 10 hours following 8 consecutive hours off duty; or2. For any period after having been on duty 15 hours following 8 consecutive

hours off duty

Moreno Group LLC and Subsidiaries shall permit or require a driver of apassenger-carrying commercial motor vehicle to drive, nor shall any driver drive apassenger-carrying commercial motor vehicle, regardless of the number of motorcarriers using the driver's services, for any period after —

1. Having been on duty 60 hours in any 7 consecutive days if the employingmotor carrier does not operate commercial motor vehicles every day of theweek; or

2. Having been on duty 70 hours in any period of 8 consecutive days if theemploying motor carrier operates commercial motor vehicles every day ofthe week.

Each individual employee is personally responsible for managing the risksassociated with prolonged working hours and shall discuss any concerns withtheir supervisor. The supervisor is responsible for appropriate addressing onthe employee’s concerns.

Rest Breaks

In an effort to minimize the potential for fatigue, breaks will be provided on adesignated frequency. During the summer months, First Line Supervision will beresponsible for evaluating the need and providing if warranted, additional breaks tominimize the potential for heat related illnesses and/or fatigue.



I9.8

Return to Work from Doctor’s Care

Facility Manager / Offshore Managers or designee shall ensure thatpersonnel returning from a prolonged injury or illness must be able to safelyperform the essential functions of their job.

An employee should not be returned to work if the employee is not releasedto full duty without prior approval of Facility Management or OffshoreManager.

Prescription and Over the Counter Medications

To maximize SH&E in the work environment, and to help minimize employeesworking while taking medications which can reasonably be anticipated to affect theemployee’s ability to perform the essential functions of his or her job, all employeesare required to certify at the beginning of each offshore assignment that they aretaking no prescription or over the counter medications which may affect their abilityto perform the essential functions of their jobs. Employees will be required to certify

their job by completing and submitting the Medical Questionnaire (See Attachment2) to their First Line Supervisor or other designated supervisory personnel at theSH&E meeting prior to beginning work assignments for offshore employees andannually for onshore employees. Onshore employees will certify daily utilizingMoreno Group LLC and Subsidiaries’ SH&E Meeting Form (onshore) that there hasnot been a change in their fitness or health. If a change has occurred, a new Fitnessto Work Certification shall be completed and evaluated.

Employees who are taking prescription or over the counter medications are requiredto notify their Offshore Coordinator or First Line Supervisor prior to accepting anassignment offshore or prior to starting work onshore if the use of such medicationmay affect their ability to perform the essential function of their jobs.

All employees who are routinely called upon to operate vehicles, machinery orequipment which may cause injury to himself or others, must also notify theirOffshore Coordinator or First Line Supervisor, prior to accepting an assignmentoffshore or prior to starting work onshore or prior to the operations of such a vehicle,machinery or equipment, of any medication the employee is taking which warnsagainst the use of vehicles or other machinery or equipment.

Upon notification of an employee’s use of any medication which can reasonably beanticipated to affect the employee’s ability to perform the essential functions of his orher job, whether by the employee’s submission of the Medical Questionnaire orthrough any other means (i.e. Drug Screen, etc.), the employee’s OffshoreSuperintendent, Offshore Coordinator or First Line Supervisor shall advise HumanResources of the employee taking such prescription or other medication.

The Offshore Superintendent or Offshore Coordinator or First Lines Supervisor shallprovide to the Human Resource Department or designee the following information:

Full Name and Correct Spelling of the prescription and over the countermedications taken by the employee which can reasonably be anticipated toaffect the employee’s ability to perform the essential functions of his or her

job.



I9.9

The dosage of each medication

For prescription medications the frequency the medication is to be taken (i.e.1 tablet a day, etc.)

The Human Resource Department or designee shall contact Moreno Group LLC andSubsidiaries Company Physician to confirm whether the employee can safelyperform the essential functions of his or her job while taking the prescription or over

the counter medication. The Company Physician will determine whether anemployee is able to perform the essential job functions of his or her job while takingthe prescription or over the counter medication.

If the Company Physician determines the employee is unable to safely perform theessential functions of his or her job while taking the prescription or over the countermedication, the Human Resource Department shall verbally notify the employee whomay not return to work while on the prescription or over the counter medication.Once the employee has finished their prescription medicine, the employee is eligibleto return to work.

Training

Upon hire and at least annually employees will be trained within this procedure andrecognizing signs of fatigue.





I9.10

Attachment 1





I9.10.a.1

ARC Industries, Inc. Fitness to Work Evaluations Requirements

Non DOTPhysical

DOTPhysical

RespiratorQuestionnaire

PulmonaryFunctionExam

RespiratorFit Test

Audiogram

Serum AluminumBlood Test

ChestX-Ray

OSHABloodLeadLevel

CBCBloodTest

SMACBloodTest

BloodLevelZPP

VisionExam

NonDOTDrugTest

DODruTes

Shipping /ReceivingCoordinator X X X

Mechanic X PS PS PS PS PS X X PService Technician X X X

Electricians X PS PS PS PS PS PS PS X X PElectricians Helpers X PS PS PS PS PS PS PS X X P

DOT Driver X PS PS PS PS PS PS PS X X X

Service Manager X PS PS PS PS PS PS PS X XStore Manger X PS PS PS PS PS PS PS X X

Carpenter X PS PS PS PS PS PS X XHousekeeping X PS PS PS PS PS PS PS X X P

Crane/Cherry pickerOperator X PS PS PS X PS PS PS PS X XPlumber’s Helper X PS PS PS X PS PS PS PS X

Mechanic Helper X PS PS PS X

Painter/Blasting X PS PS PS X PS PS PS PS X X



I9.10.a.2

Dynamic Industries, Inc. Fitness to Work Evaluations Requirements

Non DOTPhysical

DOTPhysical



RespiratorFit Test

Audiogram


ChestX-Ray

OSHABloodLeadLevel

CBCBloodTest

SMACBloodTest

BloodLevelZPP

VisionExam

NonDOTDrugTest

DOTDrugTest

AdministrativePersonnel

X X

Control PanelSpecialist

X PS PS PS PS PS X PS

DOT Driver X X

Electricians X PS PS PS PS PS PS PS X X PS

ElectriciansHelpers

X PS PS PS PS PS PS PS X PS

Fitter (Curtis Lane) X PS PS PS X PS PS PS PS X

Fitter (Fourchon) X PS PS PS PS PS PS PS X

Fitter (Harvey) X PS PS PS X PS PS PS PS XFitter (Ingleside) X PS PS PS PS PS PS X

Fitter (Offshore) X PS PS PS PS PS PS PS X PS

Fitter (Topside) X PS PS PS X PS PS PS PS X

Foreman X X3 PS, X

3 PS, X

3 PS, X

3 X

1,2 PS PS PS X

3 X

3 PS X PS

Helper (CurtisLane)

X PS PS PS X PS PS PS PS X

Helper (Fourchon) X PS PS PS PS PS PS PS X

Helper (Harvey) X PS PS PS X PS PS PS PS X

Helper (Ingleside) X PS PS PS X

Helper (Topside) X PS PS PS X PS PS PS PS X PSInstrumentationFitter


InstrumentationTechnicians


Management X XMeteringSpecialist


Offshore CraneOperator

X PS PS PS X PS PS PS PS X X PS

Offshore Rigger X PS PS PS PS PS PS PS X PS

OffshoreSuperintendents

X X3 PS, X3 PS, X3 PS, X3 PSPS,X

3

PS X3 X3 PS X PS



I9.10.a.3

Dynamic Industries, Inc. Fitness to Work Evaluations Requirements

Non DOTPhysical

DOTPhysical



RespiratorFit Test

Audiogram


ChestX-Ray

OSHABloodLeadLevel

CBCBloodTest

SMACBloodTest

BloodLevelZPP

VisionExam

NonDOTDrugTest

DOTDrugTest

Power GeneratingTechnicians


Sales X X

Van Driver X X X

Welder (Curtis

Lane) X PS PS PS X PS PS PS PS XWelder (Fourchon) X PS PS PS PS PS PS PS X

Welder (Harvey) X PS PS PS X PS PS PS PS X

Welder (Ingleside) X PS PS PS PS PS PS PS X

Welder (Offshore) X PS PS PS PS PS PS PS X PS

Welder (Topside) X PS PS PS X PS PS PS PS X

Onshore Crane orCherry PickerOperator

X PS PS PS X PS PS PS PS X X

Onshore orOffshore Painter /Sand Blaster

X X X X X PS X X X X PS

Onshore Rigger X PS PS PS X PS PS PS PS X

OnshoreSupervisors X PS PS PS X1,2 PS PS PS PS X

Sub #1 Curtis Lane - All employees, Harvey – All employees, Sub #2 Topside East and West - All employees, Sub #3 EnvironmentalTopside = East, West and Lake Charles Topside Facilities Division - Foreman and Supervisors, PS = Project Specific



I9.10.a.4

Dynamic Industries, Inc. (Construction Division) Fitness to Work Evaluations Requirements

Non DOTPhysical

DOTPhysical



RespiratorFit Test *

Audiogram


ChestX-Ray

OSHABloodLeadLevel

CBCBloodTest

SMACBloodTest

BloodLevelZPP

VisionExam

NonDOTDrugTest

DOTDrugTest

Administrative X X

Sales X X

Clerical X X

Carpenter X X X X X PS X PS PS PS PS X X

Plumber X X X X X PS X PS PS PS PS X X

Insulator X X X X X PS X PS PS PS PS X X

*All employees who may be required to wear respirators must be initially, and annually fit-tested with the specific respirator(s) thatthey may be required to wear. (Pulmonary function tests will be performed in conjunction with all fit-tests)

Dynamic Industries, Inc. (Environmental Division) Fitness to Work Evaluations Requirements

Non DOTPhysical

DOTPhysical

RespiratoryQuestion

PFTFitTest**

Audio.Serum AL BloodTest

ChestX-Ray

BloodLead

CBC SMAC ZPP VisionDrugScreen

DOTDrugTest

Administrative X X

Sales X X

Clerical X X

Cleaning Techs,includingForemen

X X X X X PS X PS X X PS XX

**All employees who may be required to wear respirators must be initially, and annually fit-tested with the specific respirator(s) thatthey may be required to wear. (Pulmonary function tests will be performed in conjunction with all fit-tests)

Dii LLC (Emergency Response, Government Projects, etal) Fitness to Work Evaluations*

Administrative, Sales, and Clerical personnel have the same ―Fitness to Work‖ requirements as Construction andEnvironmental Divisions for their positions. All other employees are subcontractors. These subcontractors will have all of theappropriate fitness evaluations according to project requirements as designated by S/H & E Dept.



I9.10.a.5

dii Industrial Services, LLC Fitness to Work Evaluations Requirements

Non DOTPhysical

DOTPhysical



RespiratorFit Test

Audiogram

SerumBenzeneBloodTest

ChestX-Ray

OSHABloodLeadLevel

CBCBloodTest

SMACBloodTest

BloodLevelZPP

VisionExam

NonDOTDrugTest

DOTDrugTest

Administrative X

Administrative/McKee

X

Helper/ other PS PS PS PS PS PS PS PS PS PS PS PS X

Helper/ McKee X X X X X X X X X X X X X

Carpenter/ other PS PS PS PS PS PS PS PS PS PS PS PS X

Carpenter/ McKee X X X X X X X X X X X X XIron Worker/ other PS X X X PS PS PS PS PS PS PS PS X

Iron Worker/ McKee X X X X X X X X X X X X X

Operator (crane)/other

X PS PS PS PS PS PS PS PS PS PS PS X X

Operator (crane)/McKee

X X X X X X X X X X X X X X

Electrician/ other PS X X X PS PS PS PS PS PS PS PS X

Electrician/ McKee X X X X X X X X X X X X X

Instrument Fitter/other

PS X X X PS PS PS PS PS PS PS PS X

Instrument Fitter/Mckee

X X X X X X X X X X X X X

Millright/ other PS X X X PS PS PS PS PS PS PS PS X

Millright/ McKee X X X X X X X X X X X X X

Instrument Tech./other

PS PS PS PS PS PS PS PS PS PS PS PS X

Instrument Tech/McKee


Pipefitter/ other PS X X X PS PS PS PS PS PS PS PS X

Pipefitter/ McKee X X X X X X X X X X X X X

Boilermaker/ other PS X X X PS PS PS PS PS PS PS PS X

Boilermaker/ McKee X X X X X X X X X X X X X

Welder, Multi Process Alloy/ other


Welder, Multi Process Alloy/ McKee




I9.10.a.6


Non DOTPhysical

DOTPhysical



RespiratorFit Test

Audiogram

SerumBenzeneBloodTest

ChestX-Ray

OSHABloodLeadLevel

CBCBloodTest

SMACBloodTest

BloodLevelZPP

VisionExam

NonDOTDrugTest

DOTDrugTest

Welder, Multi Process Alloy, Rig/ other PS X X X PS PS PS PS PS PS PS PS XWelder, Multi Process

Alloy, Rig/ McKee X X X X X X X X X X X X X

Welder/ other PS X X X PS PS PS PS PS PS PS PS X

Welder/ McKee X X X X X X X X X X X X X

Welder, Rig/ other PS X X X PS PS PS PS PS PS PS PS X

Welder, Rig/ McKee X X X X X X X X X X X X X

Mechanical Leadman/other PS X X X PS PS PS PS PS PS PS PS X

Mechanical Leadman/McKee X X X X X X X X X X X X X

Foreman 1/ Other PS X X X PS PS PS PS PS PS PS PS X

Foreman 1/ McKee X X X X X X X X X X X X X

General Foreman/other PS X X X PS PS PS PS PS PS PS PS X

General Foreman/McKee X

X X X X X X X X X X XX

Timekeeper/ other PSPS PS PS PS PS PS PS PS PS PS PS

XTimekeeper/ McKee X

Safety Supervisor/other PS PS PS PS PS PS PS PS PS PS PS PS X

Safety Supervisor/McKee X X X X X X X X X X X X X

Quality Control/ other PS PS PS PS PS PS PS PS PS PS PS PS X

Quality Control/McKee X X X X X X X X X X X X X



I9.10.a.7


NonDOTPhysical

DOTPhysical



RespiratorFit Test

Audiogram

SerumBenzeneBlood Test

ChestX-Ray

OSHABloodLeadLevel

CBCBloodTest

SMACBloodTest

BloodLevelZPP

VisionExam

NonDOTDrugTest

DOTDrugTest

Planner/ Scheduler/other


Planner/ Scheduler/McKee


Project Control/other


Project Control/

McKee PS PS PS PS PS PS PS PS PS PS PS PS XSuperintendent/other


Superintendent/McKee


AreaSuperintendent/other


AreaSuperintendent/McKee


GeneralSuperintendent/other


General

Superintendent/McKee


Project Manager/other


Project Manager/McKee




I9.10.a.8

Industrial Safety Solutions (ISS) Fitness to Work Evaluation Requirements

Non DOTPhysical

DOTPhysical



RespiratorFit Test

Audiogram


ChestX-Ray

OSHABloodLeadLevel

CBCBloodTest

SMACBloodTest

BloodLevelZPP

VisionExam

NonDOTDrugTest

DOTDrugTest

AdministrativePersonnel X X

SH&E FieldPersonnel X PS PS PS PS PS PS PS PS PS PS PS X PS

PS = Project Specific



I9.10.a.9

Southern Steel & Supply, LLC. Fitness to Work Evaluations Requirements

Non DOTPhysical

DOTPhysical



RespiratorFit Test

Audiogram


ChestX-Ray

OSHABloodLeadLevel

CBCBloodTest

SMACBloodTest

BloodLevelZPP

VisionExam

NonDOTDrugTest

DOTDrugTest

Driver X X X

Warehouse Puller X X XSteel Supply

Puller X X XWarehouseManager X X X

Receiving/Shipping Manager X X X

DOT Driver X X X

Processingemployee X X X





I9.11

Attachment 2





I9.11.a.1

FIT FOR DUTY CERTIFICATE 1410513

I certify that during my days off from _____________________ to ____________________,

Circle One

1 Was involved in any type of accident? Yes No

2 Suffered an injury to any part of my body Yes No

3 Had surgery performed, either in-patient or out-patient Yes No

Explain any “Yes” answers to the above: _________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

4 Was sick or ill? Yes No

5 Had a high temperature? Yes No

6 Was seen by any doctor? Yes No

7 Went to the emergency room of any hospital? Yes No

8 Was hospitalized overnight for any reason? Yes No

9 Prescribed medication by a doctor? Yes No

10 Underwent any type of diagnostic test? Yes No

11 Had surgery recommended by a doctor? Yes No

12 Went to a dentist? Yes No

13I had an extensive dental procedure performed or recommended bya dentist ?

Yes No

If you answered “Yes” to any questions above (1-13), you must complete and submitthe “Medication Questionnaire” on the back of this document directly to yoursupervisor.

I certify that the above answers are true and correct.

I further certify that I am fully fit to return for my regular hitch and I am physically andmentally able to safely perform my job.

___________________________________ ________________________________DATE EMPLOYEE SIGNATURE

________________________________PRINT EMPLOYEE’S NAME



I9.11.a.2

Medication Questionnaire

As described in Moreno Group LLC and Subsidiaries Substance Abuse andContraband Policy, prescription and non-prescription medications may interfere withsafe and effective performance of duties or operation of equipment. In order tomaintain a safe workplace, Moreno Group LLC and Subsidiaries would like to ensureany medication you are taking will not hinder your ability to work safely or perform the

essential function of your job. Therefore, in addition to testing completed as part ofMoreno Group LLC and Subsidiaries’ anti-drug testing and alcohol misuse preventionplans, Moreno Group LLC and Subsidiaries periodically inquires about employee useof prescription and non-prescription medications which can reasonably be anticipatedto affect the employee’s ability to perform the essent ial functions of his or her job.

Are you now taking any prescription or non-prescriptionmedications which you believe may affect your ability tomake decisions, remain alert, reactive, and responsive onthe job, or pose a threat to your safety or that of otherssuch that you believe the use of such medication canreasonably be anticipated to affect your ability to perform

the essential functions of your job?

Circle one: Yes or No

IF YOU ANSWERED “YES”, YOU ARE NOT TO BEGIN WORKING WITHOUT YOURSUPERVISOR’S APPROVAL, AND MUST COMPLETE THE CHART BELOW.

PLEASE PROVIDE THE INFORMATION REQUESTED BELOW FOR EACHPRESCRIPTION OR NON-PRESCRIPTION MEDICATION YOU BELIEVE MAY

AFFECT YOUR ABILITY TO PERFORM THE ESSENTIAL FUNCTIONS OF YOURJOB

Name of Medicat ion Dosage ofMedication

How often is theMedicine Taken

I certify that the above is true and correct.

Employee’s Printed Name Date Employee’s Signature





Hazard CommunicationProgram


I10.1

Hazard Communication Program

Purpose

The purpose of this Hazard Communication Program is to communicate MorenoGroup LLC and Subsidiaries’ policies and procedures to all employees and/orvisitors. The methods to identify hazards of chemicals in the work environment willbe per 29 CFR 1910.1200.

Scope

The scope to the Hazard Communication Program is to inform the employees of thechemical products to which they are exposed and the precautions, which must be

observed when using these chemicals. The following outlines how hazards will becommunicated:

A written Hazard Communication Program is available to all employeesand/or their representatives and visitors. The program will be located in theCompany’s SH&E Management System Manual.

All chemical products used by the company will be identified and inventoried.Material Safety Data Sheets (MSDS) will be obtained for all chemicalspurchased. The MSDS shall be available to all employee and/or visitors. TheMSDS will be located in binders in the supervisor’s office.

Assure appreciate labels are legible on the chemical containers and analternative labeling system is used should the container’s label not be legible.

Training will be conducted at the time of employee’s initial assignment,annually and whenever a new chemical is brought into the work environment.This will be conducted by the supervisor. The training will include thefollowing:

Elements of the MSDS, their location and the possible healthand physical hazards associated with the chemical.

Methods of detection of an accidental release of hazardous chemical.

Specific routine/non-routine work procedures associated with the chemical(i.e. PPE, work practices, personal hygiene).

Location of the Hazard Communication Program

Hazard Communication labeling systems (i.e. manufacturers, alternative).



I10.2

Hazard Assessment of the chemical and inventory requirements.

Responsibilities

The Hazard Communication Coordinator (Safety, Health and EnvironmentalManager) as appointed by the Facility / Site Manager is responsible for:

Overseeing the Hazard Communication program and ensuring itseffectiveness in providing necessary information to employees.

Being knowledgeable of the OSHA Hazard Communication Standard orsimilar regulations.

Maintaining the master list of hazardous substances at the Moreno GroupLLC and Subsidiaries facilities / sites and updating them as necessary.

Granting approval for a chemical’s usage. All chemicals (those currentlybeing used in the facility / site and new chemicals coming into the facility /

site) will be evaluated for associated hazards using the following protocol:

The MSDS will be carefully reviewed by the HAZCOM Coordinator and /or his designated representative.

A review will be conducted of the area that the chemical will be used in toensure that engineering controls are in place (i.e., ventilation, etc.).

Based upon the above steps, an evaluation will be conducted to assessthe potential of employee exposure to the project.

Maintaining the MSDS’s and updating them as necessary.

Retaining all outdated MSDS’s when revisions are received or use of thesubstance is discontinued.


Understanding and complying with the requirements of the HazardCommunication Procedure and appointing a Hazard CommunicationsCoordinator.

Evaluating the listing of hazardous substances at Moreno Group LLC andSubsidiaries facilities / sites. Re-evaluating the hazardous substance listannually or when changes may affect the list.

Determining appropriate personal protective equipment (PPE) to be usedwhen working with hazardous substances and defining the respiratoryprotection requirements, when applicable.



I10.3

Ensuring that personnel are informed of hazardous substances and haveaccess to the MSDS’s.

Monitoring compliance with this procedure.

Ensuring the referencing of MSDS’s in Standard Operating Procedures(SOP’s).

Ensuring MSDS’s are obtained for any new hazardous substancesbrought into any Moreno Group LLC and Subsidiaries facility / site.

The First Line Supervisors are responsible for:


Conferring with other personnel as to the hazardous substances used ona job.

Communicating to personnel reporting to him as to hazardous substancesused on a job. (Reviewing of the material safety Data Sheet.)

Obtaining special PPE when required, including proper respiratoryprotection.

Monitoring jobs and work areas for compliance with this procedure.

Initiating the use of additional precautions as specified in permits, MSDS’sor SOP’s.

Ensuring personnel new to his area have received the proper training.


Following the work practices for chemicals, this includes reviewing andfollowing the chemical’s MSDS information on the proper handling and/orusing the chemical.

Definitions

Alternative Labels - Any written and/or printed label displayed on or affixed to acontainer of a hazardous chemical container.

Hazardous Chemical - Any material that is a physical hazard or a health hazard asdefined by OSHA.

Immediate Use - Any chemical which is under the control of and used only by theperson who transfers if from a labeled container. The transferred must becompleted by the end of the work day.



I10.4

Label - Any written and/or printed label displayed on or affixed to a containers of ahazardous chemical.

Portable Container - Any bottle, box, can, cylinder or any other container thatcontains a hazardous chemical and may be carried by an individual

Hazard Assessment

Manufactures and/or Suppliers are responsible for providing MSDS for thehazardous chemicals purchased by Moreno Group LLC and Subsidiaries

New Chemicals shall not be brought onto Moreno Group LLC and Subsidiaries’ Facility without an approved MSDS on record. Individuals requesting new chemicalsmust complete the “Request for a New Chemical” form (Attachment 1).

Purchased Chemicals will not be received unless the appropriate identification andhazard information accompanies the chemical. The First Line Supervisor shallreview the containers to ensure that the containers meet Moreno Group LLC andSubsidiaries’ requirements. The manufacturer’s label shall be considered adequate

only if the label is legible.

Portable Containers shall be labeled with the name of the hazardous chemical andappropriate hazard warning. All portable containers containing flammable orcombustible materials shall be stored in the Flammable Liquid Cabinet.

Material Safety Data Sheet

Material Safety Data Sheet shall be maintained on all chemicals used and stored atMoreno Group LLC and Subsidiaries Facilities. It is the responsibility of the programadministrator to maintain and update the facilities Material Safety Data Sheet.

Material Safety Data Sheet shall be reviewed by the employee prior to handling anychemical. The Material Safety Data Sheet may be obtained by calling 1-888-362-7416 or www.msdsonline.com.

A chemical inventory list shall be maintained in the Safety, Health andEnvironmental Department. This inventory shall be utilized to submit annual Tier IIreports.

Non-Routine Tasks

Prior to performing any non-routine task such as:

Confined Space Entry into Tanks, Process vessels or Barges

The Material Safety Data Sheet of the chemicals to which the employee may beexposed to will be reviewed during the Confined Space Entry Training.



I10.5

Contractor Safety, Health and Environmental (Multi Employer Worksite)

Contractors will be informed during pre-job meetings and SH&E Orientation on howto gain access to the following information:

MSDS

Procedures/precautionary measures to be followed pertaining to chemicalsoutlined by MSDS.

Contractors shall provide MSDS’s to the yard foreman prior to bring anyhazardous material into any Moreno Group LLC and Subsidiaries facility

Labels and Signs

All chemical and hazardous materials, drums, and bulk tanks received on site shallhave the proper labels. The label shall have the following:

Identify the chemical name

Identify the hazard class of the chemical (NFPA Diamond)

Manufacture of the chemical

All containers having chemicals shall be labeled. The only exception to this rule iscontainers used by one individual, who will immediately use or transfer the chemicalfrom a fixed container and empties the dispensing container.

Facility piping will be labeled with the contents of the piping.

The original label must not be removed from the container. Alternative labels maybe used to replace the original label when the original becomes not legible.

Training

Employees will receive Hazard Communication training during the New EmployeeOrientation / SH&E Training. This training shall include all required elements of 29CFR 1910.1200. Refresher training will be conducted by the First Line Supervisorprior to handling a new chemical and a least annually.





I10.6

Attachment 1





I10.6.a.1

REQUEST FOR A NEW CHEMICAL

Chemical Name:

Chemical Manufacturer:

Type of Storage:

Is Storage Pressurized: Yes_______ No______

Maximum Daily Amount In Inventory:

Purchased Amount:

Requested By: Date:

Approved By: Date:

Recommendation(s):________________________________________

_________________________________________________________

_________________________________________________________

_________________________________________________________

_________________________________________________________

_________________________________________________________

_________________________________________________________





I10.7

Attachment 2





I10.7.a.1

Note: If Spanish speaking employees are present at worksite facilityshould consider bilingual HazCom Stickers.







Hearing Conservation


I11.1

Hearing Conservation

Purpose

The purposes of this program it to set forth the procedures, which have beenestablished to evaluate and control employee exposure to excessive workplacenoise. It is intended to address the requirements of OSHA 1910.95, “OccupationalNoise Exposure.”

Scope

The scope of this plan requires Moreno Group LLC and Subsidiaries to administer ahearing conservation program whenever employee noise exposures equal or exceed

an 8-hour time-weighted average (TWA) sound level of 85 decibels (dB) measuredon the A-weighted scale (slow response) or, equivalently, a dose of fifty percent.

Responsibilities

The Facility / Site Manager / Offshore Manager or Designee is responsible for:

Assuring that noise level surveys are conducted for all typical operations /equipment.

Notify SH&E Department when changes in the work area may affect the noise

levels.

Posting and maintaining warning signs where hearing protection is required.

Conferring with the supervisors to identify noise hazards and hearingprotection required for a specific job / task.

Audit compliance with the use of proper hearing protection.

Implement and manage this program for covered positions.

Maintaining records of employee audiometric test results per Access toMedical records requirements.

The First Line Supervisor or Offshore Superintendent is responsible for:

Understanding and implementing the requirements of the HearingConservation program.



I11.2

Conferring with SH&E Department as to the noise hazards of a job andhearing protection required.

Obtaining special hearing protection when required for a specific job.

Monitoring employee usage of required hearing protection.


Coordinating and/or conducting area noise or personal monitoring.

Facilitating employee notification concerning exposure monitoring.

Assisting Human Resource Department in annual audiogram testing forcovered employees.


Coordinating annual audiogram testing for covered employees.

Maintaining employee exposure and monitoring records per Access toMedical Records requirements.


Complying with this procedure and using the required hearing protection.

Employees are expected to cooperate with those conducting noise monitoringby providing information about the work environment, the equipment inoperation, and specific jobs.

Conferring with immediate supervisor as to noise hazards involved andhearing protection requirements associated with the job.

Inspecting hearing protection equipment prior to each use and maintaining itin a good and clean condition.

Requesting information from supervision about any portion of the HearingConservation Program that is not fully understood.

Requirements

Engineering and Administrative Controls


Engineering controls shall be implemented to reduce noise levels whenever feasible.



I11.3


Administrative controls shall be exercised to reduce noise levels, when practical.

Monitoring

Covered Employees

Employees whose noise exposures equal or exceed 85 dBA for an 8-hour TWA onthe A scale (slow response) or 82.5 dBA for a 12-hour TWA on the A scale (slowresponse) are included in the Hearing Conservation Program. Any exception to thiscriterion will be made on an individual case basis.

All personnel are included in the Hearing Conservation Program, with the exceptionto office personnel and those employees not exposed to 85 dBA for an 8-hour TWA.

Personal Sampling

Personal noise monitoring is to be conducted to determine the noise exposures ofemployees who are included in the Hearing Conservation Program.

Results of noise monitoring will be filed in the employee’s medical recor d file. Anotification letter shall be distributed to the employee explaining the results to them,on their personal noise monitoring.

Method of Noise Measurement

Employee exposure measurements are obtained by the use of noise dosimeters andsound level meters.

Noise dosimeters measure all continuous, intermittent, and impulsive sound levelsfrom 80 dB to 130 dB, which are integrated into TWA’s.

Measurements are obtained on the A-weighted scale using the “slow response”mode.

Equipment used to monitor employee noise exposures shall be calibrated beforeand after each day’s use in accordance with the equipment calibration instructions.

Observation

All employees and/or their representatives are entitled to observe any noisemonitoring that is to be conducted.

Audiometric Testing and Evaluation

Audiometric or Hearing Testing

Testing is available on an annual basis to all Moreno Group LLC and Subsidiariesemployees covered by this program.



I11.4

The audiometric test will be compared to the baseline test to determine if a StandardThreshold Shift (STS) has occurred.

A certified audiologist or technician will perform these tests.

All participating employees will receive written individual test results from the testing

company.

Employees are to be advised to avoid high noise levels, occupational and non-occupational, for fourteen (14) hours prior to taking an audiogram.

Baseline Audiogram

Moreno Group LLC and Subsidiaries shall offer a baseline audiogram within six (6)months of employment, or during a pre-placement physical.

Audiogram Evaluation

The testing facility will evaluate all audiogram to determine if an STS has occurred.The STS is defined as a change in hearing threshold relative to the baselineaudiogram of an average of 10 dB or more at 2000, 3000, and 4000 Hz in either ear.

Occupational age-adjusted noise-induced threshold shifts greater than or equal to anaverage of 25 dB at 2000, 3000 and 4000 Hz in either ear shall be recorded as anoccupational illness on the OSHA 300 log. A follow-up audiogram will be performedto confirm this result.

Employees included in the Moreno Group LLC and Subsidiaries Hearing

Conservation Program who experience an STS will be notified in writing.

A follow-up audiogram within thirty (30) days of the original audiogram.

Follow-up Procedures

All employees will be notified of an STS in writing within 21 days.

The following actions are to be taken (unless a physician determines that the STS isnot work related):

Refer as necessary for clinical evaluations or additional testing.

Inform employees with non-work related ear problems of need forexamination.

Provide employees with hearing protectors (if not already wearing) train incare and use and require them to be worn.



I11.5

Hearing Protection

Evaluation

Hearing protection provide will be evaluated to ensure the appropriate NoiseReduction Rating (NRR) is provided.

Availability

Hearing protectors are available through the customer and the Operations Manager.

Requirements

Hearing protectors are required to be worn when the following exist:

Employees are exposed to 85 dBA TWA or greater, as identified by posting ofsigns in designated areas.

During tasks that generate noise.

Precautions

Posting of signs stating “Caution Hearing Protection is Required in This Area orHearing Protection is Required Beyond This Point” have been posted in areas withnoise levels of 85 dBA or greater, measured with a sound level meter.

All employees working in the posted areas shall wear approved hearing protectors.Supervisors are responsible for ensuring that employees adhere to the hearingprotection requirements.





Dynamic Industries, Inc.

SH&E Management

SystemHeat Stress Management

Page 1 of 5

Original: 05/12/2009

Revised:

I12.1

Heat Stress Management

Purpose

The purpose of this procedure is to establish procedures throughout all of DynamicIndustries Inc. facilities to ensure heat stress management and potable drinkingwater is adequately provided throughout the workplace as well as electrolyteavailability during excessive heat.

Scope

This procedure applies to all of Dynamic Industries Inc. facilities and worksites. Thegoal of this procedure is to ensure all facilities follow uniform procedures insupplying potable drinking water throughout the workplace as well as electrolytesduring excessive heat.

Responsibilities

The Facility / Site Manager or Designee is responsible for :

Overall coordination and implementation of this procedure.


Assigning personnel the responsibility for cleaning and distributing watercontainers throughout the facility.

If applicable, developing project specific plans to address when additionalmitigation practices may need to be implemented.

The First Line Supervisor / Superintendent is responsible for:

Ensuring heat stress management is addressed during SH&E meetings andas a hazard on the JSEA with proper mitigation.

Monitoring employees and new hire employees to ensure employees arestaying hydrated throughout the workday and not showing any signs aresymptoms of any heat related illness.

Ensuring sealed and dated water containers are available in immediate workareas.



I12.2

Distributing electrolyte supplements when applicable.

Discussing proper hydration methods during morning SH&E meetings.


Discussing any concerns relating to this procedure with their immediatesupervisors or Safety, Health and Environmental Department.

The Safety, Health and Environmental Department are responsible for:

Training and coordinating the training of managers, supervisors and hourlyemployees on this procedure as well as water container cleaning procedure.

Periodically auditing the facility to ensure compliance with this procedure.

Issuing Heat Stress Safety Alerts (Attachment 1 & 2) and Heat Advisoriesduring extreme heat conditions.

Training employees on Heat Stress Awareness monthly training topic.

Requirements

Water Container Cleaning Instructions

Dynamic Industries, Inc. will ensure water containers are cleaned utilizing the below

procedure each time before a water container is utilized:

Wash hands with anti-bacterial soap or hand sanitizer and utilize nitrilegloves prior to cleaning and / or filling water containers.

Before opening the water container, remove the tape around the outside ofthe lid and thoroughly clean the outside of the container, lid, handle andspout area. Utilize a plastic bristle brush marked “For Outside Use Only”.

Clean and disinfect inside and water container and spout utilizing a 1:50bleach to water disinfectant. For spray bottles utilize 24oz. water and 3 tsp.

bleach.

For containers that have not been used in over 3 days, new containers orcontainers with excessive dirt/grime, the following needs to be performed:

o Thoroughly wash container using soap and water.o Use a long handled bristle brush marked “For Inside Use Only”, and

scrub the inside of the container.o Follow below disinfecting procedure.



I12.3

For containers that are used daily and are not excessively soiled, only thebelow disinfecting procedure shall be utilized:

o Spray or wipe the inside of the container and lid using the 1:50 bleachto water disinfectant.

o Be careful to drench all components of the container including the lidand spout area.

o Allow the disinfecting solution to sit in the container for 3 minutes priorto discarding it.

o Do not rinse the container after disinfecting as this can introduce newcontaminates.

o The container is ready for use. It can be immediately filled afterdecontamination or the top can be secured and container can be filledlater. If container is to be filled later, repeat the bleach solutiondisinfecting steps prior to filling the containers with water.

Filling Water Container Instructions:o Wash hands with anti-bacterial soap or hand sanitizer and utilize

nitrile gloves.o Fill container with ice then top off with water.o If ice machine is used, ensure ice scoop is used.o Do not handle ice or water with bare hands, ensure nitrile gloves are

utilized.o All hoses used for cleaning and filling of water coolers should only be

used for this purpose.o After the container is filled, secure the lid, dry off the container and

place tape around the lid.o Write the time and date the container was filled on the tape.

Electrolyte Supplements

Electrolyte supplements in addition to water will be provided to employees whendeemed necessary by Dynamic Industries Inc.’s Facility Management and Safety,Health and Environmental Department during extreme heat conditions.

During extreme heat conditions, employees will be provided two (2) individualpackets of Sqwencher® or equivalent electrolyte replacement supplements to beconsumed at morning and afternoon break. This will be distributed to eachemployee by their respective foremen each morning at the SH&E Meeting. When

utilizing electrolyte supplements, ensure water is still consumed in adequatequantities.





I12.4

Attachment 1





I12.4.a.1

Who Turned Up the Temperature!

Heat Stress Disorders are serious. Workers who have ignored the symptoms havelost their lives. Humans have an ingenious system for regulating body temperature-a personal, natural air conditioner. We sweat, it evaporates through our skin, and

we’re cooled off. But this personal air conditioner can fail, and often does if weoverexert when environmental temperatures are high. To help you recognize HeatStress Disorders, the following are the symptoms.

Symptoms of Heat Stress Disorders:

Heat Cramps- Symptoms are painful spasms of the muscles. Heat cramps arecaused when workers consume large quantities of water but fail to take enough saltto replace the salt their body lost through sweating. Tired muscles are mostsusceptible to cramping.

Heat Exhaustion- Symptoms are moist, clammy, pale skin; profuse sweating,extreme weakness or fatigue, dry mouth dizziness fast pulse, rapid breathing, musclecramps and nausea.

Heat / Sun Stroke- Symptoms are a very high body temperature (104 degrees F orhigher), lack of sweat, mental confusion, deep breathing and rapid pulse, hot, dry,red or mottled skin, and dilated pupils. Seek medical help at once for this condition.

Tips for Heat Stress Prevention:

Acclimatization: Adjust yourself to the heat through short exposure periods followedby longer exposures until your body is accustomed to the heat. It may take 5-7 daysof hot weather exposure before the body undergoes changes that make heat morebearable. This is especially important for new employees or offshore employees whohave been off of work who may not be acclimated to the heat. It will be important toclosely monitor these employees for the first week until they become acclimated tothe heat.

Drink lots of Water - Replenish the fluid that your body is losing though sweating.Not only water, but also critical electrolyte such as sodium, potassium and calciumare lost through sweating, so consider using electrolyte drinks to combat heat relateddisorders.

Education- Know the signs and symptoms of heat stress disorders and act quickly.

Use Your Head- Do not ignore possible symptoms of heat stress disorders. If youfeel very hot, dizzy, nauseous or if your muscles cramp, stop and cool off!!

Be Cool . Know what you have to do to Beat the Heat!





I12.5

Attachment 2





I12.5.a.1

First Aid Treatment

1. Loosen or remove clothing and boots

2.

Cool the victim as fast as possible

Symptoms

1. Heavy sweating

2.

Intense thirst from dehydration

3.

Fatigue weakness or loss of

coordination

4.

Tingling in hands and feet or

headache

HEAT STRESS – KNOW THE FACTS

Please use the following information as a guide for working in the heat, proper hydration and thesigns, symptoms and facts of heat stress and heat illness. Please keep in mind that you are themost important asset that we have as a company and if you feel that heat is impacting the workthat you are performing, please stop your job, take a break in a cool area and properly hydrate

yourself.

Q: How many workers in United States are affected by heat stress every year?A: 10 million or about 7% of the US workforce

Q: Other than the health effects of the individual, what other problems does heat stress cause?A: Decrease in productivity,A: Decrease in alertness,A: Decrease in morale,A: Increase in proneness to accidents

Q: What is the prime cause of heat stress?A: Dehydration

HEAT EXHAUSTION

HEAT STROKE

Early Symptoms1. High body temperature2. Hot, red or flushed, dry skin

3. Headache or dizziness4. Confusion or delirium

Advanced Symptoms1. Seizure or convulsions2. Loss of consciousness3. No detectable pulse



I12.5.a.2

Treatment1. Lower the victim’s body temperature as fast as possible 2. Don’t give liquids to unconscious victims

Other tips for controlling heat stressIndividuals:

Allow your body to become acclimated to your surroundings

Follow scheduled work/rest cycles to avoid overexertionDrink before you’re thirsty Drink 6-8 ounces of cool water every 15 minutes1 hour of strenuous activity requires 1 liter of fluid replacementAvoid alcohol, coffee, tea or sodaConsume a light, cool lunch instead of hot, heavy meals

Leadership:

Ensure everyone is trained on the symptoms of heat stressGive consideration to inclusion of heat stress as a hazard when developing JSAs and ensuremitigation steps are followed

Heat Index

AM I HYDRATED?

Facts Related to DehydrationOur body is 60% water.Our brain is 85% water andhas a narrow tolerance ofdehydration to stay at it'speak.



I12.5.a.3

We lose about 8-10 cups (64-80 oz) of water per day (WITHOUT exercise) throughbreathing, perspiration and normal bodily functions.75% of people are dehydrated.As little as 2% loss in water content begins to cause the brain to lose alertness and the bodyto feel fatigue. In 37% of us, the thirst mechanism is so weak it is often mistaken for hunger.The number one trigger of day time fatigue and poor performance is not lack of sleep or

stress but dehydration.

Formula

Body Weight + 12 = Daily Requirement (ounces)2

Example150 lb person = (150/2)+12 = 75+12 = 87 oz.

THE URINE COLOR CHART

This urine color chart is a simple tool your can use to assess ifyou are drinking enough fluids throughout day to stayhydrated.If your urine matches the colors numbered 1, 2, or 3 you arehydrated.

If your urine matches the colors numbered 4 through 8 youare dehydrated and need to drink for more fluid.

Be Aware! If you are taking single vitamin supplements or amultivitamin supplement, some of the vitamins in the

supplements can change the color of your urine for a fewhours, making it bright yellow or discolored.

Electrolyte Supplements

Electrolyte supplements in addition to water will be providedto employees when deemed necessary by Dynamic IndustriesInc.’s Facility Management and Safety, Health and

Environmental Department during extreme heat conditions.

During extreme heat conditions, employees will be provided two (2) individual packets of

Sqwincher® or equivalent electrolyte replacement supplements to be consumed at morning andafternoon break. This will be distributed to each employee by their respective foremen eachmorning at the SH&E Meeting. When utilizing electrolyte supplements, ensure water is stillconsumed in adequate quantities.







Hexavalent ChromiumProgram


I13.1

Hexavalent Chromium Program

Purpose

The purpose of this program is to establish and implement practices and proceduresfor protecting the health of Moreno Group LLC and Subsidiaries employees whomay be exposed to airborne hexavalent chromium while on the job. This programalso establishes methods for complying with the OSHA Construction IndustryChromium (VI) - 1926.1126 and OSHA Standards for General Industry – 1910.1027.

Scope

The scope of this program applies to all Moreno Group LLC and Subsidiariesprojects and employees involved with exposure to hexavalent chromium.

This program also applies to all subcontractors, working under the direct control ofMoreno Group LLC and Subsidiaries, involved with projects that have exposure tohexavalent chromium from work processes and activities. Subcontractors mustprovide all manpower, supplies, equipment, training, and medical examination andtesting necessary to comply with this program.

Responsibilities


Informing the SH&E Department of the any upcoming project that may havethe potential of containing hexavalent chromium exposure.

Inform any subcontractors that may be working on the project that hexavalentchromium exposure may be possible.




Designating employees for the project and ensuring that a list employees isprovided to the SH&E Department to report to the Medical Review Officer tobe placed in a medical surveillance program and receive all necessarysurveillance prior to job commencing, such as Pulmonary Function Testingand questionnaire, as well as any pulmonary testing deemed necessary.



I13.2

Coordinate with the SH&E Department to see if all designated employeeshave received hexavalent chromium training and / or up to date. If training isneeded, coordinate with the SH&E Department date and time for whichtraining will take place.



Performing with and without the SH&E Department a pre-job inspection andcontinuous monitoring of jobsite to ensure that all safe work practices arebeing done.

Coordinating with the SH&E Department at the end of the project or when anyemployee is removed from the project that those employees all go to theMedical Review Officer and receive post job medical testing that is deemednecessary.


Coordinating with First Line Supervisor to determine which projects andemployees will be working with airborne chromium and have potentialexposure.

Perform any training, such as respiratory training and fit testing, as well aspre-job hexavalent chromium training, for all employees that need thistraining.

Coordinating and performing any air monitoring which may be required, aswell as coordinating any medical surveillance needed with the HumanResources Department.

Regularly audit jobsites, along with First Line Supervisors, to ensurecompliance with this procedure.

Scheduling of third party air monitoring and notifying personnel of monitoringresults.


Authorizing all employees to go to the Medical Review Officer and receiveany medical surveillance that is needed for projects with airborne chromiumexposure.


Informing the SH&E Department of any employee that is unsuitable to workon the project due to medical reasons.



I13.3

Authorizing all employees to return to Medical Review Officer follow-upmedical surveillance once project is complete or if employee has beenremoved from project.



Reporting to his immediate supervisor any problem, which may arise, or anysymptoms of chromium exposure.

DEFINITIONS

Action level - Concentration of airborne chromium (VI) of 2.5 micrograms per cubicmeter of air (2.5 µg/m3) calculated as an 8-hour time-weighted average (TWA).

Chromium (VI) [hexavalent chromium or Cr(VI)] - Chromium with a valence ofpositive six, in any form and in any compound.

8-hour TWA Concentration - 8-hour Time-Weighted Average concentrations forairborne contaminants - common units for reporting daily airborne hexavalentchromium exposures. This is the chromium exposure received per day expressedas a constant exposure for eight (8) hours at a steady state concentration.

Employee exposure - Exposure to airborne chromium that would occur if theemployee were not using a respirator.

Competent Person - One who is capable of identifying existing and predictablehexavalent chromium hazards in the surroundings or working condition and who has

authorization to take prompt corrective measures to eliminate them.

HEPA filter - High Efficiency Particular Air filter - Filters that remove 99.97% of allparticulate 0.3 microns or greater in diameter.

mg/m - Milligrams per cubic meter of air. Common units for reporting airborneconcentration of chromium.


PEL - OSHA requires employers of workers who are occupationally exposed toairborne chromium to institute engineering controls and work practices to reduce andmaintain employee exposure at or below permissible exposure limits (PEL's). Theemployer shall ensure that no employee is exposed to an airborne concentration ofchromium in excess of 5 micrograms per cubic meter of air (5 µg/m

3), calculated as

an 8-hour time-weighted average (TWA).

Physician or other licensed health care professional [PLHCP] - An individual whoselegally permitted scope of practice (i.e., license, registration, or certification) allows



I13.4

him or her to independently provide or be delegated the responsibility to providesome or all of the particular health care services required by OSHA 29 CFR1926.1126 (k).

REQUIREMENTS

RECOGNITION OF HAZARDS

IDENTIFICATION OF CR(VI) AND WORKPLACE HAZARDS OF EXPOSURE

Cr(VI) is a natural metal used in a wide variety of industrial activities, including themanufacturing of stainless steel, welding, painting and pigment application,electroplating, surface coating processes, wood preservation, and abrasive blastingmaterials (Table 1). OSHA specifically cites those involved with welding and cuttingstainless steels as the group with the highest risk.

Table 1Cr(VI) in Industry Products

USES TYPES OF HEXAVALENTCHROMIUM CHEMICALS

Pigments for paints, inks,and plastics

Lead chromate (chrome yellow, chromegreen, molybdenum orange), zincchromate, barium chromate, calciumchromate, potassium dichromate, sodiumchromate

Anti-corrosion products(chrome plating, spraycoatings, additives)

Chromic trioxide (chromic acid), zincchromate, barium chromate, strontiumchromate

Stainless steelCr(VI) is given off when stainless steel iscast, welded, or torch cut

Wood preservation Chromium trioxide

It is important to note that welding filler metals typically have material properties thatclosely mirror the base metal compositions. It has been established that the higherthe chromium level in the supplied materials, the more Cr(VI) will be generated inwelding fumes. Studies performed by the Navy Research Center determined thatapproximately 90 percent of the fumes generated during welding come from the fillermetal, and the other 10 percent comes from the base metal.

Stainless steel electrodes and filler wires contain metallic chromium and chromium

alloys. Stainless steel filler metals contain little or no chromium oxide, but the highheat from the welding arc causes the metallic chromium to oxidize and transmits itinto the air as a fume. The high-heat oxidation process caused by the arc producesCr(VI) as a byproduct in the fume, which becomes airborne part of the weldingenvironment.

The type of welding or cutting also influences the generation of metal fumes andtherefore the concentration of Cr(VI). The highest fume exposures--from highest tolowest--are from arc gouging and plasma arc cutting, then shielded metal arc



I13.5

welding (stick welding), then gas metal arc (MIG)/gas tungsten arc (TIG) welding.However, when considering Cr(VI) fume levels apart from other metal fumes, thelowest Cr(VI) exposures are often seen in welding processes that use a flux insteadof a shielding gas.

The next most significant source of Cr(VI) exposure within Moreno Group LLC andSubsidiaries operations is the generation of dust, fumes or mist from the following

operations:

Abrasive blasting involving grit contaminated with Cr(VI);

Abrasive blasting on base material coated with any chromate or dichromatepaint;

Grinding, drilling, or other similar aggressive activity on any chromate ordichromate paint;

Welding or torch cutting on any chromate or dichromate paint;

Painting activities that use chromate or dichromate paint; and

Mist or dust generated from using chromium-containing chemicals (e.g.corrosion inhibitors).

HEALTH EFFECTS

The primary routes of exposure to Cr(VI) are inhalation and skin contact. Cr(VI) is acarcinogen and is known to cause lung cancer. It is also suspected of causingleukemia and Hodgkin’s Disease. Other acute and chronic health effects cited by

OSHA that are associated with Cr(VI) include:

Reproductive disorders;

Stomach, kidney, and bladder diseases;

Asthma;

Nasal septum ulcerations and perforations;

Skin ulceration (chrome holes); and

Allergic and irritant contact dermatitis.

Cr(VI) will irritate the nose, throat, and lungs and repeated or prolonged exposurecan damage the mucous membranes of the nasal passages and result in ulcers. Insevere cases, exposure causes perforation of the nasal septum (the wall separatingthe nasal passages).



I13.6

Prolonged skin contact with Cr(VI) can result in dermatitis and skin ulcers. Someindividuals may develop an allergic sensitization to chromium and direct eye contactwith chromic acid or chromate dusts can cause permanent eye damage.

CONTROLLING EXPOSURES AND MANAGING RISKS

EXPOSURE LIMITS

The OSHA standard regulates the permissible exposure limit (PEL) for Cr(VI) to 5micrograms per cubic meter (μg/ m3) of air as an 8-hour time-weighted average(TWA). Respiratory protection, safe work practices, and engineering controls arerequired above 5 μg/ m

3 TWA and above.

When feasible, use engineering and work practice controls to reduce and maintainworkforce exposure to chromium (VI) at or below the 5 μg/ m

3. Wherever feasible

engineering and work practice controls are not sufficient to reduce workforceexposure to or below the PEL, reduce workforce exposure to the lowest levelsachievable, and supplement them using respiratory protection.

The OSHA standard also sets an action level (AL) of 2.5 μg/ m3

as an 8-hour TWAexposure. This AL mandates medical assessments if an employee is exposed for 30days or more in a year (regardless of location). This level also triggers the need tomaintain medical assessment records, provide training, and conduct additionalexposure assessments.

DETECTING AND MEASURING CR(VI) IN THE WORKPLACE

OSHA requires that ‘each employer determine the 8-hour TWA exposure for eachemployee exposed to Cr(VI) within their workplace or work operation’ . MorenoGroup LLC and Subsidiaries will utilize air monitoring to determine the TWA

exposure on Cr(VI) projects.

RISK ASSESSMENT

Each operating facility must conduct an assessment to ascertain if any chromium-containing products or materials are being utilized. In addition, facilities shouldconduct such an assessment for each maintenance project at the planning stage.Initial assessments may include a review of Material Safety Data Sheets,engineering specifications, product labels and manufacturer’s product informationsheets. If chromium-containing materials are determined to exist (e.g. stainlesssteel, chrome steel, carbon steel, chromium containing paints or corrosion inhibitors)

or be periodically used (e.g. chromium containing welding rods or paints) in theworkplace, then additional information shall be gathered to identify:

The types and amounts of materials;

How many people are involved; and

The specific work activities involving chromium.



I13.7

QUANTIFIED SAMPLING

A comprehensive sampling and data collection program is needed to quantify therisk of Cr(VI) exposure to personnel. Moreno Group LLC and Subsidiaries shallperform initial monitoring to determine the 8-hour TWA exposure for each employeeon the basis of a sufficient number of personal breathing zone air samples toaccurately characterize full shift exposure on each shift, for each job classification, in

each work area. Representative sampling may be conducted instead of sampling allemployees in order to meet this requirement, as long as the employees sampled arethose expected to have the highest Cr(VI) exposures.

All sampling must be conducted according the analytical specifications of the OSHAstandard (OSHA standard ID 215) and be tested by a laboratory with accreditationfrom the American Industrial Hygiene Association (AIHA), the National VoluntaryLaboratory Accreditation Program (NVLAP), and the National Institute of Standardsand Technology (NIST).

Personal exposure monitoring will be conducted by an industrial hygienist or a

specifically trained technician (e.g. occupational health technician) under thedirection of an industrial hygienist using integrated sampling methods. Monitoringwill be conducted as an initial assessment for all tasks identified as having apotential for Cr(VI) exposure, periodically in accordance with the OSHA standardwhen levels are determined to exist above the action level or whenworkers/management express any reasonable exposure concern.

An industrial hygienist will report laboratory analytical results to the supervisors,SH&E coordinators and workers involved in the monitored task.

If initial monitoring indicates that employee exposures are below the action

level, monitoring may be discontinued for those employees whose exposuresare represented by such monitoring.

If monitoring reveals employee exposures to be at or above the action level,periodic monitoring must be performed for those employees at least every sixmonths.

If monitoring reveals employee exposures to be above the PEL, periodicmonitoring must be performed for those employees at least every threemonths.

If periodic monitoring indicates that employee exposures are below the actionlevel, and the result is confirmed by the result of another monitoring taken atleast seven days later, monitoring for those employees whose exposures arerepresented by such monitoring may be discontinued.

Additional monitoring must be performed when there has been any change inthe production process, raw materials, equipment, personnel, work practices,or control methods that may result in new or additional exposures to Cr(VI), orwhen there is any reason to believe that new or additional exposures haveoccurred.



I13.8

As direct reading instruments cannot be used to determine Cr(VI) concentrations inworkers’ breathing zones, protective measures, such as the use of ventilationequipment and respiratory protection, shall be utilized until quantified exposuremonitoring has been completed that determines the exposure risk associated withthe tasks and the results have been received from a certified analytical laboratoryand review by an industrial hygienist.

CONTROLLING CR(VI) EXPOSURES

Each Moreno Group LLC and Subsidiaries facility/site is responsible forimplementing control measures appropriate to the Cr(VI) exposure levels determinedto exist during the risk assessment and quantified exposure evaluations. In order tocontrol Cr(VI) exposure hazards, standard industrial hygiene controls must beemployed that consist of engineering controls, administrative controls, and personalprotective equipment. Engineering controls are preferred because the hazard isreduced or eliminated. If engineering controls are not effective enough to reduceexposure to below the PEL, the next choice is administrative controls, then finallypersonal protective equipment.

ENGINEERING CONTROLS

The target for engineering control is to reduce Cr(VI) exposure below 0.5 µg/m3,

which is an automatic exemption level to the OSHA Cr(VI) standard, or alternatively,2.5 μg/ m3, which is the action level set by the standard. When feasible, useengineering and work practice controls to reduce and maintain workforce exposureto chromium (VI) at or below the 5 μg/ m3. Wherever feasible engineering and workpractice controls are not sufficient to reduce workforce exposure to or below thePEL, reduce workforce exposure to the lowest levels achievable, and supplementthem using respiratory protection. Engineering and work practice controls are notrequired to be implemented if the 5 ug/ m3 PEL is not exceeded 30 or more days per

year. Job rotation of employees is not allowed to reduce employee exposures or tocomply with requirements of the standard. Engineering controls should beimplemented based on:

Chromium composition in materials;

Type of operations performed; and

Technology available.

It is likely specific controls may be unique to specific tasks and facilities because of

the differing exposure sources and exposure potentials.

Substitution: Substitution of chromium-containing materials with non-chromiummaterials, or substitution with a material containing less chromium, is the bestpossible engineering control.

Ventilation: Ventilation can be used to remove harmful fumes and gases. Thethree types of ventilation are natural, General Dilution and Local Exhaust. GeneralDilution lowers the concentration in the general area of the operator while LocalExhaust removes the fumes and gases at their source. Local Exhaust is the most



I13.9

effective method but may not be the most practical, particularly based upon locationof the task being performed or for blasting/painting operations. Local Exhaust canbe provided by a partial enclosure of the source such as a ventilated work bench, orby smoke suckers positioned as close to the point of welding as possible. Hoods andductwork should be constructed of fire-resistant materials.

Some examples of local exhaust ventilation are portable smoke eaters and fume

extraction welding guns. Local exhaust is best when you have:

Limited mobility;

Limited openings;

Interior obstructions;

Few sources (e.g. welders); and

More toxic alloys.

Some examples of dilution ventilation are centrifugal fans, axial fans andventuri eductors. Dilution ventilation is best when you have:

Mobile work;

Multiple openings;

Few obstructions;

Many sources; and

Less toxic alloys.

ADMINISTRATIVE CONTROLS

Facilities/sites must establish a regulated area wherever an employee's exposure toairborne concentrations of Cr(VI) is, or can reasonably be expected to be, in excessof the PEL. Regulated areas must:

Be demarcated from the rest of the workplace in a manner that adequatelyestablishes and alerts employees of the boundaries of the regulated area;and

Limit access to regulated areas to personnel authorized and required by workduties to be present in the regulated area.

Administrative controls include written instructions (e.g. written contractspecifications, JSEAs) and also include posted regulated areas and safe workpractices. If possible, always use work techniques that generate the least amount ofwelding fume or other airborne chromium-containing materials.



I13.10

Examples of administrative controls are:

Not welding on painted or coated parts and removing all surface coatingsbefore welding;

Using the less fume producing process when practical;

Using cold-cutting techniques instead of torch cutting;

Using the minimum amperage necessary to perform the work correctly;

HEPA vacuuming personnel and areas contaminated with dusts and particlesin order to remove external contamination so that it does not get takenoutside of the work area;

Washing face and hands before eating, drinking, smoking, or applyingcosmetics; and

Prohibiting the consumption of food or beverages, chewing of gum/tobacco orapplication of cosmetics within regulated areas.

PERSONAL PROTECTIVE EQUIPMENT

Personal protective equipment, including respirators, should always be used alongwith, rather than instead of, engineering controls and safe work practices.

Respiratory Protection: Whenever respirators are used to protect against Cr(VI),a written respiratory protection program that complies with OSHA requirementsfound in 29 CFR 1910.134 and a site-specific respirator program must beimplemented. Following standard protection factor application, respirators shall beworn for protection against Cr(VI) as follows:

Half facepiece air-purifying respirator with P-100 (HEPA) cartridges forexposures up to 50 µg/m3;

Loose fitting facepiece powered air-purifying respirator (PAPR) with P-100cartridges for exposures up to 125 µg/m3;

Full facepiece air-purifying respirator with P-100 cartridges for exposures upto 250 µg/m3;

Full facepiece powered air-purifying respirator (PAPR) with P-100 cartridgesfor exposures up to 500 µg/m3; and

Supplied-air respirator for exposure above 500 µg/m3.

Skin and Eye Protection: Protective clothing/equipment is required if a potentialskin or eye hazard exists from direct contact with Cr(VI) compounds. Examples ofsuch tasks include:



I13.11

Spray painting or large blasting operations involving chromium containingpaints;

Welding operations utilizing methods of high fume production on stainlesssteel, or other high Cr(VI) producing products, with known levels above thePEL in confined spaces or within a large operation; or

Handling Cr(VI) containing products, such as corrosion inhibitors (splash orspill risk).

The Industrial Hygiene coordinator should be consulted for professional supportwhen the skin or eye exposure hazard is not known.

If reusable protective clothing is required, then clean and dirty change rooms mustbe provided that are equipped with separate storage facilities for both protectiveclothing/equipment and street clothes, and that prevent cross-contamination. Whereskin contact with Cr(VI) occurs, washing facilities in conformance with 29 CFR

1910.141 shall be provided.

All protective clothing and equipment contaminated with Cr(VI) must beremoved at the end of the work shift or at the completion of tasks involvingCr(VI) exposure, whichever comes first, and no employee shall removeCr(VI)-contaminated protective clothing or equipment from the workplaceexcept for those employees whose job it is to launder, clean, maintain, ordispose of such clothing or equipment.

When contaminated protective clothing or equipment is removed forlaundering, cleaning, maintenance, or disposal it shall be stored and

transported in sealed, impermeable bags or other closed, impermeablecontainers.

Protective clothing must not be worn inside break areas or lunchrooms/galleys.

Bags or containers of contaminated protective clothing or equipment that areremoved from change rooms for laundering, cleaning, maintenance, ordisposal must be labeled in accordance with the requirements of the HazardCommunication regulatory and procedural requirements.

The removal of Cr(VI) from protective clothing and equipment by blowing,shaking, or any other means that disperses Cr(VI) into the air or onto anemployee's body is prohibited.

MEDICAL SURVEILLANCE

Moreno Group LLC and Subsidiaries must make medical surveillance available at nocost to the employee, and at a reasonable time and place, for all employees:



I13.12

Who are or may be occupationally exposed to Cr(VI) at or above the actionlevel for 30 or more days a year;

Experiencing signs or symptoms of the adverse health effects associated withCr(VI) exposure; or

Exposed in an emergency.

Medical examinations shall be provided:

By a Physician or other licensed health care professional (PLHCP);

Within 30 days after initial assignment, unless the employee has received aCr(VI) related medical examination that meets the requirements of thisparagraph within the last twelve months;

Annually;

Within 30 days after a PLHCP's written medical opinion recommends anadditional examination;

Whenever an employee shows signs or symptoms of the adverse healtheffects associated with Cr(VI) exposure;

Within 30 days after exposure during an emergency which results in anuncontrolled release of Cr(VI); or

At the termination of employment, unless the last examination that satisfiedthe requirements of medical surveillance was less than six months prior to the

date of termination.

TRAINING

The workforce must receive training and information as part of Moreno Group LLCand Subsidiaries’s Hazard Communication Program initially upon assignment, at aminimum.

Training shall include:

Cr(VI) exposure risks within the BP facility/site;

Cr(VI) health hazards and routes of exposure;

Protective measures; and

Content of the OSHA Cr(VI) standard including aspects regarding medicalsurveillance.



I13.13

RECORDKEEPING

Monitoring records must include the specific information outlined in OSHA’s newCr(VI) standard as follows:

The date of measurement for each sample taken;

The operation involving exposure to Cr(VI) that is being monitored;

Type of ventilation used

Sampling and analytical methods used and evidence of their accuracy;

Number, duration, and the results of samples taken;

Type of personal protective equipment, such as respirators worn; and

Name, social security number (or unique personal ID number), and job

classification of all employees represented by the monitoring, indicating whichemployees were actually monitored.

Medical surveillance records must include the specific information outlined inOSHA’s new Cr(VI) standard as follows:

Name and social security number;

A copy of the PLHCP's written opinions;

A copy of the information provided to the PLHCP as required by paragraph

(k)(4) of 29 CFR 1910.1026 Chromium (VI).

In accordance with 29 CFR 1910.1020 Access to Employee Exposure and MedicalRecords, employee exposure records must be maintained for at least 30 years andmedical surveillance records, if applicable, must be maintained for the duration ofemployment plus 30 years. In addition, records must be made available toemployees.

ACTION LEVEL LIMIT

The Action Level for airborne chromium is 2.5 micrograms per cubic meter of air (2.5

µg/m3) calculated as an 8-hour time-weighted average (TWA).

Whenever worker’s airborne total chromium exposures exceed due to monitoring,the Action Level, the following will be implemented for the work project:

Periodic monitoring at least every six months.



I13.14

PERMISSIBLE EXPOSURE LIMIT

The Permissible Exposure Limit (PEL) for airborne chromium exposure is five (5)µg/m

3as an 8-hour TWA concentration. This is the maximum 8-hour average

concentration of airborne chromium that an employee may be exposed to duringeach work day.

Whenever worker’s airborne total chromium exposures exceed or are expected to

exceed the PEL, the following will be implemented for the work project:

Periodic monitoring at least every three months.

Competent person



Airborne respirable chromium and exposure monitoring

Record keeping

PPE / Housekeeping

No employee will be exposed to airborne chromium above the PEL without properprotection.

The following methods will be used, as feasible and effective, for maintainingairborne chromium exposures below the PEL:


Warning signs




Housekeeping

During the period that respirators are worn, the protection factor of thespecific respirator may be used to determine employees’ exposure to airbornechromium and to achieve compliance with the PEL.



I13.15

HEALTH EFFECTS

The primary routes of exposure to hexavalent chromium are inhalation and skincontact. Hexavalent chromium is a carcinogen and is know to cause lung cancer. Itis also suspected of causing leukemia and Hodgkin’s disease. Other acute andchronic health effects cited by OSHA that are associated with hexavalent chromiuminclude:

Reproductive disorders

Stomach, kidney and bladder diseases

Asthma

Nasal septum ulcerations and perforations

Skin ulceration (chrome holes) and

Allergic and irritant dermatitis

Hexavalent chromium will irritate the nose, throat and lungs and repeated orprolonged exposure can damage the mucous membranes of the nasal passagesand result in ulcers. In severe cases, exposure causes perforation of the nasalseptum (the wall separating the nasal passages).

Prolonged skin contact with hexavalent chromium can result in dermatitis and skinulcers. Some individuals may develop an allergic sensitization to chromium anddirect eye contact with chromic acid or chromate dusts can cause permanent eyedamage.

COMPETENT PERSON

All work activities where employee airborne chromium exposures may exceed thePEL will include a competent person in both the planning and performing stages ofprojects involving chromium exposure.

The competent person will be a person with training and experience in conduction jobs involving airborne chromium exposure. The competent person will have thecapability of identifying hazards and the authority to take immediate action toeliminate them.

The competent person will be at the work site at all times while airborne chromiumexposure activities are in progress. They may have other job duties, but must beable to monitor work continuously for hazards or deficiencies, and the authority totake immediate corrective action.

EMPLOYEE INFORMATION AND TRAINING

All employees who work on projects where airborne chromium and exposures areknown to or expected to be at or above the PEL will be provided information and



I13.16

training on the hazards of airborne chromium and measures for controlling thesehazards and protecting health.

Employees will receive initial comprehensive airborne chromium training beforeperforming work that may involve airborne chromium exposure. This training will berepeated annually as a refresher course.

The content of airborne chromium training will include:

The specific nature of activities or operations that may result in airbornechromium exposure above the Action Level

The health effects and risks of airborne chromium exposure

OSHA standards and guidelines for airborne chromium exposure


Work practices for controlling airborne chromium and exposure, including

information, warning signs, housekeeping, protective clothing and properhygiene facilities and practices

Respiratory protection for controlling airborne chromium exposure, includingfit testing

Methods for monitoring airborne chromium concentrations and exposures


When conducting airborne chromium exposure activities on a multi-employer worksite, Moreno Group LLC and Subsidiaries will notify other employers of the nature ofthe chromium exposure system in effect, and the potential need to take measures toprotect their employees. Notification to other employers will contain the following:

NOTICE - MORENO GROUP LLC AND SUBSIDIARIES IS PERFORMINGACTIVITIES AT THIS JOB SITE THAT MAY CREATE AIRBORNE CHROMIUMEXPOSURE. ALL CONTRACTORS AT THIS JOB SITE SHALL REMAIN CLEAROF ANY CHROMIUM EXPOSURE AREA. ACCESS INTO CHROMIUMEXPOSURE AREA IS CONTROLLED BY THE MORENO GROUP LLC ANDSUBSIDIARIES JOB FOREMAN. ONLY TRAINED, QUALIFIED WORKERS AREPERMITTED TO ENTER CHROMIUM EXPOSURE AREAS AND MUST WEAR

RESPIRATORS AND/OR PROTECTIVE CLOTHING.

WELDING OPERATIONS

Welders at Moreno Group LLC and Subsidiaries are exposed to hexavalentchromium-CR(VI) through the following means:

Stainless steels or other chromium-containing alloys represent the source ofhexavalent chromium in welding operations.



I13.17

Most welding operations join metals by heating the base and/or filler metal totemperatures at or above the melting point and vaporization temperature ofthe weld joint material.

A portion of the metal vapor, including chromium vapor originating from thebase metal, consumable electrode, surface coating, or surface contaminants

instantaneously reacts with atmospheric oxygen and condenses into solidparticles (known as fume) to form metal oxides, such as iron oxide, andchromium oxides.

o Metallic chromium when vaporized may react with oxygen to form bothtrivalent chromium and hexavalent chromium oxide-containing fume.

Hotwork done on galvanized material, such as cutting on grating or handrailsthat have been coated with galvanize.

WARNING SIGNS

Warning signs will be posted in the work area around activities where airbornechromium exposures may exceed the PEL. The work area can be demarcated byropes, tape, walls, or containments.

Signs will be posted at every accessible side of the work area. These signs will beeasily visible from a distance so that employee can read the sign and takenecessary protective measures before entering the work area. Signs will read asfollows: WARNING, CHROMIUM WORK AREA.



Eating, drinking, smoking, and chewing are prohibited in work areas and any areawhere airborne chromium exposure may exceed the PEL.

CONTAINMENTS


The purpose of containments is to restrict or prevent the spread of airbornechromium or debris to surrounding areas or the environment. While the proper useof containments can help protect the public and the environment, they generallycause a significant increase in airborne chromium concentrations in the work area.Containments may increase the potential for higher employee chromium exposures.Therefore, the use of well designed exhaust ventilation and the use of moreprotective respirators may be necessary to properly protect workers.



I13.18






PERSONAL HYGIENE PRACTICES

All employees whose airborne chromium exposures may exceed the PermissibleExposure Limit will, at a minimum wash, their hands and face before breaks, atlunch and at the end of each work shift.

An adequate number of clean lavatory and hand washing facilities will be provided.

These will comply with the OSHA Standard, 29 CFR 1926.51, Sanitation.

EXPOSURE MONITORING

For work projects when exposure is at or above PEL, personal air samples will becollected to determine airborne chromium exposures to employees performing tasksinvolving chromium exposure. Full shift (at least 7 hours) air samples will becollected for each job classification in each work area. The air samples will be takenfor the shift with the highest expected exposure level. Moreno Group LLC andSubsidiaries will implement employee protective measures until results of theemployee exposure assessment are received. The competent person will be

responsible to ensure that exposure monitoring is performed.

Where initial monitoring indicates that chromium exposures are below the PEL, andwhere work activities and conditions will remain the same as at the time of initialsampling, additional monitoring need not be repeated for that work project.Historical data on past exposure monitoring shall be used and a written record of theair monitoring data will be kept at the job site.

Where initial monitoring indicates that airborne chromium exposures are below thePEL, additional representative exposure monitoring will be conducted at least onceevery six (6) months for that work project. Where initial monitoring indicates that

chromium exposures are above the PEL, additional representative exposuremonitoring will be conducted at least once every three (3) months. Representativemonitoring should be conducted during the beginning of each different phase of theproject or when changes occur to determine range or exposures for chromiumremoval and clean-up activities.

All air samples will be collected and analyzed according to NIOSH 7082 Method orequivalent. All samples will be analyzed by laboratories accredited under theLaboratory Accreditation Program of the American Industrial Hygiene Association formetals analysis.



I13.19


Initial exposure monitoring may not be required when previously collected data hasconclusively determined that current job condition exposure levels will be less thanthe PEL.

HOUSEKEEPING

Accumulations of chromium and chromium-containing dust and debris generated bywork activities will be removed and cleaned daily.

All persons doing the clean-up will be trained in performing chromium activities,respirator qualified, and participate in the medical surveillance program. Respiratorsand protective clothing will be worn by all persons doing the cleanup unlessexposure monitoring proves otherwise.


All chromium and chromium-containing dust and debris will be collected into sealedcontainers. The waste will be tested to determine whether it will be disposed ashazardous or non-hazardous waste.

RECORDKEEPING

All records relating to training, medical examinations, blood chromium monitoring,exposure monitoring, and project specific requirements will be maintained byMoreno Group LLC and Subsidiaries, for the employees length of employment plus

30 years.

OTHER RELEVANT INFORMATION









Hydrogen Sulfide – H2SPage: 1 of 8Original: 10/01/06Revised:

I14.1

Hydrogen Sulfide – H2S

Purpose

The purpose of this program is to establish and implement practices and proceduresfor protecting the health of Moreno Group LLC and Subsidiaries employees whomay be exposed to hydrogen sulfide (H2S). Hydrogen sulfide (H2S) is an extremelytoxic gas responsible for numerous deaths in the oil industry. Many of these deathsare caused by a lack of awareness, improper or shortcutting procedures, lack ofrespiratory protection, and/or poor rescue techniques.

Scope

The scope of this program applies to all Moreno Group LLC and Subsidiariesprojects and employees involved with projects which may contain H2S. H2S can befound in drilling operations, recycled drilling mud, water from sour crude wells,blowouts, tank gauging, tanks at the producing, pipeline and refining operations, fieldmaintenance activities, tank batteries and wells.

Responsibilities

The Facility Manager/Offshore Manager/Yard Foreman or Designee is

responsible for:

Understanding and complying with this policy/ procedure.

Informing the SH&E Department of any upcoming project at an H2S facility.

Designating employees for the project and ensuring that those employees allgo the Human Resources Department to get an authorization to go theapproved Medical Facility and receive Respiratory Protection evaluation andpulmonary function testing.

Coordinate with the SH&E Department to see if all designated employeeshave received proper H2S training and or up to date. If training is neededcoordinate with the Safety Department date and time for which training willtake place.

The First Line Supervisor / Offshore Superintendent is responsible for

Understanding and complying with this policy/ procedure.



I14.2

Ensuring proper respiratory protection is readily available and location ofemergency respiratory equipment.

Ensure client locations site specific plan meets or exceeds this plan.


Coordinating H2S training and respiratory training and fit testing.

Identifying respiratory protection equipment which will be utilized on theproject.


Authorizing all employees to go to the Medical Facility and receive properevaluation.




Reporting any incident to his immediate supervisor.

H2S Toxiity

H2S is an acute toxin; that is, it’s only known toxic properties are caused by short-term exposures to the gas. There are no known health effects associated with long-

term exposure to hydrogen sulfide gas, particularly at concentrations at or below thepoint where short-term symptoms (for example, eye or respiratory irritation) areobserved.

The acute toxicity of H2S can not be overemphasized. H2S paralyses the nervecenter responsible for breathing. One breath of a high concentration (> 1000 ppm)can result in immediate unconsciousness and death by suffocation.

H2S does not last long nor accumulate in the body. Therefore, if the victim ispromptly removed from exposure, there is a good chance that he/she can besuccessfully resuscitated. Any aftereffects would be dependent on the amount of

time the person was without oxygen, not on the amount of H2S inhaled.

Written Hydrogen Sulfide Policy

Each facility/location with hydrogen sulfide (H2S) should have a written H2S programor procedures governing activities that may expose personnel to H2S. MorenoGroup LLC and Subsidiaries will follow the facilities Hydrogen Sulfide Policy unlessthis policy is most stringent. This program should meet or exceed the provisionsoutlined in the sections of this standard.



I14.3

Training Requirements and Hazard Communication

All personnel who may be required to work in a known or suspected H2Senvironment should receive initial training and bi-annual refresher training in thefollowing areas:

hazards and characteristics of H2S gases;

toxicity and properties of H2S;

the proper use of H2S detection devices, including personal detectiondevices;

H2S alarms, employee response to alarms, and contingency plans;

use and limitations of respiratory protective equipment for H2S and SO2 (sulfur dioxide);

symptoms of exposure, first-aid and emergency medical procedures;

emergency rescue, stand-by and "buddy system" requirements;

site-specific H2S procedures, contingency plans, rules, labeling and posting.

All such training should be documented with attendance and course outline.

All sub-contractor personnel should be advised of the presence of H2S, thefacility's/location's H2S program, rules and procedures, and other specialprecautions.

Contractors should document and provide suitable verification of such training fortheir employees upon request.

Respiratory Protection Equipment

For the purpose of this standard, the term "respiratory protective equipment" (RPE)shall imply only positive pressure NIOSH approved self-contained breathingapparatus (SCBA) or positive pressure airline units with an emergency egress bottle;no other types of respiratory protective equipment shall be used in H 2Senvironments, except:

NlOSH/MSHA-approved compressed air escape units may be used forescape from an emergency release of H2S.

NOTE: Air-purifying respirators, including canister units, shall not be used forH2S, even for escape (because of the poor warning properties of H2S, i.e.,olfactory fatigue).

The Standard for “Respiratory Protection and Medical Surveillance” shall be followedfor RPE and personnel required to wear such equipment.



I14.4

Instrumentation and Atmospheric Testing

The odor of H2S shall not be used as an indicator of the presence or absenceof H2S under any circumstances.

The detection of the typical "rotten egg" odor indicates the presence of H2S, but the

odor threshold is very low (<0.02 ppm); and

Above 30 ppm and well below lethal concentrations, H2S produces olfactory fatigue(lack of smell). At high concentrations (> 200 ppm), olfactory fatigue occurs almostinstantaneously. Therefore, the lack of odor is not indicative of the absence ofH2S.

Real-time measurement of H2S concentration in the breathing zone or tank/vesselvapor space can be made with the following types of instruments.

Fixed detector, portable/gas test meter), and personal electronic

instrumentation:

Direct-read" digital meter for determining actual concentration with alarm setpoints; or

"Alarm only" type (no indication of concentration). This type should only beused for personnel warning and should not be used as a screening devicebecause there is no indication of concentration.

Both fixed and personal H2S detection instruments should have a distinctiveaudible and visual alarm signal consistent throughout the facility/location

Color-metric indicating tubes – These are generally less susceptible tointerferences (such as from other sulfur compounds and hydrocarbons) andcan read higher ranges than most electronic instrumentation. If electronicinstrumentation indicates the presence of H2S where none is suspect, color-metric tubes can be used as a confirmatory source. See the Standard “ToxicGas Testing” for additional information on this equipment.

Lead-acetate paper (commonly a “go/no-go” type of indicator): generally hasbeen replaced by other instrumentation. Not recommended, particularly forpersonal monitoring.

Calibration - All instrumentation should be calibrated according to the manufacturer'sinstructions at least monthly, at the time of servicing or repair, and at the timeof battery replacement. See the Standard, “Calibration of Portable ToxicGas/Oxygen Meters.” A calibration log and maintenance record should bemaintained.

Recommended alarm points for H2S instrumentation are 10 ppm for the low alarmpoint and 20 ppm for the high alarm.*



I14.5

Employee(s) must be instructed to evacuate the area immediately, even if the lowalarm is the only one to sound.

Ambient H2S levels should be made in the employee's breathing zone; except that

For tank gauging/sampling purposes, the H2S concentration should be measured atthe level of the thief or gauging hatch, not the breathing zone of the employee. (see

“9.c”)

Safe Work Practices

Written H2S procedures should identify jobs and work conditions where H2S may beof concern and describe appropriate work practices. These procedures shouldinclude at least the following as applicable.

Respiratory protection:

Shall be worn until the concentration of H2S has been established.

Shall be worn for any known or expected environment that equals/exceeds 10ppm in the employee's breathing zone.

Buddy system and requirements of the standby person:

A standby with respiratory protection is required whenever the H2Sconcentration in the breathing zone could exceed 300 ppm (See “9.c”regarding open hatch tank gauging).

Trained in CPR/First-Aid and appropriate rescue techniques or how to initiate

a rescue response.

Trained on and proficient in the use of SCBA.

Have a two-way radio to request back up assistance if an emergencydevelops.

Standby shall be located upwind with a clear view of his/her "buddy."

Ground level is preferable; if the standby must climb to keep his/her "buddy"in view; the standby should don the SCBA, except the facepiece. If the

standby must actually use the RPE because of potential exposure anotherstandby located in a "safe" area would be required.

Requirements for gauging/sampling tank which contain a product producinghydrogen sulfide (H2S) in the tank vapor space are as follows:

For H2S concentration < 10 ppm above the gauging hatch and < 300 ppmat the gauging hatch, no respiratory protection is required; a standby personis not necessary (Figure 1).



I14.6

For H2S concentration > 10 ppm above the gauging hatch and < 300 ppmat the gauging hatch, SCBA or supplied air is required; a standby person isnot necessary (Figure 2).

For H2S concentration > 300 ppm at the gauging hatch, SCBA or suppliedair with escape bottle and a standby person is required (Figure 3).

For the purpose of this discussion, at the hatch means on a plane level withthe top of the hatch.

Alarm investigation

All alarms should be investigated as an actual gas release with properrespiratory equipment and standby personnel.

Employees with personal monitors should be instructed to evacuate the areaimmediately even if the low alarm is the only one to sound.

General Work and Hazardous Work Permit

Efforts shall be made to reduce H2S levels to below 10 ppm beforeimplementing H2S/RPE procedures.

If RPE is required because of H2S levels, appropriate managementauthorization of the work should be required on the work permit. Second levelmanagement review is recommended for IDLH (> 300 ppm) work.

No tank, valve, line, flange, relief vent, pig access, etc. which may create an

H2S concentration of 10 ppm or greater in the employee's breathing zoneshall be opened without proper RPE (“G.1”). The H2S concentration in theprocess stream should be considered when determining the potential forexposure.

H2S procedures should always be employed if gas stream concentrationsexceed 300 ppm (volume) or 5 ppm (weight) in liquid streams regardless ofanticipated breathing zone levels.

Personal H2S instruments

Should be used by personnel not using RPE where there is a possibility thatthe breathing zone concentration may exceed 10 ppm, unless fixedmonitoring is effectively employed at the facility/location. These areas shouldbe described in the written H2S program.

Some areas may include:

a. Catwalks and inside of firewalls of sour tanksb. Sour crude tank batteries, well sites, and gas handling facilities



I14.7

c. Sour water stripper areas, amine units, sulfur plantsd. Tail gas (Beavon-Stretford) open reaction/regeneration tankse. Sour gas Compressors

If personal H2S monitors are issued to warn employees of H2S (as opposed tousing a gas test meter with readout to test for H2S concentration), thefacility/location should consider "alarm-only" monitors. Since there is no read-

out, employees will not have the tendency to further investigate the sourcewithout proper precautions or RPE.

Fixed-point H2S monitors:

Some considerations for applicability include, but are not limited to: Indoor,enclosed, or semi-enclosed process areas, compressor houses, etc.;

Near equipment with potential for failure, such as sour water pump seals;

Where required by regulation.

Signs and Postings

When the breathing zone concentration is 10-300 ppm, the following sign should beposted at employee access points.

DANGERHYDROGEN SULFIDE

POSITIVE PRESSURE RESPIRATORY PROTECTION REQUIRED

When the breathing zone concentration could exceed 300 ppm:

DANGERHYDROGEN SULFIDE

POSITIVE PRESSURE RESPIRATORY PROTECTION ANDSTANDBY PERSON REQUIRED

If posting at the base of a tank, add the words "WHEN TANK OPENED" after theword "REQUIRED."

Tank battery access roads (particularly public access) should be posted with a sign:

DANGERPOISON GAS

Signs already in place conveying the same meaning need not be replaced.

Windsocks should be installed in easily visible locations where breathing zoneconcentrations (including tank hatch concentrations) may exceed 100 ppm.



I14.8

Emergency Procedures

The facility/location should have an Emergency Action Plan and procedures whichaddress H2S, including, at minimum:

Evacuation:

Evacuate personnel in a direction upwind or crosswind from the source to adesignated safe refuge;

Several selected areas of safe refuge for variable wind conditions;

Consider appropriate ventilation system scrubbers, air intake alarms,automatic shutdown of air handlers, and RPE systems to protect thosepersonnel who can not evacuate the area, such as control room personnel.

Alarm Investigation

All alarms should be treated as an actual gas release.

Respiratory protection shall be worn when investigating alarms, and actual orpotential releases.

First Aid and Rescue

DO NOT INITIATE ANY RESCUE WITHOUT WEARING SCBA.

DO NOT ATEMPT ANY RESCUE IF YOU ARE NOT AUTHORIZED ANDTRAINED

A single standby person should not initiate rescue until radio contact hasbeen made and it is known that help is on the way.

After donning SCBA and calling for help, remove the victim from the area ofexposure.

First-Aid and medical treatment instructions: After removing the victim to asafe location, clear the airway, begin mouth to mouth resuscitation. Thevictim will die from lack of oxygen unless resuscitation is promptly andsuccessfully administered.

Administer oxygen if available and trained or qualified to do so.

Seek immediate medical attention.





Lead ProtectionPage: 1 of 15Original: 01/01/2001Revised: 01/01/2004

I15.1

Lead Protection

Purpose

The purpose of this program is to establish and implement practices and proceduresfor protecting the health of Moreno Group LLC and Subsidiaries employees whomay be exposed to lead on the job. This program also establishes methods forcomplying with the OSHA Construction Industry Lead Standard, 29 CFR 1926.62.

Scope

The scope of this program applies to all Moreno Group LLC and Subsidiariesprojects and employees involved with lead paint removal projects and activities.

This program also applies to all subcontractors, working under the direct control ofMoreno Group LLC and Subsidiaries, involved with lead-based paint removalprojects and activities. Subcontractors must provide all manpower, supplies,equipment, training, and medical examination and testing necessary to comply withthis program.

Responsibilities

The Facility Manager/Offshore Manager/Yard Foreman or Designee isresponsible for:

Informing the SH&E Department of any upcoming project that may have thepotential of containing lead

Inform any subcontractors that may be working on the project that the projectcontains lead.

Ensure that subcontractors understand and comply with this policy as well asthe Lead Employee Project Specific Protection Plan.


Understanding and complying with this policy/ procedure as well as the LeadEmployee Project Specific Lead Protection Program.

Designating employees for the project and ensuring that those employees allgo to the Human Resources Department to get an authorization to go to theMedical Review Officer and receive initial blood lead levels prior to performingany work on the project



I15.2

Coordinate with the SH&E Department to see if all designated employeeshave received lead training and or up to date. If training is needed coordinatewith the Safety Department date and time for which training will take place.



Performing with the safety department the Lead Job Checklist and performingthis checklist throughout the project.

Coordinating with the Human Resources Department at the end of the projector when any employee is removed from the project that those employees allgo to the Medical Review Officer and receive blood lead levels.


Coordinating paint samples to have analyzed to determine if project containslead.

Informing Facility Manager/Offshore Manager/Yard Foreman or designee ofthe outcome of the sample analysis.

Perform any lead training, any respiratory training and fit testing for allemployees that need this training

Coordinating and performing any air monitoring which may be required.

Developing Lead Employee Project Specific Protection Plan.


Authorizing all employees to go to the Medical Review Officer and receive aninitial blood lead level as well as a respiratory analysis if one is needed.


Informing the safety department of any employee that is unsuitable to work onthe project due to high lead levels or medical conditions that do not allowemployee to wear a respirator.

Authorizing all employees to return to Medical Review Officer for blood leadlevels once project is complete or if employee has been removed fromproject.



I15.3


Understanding and complying with this policy/procedure as well as the LeadEmployee Project Specific Protection Plan.

Reporting to his immediate supervisor any problem, which may arise, or anysymptoms of lead exposure.

Definitions

Lead - The word “lead” when used in this program means elemental lead, allinorganic lead compounds. Lead is a heavy metal at room temperature andpressure and is a basic chemical element. It can combine with various othersubstances to form lead compounds.

Lead-based Paint - Although there is no federal guideline or definition for lead-basedpaint, it is generally accepted to be dry paint that contains 0.06% (600 ppm) orgreater lead by weight. A more restrictive limit for lead based paint may be defined

for specific projects by the project sponsor, the project owner, or federal, state orlocal regulation.

g/m - Micrograms per cubic meter of air. Common units for reporting airborneconcentration of lead.

8-hour TWA Concentration - 8-hour Time-Weighted Average concentrations forairborne contaminants - common units for reporting daily airborne lead exposures.This is the lead exposure received per day expressed as a constant exposure foreight (8) hours at a steady state concentration.

g/100g - Micrograms per 100 grams of whole blood. Common units for reportingconcentrations of lead in blood samples. Also reported as g/dl (micrograms perdeciliter) of whole blood.


HEPA filter - High Efficiency Particular Air filter - Filters that remove 99.97% of allparticulate 0.3 microns or greater in diameter.

Competent Person - One who is capable of identifying existing and predictable leadhazards in the surroundings or working condition and who has authorization to takeprompt corrective measures to eliminate them.

Action Level

The Action Level means employee exposure, without regard to the use of

respirators, to an airborne concentration of lead of thirty (30) g/m , calculated as an8-hour TWA.



I15.4

Whenever workers’ airborne lead exposures exceed or are expected to exceed the Action Level, the following will be implemented for the work project:

Competent person



Airborne lead exposure monitoring

Record keeping

The Action Level may be exceeded where lead-containing coating or paint arepresent and the following activities are performed: abrasive blasting, cleanup ofexpendable abrasives, containment movement and removal, spray painting with leadpaint, manual scraping, manual sanding, power tool cleaning with and without dustcollection systems and heat gun applications. Some non-painting related activities

include: manual demolition of structures, welding, cutting, torch burning, rivetbusting, installation, removal, or demolition of lead containing materials, lead burningand lead contamination/emergency cleanup operations.


The Permissible Exposure Limit (PEL) for airborne lead exposure is fifty (50) g/m ,as an 8-hour TWA concentration. This is the maximum 8-hour averageconcentration of lead that an employee may be exposed to during each work day.

No employee will be exposed to airborne lead above the PEL without proper

protection.

The following methods will be used, as feasible and effective, for maintainingairborne lead exposures below the PEL:


Warning signs




Housekeeping



I15.5

During the period that respirators are worn, the protection factor of the specificrespirator may be used to determine employees’ exposure to airborne lead and toachieve compliance with the PEL. The protection factors listed in the respiratorselection table of Moreno Group LLC and Subsidiaries Respiratory ProtectionProgram. For example:

Measured airborne lead concentrations at the workers breathing zone: 300

g/m ,8-hour TWA

Half-mask, air-purifying, negative pressure respirator with HEPA filters wornall day: protection factor of 10

Employees daily lead exposure: 30 g/m

Competent Person

All work activities where employee airborne lead exposures may exceed the ActionLevel will include a competent person in both the planning and performing stages of

projects involving lead exposure.

The competent person will be a person with training and experience in conducting jobs involving lead exposure. The competent person will have the capability ofidentifying hazards and the authority to take immediate action to eliminate them.

The competent person will be at the work site at all times while lead exposureactivities are in progress. They may have other job duties, but must be able tomonitor work continuously for hazards or deficiencies, and the authority to takeimmediate corrective action.

Employee Information and Training

All employees who work on projects where airborne lead exposures are known to orexpected to be at or above the Action Level will be provided information and trainingon the hazards of lead and measures for controlling these hazards and protectinghealth.

Employees will receive initial comprehensive lead training before performing workthat may involve airborne lead exposure. This training will be repeated annually as arefresher course.

The content of lead training will include:

The specific nature of activities or operations that may result in airborne leadexposure above the Action Level

The health effects and risks of lead exposure

OSHA standards and guidelines for lead exposure




I15.6

Work practices for controlling lead exposure, including information, warningsigns, housekeeping, protective clothing and proper hygiene facilities andpractices

Respiratory protection for controlling lead exposure, including fit testing

Methods for monitoring airborne lead concentrations and exposures


Precautions for female employees who are pregnant.

Instructions to employees that chelating agents should not be used to removelead from their bodies

When conducting lead exposure activities on a multi-employer work site, MorenoGroup LLC and Subsidiaries will notify other employers of the nature of the lead

exposure system in effect, and the potential need to take measures to protect theiremployees. Notification to other employers will contain the following: NOTICE -MORENO GROUP LLC AND SUBSIDIARIES IS PERFORMING ACTIVITIES ATTHIS JOB SITE THAT MAY CREATE AIRBORNE LEAD DUST. ALLCONTRACTORS AT THIS JOB SITE SHALL REMAIN CLEAR OF ANY LEADEXPOSURE AREA. ACCESS INTO LEAD EXPOSURE AREA IS CONTROLLEDBY THE MORENO GROUP LLC AND SUBSIDIARIES JOB FOREMAN. ONLYTRAINED, QUALIFIED WORKERS ARE PERMITTED TO ENTER LEADEXPOSURE AREAS AND MUST WEAR RESPIRATORS AND PROTECTIVECLOTHING.


All employees who may be exposed to lead above the Action Level or who may berequired to wear a respirator will be provided initial and periodic medicalexaminations.

All employees who may be exposed to lead above the Action Level will be providedwith initial and periodic biological monitoring in the form of blood sampling andanalysis of lead and zinc protoporphyrin.

All employees who are temporarily removed from lead exposure due to elevated

blood lead levels or at the recommendation of a physician may be reassigned other job duties at the site that do not involve exposure to lead above the Action Level.

The specific components, requirements, and frequencies of medical examination,blood lead test, and medical removal protection benefits are provided in MorenoGroup LLC and Subsidiaries Medical Surveillance / Examination Program for LeadExposure and Respirator Use (see Attachment 1)



I15.7

Warning Signs

Warning signs will be posted in the work area around activities where leadexposures may exceed the Permissible Exposure Limit. The work area can bedemarcated by ropes, tape, walls, or containments.

Signs will be posted at every accessible side of the work area. These signs will be

easily visible from a distance so that employee can read the sign and takenecessary protective measures before entering the work area. Signs will read asfollows: WARNING, LEAD WORK AREA, POISON, NO SMOKING OR EATING.



Eating, drinking, smoking, and chewing is prohibited in work areas and any areawhere lead exposure may exceed the Permissible Exposure Limit.

Containments


The purpose of containments is to restrict or prevent the spread of lead-containingdust or debris to surrounding areas or the environment. While the proper use ofcontainments can help protect the public and the environment, they generally causea significant increase in airborne lead concentrations in the work area.Containments may increase the potential for higher employee lead exposures.Therefore, the use of well designed exhaust ventilation and the use of more

protective respirators may be necessary to properly protect workers.






Personal Hygiene Facilities and Practices

Clean change areas will be provided for all projects where employee airborne leadexposures may exceed the Permissible Exposure Limit. These clean change areaswill be equipped with storage facilities for street clothing and a separate area for theremoval and storage of lead-contaminated clothing and equipment. This changearea will be designed and used so that contamination of street clothing does not



I15.8

occur. Airborne lead exposures in the change area will be maintained below the Action Level.

Shower facilities will be provided for all projects where feasible when employee leadexposures exceed the Permissible Exposure Limit. Shower facilities will comply withthe OSHA Standard, 29 CFR 1926.51, Sanitation. All employee whose airbornelead exposures may exceed the Permissible Exposure Limit will shower or at a

minimum wash their hands and face at the end of each work shift. Employeesrequired to shower will not leave the workplace wearing any clothing worn whileperforming lead exposure activities.

Clean lunch areas will be provided for all projects where employee airborne leadexposures may exceed the Permissible Exposure Limit. Employee will remove orclean their protective clothing and wash their hands and face before eating, drinkingor smoking. Airborne lead exposures in the lunch area will be maintained below the

Action Level.

An adequate number of clean lavatory and hand washing facilities will be provided.

These will comply with the OSHA Standard, 29 CFR 1926.51, Sanitation.

Where required by federal, state, or local regulation; the project sponsor; or theproject owner; decontamination units will be constructed and used as specified.These generally are maintained under negative pressure and contain clean changerooms, showers and dirty equipment rooms.

Protective Clothing and Equipment

Protective clothing and equipment will be worn by all employees whose airbornelead exposures may exceed the Permissible Exposure Limit. Protective clothing and

equipment will be provided at no cost to the employee.

Protective clothing will include washable or disposable full body coveralls. Otherprotective equipment will include faceshields, hats, gloves, shoes or disposable shoecovers, eye protection, and hearing protection as appropriate.

Disposable protective clothing will be used for no more than one (1) work day. Theywill be disposed of as lead-contaminated waste.

Reusable coverall will be collected at the end of each work day in closed containers.Contaminated clothing will be cleaned by authorized laundries according to all

applicable federal, state, or local regulations pertaining to lead-contaminated laundryand water discharge. All containers of lead-contaminated laundry will be labeled asfollows: CAUTION: CLOTHING CONTAMINATED WITH LEAD. DO NOTREMOVE DUST BY BLOWING OR SHAKING. DISPOSE OF LEADCONTAMINATED WASH WATER IN ACCORDANCE WITH APPLICABLE LOCAL,STATE OR FEDERAL REGULATIONS.

Reusable protective clothing (coveralls) will be laundered at least weekly, and cleancoveralls provided daily to employees whose exposure levels without regard to a

respirator are over 200 g/m3 of lead as an 8-hour TWA.



I15.9

Protective clothing and equipment will be removed in the contaminated section ofthe change area and will not be worn into any clean areas not contaminated withlead.

Protective clothing and equipment will be worn by all employees performing thefollowing activities where lead-containing coatings or paint are present unless

exposure monitoring proves otherwise: When abrasive blasting, cleanup ofexpendable abrasives, abrasive blasting enclosure construction, movement andremoval, power tool cleaning with and without dust collection systems, manualscraping, manual sanding, manual demolition of structures, heat gun applications,welding, cutting, torch burning, chemical stripping and leadcontamination/emergency clean-up activities.


Respiratory protection will be used in combination with engineering controls andwork practices to maintain employee airborne lead exposures below the Permissible

Exposure Limit.

Respirators will be worn by all employees, other contractors, inspectors, orobservers who may be exposed to airborne lead at or above the PermissibleExposure Limit.

The selection, use, maintenance, and inspection of respirators will be according toMoreno Group LLC and Subsidiaries Respiratory Protection Program. Qualificationsfor respirator users are also contained in this program. Select respirators from thetypes listed below in Table 1. Any respirator chosen must be approved by the MineSafety and Health Administration (MSMA) or the National Institute for Occupational

Safety and Health (NIOSH).

Table 1 – Respiratory Protection for Lead Aerosols

Airborne Concentration of Lead orCondition of Use

Respirator Required

Not in excess of 500 ug/m ½ mask air purifying respirator withHEPA filters2,3

½ mask supplied air respirator operatedin demand (negative pressure mode.)

Not in excess of 1,250 ug/m Loose fitting hood or helmet powered

air-purifying respirator with HEPAfilters.

3

Hood or helmet supplied air respiratoroperated in continuous flow mode thatis type CE abrasive blasting respiratorsoperated in continuous flow mode.

Not in excess of 2,500 ug/m Full facepiece air purifying respiratorwith HEPA3

Tight fitting powered air-purifyingrespirator with HEPA



I15.10

Full facepiece supplied air respiratoroperated in demand mode.

½ mask or full facepiece supplied airrespirator operated in a continuous-flowmode.

Full facepiece self-contained breathingapparatus (SCBA) operated in demand

mode.

Airborne Concentration of Lead orCondition of Use

Respirator Required

Not in excess of 50,000 ug/m3 ½ mask supplied air respirator operatedin pressure demand or other positive-pressure mode.

Not in excess of 100,000 ug/m Full facepiece supplied air respiratoroperated in pressure demand or otherpositive pressure mode, that is, type CEabrasive blasting respirators operated in

a positive-pressure mode.Greater than 100,000 ug/m

, known

concentration, or fire fighting Full facepiece SCBA operated in

pressure demand or other positivepressure mode.

1 Respirators specified for higher concentrations can be used at lower concentrationsof lead.

2Full facepiece is required if the lead aerosols cause eye or skin irritation at the useconcentration.

3 A high efficiency particulate filter (HEPA) means a filter that is 99.97 percentefficient against particles of 0.3 microns size or larger.

Exposure Monitoring

For each work project, personal air samples will be collected to determine airbornelead exposures to employees performing tasks involving lead exposure. Full shift (atleast 7 hours) air samples will be collected for each job classification in each workarea. The air samples will be taken for the shift with the highest expected exposurelevel. Moreno Group LLC and Subsidiaries will implement employee protectivemeasures until results of the employee exposure assessment are received. Thecompetent person will be responsible to ensure that exposure monitoring isperformed.

Where initial monitoring indicates that lead exposures are below the Action Level,and where work activities and conditions will remain the same as at the time of initialsampling, additional monitoring need not be repeated for that work project. A writtenrecord of the air monitoring data will be kept at the job site.

Where initial monitoring indicates that lead exposures are at or above the ActionLevel but at or below the PEL, additional representative exposure monitoring will beconducted at least once every six (6) months for that work project. Where initialmonitoring indicates that lead exposures are above the PEL, additionalrepresentative exposure monitoring will be conducted at least once every three (3)



I15.11

months. Representative monitoring should be conducted during the beginning ofeach different phase of the project or when changes occur, such as an increase inthe number of blasters in the area, to determine range or exposures for lead removaland clean-up activities.

All air samples will be collected and analyzed according to NIOSH 7082 Method orequivalent. All samples will be analyzed by laboratories accredited under the

Laboratory Accreditation Program of the American Industrial Hygiene Association formetals analysis.


Initial exposure monitoring may not be required when previously collected data hasconclusively determined that current job condition exposure levels will be less thanthe Action Level.

Housekeeping

Accumulations of lead-containing dust and debris generated by work activities will beremoved and cleaned daily.

All persons doing the clean-up will be trained in performing lead activities, respiratorqualified, and participate in the medical surveillance program. Respirators andprotective clothing will be worn by all persons doing the cleanup unless exposuremonitoring proves otherwise.


All lead-containing dust and debris will be collected into sealed containers. Thewaste will be tested to determine whether it will be disposed as hazardous or non-hazardous waste.

Employees will not be permitted to remove lead-containing dust from protectiveclothing or equipment by blowing, shaking, or by any other means which disperseslead in the air.

Project Specific Requirements

The specific worker lead protection requirements for each lead-removal project will

be determined by Moreno Group LLC and Subsidiaries, the project sponsor, and theproject owner. The job specific requirements will be placed in Attachment 2 - LeadPaint Removal Project Specific Requirements. Enough detail will be provided as toaccurately outline the job specific requirements. This attachment will be posted atthe job site and maintained with the work records of the project.

Recordkeeping

All records relating to training, medical examinations, blood lead monitoring,exposure monitoring, and project specific requirements will be maintained by



I15.12

Moreno Group LLC and Subsidiaries, for the employees length of employment plus30 years.

Other Relevant Information





I15.13

Attachment 1





I15.13.a.1

Medical Surveillance/Examination Program ForLead Exposure And Respirator Use

Purpose

To establish and implement a program that meets, in substance, the medicalsurveillance requirements of the OSHA Construction Industry Lead Standard, 29CFR 1926.62 and by the OSHA Respiratory Protection Standard, 29 CFR 1926.103.

Scope

This program applies to all Moreno Group LLC and Subsidiaries, employees whomay be exposed to lead in the course of their work and who are required to wearrespirators.

This program also applies to all subcontractors working under the direct control ofMoreno Group LLC and Subsidiaries Subcontractors must provide all manpower,medical examination and testing, and other resources necessary to comply with this

program.

This program combines the medical surveillance and examination requirements ofthe OSHA Construction Industry Lead Standard and the Respiratory ProtectionStandard into one unified program.

Requirements

All medical examination will be conducted by or under the supervision of a licensedphysician.

All medical examination will be provided at no cost to the employee and at areasonable time and place.

Moreno Group LLC and Subsidiaries will provide the following information to theexamining physician:

A copy of the OSHA Construction Lead Standard, 29 CFR 1926.62, includingall Appendices.

A description of the employee’s duties as they relate to lead exposure.

The employee’s representative or anticipated exposure level to lead and anyother toxic substance they may be exposed to at work.

A description of any protective clothing and respirators to be used.

Information from previous examination(s) performed for lead exposureor respirator use, including past blood lead results, including all priorwritten medical opinions concerning the employee, that may be in thepossession or control of Moreno Group LLC and Subsidiaries



I15.13.a.2

Medical examinations provided by other employers or groups may be accepted byMoreno Group LLC and Subsidiaries provided the following conditions are met:

The employee agrees to release all medical record of these examinations andtests to Moreno Group LLC and Subsidiaries or their medical examinationprovider.

All medical examinations and tests specified in this program were performed.

The physician’s medical opinion is reviewed by Moreno Group LLC andSubsidiaries medical provider or an additional medical opinion is provided.

Records of medical examinations and tests are confidential medical records. Access to these records by employees, their designated representatives, or otherparties will be according to 29 CFR 1926.63, Access to Employee Exposure andMedical Records.


All medical surveillance will be performed by or under the supervision of a licensedphysician.

Initial medical surveillance consisting of blood sampling and analysis for lead andzinc protoporphyrin (ZPP) will be provided to all employees exposed at any time (1day) above the action level. For each employee who may be exposed at or abovethe action level for more than thirty (30) days in any consecutive 12 months,biological monitoring for blood lead and ZPP will be provided at least every two (2)months for the first six (6) months and every six (6) months thereafter.

Respirator Requirements. Respirators will be provided whenever an employee’sexposure to lead exceeds the Permissible Exposure Level, in work situations inwhich engineering controls and work practices are not sufficient to reduce exposuresto or below the PEL, and whenever an employee requests a respirator.

Respirators will be selected from those approved for protection against lead dust,fume, and by the Mine Safety and Health Administration and the National Institutefor Occupational Safety and Health.

Respirators or combinations of respirators that will provide adequate protection to

the employee will be chosen by the competent person based on OSHAConstruction Industry Lead Standard 29 CFR 1926.62 Table 1: RespiratoryProtection for Lead Aerosols.

Each employee will be required to wear a half-mask, negative pressure respiratorwill be qualitatively fit tested every six (6) months on the specific respirator that willbe used. Fit test procedures specified in the OSHA Construction Industry LeadStandard, 29 CFR 1926.62, Appendix D will be followed. Full facepiece negativepressure respirator will be quantitatively fit tested in accordance with Appendix D ofthe standard.



I15.13.a.3

Medical Exam - Requirements for respirator users will include examinations andtests as deemed necessary by the examining physician to ensure the ability to wearand utilize respiratory protection. These tests will be provided annually toemployees assigned to wear a respirator.

Medical Examination for Lead Exposure

Frequency of Medial Examinations - Medical examinations will be provided at leastannually for each employee for whom a blood sampling test conducted at anytimeduring the preceding twelve (12) months indicated a blood lead level at or above

forty (40) g/dl; as soon as possible, upon notification by an employee either that theemployee has developed signs or symptoms commonly associated with leadintoxication; that the employee desires medical advice concerning the effect ofcurrent or past exposure to lead on the emp loyee’s ability to procreate a healthychild, the employee is pregnant, or that the employee has demonstrated difficulty inbreathing during a respirator fit test or during use; and as medically appropriate foreach employee either removed from exposure to lead due to a risk of sustaining

material impairment to health, or otherwise limited pursuant to a final medicaldetermination.

Content of Medical Examinations - Medical examination will include, as a minimum:

A detailed work and medical history, with particular attention to past leadexposure (occupation and non-occupational), personal habits (smoking,hygiene), reproductive history and plans, and past problems involving thecardiovascular, nervous or digestive systems, liver, kidneys, blood, or lungs.

A thorough physical examination with particular attention to the teeth, gums,

heart, lungs, digestive system, liver, kidneys, blood, and nervous system.

Pulmonary function test of forced vital capacity and forced expiratory volume.

Tests for blood pressure and resting heart rate.

Blood sample and analysis for blood lead level, hemoglobin and hematocritdeterminations, red cell indices, peripheral smear morphology, zincprotoporphyrin, blood urea nitrogen, and serum creatinine.

Routine urinalysis with microscopic examination.

Other examinations or tests deemed necessary by the examining physician

Physician’s Written Opinion - Medical Examinations

For each examination, Moreno Group LLC and Subsidiaries will obtain a writtenopinion from the examining physician that contains the following:



I15.13.a.4

Whether the employee has a detected medical condition that places them atan increased risk or health effects from exposure to lead

Any special protective measures to be provided to the employee or limitationsto be placed on the employee’s exposure to lead

Whether the employee is medically qualified to wear a respirator and any

limitations of use, especially concerning negative pressure respirators

A statement that the employee has been informed by the physician of theresults of the medical examination, blood tests, urine tests, and of anymedical conditions that may result from lead exposure

Moreno Group LLC and Subsidiaries will provide a copy of the examination and testresults and the physician’s written opinion to the employee immediately after itsreceipt.

Medical records of examinations and tests will be retained by Moreno Group LLC

and Subsidiaries for the employee’s length of employment plus 30 years.

Blood Lead Monitoring

Along with the initial and annual medical examinations have been addressed,Moreno Group LLC and Subsidiaries will provide periodic blood sampling andanalysis for lead and zinc protoporphyrin levels to each employee exposed to leadabove the Action Level.

Blood lead analysis will be performed by laboratories licensed by the US Center forDisease Control (CDC) or which has received a satisfactory grade in blood lead

proficiency testing from the CDC in the prior twelve (12) months.

Periodic blood lead monitoring will be provided every two (2) months for the first six(6) months and every six (6) months thereafter to exposed employees during lead-paint removal projects, or more often if required.

Employees with blood lead levels above 40 g/dl but below 50 g/dl will continue tobe provided blood lead tests every two (2) months, until two (2) consecutive blood

lead levels are below 40 g/dl.

Employees who are identified with a blood lead level at or above fifty (50) g/dl will

be provided with a blood lead test within two (2) weeks. If the blood lead levelremains at or above fifty (50) g/dl, blood lead testing will be provided once a month,

until two (2) consecutive blood lead levels are less that forty (40) g/dl.

Employee will be informed in writing of their blood test results within five (5) workingdays after receiving results. Employees will also be informed in writing that theymust be temporarily removed from lead exposure jobs and may be reassigned toother duties at the site not involving lead exposure if their blood lead levels are at or

above fifty (50) g/dl. Anytime an employee’s blood lead level exceeds fifty (50)

g/dl, another blood lead test will be taken within two (2) weeks from the receipt date



I15.13.a.5

of the initial results. If both test results exceed fifty (50) g/dl the employee will betemporarily removed and successive blood lead level tests will be made on amonthly basis during the employee’s removal.

Medical Removal Program

Employees with blood lead levels at or greater that fifty (50) g/dl and as described

in Blood Level Monitoring will be temporarily removed from any work where airbornelead exposure may exceed the Action Level. Workers will be removed from leadexposures until two (2) consecutive blood lead samples show results below forty

(40) g/dl.

Employees determined, by a physician, to be at increased risk of health impairmentfrom exposure to lead will also be temporarily removed from any work whereairborne lead exposure may exceed the Action Level. Moreno Group LLC andSubsidiaries will implement and act consistent with the physician’s recommendationsfor any special protective measures or lead exposure limitations for the employees.

Any employee temporarily removed from lead exposure activities due to elevatedblood lead levels or a physician’s r ecommendations will be provided blood lead testevery four (4) weeks until two (2) consecutive tests indicate that blood lead levels

are at or below forty (40) g/dl.

Employees temporarily removed from lead exposure activities may be assigned toother duties on-site that do not involve lead exposure above the Action Level.

Employees temporarily removed from lead exposure activities may return to theirnormal lead exposure duties after two (2) consecutive blood lead tests indicate that

blood lead levels are at or below forty (40) g/dl.





I15.14

Attachment 2





I15.14.a.1

Moreno Group LLC and Subsidiaries Lead Paint RemovalProject Specific Requirements

PROJECT

LOCATION

DATES

ON-SITE COMPETENT PERSON

DESCRIPTION OF EACH ACTIVITY EMITTING LEAD

EQUIPMENT USED

WORKER TRAINING REQUIRED

MEDICAL SURVEILLANCE REQUIRED

MECHANICAL VENTILATION EFFECTIVENESS

LEAD WORK AREA LOCATIONS

WARNING SIGNS NEEDED

HYGIENE FACILITIES

EXPOSURE ASSESSMENT CONDUCTED

EXPOSURE ASSESSMENT RESULTS

ADEQUATE RESPIRATORY PROTECTION

RESPIRATORY FIT TEST REQUIRED

RESPIRATORY FIT TEST PERFORMED

PROTECTIVE CLOTHING

HEPA VACUUMS NEEDED



I15.14.a.2

EMPLOYEE JOB RESPONSIBILITIES

OPERATING PROCEDURES FOR WORKER DECONTAMINATION, DISPOSAL OF

PROTECTIVE CLOTHING, CLEANING EQUIPMENT, ETC...

JOB ROTATION SCHEDULE

EMPLOYEE NAME(S)

JOB DURATION AND EXPOSURE LEVELS

OTHER LEAD REDUCTION ADMINISTRATIVE CONTROLS



I15.14.a.3

ALL CONTRACTORS ON SITE INFORMED OF POTENTIAL LEAD EXPOSURE

A DESCRIPTION OF THE SPECIFIC MEANS THAT WILL BE EMPLOYED TO

ACHIEVE OSHA COMPLIANCE. IF ENGINEERING CONTROLS ARE REQUIRED,

LIST THE ENGINEERING PLANS AND STUDIES USED TO DETERMINE THE

METHODS SELECTED FOR CONTROLLING EXPOSURE(S) TO LEAD

LIST THE TECHNOLOGY CONSIDERED IN MEETING THE PEL

SCHEDULE FOR IMPLEMENTATION OF THE COMPLIANCE PROGRAM

CONSTRUCTION CONTRACTS/PURCHASE ORDERS







NORM ProgramPage 1 of 42Original: 03/01/2006Revised: 09/08/2009

I16.1

NORM Program

Purpose

The purpose of this program is to establish and implement practices and proceduresfor protecting the health of Moreno Group LLC and Subsidiaries employees whomay be exposed to harmful levels of Naturally Occurring Radioactive Material(ionizing radiation) encountered on the job. This program also establishes methodscomplying with the OSHA construction industry radiation standard, 29 CFR1910.1096 and LAC 33:XV.

Scope

The scope of this program applies to Moreno Group LLC and Subsidiaries

Environmental Divisions’ projects and employees involved with the maintenance,cleaning, decontamination, land remediation, transportation, and handling of NORMand TENORM contaminated material including but not limited to equipment,tubulars, tanks, vessels and facilities. Also any land classified as NORM andTENORM contaminated according to this program.

Responsibilities

The Facility Manager/Offshore Manager or Designee is responsible for:

Informing the SH&E Department and corporate RSO of any upcoming project

that may have the potential or has been clarified to contain NORM material oraction level NORM readings.

Purchase any radiological supplies as necessary and in accordance withMoreno Group LLC and Subsidiaries’ purchasing procedure.

Inform any subcontractors that may be working on the project that the projectcontains NORM and at what levels.

Ensure that subcontractors understand and comply with this policy as well asthe NORM employee project specific protection plan.

The Corporate Radiation Safety Officer (RSO) is responsible for:

The Corporate Radiation Safety Officer shall have overall responsibility andcharge of radiological conditions during activities performed under thislicense. The corporate RSO may designate other RSOs to act in his absenceat the Moreno Group LLC and Subsidiaries NORM temporary jobsites. Theseindividuals, while acting in the capacity of an RSO, will be called NORM



I16.2

Supervisors (NS). RSOs will coordinate activities with Work Supervisors,employees, and contract personnel to ensure that all work can beaccomplished in a safe and radiologically sound manner. RSO/NSresponsibilities are as follows:

The RSO will have familiarity with the Louisiana radiation ProtectionRegulations, company requirements and procedures, general training in basic

radionuclide handling techniques and safety practices, and on-the-jobexperience actually handling comparable materials. The position requires aminimum of 40 hours of instruction in radiation safety and health physics thatis recognized by the state of Louisiana and 3 months of hands-on practicalNORM supervisory field experience, or 6 months of experience handlingHazardous Materials.

The RSO/NS will maintain control of NORM operations to ensure properradiological health and safety procedures are in effect. The RSO/NS, as wellas anyone in the work area, shall have the specific authority to stopoperations at any time an unsafe or environmentally hazardous condition

exists. He may purchase radiological supplies as necessary and inaccordance with Moreno Group LLC and Subsidiaries’ purchasingprocedures. And, he may promulgate changes to Moreno Group LLC andSubsidiaries’ NORM Policies and Procedures as necessary to maintainradiological safety controls.

Preparation of a Radiation Work Permit (RWP) outlining radiologicalconditions and precautions to be taken during work activities. The RWP shallbe maintained available for review by all employees and contractors. TheRSO/NS will ensure that all employees sign the RWP prior to the start of workacknowledging their understanding of and responsibility to comply with the

requirements of the RWP.

The RSO/NS is responsible for all employees being properly informed andtrained regarding radiological safety issues. At a minimum, employees shallreceive a 4 hours of training that meets the applicable regulations. Topicsshall include, but are not limited to: radiation safety and work procedures foremployees and contractors; health physics precautions; contaminationcontrol; and, other radiological conditions outlined in this license and theLouisiana Radiation Regulations (LRR).

Ensure that equipment used, areas where NORM is handled and stored, and

operations involving NORM are operated and maintained in a safe workingcondition and in compliance with the license, LRR, and other applicable rules,regulations, and orders.

Conduct baseline, release, dose rate and radiological surveys of equipment,lands, jobsite, and personnel. Ensure proper decontamination of lands,equipment, and personnel who become contaminated with NORM.

Ensure that only those individuals properly trained in the safe handling ofNORM shall have access to controlled areas and that all applicable areas are



I16.3

properly posted in accordance with this license and LAC 33:XV. He will alsoensure that individuals frequenting Restricted Areas are provided personaldosimetry and adequate personal protective equipment to prevent NORMcontamination.

The RSO/NS is responsible for proper documentation of all safety meetings,training, surveys, and control.

In the event of an emergency such as fire, accident, or uncontrolled NORMrelease, the RSO/NS shall have authority to respond so as to minimize injuryto personnel or the environment. The corporate RSO shall be contactedimmediately.

Ensure that the requirements of this license, LAC 33:XV, 29 CFR, 10CFR,and other pertinent rules, regulations, and orders are properly met andimplemented.


Review the implementation of all safety requirements and procedures of allpersonnel working in the area.

Review personnel training and knowledge of their duties and responsibilities.

Review the availability of necessary safety, personal protective andenvironmental equipment and ensure that it is functioning and in good status.

Periodically inspect employee and contractor’s work habits to ensure that theyare working in a safety conscious manner.

Periodically inspect all equipment, plastic protective sheeting, storage areas,containers, and other jobsite materials to ensure that they are properlymaintained in accordance with the applicable provisions of this license andthat NORM or other contaminants do not contaminate equipment, personnel,or the equipment.


Qualifications are to include instructions in radiation safety practicesappropriate for operating procedures, knowledge of radiation regulations, and

on-the-job experience handling comparable materials. This individual willhave a minimum of 16 hours of instruction in radiation safety or 8 hours ofinstruction in radiation safety and 40 hours of Hazardous Material safetyinstruction. In addition, this individual will have a minimum of 3 months ofexperience performing NORM decontamination procedures or 6 months ofexperience handling Hazardous Materials. At a minimum, annual refreshertraining will be required.



I16.4

Supervise all working personnel and all work activities taking place at the jobsite.

Conduct safety meeting, at a minimum of the beginning of each job or whenadditional (or new) personnel become necessary to perform work activities, toinform employees and contractors of safety concerns and procedures prior tothe start of work.

Perform pre-job and daily/continual inspections of work site, equipment andpersonnel work habits to ensure compliance with work plans, safetystandards and procedures, license specifications, and the LRR are beingfollowed. The inspections shall be documented on the Moreno Group LLCand Subsidiaries NORM pre-job checklist and NORM daily checklist. (see

Attachments 1 & 2)

Shut down operational activities in the event of any emergency which couldresult in injury to personnel or the environment.

All accidents and near misses are to be reported to the RSO and SH&EDepartment.

Assist in preparing the daily RWP and associated paperwork required by thislicense for the job and supply the RWP and associated paperwork to theRSO.

The Personnel Working in Restricted/ Radioactive Areas are responsible for:

Facilities and areas where NORM contaminated equipment or waste is being stored,utilized, or worked with shall be considered Radioactive Material Areas. A jobsite or

facility may be posted as a Radioactive Material Areas. A jobsite or facility may beposted as a Radioactive Material Area and contain within it one or more Restricted

Areas. A Restricted Area is any area where access is controlled by the licensee forpurposes of protection of individuals against undue risks from exposure to radiationand radioactive materials. The immediate area in which NORM activities are takingplace shall be considered Restricted Areas. Only individuals who have beenproperly trained and/or informed regarding the risks associated with NORM andproper handling of sources of radiation shall be allowed to work in Restricted Areas.

Individuals who perform the decontamination activities will have a minimum of8 hours of instruction in radiation safety. In addition, these individuals will

have a minimum of 8 hours of on-the-job training in performing NORMdecontamination procedures. At a minimum, annual refresher training will berequired.

Visitor and short term contractors (contractors working less than one full day)entering a Restricted Area will be briefed on the radiological health hazardscontained in the area, and made aware of precautions to be taken to minimizetheir exposure. The guidelines used for this briefing shall be those containedin LAC 33:XV.1012.



I16.5

Moreno Group LLC and Subsidiaries may employ contract labor for use inoperations involving NORM. These personnel, while not directly employed byMoreno Group LLC and Subsidiaries, will be treated as employees forpurposes of training, worker protection, and qualifications.

All personnel working in a Restricted Area will be required to read and signthe RWP prepared by the RSO/NS prior to commencing operations. The

RWP will describe authorized activities, personal protective equipmentrequired, and expected radiological and safety concerns. The RWP shall beavailable for review at all times.

All personnel working in the Radioactive Materials/Restricted Areas shallretain, at all times, “Stop Work Authority”. All employees will have not only the right, but also the responsibility to immediately stop any operation orevolution which may be dangerous to safety, health, equipment, and/or theenvironment.

All personnel entering Restricted Areas will be required, as a minimum, to

perform a hand and foot “frisk” immediately upon exiting the Restricted Area. A whole body frisk will be performed before leaving the work site and whenprotective clothing was worn in the Restricted Area. Any reading abovebackground when performing a personal frisk shall be removed and theperson refrisked.

All accidents or injury, no matter how minor, will be reported to the designatedWork Supervisor, RSO/NS, and/or SH&E Department

All personnel working in Restricted Areas at temporary jobsites will hold DailySH&E Meeting. Meetings will include, but not limited to, a review of all

personnel concerns and the scheduled operations for the week (or day, asappropriate), including any radiological hazards and concerns.

Requirements

HEALTH PHYSICS PROGRAM

BASIC PRACTICES AND GUIDELINES

Safety is of highest concern to Moreno Group LLC and Subsidiaries at all times, allpersonnel will follow safe work procedures to protect themselves and their fellow

employees from direct contact with NORM and to prevent the release of NORMcontamination into the environment. All employees and contractors shall use, to theextent practicable, procedures and engineering controls based upon sound radiationprotection principles to achieve occupational doses and public doses that are “as lowas reasonable achievable” (ALARA).



I16.6

PERSONNEL MONITORING

External Exposure

All personnel working in a Restricted Area shall be provided with personaldosimetry devices to monitor the individual’s received radiation dose.Dosimeters will consist of either a film badge or thermoluminescent

dosimeter.

- Each dosimeter will be assigned to a specific person and will beworn only by that person. It will bear the name of the individualand/or a number corresponding to the individual assigned. Whenthe employee reports to work, they will attach their assigneddosimetry to their outermost clothing above the waist (typically atthe neck or collar) and wear it throughout the work shift. Utmostcare will be taken to prevent dosimeter loss or damage. At the endof the shift, the employee will leave his dosimeter in a location withlow background radiation readings as designated by the RSO/NS.

- Dosimeters will be read at 3 month intervals by Landauer, or otherapproved suppliers.

- Taking into account that oilfield NORM does not normally exhibithigh radiation exposure levels, the annual occupational dose limit toindividual adults working under this license shall be that which isthe most limiting of: the total effective dose equivalent being equalto 0.05 Sv (5 rem); or, the sum of the deep dose equivalent and thecommitted dose equivalent to any individual organ or tissue otherthan the lens of the eye being equal to 0.5 Sv (50 rem). In any

other circumstances, those limits as specified in LAC 33:XV.410shall be utilized. Moreno Group LLC and Subsidiaries shall reducethe dose that an individual may be allowed to receive in the currentyear by the amount of occupational dose received while employedby any other person(s)

- A control dosimeter will be kept at a low background area at alltimes and be read at the same frequency as those dosimeters wornby employees.

- Records of readings of the dosimeters will be maintained

indefinitely at the facility housing the corporate RSO for his review.In addition, each individual’s records shall be maintained at theiremployment facility. Pursuant to LAC 33:XV.1013, results of themonitoring will be reported to each individual once results arereceived. This may be done at scheduled safety meetings with theindividual initiating the report acknowledging his receipt.

Visitors and short term contractors (working less than 12 hours) entering aRestricted Area will not be assigned dosimetry. These individuals will bebriefed, as described in LAC 33:XV.1012, on the radiological health hazards



I16.7

contained in the area and made aware of precautions to be taken to preventexposure to NORM.

Internal Exposure

No eating, drinking, smoking, or chewing will be allowed in Restricted Areas.Open wounds, sores, or cuts shall be reported to the RSO/NS and covered

with bandages and/or protective clothing prior to working in the Restricted Areas.

Significant intakes by ingestion or inhalation are presumed to occur only as aresult of accidents, poor procedure, inadvertence, or similar situations.Intakes will be evaluated and accounted for by techniques appropriate for theoccurrence as determined by the RSO/NS. Techniques measuring the intakeof radioactive material into the body may include bioassays (themeasurement of radioactivity excreted from the body), whole body counts (themeasurement of radioactivity in the body), or a combination thereof (per LAC33:XV.413) as necessary for timely detection and assessment of individual

intakes.

Baseline bioassays will not be required for workers involved in NORM activities dueto the large amount of NORM material which must be inhaled or ingested prior tobeing detectable using modern bioassay techniques. Documentation of thecircumstance and results of the bioassay shall be maintained by Moreno Group LLCand Subsidiaries for a minimum of five years. This documentation shall be madeavailable to LDEQ/RPD upon request.

Air Sampling

Every practicable effort shall be made to prevent or effectively reduceairborne NORM through proper equipment layout, design, and use ofengineering controls (i.e., wetting down NORM, ventilation systems, etc.) toan extent where respirator usage is not necessary.

When it is not practicable to apply process or other engineering controls tocontrol the concentrations of radioactive material in air to values below thosethat define an airborne radioactivity area, Moreno Group LLC andSubsidiaries shall, consistent with maintaining the total effective doseequivalent ALARA, increase monitoring and limit intakes by one or more ofthe following means:

- control of access;- limitation of exposure times;- use of respiratory protection equipment; or,- other controls.

Air sampling shall be conducted of the Restricted Area breathing zone of allworkers wearing respiratory protection at the direction of the RSO/NS andboundaries of airborne-causing evolutions to ensure that no airborne



I16.8

radionuclides are being released to the environment outside of the Restricted Area.

A low-volume air sampler equipped with a two inch filter holder and having avolumetric flow rate of at least 50 liters per minute shall be used to sample forairborne particulates. The air sampler shall be calibrated at least once every12 months and at each servicing.

The air will be drawn through a filter paper patch for a minimum of 20 minutesat a flow rate of 2 cfm to achieve proper volume. Longer run times to obtainlarger volumes will be allowed at the direction of the RSO/NS. Should anyemployee believe the instrument not be working properly, he should contactthe RSO/NS immediately.

Once air sampling is complete, the filter should be removed from the airsampler using tweezers to prevent cross-contamination and placed into aplastic bag for analysis. The bag should be labeled as a minimum with thedate the sample was taken, the start and stop times of the sample, air flow

rate, the sample location, and the printed initials of the person taking thesample.

A chain of custody form will be completed to accompany the sample to anapproved lab for analysis. LDEQ/RPD approved field analysis may be usedfor analysis of air samples. The results of all air samples will be documentedand retained for a minimum of five years at Moreno Group LLC andSubsidiaries

Moreno Group LLC and Subsidiaries shall monitor, to determine compliancewith LAC 33:XV.413, the occupational intake of radioactive material by and

assess the committed effective dose equivalent (CEDE) to adults likely toreceive, in one year, an intake in excess of 10 percent of the applicable ALI inTable I, Columns 1 and 2, of Appendix B.

PERSONAL PROTECTION

Protective Clothing

A minimum of coveralls, gloves, and shoe coverings or water resistant bootsshall be worn by all personnel who may come into contact with NORMcontaminated items when entering a Restricted Area. Direct skin contact with

NORM scale, sludge, solids, waters or materials will be avoided to the extentpossible. Any coveralls, gloves, or shoe coverings that become torn will beimmediately replaced.

Eye protection, such as safety glasses equipped with side shields and arespirator with a HEPA filter, should also be worn while working in Restricted

Areas.

Upon exiting an area of known or suspected NORM contamination, theworker will immediately proceed to a designated personal survey station in a



I16.9

low background area to perform a contamination frisk. Receptacles for usedcontaminated clothing will be made available at the exit area.

Respiratory Protection Procedures

This procedure delineates precautions and procedures for the use of respiratoryprotection equipment. Included in this procedure are items concerning

responsibilities, selection, fit testing, issuing, use, and maintenance of respirators.This procedure also addresses medical and bioassay evaluations.

Responsibilities

- It is the responsibility of the RSO to ensure that all aspects of thisprocedure are implemented and that all necessary materials toimplement this procedure are available. The RSO will ensure thatall potential wearers of respirators are properly trained andknowledgeable in the use of respirators; that respirators areproperly selected, issued, and used; and that respirator

maintenance is accomplished as provided by this procedure.

- All personnel wearing respirators are responsible to ensure thatthey are trained and knowledgeable in the use and maintenance ofrespirators. They should also ensure that they maintain themselvesqualified to wear and knowledgeable in the requirements to wearrespirators.

- It is the responsibility of all personnel to conduct themselves andtheir work assignments in a fashion so as to minimize, to thegreatest extent possible, the need for respiratory protection by

minimizing the amount of radioactive material disturbed into the air.

Materials

The materials necessary to implement this procedure vary. The following listserves as a guideline of items that may be kept on hand.

* NIOSH/MSHA Approved Respirators * Iodine Cleaning Solution* HEPA Respirator Filters * Respirator Repair Kit* Irritant Smoke Tubes * Air Sampler* Alcohol Wipes * Air Sampler Filters

* Face shields * Ziploc Bags (for A/S filters)* Respirator Qualification Sheet * Air Sample Data Log* HEPA Ventilation Unit

Operating With Respirators

- Philosophy

1) State and federal regulations state that respirators will beprescribed only when it is likely that a potential for the



I16.10

inhalation of ingestion of radioactive material exists at levelsabove those prescribed in LAC 33:XV, Chapter 4, AppendixB, or in oxygen deficient or toxic contaminant confined spaceentries. Respirators will not be a contamination controlmethod nor will they be used as a substitute for engineeringor process controls.

2) To the greatest extent practical, Moreno Group LLC andSubsidiaries will incorporate process or engineering controlsto limit the concentrations of radioactive materials in the airto levels below those specified in LAC 33:XV, Chapter 4,

Appendix B. These controls will also be used to assist inconfined space entries. These controls will include, but arenot limited to, system venting, system flushing, and the useof containments and HEPA ventilation systems.

3) Contaminated equipment or areas may be wiped down ordecontaminated to limit the potential for airborne radioactive

or toxic contaminants and the subsequent need forrespirators.

4) Good work practices will be incorporated so as to limit thepotential for airborne radioactive or toxic contaminants andthe subsequent need for respirators.

- Respirator Selection

1) When it becomes necessary for an employee or contractorentering a Restricted Area likely to contain airborne

contamination, that person shall wear a properly fittedNIOSH/MSHA approved respirator equipped with cartridgescapable of removing airborne radionuclides. The RSO/NSwill determine when respirators are justified for anymaintenance activity and shall use the followingconsiderations:

(a) the nature of the maintenance activity,

(b) the levels of contamination,

(c) the duration of the task,

(d) the use and effectiveness of process andengineering controls,

(e) the potential for decontamination, and

(f) any other hazards present such as hydrogen sulfide,ammonium’s, or oxygen deficiency.



I16.11

2) The RSO/NS will select the appropriate respirator to ensurethat the average concentration of radioactive materialinhaled during respirator use does not exceed theconcentrations specified in LAC 33:XV, Chapter 4, AppendixB. For confined space entries, respirators will be selectedfor oxygen deficient atmospheres and to limit toxic

contaminant exposure to levels below the PEL.

3) Half-face, full face negative pressure, supplied air, and self-contained air respirators may be used, depending on thetype and levels of contaminants encountered. For mostactivities, the half-face respirator will provide sufficientprotection. However, for environments which are oxygendeficient or contaminated with ammoniums, hydrocarbons,or hydrogen sulfide, the RSO may determine that the self-contained breathing respirator is warranted.

4) Respirators will only be used when necessary to limit thepotential ingestion or inhalation of radioactive materials ortoxic contaminants, or in oxygen deficient atmospheres.When it is necessary or warranted to use respirators, it isimportant to select a respirator that adequately protects theworker, but will not unnecessarily burden him. Negativepressure, full-face respirators and SCBA’s, in particular,increase worker fatigue and limits the time the worker maywork safely.

5) If the RSO/NS determines that respirators are warrantedbased on the Hazards/Exposures, the RSO/NS will specifythe type of respirator and for what work activity it is to beworn on the RWP and/or on the confined space entry permit.

- Fit Test

1) To ensure a given respirator provides the worker withprescribed protection, qualitative fit tests will be performedby every potential respirator wearer with any and everyrespirator type that might be worn (i.e., half-face, full-facenegative pressure, SCBA, etc.).

2) Qualitative fit tests will be performed initially and withrefresher training.

3) Qualitative fit tests are performed by donning the respirator,performing a negative pressure face seal test, and thetesting the face seal area with irritant or aroma smoke. Bycovering the face seal area with the smoke and breathingnaturally, the respirator wearer immediately recognizeswhether the respirator fits properly.



I16.12

4) Qualitative fit test dates should be recorded and theRespirator Qualification Sheet.

- Issuing Respirators

1) Prior to issuing a respirator to anyone, the RSO/NS, or his

designee, will determine that the individual is qualified towear that type of respirator.

2) As a minimum, the following items will be verified for eachwearer:

(a) physical examination,

(b) qualitative fit test,

(c) training,

(d) type and size of respirator, if appropriate.

3) Respirator qualifications need only be verified once during agiven job at a temporary jobsite as long as any individual’squalifications will not expire during the job. Records of therespirator qualifications shall be maintained by MorenoGroup LLC and Subsidiaries for a period not less than 5years.

- Using Respirators

1) Inspection

(a) Each individual issued a respirator will be required tovisually inspect the respirator prior to its use to ensurethat it is in good operating condition.

(b) The inspection should include the tightness of theconnections and the condition of the harness, thecoverings, filter(s), canister(s), and the cartridge(s).

(c) Each wearer should also ensure that the filter,cartridge, or canister being used is applicable forradioactive particulates or radionuclides. The filter,cartridge, or canister should be specified as 99.97%efficient for protection against radioactive particulatesor radionuclides or for use with organic vapors andmists.



I16.13

2) Seal Tests

(a) The wearer of a respirator shall ensure properprotection by checking the seal of the facepiece priorto each use by performing a negative pressure sealtest.

(b) The negative pressure seal test is performed bycovering the respirator’s canister or filter inlets withthe palms of the hands. The wearer then inhalesgently and holds his breath for at least 10 seconds. Ifthe facepiece collapses slightly and no inwardleakage of air into the respirator is detected, the fit isconsidered satisfactory.

(c) No one is authorized to use any respirator without firstperforming a satisfactory face seal test.

3) Relief From Use

(a) Each and every respirator user may leave the area atany time for relief from respirator use in the event ofequipment malfunction, physical or psychologicaldistress, procedural or communication failure,significant deterioration of operating conditions, or anyother condition that might require relief.

(b) Relief from use will be included as part of the pre-jobbrief.

- Air Monitoring

Air monitoring will be conducted as needed.

- Medical Evaluations

1) Physicals

(a) Employees will be evaluated by competent medical

personnel to ensure that they are physically andmentally able to perform work while wearingrespiratory protection equipment.

(b) These evaluations will be performed initially and atleast annually thereafter.

(c) Records of these physicals shall be maintained atMoreno Group LLC and Subsidiaries for not less than5 years.



I16.14

- Respirator Maintenance

1) Respirators will be inspected prior to each use, whencleaned and both during and after the day’s work. Anyrespirator not in working condition will be removed from useand repaired or replaced.

2) Respirators will be cleaned after each use with alcohol orother suitable swabs. At the end of the work shift, therespirators will be washed in soapy water and let to dry.

3) Respirators will be maintained in bags or some otherprotective enclosure to ensure that they do not becomecontaminated. They shall be stored in a clean, dry area,preferably out of direct sunlight.

ALARA PROGRAM

Philosophy

Moreno Group LLC and Subsidiaries will maintain all exposure to personnel and theenvironment ALARA (as low as reasonable achievable). This will be accomplishedby minimizing personnel time spent in the vicinity of radioactive sources and bymaximizing distance from radioactive sources. ALARA practices will also includenecessary surveys, safety/radiological meetings, and other measures to track,control, and dispose of NORM appropriately and in accordance with the radiationprotection philosophy of this license and existing regulations.

Program Structure and Responsibilities

The ALARA program consists of all Moreno Group LLC and Subsidiaries personnel:workers (both employee and Contractor), supervisors and management.

- Moreno Group LLC and Subsidiaries Management has the responsibilityto generate and maintain company commitment to ALARA principles andpractices. Management must ensure that area audits are performed at afrequency and depth to evaluate the success of this program and tofacilitate necessary changes ensuring that all exposures to personnel andthe environment are ALARA. Management shall also provide direction tothe RSO/NS in the development and implementation of this program.

- RSO/NS’s have the direct responsibility of developing, implementing, andevaluating ALARA procedures. They shall take direction from MorenoGroup LLC and Subsidiaries management and provide continuoussurveillance of any areas that apply to the program and address theconditions that exist. The RSO/NS has the authority to enforce anyregulations and administrative policies that affect any aspect of theprogram.



I16.15

- All Moreno Group LLC and Subsidiaries personnel shall adhere to therules and procedures established by the RSO/NS. The worker mustreport any unsafe work practices and/or equipment malfunctions thatcould result in any increase of radiological hazard to the RSO/NS or hisdesignee. The worker may also make suggestions as to improve the

ALARA program.

Administrative Procedures

- Frequent inspections and audits of operational practices shall provideMoreno Group LLC and Subsidiaries management with necessaryinformation to conduct an appropriate ALARA program. These inspectionsshall be made at intervals not to exceed 12 months. Documentation of thefinding shall be maintained and will provide future references to makecomparisons during the development of an effective program.

- The following shall serve as a guideline for documentation of inspectionsand audits:

a) employee exposure records

b) bioassay results

c) logs of inspections made of the program

d) documented training program activities

e) pre-job briefs

f) survey and sampling data

g) facility changes and reviews

h) discussions of the findings during the inspections and audits

- NORM training shall include reference to this program and the conceptsthis program is based on.

Written Procedures

Standard procedures shall be written for all practices involving the handling,processing, and temporary storage of NORM. These procedures should containproper radiation work practices to minimize exposure during all NORM activities.

Operating Procedures

The ALARA program shall be maintained while performing NORM activities at theMoreno Group LLC and Subsidiaries temporary jobsites. It is the responsibility ofeach individual to adhere to procedures for safe radiological work practices.



I16.16

- During operations, the RSO/NS is responsible for implementing the ALARA program.

- Pre-job briefings shall be conducted prior to commencing work activities toinform workers of existing radiological conditions and ALARA workpractices.

- Surveys shall be performed in accordance with this license to identify anychanges in radiological conditions.

- Minimization of potential hazards can be accomplished through the use ofengineering controls such as ventilation systems, HEPA units, wetting ofmaterials to reduce airborne contamination, etc..

- Protective equipment shall be worn as required to prevent anyunnecessary exposure to radioactive materials. It is the duty of theRSO/NS to assign the proper personal protective equipment for tasksassociated with the NORM activities taking place.

- Access to areas containing NORM should be controlled in such a way asto prevent any unnecessary exposures to personnel or the environment.

- Workers shall be made aware of any changes in the program andprocedures pertinent to maintaining safe radiological work practices andbe reminded of the basics: minimize time and maximize distance fromradioactive sources.

Equipment Design and Facility Use

- The jobsite layout, types, and placement of equipment to be used duringNORM activities should be considered prior to commencing work. Itshould be established in such a manner as to minimize exposure topersonnel while at the same time reducing the risk of exposure tounauthorized persons and the environment.

- Packages containing NORM should be stored in the designated areas andposted in accordance with this license and LAC 33:XV to preventunnecessary exposures to personnel.

ACCIDENTS

In the event of an accident, fire, release, or spill, the RSO/NS will be immediatelynotified. First priority will always be given to injured personnel. Radiologicalconcerns will be addressed only after conditions involving personnel, fires,uncontrolled releases, or spills have been stabilized. In the event of a spill, theperson discovering it shall immediately implement the Spill Contingency Plan inSection 11.0 of this license.



I16.17

RADIATION TRAINING REQUIREMENTS

All persons entering a Restricted Area will be trained in accordance with LAC33:XV.1012.

This training shall consist of a minimum of 8 hours classroom instruction,practical factors, and an examination. This course of instruction will be

provided by individuals recognized by LDEQ/RPD as having sufficientknowledge and skills to provide such training.

Visitors and short term contractors shall be briefed.

A minimum of eight hours refresher training shall be conducted annually.

Employees shall also receive respiratory protection training as per DIIRespiratory Protection program.

Other personnel not working directly with NORM, will receive NORM awareness

level training during New Hire Orientation / SH&E Training. This training shallconsist of the hazards related to NORM exposure and protection methods.

REPORTING

RESPONSIBILITY

The corporate RSO or his designee is responsible for making reports to theLouisiana Department of Environmental Quality / Radiation Protection Division(pursuant to LAC 33:XV. Chapter 4, Subchapter J) should any of the followingbecome necessary:

Reports of Stolen, Lost, or Missing Sources of Radiation

- Telephone Reports

a) Immediately after its occurrence becomes known to Moreno GroupLLC and Subsidiaries, stolen, lost, or missing radioactive material inan aggregate quantity equal to or greater than 1,000 times thequantity specified in Chapter 4, Appendix C under suchcircumstances that it appears to Moreno Group LLC andSubsidiaries that an exposure could result to individuals in

unrestricted areas; or

b) Within 30 days after its occurrence becomes known to MorenoGroup LLC and Subsidiaries, stolen, lost, or missing radioactivematerial in an aggregate quantity greater than 10 times the quantityspecified in Chapter 4, Appendix C that is still missing.

- Written Reports



I16.18

Should Moreno Group LLC and Subsidiaries be required to make a report asmentioned above, a written report to LDEQ/RPD shall be made within 30 days aftermaking the telephone report setting forth the following information:

a) A description of the NORM involved, including the kind, quantity,and chemical & physical form;

b) A description of the circumstances under which the loss or theftoccurred;

c) A statement of disposition, or probable disposition, of the NORMinvolved;

d) Exposure of individuals to radiation, circumstances under which theexposures occurred, and the possible total effective doseequivalent to persons in unrestricted areas;

e) Actions that have been taken, or will be taken, to recover theNORM; and

f) Procedures or measures that have been, or will be, adopted toensure against a recurrence of the loss or theft of NORM.

- Subsequent to filing the written report, Moreno Group LLC andSubsidiaries shall also report additional substantive information on theloss or theft within 30 days after learning of such information.

- Moreno Group LLC and Subsidiaries shall prepare any report filed to

LDEQ/RPD so that names of individuals who may have received exposureto radiation are stated in a separate and detachable portion of the report.

Notification of Incidents

- Given that oilfield NORM should not reach elevated levels of exposure,should it occur, Moreno Group LLC and Subsidiaries will follow theprocedures listed in LAC 33:XV.486 and 487.

Notifications of Spills (See Section 11.2 of this license)

Notifications and Reports to Individuals

- Requirements for notification and reports to individuals of exposure toradiation or radioactive material are specified in this license and LAC33:XV.1013.

- Should Moreno Group LLC and Subsidiaries be required to report toLDEQ/RPD pursuant to LAC 33:XV.487, Moreno Group LLC andSubsidiaries will also notify the individual at a time no later than the



I16.19

transmittal to division and shall comply with the provisions of LAC33:XV.1013.A.

Quarterly Work Activity Report

- This report shall be submitted to LDEQ/RPD within 30 days of the end ofeach calendar quarter. Should additional time become necessary for

preparation and submittal of this report, a written request for extension willbe forwarded to LDEQ/RPD.

- It will include waste generating activities from the Moreno Group LLC andSubsidiaries temporary jobsites within LDEQ/RPD jurisdiction.

- The report shall list the customer (or generator) name, jobsite location,dates of job, amount of waste generated, and the date the waste wastransferred.

Financial Security Requirements

- Pursuant to LAC 33:XV.1420, Moreno Group LLC and Subsidiaries shallpost with the division financial security to ensure protection of the publichealth and safety and the environment in the event of abandonment,default, or other inability or unwillingness of Moreno Group LLC andSubsidiaries to meet the requirements of the state and federal rules andregulations. This financial security shall:

a) name the division as beneficiary with a bond issued by a fidelity or suretycompany authorized to do business in Louisiana. The amount of the bondshall be equal to or greater than the amount of the security required. It

shall be available in Louisiana and subject to judicial process andexecution in the event required for the purposes set forth in LAC 33:XV,Chapter 14 and be continuous for the term of the license; and

b) be in an amount based upon a division-approved cost estimates plan fordecontamination, decommissioning, restoration, and reclamation ofbuildings, equipment, and the site to levels that would allow unrestricteduse.

- No later than 90 days after Moreno Group LLC and Subsidiaries notifiesLDEQ/RPD that decontamination and decommissioning have beencompleted, the division shall determine if these have been conducted inaccordance with appropriate rules and regulations. If the division finds thatthe requirements have been met, the secretary or his designee shall directthe return or release of Moreno Group LLC and Subsidiaries security in fullplus any accumulated interest within 14 days. If the division finds thatthese requirements have not been met, the division will notify MorenoGroup LLC and Subsidiaries of the steps necessary for compliance.



I16.20

RADIATION AND CONTAMINATION SURVEYS

Radiation surveys shall be conducted to determine exposure rates, area postings,presence or absence of loose surface, fixed and airborne contamination and forestablishing baseline and release criteria.

ACTION LEVELS FOR DEFINING RADIATION AREAS

Definitions

A Radiation Area is an area accessible to individuals in which there exists radiationat such levels that a major portion of the body could receive in any one hour a dosein excess of 5 millirems (0.05 millisievert), or in any five consecutive days, a dose inexcess of 100 millirems (1 millisievert).

A High Radiation Area is an area accessible to individuals in which there existradiation at such levels that a major portion of the body could receive in any onehour a dose in excess of 100 millirems (1 millisievert).

An Airborne Radioactivity Area is an area in which airborne radioactive materialsexists in concentrations:

- in excess of the derived air concentrations (DAC’s) specified in LAC33:XV Chapter 4, Appendix B, Table 1; or

- to such a degree that an individual present in the area withoutrespiratory protective equipment could exceed, during the hours anindividual is present in a week, an intake of 0.6% of the annual limiton intake (ALI) or 12 DAC hours.

A Radioactive Material Area is an area where NORM contaminated equipment orwaste is stored, utilized, or treated. A facility or area may be posted as aRadioactive Material Area and contain within it one or more work areas controlled asRestricted Areas.

A Restricted Area is an area, excess to which is limited by the license for thepurpose of protecting individuals against undue risks from exposure to sources ofradiation.

Radiation surveys shall be conducted at each jobsite to ensure that the

exposure rates are less than 2,000 uR/hr at the boundary of any Restricted Area and that exposure rates at the perimeter are such that a member of thegeneral public will not receive a dose greater than 100 mrem in one calendaryear. An action level of 600 uR/hr will be used for exposure rates at theperimeter of temporary jobsites. If this exposure rate is encounteredanywhere on the perimeter, work activities will stop and the RSO will beimmediately notified. Work activities shall not recommence until the radiationlevels at the perimeter have been lowered.



I16.21

The Restricted Area boundary surveys shall be conducted before, during, andafter all work activities involving NORM operations. A minimum of oneradiation and contamination boundary survey shall be conducted each day attemporary jobsites. Additional surveys shall be conducted as warranted bythe work activities and as directed by the RSO.

Survey results shall be documented on a jobsite sketch or map and reported

to the RSO. Records of surveys shall be maintained for a period of not lessthan 5 years at Moreno Group LLC and Subsidiaries

EQUIPMENT CONTAMINATION SURVEYS

Wipe Tests

- Random wipe tests shall be taken of contaminated equipment at theMoreno Group LLC and Subsidiaries temporary jobsites to ascertain thepresence or absence of loose surface contamination upon receipt of thematerial and to verify decontamination to acceptable levels.

- The wipe shall be of a porous material approximately 1” in diameter andshall be wiped across an accessible area of the equipment equivalent toapproximately 100 square centimeters.

Only those persons who have received, at a minimum, proper training forNORM surveying will be allowed to conduct wipe testing of equipment, etc.

A Ludlum Model 2 survey meter outfitted with a Ludlum Model 44-9 probe (orequivalent instrumentation) shall be used to measure the wipes. Otherinformation on instrumentation can be found in Section 9.0 of this license.

After the wipe has been taken, it will be brought to an area of low background(equal to or less than 50 cpm) and counted with the instrumentation listedabove. Taking into account the instrument efficiency, add the backgroundreading to the action level of 100 cpm to get a true action level. Items withloose surface contamination exceeding this true action level will be handledas NORM contaminated and appropriate action taken. If the item has beenverified free of loose surface contamination, the item shall be taken to an areaof low background and surveyed for fixed contamination over 100% of allaccessible surfaces. Any item found to have fixed contamination exceedinglevels for unrestricted use, or as directed by the customer, shall not be

released for such use. Should the item contain levels exceeding thosespecified in LAC 33:XV.1404, it shall be handled and controlled as NORMcontaminated.

PERSONNEL CONTAMINATION SURVEYS

A Ludlum Model 2 survey meter outfitted with a Ludlum 44-9 probe (orequivalent instrumentation) shall be utilized to perform contamination surveys.See Section 9.0 for further information.



I16.22

Only those persons who received, at a minimum, proper training for NORMsurveying shall be allowed to perform personal frisks.

Personal Frisking Procedures

- All personnel entering Restricted Areas will be required, as a minimum, to

perform a hand and foot frisk immediately upon exiting the Restricted Area. A whole body frisk will be performed before leaving the work siteand when protective clothing was worn in the Restricted Area.

- The probe shall be held within ½” of the body and moved at a rate of 2 – 3inches per second. Any sustained readings above background shall because to slow or stop the probe over the affected area for adequatemeasurement. Should the reading persist, the contamination in that areashall be removed and the person refrisked.

- Any contamination found on personnel shall be immediately reported to

the RSO/NS. The RSO/NS will identify where the individual becamecontaminated and what work activities he was involved in. Personalprotective measures and work activities shall be reviewed to prevent arecurrence of the incident. The RSO/NS shall complete an IncidentReport Form for each contaminated individual. As a minimum, the reportshall document:

a) the full name of the individual,

b) the date and time the incident occurred,

c) location(s) on the body and level(s) to which the individual was

contaminated,

d) approximate length of time the individual was contaminated,

e) work location where the contamination occurred and thecircumstances involved,

f) methods of decontamination and level to which the individual wasdecontaminated,

g) corrective actions which can be taken to prevent recurrence.

- After completion of the Incident Report Form, the RSO/NS shall review theform with the individual. The individual will counter-sign the formindicating the information contained on the form is true and correct to thebest of his knowledge.

- Personnel shall not be allowed to leave the temporary jobsite withaccessible loose surface contamination. An exception will only be madein event of a life threatening injury to a person requiring immediate



I16.23

medical attention. Whenever possible, the RSO/NS will arrange fordecontamination of the person prior to leaving the Restricted Area.

SAMPLING

SOIL SAMPLING

Temporary Jobsites

Procedures

- Soil and sediment samples shall be taken at a depth up to 15 cmretrieving approximately one liter of soil to be analyzed.

- Appropriate sampling tools (i.e., shovel, trowel, auger, coring device, etc.)shall be utilized to retrieve representative samples at the appropriatedepths. Tools will be wiped and cleaned between samples to preventpossible cross contamination.

- Each sample shall be placed into a suitable container (i.e., Ziploc bag,plastic wide-mouth container, etc.) and labeled including customer name,date, project number, sample number, sample location, contents, and anyother appropriate markings for shipping protocol.

- A chain of custody will be completed with a minimum of one copy retainedfor project files and one copy to accompany the sample shipment to thelaboratory.

- All soil and sediment samples shall be analyzed by a laboratory

recognized or licensed by the LDEQ/RPD to perform analysis ofradioactive materials and which utilizes National Institute of Standards andTesting (NIST) traceable sources. The reporting units shall be inpicocuries per gram.

WATER SAMPLING

Wash water

- A decontamination area will be established at temporary jobsites andprovisions will be made to collect all wash water so as to prevent the

spread of NORM contaminated fluids or materials to uncontrolled areas.The wash water collected will be filtered to remove particulates andrecycled for further wash down activities. Settling tanks may also be usedto remove solids from the water. Decontamination activities will stop if anywater leaks are noted and shall not recommence until the leak has beencorrected. The wash water collected shall be considered NORM wasteuntil a laboratory analysis proves otherwise.

Any surface (or ground) water that may accumulate in a low or remediatedarea of known NORM contamination shall be pumped into appropriate



I16.24

containers. The water will be filtered to remove particulates and recycled forfurther wash down activities. It will also be considered NORM waste until alaboratory analysis proves otherwise.

Sampling procedures

- A sample measuring approximately one (1) gallon will be collected into an

appropriate container and marked.

- A chain of custody shall be completed and handled.

- Laboratory analysis shall be in picocuries per milliliter.

Under no circumstances will washwater be released for unrestricteddischarge. Once analysis of the water proves it to be below 60 pCi/L,approval from the Louisiana Office of Conservation will be solicited for properdisposal at a state-approval injection well.

AIR SAMPLING

Air sampling for radioactive materials shall be performed in accordance with Section3.2.C of this license.

ENVIRONMENTAL RESPONSIBILITIES

BASELINE AND RELEASE SURVEYS OF TEMPORARY JOBSITES

Prior to commencement of any NORM work activities at a temporary jobsite, abaseline radiological survey of the area shall be conducted in accordance with LAC33:XV Chapter 14 and the guidelines contained in the current Implementation

Manual for Management of NORM in Louisiana. The survey shall include, but is notlimited to, the following:

Baseline Dose Rate Survey

- Instrumentation utilized per manufacture requirements.

- A dose rate survey shall be performed in an area immediately adjacent tothe proposed work site to determine background levels of exposure.

- A dose rate survey shall be performed on the lands, equipment, and well

head found on the work site.

a) The survey will be documented on gridded survey maps or plats.The maps shall be constructed so that grid locations can be easilyidentified and referenced. All notes and other information notrecorded directly on the map should be referenced to grid locations.Maps should be of sufficient size and scale to contain all surveyinformation, sample locations, and all significant objects.



I16.25

b) In no case will grid spacing be greater than 10 meters. In areas ofknown contamination, the grid spacing shall not exceed 3 meters.Each grid line should be surveyed from outside point to outsidepoint. Readings should be recorded at no more than 10 meters or3 meter intervals, as appropriate.

c) Survey instrument readings shall be taken within 1 cm of the

ground surface or any object surveyed. The response of the surveyinstrument shall be continuously monitored while performing thesurvey.

d) Any areas surveyed reading twice background levels ofradioactivity or greater when performing the initial baseline doserate survey shall be noted on the grid map as a potential samplinglocation and a 100 square meter delineation constructed.

e) Upon completion of the land survey, all areas of identifiedcontamination should be demarcated to prevent workers fromwalking through the contamination, thereby reducing the potentialof contaminating themselves and spreading contamination. Thesurveyor will then perform a whole body frisk to verify the absenceof contamination on his body.

- A copy of the baseline dose rate survey shall be retained on the temporary jobsite for the duration of the project for review by the RSO/NS, otheremployees & contractors, and the LDEQ.

Baseline Soil Sampling

- A minimum of three (3) soil samples shall be taken within the first 15 cm inthe following locations:

f) in an area adjacent to the work site to determine area backgroundlevels,

g) within the worksite, at or outside of the Restricted Area boundary,and

h) at the point of work activities within the Restricted Area.

- Additional soil samples may be taken of the areas delineated as potentialsampling locations on the grid map.

- Sample locations shall be marked on the grid map.- Sampling procedures shall be in accordance with the license and the

implementation manual mentioned in the preceding page.- A copy of the baseline survey report indicating soil sample locations and

soil sample analysis results shall be kept on the temporary jobsite forreview by the RSO/NS, other employees & contractors, and the LDEQ.

Upon completion of work activities involving NORM at the temporary jobsite, asimilar dose rate survey shall be made with soil samples retaken in the initialbaseline locations for comparison. Any increase in dose rates or activity as



I16.26

compared to the initial baseline survey shall be documented on a survey mapand reported to the RSO/NS. Those areas noted with dose rates above thoseidentified in the baseline survey shall be sampled or decontaminated asnecessary.

Records of the baseline and release surveys of temporary jobsites shall beretained at Moreno Group LLC and Subsidiaries for a period of not less than 5

years; or, until copies have been turned over to LDEQ for site closure.

RELEASE FOR UNRESTRICTED USE

Pursuant to LAC 33:XV.1417, facilities, equipment and land exceeding the level ofcontamination provided in LAC 33:XV.1404 and are subject to the provisions ofChapter 14, they shall not be released for unrestricted use until they have beendecontaminated in accordance with this license and LRR.

For equipment contaminated in excess of limits specified, decontaminationmust be performed to reduce exposure levels below 50 microroentgens per

hour including background and ensure that it is free of loose surfacecontamination (or to current regulatory limits).

For areas or soil contaminated in excess of those specified limits,decontamination shall be to five picocuries per gram above background ofradium-226 or radium-228. However, prior to land being released forunrestricted use, the closure procedures contained in LAC 33:XV.1417.B,C,D,& E must be met.

PREVENTING THE SPREAD OF CONTAMINATION

All personnel involved with NORM work activities shall make a conscious effort toavoid conditions leading to the uncontrolled release of NORM which maycontaminate personnel, equipment, and the environment. All unsafe workingconditions and defective equipment shall be reported to the RSO/NS, SH&E Officer,or Work Supervisor immediately.

Although it is difficult to anticipate all potential scenarios and proceduralize the stepsto take, Moreno Group LLC and Subsidiaries will take necessary actions to ensurethat no contaminated, or potentially contaminated, equipment or materials come indirect contact with unprotected skin or uncovered ground or soil. Moreno Group LLCand Subsidiaries will also take actions necessary to ensure that NORM particulates

are not allowed to become inhaled or ingested. The following steps shall befollowed to provide adequate protection against the spread of NORM contaminationfor workers, the public, and the environment.

A baseline radiological survey will be performed of all temporary jobsites.Refer to the license and LRR for further information on these surveys.

Daily visual inspections of equipment shall be made by the RSO/NS, SH&EOfficer, or another designated representative to ensure that hoses, pipes,



I16.27

valves, flanges, pumps, and containers are not leaking NORM or othercontaminants to the environment.

Per existing regulations and conditions of this license, only properly briefedand/or trained individuals shall be allowed to work with NORM.

A boundary shall be established around the jobsite and posted with

appropriate signs as specified in LAC 33:XV.450, 451 & 452 and Section 5.2of this license. The signs shall bear the conventional radiation colors(magenta, purple, or black on a yellow background) and the three blade tri-foil design. As a minimum, the sign shall bear the words “Caution – Radioactive Materials”. Additional postings such as “Radiation Area”,“Airborne Radioactivity Area”, “Restricted Area”, etc. may be requireddepending upon other activities taking place.

The area posted and controlled as a Restricted Area shall be kept as small aspossible. However, the area will be large enough to allow for all work and transit ofpersonnel and equipment to be performed in a safe manner.

No eating, drinking, smoking, or chewing will be allowed within the Restricted Area or Radioactivity Area. Open wounds, sores or cuts shall be reported tothe RSO/NS and covered with bandages and/or protective clothing prior toworking in the Restricted Area or Radioactivity Area.

The provisions of the RWP shall be carried out which delineates, among otherthings, personal protection requirements as specified in the Health Physicssection of this license.

Depending on the site conditions and layout, plastic sheeting, rubber or

plastic mats, drip pans, cement or plastic lined slabs, or other non-permeablematerial shall be used to minimize the potential spread of contamination.

A point of entry and egress from the Restricted Area shall be designated andestablished based on several conditions, not the least of which concernspersonal and environmental safety. As stipulated in the license, all personnelexiting controlled areas will perform a personal frisk to ensure thatcontamination is not being removed from the controlled area and that theindividual is not contaminated.

All containers and equipment used in NORM work activities will be wiped or

smeared for loose surface contamination per the license. They will not bereleased for unrestricted use should those levels reach or exceed twicebackground.

Prior to being released for unrestricted use, facilities, equipment, or sites shallbe decontaminated in accordance with this license and current LRR.

As directed by the RSO/NS, radiation & contamination surveys shall beperformed or controlled areas at temporary jobsites. They shall be



I16.28

documented & maintained for review by employees, contractors, and LDEQat Moreno Group LLC and Subsidiaries for a period of not less than five (5)years.

During NORM activities which may cause NORM materials to becomeairborne, air samples will be taken of the workers’ breathing zone and at theRestricted Area boundary per Section 3.2.C of this license.

When NORM activities are to be continued the next day, the work area shallbe placed in a controlled condition to prevent the release or escape of NORMcontaminants.

All containers shall be surveyed and labeled according to the client’sprocedures and current radiation regulations. At a minimum, they shall bemarked with the generator’s name, contents, date sealed, identificationnumber, and the maximum dose rate.

Wash or process water will be filtered and recycled to minimize the

generation of contaminated fluids. All remaining waste water will be sampledand analyzed by a laboratory which utilizes NIST traceable standards forradioactivity and disposed of as per existing regulations and policies.

All other waste materials generated from NORM activities will be surveyed,decontaminated or disposed of in accordance with existing state and federalregulations and policies.

Upon completion of NORM activities at a temporary jobsite, a release surveyshall be performed in accordance with the license.

Records of all NORM activities will be properly documented and maintainedat Moreno Group LLC and Subsidiaries for a period of not less than 5 years.

RECEIPT, TEMPORARY STORAGE AND TRANSFEROF NORM AND NORM CONTAMINATED MATERIALS

NORM contaminated equipment, and waste generated from NORM activities, shallbe temporarily stored and handled pursuant to the following procedures.

MATERIAL RECEIPT

NORM material received at temporary jobsite shall be handled as follows:

The person designated to register receipt of NORM materials shall ensurethat all documentation (i.e., prior written confirmation of the acceptability,manifests, etc.) has been received and/or shipped with the NORM material.He will also ensure that the paperwork adequately reflects the material beingreceived.



I16.29

All items received shall be randomly surveyed for radiation levels and loosesurface contamination. Items having loose surface contamination shall becontrolled and worker protection measures placed in effect (i.e., protectiveclothing, sealing exposed openings with plastic or other suitable materialspreventing the spread of contamination) until such time that the items havebeen moved into a decontamination area and/or decontaminated. In addition,trucks, boats, or other vehicles transporting the NORM shall be surveyed for

loose surface contamination and shall not be released for unrestricted useuntil verified free of contamination.

Records shall be kept of NORM contaminated equipment and materialsreceived and shall include, but not be limited to:

- the name, address, phone, and general license number of the generator;

- the amount (or estimate) of drums, containers, tubulars, etc., included inthe shipment;

- the maximum dose rate obtained from the random survey of the externalsurface of the material the NORM is contained in;

- the presence of any loose surface contamination on the external surfaceof the material;

- the date of the survey; and,

- the name of the person performing the survey.

Upon completion of the radiation and contamination surveys, the received

items shall be moved to a designated temporary storage location to awaitfurther action.

TEMPORARY STORAGE AREAS

Temporary storage areas shall be posted with conspicuous signs reading, asa minimum, “Caution-Radioactive Materials”. Additional postings maybecome necessary depending on exposure levels.

Access will be controlled by erecting rope or tape barriers, as a minimum,around the storage area when NORM materials or equipment is being stored.

No person will be allowed entrance into the storage area until that individualhas been briefed and/or appropriately trained in the precautions and potentialhazards of NORM.

Visual inspections shall be made of the temporary storage areas. Ontemporary jobsites, they shall be performed daily

During the inspection, the designated individual shall look for leaking or deterioratingcontainers, labels, and the condition of materials preventing the spread of



I16.30

contamination. The RSO/NS shall be informed of any container holding NORMwaste that is found not to be in good or safe condition (i.e., severe rusting, leaks,apparent structural defects, etc.) The NORM from the defective container shall betransferred to a container free from material defects and the area decontaminated assoon as possible.

Records of the inspections shall be maintained per LAC 33:XV.1414.G for inspection

by the RSO/NS and LDEQ at the jobsite for the duration of the project and/or atMoreno Group LLC and Subsidiaries job for a period of not less than 5 years.

An inventory of all containers stored in the temporary storage area(s) shall bemaintained. The inventory shall contain, as a minimum, unique identificationnumbers, origin of the item (i.e., owner or generator name), date transferredto storage (or date sealed of the item is a waste container), item exposurerate, date removed form storage, and place transferred to.

Moreno Group LLC and Subsidiaries Does not intend to store NORM waste attheir Facilities.

CONTAINERS

NORM and NORM waste shall be kept in containers that are in good or safecondition. The container shall meet DOT approval and be made of, or linedwith, materials that will not react with, or be incompatible with, the NORMwaste to be stored so that the ability of the container to contain the waste isnot impaired or compromised.

A container of NORM waste shall not be opened, handled, or stored in amanner that may rupture it or cause it to leak. It shall be closed and sealed

during storage, except when necessary to add or remove waste.

All containers of NORM waste shall be stacked in a fashion that eachcontainer identification label can be read from the access aisle or area.Containers having higher exposure rates shall be arranged so as to minimizeboundary exposure rates.

All containers of NORM waste shall bear a durable, clearly visible labelbearing the radiation symbol and the words “Caution – Radioactive Material”.Other markings shall include, but not be limited to, name of the generator,date sealed, unique identification number, contents, and exposure levels to

permit individuals handling or using the containers, or working in the vicinity ofthe containers, to take precautions to avoid or minimize exposures.

Prior to removal or disposal of empty uncontaminated containers tounrestricted areas, removal or defacing of the radioactive material label andmarkings shall be performed or otherwise clearly indicated that the containerno longer contains radioactive materials.

TRANSFER FOR DISPOSAL AND MANIFESTS



I16.31

All NORM waste generated by activities performed by Moreno Group LLCand Subsidiaries Remains the property of the generator and is shipped toeither his authorized temporary storage location or disposal facility.

Waste transfers shall be accompanied by a shipment manifest that containsthe name, address, and phone number of the generator, transporter, anddesignated facility for receipt of the material. Transfer, manifest, and

documentation requirements shall be conducted in accordance with LAC33:XV.1412 & 1418, Chapter 15, and as appropriate, DOT regulations andpolicies.

INSTRUMENTATION

Radiation and contamination survey instruments should conform to specifications inLAC 33:XV.1406 and the following guidelines.EXPOSURE INSTRUMENTATION

Instrumentation utilized to measure gamma radiation exposure rates from land and

equipment shall be capable of measuring from 1 to 5000 microreontgens per hour.This may be accomplished with a Ludlum Model 3 survey meter equipped with aLudlum Model 44-2 sodium iodide detector (or equivalent instrumentation). At leastone exposure rate instrument shall be available at each temporary jobsite.

CONTAMINATION INSTRUMENTATION

Instrumentation utilized to detect both alpha and beta particle contamination onpersonnel and equipment shall be capable of measuring from 1 to 500,000 countsper minute (cpm). A Ludlum Model 2 survey meter equipped with a Ludlum Model44-9 GM Pancake probe (or equivalent instrumentation) may be used. At least one

contamination survey instrument shall be available at each temporary jobsites.

CALIBRATION

The following companies offer survey instrument calibration that may be used byMoreno Group LLC and Subsidiaries:

Amersham Corporation Baton Rouge, LA. (504) 751-5893Suntrac Services, Inc. Webster, TX. (713) 280-9982Ludlum Measurements, Inc. Sweetwater, TX. (915) 235-5494Total Safety Broussard, LA. (800) 824-4250

Each survey instrument shall be calibrated: at intervals not to exceed one year; anytime the instrument is found to respond inconsistently to a known source; when itshows any indication of physical damage; after each instrument servicing; atenergies and radiation levels appropriate for use; and, so that accuracy within plusor minus 20 percent of the true radiation level can be demonstrated on each scale.



I16.32

PRE-OPERATIONAL TESTING OF SURVEY INSTRUMENTS

Four different pre-and post-operational checks will be performed on surveyinstruments. They may also be conducted any time the user believes andinstrument may not be operating properly. These checks include:

A physical integrity check,

A battery check (to also be performed during each use)

Source response check (with a button source, lantern mantle, or NORMsample)

Check the calibration sticker to ensure proper calibration requirementshave been met.

CARE AND USE

Radiation and contamination survey instruments are very fragile. Therefore,extreme care will be taken during storage and while being handled. When surveyingpersonnel, equipment, or land for unrestricted release, the instruments shall only beused by individuals trained in accordance with this license and current LRR.

DECONTAMINATION

PERSONNEL DECONTAMINATION

All personnel exiting a Restricted Area are required to have a personal friskperformed as outline in the license. When sustained readings above backgroundare encountered requiring decontamination, the method used should be chosen onthe basis of not only the effectiveness of removing the contamination, but also theeffect it will have on the individual.

NORM contamination on the skin is best removed by gently washing theaffected area with a mild, high lather soap and tepid water. A waterlesswashing gel may also be used and wiped from the skin with rags beingcareful not to push the contamination further into the skin. Upon completionof the initial washing process, the affected area shall be re-surveyed. Ifnecessary, a second washing will be performed and the area againresurveyed. If contamination is still present after two washings, the RSO/NSwill be contacted for further guidance.

If clothing (or rags) is found to be contaminated, it shall be washed andsurveyed until it is free of contamination. If it cannot be decontaminated, itshall be disposed of as NORM waste.

All wash water shall be collected and handled in accordance the license.



I16.33

If necessary, and Incident Report Form shall be completed in accordance withthe license.

EQUIPMENT DECONTAMINATION

A decontamination area will be established at the temporary jobsites.

The area will be of a size to adequately contain essential working personnel,the equipment being decontaminated, the decontamination equipment, and allwash water. Proper postings and boundaries shall be utilized in accordancewith this license and LRR.

Decontamination shall be accomplished by the simplest and mostradiologically-sound method. Wipedown and washing with low pressurewater is preferable to high pressure hydro-lancing. Prior to beginningdecontamination, consideration will be given to the potential for spreadingNORM throughout the decontamination area during the decontaminationprocess.

All wash water shall be collected and handled in accordance with Section6.2.A. of this license.

After decontaminating the item(s), a contamination survey shall be performedin accordance with the license.

LAND DECONTAMINATION

In the unlikely event land should become contaminated, the procedures for landremediation outlined in the license shall be followed. Other pertinent sections of this

license and LRR shall also be followed.

SPILL CONTINGENCY PLAN

This spill contingency plan consists of procedures to follow in the event of a spill ofNORM materials. Its purpose is to provide coordinated response to spills oraccidental discharges of NORM waste. The RSO/NS is responsible for ensuringthat all personnel are familiar with this plan. The RSO/NS is also responsible forensuring that the spill is stopped and for any subsequent cleanup anddecontamination efforts.

BASIC SPILL PROCEDURES

This spill contingency plan will follow the basic “S.W.I.M.S.” procedures as outlinedbelow. All of the steps in the procedures shall be carried out concurrently with eachother.

Stop the spill. The primary effort of personnel upon noticing the spill will be tostop the spill. This may be accomplished by simple operations such asclosing a container, shutting a valve, stopping a pump, or tightening a flangeor gasket.



I16.34

Warn others. It is the responsibility of the person noticing the spill to warnothers in the vicinity of the spill of the danger and ensure that the RSO/NS isnotified of the occurrence as soon as possible.

Isolate the area. It is the responsibility of the personnel combating the spill tocontain the spill and isolate the area of occurrence to prevent possible

inadvertent personnel contamination.

Minimize the spill spread and personnel exposure. Every effort shall be madeby the personnel combating the spill to contain the spill to as small an area aspossible. Additionally, the personnel will take steps to minimize theirexposure. Exposure to NORM contaminants can be prevented through useof appropriate protective clothing. Other measures may be taken as noted inthe license and/or as directed by the RSO/NS.

Secure operations. All operations which could possible result in the spread ofthe spill, or which could cause the spilled effluents to become airborne, shall

be immediately stopped.

NOTIFICATION REQUIREMENTS

The RSO/NS on duty will be responsible for determining which spills andincidents need to be reported to the corporate RSO. The corporate RSOshall

then determine if the spill or incident needs to be reported to LDEQ/RPD inaccordance with LRR. These spill or incidents shall be reported to:

STATE OF LOUISIANADepartment of Environmental QualityOffice of Air Quality and Radiation ProtectionRadiation Protection DivisionP.O. Box 4313Baton Rouge, LA. 770821-4313(225) 765-0160

Additionally, the RSO/NS shall determine if it is necessary to contact one ormore of the members of Moreno Group LLC and Subsidiaries RadiationSafety Committee. The following names are listed in order of priority for

contact.

Corporate Radiation Safety Officer ........ Alan TasarWork: 337-364-7170Cell 337-577-4994

Environmental Manager ......................... Anthony Sagrera IIWork 337-364-7170Cell 337-298-8615



I16.35

Upon detection of a spill or incident requiring notification, the corporate RSO,or his designee, will give verbal notification to LDEQ/RPD. At a minimum, thereport shall include:

- The name of the person reporting the spill / incident and a telephonenumber where he may be reached.

- The location of the spill / incident.- Time and date the spill / incident began and ended, or the estimated time

of continuation of discharge of the material

- Best estimate of the amount of NORM contaminated material lost in thespill, including the method of calculating the spill volume.

- The potential for personnel exposure to the NORM contaminants.

Within seven (7) days following a verbal report, a written report shall besubmitted to LDEQ/RPD. The written report shall include:

- The name of the person filing the written report.

- Time and date of the verbal notification and name of the person who madethe verbal notification.

- Date and time that the spill / incident occurred.

- Details of the circumstances and events that caused the spill / incident.

- Best estimate of the amount of NORM contaminated material lost,including the method for calculation the spill volume.

- Description of the remedial action taken to recover any NORMcontaminated material and to restore any contaminated material to itsoriginal state.

- Procedures or measures which have or will be adopted to prevent arecurrence of the spill / incident.

- The results of any personnel NORM contamination(s) and their exposure.

SPILL CLEANUP

In the unlikely event that a spill might migrate or occur over unprotected land, thecontaminated soil shall be removed in accordance with the license and shall bereturned to the client as part of the decontamination project for temporary storage ordisposal. Cleanup will continue until the area is cleaned to background (or baseline)levels.

OPERATING PROCEDURES

Moreno Group LLC and Subsidiaries shall follow all applicable state and federalrules and regulations in addition to the policies and procedures contained in this



I16.36

document. Following are additional general operational procedures to those alreadyoutlined in this license that will be taken when performing NORM activities at thetemporary jobsites.

TUBULAR (PIPE) AND MISCELLANEOUS EQUIPMENT CLEANING

Tubular and miscellaneous equipment cleaning will take place over an

impermeable surface such as a concrete slab, drip pans, etc. to containNORM contamination and prevent the spread of the contamination.

A high pressure water lance, flex auger, fixed auger, heating, and/or a dry airtool system may be utilized to clean the tubulars. Other methods may beemployed as long as the requirements of this license are met.

- The water lance will utilize a multi-port tip affixed to it allowingcircumferential spraying inside the tubular. The waste and wash watergenerated will be collected and contained as mentioned above. All washand spray fluids will be recycled and filtered to minimize waste.

- The air tool scrapes the internal surface of the tubular using centrifugalforce to remove the scale. The NORM particles are sent to a collectionchamber from where the air is filtered prior to release into the atmosphere.

- Heat may be applied to the tubular surface to remove the moisture fromthe NORM scale effectively causing it to flake off. Small hand tools mayalso aid the removal of fixed NORM contamination.

Radiological controls (PPE, postings, minimizing exposure, etc.) shall beincorporated and followed as delineated in the RWP and/or as directed by the

RSO/NS.

TANK AND VESSEL CLEANING

Areas around tanks or vessels requiring cleaning will be protected asnecessary with suitable impermeable protective materials (concrete slabwhen available, drip pans, etc.).

NORM contaminated tanks or vessels will be cleaned using vacuum trucks,hydrolances, hand tools, portable vacuum systems, or other appropriatemeans as long as the requirements of this license are met. To clean process

vessels while in production, a remote hydraulic hydro-injection and suctiondevice may be used. Attachment, and detachment, of hoses, fittings, orvalves should not result in spillage of NORM materials to unprotected areas.

Tanks or vessels evaluated as confined spaces shall be treated as such inaccordance with 29CFR1910.146 and the attached Moreno Group LLC andSubsidiaries policy. Radiological controls, postings and worker protectionprocedures will be incorporated as outlined in this license and delineated inthe RWP and/or as directed by the RSO/NS.



I16.37

LAND AND SOIL REMEDATION

Prior to commencing remediation (decontamination) of NORM contaminatedland and soil, a thorough radiological assessment of the area will beperformed as specified in the license and LRR. This assessment willestablish background levels of radiation exposure in the adjacent area andidentify those areas needing to be remediated.

NORM contaminated land and soil will be remediated using equipment suchas backhoes, graders, front end loaders, hand tools, or similar equipment andplaced into containers appropriate to the situation.

Radiological controls, postings, and other worker protection procedures willbe instituted into the remediation activities as outlined in this license and asdelineated in the RWP and/or as directed by the RSO/NS.

At job completion, a release survey shall be performed of the remediated areaas described in Section 7.1 of this license and the Division’s current

“Implementation Manual for Management of NORM in Louisiana”. Oncecontaminated, areas may not be released for unrestricted use prior to close-out authorization by the LDEQ/RPD as prescribed in LAC 33:XV.1417.

ENCAPSULATION OF NORM

Encapsulation of NORM into pipe or tubulars provides the generator a meanswith which to dispose of his NORM waste into a plugged and abandoned welllocation. This encapsulation activity shall be performed in an area protectedwith suitable impermeable protective materials (concrete slab, drip pans,etc.).

The pipe or tubular used shall be constructed of steel, PVC, or other suitablematerials. After placing a plate (or end cap) on one end of the pipe forcontainment, the NORM waste will be place into it. If the waste is a dryproduct, water may be added to minimize the potential for airborne particlesand/or to maximize flow into the capsule. Once the pipe is filled, the oppositeend will be closed in a similar fashion.

Radiological controls, postings, and other worker protection procedures willbe incorporated as outlined in this license and as delineated in the RWP,and/or as directed by the RSO/NS.

The filled capsule shall be marked, labeled, and handled as outlined in thislicense similar to other containers of NORM waste.

VOLUME REDUCTION

NORM waste will be placed through a volume reduction device using variousmesh screens, possibly in combination with a shaker system, to separate thewaste or foreign debris into respective particle sizes. Materials may betransferred utilizing a variety of methods depending on the material handling



I16.38

characteristics of the NORM. Water, mud, surfactants, emulsifiers,stabilizers, and other chemicals may be added to facilitate handling andtreatment. Water used in the process will be recycled and filtered.

Radiological controls, postings, and other worker protection procedures willbe incorporated as outlined in this license and as delineated in the RWP,and/or as directed by the RSO/NS.

NORM TREATMENT / SLURRING FOR DOWNHOLE DISPOSAL

Treatment of slurring of NORM waste may be accomplished by utilizing amixing tank and injection unit. The unit may consist of a shaker, chopperpump, auger tank, inclined auger, generator, triplex pump, centrifuge, watertank, settling tank, and decontamination enclosure.

NORM waste will be placed into the shaker and small particles will passthrough a mesh screen. Larger particles will be funneled through a chopperpump to grind the material and drop it into a tank. Material that cannot be

grinned are removed and decontaminated by hand. The waste that fell intothe tank will be mixed with water and a bentonite or polymer to have theNORM waste remain suspended until disposal. This material will becirculated through the auger tank until being pumped into the well preparedfor NORM disposal or into a cutting box for temporary storage.

Prior to injecting NORM into a plug and abandon well location, the generatorwill submit the proper form (UIC-30) to the Department of Natural Resources,Office of Conservation, Injection and Mining Division in Baton Rouge forapproval.

Once written authorization is received, a copy of the completed UIC-30 form shallbe submitted to LDEQ/RPD along with form RPD-34.

Plugging and abandon procedures utilized by the generator will be inaccordance with the guidelines set forth by the Injection and Mining Division.Radiological controls, postings, and other worker protection procedures willbe incorporated as outlined in this license and delineated in the RWP and/oras directed by the RSO/NS.

NORM HANDLING

All NORM handling will be in accordance with this license and LRR. NORM

contaminated equipment and waste containers may be handled by forklift, crane,manually, or other similar means with extreme care being taken not to damage theintegrity of the material containing the NORM preventing the potential spread ofcontamination.

RECORDS

Master copies of all records associated with Moreno Group LLC andSubsidiaries NORM work activities at the temporary jobsites shall be kept at



I16.39

Moreno Group LLC and Subsidiaries These records shall be kept legible andshall include, but not be limited to, the following:

- Those that will be maintained for a period of not less than five (5) years.

a) Training records of all personnel; briefs & instructions given to

visitors & short term contractors.

b) Inventory and manifests reflecting all material processed at thetemporary jobsites. This shall include the generator of origin, dateshipment was received, the number of drums or packagesreceived, and the maximum dose rate readings and smearablecontamination reading on each drum or package.

c) Instrumentation calibration records.

d) Radiation and contamination surveys conducted by Moreno GroupLLC and Subsidiaries at the temporary jobsites. This includes

decontamination, spill/cleanup operations and environmentalmonitoring, such as air and soil laboratory results.

- Those that must be kept indefinitely either by Moreno Group LLC andSubsidiaries or, at termination of this license, by making provisions withLDEQ/RPD for transfer to the division.

e) Personnel monitoring data.

f) Results of surveys used to evaluate the release of NORM effluentsinto the environment.

g) Records of disposal of radioactive material.

The following documents, or copies, shall be maintained on-site at alltemporary jobsite for the duration of the job:

- Moreno Group LLC and Subsidiaries NORM license procedures

- NORM regulations (LAC 33:XV, specifically Chapters 4, 10, and 14)

- On-site personnel’s current NORM training, monitoring, and respiratoryqualification records

- Temporary job-site authorization

- Survey instrumentation calibration records

- Survey records including baseline & release radiation and contaminationsurveys associated with the job.



I16.40

- NORM manifest(s) associated with the job

- Inventory of NORM material located at the job – site

- Form DRC-3



I16.41

Attachment 1





I16.41.a.1

# Initials

1

2

3

4

5

6

7

6

Instrument Pre-operational Checks UIC - 28s - NOW Waste Manifest

Ludlum Model 3 w/44-2 Probe Ludlum Model 3 w/44-9 Probe

Radiation and Contamination Survey NORM Manifests Air Sample Log Personal Frisk Sheet

Respirator Policy Statement

Radiation Work Permits (RWP Waste Inventory/ Tracking Sheets

Records of worker physicals and fit

tests:

The pre-job Norm survey for the

specific job:

Ensure required records are current (training, calibration certificates, physicals, etc

Assimilate blank paperwork for job documentation

RPD - 35. Temporary Jobsite

Notification to LDEQ

Sample storage bottles/bags Irritant smoke test (if applicable)

Person Completing Report (Print)__________________ Signature:___________________________

Perform pre-job survey of jobsite

Obtain or perform a waste inventory of client's waste

Respirator Wipes Pens and MarkersRadioactive Material Labels Rags for decontamination

Work area postings (signs) Protective Clothing

Assimilate radiological instrumentations, equipment, and supplies

Air sampler with sample head and

tygon tubing Air sampler filters

Work area barrier rope or tape Ziploc bags for air sample storage

Personnel Training Certificates Form DRC-3, "Notice to Employees"

Verify planned activities and isotopes are authorized IAW License Number

Submit RPD - 35. Temporary Jobsite Notification to LDEQ

Gather required records

Instrument calibration records;

dii LLC radioactive material license,

LA

Louisiana regulations LAC 33:XV,

Chapters 1,3,4,10,14,15, & 25

dii LLC NORM Procedures

Any current dii LLC Notice of

Violation

Job Description: __________________________ __________________________ Job Locations:

Task/Item

Customer Representative:(Print)

NORMPre-Job Checklist

Job Name: Job #: Date:





I16.42

Attachment 2





I16.42.a.1

# Initials

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

NORMDaily Checklist

Job Name: Job #: Date:

Job Description: __________________________ __________________________ Job Locations:

Task/Item

Conduct safety meeting and complete Radiation Work Permit

Issue Dosimetry Badges

Perform NORM instrument(s) pre-operational checks

Inspect and verify worksite, storage area, and posting

Perform Surveying and Monitoring

Daily Work Area(s) Boundary Survey

Air sample when likely to exceed

10% of DAC from appendix B

Daily Storage Area Boundary Survey

Periodic radiation and/or loose

contamination survey of work area(s)

Breathing Zone Air Sample for eachoccasion of respirator use Periodic work area air samples

Daily Boundary Air Sample

Periodic radiation and/or loose

contamination survey of work area(s)

Equipment/material loose surface

contamination survey(s) prior to

removal from work area

Equipment decon and loose

contamination survey prior to

releasing for unrestricted use

Monitor worker frisking and decontamination procedures

Monitor use of respirators appropriately

Evaluate public awareness and exposure issues

Evaluate job for potential spread of contamination

Survey, label and transfer waste containers to storage, Document on waste sheet

Properly transfer and document waste shipments (Manifest, UIC-28s) Update Waste-

tracking sheet

Ensure air samples properly logged and storage bags labeled

Ensure all equipment / Material removed from work area(s) has been properly surveyed

and the surveys logged

At end of day secure work and storage area(s)

At end of day collect dosimetry

Person Completing Report (Print)__________________ Signature:___________________________

At end of day, verify documentation complete for the day

Radiation/Contamination Survey Log Waste Tracking Sheet

Air Sample Log Safety Meeting and RWP

Instrument Pre & Post-Operational

Checks Work Design Diagram







Respiratory ProtectionPage: 1 of 21Original: 01/01/2001Revised: 06/01/2008

I17.1


Purpose

The purpose of Moreno Group LLC and Subsidiaries’ respiratory protection programis to establish and set guidelines for the selection of respiratory equipment,situations for its use, and training in the use of the respirator selected.

Scope

It is the policy of Moreno Group LLC and Subsidiaries to maintain and implement aRespiratory Protection Program that will ensure employee respiratory protection forroutine, and non routine activities when feasible engineering controls or work

practices are not adequate or available to control exposure to airbornecontaminants.

Whenever possible, effective engineering controls shall be used to control employeeexposure. Effective engineering controls include enclosure or confinement of theoperation, general and local ventilation, and substitution of less toxic materials.When not feasible, or while instituting controls, appropriate respiratory protectionshould be use as described in this program.

Administration

Moreno Group LLC and Subsidiaries’ Management will have the primaryresponsibility for administering and updating the Respiratory Protection Program.

The following portions of the program may be delegated to the Safety, Health andEnvironmental Department; program evaluation, employee training, fit testing,procedures for selecting a respirator and use, and respirator hazard determination.The following portion shall be administered by the supervisor; respirator use insurveillance areas, respirator purchasing and inventory and respiratormaintenance(i.e. cleaning, storage, inspection and repair).

Responsibilities


Evaluating the respiratory hazards at their facility / site and the protectiveequipment required.

Obtaining the assistance of an outside consultant whenever necessary tosatisfy the requirements of this Procedure.



I17.2

Assuring use of engineering controls where feasible. Such controls mayinclude:

Change of the work process

Substitution of less hazardous substances for harmful materials

Isolation or enclosure of the work process or employees

Local exhaust or general dilution ventilation

Providing to employees proper respiratory protection training equipment andmedical evaluations to employees covered under this program.


Understanding the requirements of the Respiratory Protection Procedure.

Ensuring all personnel required to wear a respirator as part of their job havehad a medical evaluation and are physically capable of wearing a respirator.

Ensuring personnel required to wear a respirator have been fit tested andproperly trained. Also ensuring documentation of fit testing and training.

Conferring with the area personnel as to the respiratory hazards andprotection required.

Conferring with the personnel reporting to him / her as to the respiratory

hazards of a job and the respiratory protection required.

Obtaining special respiratory protection when required for a specific job.

Monitoring the job and work area for compliance with required respiratoryprotection usage.

Initiating the use of additional respiratory protection as specified in any workpermits such as confined space entry.

Ensuring special-use respirators are cleaned, sanitized and inspected after

each use.

Using respiratory equipment as outlined in safe operating procedures (SOP’s)or Job Safety and Environmental Analyses (JSEA’s).



I17.3


Assuming overall responsibility for the respiratory protection program andserving as the Respiratory Program Administrator.

Assisting area supervision with initial and ongoing monitoring of areas whererespiratory protection may be necessary in order to ensure the adequacy of

respiratory protection.

Specifying the appropriate styles of respirators based upon the hazardsdetermined from a hazard assessment.

Re-evaluating the hazards when changes in work areas may affect therespiratory protection required.

Re-evaluating respiratory protection requirements on an annual basis.

Posting and maintaining warning signs where respiratory protection is

required.

Conferring with supervisors / to identify respiratory hazards and whatprotection is required for a job.

Providing initial and annual training and fit testing to all users of respiratoryprotection.

Maintaining records of respirator inspections, respiratory protection training, fittesting, and medical determinations of fitness to wear respiratory protection.

Providing maintenance or access to maintenance for respirators.

Approving all purchases of respiratory equipment.

Remaining knowledgeable of new respiratory protection products orstandards.

The Engineering Personnel are responsible for:


Recommending less hazardous chemicals or substances be used rather thanmore hazardous ones whenever it is practical to do so.


Complying with this procedure and using the required respiratory protection.

Being clean shaven in the facial areas where the respiratory facepiece makesa seal with the wearer.



I17.4

Conferring with his / her Supervisor / designee as to the respiratory hazardsinvolved and the protection requirements associated with the job.

Inspecting the respiratory protection equipment prior to each use andmaintaining it in a good and clean condition.

Performing a positive-pressure or negative-pressure fit check each time arespirator is worn.

Advising supervision of any suggestions to improve the respiratory protectionprogram or the use or selection of protective equipment.

Advising supervision when experiencing any respiratory conditions that maybe related to occupational exposure of contaminants or hazardousatmospheres.

Requesting information from supervision about any portion of the respiratory

protection program that is not fully understood.

Having respiratory protection when it is required and using protectionwhenever there is the possibility of exposure to contaminants or hazardousatmospheres.

Changing cartridges and canisters as specified by supervision.

Definitions

Air-purifying respirator means a respirator with an air-purifying filter, cartridge, or

canister that removes specific air contaminants by passing ambient air through theair-purifying element.

Atmosphere-supplying respirator means a respirator that supplies the respirator userwith breathing air from a source independent of the ambient atmosphere, andincludes supplied-air respirators (SARs).

Canister or cartridge means a container with a filter, sorbent, or catalyst, orcombination of these items, which removes specific contaminants from the airpassed through the container.

Emergency situation means any occurrence such as, but not limited to, equipmentfailure, rupture of containers, or failure of control equipment that may or does resultin an uncontrolled significant release of an airborne contaminant.

Employee exposure means exposure to a concentration of an airborne contaminantthat would occur if the employee were not using respiratory protection.

Filter or air purifying element means a component used in respirators to removesolid or liquid aerosols from the inspired air.



I17.5

Filtering facepiece (dust mask) means a negative pressure particulate respirator witha filter as an integral part of the facepiece or with the entire facepiece composed ofthe filtering medium.

Fit factor means a quantitative estimate of the fit of a particular respirator to aspecific individual and typically estimates the ratio of the concentration of asubstance in ambient air to its concentration inside the respirator when worn.

Fit test means the use of a protocol to qualitatively or quantitatively evaluate the fit ofa respirator on an individual. (See also Qualitative fit test QLFT and Quantitative fittest QNFT.)

Helmet means a rigid respiratory inlet covering that also provides head protectionagainst impact and penetration.

High efficiency particulate air (HEPA) filter means a filter that is at least 99.97%efficient in removing monodisperse particles of 0.3 micrometers in diameter. Theequivalent NIOSH 42 CFR 84 particulate filters are the N100, R100, and P100 filters.

Hood means a respiratory inlet covering that completely covers the head and neckand may also cover portions of the shoulders and torso.

Immediately dangerous to life or health (IDLH) means an atmosphere that poses animmediate threat to life, would cause irreversible adverse health effects, or wouldimpair an individual's ability to escape from a dangerous atmosphere.

Loose-fitting facepiece means a respiratory inlet covering that is designed to form apartial seal with the face.

Negative pressure respirator (tight fitting) means a respirator in which the airpressure inside the facepiece is negative during inhalation with respect to theambient air pressure outside the respirator.

Oxygen deficient atmosphere means an atmosphere with oxygen content below19.5% by volume.

Physician or other licensed health care professional (PLHCP) means an individualwhose legally permitted scope of practice (i.e., license, registration, or certification)allows him or her to independently provide, or be delegated the responsibility toprovide, some or all of the health care services required by this program.

Positive pressure respirator means a respirator in which the pressure inside therespiratory inlet covering exceeds the ambient air pressure outside the respirator.

Powered air-purifying respirator (PAPR) means an air-purifying respirator that uses ablower to force the ambient air through air-purifying elements to the inlet covering.

Qualitative fit test (QLFT) means a pass/fail fit test to assess the adequacy ofrespirator fit that relies on the individual's response to the test agent.



I17.6

Quantitative fit test (QNFT) means an assessment of the adequacy of respirator fitby numerically measuring the amount of leakage into the respirator.

Respiratory inlet covering means that portion of a respirator that forms the protectivebarrier between the user's respiratory tract and an air-purifying device or breathingair source, or both. It may be a facepiece, helmet, hood, suit, or a mouthpiecerespirator with nose clamp.

Service life means the period of time that a respirator, filter or sorbent or otherrespiratory equipment provides adequate protection to the wearer.

Supplied-air respirator (SAR) or airline respirator means an atmosphere-supplyingrespirator for which the source of breathing air is not designed to be carried by theuser.

Tight-fitting facepiece means a respiratory inlet covering that forms a complete sealwith the face.

User seal check means an action conducted by the respirator user to determine ifthe respirator is properly seated to the face.

Requirements

Respirator Selection Procedures

Respirators used in the work place are selected based on:

A reasonable estimate of employee exposure to respiratory hazards and

Relevant work place and user factors.

Where the employee exposure cannot be identified or reasonably estimated, theatmosphere shall be considered IDLH.

Respirators selected shall be NIOSH certified and used within the conditionsof the NIOSH certification.

The number of respirator models and sizes offered by Moreno Group LLCand Subsidiaries will be sufficient to correctly fit any user.

Respiratory Hazard Evaluation

The employee respiratory hazard evaluation and identification of relevant workplaceand user factors may be found in the Attachments. The evaluation shall be updatedwhen new hazards or exposures are identified or job descriptions or job taskschange.

The table within Attachment 1 was developed from the evaluation and lists respiratorand cartridge selection based on the evaluation. After any update of the hazard



I17.7

evaluation the following table will be updated and the Respiratory Protectionprogram will be amended.

The following table lists the respirators by job description and task. With each joband respirator listed is the associated contaminant for which the respirator isauthorized and the cartridge’s required change schedule (maximum use time limit).

Respirator Use In Non-IDLH Atmospheres

Compliance with all OSHA statutory and regulatory requirements, under routine andreasonably foreseeable emergency situations shall be provided.

Moreno Group LLC and Subsidiaries’ requirements include Lead, 29 CFR1910.1025 and Air Contaminants, 29 CFR 1910.1000.

The respirator shall be appropriate for the chemical state and physical form ofthe contaminant.

Respirator Change Schedule

The change schedule is “week’s equivalent” replacement of the cartridge unlessrequired earlier by contaminant breakthrough suspicion or potential equipmentperformance deterioration. “Week’s equivalent” means 40 hour s of continuous use.

When the painting workload is heavier than normal and the respirator changeschedule based on “week’s equivalent” is suspect, the cartridge replacement cyclewill be reduced an appropriate amount.

When equipment inspection reveals the performance of the respirator is diminished,

such as, but not limited to head band elastic loss, valves not sealing, the respiratorwill be replaced.

Change Schedule Basis

The change schedule is based on a combination of manufacture’srecommendations, employee historical evidence of breakthrough-suspicion and pre-and post-use inspection observations.

Cartridges shall be selected from:

NIOSH certified HEPA,

Filter certified for particulates by NIOSH under 42 CFR part 84, or

Any filter certified by NIOSH for particulates.



I17.8

Respirator Use In IDLH Atmospheres

IDLH Atmosphere Routine Work

Moreno Group LLC and Subsidiaries’ employees shall not enter IDLH atmospheresfor routine work.

IDLH Atmosphere Non-routine Work

Moreno Group LLC and Subsidiaries’ employees shall not enter IDLH atmospheresfor non-routine work.

Oxygen Deficient Atmospheres

Oxygen-deficient atmospheres, that is atmospheres with less than 19.5 percentoxygen, shall be considered IDLH. Oxygen deficient atmospheres that cannot bemaintained within the range of 16.0 percent to 19.5 percent oxygen (at altitudes less

than 3,000 feet) cannot be entered under any circumstances.

Medical Evaluation Procedures

The medical evaluation is completed to determine the employee’s abil ity to use arespirator. Respirator use may be limited by the physiological burden placed on theemployee due to the respirator worn, the job and work place conditions in which therespirator is used, and the medical status of the employee.

Medical Evaluation

A medical evaluation is required before an employee is fit tested or requiredto wear a respirator in the work place.

The medical evaluations for Moreno Group LLC and Subsidiaries will be atdesignated Occupational Health Clinics.

The initial medical evaluation may be administered as a questionnaire.

Medical Questionnaire

The medical evaluation consists of a medical questionnaire. An initial medical

examination that obtains the same information as the questionnaire is alsoacceptable.

Follow-up Medical Examination

A follow-up medical examination is required for any employee who givespositive response to any question among questions 1 through 8 in Section 2,Part A on the medical questionnaire.



I17.9

A follow-up medical examination is required for any employee whose initialmedical examination indicates the need for a follow-up examination.

The follow-up medical examination consists of any medical tests,consultations, or diagnostic procedures that the PLHCP deems necessary tomake an employee fitness to use respiratory protection determination.

Medical Questionnaire and Examination Administration

Administer the questionnaire and examinations confidentially during theemployee’s normal working hours or at a time and place convenient to theemployee.

Administer the questionnaire content in a manner that ensures the employeeunderstands.

The employee shall have the opportunity to discuss the questionnaire andexamination results with the PLHCP.

Supplemental Information for the PLHCP

Information Submittal

Provide the following information to the PLHCP before the PLHCP makes arecommendation concerning individual respirator use. When information remainsthe same, it needs to be submitted only once. Provide:

The type and weight of the respirator

The duration and frequency of routine respirator use and emergencyrespirator use.

Expected physical work effort.

Additional protective clothing and equipment to be worn, and

Expected temperature and humidity extremes.

A copy of the respiratory protection program.

Changing PLHCPs

When a PLHCP is changed the information shall be provided to the newPLHCP directly from Moreno Group LLC and Subsidiaries or transferred fromthe former PLHCP to the new PLHCP.

Employees do not have to be reevaluated when PLHCPs are changed.



I17.10

Medical Determination

Moreno Group LLC and Subsidiaries shall do the following to determine anemployee’s ability to use a respirator.

Obtain the PLHCP’s written recommendation regarding the employee’s abilityto use the respirator. Include only the following in the recommendation.

Any respirator use limitations due to medical condition or work placeconditions including the employee’s fitness to wear the respirator.

The need for follow-up medical evaluations if required, and

A PLHCP’s statement the employee was provided with a copy of thePLHCP’s written recommendations.

For negative pressure respirator use, a negative finding by the PLHCP orother qualified person means Moreno Group LLC and Subsidiaries will:

Examine the reason for the negative finding with the help of the PLHCP orother qualified person.

Investigate alternative respiratory protection.

Provide alternative respiratory protection as required to ensure the employeeis provided with adequate respiratory protection.

Additional Medical Evaluation

An additional medical evaluation will be provided to employees under the followingconditions:

The employee reports medical signs or symptoms that are related to theability to use a respirator,

A PLHCP, Superintendent, Foreman, or the program administratordetermines that an employee needs to be reevaluated,

Program information, including fit testing observations and programevaluation that indicates a need for employee reevaluation, or

Changes to work place conditions, that is, physical work effort, protectiveclothing, temperature, that result in a substantial increase in the physiologicalburden on the employee.



I17.11

Fit Testing Procedures

Employees using a tight-fitting facepiece respirator must pass a qualitative fit test(QLFT) or a quantitative fit test (QNFT). The employee must be fit tested with thesame make, model, style, and size of respirator that will be used by the employee.The fit QLFT and QNFT protocols and procedures available for Moreno Group LLCand Subsidiaries’ use are stated in the OSHA Respiratory Protection Regulation 29

CFR 1910.134.

Fit Testing Schedule

Before an employee may use any negative or positive pressure tight-fittingrespirator the employee must be fit tested.

Fit testing shall be conducted whenever a different respirator facepiece (size,style, model, or make) is used and then annually.

Changes in the employee’s physical condition that could affect respirator fit

shall require re-fit testing. Some examples include obvious changes in bodyweight, facial scarring, and dental changes.

Fit Testing Considerations

Respirators may need to be modified before fit testing. Remove anymodifications to the respirator so it is restored to NOISH-approvedconfiguration before using the facepiece in the workplace

The test shall not be conducted if there is any hair growth between the skinand the facepiece sealing surface, such as stubble beard growth, beard,

mustache or sideburns which cross the respirator sealing surface. Any type ofapparel, which interferes with a satisfactory fit, shall be altered or removed.

Qualitative Testing (OLFT)

Qualitative fit tests shall be used to fit test only negative pressure air-purifyingrespirators that are used for a fit factor of 100 or less.

Qualitative fit tests shall be conducted using the employee’s actual respirator.Convert the facepiece into a negative pressure respirator if it is not already anegative pressure respirator. Use appropriate filters for negative pressure

respirators or an identical surrogate for the atmosphere supplying or PAPRfacepiece and convert to a negative pressure respirator.

Quantitative Testing (ONFT)

Quantitative fit tests are passed only when a tight-fitting facepiece fit factor of100 or more has been achieved for half-facepieces and 500 or more hasbeen achieved for full facepieces.



I17.12

Quantitative fit testing shall require sampling inside the facepiece midwaybetween the nose and the mouth of the employee. Modification of theemployee’s respirator with a temporary sampling adapter or surrogaterespirator modification to accept a permanent sampling probe is required.

Respirator Use Procedures

Procedures include proper use for routine and reasonably foreseeable emergencysituations. The following procedures establish proper use of respirators. Proceduralrequirements include:

Prohibiting facepiece seal leakage,

Preventing removal of respirators in hazardous environments,

Ensuring continued effective respirator operation throughout the work shift,

And

Preventing use of respirators in IDLH atmosphere without approval of theadministrator and prior development of specific written procedures.

Facepiece Seal Protection

Conditions That Will Prevent Employees Wearing Tight -Fitting FacepieceRespirators

When facial hair comes between the sealing surface of the facepiece,

When facial hair interferes with valve function, and

When any condition interferes with the face-to-facepiece seal or valvefunction.

Ensure Tight Fitting Respirator Seals To The Employee’s Face

Ensure corrective glasses or goggles or other personal protective equipmentis worn in a manner that does not interfere with the seal of the facepiece tothe face.

Ensure the employee performs a user seal check each time the respirator isput on. Use the following procedure. The user seal check is not a substitutefor qualitative or quantitative fit testing.



I17.13

Facepiece Positive and/or Negative Pressure Checks

Positive Pressure Check.

Close off the exhalation valve and exhale gently into the facepiece. The facefit is considered satisfactory if a slight positive pressure can be built up insidethe facepiece without any evidence of outward leakage of air at the seal. For

most respirators this method of leak testing requires the wearer to firstremove the exhalation valve cover before closing off the exhalation valve andthen carefully replacing it after the test.

Negative Pressure Check.

Close off the inlet opening of the cartridges by covering with the palm of thehand(s) or by replacing the filter seal(s), inhale gently so that the facepiececollapses slightly, and hold the breath for ten seconds. The design of the inletopening of some cartridges cannot be effectively covered with the palm of thehand. In this case, perform the test by covering the inlet opening of the

cartridge with a material so that no air may pass the inlet opening. If thefacepiece remains in its slightly collapsed condition and no inward leakage ofair is detected, the tightness of the respirator is considered satisfactory.

Manufacturer's Recommended User Seal Check Procedures

The respirator manufacturer's recommended procedures for performing auser seal check may be used instead of the positive and/or negative pressurecheck procedures provided that the employer demonstrates that themanufacturer's procedures are equally effective.

Ensure Continuing Respirator Effectiveness

The First Line Supervisor or Superintendent shall provide appropriatesurveillance of the work area conditions and degree of employee exposure orstress. When there is a change in work area conditions or degree ofemployee exposure or stress that may affect respirator effectiveness,respirator use shall be reevaluated. To reevaluate respirator use, contact theProgram Administrator.

The employee shall leave the respirator use area for the following reasons:

To wash faces and respirator facepieces as necessary to prevent eye orskin irritation from respirator use, or

If vapor or gas breakthrough, changes in breathing resistance , orfacepiece leakage is detected, or

To replace respirators, the filter, or the cartridge.



I17.14

If vapor or gas breakthrough, changes in breathing resistance or leakageof the facepiece are detected, Moreno Group LLC and Subsidiaries willreplace or repair the respirator before allowing the employee to return tothe work area.

IDLH Atmosphere Non-routine Work

Moreno Group LLC and Subsidiaries’ employees shall not enter IDLH atmospheresfor non-routine work.

Respirator Maintenance

Procedures include schedules for cleaning, disinfecting, storing, inspecting,repairing, discarding, and otherwise maintaining respirators.

Cleaning and Disinfecting

Moreno Group LLC and Subsidiaries shall provide employees with respirators

that are clean, sanitary, and in good working order.

Employees shall keep, respirators clean, sanitary, and in good working order.

Respirators issued to more than one employee shall be cleaned anddisinfected following use by the employee who used the respirator. Therespirator shall be cleaned and disinfected before the respirator is providedfor the next employee.

Respirators issued for exclusive use shall be cleaned and disinfected aftereach use or more often to maintain the respirator in sanitary condition.

Respirators used in fit testing and training shall be cleaned and disinfectedafter each use.

Use the procedures described in OSHA 29 CFR 1910.134 Appendix B-2 toclean and disinfect respirators. The procedures are general in nature, andthe employee, as an alternative may use the cleaning recommendationsprovided by the manufacturer of the respirators. The alternative proceduresmust also ensure that the respirator is properly cleaned and disinfected in amanner that prevents damage to the respirator and does not cause harm tothe user.

Test the respirator to ensure that all components work properly after therespirator is cleaned and reassembled.



I17.15

Storage

Employees shall store respirators as follows:

Respirators shall be protected from damage, contamination, dust, sunlight,extreme temperatures, excessive moisture, and damaging chemicals, andthey shall be packed in a container to prevent deformation of the facepiece

and exhalation valve.

Emergency respirators shall not be routinely used by Moreno Group LLC andSubsidiaries’ employees. In the event that the administrator deems they arenecessary for non-routine work, the program administrator shall provide aprocedure for respirator use consistent with the OSHA Respiratory ProtectionRegulation, 29 CFR 1910.134.

Inspection

Respirators shall be inspected by the employee as follows:

Respirators shall be inspected before each use and during cleaning.

Respirator inspections shall include the following:

Check for function, tightness of connections, and the condition of thevarious parts including, but not limited to, the facepiece, head straps,valves, connecting tube, and cartridges, and filters.

Check plastic and rubber parts for pliability and signs of deterioration.

Repairs

Respirators that fail inspection or are otherwise defective shall be removedfrom service and discarded, repaired, or adjusted.

Respirator repair shall be performed by Program Administrator authorizedpersons.

Authorized persons include Safety Department Safety Managers orcoordinators or persons working directly under the manager orcoordinators’ direction.

Repairs shall be made according to the manufacturer’s recommendationsand specification for the type and extent of repairs to be performed. At notime shall respirator parts for one make or type respirator be used on arespirator of another make or type.



I17.16

Breathing Air Quality and Use

Procedures are included to ensure adequate air quality, quantity, and flow ofbreathing air for atmosphere-supplying respirators.

Air Quality

Moreno Group LLC and Subsidiaries will provide employees using supplied-airrespirators with breathing gases of high purity.

Employees will not use self-contained breathing apparatus for routine work.In the event that the program administrator deems SCBA is necessary fornon-routine work, the program administrator shall provide a procedure forrespirator use consistent with the OSHA Respiratory Protection Regulation,29 CFR 1910.134.

Compressed or liquid oxygen shall not be used for respiration.

Compressed breathing air shall meet at least the following requirements forGrade D breathing air. The requirements are described in ANSI/CompressedGas Association Commodity Specification for Air, G-7.1-1989.

Oxygen content (volume/volume) of 19.5 percent to 23.5 percent;

Hydrocarbon (condensed) content of 5 milligrams per cubic meter of air orless;

Carbon monoxide (CO) content of 10 ppm or less;

Carbon dioxide (CO2) content of 1,000 ppm or less; and

Lack of noticeable odor.

Supplied Air Cylinders

When SAR requirements are met by supplying air from compressed aircylinders, the cylinders shall be tested and maintained as prescribed in theShipping Container Specification Regulations of the Department ofTransportation (49 CFR part 173 and part 174); the air shall have a certificateof analysis from the supplier that the breathing air meets the requirements for

Grade D breathing air and the moisture content in the cylinder does notexceed a dew point of –50 degrees Fahrenheit at 1 atmosphere pressure.

Supplied Air Compressors

Breathing air compressors shall be constructed and situated so as to:

Prevent entry of contaminated air into the air-supply system;



I17.17

Minimize moisture content so that the dew point at 1 atmosphere pressure is10 degrees Fahrenheit below the ambient temperature;

Have suitable in-line air-purifying sorbent beds and filters to further ensurebreathing air quality. Sorbent beds and filters shall be maintained andreplaced or refurbished periodically following the manufacturers instructions.Maintain at the compressor a tag containing the most recent change date and

the signature of the superintendent or foreman who performed the change.

For non-oil lubricated compressors, ensure the carbon monoxide level in thebreathing air does not exceed 10 ppm.

For oil lubricated compressors ensure a high-temperature or carbonmonoxide alarm (or both) monitor carbon monoxide levels. If only high-temperature alarms are used, the air supply shall be monitored at intervalssufficient to prevent carbon monoxide in the breathing air from exceeding 10ppm.

Ensure breathing air couplings are incompatible with outlets for non-respirable worksite air or other gas systems. No asphyxiating substance shallbe introduced into breathing air lines.

Ensure breathing gas containers are marked in accordance with the NOSIHrespirator certification standard, 42 CFR part 84

Filters and Cartridges

Filters and cartridges used in the workplace shall be labeled and color-codedwith the NIOSH approved label. Ensure the label is not removed and remains

legible.

Training Procedures

Training provisions provide effective training to employees who are required to userespirators. The training shall be comprehensive, understandable, and shouldinclude the following: Hazards, proper use, provision, information, evaluation, andrecordkeeping.

Training on Respirator Hazards

Provisions include hazards to which employees are potentially exposedduring routine situations.

Training on Proper Respirator Use

Ensure employees can demonstrate knowledge of at least the following:

Why the respirator is necessary, how improper fit, usage, or maintenance canreduce the protective effect of the respirator;



I17.18

The limitations and capabilities of the respirator;

How to inspect, put on and remove, use, and check the seals of therespirator;

Procedures for respirator maintenance and storage;

Recognition of medical signs and symptoms that may limit or preventrespirator effective use;

General requirements of the Respiratory Protection standard, 29 CFR1910.134.

Training Provision

Provide training prior to requiring the employee to use a respirator in theworkplace.

When a new employee can demonstrate receipt of training within the last 12months that addresses the elements specified above, the employee is notrequired to repeat the training, provided that the employee can demonstrateknowledge of the elements by examination. The new employee must haverepeat training within 12 months from the date of the previous training.

Retraining shall be administered annually, or earlier, when the followingconditions occur:

Changes in the workplace or the type of respirator render the previoustraining obsolete;

Inadequacies in the employee’s knowledge or use of the respiratorindicate that the employee has not retained the knowledge;

Any other situation arises in which retraining appears necessary to ensuresafe respirator use.

Information for Employees Using Respirators When Not Required Under theStandard

Respirators are an effective method of protection against designated hazardswhen properly selected and worn. Respirator use is encouraged, even whenexposures are below the exposure limit, to provide an additional level ofcomfort and protection for workers. However, if a respirator is used improperlyor not kept clean, the respirator itself can become a hazard to the worker.Sometimes, workers may wear respirators to avoid exposures to hazards,even if the amount of hazardous substance does not exceed the limits set byOSHA standards.



I17.19

If a respirator is provided by Moreno Group LLC and Subsidiaries forvoluntary use, of if the respirator is employee provided, certain precautionsare required to be sure that the respirator itself does not present a hazard.The following is required:

Read and heed all instructions provided by the manufacturer on use,maintenance, cleaning and care, and warnings regarding the respirators

limitations.

Choose respirators certified for use to protect against the contaminant ofconcern. NIOSH, the National Institute for Occupational Safety and Healthcertifies respirators. A label or statement of certification should appear onthe respirator or respirator packaging. The label or statement ofcertification will tell you what the respirator is designed for and how muchit will protect you.

Do not wear the respirator into atmospheres containing contaminants forwhich the respirator is not designed to protect against. For example, a

respirator designed to filter dust particles will not protect against gases,vapors, or very small solid particles of fumes or smoke.

Keep track of the respirator so that one employee’s respirator is notmistakenly used by someone else.

Program Evaluation Procedures

Program evaluation shall be conducted to ensure that the written program is properlyimplemented and employees are using respirators properly.

Provisions of the written program shall be evaluated to ensure they havebeen implemented and are effective.

Employees shall be regularly consulted to assess the employees’ views onprogram effectiveness and to identify any problems. Problems identified shallbe corrected. Factors to be assessed at least include:

Respirator fit (including respirator use without interfering with workplaceperformance)

Appropriate selection for the hazards to which the employee is exposed.

Proper respirator use.

Proper respirator maintenance.



I17.20

Record Keeping

Records must be maintained for medical evaluations, fit testing, and the respiratorprogram. The records shall be available to facilitate employee involvement in theprogram, assist in auditing adequacy of the program and provide a record forcompliance determinations by OSHA.

Medical Records

Ensure records are retained and made available in accordance with 29 CFR1910.1020.

Fit Testing

Ensure records of qualitative and quantitative fit tests administered toemployees are retained including:

Name or identification of employee tested.

Type of fit test performed

Specific make, model, style, and size of respirator tested,

Date of test, and

Pass/fail result for QLFTs or the fit factor and strip chart recording or otherrecording of the test results of QNFTs.

Fit test records shall be retained for respirator users until the next fit test is

administered.

Note: Moreno Group LLC and Subsidiaries Inc. reserves the right to change thispolicy at their discretion.

Written Respiratory Protection Program

A written copy of the current program shall be retained by the Program Administrator. Current copies shall be distributed as needed to First LineSupervisors and Offshore Superintendents and foremen who have respirator users.



I17.21

Attachment 1





I17.21

Moreno Group LLC and Subsidiaries Respirator Requirements

Job Description Job Task Respirator and Cartridge ContaminantMaximum Change

Schedule

Onshore Painter Paint3M 5301 (L) oranic vaporwith 5P71 prefilter

expoxies, VOC based paints, Urethanes 900paints,Solvents

8 hour orbreakthrough

Onshore PainterMixing/Cleaning-3M

3M 5301 (L) oranic vaporwith 5P71 prefilter

expoxies, VOC based paints, Urethanes 900paints,Solvents


Blaster Blasting Supplied Air BlasthoodSilica,Quartz,Cristobalite,Trydimite,Respirabledust




I17.21.a.2

The following table lists the respirators by job description and task. With each job and respirator listed is the associated contaminant for which therespirator is authorized and the cartridge’s required change schedule (maximum use time limit). Respirator Selection Table for all Moreno Group LLC andSubsidiaries Locations (onshore and offshore)

JobDescription

JobTask Respirator and Cartridge Contaminant

Maximum ChangeSchedule

Supplied Air Blasthood Primary

3M 5101 (S) organic vapor with 5P71 prefilter (onlywith Project Manager or Designee approval)

Inorganic Zinc 8 hour or breakthrough

OnshorePainter

Paint3M 5201(M) organic vapor with 5P71 prefilter (onlywith supervisor’s approval)

Epoxies (incl. coal tar) 8 hour or breakthrough

3M 5301 (L) organic vapor with 5P71 prefilter (only VOC based paints 8 hour or breakthrough

with supervisor’s approval) Urethanes 8 hour or breakthrough

Solvents 8 hour or breakthrough

Supplied Air Blasthood Primary 8 hour or breakthrough 3M 5101 (S) organic vapor with 5P71 prefilter (onlywith Project Manager or Designee approval)

Inorganic Zinc 8 hour or breakthrough

OffshorePainter

Paint3M 5201(M) organic vapor with 5P71 prefilter (onlywith Project Manager or Designee approval)

Epoxies (incl. coal tar) 8 hour or breakthrough

3M 5301 (L) organic vapor with 5P71 prefilter (only VOC based paints 8 hour or breakthrough

with Project Manager or Designee approval) Urethanes 8 hour or breakthrough


3M 5101 (S) organic vapor with 5P71 prefilter Inorganic Zinc 8 hour or breakthrough

Onshore Mixing/Cleaning-3M 3M 5201(M) organic vapor with 5P71 prefilter Epoxies (incl. coal tar) 8 hour or breakthrough

Painter 3M 5301 (L) organic vapor with 5P71 prefilter VOC based paints 8 hour or breakthrough

Urethanes 8 hour or breakthrough


3M 5101 (S) organic vapor with 5P71 prefilter Inorganic Zinc 8 hour or breakthrough

Offshore Mixing/Cleaning-3M 3M 5201(M) organic vapor with 5P71 prefilter Epoxies (incl. coal tar) 8 hour or breakthrough

Painter 3M 5301 (L) organic vapor with 5P71 prefilter VOC based paints 8 hour or breakthrough

Urethanes 8 hour or breakthrough


Helper Welding help 3M 6000 with 2097 filter Zinc 8 hour or breakthrough Welder Welding 3M 6000 with 2097 filter Galvenize/Lead 8 hour or breakthrough

Helper Welding help 3M 6000 with 2097 filter Galvenize/Lead 8 hour or breakthrough

Blaster Blasting Supplied Air BlasthoodSilica, Quartz, Cristobalite,Trydimite, Respirable dust

N/A

WelderWelding in Confined

Space

3M 6101 (s) with 2097 filter

3M 6201 (m) with 2097 filter

3M 6301 (l) with 2097 filter

Organics, Fumes 8 hour or breakthrough

WelderWelding on StainlessSteel or Exotic Metals

3M 6101 (s) with P-100 filter

3M 6201 (m) with P-100 filter

3M 6301 (l) with P-100 filter - also refer to HexavalentChromium Program.

Hexavalent Chromium 8 hour or breakthrough



I17.21

Moreno Group LLC and Subsidiaries Industrial Service, LLCJob

DescriptionJob Task

Respirator and Cartridge ContaminantMaximum Change

Schedule

Laborer/Helper Assist with first flange 3M 6000 organic vapor cartridge Benzene > 1ppm - <25ppm 8 hour or breakthroughbreak Full Face Scott AV 2000 organic vapor cartridge Benzene >25ppm - <50ppm

HF Acid >3ppm - < 6ppmH2S >5ppm- < 15ppm

8 hour or breakthrough

Assist with environmental cleanup

Supplied air Respirator Benzene >50ppmHF Acid >6ppmH2S >15ppmUnknown concentration of anyof the above contaminants

N/A

Helper Welding help 3M 6000 with 2097 filter ZincGalvanize/Lead 8 Hours or breakthrough

Boilermaker First flange break 3M 6000 organic vapor cartridge Benzene > 1ppm - <25ppm 8 Hours or breakthrough

Hot Bolt work Full Face Scott AV 2000 organic vapor cartridge Benzene >25ppm - <50ppmHF Acid >3ppm - < 6ppmH2S >5ppm – <15ppm

8 Hours or breakthrough

Supplied air Respirator Benzene >50ppmHF Acid >6ppmH2S >15ppm

N/A

Painter Mixing/Cleaning-3M 3M 6000 organic vapor with prefilter Inorganic Zinc 8 Hours or breakthrough

Epoxies (incl. coal tar) 8 Hours or breakthrough

VOC based paints 8 Hours or breakthrough

Urethanes 8 Hours or breakthrough

Solvents 8 Hours or breakthrough

Welder Welding 3M 6000 with 2097 filter Galvanize/Lead 8 Hours or breakthroughWelder Welding in Confined Space 3M 6101 with 2097 filter Organics, Fumes 8 Hours or breakthrough

Welder Welding on Stainless Steel orExotic Metals

3M 6101 with P-100 filter - also refer to HexavalentChromium Program.

Hexavalent Chromium8 hours or breakthrough

Pipe Fitter Welding help 3M 6000 with 2097 filter ZincGalvanize/Lead

8 Hours or breakthrough

Pipe Fitter Welding help on Stainless Steel orExotic Metals

3M 6101 with P-100 filter - also refer to HexavalentChromium Program.

Hexavalent Chromium8 hours or breakthrough

Blaster Blasting Supplied Air Blasthood Silica, Quartz, Cristobalite,Trydimite, Respirable dust

N/A

Instrument Technician Breaking into Instrument Lines Supplied Air Hydrogen/NitrogenOther unknown gases

N/A

Millwright Work on process 3M 6000 organic vapor cartridge Benzene > 1ppm - <25ppm 8 hour or breakthrough

pumps Full Face Scott AV 2000 organic vapor cartridge Benzene >25ppm - <50ppmHF Acid >3ppm - < 6ppmH2S >5ppm- < 15ppm

8 hour or breakthrough

Supplied air Respirator Benzene >50ppmHF Acid >6ppmH2S >15ppmUnknown concentration of any ofthe above contaminants

N/A



I17.21.a.4

Respirator Selection Table for Moreno Group LLC and Subsidiaries

Insulator Asbestos Abatement North, 550030 / HEPA Cartridge 7581, P100 Airborne Asbestos Fiber8 hour or breakthrough

Carpenter Spray Painting North, 550030 / 75001, OV Organic Vapor 8 hour or breakthrough

All Trades Mold Abatement North, 550030 / HEPA Cartridge 7581, P100 Mold, Mold Spore 8 hour or breakthrough

Cleaning Tech Tank Cleaning* (Confined Space) Scott Full Face SAR (Or Equivalent) Environment NA

Cleaning TechTank Cleaning(From Outside)

Scott Full Face Neg. Pressure / 642-OV-T100(Cartridge will vary depending on contaminant)

Material being removed 8 hour or breakthrough

Cleaning Tech Rescue Scott Pac Full Face SAR (Or Equivalent) Environment NA

* We stay on air in allenvironments wherethere may beunknowncontaminants, or highend CO, or low endO2. We never enterIDLH atmospheres



I17.21.a.5

Assig ned Protection Factors (APFs) Employers must use the assigned protection factorslisted in Table 1 to select a respirator that meets or exceeds the required level of employeeprotection. When using a combination respirator (e.g., airline respirators with an air-purifyingfilter), employers must ensure that the assigned protection factor is appropriate to the modeof operation in which the respirator is being used.

Table 1. -- Assigned Protection Factors5 Type of respirator 1, 2 Quarter

maskHalf

maskFull

facepieceHelmet/

hoodLoose-fitting

facepiece1. Air-Purifying Respirator 5 310 50 .............. ..............2. Powered Air-Purifying

Respirator (PAPR).............. 50 1,000 425/1,000 25

3. Supplied-Air Respirator(SAR) or Airline Respirator

• Demand mode • Continuous flow mode • Pressure-demand or

other positive-pressuremode

..............

..............

..............

105050

501,0001,000

..............425/1,000..............

..............25

..............

4. Self-Contained Breathing

Apparatus (SCBA)• Demand mode • Pressure-demand or

other positive-pressuremode (e.g., open/closedcircuit)

..............

..............10

..............50

10,00050

10,000............................

Notes:1Employers may select respirators assigned for use in higher workplace concentrations of ahazardous substance for use at lower concentrations of that substance, or when requiredrespirator use is independent of concentration.

2The assigned protection factors in Table 1 are only effective when the employerimplements a continuing, effective respirator program as required by this section (29 CFR

1910.134), including training, fit testing, maintenance, and use requirements.3This APF category includes filtering facepieces, and half masks with elastomericfacepieces.

4The employer must have evidence provided by the respirator manufacturer that testing ofthese respirators demonstrates performance at a level of protection of 1,000 or greater toreceive an APF of 1,000. This level of performance can best be demonstrated byperforming a WPF or SWPF study or equivalent testing. Absent such testing, all otherPAPRs and SARs with helmets/hoods are to be treated as loose-fitting facepiecerespirators, and receive an APF of 25.

5These APFs do not apply to respirators used solely for escape. For escape respiratorsused in association with specific substances covered by 29 CFR 1910 subpart Z,employers must refer to the appropriate substance-specific standards in that subpart.

Escape respirators for other IDLH atmospheres are specified by 29 CFR 1910.134 (d)(2)






Management SystemAir Tugger / Winch Operations

Page:Original: 01/01/2010Revised:

J1.1

Air Tugger / Winch OperationsPurpose

The purpose of this policy is to establish and set guidelines for the safe use of material

handling equipment related to Air Tugger Operations

Scope

This procedure applies to all Moreno Group, LLC and Subsidiaries employees,non-permanent employees and sub-contract employees who operate, use, inspect,maintain or work around air tugger operations.

Responsibilities

The Facility Manager / Yard Manager / Offshore Manager or Designee is

responsible for:

Continually communicated to First Line Supervision the employees’ right to use“STOP WORK AUTHORITY”.

Assuring compliance with this procedure.

Evaluating air tugger needs for the facility / site, preparing detailed purchase /rental specifications and providing sufficient equipment to support the needs ofMoreno Group, LLC and Subsidiaries.

Assuring the equipment is operated and maintained in a safe manner and inaccordance with equipment manufacturer’s recommendations.

Assuring that equipment operators are properly trained and qualified to operatespecific equipment.

Ensuring that no modifications or additions are made to equipment without themanufacturer’s written approval.

Ensuring that all work group investigations, significant incidents, propertydamage reports, and general information regarding mobile / motorized equipment

is communicated to applicable employees.

Informing all Contractors of this procedure during the project meeting and ensurethe Contractor follows the requirements of this procedure.

Ensuring air tugger / winch operations procedure is reviewed and approved for allvertical and multi-tugger lifts

Approving of the spooling of air tugger / winches offshore.



J1.2


Understanding and enforcing the provisions of this procedure.

STOP WORK anytime any employees are in question of the lift, lift operation,lifting equipment, lifting accessories or work activities around lift operation.

Identify the hazardous area (Red Zone) around operating equipment, and notifyall affected personnel of this area.

Conferring with personnel reporting to them as to the hazards of specific jobs andthe air tugger to be used.

Assuring that equipment is inspected, operated and maintained in accordancewith this procedure and the manufacturer’s recommendations.

Assuring recommended power supply input for best performance.

Assuring that only trained, authorized and physically fit personnel operate andmaintain equipment.

Assisting in the evaluation of operator competency.

Ensuring no one places their hands on the cable while the air tugger isconnected to the power source.

Assuring a detailed Job Safety and Environmental Analysis (JSEA) is developedand followed for the air tugger operations.

Sending approved air tugger operations procedure and JSEA to OperationsManager for approval prior to starting operation

The Equipment Operator is responsible for:

Use “STOP WORK AUTHORITY” anytime the operator is questioning the lift orlift operation, lifting equipment, lifting accessories or work activities around liftoperation.

Complying with this procedure and operating equipment safely.

Remaining alert and not operating equipment if mentally or physically impaired.Consulting with the supervisor if taking either over-the-counter or prescriptionmedication.

Conferring with supervision as to hazards involved or associated with the job.

Surveying the work areas for hazards and erecting barricades.

Operating only equipment for which they have been trained.



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Reading and being familiar with the manual for the equipment being operatedand operating the equipment as intended by the manufacturer.

Never operating equipment that is unsafe and in need of repair.

Performing and documenting the pre-use / shift inspection.

Check brake operation, by lifting load a short distance and releasing control.

Be aware of shut-off valve or electrical disconnect location and proper operation.

Confirm that winch inspections and lubrication checks have been completed


Notifying supervision of any significant incidents, property damage or nearmisses with regards to mobile / motorized equipment.

Participating in the task JSEA and ensuring the lift team follows the JSEA aswritten. If any changes occur during the lift, ensuring the operation is stoppedand the JSEA is revisited.

The Signal Person is responsible for:

Providing clear signals and being able to recognize hazards and signal theoperator to avoid them (see Attachment 1).

Use “STOP WORK AUTHORITY” anytime the signal person is questioning the lift

or lift operation, lifting equipment, lifting accessories or work activities around liftoperation.


The Personnel Working around Equipment is responsible for:

Use “STOP WORK AUTHORITY” anytime any employee is questioning the lift orlift operation or work activities around lift operation.

Knowing of the hazards of working around equipment.

Keeping a safe distance from operating equipment.

Staying out of designated “Red Zone”.

Obeying all signs, and barricades.



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Never getting on or off moving equipment.

Remaining alert and responding as necessary when an equipment warningdevice is heard.

Never walking or working below a raised load on equipment.


Definitions

Qualified Operator - A person who has received and successfully completed anappropriate air tugger / winch operators training, authorized by the Moreno Group, LLCand Subsidiaries to operate the equipment and meets the following physicalqualifications:

Have vision of at least 20/30 Snellen in one eye and 20/50 in the other with orwithout glasses, and have no depth perception problems.

Be able to distinguish red, green and yellow, regardless of position of colors, ifcolor differentiation is required to crane operation.

Have hearing, with or without a hearing aid, adequate for the specific operation.

Have sufficient strength, endurance, agility, coordination and speed of reaction tomeet the demands of equipment operations

Evidence of physical limitations or emotional instability that could render theoperator a hazard to himself or other or which in the opinion of the examinercould interfere with the operator’s safe performance, may be cause fordisqualification.

Evidence that an operator is subject to seizures or loss of physical control shallbe reason for disqualification.

Operators should have good depth perception, field of vision, reaction time,manual dexterity, coordination and should not be prone to dizziness or similarundesirable characteristics.

Qualified Inspector - A person who has received and successfully completed theappropriate air tugger / winch maintenance and is designated by the employer.

Qualified Rigger – A rigger is anyone who attaches or detaches lifting equipment toloads or lifting equipment and/or anyone who directs or signals a lift operation. Thisperson shall have the training and experience and who has successfully completed APIRP 2d rigger training program.



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Pre-use Inspection - An inspection that is performed daily by the qualified operator.This type of inspection shall be conducted prior to beginning each new shift.

Designated Personnel - Only designated personnel shall be permitted to operate an airtugger covered by this policy.

Red Zone- Designated area around air tugger operations that must be clear of all non-

essential personal before operation begins.

Requirements

Air Tugger / Winch Installation

Installation personnel should be trained and knowledgeable in air tugger / winchinstallation. During the installation of an air tugger, never weld on any part of thewinch. All supporting structure, mounting hardware and load attaching hardware mustbe in accordance with all applicable standards, codes and regulations. When movingthe winch, ensure proper rigging is used and the lift is not made over personnel.

Prior to the installation of the air tugger on location, the installation team shall perform asite assessment as part of the Job Safety and Environmental Analysis (JSEA) process.This site assessment shall be performed where the air tugger will be mounted and theentire path that the load will be taking. The path shall be evaluated to ensure allobstacles are removed prior to the installation of the tugger. If an obstacle is unable tomoved, a different plan shall be developed. In addition to the path being evaluated, theassessment shall ensure that the mounting surface will be large enough for air tugger /winch and the operator. Refer to air tugger / winch the Manufacture’s ProductInformation Manuals for specific information on mounting surface requirements,attaching hardware and power supply requirements. This assessment shall include the

evaluation of the operator ’s ability to reach all controls comfortably and observe loadsduring operation.

The installation team shall check that sufficient space is available to operate winchcontrol, manual brake or other components and to make inspections or adjustmentswhen necessary. No welding shall be performed on the winch portion of the air tuggersince this process can change the physical properties of some of the parts, which canaffect strength or durability. In addition to the possibility of changing the physicalproperties, the excessive heat can be generated which can affect and/or damageinternal parts such as seals and bearings.

Once the appropriate location has been determined by the installation team, the areashall be hard barricaded prior to any deck penetrations are made to access the maindeck beams.

The air tugger / winch shall be welded directly to the deck beams with the use of plateclips (dogs). Both the installation procedure and number of plate clips need to beevaluated and approved by the Facility’s Registered Structural Engineer

Note: The only exception to this rule will be for 1 ton air tuggers / winch. The tie downof this piece of equipment can be performed by use of certified Alloy Grade 80 riggingchain.



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Installation of Air Tugger / Winch for Onshore Operations

Installation of an air tugger / winch within an onshore facility, the ability to weld the airtugger / winch to the structure may not be an option. If during the installation the airtugger / winch is unable to be welded to the facility, it maybe tied down by use ofcertified Alloy Grade 80 rigging chains.

Note: The preferred method of tie down will be appropriately welding down the airtugger / winch onto the facility.

Warning Labels and Tags

Installation personnel shall not remove or obscure any warning label(s) or tag(s). Theseindividuals shall ensure warning label(s) or tag(s) are visible to the personnel in thearea. If warning label(s) or tag(s) are damaged, illegible or become lost, contact therental company for replacements.

Data Plate

Ensure that data (name) plate is attached and readable. Replacement data (name)plates are available when complete winch serial number is provided to the manufacture.

Power Supply

To ensure the best performance with any power supplied (electrical, hydraulically orpneumatic) to the winch; it must meet the manufactures specifications for the air tugger/ winch. The recommended power supply for an air tugger / winch can be located in theManufacture’s Product Information Manual.

Should a power supply of less than recommended be used, this will result in reducedwinch performance and may cause some items such as brakes, overload valves or limitswitches to function incorrectly. Exceeding the power supply can cause winch to exceedrated performance in addition, brakes, overload sensors, limit switches/valves may notfunction correctly.

In those cases where electrical power is used to as a power source to the operations, alicensed electrician shall install, properly ground and commission the electrical powersource to these operations.

Electric winches can also be affected by contamination. To reduce this possibility, the

motor and controls should be kept clean and ensure phase, cycle and voltage of motormagnetic reversing starter and controls all match the electrical service being used..

Air and hydraulic powered winches require filtration before the control valve. TheManufacture’s Product Information Manuals should be referred to for specific filtrationlevel, type and location. Without filtration, contaminates can enter the system and causecomponents to malfunction.



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In those cases where multiply air tuggers / winches are to be used simultaneously, themanufactures’ specifications shall be applied to each individual air tugger / winchinvolved in the operations.

All connections must be tight and installation made with hoses, cables and/or fittingsthat are new or in good condition and rated for the power supplied. Pneumaticconnections shall be secured using both a safety pin and the appropriately sized whipchecks.

Shut off Valve

On all pneumatic powered air tuggers / winches the installation personnel shall ensurean accessible emergency shut off valve has been installed in the air supply line. Thevalve position shall be installed within easy range of the operator and positioned so thatactivation can occur quickly or any person in the area of the air tugger / winch can alsoactivate the valve. In addition to an emergency shut off valve, this valve will provide theoperator a positive way of stopping the air tugger / winch operations in the event of anemergency or prior to performing any adjusting, servicing, maintenance or maneuveringof wire rope on the winch drum. Any time the air tugger is left unattended the air tugger

shall be shut down and depressurized. All personnel involved in and/or around the airtugger operations shall be instructed and shown where this valve is located.

Air Tugger / Winch Controls

The location of controls and their features varies between air tuggers / winches. This isdependent on application requirements for each individual air tugger / winch. Theoperator shall be familiar with location of controls and their features. Operators shouldbe aware that controls are not always included with electric and hydraulic poweredwinches. Due to the differences in each air tugger / winch, users and operators shouldnot assume that all winches operate the same. Although, there are many similarities,

every air tugger / winch should be reviewed to identify their individual characteristics.Each air tugger / winch has specific characteristics that the operator must understandand be familiar with.

For instance Ingersoll Rand’s winches are operated by applying power to a motor,which is connected through a drive train to the drum. The direction of the drum rotationand speed is managed by the controls. Various controls are available with the winchesand are dependent on power source, location to winch and degree of control required.

For air winches, full flow control valves are normally used which are connected directlyto the winch motor. These have a lever, which is actuated forward and back for direction

control. The degree of lever movement controls drum speed.

Safety features for these operations; levers should not be able to engage without goingthrough another action first, such as pulling up a safety pin or resisting a safety spring.

Pendant controls are typically used on electric winches but are also available onpneumatic and hydraulic winches. This type of control sends a signal back to a valve orcontrol panel mounted to the winch. This control allows the operator to be somedistance from the winch. Pendant controls have levers or buttons which control forwardand reverse drum rotation. The use of pendant controls require additional safety



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considerations, as the operator may not be at the winch to observe drum rotation or wirerope spooling. Operators must maintain visual contact with the load, drum and wirerope at all times.

Exhaust

The installation location shall be evaluated for ventilation to ensure exhaust from theseoperations does not affect other operations and eliminates personnel from standing in or

around exhaust streams. A muffler should be used to reduce noise level to acceptablelimits. Pipe away the exhaust where possible to prevent oil mist creating a slipperyenvironment.

On pneumatic powered winches, careful consideration must be given to the exhaust.

Noise. Using piping or tubing to move exhaust away from operator can reducethis. The addition of a muffler is also recommended to reduce noise level.

Misting. Clean and remove any build-up of oily residue in area.

Natural/Sour Gas For air powered winches that use natural/sour gas as thepower source, pipe away exhaust from winch. Exhaust system shall provide saferemoval or recirculation of gas and meet all applicable federal, state, and localsafety regulations – Note: This application is discouraged and must haveMoreno Group LLC and Subsidiaries Management’s Approval at the VicePresident level prior to the use of this type of power supply.

Unauthorized Modifications to Air Tugger / Winch

During the installation or during the operations of any air tugger / winch, nounauthorized modification shall be allowed without the manufactures written approvalprior to the modification being performed.

Air Tugger / Winch Guards and Barricading of Operations

All guards shall be installed to prevent personnel from accidentally contacting anyexposed moving parts associated with the winch drum. Personnel shall ensure theguards do not interfere with the air tugger / winch wire rope spooling or controloperations. Guarding moving parts of an air tugger / winch from accidental contact withpersonnel shall be a prime consideration for the installation and maintaining of guardson the air tugger / winch. Guards shall be capable of supporting, without permanentdistortion, the weight of a 200 lb person. In addition, guards shall not cause an operatorto work in a non-stable or ergonomically incorrect position.

The travel area through which the air tugger / winch wire rope travels shall bebarricaded with Red Danger Tape to prevent non essential personnel from entering thearea without permission.

Approval Prior to Start of Operations

Upon completion of the installation of the air tugger to its fixed location, a photo shall betaken and sent to the Facility’s Register Structural Engineer or Designee for approval oftie down method and location. In those cases that a photo is unable to be taken, adetailed drawing shall be made and provided to the Facility’s Register Structural



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Engineer or Designee. The First Line Supervisor will be responsible for providing theFacility’s Register Structural Engineer or Designee the following information:

In those cases where a picture can be taken the following additional information shall beprovided:

Picture

Weight of load to be lifted

Size and thickness of clips

Amount and locations of clips

Size and locations for welds (especially on the back portion of the air tugger /winch)

Tie-in details of snatch blocks

In those cases where a picture can not be taken the following shall be provided:

A Sketch showing tugger placement, snatch block placement

Weight of load to be lifted

Size and thickness of clips Amount and locations of clips

Size and locations for welds (especially on the back portion of the air tugger /winch)

Tie-in details of snatch blocks

Snatch Block or Sheave Installation

To prevent the improper spooling of the wire rope on the winch drum, a snatch block orsheave shall be placed 6 to 8 feet in front of the air tugger. In those cases where the airtugger / winch is being used to perform a vertical lift, the snatch block shall be placed

above air tugger / winch prior to the line being ran through the deck or gradingpenetration.

To help prevent individuals from placing their hands on the air tugger / winch line, Red“Danger” Barricade tape shall be placed on the snatch block or sheave as streamers tohelp remind individuals not to place their hands on the wire rope.

The snatch block is used to help prevent the improper spooling of the drum rope.

Note: There are two (2) exceptions to this rule they are as follows:

Air tugger / winch operations that requires a straight pull in a horizontal direction.During these operations a snatch block or sheave is not required.

Air tugger / winch operations that will be performing a downward lift and does nothave an appropriate anchor point for a snatch block or sheave above the deckopening. In this case the First Line Supervisor must ensure the deck opening isproperly sized and runs the full length of the drum.

Ensuring the proper selection and installation of wire rope and sheaves is important tomaintain the safety of these operations. Sheaves and sheave mounting must bedesigned and selected in accordance with all applicable standards, codes and



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regulations. Improper installation of wire rope or sheave can cause uneven spooling andwire rope damage that could cause a load to drop.

The First Line Supervisor shall ensure wire rope and the rigging accessories arecorrectly rated for the application. The following shall be considered when determiningthe rating: weight of the load, weight of the rigging and rigging accessories.

Example of Sheave Sizes Wire Rope Diameter Min. Sheave Diameter inch mm inch mm

Wire Rope Diameter Minimum Sheave DiameterInch. mm. Inch. mm.

¼ 6 4-1/2 108

3/8 9 6-3/4 162

½ 13 9 234

5/8 16 11-1/4 288

¾ 18 13-1/2 324

7/8 22 15-3/4 396

1 26 18 468

When using a sheave check minimum D/d ratio for application.

D = Sheave Pitch Diameterd = Wire Rope Diameter

Typically for hoisting applications an 18:1 ratio is required. Periodically check sheaves for wear inaccordance with sheave manufacturer recommendation.

Maneuvering of Air Tugger / Winch Wire Rope

To help maneuver the wire rope back into the proper sequence, either a certified gratinghook should be place at the air tugger / winch or a come-a-long or Cadillac shall beplaced on the winch. Should the wire rope begin to improperly spool, a certified gratinghook, the come-a-long or Cadillac shall be used to pull the wire rope back into theproper sequence.

Deck or Grating Penetrations

All deck or grating penetrations performed for below deck lifts / pulls shall be made insuch a way that promotes proper spooling of the air tugger / winch and protects againstthe wire rope rubbing or snagging on the edges of the penetration. To help protect thewire rope from rubbing or snagging on the edges of the penetration, the installationteam shall place softening material to eliminate potential damage to the wire rope by its

contact with the edge of the penetration.

All deck penetrations shall be appropriately barricaded per our open hole procedureswhich should include the appropriate fall protections systems if warranted.

Pneumatic Operated Air Tuggers / Winches Operated in Potentially Explosive Atmospheres

Due to the potential for rubbing and friction, which may cause sparks or elevatedtemperatures that could be a source of ignition in an explosive atmosphere, the First



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Line Supervisor shall ensure the air tugger / winch operations receives a hot workpermit. The hot work permit shall be obtained from the facility owner for the air tugger /winch operations. The First Line Supervisor is responsible for incorporating all permitrequirements into the air tugger / winch operations.

Pre Use Inspection / Pre Lift Testing

Prior to every shift and prior to the initial start up of any air tugger operations a pre use

inspection of the winch, wire rope and rigging shall be performed. Any deficiencies shallbe noted on the pre use inspection form, the First Line Supervisor Notified and thedeficiencies corrected prior to the air tugger operations beginning. The pre useinspection shall be documented on the Air Tugger Operations Pre Use Inspection Form.(see attachment 1)

The intent of an air tugger / winch operations pre use inspection is to ensure all winchcomponents and attachments are functioning properly and/or properly adjusted. Duringthis pre use inspection the operator shall perform an operational test by running the airtugger / winch slowly in each direction with no load and check the operation of eachattachment or option prior to application use.

For loads exceeding eighty percent (80%) of the air tugger capacity, a pre lift test shallbe performed and documented on the Air Tugger / Winch Pre Use Inspection Form.This test shall consist of the following:

The test load shall not be less than 110% of the rated load nor more than 125%of the rated load, unless otherwise recommended by the manufacture.

The test load shall be hoisted a vertical distance to assure that the load issupported by the air tugger(s) / winch(es) and held by the hoist brake(s).

The test load shall be lowered, stopped, and held with the brake(s).

Note: If a lift is to be used with a multiple number of air tuggers / winches, the test shallbe performed with all air tuggers / winches in operations at once. This pre lift test willhelp ensure winch anchors and supporting structure are secure and in good condition.In addition the following shall be observed and checked.

Ensuring air tugger / winch anchors and supporting structures are secure and in goodcondition:

Fasteners - Check retainer rings, split pins, cap screws, nuts and other fasteners

on winch, including mounting bolts. Replace if missing or damaged and tighten ifloose.

Foundation or supporting structure - Check for distortion, wear, rigidity andcontinued ability to support winch and rated load. Ensure winch is firmly mountedand that fasteners are in good condition and tight.

Ensuring air tugger / winch supply cables and hoses are in good condition andconnections are tight:



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Failure of electric cables or their disconnection while power is supplied can resultin electrocution.

Failure of air or hydraulic hoses or their disconnection while pressurized canresult in hazardous situations including the whipping of hoses. To prevent thispotential hoses shall be connected with safety pins installed in crow feetconnects with the appropriately sized whip checks are installed

Keep clear of whipping hoses. Shut off the compressed air or hydraulic pressurebefore approaching the whipping hose.

Notify supervisory or maintenance personnel of any malfunction or damage.

Trained and authorized personnel must determine if repairs are required prior tooperating the winch.

Winch should never be operated with damaged wire rope, controls or guards.

Operating an Air Tugger / Winch

The following operating instructions have been adapted in part from American National(Safety) Standard ASME B30.7 and are intended to avoid unsafe operating practiceswhich might lead to injury or property damage. The four most important aspects ofwinch operation are:

Follow all safety instructions when operating winch.

Allow only people trained in safety and operation of this winch to operate thisequipment. See Training section of this procedure.

Subject each winch to a regular inspection and maintenance program.

Be aware of winch capacity and weight of load at all times. Ensure load does notexceed winch, wire rope and rigging ratings.

CAUTION Note: If a problem is detected, immediately STOP operation and notify supervisor. DONOT continue operation until problem is corrected.

During all air tugger / winch operations, the operator must be aware of load and its path.Load must have a free unobstructed path from pick up to set down. This awareness isto ensure that load does not contact any hazards. Some of the hazards to watch for andavoid are:

Guide wires, other load lines, strung hoses.

Personnel in the working or walking in the path of the lift or under the load as itmoves. To prevent this condition the travel area of the air tugger / winch ropeshall be barricade. Personnel shall NEVER be under or in the path of a movingload.



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Air tugger / winch operations shall be shut down when winds exceed 25 miles perhour. No loads shall be lift suspended for any period of time.

If during the lift a load must be held suspended, the following shall be followed:

o Operator shall not leave the controlso If the load must remain suspended for a considerable time a pawl or other

equivalent means, rather the brake alone shall be used to hold the load.

Erratic control valve operation (can cause a sudden jerk on load which couldcreate an overload condition).

Removing all obstacle such as buildings, support members, another load, etcfrom the path to prevent the load from banging or hanging up on the obstacle.Should the obstacle be unable to be moved, a different plan and site evaluationshall be performed.

When multi-parting the load line, the two sheaves come together (also calledTwo-Blocking).

During onshore operations, power lines, telephone lines and electrical cables.

During pulling (dragging) operations:

Watch for obstructions that could cause load to hang up, causing suddenuncontrolled load shift.

Direct foot and vehicle traffic to ensure they maintain a safe distance from theload path and load line.

Additional Operating Procedures

When a “DO NOT OPERATE” sign is placed on the winch, or controls, do not operatethe winch until the sign has been removed by designated personnel.

Ensuring proper communication is established with the signal person. When theoperation does not allow for the operator to maintain visual contact on the lift at all times(i.e. Blind lift), the JSEA shall identify who is responsible for signaling the operator andidentifies the method of communications between signal person(s) and operator.

Keep hands, clothing, jewelry, etc. away from wire rope, drum and other moving parts.

Ensuring the operator operates the air tugger / winch with smooth control movements toprevent jerking or sudden movements of the load.

Ensure the load is not pulled into support structure or winch of the air tugger

Ensure wire rope hook end is not attached or connected (stowed) to an unmovablepoint prior to lift operation.

Immediately stop operation if load does not respond to air tugger / winch control.



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Ensure brake(s) hold prior to making complete lift by lifting load a short distance andreleasing control.

Ensuring the operator is able to maintain visual contact with the load, drum or wire ropeat all times. During a blind lift, the operator shall ensure an adequate number of signalpersons are identified, appropriately spaced / located, provided appropriate means tocommunicate effectively with each other and with the operator. This shall be

documented on the task JSEA.

Ensure all personnel involved in the air tugger / winch operations keep hands andclothing clear of gaps or spaces on winches, off of wire rope and away from sheaves orsnatch blocks.

Operating in Cold Weather

When operating an air tugger / winch in Cold weather, these operations can presentadditional hazards. At very cold temperatures metal can become brittle and the use ofthis piece of equipment requires extreme care to ensure that load movements are

smooth and even. The lubricating fluids do not flow as readily during cold temperaturesand every effort to warm all fluids and components before operation needs to occur forthe best performance. The warming of fluids can be accomplished by running the winchslowly in both directions with no load to initially lubricate components.

In addition to the equipment concerns, operators maybe wearing increased clothing.Their feel of controls, field of vision and hearing could be impaired due to the increasedclothing. To help minimize these effects the First Line Supervisor shall ensure thatadditional personnel and / or signal person are used to maintain a safe operation.

Whenever temperature are below freezing, 32˚ F (0˚ C), extreme caution must be

exercised to ensure that no part of product, supporting structure or rigging is shockloaded or impacted as brittle fracture of steel may result.

Completion of Air Tugger / Winch Operations

At the completion of air tugger / winch operation or when in a non-operational mode thefollowing actions shall occur:

Remove load from load line. Never maintain a load suspended in the air.

Spool load wire rope back onto winch drum and secure. For load lines over

sheaves or snatch blocks, the wire rope shall be secured in a position that willavoid a safety hazard in the area.

Turn off/shut off or disconnect power supply.

Secure winch against unauthorized and unwarranted use.



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Air Tugger / Winch Brake

Brakes are of two basic types, band brake and disc brake. Disc brakes are internal andconnected to the drive train. They are automatically engaged, locking the drive train tothe winch frame, thereby stopping drum rotation when the control is released or placedin the neutral position.

External band brakes wrap around the drum. When applied, the brake band tightens on

the drum and a stop on the band brake contacts the frame of the winch to stop drumrotation. This tightening can be done two ways. Manually by a lever or wheel which theoperator controls or automatically. On automatic band brakes when the control is placedin the neutral position the band brake tightens, locking the drum.

Winches with a manual band brake require the operator to operate both winch controland band brake control simultaneously during operations. It is recommended thatowners/users practice operation of brake and winch control with lighter loads untilproficient with both functions.

When lowering loads near the winches rated load at very slow speeds, monitor the

temperature of the brake bands and/or brake housing. This load/speed combinationmay result in automatic brakes dragging, which could cause heat build up. Indicationsthat the heat build up on the brake is excessive are:

Housing surface temperatures in access of 120˚ C

Visible indications of hot paint, such as blisters or scorching

The smell of hot oil or burning paint

Stop all operations any time a hot brake is detected.

When operating a winch with a manual drum brake, ensure the brake is fully releasedwhen load is in motion. Use the control throttle to control the speed of the winch. Do notdrag the brake to control the winch speed. If the winch has only a manual drum brake(no automatic brakes), set the brake to stop winch motion.

Operators must pay careful attention to brake operation at all times. At any indication ofloss of braking ability operator must immediately cease operation, shut off power to thewinch and inform their supervisor. Some indications of brake problems are:

Brake bands or housings becoming very hot during operation. This is anindication of excessive slippage

Abnormal sounds, such as grinding, coming from brake parts during activationof the brake. This is an indication of worn bands

Brake(s) do not hold load when winch control is in neutral

During operation it is necessary for the operator’s hand to be close to the drum when using a manual band brake. To minimize the possibility of contact:



J1.16

Maintain a firm grip on brake lever handle and winch throttle control lever.

Ensure footing is clean, dry and firm.

Maintain a good comfortable posture, do not lean.

Ensure any loose clothing is tucked in or out of the way of the drum.

Ensure the band brake is correctly adjusted which will allow the operator to stopdrum rotation when the brake is fully engaged.

Use Winch Drum Guards which are available and recommended by themanufacturer for all air tugger / winch installations

Disengaging Clutch

Clutches are used to disengage the drum from the drive train, which allows wire rope to“free spool” from the drum. When the drum is in the “free spool” mode, use of the band

brake to control wire rope payout is required to prevent the loosening of wraps on thedrum. After wire rope is out and connected to load, the operator should engage thedrum and slowly apply tension to wire rope.

On winches with a clutch “free spool” option, wire rope should spool from drum with minimal effort. When pulling wire rope from drum in the “free spool” mode, do not strainor lose balance and always look where you’re going to avoid tripping.

Note: To prevent load control loss, do not disengage the clutch when there is a load onthe air tugger / winch.

Spooling and Handling of Wire Rope

The most important part of wire rope spooling is attaching wire rope to the drum.Different methods are used to fasten the wire rope to the drum. The individuals spoolingthe wire rope shall refer to the Manufacture’s Product Information Manuals for thespecific method. Note: Failure to match wire rope diameter with the correct wire ropeanchor hardware can cause wire rope to release from drum and drop the load.

Prior to the staring the spooling operations the individual performing this installationshall ensure all non-essential individuals are kept away from this operations. This shallbe accomplished by barricading the area with Red Barricade Tape around thisoperation. Note: Spooling of an air tugger / winch shall not occur offshore unlessdetermined as an emergency situation by the Offshore Operations Manager.

The individuals spooling the wire rope shall ensure the anchor pocket guard is installedwhen provided with the winch. This individual shall check to ensure the wire rope lengthis sufficient for the task meaning the length for the entire range of movement specifiedfor the application, with no less than three (3) full wraps of rope on the drum at all times,does not exceed the top layer diameter and is approved for the application. At no timeshall anyone be allowed to add additional wire rope to the established length to extendthe length of the air tugger / winch wire rope. All ends of the air tugger / winch wire ropewill be required to have a manufactured eye.



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Only factory approved hardware shall be used to attach wire rope to drum. Wheninitially spooling wire rope onto the winch drum make certain that it bends in the samedirection. The proper method of spooling an air tugger / winch is to re-reel from the topof one reel to the top of another, or from the bottom of one reel to the bottom of another.It is also necessary to apply a tensioning load to the wire rope to achieve good spooling.

A. Correct; B. Over wound; C. Winch Drum; D. Wire Rope Spooling; E. Spool;F. Under wound; G. Incorrect.

Note: Always use gloves, or suitable hand protection when handling wire rope.

When installing new wire rope it is important that all wraps of the first layer are tight onthe drum and adjoining the previous wrap. Open or wavy winding will result in wire ropedamage when multiple layers are used. Adjacent turns should be tight against eachother. If gaps occur between wraps, STOP air tugger / winch and tap wire rope with a

composite or wooden mallet, so that the strands are snug but not interlocked. Do notrestart drum rotation until everyone is clear. The succeeding layers of wire rope shouldwind across the preceding layer of wire rope without gaping or bunching. Ensure thatthe correct length of wire rope is fitted. This is particularly important as it may benecessary to fit specific lengths of wire rope for particular applications and wire ropereeving combinations. The installer shall watch for the following conditions:

Too short of a wire rope could result in the wire rope completely paying out andthe wire rope anchorage on the drum having to carry the full load.



J1.18

Too long a wire rope could exceed the drum’s spooling capacity, causing the wirerope to ride over the drum flange resulting in the load dropping, severe damage,wire rope crushing or complete winch failure.

It is good practice to check the wire rope length whenever the structure is changed, wirerope is changed or reeving altered. To be certain that wire rope spools evenly on drumuse a spooling device to keep tension on wire rope, approximately 10% of the workingload is recommended. Maintain a fleet angle between the lead sheave and winch of nomore then 1-1/2˚. A 2˚ fleet angle is allowable with grooved drums. Exceeding thespecified fleet angle can cause excessive friction, leading to heat build up or sparks.The lead sheave must be on a center line with the drum, and for every inch (25 mm) ofdrum length, be at least 1.6 ft (0.5 m) from the drum. See the diagram below:

A. Sheave; B. Fleet Angle; C. Drum Flange.

The entire length of wire rope should be wound on the drum tightly and correctly as thiswill facilitate good winding during operation. Poor or incorrect spooling can:

Shorten wire rope life cause erratic winch operation.

Cause wire rope to drop.

Cause wire rope to bunch.

Be less than distance to flange dimension.



J1.19

A. Sheave Flange and Wire Rope Wear; B. Wire Rope Wear; C. Wire Rope Wound tootightly compressed; D. Uneven Spooling Bunched Wire Rope; E. or; F. When the Fleet

Angle is too small the Result is Poor Winding.

The spooling area shall be clean and free of debris and care shall be taken to ensurethat the wire rope is clean and properly lubricated as it is spooled onto drum. The Wirerope shall not be allowed to drag or touch the ground during spooling. Prior to thespooling of the wire rope, an inspection shall be performed of the wire rope andcarefully as the wire rope is being spooled onto drum. The individual installing the wirerope shall watch for broken or loose strands or other signs of damage or unserviceablewire rope.

Note: Use of wire rope sizes other than recommended will greatly decrease the life ofthe wire rope.CAUTION



J1.20

Upon completion of spooling and prior to final installation, the individual spooling thewire rope shall secure the rope to drum. The securing of the wire rope will prevent wirerope from loosening on the drum.

Grooved drums are designed with the correct groove pitch and depth for one diameterof wire rope. To determine the proper wire rope size the individual spooling the airtugger / winch shall refer to the Manufacture’s Product Information Manuals. Should thewire rope size and grooved drum do not match, the individual spooling the air tugger /

winch shall notify his First Line Supervisor immediately so either the drum or wire ropecan be replace with the correct size. Remember the use of the wrong diameter wirerope on a grooved drum will cause improper spooling of the first layer and it will alsocause excessive wear, damage, erratic operation and shortened life of the wire rope.

Winches without grooved drums are designed for a range of wire rope sizes. Theindividual spooling the air tugger / winch shall refer to the Manufacture’s ProductInformation Manuals for the specific range. The use of a wire rope with a largerdiameter than specified will result in decreased life of the wire rope and can causedamage to the internal wire rope strands, which cannot be seen with a visual inspection.

The diagram below illustrates the correct manner to spool wire rope onto the air tugger /winch drum.

A. Correct Spooling; B. Distance to Flange; C. Even, Tight Wraps on Drum.

Remember when spooling is complete the wire rope should:

Be tight on each layer.

Have single even layers.

Not be bunched.

Not exceed distance to flange dimension (as specified in the Manufacture’s Product Information Manuals).



J1.21

Preventive Maintenance Program

A preventive maintenance program shall be implemented on the air tugger / winch perthe manufacturer's recommendations. Rental companies are expected to maintainrecords of the preventive maintenance inspections and must be kept for the life of theequipment.

Personnel Lifting

Personnel lifting shall not occur within air tuggers / winch that are not personnel or man.

Note: All personnel lifts performed by air tuggers / winches shall be personnel or manrated and meet the requirements outline within the Moreno Group, LLC andSubsidiaries SH&E Management System, Crane Policy under Suspended PersonnelMan Baskets / Platforms.

Training of Operators

Each Air Tugger / Winch operations shall be performed by a Qualified Operator that

meets the definition of a Qualified Operator both physically and training.

To designate an employee as a Qualified Operator, the individual must possess acurrent API RP 2d Rigging Certification prior to attending the Moreno Group LLC andSubsidiaries Air Tugger / Winch Operator Training course. The Air Tugger / WinchOperators Training shall consist of the following:

Classroom and a Hand-on performance evaluation

Moreno Group LLC and Subsidiaries Air Tugger / Winch Operations Safe WorkPractices.

Proper methods and documentation involved in the pre use inspection of an AirTugger / Winch

Air Tugger / Winch Operator Training shall be performed at a minimum every 4 years.





J1.22

Attachment 1





J1.23

Air Tugger / Winch Pre-Use Checklist

Date: Customer:

Supervisor: Job Location:

Operator: Job #:

Appl icat ion : Pull or “Dragging” Lifting / Weight Bearing (Lift Preparation section MUST be completed)

Air Tugger secured in appropriate manner and approved by facility rep.? YES NO

Certification of Tugger & Cable Current (within 1 year)? YES NO

(Certification Certificates should be verified before operations begin)

Capacity of Tugger : LBS KG Metric Tons

Wire Rope

Diameter: inch mm Tagged Capacity

Is the wire rope spliced in any place? YES NO (If yes, remove from service)

Is manufactured thimble & eye in place? YES NO (If no, remove from service)

Power Supply & Contro ls :

Combined Compressor CFM Output: CFM

Volume Bottles Added? YES NO

Is the tugger spool side loaded? YES NO (If yes, then repositioning required)

(Angle from spool opening to snatchblock greater than 15 degrees)

Safety Devices:

Control Arm Return to locked position when not in use? Safety Cage intact?

Snatch Blocks Properly Rigged Location of Snatch Blocks:

Certified Grating Hook / Come-A-Long / Cadillac to keep Wire Rope properly aligned

Shut off Valve at air tugger

Barricades installed around tugger operation area Snatch blocks flagged to denote pinch point

Brakes & Auxi l iary Hold ing Devices:

Manual Band Gear Brake

Communication Method:

Lift Preparations :

Function Test Complete? YES NO (NOTE: Proof Test required if load is greater than 80% of air

tugger capacity)

For Function Test to be valid, all tuggers involved must be operated simultaneously & all brakes tested.

Tugger Air Demands Total: Combined Tugger Capacity: lbs

Total Weight of Load: lbs

FOR MULTIPLE TUGGER/VERTICAL LIFTS, THIS CHECKLIST AND JSEA + JOB PLAN MUST BE FAXED

TO MANAGER FOR APPROVAL AND SIGNOFF

Manager Approval:

Supervisor on Site: Platform Rep agreeing to task:






Barricading ProcedurePage 1 of 3Original: 01/01/2004Revised: 01/01/2008

J2.1

Barricading Procedure

Purpose

To provide minimum safe work practices for the set-up and maintenance ofbarricades that restrict entry and/or provide warning for areas that involve hazardousactivities, unsafe conditions, or unusual circumstances.

Scope

The scope of this procedure is to address the various situations, which require theuse of barricades and the types of barricades, which should be utilized.

Responsibilities


Provide resources to fully implement this procedure.



Ensuring that employees comply with the requirements of this procedure.

Evaluating work areas and ensuring that situations, which require barricades,have been barricaded as per this procedure.

Authorizing employees to enter barricaded area to perform assigned work.

Authorizing employees to remove barricade once hazard has beeneliminated.


Evaluating Program to ensure compliance



Communicating to supervisors any suggestions or concerns related to thisprocedure

Stopping unauthorized employees from entering inside a barricaded area..



J2.2

Definitions

Caution Yellow – for situations, which may cause minor incident. Signs will beposted on the barricade to identify the specific hazards and requirements, whichshall be taken inside the barricaded area. Employees shall exercise caution prior toentering inside a yellow barricade.

Danger Red – for hazards which are immediately or potentially life threatening orcan cause serious injury. Only authorized employees shall enter into areas, whichhave been barricaded with Danger Red. Signs will be posted on the barricade toidentify the specific hazards and requirements, which shall be taken inside thebarricaded area.

Magenta or Purple or Black on a Yellow background – Signage that identifies areaswhere there is potential for radiation exposure. Only designated personnel areallowed inside radiation areas. Moreno Group LLC and Subsidiaries personnel shallnot enter a radiation area at any time unless the crew is not performing any X-rayingand when authorized by the X-ray crew to enter the regulated area.

Protective Barricade - Provides a physical barrier withstanding 200 pounds ofpushing force to protect personnel from hazards such as floor openings orexcavations. Protective barricades shall consist of a toprail, midrail and toeboards.

Anytime wire rope is used, it shall have a diameter of at least 3/8 inch and barricadeshould be covered with high visibility orange mesh fencing. If fencing is notavailable, red danger flagging needs to be placed at 6 feet intervals on toprail ofbarricade to ensure visibility.

Warning Barricade - Erected to call attention to specific hazards, but provides nophysical protection from the hazard.

Requirements

Moreno Group LLC and Subsidiaries will require the use of barricades wherevernecessary for the physical protection of people or property.

The following is a list of activities, which require the use of protective barricades:

Open holes or missing handrails that pose the threat of a fall to a lower level.

Excavations / Trenches

The following is a list of activities, which require the use of Danger – Red ColorCoded warning barricades:

Areas underneath construction activities where there is potential for fallingobjects.

Areas with temporary wiring operating at more than 600 volts.

Work areas for electrical equipment with exposed, energized parts.



J2.3

Confined Space work areas

Accident / Incident scenes which have not been investigated, or potentiallyinfectious material may be present.

Work Areas which pose a health risk (i.e. Lead, Asbestos, etc.)

The following is a list of activities, which require the use of Caution – Yellow ColorCoded warning barricades:

Material Storage Areas

Slip / Trip and Same Level Fall Hazards

Areas in which x-raying is being performed may be barricade with Caution or DangerTape with a sign that contains the standard radiation symbol with the use of colorsmagenta or purple or black on yellow backgrounds. When approved by the FacilityManagement cones and required signage may be utilized to barricade the regulated

area.

Barricades must completely enclose areas of a more hazardous nature.

Barricades should be erected approximately 42 inches from the ground or floor.

Barricades protecting work areas below overhead work shall be built to a 1' to 1'ratio (meaning if working 10' above work area, barricade shall be at least 10' radiusof work area below).

All personnel who work inside the barricade are responsible to see that the barricade

is maintained and that housekeeping within the barricade is maintained.

Warning signs shall be placed on barricades to notify personnel of purpose ofbarricade, and precautions to be taken prior to entering barricade.

Barricades shall not be removed until hazard is completely removed and only withsupervisor’s permission.

Barricade material can include plastic barricade tape, woven tape, rope, plasticchain, or any other material that provides the proper color-coding and will withstandthe environment in which it is placed.

Procedures for Entering a Barricaded Area

Danger Barricaded areas are to be entered only with specific permission from yourimmediate supervisor. Barricades should be entered only after all of therequirements identified on the barricade sign have been followed.

Caution Barricaded areas are only to be entered after carefully reading the warningsign and ensuring that protective measures are being taken as per the warning sign.






Management SystemConfined Space Entry


J3.1

Confined Space Entry

Purpose

To establish methods to identify confined spaces, classify them according to theirrisks and to establish guidelines necessary for the safe preparation, entry, andrestoration of a confined space entry.

Scope

The scope of this program establishes recommended procedures for classifying;preparing and entering of confined spaces. This program applies to any confinedspace that meets the following definition:

That has limited openings for entry and/or exit;

That could contain known or potential hazards;

That is not intended for continuous occupation;

Or that has insufficient natural ventilation.

Note: This program shall be followed when our customer (owner of the facility) doesnot have a Confined Space Entry Program or when a confined space entry isconducted at our facility. Although, Moreno Group LLC and Subsidiaries’employees shall not enter confined spaces, which has an ImmediatelyDangerous to Life and Health (IDLH) condition.

Examples of confined spaces include:

Spaces normally entered through a manhole, such as tank cars, processvessels, bins, furnaces, boilers, storage vessels, mixers, etc.

Open topped spaces more than four (4) feet deep not subject to goodventilation, such as pits, trenches, vessels, vaults, sumps, wells, etc.

Other types of spaces, such as large diameter pipes, septic tanks, sewers,etc.

Responsibilities

The Facility / Site Manager / Offshore Manager is responsible for overall programadministration.



J3.2

The First Line Supervisor / Offshore Superintendent in charge of the space and / or work is responsible for:

Implementing the program in their areas and monitoring compliance.

Assuring that entrants, attendants, gas testing and rescue personnel havecompleted the appropriate training.

Obtaining and / or issuing the necessary permits and serve as the EntrySupervisor.

Verifying that equipment preparation and isolation methods have beencompleted (including the placement of tags and / or locks as required) and aresufficient to protect personnel and equipment.

Perform Confined Space Pre-entry Checklist and Hazard Assessment. (See Attachment 1)

Performing, or having a qualified gas tester perform, the pre-entry and follow-up atmospheric monitoring for oxygen, flammable and toxic atmospheres.

Complete Confined Space Entry Permit. (See Attachment 2)

Instructing personnel on the proper methods and safeguards required toperform the job safely.

Develop Rescue Plan for Entry. (See Attachment 1)

Compliance with pre-set conditions on the permit.

Alerting all affected personnel to changes in area conditions which couldadversely affect personnel or equipment involved.

Leaving the jobsite in a safe, clean condition.

Informing the appropriate personnel when the work has been completed, byreturning and / or signing "off" on the permits (including the removal of anytags and / or locks used to isolate the equipment).


Maintaining a master list or description of permit and non-permit requiredconfined spaces at the facility / site.

Assisting Moreno Group LLC and Subsidiaries managers andsupervisors/superintendents with the confined space hazard analysis and thedevelopment of entry and emergency procedures.

Procurement, maintenance and calibration of gas testing equipment.



J3. 3

Coordinating Confined Space Entry and Gas Testing training.

Assisting with atmospheric monitoring as needed.

Reviewing and endorsing the Confined Space Entry Permit before personnelenter the space.

The Personnel entering a Confined Space are responsible for:

Understanding and following the Confined Space Entry Procedure.

Knowing the requirements and precautions specified on the Confined SpaceEntry Permit.

Knowing the potential hazards related to the confined space involved.

Being able to recognize the signs and symptoms of over-exposure to potentialhazards.

Understanding the consequences of over-exposure to potential hazards.

Maintaining contact with the Attendant (Hole-Watch).

Evacuating the confined space when conditions change, become unsafe orwhen instructed to do so by the Attendant.

Using the personal protective equipment required for the job as specified onthe Confined Space Entry Permit.

The Attendant (Hole Watch) for Confined Space Entry is responsible for:

Understanding and following the Confined Space Entry Procedure.

Maintaining an accurate count of all persons in the confined space (see Attachment 3) utilizing the back of the Confined Space Entry permit.

Knowing the requirements and precautions specified on the Confined SpaceEntry Permit.

Knowing the potential hazards related to the confined space and potentialhazards from activities outside the Confined Space, which could affect theconfined space.

Maintaining contact with personnel working in the confined space.

Being able to recognize the signs and symptoms of over-exposure to potentialhazards.

Ordering evacuation of the confined space when:



J3.4

A condition develops which is not allowed by the entry permit.

Personnel show behavior-indicating over-exposure to hazardous materials.

A situation outside the space develops which could endanger personnel inthe confined space.

The Attendant must leave his / her workstation.

Keeping unauthorized persons away from the confined space.

Summoning rescue services in emergency situations.

NOTE: The Attendant may leave his / her workstation only long enough tosummon rescue or emergency services.

Assisting rescue personnel to the extent possible based on training to do so.The Attendant is not to enter the confined space to attempt rescue except as a

trained member of a rescue team.

Definitions

Confined Space means a space that:

is large enough and so configured that an employee can bodily enter andperform assigned work; and

has limited or restricted means for entry or exit; and

is not designed for continuous employee occupancy.

Non-Permit Confined Space means a confined space that does not contain or withrespect to atmospheric hazards, have the potential to contain any hazard capable ofcausing death or serious harm. This type of confined space shall require a writtenpermit to certify the confined space is able to be entered.

Permit-Required Confined Space means a confined space that has one or more ofthe following conditions or characteristics:

Contains or has the potential to contain a hazardous atmosphere or

Contains a material that has the potential for engulfing an entrant or

Has an internal configuration such that an entrant could be trapped orasphyxiated by inwardly converging walls or by a floor, which slopesdownward and tapers to a smaller cross-section or

Contains any recognized serious safety or health hazard.



J3. 5

Note: A Permit-Required Confined Space may be reclassified as a Non-PermitConfined Space by removing the hazard.

Acceptable Entry Conditions means the conditions that must exist in a permit spaceto allow entry and to ensure that employees involved with a permit-required confinedspace entry can safely enter into and work within the space.

Attendant means an individual stationed outside the permit space who monitors theauthorized entrants and who performs all attendants’ duties assigned by the ConfinedSpace Entry Program.

Authorized Entrant means an employee who is authorized by the employer to enter apermit space.

Blanking or Blinding means the absolute closure of a pipe, line or duct by fastening ofa solid plate that completely covers the bore and is capable of withstanding themaximum pressure of the pipe, line or duct with no leakage beyond the plate.

Attempts should be made to blind at the closest point to the confined space.

Double Block and Bleed means the closure of a line or pipe by closing and locking ortagging two (2) in-line valves and by opening and locking or tagging a drain or ventvalve in the line between the two closed valves.

Entry means the action by which a person passes through an opening into a permit-required confined space. Entry occurs as soon as any part of the entrant’s bodybreaks the plane of an opening into the space.

Entry Permit means the written or printed document that is provided by the employerto allow and control entry into a permit space. Acceptable entry conditions are

properly noted on the document.

Entry Supervisor means the person responsible for determining if acceptable entryconditions are present at a permit space where entry is planned, for authorizing entryand overseeing entry operations, and for terminating entry as required.

Hazardous Atmosphere means an atmosphere that may expose employees to therisk of death, incapacitation, impairment of the ability to self-rescue, injury, or acuteillness from one or more of the following causes:

Atmosphere oxygen concentration below 19.5 percent or above 23.5 percent.

Flammable gas, vapor, or mist in excess of 10 percent of the lower explosivelimits (LEL).

Airborne combustible dusts at a concentration that meets or exceeds its lowerexplosion limits (LEL).

Any other atmospheric condition that is Immediately Dangerous to Life andHealth (IDLH).



J3.6

Atmospheric concentration of any substance for which exposure could result inexcess of that substance’s permissible exposure limit.

Hot Work Permit means the employer’s written authorization to perform operationscapable of providing a source of ignition.

Immediately Dangerous to Life or Health (IDLH) means any condition that poses an

immediate or delayed threat to life or that would cause irreversible advance healtheffects or that would interfere with an individual’s ability to escape unaided from apermit space.

Inerting means the displacement of the atmosphere in a permit space by anoncombustible gas to such an extent that the resulting atmosphere isnoncombustible. Note that this procedure produces an IDLH oxygen deficientatmosphere.

Isolation means the process by which a permit space is removed from service andcompletely protected against the release of energy or material into the space.

Oxygen Deficient Atmosphere means an atmosphere containing less than 19.5percent oxygen by volume.

Oxygen Enriched Atmosphere means an atmosphere containing more than 23.5percent oxygen by volume.

Permit System means the employer’s written procedure for preparing and issuingpermits for entry and for returning the permit space to service following termination ofentry.

Prohibited condition means any condition in a permit space that is not allowed by thepermit during the period when entry is authorized.

Rescue service means the persons designated to rescue employees from permitspace.

Retrieval system means the equipment (including a retrieval line, chest or full-bodyharness, wristlets, if appropriate, and a lifting device or anchor) used for non-entryrescue of persons from permit spaces.

Testing means the process by which the hazards that may confront entrants of a

permit space are identified and evaluated. Testing includes specifying the tests thatare to be performed in the permit space.

Confined Space Duties

Duties of Authorized Entrant

The authorized entrant shall be trained and understand the following duties:

Know the hazards that may be faced during entry, including information on the mode,signs or symptoms, and consequences of the exposure.



J3. 7

Properly use atmosphere testing equipment, ventilation equipment, personalprotective equipment, communication equipment, lighting equipment and rescue oremergency equipment.

Communicate with the attendant as necessary to enable the attendant to monitorentrant status and to enable the attendant to alert entrants of the need to evacuatethe space.

Alert the attendant whenever:

The entrant recognizes any warning sign or symptom of exposure to adangerous situation, or

The entrant detects a prohibited condition; and

Exit from the permit space as quickly as possible whenever:

An order to evacuate is given by the attendant or the entry supervisor,

The entrant recognizes any warning sign or symptom of exposure to adangerous situation,

The entrant detects a prohibited condition, or

An evacuation alarm is activated

Duties of Authorized Attendant

The authorized attendant shall be trained and understand the following duties:

Knows the hazards that may be faced during entry, including information on themode, signs or symptoms and consequences of the entrants.

Is aware of possible behavioral effects of hazard exposure in authorized entrants.

Continuously maintains an accurate count of authorized entrants in the permit spaceon the back of the Confined Space Permit. No one shall enter the confined spacewithout reading, and understand the conditions and requirements on the confinedspace permit.

Remains outside the permit space during entry operations until relieved by anothertrained attendant. Each attendant shall sign the back of the confined space permitprior to going on or off duty.

Entry attendant will be responsible for periodically or continuously monitoring theconfined spaces atmosphere

Communicates with authorized entrants as necessary to monitor entrant status and toalert entrants of the need to evacuate the space.



J3.8

Monitors activities inside and outside the space to determine if it is safe for entrantsto remain in the space and orders the authorized entrants to evacuate the permitspace immediately under any of the following conditions:

Attendant detects a prohibited condition

Attendant detects the behavioral effects of hazard exposure in an authorized

entrant.

Attendant detects a situation outside the space that could endanger theauthorized entrant.

Attendant cannot effectively and safely perform all the duties required.

Summon rescue and other emergency services as soon as the attendant determinesthat authorized entrants may need assistance to escape from permit space.

Take the following actions when unauthorized persons approach or enter a permit

space while entry is underway:

Warn the unauthorized persons that they must stay away from the permit space.

Advise the unauthorized persons that they must exit immediately if they haveentered the permit space

Inform the authorized entrants and the entry supervisor if unauthorizedpersons have entered the permitted space.

Perform non-entry rescues as specified within entry SH&E Meeting.

Preventing any unauthorized personnel from attempting a rescue.

Perform no duties that might interfere with the attendant’s primary duty to monitor andprotect the authorized entrants.

Maintains any Material Safety Data Sheets (MSDS) of chemicals present orpotentially present within confined space.

Duties of Entry Supervisors

The entry supervisor shall be trained and understand the following duties:

Knows the hazards that may be faced during entry, including information on themode, signs or symptoms, and consequences of the exposure;

Conducts a Pre-Entry Hazard Assessment of the space to be entered;

Verifies, by checking that the appropriate entries have been made on the permit, thatall tests specified by the permit have been conducted and that all procedures and



J3. 9

equipment specified by the permit are in place before endorsing the permit andallowing entry to begin;

Terminates the entry and cancels the confined space permit if the following happens:

The entry operations covered by the entry permit have been completed; or

A condition that is not allowed under the entry permit arises in or near thepermit space.

Verifies that rescue services are available and that the means for summoning themare operable;

Removes unauthorized individuals who enter or who attempt to enter the permitspace during entry operations; and

Determines, whenever responsibility for a permit space entry operation is transferredand at intervals dictated by the hazards and operations performed within the space

that entry operations remain consistent with terms of the entry permit and thatacceptable entry conditions are maintained.

Requirements

A master list of confined spaces at the each location shall be maintained at eachMoreno Group LLC and Subsidiaries facility. Confined Spaces have either beenclassified as Permit Required or Non-Permit Required Spaces. All supervisorsshould be familiar with this list and consult it to see if a permit is required beforeallowing anyone to enter any confined space.

Additions or deletions from the facility’s list of Confined Spaces must be approved bythe Facility / Site Manager and the Safety, Health and Environmental Manager.

Supervision should be alert to the possibility that a confined space may exist or maybe introduced to the facility / site at a later date and that should be added to the list.Warning signs must be posted at the entrance of confined spaces that may not berecognized as a confined space.

Anytime multi employers are involved within a confined space a meeting shall occurto coordinate the entry operation and to determine which permit system will befollowed.

Permit System

Trained Supervision, Safety, Health & Environmental Department or Yard Formanmay only perform atmosphere testing and issuing of Confined Space Entry Permits(see Pre-Entry Checklist and Hazard Assessment, Attachment 1 and Attachment 2).

The supervisor of personnel performing work inside the space is the recipient of thepermit.



J3.10

The permitting system shall allow the entry supervisor to evaluate the confined spaceto ensure it has been properly prepared for entry. The space shall be blinded at eachinlet and outlet and/ or disconnected, lockout and tagout, cleaned (i.e. purging,inerting, flushing, steaming, etc.) and properly ventilated.

Note: A double block and bleed shall not be substitute for blinding or disconnecting ofinlets or outlets of the space. Although, double block and bleeds can be used in

conjunction with blinding and disconnecting of inlets or outlets.

The entry supervisor shall barricade the immediate area around the confined spaceto protect the space from unauthorized personnel, vehicles, etc. This will help protectentrants from external hazards being created after the permit has been issued. A“Danger Permit Required Confined Space”, “Do Not Enter” sign shall be placed onthe barricade.

All atmosphere testing and monitoring equipment used in, or to monitor atmospheresin, confined spaces shall be UL Listed or FM Approved as Intrinsically Safe or

Approved for Use in Hazardous (electrically classified) Locations. Atmosphere

testing and monitoring equipment must have a field calibration check before the initialuse each day. In addition, functional operation checks must be performed before andafter each use. All calibration checks must be recorded and maintained by theSafety, Health and Environmental Department. Personnel who perform gas testing oratmospheric monitoring must be trained. Entry attendant will be responsible forperiodically or continuously monitoring the confined spaces atmosphere

Note: All ventilations systems shall be turned off during atmosphere testing.

All permit required and non-permit required confined spaces must have theatmosphere tested before they are entered. Entry is not allowed into a confined

space with a "hazardous atmosphere".

Permissible exposures to abnormal atmospheres in Confined Spaces for purposes ofentry into confined spaces - a normal working atmosphere will be defined as onewhich contains an oxygen concentration of 19.5% minimum and maximumconcentration of 23.5% and is free of harmful amounts of flammable gases, dusts,and toxic materials (Less than 10% of the LFL and below the PEL or TLV). Anythingother than this will be considered an abnormal or alien atmosphere. Where normalatmospheres cannot be achieved, personnel will not be permitted to enter.

Entry personnel must be given the opportunity to witness all calibrations of

atmospheric testing equipment and atmospheric monitoring of the space. When entrypersonnel feel conditions within the confined space has changed, they can requestadditional monitoring to be performed.

Continuous monitoring of the Confined Space atmosphere shall be performed at alltimes during the entry. The Entry Supervisor shall recheck the atmosphere of theconfined space after all breaks.

Before any employee is permitted to enter a Permit Required Confined Space, aConfined Space Entry Permit must be completed by the Entry Supervisor.



J3. 11

The Entry Supervisor will communicate the following to all employees involved withthe confined space:

The conditions of the permit and hazards present within space.

The Material Safety Data Sheets (MSDS) of any chemicals present orpotentially present.

Communication procedures to be used between the authorized entrants andattendants shall be established during this meeting.

Required Personal Protective Equipment, within confined space.

Additional equipment to be used during entry, rescue equipment, alarmsystems, testing equipment, etc.

Duration of permit.

All employees involved in the confined space must read and sign the permit prior tothe posting of the permit at the entrance to the space.

A trained Attendant must be assigned and stationed at the entrance of all permitrequired confined space entry jobs. The authorized attendant shall ensure eachauthorized entrant’s name and time entering and exiting the space is placed on theback of the permit.

Anytime an authorized attendant will be monitoring more than one space, they shallhave radio communication with the entrants and the spaces shall not be more than10 feet a part from one another. The attendant may not perform any other duties

other than those of an authorized attendant.

A Confined Space Entry Permit is valid for one (1) shift. A new entry permit must befilled out, and posted at the main access way and reissued every shift or 12 hours.The permit is void and must be reissued whenever one of the following occurs:

A condition develops which was not covered by the permit.

Unauthorized entry of the Confined Space.

Facility Evacuation Alarm.

An incident within the confined space or outside the confined space that hasaffected the confined space.

The confined space permit shall not be removed until all personnel have signed offthe permit. The Entry Supervisor shall identify any problems encountered during theentry on the permit and forward the permit to the Safety, Health and EnvironmentalDepartment for retention. Some examples of problems encountered during any entrymay include:



J3.12

The unauthorized entry of a confined space.

A hazard not covered by the Confined Space Permit

An incident within the Confined Space or that affected the Confined Space.

The Safety, Health and Environmental Department will review all cancelled permits

for any problems that had been encountered during the entry. The Confined SpaceProgram shall be revised to address any problems that occurred during the entry. Allcancelled permits will be retained for 1 year and at a minimum shall be reviewedannually.

Personal Protective Equipment / Non Entry Rescue

Suitable personal protective equipment must be worn when entering a confinedspace. Although the equipment can vary depending on the assigned work, it mayinclude:

Self contained respiratory equipment

Acid or caustic resistant apparel i.e. slicker suits

Suitable hand protection

Eye and face protection

Head protection

Hearing protection

Foot protection

Safety harness

Personal protective equipment such as hard hats, safety glasses, face shields, andsteel toed boots etc., shall meet the applicable ANSI or other recognized industrystandards for the application.

Respiratory protection equipment shall have NIOSH Approval for the application.

Fall Protection & Rescue Retrieval equipment shall meet the applicable ANSIStandards for the application.

A full body harness with lifelines attached may be required for those who enter theconfined space. If a lifeline is not required for those entering and if entry is fromabove or through a manway, a lifeline must be immediately available to the standbyemployee.

Each authorized entrant using a full body harness must have a retrieval line attachedat the center of the entrant’s back near shoulder level, or above the entrant’s head.



J3. 13

Wristlets may be used in lieu of the full body harness, for horizontal entry, if the useof a full body harness is infeasible or creates a greater hazard and that the use ofwristlets is the safest and most effective alternative.

The other end of the retrieval line must be attached to a mechanical device or fixedpoint outside the permit space in such a manner that rescue can begin as soon asthe rescuer becomes aware that rescue is necessary. A mechanical device must be

available to retrieve personnel from vertical type permit spaces more than five (5) feetdeep.

Ventilation

General ventilation should be by exhausting from the confined space and dischargingto the outside.

Ventilation equipment should be placed at the top or bottom of the confined spacebased on the risk/nuisance factors to be encountered. For example, if the risk factorsare represented by lighter than air gases such as hydrogen (H2) or natural gas

(methane), the air mover must be near the top of the confined space where thesegases will rise. In all other circumstances, the air mover should be at the bottom ofthe confined space.

The inlet for ventilation air must be at a position upwind from the air mover to avoidshort circulating which defeats the purpose of ventilation, and away from dieselengines, etc., such as welding machines.

A positive means of ventilating the vessel or space must be established and operatedthe entire time work is in progress. The accepted practice and the recommendedlevel for general ventilation is one complete air change every three (3) minutes. In

some cases natural may be sufficient. In other cases it may be necessary to usefans or air movers. The ventilation system must be arranged so that only clean, freshair is drawn into the vessel. Ventilation systems should be bonded to the space orvessel.

If air operated horns are used to ventilate a space they must exhaust outside thespace, not inside. Air horns may only be operated by clean fresh air. Nitrogen,oxygen or other gases are hazardous and may not be used.

Whenever welding, cutting, burning or brazing is performed in a confined space, localexhaust ventilation may be necessary to "capture" contaminants or fumes at the

source (the point of operation) and remove them from the atmosphere within theconfined space. The exhaust air mover must be outside the Confined Space and aflexible hose/duct connected to it and extending to the point of operation. Hot WorkPermits are required before performing these operations in Confined Spaces. Note:The LEL during Hot Work shall be and remain at Zero during this type operation.

Specific Requirements

Compressed gas bottles (acetylene, oxygen, argon, nitrogen, air, etc.) must not bebrought into a confined space. Anytime work is suspended, welding leads andhoses must be removed from the confined space. This is to prevent leakage into the



J3.14

space, which would compromise the atmosphere, and to reduce the risk of anexplosive release into a small area where its effects would be greatly concentrated.

When painting, welding, burning, applying coatings, or doing anything, which mightgenerate gases, vapors or fumes, adequate ventilation and respiratory protectionmust be used. It should also be noted that coatings may cause a fire hazard.

Pneumatic tools should be used whenever possible to reduce the hazard of electricalshock and ignition sources. Pneumatic tools may only be operated with air. The useof nitrogen, oxygen, or other gas is prohibited.

Portable electric tools, lights and equipment operated in areas where there is apotential for flammable or combustible atmospheres to be present or accumulateshall be of industrial grade, in good condition and UL listed or FM approved asIntrinsically Safe or Approved for use in Hazardous (electrically classified) locations.Portable electric tools, lights and equipment used in Confined Spaces shall be ofindustrial grade, in good condition, operated at a maximum of 110 volts AC andconnected to a ground fault circuit interrupter, or be operated at no more than 12

volts DC.

When performing hot-work inside of vessels which contained a flammable orcombustible product, the following steps must be taken with written verification inaddition to all other confined space requirements to ensure vessel is safe for hotwork:

Ensure vessel is properly isolated, locked out and blinded with skillets.

Vessel needs to be cleaned of all hydrocarbons.

Once all hydrocarbons have been removed from the vessel, the vessel needs

to be closed off in preparation for steam cleaning.

A valve should be cracked open to drain liquids produced during the steamcleaning process.

Steam cleaning equipment needs to be setup and grounded. The purpose ofsteaming the vessel is to get the vessel hot enough so the pores of the metalopen up and the potential gases in the metal is released.

The vessel needs to be brought to an inside temperature of 120deg F.Depending on the size of the vessel, this could take several hours. A

temperature stick or thermal gun will be utilized to verify the internaltemperature has reached 120deg F. The vessel must continue to steam for 2hours at a temperature of 120deg F.

After steam cleaning has been completed, the equipment needs to be turnedoff and removed from the vessel.

The vessel should be opened up and ventilated, then verify LEL with aportable gas meter by a Confined Space Competent Person.



J3. 15

Rescue Services

Emergency notification, response and rescue plans must be made in advance. TheRescue Plan will be documented on the Pre-Entry Checklist and Hazard Assessment(See Attachment 1). If special equipment is needed such as, scoop stretches, safetyharnesses, retrieval lines, life lines, self contained breathing equipment, etc., it shouldbe made ready for immediate use. All rescue equipment shall be inspected by a

competent person prior to each entry. This will be documented on the Pre-EntryChecklist and Hazard Assessment. If there is a reasonable chance that lifethreatening incidents (asphyxiation or severe bleeding) may occur, an onsite rescueteam may be needed.

If the facility / site plans to use an offsite rescue team, facility / site management mustevaluate the capabilities of the response group to assure their response times areappropriate for the hazards. Agreement with offsite rescue teams should bedocumented and updated at least annually.

The rescue team shall be given the opportunity to evaluate the entry site, practice

rescue and decline as appropriate.

The rescue team shall have at least one person with a current First Aid / CPRcertification.

The members of the rescue team shall be provided all training and personalprotective equipment at no cost to them to safely perform a rescue.

Non-Permit Required Confined Spaces

To be classified as a "Non-Permit Required Confined Space" the Confined Space

must not have conditions which are, or could reasonably become, "ImmediatelyDangerous to Life or Health" (IDLH). Examples of "Non-Permit Required Spaces"might include, but not necessarily be limited to:

Pits less than four (4) feet in depth

Heating, ventilating or air conditioning (HVAC) plenums designed to beentered for servicing

Manholes or large diameter pipe that have very low or no potential for ahazardous atmosphere to develop.

Non-Permit Required Confined Space work should be conducted as work in regularwork areas. However, personnel should consider if:

There have been changes in the Confined Space since it was determined tobe a "Non-Permit Required Confined Space".

The work planned could cause Confined Space to become "ImmediatelyDangerous to Life or Health" (IDLH).



J3.16

Other work being performed in the area of the "Non-Permit Required ConfinedSpace" could cause it to become "Immediately Dangerous to Life or Health"(IDLH).

If any of the above apply, the Non-Permit Required Confined Space should betreated as a Permit Required Confined Space. If there is any question about theclassification, stop and check with your supervisor.

Pipe Fabrication and Confined Space Classification

The fabrication of pipe or other equipment may create a permit required space atsome point in the fabrication process. If, during the fabrication of equipment, theconfined space becomes difficult to enter or exit or could be subject to a hazardousenvironment, the Facility Manager, a Safety, Health, Environmental DepartmentRepresentative, Yard Foreman, and the First Line Supervisor will decide if specialprecautions and / or a permit is required. If all individuals involved cannot agree, thespace must be classified as Permit Required.

Training

Confined Space Entry training will be performed so that all employees acquire theunderstanding, knowledge, and skills necessary for the safe performance of theirassigned duties within the confined space entry process.

Training shall be performed to each affected employee on the following intervals:

Before the employee is first assigned duties under this program;

Before there is a change in assigned duties;

Whenever there is a change in permit space operations that presents a hazardabout which an employee has not previously been trained;

Whenever there is reason to believe either there have been a deviation fromthe permit space entry procedures or that there are inadequacies in theemployee's knowledge or use of these procedures.

Training of affected employees shall establish the employee proficiency in their dutieswithin this program and shall introduce new or revised procedures as necessary.

The employee training shall be certified that the training has been accomplished byproviding the following information within the employees training records:

Employee’s Name

Signature or initials of the Trainer

Dates of training



J3. 17

Certifications shall be available for inspection by employees and their authorizedrepresentatives upon their requests.





J3.18

Attachment 1





J3.18.a.1 1

Date: Job Name: Job Number:

Confined Space Pre-Entry Checklist & Hazard Assessment

The following checklist is to be used to evaluate any confined space prior to an entry attempt. Thischecklist will be turned in with all other applicable forms including but not limited to Confined SpacePermit, JSA, Tool Box Safety Forms or Site Safety and Health forms as required. These forms shallbe retained for three (3) years.

Do not enter any confined space until you have determined that acceptable entry conditions exist anda Moreno Group LLC and Subsidiaries confined space entry permit has been completed. A permitwill be accomplished whether it is a stand-alone permit or a parallel permit with thecustomers.

Pre-Job Conference

Yes No N/A

Is the entry necessary?

Has the customer informed Moreno Group LLC and Subsidiaries of thehazards applicable to the Confined Space?

Is there a potential for any of the following conditions to be present?

Oxygen Deficient / Enrichment Toxic Atmosphere

Flammable or Explosive Atmospheres Engulfment

Corrosive Atmospheres Electrical

Reactive (oxygen or water) Mechanical

Temperature Extremes

Have Material Safety Data Sheets been obtained from the customer?

Has the area been surveyed for external hazards? (i.e., drifting vapors,nearby hot work, traffic and vehicular movement, potential ignition sources,etc.)

Have you reviewed with the customer hazards specific to Moreno Group LLCand Subsidiaries equipment processes?

Lock Out / Tag Out, Binding and Blanking

Yes No N/A

Has the space been isolated from all other systems?

Has all electrical equipment been locked out?

Have disconnects been used where possible?

Has mechanical equipment space been blocked, chocked and/ordisengaged?

Have all the lines in the space that are under pressure been blanked or bled?

Has the space been washed, cleaned or rinsed before entry is made?



J3.18.a.2

What are the physical characteristics of any remaining contents in the space?

Solids Liquids Semi-Solids Dusts SludgesGases Vapors Other

Was the space steamed? If so, was it allowed to cool? Yes No

Are there other extreme temperature hazards present? Specify:

Atmospheric Testing

Yes No N/AIs the person conducting the testing trained in the proper use of the testingequipment?

Are the instruments being used for testing properly calibrated? (manufactureror field)

Has the Atmosphere in the Confined Space been tested?Specify person by name: Position:

Was the oxygen content at least 19.5% and less than 23.5%?

Were there toxins, flammables, oxygen displacing gases / vapors present?

Will the atmosphere in the space be monitored while work is ongoing?Specify intervals: ContinuouslyPeriodically

Note: Atmospheric changes can occur due to the work procedures or the product stored.The atmosphere may be safe on initial entry, but can change very quickly.

Ventilation:

Yes No N/AHas the space been ventilated prior to entry?

Will ventilation be continuous during entry?Mechanical Natural Draft

Is the air intake for the ventilation system located in an area that is free ofcombustible dusts, vapors / gases and toxic substances?

If the atmosphere was found unacceptable and then ventilated, was it re-testedand found acceptable prior to entry?

Personal Protective Clothing / Equipment

Yes No N/AIs specialized clothing required? If so, specifyLevel of Protection A B C DOther

Are special tools required? If so, specify, (i.e., spark proof, explosion proof,etc.)



J3.18.a.3

Respiratory Protection Requirements

Yes No N/AIs respiratory protection required? Air Purifying Supplied Air SCBA

Specify: Manufacturer: Cartridge Type:

Can entrants / rescuers get through the opening with an SCBA on? (If youdon’t know, find out prior to beginning the job)

Training

Yes No N/AHave all participants been trained / fit tested in the proper use of the respiratorrequired for entry?

Has at least one person on the team been trained and certified in 1st Aid and

CPR?

Have all participants been trained in Confined Space Procedures?

Entry Supervisor / Competent Person

Entrant

Attendant

Attendant / Rescue

Yes No N/AWill there be an attendant on the outside in constant visual or auditorycommunications with the entry team on the inside?

Will the attendant be able to hear and see the entrants at all times?

Has the attendant been trained in Emergency Procedures?

Has an Emergency Rescue Action Plan been completed?

Are safety lines and harnesses in place to assist in removing a person?

Are rescue procedures available to be followed in the event of an emergency?

Are all participants familiar with emergency rescue procedures?

Do all participants know who to notify, and how, in the event of an emergency?

Rescue Equipment Inspection

The following checklist shall be conducted by a competent person responsible for emergency retrievalof personnel onsite prior to use of the equipment on a daily basis while it is on the worksite. Thischecklist satisfies the daily inspection and monthly inspection procedures set forth by themanufacturers recommendations.

Yes No N/AInspect all screws, bolts, nuts to ensure they are tight and not bent or broken.

Inspect all covers, housings, and guards to ensure free of cracks, dents, or otherdamage.



J3.18.a.4

Yes No N/AInspect crank handle to ensure that it locks positively onto the shaft and be free ofcracks, bends, or any other visible damage.

Inspect connecting hook to ensure there is no damage, breaks, distortion, or haveany sharp edges, burrs, cracks, worn parts, or corrosion.

Insure the connecting hook works properly. Hook gate must move freely and lock

upon closing. Hook must swivel freely.

Inspect wire rope assembly starting at the hook by bending along the length of thecable by inspecting closely for cracks, breaks, corrosion, or frayed strands.

Inspect all identification and warning labels ensuring they are legible and securelyattached.

Inspect each system component (support structure, backup fall arrest system, bodysupport, and connectors.

Inspect the winch locking mechanism, drum, and drum sprocket for damage. Thelocking mechanism should move smoothly in and out of the drum sprocket.

Check operation of the winch in high speed and low speed positions. Must crankup and back down freely.

Inspect the ratchet brake with brake engaged. The drum should be prevented fromreleasing cable. The spring must be in place and not damaged.

Inspect for oil in the gearbox by removing plug on top and tilting unit so oil can beseen through the hole. Then inspect for leaks. Replace with SAE 80 or 90 gear oil ifneeded.

Check operation of the handle over the speed brake.

Confined Space Emergency Rescue / Action Plan

The following checklist can be used to establish a rescue plan for each confined space. Modify thisplan as necessary to fit the specific situation. Once completed, the checklist becomes part of thepermanent record and may not be destroyed for three (3) years.

General Information

What are the Confined Space Atmospheric hazards?

What is or was in the Space that makes it hazardous?

Emergency Communications

Identify the method to be used to notify site workers of an emergency situation and evacuation of thework site (portable air horn, radios, hand signal, etc)



J3.18.a.5

The following standard hand signals will be used in the event audible communications are lost.

Hand Gripping Throat Out of air / Can’t breathe

Grip Partners Wrist or Leave area immediatelyBoth Hands Around Waist

Thumbs Up I’m OK, I understand

Thumbs Down No. Negative

Emergency Procedures (Modify as Necessary)

The Entry Supervisor and/or Project Manager shall be notified of any on-site emergencies and areresponsible for ensuring that the appropriate procedures are followed. In addition, the CustomerRepresentative and a Moreno Group LLC and Subsidiaries Safety person will be notified of allaccidents, incidents, near misses and/or illnesses that occur at the Customer facility.

Change of Conditions or Unsafe Situation Discovered

The Entry Supervisor and/or Attendant shall:

Order authorized entrants out of the Confined Space

Provide assistance as necessary for removing personnel from the Confined Space (No Entry)

Remove and cancel the Entry Permit

Post the “Do Not Enter” tag at the entryway

Standby until acceptable entry conditions are re-established and a new permit issued

Notify a Moreno Group LLC and Subsidiaries Safety person





J3.19

Attachment 2





J3.19.a.1





J3.20

Attachment 3





J3.20

MORENO GROUP LLC AND SUBSIDIARIES



J3.20.a.2




Management SystemCrane Policy


J4.1

Crane PolicyPurpose

The purpose of this policy is to establish and set guidelines for the safe use of materialhandling equipment related to crane operations per 29 CFR 1910.179, 29 CFR 1910.180and API RP 2d.

Scope

This procedure applies to all Dynamic employees, non-permanent employeesand sub-contract employees who operate, use, inspect, maintain or work aroundcranes.

Responsibilities

The Facility Manager / Yard Manager / Offshore Manager or Designee isresponsible for:

Continually communicated to First Line Supervision the employees’ right to use―STOP WORK AUTHORITY‖.


Evaluating mobile equipment needs for the facility / site, preparing detailed purchase/ rental specifications and providing sufficient equipment to support the needs ofDynamic Industries.


Assuring that equipment operators are properly trained and qualified to operatespecific machines.

Ensuring that no modifications or additions are made to equipment without themanufacturer’s written approval.

Ensuring that all work group investigations, significant incidents, property damagereports, and general information regarding mobile / motorized equipment iscommunicated to applicable employees.

Informing all Contractors of this procedure during the project meeting and ensure theContractor follows the requirements of this procedure.



J4.2



STOP WORK anytime any employee is in questioning the lift or lift operation or workactivities around lift operation.

Identify the hazardous area (Red Zone) around operating equipment, and notify allaffected personnel of this area.

Conferring with personnel reporting to them as to the hazards of specific jobs andthe crane to be used.

Assuring that equipment is inspected, operated and maintained in accordance withthis procedure and the manufacturer’s recommendations.

Assuring that only trained, authorized and physically fit personnel operate andmaintain equipment.



Use ―STOP WORK AUTHORITY‖ anytime the operator is questioning the lift or liftoperation or work activities around lift operation.


Remaining alert and not operating equipment if mentally or physically impaired.Consulting with the supervisor if taking either over-the-counter or prescriptionmedication.


Surveying the work areas for hazards and erecting barricades as necessary.

Obeying all traffic rules including speed limits, signals and warning signs.


Reading and being familiar with the manual for the equipment being operated andoperating the equipment as intended by the manufacturer.





J4.3

Notifying supervision of any significant incidents, property damage or near misseswith regards to mobile / motorized equipment.

The Signal Person is responsible for:

Providing clear signals and being able to recognize hazards and signal the operatorto avoid them (see Attachment 1).

Use ―STOP WORK AUTHORITY‖ anytime the signal person is questioning the lift orlift operation or work activities around lift operation.

The Personnel Working Around Equipment are responsible for:

Use ―STOP WORK AUTHORITY‖ anytime any employee is questioning the lift or liftoperation or work activities around lift operation.



Staying out of designated ―Red Zone‖.



Remaining alert and responding as necessary when an equipment warning device isheard.


Definitions

Qualified Operator - A person who has received and successfully completed an appropriatecrane operators training, authorized by Dynamic Industries to operate the equipment andmeets the following physical qualifications:

Have vision of at least 20/30 Snellen in one eye and 20/50 in the other with orwithout glasses, and have no depth perception problems.

Be able to distinguish red, green and yellow, regardless of position of colors, if colordifferentiation is required to crane operation.

Have hearing, with or without a hearing aid, adequate for the specific operation.

Have no history of disabling medical condition, which may be sufficient reason fordisqualification



J4.4

Qualified Inspector - A person who has received and successfully completed theappropriate crane maintenance and is designated by the employer.

Qualified Rigger – A rigger is anyone who attaches or detaches lifting equipment to loadsor lifting equipment and/or anyone who directs or signals a lift operation. This person shallhave the training and experience and who has successfully completed a rigger trainingprogram.

Initial Inspection - An inspection that applies to cranes that are new to the location and arebeing placed into service and are being permanently relocated. A qualified inspector shallconduct this type of inspection. Every initial inspection shall include a load test.

Pre-use Inspection - An inspection that is performed daily by the qualified operator. Thistype of inspection shall be conducted prior to beginning each new shift.

Designated Personnel - Only designated personnel shall be permitted to operate a cranecovered by this policy.

Red Zone- Designated area around a crane or equipment that must be clear of all non-

essential personal before operation begins.

Requirements

Mobile Cranes

All cranes shall have specifications as to their rating and load capacity for safe operation.The qualified operator to ensure the safety of the operation shall strictly follow the ratingmeasurements. The operating rating chart and load chart shall be visible to the operator atall times. The manufacturer’s load rating shall not be exceeded unless prior approval isobtained from the manufacturer. All crawler, truck, or locomotive cranes in use shall meet

the applicable requirements for design, inspection, construction, testing, maintenance andoperation as prescribed in the ANSI B30.5-1968 including all jibs shall having positive stopsto prevent their movement of more that 5 degrees above the straight line of the jib andboom on conventional type crane booms.

A qualified inspection company under the following conditions shall conduct certified loadtests:

New cranes being placed into service.

Cranes that are being permanently relocated.

Temporary / rental cranes after each rig-up or relocation.

The documentation illustrating the load test procedure and the results shall be maintainedreadily available for a period of 3 years at the facility



J4.5

Mobile Crane Operator Training Requirements

New Hire

All employees being hired to operate a mobile crane, must contain and present a currentcertification for the type of crane (i.e. cherry picker or crawler) they are being hired tooperate.

Upon successful completion of Dynamic Industries, Inc. New Hire Process (i.e. medicalsurveillance, etc.) and our New Employee Hire Process and New Employee Orientation /SH&E Training, this new operator must obtain a new mobile crane certificate from DynamicIndustries, Inc. This training / certification shall be performed by a recognized Third PartyTraining Company. This training / certification shall be performed at least every 4 years.

The training shall meet all regulatory and industry requirement that includes classroom,written and practical examinations. The practical examination shall be performed on thelargest capacity mobile or crawler crane operated at our facilities. Should the operator havethe potential to operate both a mobile and/or a crawler crane, they shall receive training on

both types of cranes. Upon completion of this training, the mobile crane operator shallreceive a competency assessment from their supervisors, utilizing the appropriate operatorperformance evaluation form. (See Attachment 7)

Current Employees

All employees who are being promoted to a mobile crane operator status shall be medicallycleared prior to receiving their Mobile Crane Training / certificate. This training / certificationshall be performed by a recognized Third Party Training Company. At least annually eachmobile crane operator shall receive a competency assessment from their supervisors,utilizing the appropriate operator performance evaluation form. (See Attachment 7)

The training shall meet all regulatory and industry requirement that includes classroom,written and practical examinations. The practical examination shall be performed on thelargest capacity mobile or crawler crane operated at our facilities. Should the operator havethe potential to operate both a mobile and/or a crawler crane, they shall receive training onboth types of cranes. This training / certification shall be performed at least every 4 years.

Note: If the operator does not maintain and present documentation of a current operatorcertification, local Management and the SH&E Department will need to discuss anapprenticeship program for this operator perform allowing them to operate.

Load Chart Considerations

Read the operation notes supplied with the machine closely and thoroughly. The notes willcontain important information concerning proper set-up, operation and any additional pointsthat need to be considered when calculating load handling capacities of the crane.



J4.6

Inspection Records

Certification records, which include the date of inspection, the signature of the person whoperformed the inspection and the serial number or other identifier of the crane, which wasinspected, shall be made daily. The daily (pre-use) shall be maintained for 1 calendarquarter (see Attachment 2) and the periodic inspections shall be maintained readily for 3years.

Inspection Program

The following reflects the requirements of OSHA 1910.179(j) and (m) and constitutesminimum inspection requirements. Prior to initial use all new and modified cranes musthave an initial inspection to ensure they are in good condition and safe for use.

Inspection procedure for cranes in regular service is divided into two general classificationsbased upon the intervals at which inspection should be performed. The intervals aredependent upon the nature of the critical components of the crane and the degree of theirexposure to wear, deterioration, or malfunction. The two classifications are designated withrespective intervals between inspections as:

Frequent inspection -- Daily to monthly intervals.

Periodic inspection -- 1 to 12 month intervals.

Note: Should either of the above mentioned inspection indicates the need for anondestructive type of testing of the crane hook, the use of outside firm to perform the non-destructive testing of Dynamic’s equipment requires written proof that technicians arecertified to the latest requirements of the Society for Non-Destructive Testing and that theirinspection equipment was calibrated prior to the inspection itself.

Frequent Inspections

The following items must be inspected for defects at daily to monthly intervals or asspecifically indicated. This must include observation during operation for any defects whichmight appear between regular inspections. All deficiencies must be carefully examined anda determination made as to whether they constitute a safety hazard.

All functional operating mechanisms for maladjustment interfering with properoperation.

Deterioration or leakage in lines, tanks, valves, drain pumps, and other parts of air or

hydraulic systems.

Hooks with deformation or cracks. Visual inspection with a certification record whichincludes the date of inspection, the signature of the inspector, and the serial number,or other identifier, of the hook inspected. Hooks with cracks, or those having morethan 15 percent in excess of normal throat opening or more than 10 degrees twistfrom the plane of the unbent hook must be discarded.

Hook safety latch/wire in undamaged and functional.



J4.7

Hoist chains, including end connections, for excessive wear, twists, distorted linksinterfering with proper function, or stretch beyond manufacturer's recommendations.Visual inspections with a certification record which includes the date of inspection,the signature of the inspector and an identifier of the chain which was inspectedshall also be included.

All functional operating mechanisms for excessive wear of components.

Wire rope reeving for noncompliance with manufacturer's recommendations.

Spreader bars must be checked for mechanical integrity to locate cracks, bends,deformations, connecting devices, etc. If any deficiencies are found, they need to becorrected before operation is started. The deficiencies and corrective actions shallbe documented and maintained for 1 calendar quarter at the facility.

Periodic Inspections

Complete inspections of the crane should be performed at one to twelve month intervals,

depending upon its activity, severity of service, environment, or as specifically indicatedbelow. These inspections must also include the following items. Any deficiencies must becarefully examined and determination made as to whether they constitute a safety hazard.

Deformed, cracked or corroded members.

Loose bolts or rivets.

Cracked or worn sheaves and drums.

Worn, cracked or distorted parts such as pins, bearings, shafts, gears, rollers,locking and clamping devices.

Excessive wear on brake system parts, linings, pawls, and ratchets.

Load, wind, and other indicators over there full range, for any significantinaccuracies.

Gasoline, diesel, electric, or other powerplants for improper performance ornoncompliance with applicable safety requirements.

Excessive wear of chain drive sprockets and excessive chain stretch.

Electrical apparatus, for signs of pitting or any deterioration of controller contacts,limit switches and pushbutton stations.

Cranes Not in Regular Use must be inspected as follows:

A crane which has been idle for a period of one (1) month or more, but less than six(6) months, must be given an inspection conforming with all requirements of thisprocedure before placing it in service.



J4.8

A crane which has been idle for a period of over six (6) months must be given acomplete inspection conforming with requirements of this procedure before placing itin service.

Standby cranes must be inspected at least semi-annually in accordance withrequirements of this procedure.

Running Ropes

A thorough inspection of all ropes must be made at least once a month and a certificationrecord which includes the date of inspection, the signature of the inspector, and anidentifier for the ropes which were inspected must be kept on file where readily available.

Any deterioration, resulting in appreciable loss of original strength must be carefullyobserved and determination made as to whether further use of the rope would constitute asafety hazard. Some of the conditions that could result in an appreciable loss of strengthare the following:

Reduction of rope diameter below nominal diameter due to loss of core support,

internal or external corrosion, or wear of outside wires.Reductions from nominal diameter of more than 1/64‖ for diame ters to andincluding 5/16‖.

Reductions from nominal diameter of more than 1/32‖ for diameters 3/8‖ to andincluding ½‖.

Reductions from nominal diameter of more than 3/64‖ for diameters 9/16‖ to andincluding ¾‖.

Reductions from nominal diameter of more than 1/16‖ for diameters 7/8‖ to 1 1/8‖inclusive.

Reductions from nominal diameter of more than 3/32‖ for diameters 1 ¼‖ to 1 ½‖inclusive in standing ropes, more than two broken wires in one lay in sectionsbeyond end connections one more than one broken wire at an end connection.

A number of broken outside wires and the degree of distribution or concentration ofsuch broken wires.

Worn outside wires.

Corroded or broken wires at end connections.

Corroded, cracked, bent, worn, or improperly applied end connections.

Severe kinking, crushing, cutting, or unstranding.

All rope and choker cables, which have been idle for a period of a month or more due toshutdown or storage of a crane on which it is installed, must be given a thorough inspectionbefore it is used. This inspection must be for all types of deterioration and must beperformed by an appointed or authorized person whose approval is required for further useof the rope. A certification record must be available for inspection, which includes the dateof inspection, the signature of the inspector and an identifier for the rope, which wasinspected.



J4.9

If any deficiencies are found, they need to be corrected before operation is started. Thedeficiencies and corrective actions shall be documented and maintained for 1 calendarquarter at the facility.

Preventive Maintenance Program

A preventive maintenance program based on the crane manufacturer's recommendationsmust be established by Maintenance Services. Records of the preventive maintenanceinspections must be kept for the life of the equipment.

Adjustments and repairs on a crane and other lifting equipment must include the followingprecautions:

The lifting equipment to be repaired must be run to a location where it will cause theleast interference with other equipment and operations in the area.

Where other lifting devices or equipment are in operation on the same runway, rail

stops or other suitable means must be provided to prevent interference with the idlecrane.

Safe Operating Practices for Mobile Cranes

Cranes are carefully designed, tested and manufactured. When used properly by qualifiedoperators, they will give safe, reliable service.

Because cranes have the ability to lift heavy loads to great heights, they also have apotential for accidents if safe operating practices are not followed. This section will helpyou prevent accidents which could result in injury, death or property damage.

General safe practices for working on machinery must be followed as well as the safeoperating practices recommended here.

Safety devices installed on any crane shall not be over ridden. Should a safety deviceneed to be over ridden to perform a lift safely, this lift must be approved by FacilityManagement. A specific JSEA shall be developed for this lift which shall include a spotter.First line Supervision and a SH&E Representative shall be present during this lift.

Safety device shall not be over ridden for any lift involving the lifting of personnel.

Each crane shall have a dry chemical fire extinguisher located in the crane cab.

Crane’s swing radius shall be barricaded to prevent employees and equipment access intothe area of the swing radius.

No loading or unloading of equipment and/or material is allowed after normal working hourswithout Management's approval.



J4.10

Whenever internal combustion engine exhausts in enclosed spaces, tests shall be madeand recorded to see that employees are not exposed to unsafe concentrations of toxicgases or oxygen deficient atmospheres.

Planning the Job

Most accidents can be avoided by careful job planning. The person in charge must have aclear understanding of the work to be done, consider all dangers at the jobsite, develop a

plan to do the job safely (i.e. Job Safety and Environmental Analysis), and then explain theplan to all involved in the crane operation. Factors such as these should be considered:

What crewmembers are needed and what responsibilities will they be given?

What is the weight of the load to be lifted, the lift radius, boom angle and the ratedcapacity of the crane?

How will the signalman communicate with the operator?

What equipment is required to do the job safely?

How can the equipment be safely transported to the jobsite?

Is the crane safe to mount and dismount using the handholds and steps provided bythe crane manufacturers?

Are there power lines or structures, which must be moved or avoided?

How will loads be rigged?

What special safety precautions will be taken if the crane must travel with asuspended load or if more than one crane is needed to lift a load?

Are unusual weather conditions such as wind or extreme cold weather expected?

What steps will be taken to keep unnecessary people and equipment safely awayfrom the work area? Is barricade tape needed to identify hazards and the work area?

How can cranes be positioned to use the shortest boom and radius possible?

Note: A crane lift plan shall be utilized for lifts greater than 50% of the crane's rated

capacity, if two are more cranes are used or if other conditions warrant a critical lift.

Operating Precautions

Only qualified and properly designated operators shall operate the machine. The operatorneeds to know the location and purpose of all controls, instruments, indicator lights andlabels. An operator also needs to comprehend load chart notes and accurately calculate amachine’s load handling capacity.



J4.11

General Operation

The engine should not be started if the main, auxiliary hoist and/or swing are released. Always warm up the engine and hydraulic system before attempting to operate themachine. Watch all instrument readings, if readings are not correct stop the engine andfind cause.

Avoid sudden applications of all controls, particularly at start and end of each operation.

Propel with engine rpm’s around ―medium position‖.

Avoid Power Lines

Always survey the work area to determine whether there are power lines in the area.OSHA regulations require at least ten (10) feet clearance from lines carrying up to 50,000volts. Greater clearances are required for lines with higher voltages. All overhead powerlines shall be considered energized unless verified and indicated by the utility companyowning the line that it has been de-energized and grounded. Some states require that you

stay as far as possible from power lines and never violate minimum clearances. In theState of Louisiana, we must notify the owner of the electrical line within 48 hours of ouroperation. The power company must determine if line will be deenergized or other meanswill be put in place.

Always take these precautions if power lines are present:

Warn people to stay away from the machine and load at all times. An observer should beplaced to ensure the radius of the crane, maintains the appropriate clearance from theenergized lines. If the load must be guided into place, ask the Power Company about

special precautions such as insulated poles or hot sticks.

Warning: Careful planning and supervision offer better protection than any known device.Insulated boom cages, proximity devices, and insulating links have limitations and can failwithout warning. Insulated boom cages and links only protect part of the crane, and canbreak down electrically when contaminated with dust and water. Operation of proximity,warning devices can be affected by the different arrangement of multiple power lines, themovement of trucks, materials, the crane itself, and other influences. Relying completelyon these devices could be dangerous because operators may think they are providing

protection when in fact they are not.

During Operation

Foot pedal brake locks are furnished on some cranes to allow the operator to resthis legs when suspending the load for short periods of time. Keep your feet on thepedals while foot pedal brake locks are in use. Brakes may cool, if not leaked downproperly, allowing the load to fall.

When you operate the crane, do not let another person on the machine.



J4.12

When you get on or off the crane, use handrails and steps. Start the engine only in awell-ventilated area.

Before you move the boom, swing, travel or hoist ensure all persons are away fromthe load area.

Trying to repair or adjust equipment with a suspended hook or load or with the boomraised could release machinery and let it move unexpectedly. Always lower the load

to the ground and the boom onto proper cribbing before doing maintenance or repairwork.

Leaving a machine unattended can be very dangerous. Never leave the operator’scab with the engine running or with the load suspended. Before leaving his or hersseat, the operator shall take the following steps to prevent his machine from moving:

Lower the load to the ground.

Lower the boom when necessary.

Set the swing brake or lock.

Set all drum pawls.

Set parking brakes and shut off engine.

Suspended Loads

An Operator shall avoid swinging a load over personnel and not allow them to work or walkunder any part of machine or load.

A warning signal shall be sounded when approaching personnel.

Apply hoist brake, drum pawls and swing brake if the engine stalls during operation.

Pick and Carry

Load ratings for cranes are based on the machine being stationary and level. Traveling acrane with a suspended load or with the boom erected involves special hazards, includingthe possibility of side loading or tipping over.

Because of the many variables involved in pick and carry operations, the user must

evaluate conditions and take precautions such as these:

Check the load chart and notes for limitations.

Position the boom in line with the direction of travel.

Reduce the maximum load while traveling to reflect operating conditions. The safeload will vary depending on speed, crane, terrain and other conditions.

Travel slowly and avoid sudden stops and starts.



J4.13

Avoid backing away from the load. This could increase the radius and cause themachine to tip over.

Use tag lines to keep loads under control.

Keep the load close to the ground while using the shortest boom possible.

Move Crane Safely

Before you move a crawler or wagon crane; find out which way to move propel levers

for the direction you want to go. If the propel motors are in front of the cab, pull thepropel levers back to move forward.

When traveling:

Do not travel near the edge of a ditch, gully or excavation.

Travel carefully where room is limited, over rough ground and on slopes.

Use a signal person.

Know your machine height, width and weight.

Know bridge load limits and do not exceed them.

Be sure of tail swing clearance in a narrow spot.

Control travel speed for safely moving and ensure ball or block is secure.

Park Safely

Before the operator leaves the cab ensure the following is conducted:

Lower the load to ground and apply the brakes.

Put control levers in neutral position.

Shut off engine.

Never park on an incline with out carefully blocking the machine to preventmovement.

Do not leave it where there is a chance of a bank caving in or a low spot where rainsmay wash out the footing.

Take the engine key and the cab door key with you.



J4.14

Always dismount facing the crane using handholds and step provided by youremployer or crane manufacturer.

Offshore Cranes

A qualified operator (API RP 2d qualified) shall conduct all offshore crane operations. Allcrane operations shall be conducted in a safe manner. At a minimum this shall include thefollowing:

The operator will perform a Pre-Use Inspection.

The crane operator will become familiar with the load in respect to it’s weight andconfiguration including all special rigging used to lift it prior to making the lift.

When determining if the fast line can be used for a lift, identify from the load chartthe dynamic lifting capacity of the crane (fast line) at the lowest proposed lift angle orlongest radius. If the lift is within 10% of this dynamic lifting capacity the fast lineshall not be used.

The crane shall not be overloaded.

Loads shall not be moved over personnel.

All personnel involved in the lifting operations shall develop and review a Job Safetyand Environmental Analysis to clearly communicate the lifting operation. Allpersonnel must be clear of the load before it is lifted or moved.

Crane lifting operations may not begin until the crane operator has designated onequalified signal person for all areas where the crane operator's vision is, or will be,obstructed during any part of the lift. The crane operator and the signal person(s)must maintain direct communication with each other throughout their portion of thelift either visually or by radio. Examples of situations requiring two signal personswould include lifts from one deck to another deck (if the signal person from one deckremained on that deck) and lifts to and from boats.

The crane operator shall respond to signals only from the designated signalperson(s), but shall obey any "STOP" signal from anyone whenever it is given. If astop signal is given, crane operations shall cease until the appropriate designatedsignal person verifies that it is safe to resume operations. When it is safe to resumeoperations, the appropriate designated signal person shall communicate that fact tothe crane operator.

When helicopter approaches a facility, the crane boom shall be swung away fromthe heliport, the swing lock shall be engaged, and the crane operator shall step outof the cab of the crane. Pilots have been instructed not to land if anyone is in acrane cab. If a lift is in progress, the lift should be completed before the crane issecured.



J4.15

Due to potential safety hazards, the crane boom shall be properly cradled under thefollowing conditions: severe weather, high winds, and periods of infrequent use(defined as: several hours, not days) especially at night.

On lifting, the load hook shall be positioned directly over the load to avoid a sidethrust on the boom and to prevent the load from swinging. The swing brake shouldbe unlocked at this time to allow the boom to track the load.

The crane shall not be used in a manner that might result in shock loading (forexample, pulling up grating that is still welded to the platform).

Safety devices installed on any crane shall not be over ridden. Should a safetydevice need to be over ridden to perform a lift safely, this lift must be approved byOffshore Management. A specific JSEA shall be developed for this lift which shallinclude a spotter. First line Supervision and a SH&E Representative shall bepresent during this lift.

Safety device shall not be over ridden for any lift involving the lifting of personnel.

Personnel Transfer

A personnel basket will be used for all offshore transfers between a facility and aboat whenever the crane is used to make the transfer.

Only properly designed workbaskets shall be used as work platforms orworkstations. Personnel baskets are not designed for this purpose and shall not beused as such.

Crane hooks used to lift personnel baskets will have a positive locking device (not aspring loaded flap or clip)

All shackles incorporated in a Personnel Basket lifting configuration will be tight andwire locked.

Personnel lifts to and from a motor vessel shall be swung over water wheneverpossible.

All personnel being transferred over water must wear an approved life preserver thatis properly donned.

A maximum of four (4) personnel are permitted to ride in the personnel basket at atime.

Personnel riding on the personnel basket shall ride on the outside of the basket,facing inward, with their arms locked around the netting.

Personnel baskets will be equipped with tag lines free of knots.



J4.16

Cargo other than personal hand luggage and small supplies and equipment will notbe transferred with the personnel basket. Cargo must not overhang the edge of thepersonnel basket.

All personnel baskets will have a safety "shock" load strap.

Cranes shall not be used to raise or lower personnel into or out of tanks or otherproduction vessels. Only properly designed personnel hoisting equipment shall be

used for this purpose.

Personnel are not allowed to ride on the following: any load, slings, cables,"headache" ball (connected to the whip line or fast line), nor the load block.

All personnel lifts shall be under power control both up and down.

Offshore Operator Training Requirements

New Hire

All employees being hired to operate an offshore crane must contain and present acurrent certification for the type of crane they are being hired to operate.

Upon successful completion of Dynamic Industries, Inc. New Hire Process (i.e. medicalsurveillance, etc.) and our New Employee Hire Process and New Employee Orientation /SH&E Training, this new operator must obtain a new API RP 2d offshore pedestal cranecertificate from Dynamic Industries, Inc. This training / certification shall be performed by arecognized Third Party Training Company. The training shall meet all requirements of thelast edition of API RP 2d and shall be performed at a minimum every 4 years.

Current Employees

All employees who are or being promoted to an offshore crane operator status shall bemedically cleared prior to receiving their API RP 2d training / certificate. This training /certification shall be performed by a recognized Third Party Training Company. Thetraining shall meet all requirements of the last edition of API RP 2d.

Note: If the operator does not maintain and present documentation of a current operatorcertification, local Management and the SH&E Department will need to discuss anapprenticeship program for this operator prior to allowing them to operate for DynamicIndustries, Inc..

Overhead Cranes

Before operating the crane, the crane operator should carefully read and study theoperation manual supplied by the Crane manufacturer and note any special instructions notgiven previously by the proper instructor or supervisor.

With the mainline switch open (power off) the crane operator should operate each masterswitch or push button in both directions so as to get the ―feel‖ of each device and also to



J4.17

determine that they do not bind or stick in any position. If any of them do, before doinganything else, the operator should report the condition to the proper supervisor.

Overhead Cranes Operator Qualifications

Crane operation, requires skill, the exercise of extreme care and good judgment, alertness

and concentration. No individual shall be permitted to operate an overhead crane if theirsupervisor has not designated them. The supervisor shall ensure the individual meets thefollowing criteria’s:

One who can speak the appropriate language or read and understand the printedinstructions;

One who is of legal age to operate this type of equipment;

Whose hearing or eyesight is not impaired, or suitably corrected, with good depthperception;

The operator has carefully read and studied the operation manual supplied by theCrane Manufacturer;

The operator has been properly trained;

The operator has demonstrated his instructions through practical operation;

The operator is familiar with hitching equipment and practices.

Operator Responsibility

The crane operator should be held directly responsible for the safe operation of the crane.Whenever there is any doubts as to safety, the crane operator should stop the crane andrefuse to handle loads until:

Safety has been assured.

The operator shall not permit anyone to ride on the hook or the load.

Learning the Controls

Having observed the feel of the controllers, the crane operator is now ready to try the cranewith power applied.

After checking to be sure no one is on or near the crane, close the crane disconnectingmeans and press the ―ON‖ or ―RESET‖ button so that the power is ―ON‖.

Try the hoisting motion first. The hook should be in an intermediate position. Move themaster or push button slowly in the ―up‖ direction or press the ―UP‖ button in the pendant in



J4.18

the same manner. The resultant movement should correspond with master switch or pushbutton markings for all motions. Observe the speed increase in relation to the steps in thecontroller. Try to feel the steps in a pendant-type controller. Move the hook to a positionnear the upper hook position and slowly inch the hook into the upper limit stop position.The limit switch should cause the hoisting motion to stop at the upper limit of travel. If anymalfunction of either the hoist brake or the limit switch is suspected, this condition shouldbe reported to the supervisor before proceeding. The hoist limit switch should never beused as an operating control for stopping the load. It is to be considered as an emergency

limit switch only.

Repeat this procedure with the trolley controller. If the trolley is not equipped with a brake,note how it can be stopped by momentarily operating the control in the first point of thereverse direction. This is known as ―plugging.‖ Next try the bridge motion, first makingsure that the first movement is in the direction the bridge is free to travel. Check thestopping of the bridge by means of the brake and by plugging.

Good operators should always remember and follow four simple rules:

Start all motions slowly, by moving the controller handle or push button step by step

until the fastest safe speed is reached.

Stop slowly, by bringing the master switch or push button to the ―off‖ position step bystep so as to minimize ―swinging‖ of the load and unnecessary wear of the brakes.

Learn to judge the drift of each motion of the crane after power is removed. Properuse of this drift will facilitate spotting of the load and minimize wear of cranecomponents.

Handle the load in a safe manner with the area free of personnel and otherobstructions.

Handling the Bridge Travel Motion

Before using the trolley or bridge of the crane, the operator should be sure the hook is highenough to clear any obstruction. Before a load is handled by the crane, the bridge shouldbe brought in position so that it is directly over the load. Otherwise it will be impossible to―spot‖ the trolley and hoist hook over the load.

In addition to other operating controls, the bridge has a brake, usually operated by a footpedal in the cab or an electric brake where push button floor control is used. The purposeof this brake is to permit stopping the bridge exactly where desired. After the operator has

learned the distance that the bridge travels after power is removed, the operator should beable to judge distances so that the need to use the bridge brake will be greatly reduced.On floor-controlled cranes, the electric brake will set automatically when the push button isreleased.

Handling the Trolley Travel Motion

Before a load is handled, the hoist should be brought directly over the load that is to behandled. When the slack is taken out of the slings, if the hoist is not directly over the load,



J4.19

bring it directly over the load before hoisting is continued. Failure to center the hoist overthe load may cause the load to swing upon lifting.

If the trolley is equipped with a brake, follow the instructions given for controlling the bridge.

If the trolley is not equipped with a brake, this motion may require more skillful handlingthan any other motion of the crane. As the operator becomes familiar with the crane, he

can gauge the amount of ―drift‖ and allow for it. This will eliminate the necessity of quicklyreversing power to the trolley motor to bring the trolley to a stop.

Always start the trolley motion slowly and reduce the trolley speed gradually. For veryslight trolley movements, follow the practice of ―inching‖ as described in ―Handling theBridge Travel Motion.‖

Handling the Hoist Motion

After the hook has been brought over the load, lower it until the load can be attached to thehook. As the hook approaches this level, reduce the speed so that the lowering can be

stopped smoothly and quickly.

If load slings are used to handle the load, the slings should be fully seated in the saddle ofthe hook. With the hook latch closed (if equipped with hook latch), the hook should bestarted upward slowly until all slack has been taken out of the slings. Then the load shouldbe lifted slowly until it is clear and it has been determined that the load is properly balancedand the slings properly placed. The hoisting speed may then be increased and maintaineduntil the load is clear of all obstructions or if a hitcher gives the signal to stop.

Housekeeping

Good housekeeping should be maintained at all times. The crane operator should keep thecrane cab and access or pendent controls clear and clean. Do not permit loose objectssuch as tools, bolts, boards, etc. around the cab or on the crane because they represent asafety hazard.

Inspection

Test all controls on the crane at the beginning of each shift. Be sure the limit switchers,brakes, ropes, hooks and other protective devices are in good working order. Check cranefor such things as proper functioning of all controls, and check for loose or damaged parts.

Weekly the hook of the overhead crane shall be inspected (see Attachment 4 or Hazard Assessment Checklist (Shop)).

Note: Should the above mentioned inspection indicate the need for a nondestructive type oftesting of the crane hook. The use of outside firm to perform the non-destructive testing ofDynamic’s equipment requires written proof that technicians are certified to the latestrequirements of the Society for Non-Destructive Testing and that their inspection equipmentwas calibrated prior to the inspection itself.



J4.20

Whenever the operator finds anything wrong or apparently wrong, the problem should bereported immediately to the proper supervisor. See Sling section for inspections of wirerope and slings.

Signals

Standard crane signals should be accepted from only ONE authorized person – exceptwhere it is apparent that not doing so would result in an accident.

Obey a STOP signal at all times, no matter who gives it.

Loads should not be moved unless the standard crane signals are clearly given, seen andunderstood.

Unusual signals are seldom required, but if used they should be thoroughly understood bythe crane operator and authorized person giving the signal.

During any lift where the operator’s vision is blocked, radio communication shall be used torelay signals.

Stay Alert

The crane operator should keep hands on the handles of the controller or master switches,which control the motions in operation so stops can be made quickly in case of anemergency. Stand up, when necessary to improve vision, when making a lift or whenmoving a load in any direction. Be especially alert for any unusual sounds or warnings.Danger may be present that the crane operator cannot see.

Operating Precautions

One measure of a good crane operator is the smoothness of the crane operation. Jumpyand jer ky operation, flying starts, quick reversals and sudden stops are the ―trademarks‖ ofa poor operator. The good operator should know and follow these proven suggestions forsafe, efficient crane handling:

Crane controls should be moved smoothly and gradually to avoid abrupt, jerkymovements of the load. Slack must be removed from the sling and hoisting ropesbefore the load is lifted.

Center the crane over the load before starting the hoist to avoid swinging the load asthe lift is started. Loads should not be swung by the crane to reach areas not under

the crane.

Crane hoisting ropes should be kept vertical. Cranes shall not be used for sidepulls.

Never lower the block below the point where less than two full wraps of rope remainon the hoisting drum. Should all the rope be unwound from the drum, be sure it isrewound in the correct direction and seated properly in the drum grooves orotherwise the rope will be damaged and the hoist limit switch will not operate to stopthe hoist in the high position.



J4.21

Be sure everyone in the immediate area is clear of the load and aware that a load isbeing moved. Sound the warning device (if provided) when raising, lowering ormoving loads wherever people are working to make them aware that a load is beingmoved.

Do not make lifts beyond the rated load capacity of the crane, sling chains, rope

slings, etc.

Do not operate the crane if limit switches are out of order, or if ropes show defects orwear.

Make certain that before moving the load, load slings, load chains, or other liftingdevices are fully seated in the saddle of the hook with hook latch closed (if equippedwith hook latch).

When a duplex hook (double saddle hook) is used, a double sling or choker shouldbe used to assure that the load is equally divided over both saddles of the hook.

On all capacity or near capacity loads, the hoist brakes should be tested by returningthe master switch or push button to the ―OFF‖ position after raising the load a fewinches off the floor. Check the load for drift. If no drift, lower the load halfway to thefloor and stop. Again check for drift. If load drift is noticed in either step, lower theload to the floor and report the situation immediately to the supervisor.

Check to be sure that the load and/or bottom block is lifted high enough to clear allobstructions when moving bridge or trolley.

At no time should a load be left suspended from the crane unless the operator is atthe master switches or push button with the power on, and under this condition keepthe load as close as possible to the floor to minimize the possibility of an injury if theload should drop. When the crane is holding a load, the crane operator shouldremain at the master switch or push button.

When a hitcher is used, it should be the joint responsibility of the crane operator andthe hitcher to see that hitches are secure and that all loose material has beenremoved from the load before starting a lift.

Do not lift loads with any sling hooks hanging loose. (If all sling hooks are notneeded, they should be properly stored, or use a different sling.)

All slings or cables should be removed from the crane hooks when not in use.(Dangling cables or hooks hung in sling rings can inadvertently snag other objectswhen the crane is moving.)

Crane operators should not use limit switches to stop the hoist under normaloperating conditions. (These are emergency devices and shall not be used asoperating controls.)



J4.22

Do not block, adjust or disconnect limit switches in order to go higher or lower thanthe switch will allow.

Upper limit switches (and lower limit switches, when provided) should be tested instopping the hoist at the beginning of each shift, or as frequently as otherwisedirected.

Operators shall not carry loads and/or empty bottom blocks over personnel.

Particular additional caution should be practiced when using magnet or vacuumdevices. Loads, or parts of loads, held magnetically could drop. Failure of power tomagnets or vacuum devices can result in dropping the load.

If the electric power goes off, place your controllers in the ―OFF‖ position and keepthem there until power is again available.

Before closing main or emergency switches, be sure that all controllers are in the―OFF‖ position so that the crane cannot start unexpectedly.

If plugging protection is not provided, always stop the controllers momentarily in the―OFF‖ position before reversing—except to avoid accidents. (The slight pause isnecessary to give the braking mechanism time to operate.)

Whenever the operator leaves the crane this procedure should be followed:

Raise all Hooks to an intermediate position

Spot the crane at an approved designated location

Place all controls in the ―OFF‖ position

Open the main switch to the ―OFF‖ position

Make visual check before leaving the crane

Note: On yard cranes (cranes on outside runways), operators should set the brake andanchor securely so the crane will not be moved by the wind.

When two or more cranes are used in making one lift, it is very important that thecrane operators take signals from only one designated person.

Never attempt to close a switch that has an ―OUT OF ORDER‖ or ―DO NOTOPERATE‖ card on it. Even when a crane operator has placed the card, it isnecessary to make a careful check to determine that no one else is working on thecrane, before removing the card.

In case of emergency or during inspection, repairing, cleaning or lubricating, awarning sign or signal should be displayed and the main switch should be locked inthe ―OFF‖ position. This should be done whether the work is being done by thecrane operator or by others. On cab-operated cranes when others are doing the



J4.23

work, the crane operator should remain in the crane cab unless otherwise instructedby the supervisor.

Never move or bump another crane that has a warning sign or signal displayed.Contacts with runway stops or other cranes shall be made with extreme caution.The operator should do so with particular care for the safety of persons on or belowthe crane, and only after making certain that any persons on the other cranes are

aware of what is being done.

Do not change fuse sizes. Do not attempt to repair electrical apparatus or to makeother major repairs on the crane unless specific authorization has been received.

Never bypass any electrical limit switches or warning devices.

Load limit or overload devices shall not be used to measure loads being lifted. Sincethis is an emergency device, it shall not be used as a production operating control.

Sling Inspection

Wire Rope

Sling inspections are intended to detect serious damage or deterioration to the sling, whichmay lower the rated capacity or weaken the sling. The inspection shall be conducted by aqualified operator or riggers prior to use, and documented on our wire rope sling inspectionform (see Attachment 2 or Hazard Assessment Checklist (Shop)).

Sling shall be immediately removed from service if any of the following conditions arepresent:

Broken wires: For a single part sling, 10 randomly distributed broken wires in onerope lay, or five broken wires in one strand of one rope lay.

Metal loss: Wear or scraping of one-third (1/3) of the original diameter of outsideindividual wires.

Distortion: Kinking, crushing, birdcaging or other damage which distorts the ropestructures.

Evidence of heat damage.

End attachments that are cracked, deformed or worn.

Hooks that have been opened more than 15 percent of the normal throat openingmeasured at the narrowest opening measured at the narrowest point or twisted morethan 10 degrees from the plane of the unbent hook.

Corrosion of the rope or end attachments.



J4.24

Web Slings

Web slings shall be inspected prior to each use (visually) and documented on the ―DailyCherry Picker Checklist‖ (see Attachment 1 or Hazard Assessment Checklist (Shop)). Theoperating area shall maintain a certification of the load test on file for each sling.

Each sling shall be marked or coded to show the rated capacities for each type hitch anduniform thickness and width.

When synthetic web slings are used the following precaution shall be taken:

Nylon web slings shall not be used where fumes, vapors, sprays, mists or liquids ofacids or phenolics are present.

Polyester and polypropylene web slings shall not be used where fumes, vapor,sprays, mists or liquids of caustics and present.

Web slings with aluminum fitting shall not be used where fumes, vapor, sprays,mists or liquids of caustics and present.

Web slings, which are repaired, shall not be used unless repaired by the slingmanufacturer. Repaired slings shall be proof tested by manufacturer to twice the ratedcapacity. The manufacturer shall provide, for the employer’s records, a certificate of thetest.

Synthetic web slings shall be immediately removed from service if any of the followingconditions are present.

Acid or caustic Burns.

Melting or charring of any part of the sling surface.

Snags, punctures, tears or cuts.

Broken or worn stitches or

Distortion of fitting.

Chain Slings

Alloy steel chain slings grade 80 or 100 shall be used for any type of lifting

Transport chain slings grade 70 or 700 shall only be used for binding down loads fortransportation. Under no circumstance shall transport chain slings be used for lifting.

Alloy steel chain slings, Grade 80 or 100, shall have permanently affixed durableidentification stating size, grade, rated capacity and reach. Chain slings’ attachments shallhave a rated capacity at least equal to that of the alloy chain sling. Make shift links,fasteners or attachments shall not be used. Individuals shall not use alloy chain slings withloads, which exceed the rated capacity of the sling.



J4.25

Inspection shall be conducted prior to each use and a documented inspection conductedweekly (see Attachment 4 or Hazard Assessment Checklist (Shop)). Each chain sling shallbe re-certified on an annual interval.

Rigging Practices

Only employees who have completed Dynamic Industries or a designated Rigger

course may perform rigging operations and perform Pre-use inspections of riggingand rigging equipment to ensure the rigging is safe to be used.

Sling angles will not be less than 30 degrees from the horizontal (or not more than60 degrees from the vertical). (See Attachment 5 for proper sling anglecalculations.) Never use slings for loads that weight more than the rating of the sling.

NO "field fabricated" slings shall be used.

Knots or kinks are not permitted in wire rope or slings for any reason.

Slings and wire rope must not be used and removed from service if they have nocertification tag or matching certification documents, any excessive amount of wear,damage, flat spots, broken wires, or visual lack of lubrication exist and must becertified and tagged. If any of the above conditions are present, the equipment willbe replaced or sent in for inspection, testing, and refurbishment by qualifiedpersonnel.

Chains, fiber rope, or "soft line" shall not be used in the place of wire rope slings tolift loads or personnel. Appropriately rated nylon or synthetic webbed slings areacceptable for non-personnel lifts.

Wire rope and slings shall not contact any rough cut edges or holes such as padeyes and shall be padded or properly protected to prevent damage from contact bysharp corners. Shackles must be used with all pad eyes.

Hook openings shall be turned outward on hook slings. (see Attachment 5)

Tag lines shall be used on all lifts. They shall be of sufficient length, diameter, andstrength to allow adequate control of the load by the rigger(s).

The free end of tag lines should not contain anything that is likely to becomesnagged during lifting operations (e.g., knots or weights).

Tag lines should be connected to the lowest practical point and at right angles on theload whenever possible. If a tag line cannot be attached directly to the load, it mustbe attached to the shackle end of the sling as near the load as possible.

Slings and tag lines must be clear of all obstructions before the signal person and/orrigger divert their attention from the load.



J4.26

At no time are load hooks or lines to be used underwater. If underwater operationsare to be performed, the contractor shall furnish the proper submergiblecable/equipment.

Wedge sockets shall be installed in accordance with API RP 2D (see Attachment 5).

Rigging and rigging equipment shall be stored in designated locations when not in

use.

Shackle Information

There are two types of shackles commonly used in rigging. They are the anchor(bow type) shackle and chain ("D" type) shackle. The pin styles commonly usedwith shackles are screw pins, bolt pins, and loose pins. Shackles, like most otherrigging hardware, are sized by the diameter of the steel in the bow section ratherthan the pin size.

Only screw type pins are accepted on Dynamic Industries locations for rigging and

lifting operations.

Only high strength alloy steel shackles are to be used in lifting operations (see Attachment 5).

Only properly fitted screw pins shall be used in shackles. Never replace the shacklepin with a bolt.

Shackles should never be used if the distance between the eyes is greater thanlisted in Appendix C.

All screw pins must be straight and completely seated in the shackle.

Shackles worn in the crown or the pin by more than 10% of the original diametershall be discarded.

Shackles should never be attached where the load could possibly roll or unscrew thepin during the lifting process.

Shackle specifications: (see Attachment 5)

Suspended Personnel Man Baskets/Platforms

General

Personnel are allowed to work from approved suspended personnel baskets only.

Hoisting of personnel should be performed in a slow, controlled, and cautiousmanner.



J4.27

Lifting of employees in a personnel platform with a crane is prohibited unlessconventional means create more hazards because of worksite conditions.

Load and boom hoist drum brakes, swing brakes, and locking devices such as pawlsshall be engaged when the suspended personnel basket is in a stationary workingposition.

The combined weight of the platform and its rigging cannot exceed 50% of thecranes total lifting capacity.

Use of machines having live loads is prohibited.

Instruments and components

Cranes must have boom angle indicators readily visible to the operator.

Cranes with variable boom lengths must have a device to clearly indicate the boomlength.

Crane must be equipped with an anti-two block device.

Design

Each basket must be designed by a qualified engineer, and be able to suspendloads five times greater than the maximum expected load weight the basket wouldever carry.

Top guardrails should be 42’ in height with toeboard to top rail enclosed with eithersolid construction or expanded material with opening greater than ½ inch.

A grab rail must be installed inside the entire perimeter of the platform.

If basket is designed with a gate, the gate must not swing open, and must have alatch to prevent it from accidentally opening.

There shall be enough headroom to allow personnel to stand upright.

When exposed to falling objects, there shall be overhead protection on thesuspended personnel platform along with employees wearing hard hats.

All welding of suspended personnel platforms must done by a qualified welderfamiliar with weld grades, types and material specified in the platforms design.

Platform must be equipped with a label that states the baskets weight and maximumrated load capacity.

Loading

The personnel platform shall not be loaded in excess of its rated load capacity.



J4.28

The number of personnel occupying the personnel platform shall not exceed thenumber of employees required to do the job.

Personnel platforms shall be used only for employees, their tools, and the materialsnecessary to do their work.

Materials and tools shall be evenly distributed and secured to prevent displacement.

Rigging

Crane hooks used to lift suspended work baskets will have a positive locking device(not a spring loaded flap or clip)

Rigging for a suspended personnel basket will be installed to minimize tipping overregardless of location of personnel in the basket.

All slings, shackles, and wire rope must be inspected and rated for 5 times thebaskets maximum rated load capacity. If rotational resistant rope is used, it mustsupport at least 10 times the maximum load.

All eyes of wire rope slings shall be fabricated with thimbles.

All rigging for personnel platforms must be used only for the personnel platform.

All shackles incorporated in a Personnel Basket lifting configuration will be tight andwire locked.

Trial lift, inspection, and proof test

Trial lift must be performed immediately prior to placement of personnel on theplatform. The platform must be loaded with at least the anticipated lift weight.During the trial lift, the platform must be lifted from the area where the personnel willenter the basket. A single trial lift may be performed at one time for all the locationsthat are to be reached from a single set up position. The operator must insure thatthe load does not exceed 50% of the cranes capacity at any of the platformslocations. The test lift must be documented on the Suspended Personnel PlatformTest Lift/Proof Test Form. (See Attachment 6)

A proof test, which can be done concurrently with the trial lift, must be performedbefore personnel enter the personnel platform. A proof test must be performed witha test weight equaling 125% of the platforms capacity. This lift must be a minimumof 5 minutes long with the crane, platform, and hoist inspected by a competentperson after lift is completed. Any defects found must be corrected, and another 5minute test must be performed. The proof test shall be documented on the Test LiftChecklist (see Attachment 6).

After trial lift, the platform must be lifted a few inches to ensure that the platform isproperly balanced.



J4.29

Before personnel are lifted in platform, the rope hoist shall be free of kinks, multiplepart lines must not be twisted, primary attachment must be centered over theplatform, and the hoist system should be inspected for any slack in the line.

A complete inspection of the crane, rigging, and personnel platform must becompleted after the trial test. If any deficiencies or modifications to the crane,

rigging, or personnel platform are found, another trial test must be performed.

Work practices

Before employees enter or exit the personnel platform that is not landed, the basketmust be secured to the structure unless this creates an unsafe situation.

All personnel working in suspended personnel baskets over water must wear anapproved life preserver that is properly donned.

Workbaskets will be equipped with tag lines free of knots unless they create an

unsafe condition.

The operator must remain at the controls at all times the personnel platform isoccupied.

Hoisting of personnel should be promptly stopped upon indication of dangerousweather.

Personnel being hois-pted shall remain in continuous sight of and in directcommunication with the operator or signal person. If this is not possible, radiocommunication alone can be used.

All employees are required to wear fall protection at all times while being lifted onpersonnel platforms.

No lifts shall be made on any of the cranes other hoists while the personnel platformis attached to the crane.

All personnel lifting operations shall be shut down when wind speeds are equal to orgreater than 25 mph.

Traveling

Hoisting employees while the crane is traveling is prohibited.





J4.30

Attachment 1





J4.30.a.1





J4.31

Attachment 2





Daily Cherry PickerChecklist

J4.31.a.1

VISUAL CHECKS:

OK NOBEFORE STARTING ENGINE

OK

REMOVE

FROMSERVICE

LOGBOOK TIRES, WHEELS, & LUG NUTS

LOAD CHARTS & MANUALS FLUID LEAKS & HOSES

DECALS & MARKINGS LUBE & FLUID LEVELS

CLEANLINESS & GUARDS HOIST MOUNTING

FIRE EXTINGUISHER PEDESTAL MOUNTING

OK NO AFTER STARTING ENGINE OKREMOVE

FROMSERVICE

INSTRUMENTS & GAUGES STEERING

MIRRORS & WIPERS BRAKES

LIGHTS & ALARMS (i.e. Backup)

OKREMOVE

FROMSERVICE

WITH CRANE ON OUTRIGGERS OKREMOVE

FROMSERVICE

CONTROLS JIB & EXTENSION

OUTRIGGERS LOAD BRAKE

HOIST ROPE & SHEAVES TRANSMISSION OIL LEVEL

HOOKS (i.e. cracked, bent,

Stretched)

TWO BLOCK CRANEPROTECTION

BOOM

OKREMOVE

FROMSERVICE

SYNTHETIC WEB SLING OKREMOVE

FROMSERVICE

MELTING OR CHARRING OF ANYOF THE SLING SURFACES

ACID OR CAUSTIC BURNS

DISTORTION OF FITTINGS SNAGS, PUNCTURES, TEARSOR CUTS

BROKEN OR WORN STITCHES

*NOTE:

1. Repair deficiency(ies) if authorized to perform maintenance.

2. Explain deficiency(ies) in REMARKS.

3. Remove cherry picker from service

4. Place a completed white ―DO NOT USE‖ tag on the steering wheel.

5. Submit checklist to supervisor for handling.

REMARKS:

DATE:

OPERATOR: CHERRY PICKER #





Daily Crawler Crane Inspection Checklist

J4.31.a.2

DATE:

OPERATOR: CRAWLER CRANE#

OK NO VISUAL CHECKS OKREMOVE

FROMSERVICE

BROKEN OR CRACKED GLASSBOOM HOIST, WHIP LINE & HOISTWIRE ROPE – PENDANTS – LOADBLOCKS – SHEAVES

DAMAGED OR MISSING SHEET METAL,GUARDS, GEAR OR CHAIN CASE COVERS

FUEL TANS)S) – FUEL GAUGES – HOSES & CONNECTIONS

DRIVE CHAINS & SPROCKETS FORCRACKED OR BROKEN PIECES

LIMIT DEVICES – BOOM / MAST STOPS – DRUM PAWLS

OIL OR COOLANT LEAKING BELOWROTATING BED OR CARBODY

CONTROL VALVES – LEVERS &LINKAGE – INSTRUMENT PANEL(S)

ROLLER PATH, HOUSE ROLLERS, HOOKROLLERS FOR CHIPS OR CRACKS

FIRE EXTINGUISHER AVAILABLE – INWORKING ORDER

OK NO PREVENTIVE MAINTENANCE OK NO

RADIATOR COOLANT ENGINE OIL

CONTROLLED CONVERTER FLUIDTRANSMISSION AND / OR CHAIN CASE ORRESERVOIR

HYDRAULIC SYSTEM(S) LEVEL ROTATING BED SUMP

GEAR CASE LUBECONVERTER INPUT AND / OR OUTPUTHOUSING(S)

―CUNO‖ OIL FILTER(S) AIR COMPRESSOR

YES NO WIRE ROPE SLING / CRANE HOOK INSPECTION

Is the identification tag attached to sling?



Is there wearing or scraping of 1/3 or 33% original diameter of outside wire?



Are there end attachments that are cracked or deformed?

Is the hook cracked? (Fast Line and Main Line)

Has the hook been opened more than 15% of normal throat opening measured at the narrowestpoint?

Is the hook twisted more than 10 degrees from the plane of the unbent hook?

Remove from service.

NOTE:

1. Repair deficiency (ies) if authorized to perform maintenance.2. Explain deficiency (ies) in REMARKS.3. Remove crawler crane from service4. Place a completed white ―DO NOT USE‖ tag on the steering wheel. 5. Submit checklist to supervisor for handling.

REMARKS:





Wire Sling Inspection Report

J4.31.a.3

Serial No: Size: Max Lifting Capacity:

Job#: Location: Dept:

CHECK

OUT

CHECK IN

YES NO YES NO

Is the identification tag attached to sling?



Is there wearing or scraping of 1/3 or 33% original diameter ofoutside wire?



Are there end attachments that are cracked or deformed?

Is the hook cracked?

Has the hook been opened more than 15% of normal throatopening measured at the narrowest point?

Is the hook twisted more than 10 degrees from the plane of theunbent hook?

REMOVE FROM SERVICE

Remarks:

Inspector

Inspector Signature

Date:





J4.32

Attachment 3





J4.32.a.1

Location: __________________________________

Crane Operators Name: _______________________

Lift/Load Description: ________________________

Date of Lift: ________________________________

Certified Operator? Yes ________ No ________

Communication to be Used:_____________________

Sea state & wave conditions: Latest Crane Certification Date:

Environmental Conditions: (Must be within the one year)

Weight of Load: _________________________________

Weight of Lifting Tackle: _________________________________

Boom Angle: _________________________________TOTAL LIFT IS _____% OF THE CRANE’S RATED CAPACITY

This lift plan shall be utilized for lifts grater than 50% of the crane’s rated capacity, if two or more cranes

are used or if other conditions warrant a critical lift.

Verified by: Operator Name:

A. WEIGHT

1. Weight of Headache Ball _________lbs. 2. Weight of Block _________lbs. 3. Weight of Lifting Bar _________lbs. 4. Weight of Slings & Shackles _________lbs. 5. Allowance for Unaccounted

Material in Equipment _________lbs. 6. TOTAL WEIGHT = _________lbs.

Source of the Load Weight:

____________________________________(i.e.: Name Plate, Drawings Calculated, Etc.)

B. CRANE PLACEMENT1. Obstacles or obstructions to lift or swing?

________________________________

2. Swing Direction and Degree (Boom Swing). ________________________________

C. CRANE CABLE, BLOCK (Including Hook) 1. Number of Parts of Line? _______________

2. Size of the Cable? _____________________

3. Cable Capacity: _______________________

4. Block Capacity: _______________________

5. Cable & Block Pre-Lift Inspected?Yes _____ No _____

Special Instructions/Restrictions for Crane,

Rigging, Lift, etc. ____________________________

___________________________________________

D. RIGGING1. Sling Selection a. Type of Arrangement _______________ b. Number of Slings in Hook-up ________ c. Sling Size ________________________ d. Sling Length ______________________ e. Rated Capacity of Sling _____________

D. RIGGING (Continued)

2. Shackle Selection a. Type of Shackle: __________________ b. Capacity (tons): ___________________ c. Shackle Attached to the Load By:

________________________________ d. Number of Shackles: _______________

3. Rigged for center of load? Yes ____ No ___ 4. All Rigging Inspected? Yes ____ No ____ 5. Sling Angles within Capacity Limits?

Yes ____ No ____ E. CRANE

1. Type of Crane: _______________________ 2. Crane Capacity (tons): _________________

3. Lifting Arrangement a. Max. Distance – Center of Load to

Crane Hook (ft.): __________________ b. Angle of Boom at pick-up: _____ Degrees c. Angle of Boom at Set: _____ Degrees

4. From Chart – Rated Capacity of Crane for

this Lift (tons): ______________________ 5. Max Load on Crane (tons): ____________ 6. Pre-lift Inspection on Crane: Y____ N ____

F. PRE-LIFT CHECK LIST Yes No 1. Swing Room

2. Head Room Checked

3. Load Secured & Stable4. Tag Line Used

5. Exp./Designated signal man 6. Experienced Rigger 7. Area Barricaded 8. Load Chart in crane 9. All personnel in area notified 10. Wind Conditions _____________________ 11. Helicopter Concerns: __________________

[ ] [ ]

[ ] [ ]

[ ] [ ][ ] [ ]

[ ] [ ]

[ ] [ ]

[ ] [ ]

[ ] [ ]

* When liftin from a vessel the d namic load chart should alwa s be used!

CRITICAL LIFTING PLAN





J4.32.a.2

WIRE

ROPE

SIZE

MINIMU

M

SHACKL

E SIZE

RATED CAPACITY FOR 6X19 OR 6X37 CLASSIFICATION SLINGSIMPROVED PLOW STEEL GRADE WITH INDEPENDENT WIRE ROPE CORE

(in.) (in.)

VERTICAL CHOKERTWO LEG OR

BASKET HITCH60° DEGREE

SLING ANGLE45° DEGREE

SLING ANGLE30° DEGREE

SLING ANGLE

1/4 5/16 1120 820 2200 1940 1500 1100

7/16 3/8 1740 1280 3400 3000 2400 1700

3/8 7/16 2400 1840 4800 4200 3400 2400

7/16 1/2 3400 2400 6800 5800 4800 3400

1/2 5/8 4400 3200 8800 7600 6200 4400

9/16 5/8 5600 4000 11200 9600 7900 5600

5/8 3/4 6800 5000 13600 11800 9600 6800

3/4 7/8 9800 7200 19600 16900 13800 9800

7/8 1 13200 9600 26400 22800 18600 13200

1 1-1/8 17000 12600 34000 30000 24000 17000

1-1/8 1-1/4 20000 15800 40000 34600 28300 20000

1-1/4 1-3/8 26000 19400 52000 45000 36700 26000

1-3/8 1-1/2 30000 24000 60000 52000 42400 30000

1-1/2 1-1/2 34000 26000 70000 60000 50000 34000

1-3/4 1-3/4 48000 36000 94000 82000 66000 48000

2 2 60000 46000 122000 106000 86000 60000

NOTE: HORIZONTAL SLING ANGLES OF LESS THAN 45 DEGREES ARE NOT RECOMMENDED

Screw Pin Anchor Shackles

Size Work Pin Approx.

Dimensions in Inches

(A) Load Diam. Weight

Limit (B) Each C D E F

tons

3/16‖ 1/5 ¼ .05 lbs. 7/8 3/8 15/32 5/8

¼‖ ½ 5/16 0.13 1.1/16 15/32 21/32 ¾

5/16‖ ¾ 3/8 0.21 1.1/4 17/32 13/16 27.32

3/8‖ 1 7/16 0.33 1.7/16 5/8 15/16 1

7/16‖ 1.1/2 ½ 0.47 1.11/16 13/16 1.1/8 1.1/8

½‖ 2 5/8 0.76 1.7/8 13/16 1.1/4 1.1/4

5/8‖ 3.1/4 ¾ 1.44 2.5/16 1.1/16 1.9/16 1.5/8

¾‖ 4.3/4 7/8 2.3 2.7/8 1.3/16 1.7/8 1.15/16

7/8‖ 6.1/2 1 3.5 3.7/16 1.1/2 2.1/8 2.1/41‖ 8.1/2 1.1/8 5 3.7/8 1.5/8 2.3/8 2.5/8

1.1/8‖ 9.1/2 1.1/4 7 4.3/16 1.13/16 2.9/16 2.15/16

1.1/4‖ 12 1.3/8 9.5 4.11/16 2 2.7/8 3.1/8

1.3/8‖ 13.1/2 1.1/2 13 5.1/4 2.3/16 3.1/4 3.3/8

1.1/2‖ 17 1.5/8 16.5 5.5/8 2.5/16 3.1/2 3.3/4

1.3/4‖ 25 2 29 7.1/8 3 4.5/16 5

2‖ 35 2.1/4 43 8 3.1/8 5 5.5/8

2.1/4‖ 45 2.1/2 59.4 8.3/4 3.3/4 5.1/4 5.1/2

2.1/2‖ 55 2.3/4 86 10.1/4 4.1/4 5.7/8 7.1/8

3‖ 85 3.1/4 119.5 13 4.7/8 7.1/4 7.7/8

Design Factor 6:1Do not use screw pin shackles if the pin can roll and unscrew under load.CAUTION: NEVER EXCEED SAFE WORKING LOAD LIMIT Add/Rev 6/00





J4.33

Attachment 4





Weekly Chain Sling Inspection

J4.33.a.1

SerialNo:

Size: Type:

Job#: Location: Dept:

Checked out by:

Minimum Allowable Chain Size at Any Point of Link

(Circle size of chain being inspected)

Chain size,inches

Minimumallowable

chain size,inches

¼ 1364

3/8 1964

½ 2564

5/8 3164

¾ 1932

OKREMOVE FROM

SERVICE

7/8 4 564

1 1316

1 1/8 2932

1 ¼ 1

1 3/8 1 332

1 ½ 1316

1 3/4 11332

YES NO Inspection of Crane and Sling Hooks

Is hook cracked?

Has the hook been opened more than 15% of the normalthroat opening measured at the narrowest point?

Has the hook been twisted more than 10 degrees from theplane of the unbent hook?

Is the safety latch in working condition?

Are load and retain points secure?

Is the chain corroded?

Inspector: Inspector Signature:

Date:





J4.34

Attachment 5





J4.34.a.1





J4.34.a.2

Attachment 5 - Continued





J4.34.a.3






J4.34.a.4






J4.34.a.5






J4.34.a.6

Attachment 5 – Continued





J4.34.a.7






J4.35

Attachment 6





J4.35.a.1

DATE: PERSONNEL PLATFORM #:

TIME: CRANE:LOCATION: CRANE OPERATOR:

BASKET INSPECTION PASS FAIL

SLING INSPECTION PASS FAIL

TOTAL GROSS WEIGHT ON PLATFORM

*TEST WEIGHT (125% OF TOTAL GROSS WEIGHT ON THE PLATFORM)

RADIUS OF CRANE

RATED LOAD OF CRANE AT DESIRED RADIUS

*NOTE: TEST LIFT MUST BE DONE IN ALL LOCATIONS THAT ARE TO BE REACHED FROM THE PLATFORM

CRANE OPERATOR SIGNATURE:

SUPERVISOR SIGNATURE:

DYNAMIC INDUSTRIES, INC.

SUSPENDED PERSONNEL PLATFORM

TEST LIFT / PROOF TEST

*NOTE - TOTAL GROSS WEIGHT IS EQUAL TO COMBINED WEIGHT OF PERSONNEL,

MATERIALS AND TOOLS IN THE BASKET

% OF RATED LOAD (MUST NOT EXCEED 50% OF

THE CRANE CAPACITY)

TIME OF TEST LIFT / PROOF TEST

(MINIMUM OF 5 MINUTES):





J4.36

Attachment 7





J4.36.a.1





J4.36.a.2






Management SystemElectrical Safety Program


J5.1

Electrical Safety Program

Purpose

The purpose of this program is to pr ovide Moreno Group LLC and Subsidiaries’ proper guidelines for working with electricity and the various aspects required whileinstalling, servicing and wiring electrical equipment.

Scope

This program is designed to prevent electrically related injuries and propertydamage. This program also provides for proper training for these affectedemployees to ensure that they have the requisite knowledge and understanding of

electrical work practices and procedures.

Responsibilities

The Facility Manager/Offshore Manager or Designee is responsible for:

Provide training for qualified and unqualified employees.

Conduct inspections to identify electrical safety deficiencies.

Guard and correct all electrical deficiencies promptly.

Ensure all new electrical installations meet codes and regulations.

The Yard Foreman/Offshore Superintendent/First Line Supervisor is responsiblefor:

Ensuring that qualified employees follow the Electrical Saf ety Program’swithin their processes or areas.

Ensuring that qualified employees have received appropriate training to theprocedure prior to commencement of work activities.

Ensuring that monthly electrical cord inspections and color coding are beingkept up to date for all temporary electrical equipment at all onshore facilities.

Reporting to the Facility Manager and/or Safety, Health and EnvironmentalDepartment any injury, incident or near miss resulting from electrical workactivities.



J5.2

Periodic auditing, with the assistance of the Safety, Health and EnvironmentalDepartment, of work sites and activities where this program will beimplemented.

Ensure that all electrical cords and welding leads are kept up to date withMonthly Color Coding as identified in Attachment 2 of this procedure.


Assist management in implementation of the Electrical Safety Program.

Assist management in the monitoring and auditing of employees in theadjustment, repair or replacement of electrical components.

Audit the Electrical Safety Program, with the assistance of management,periodically, or whenever changes are made, to the program or processesthat they pertain to change.

Assist management in any changes that are necessary to the ElectricalSafety Program.


Following all appropriate rules pertaining to the Electrical Safety Program.

Reporting any injury, incident or near miss to the Supervisor or Safety, Healthand Environmental Department.

Definitions

Qualified Worker: An employee trained and authorized to conduct electrical work.

Unqualified: Employees who have not been trained or authorized by managementto conduct electrical work.

Static Electricity: Electrification of materials through physical contact andseparation and the various effects resulting from the positive and negative chargesso formed. Static is generated when liquids move in contact with other materials,such as in pouring, mixing, pumping, filtering, or agitating.

Static Spark: An impulsive discharge of electricity across a gap between two pointsnot in contact.

Bonding: The process of connecting two or more conductive objects together bymeans of a conductor to minimize potential differences between conductive objects.Bonding “equalizes” the potential between objects.



J5.3

Grounding: The process of connecting one or more conductive objects to theground to minimize potential differences between objects and the ground.Grounding dissipates an electric charge to ground.

Requirements

Hazard Control


All electrical distribution panels, breakers, disconnects, switches, junctionboxes shall be completely enclosed.

Watertight enclosure shall be used where there is a possibility of moistureentry either from operations or weather exposure.

Electrical distribution areas will be guarded against accidental damage bylocating in specifically designed rooms, use of substantial guard posts and

rails and other structural means.

A clear approach and 3-foot side clearance shall be maintained for alldistribution panels.

All conduit shall be fully supported throughout its length. Non-electricalattachments to conduit are prohibited.

All non-rigid cords shall be provided strain relief where necessary.


Only trained and authorized employees may conduct repairs to electricalequipment.

Contractors performing electrical work must hold a license for the rated work.

Areas under new installation or repair will be sufficiently guarded with physicalbarriers and warning signs to prevent unauthorized entry.

Access to electrical distribution rooms is limited to those employees who areauthorized to enter.

All electrical control devices shall be properly labeled.

Work on energized circuits is prohibited unless specifically authorized bysenior facility or project management.

All energized equipment will be de-energized and will be locked and/ortagged out utilizing the established Moreno Group LLC and Subsidiaries’



J5.4

Energy Isolation Procedure (Lockout/Tagout). (See Energy IsolationProcedure (Lockout/Tagout))

All qualified employees will follow established electrical safety procedures andprecautions.

Protective Equipment

Qualified employees will wear electrically rated safety shoes/boots and headprotection.

All tools used for electrical work shall be properly insulated.

Electrical rated gloves shall be available for work on electrical equipment.

Flash protection shall be available for all work in which it is required.

Electrically rated matting will be installed in front of all distribution panels inelectric utility rooms.

Examination of Electrical Equipment

Electrical equipment shall be free from recognized hazards that are likely to causedeath or serious physical harm to employees. Safety of equipment shall bedetermined using the following considerations:

Suitability for installation and use in conformity with the provisions of thissubpart. Suitability of equipment for an identified purpose may be evidenced

by listing or labeling for that identified purpose.

Mechanical strength and durability, including, for parts designed to encloseand protect other equipment, the adequacy of the protection thus provided.

Electrical insulation.

Heating effects under conditions of use.

Arcing effects.

Classification by type, size, voltage, current capacity, and specific use.

Other factors which contribute to the practical safeguarding of employeesusing or likely to come in contact with the equipment.

Onshore Facilities will use the color coding system identified in Attachment 2 on amonthly basis on all temporary electrical equipments and electrical tools.



J5.5

Identification of Disconnecting Means and Circuits

Each disconnecting means for equipment shall be legibly marked to indicate itspurpose. Each service feeder and branch circuit, at its disconnecting means orovercurrent device, shall be legibly marked to indicate its purpose. These markingshall be of sufficient durability to withstand the environment involved.

A disconnecting means is a switch that is used to disconnect the conductors of acircuit from the source of electric current. Each disconnect switch or overcurrentdevice required for a service, feeder or branch circuit must be clearly labeled toindicate the circuit’s function, and the label or marking should be located at the pointwhere the circuit originates.

All labels and markings must be durable enough to withstand weather, chemicals,heat, corrosion, or any other environment to which the may be exposed.

Training

Training for Unqualified Employees

Unqualified Employees will be trained in general electrical safety precautions toprovide an awareness and understanding of electrical hazards in the workplace.

Electrical Safety Rules for Non-Qualified Workers

1. Do not conduct any repairs to electrical equipment.

2. Report all electrical deficiencies to your supervisor.

3. Do not operate equipment if you suspect an electrical problem.

4. Water and electricity do not mix.

5. Even low voltages can kill you.

6. Do not use cords or plugs if the ground prong is missing.

7. Do not overload electrical receptacles.

Training for Qualified Employees

Training for Qualified Employees includes specific procedures and requirements of29 CFR 1910.331 through 1910.339. Qualified Employees shall be trained in andfamiliar with the skills and techniques necessary to distinguish exposed live partsfrom other parts of electric equipment; the skills and techniques necessary todetermine the nominal voltage of exposed live parts; and the clearance distancesspecified in 1910.333(c) and the corresponding voltages to which qualifiedemployees will be exposed.



J5.6


Employees working in areas where the potential contact with exposed electricalsources are present and likely will be provided and shall use Personal ProtectiveEquipment (PPE). The following rules apply to the use and care of PPEs.

1. PPEs shall be used where contact with exposed electrical sources are

present and likely.

2. PPEs shall be designed for the work being performed and environment inwhich it is used (See Attachment 1).

3. PPEs shall be visually inspected and/or tested before use. Any defects ordamage shall be replaced, repaired or discarded.

4. In cases where the insulating capabilities of the PPEs may be damagedduring the work, a protective outer cover, such as leather, must be used.

5. Employees shall wear non-conductive head protection wherever there is adanger of injury from electrical shock from contact with exposed energizedparts.

6. Employee shall wear protective eye/face equipment whenever there is adanger from electrical arcs or flashes or from flying object resulting froman electrical explosion.

Electrical PPE Inspection Schedule

Type of equipment When to test

Rubber insulating line hose Upon indication that insulating value issuspect.

Rubber insulating coversUpon indication that insulating value issuspect.

Rubber insulating blankets Before first issue and every 12 months

Rubber insulating gloves Before first issue and every 6 months

Rubber insulating sleeves Before first issue and every 12 months

Electrical Lockout & Tagout Requirements

See Energy Isolation Procedure (Lockout/Tagout).

Working at Elevated Locations

Any person working on electrical equipment, being it installation or repair, or on anelevated surface greater than 6 feet above any unprotected surface, shall takenecessary precautions to prevent a fall from reaction to electric shock or othercauses. This applies to work out of a manlift, work on scaffolds without siderails thatare 6 feet in height or higher and work on any unprotected edge 6 feet in height orhigher, where the potential for a fall is evident. Fall protection shall consist of safety



J5.7

harnesses with 100% tie off with the use of double lanyards. Proper anchor pointsshall be used when fall protection with the use of safety harnesses is utilized.Portable ladders shall have non-conductive siderails if they are used where theemployee or the ladder could contact exposed energized parts.

General Protective Equipment and Tools

General protective equipment and tools shall be used when in the proximity of, orworking on, exposed energized parts. The following rules apply:

1. When working on or near exposed energized parts, Qualified Employeesshall use insulated tools or handling equipment suitable for the voltagepresent and working equipment. In cases where the insulation may bedamaged, a protective outer layer should be employed.

2. Conductive jewelry and clothing may not be worn if they might contact anyexposed energized parts.

3. Fuse handling equipment, insulated for the circuit voltage, shall be used toremove or install fuses when the terminal is energized.

4. Ropes and other handlines used near exposed energized equipment shallbe non-conductive.

Warnings and Barricades

Warnings and barricades shall be employed to alert unqualified Employees of thepresent danger related to exposed energized parts. The following rules apply:

1. Safety signs, warning tags, etc., must be used to warn UnqualifiedEmployees of the electrical hazards present, even temporarily, that mayendanger them.

2. Non-conductive barricades shall be used with safety signs to preventUnqualified Employees access to exposed energized parts or areas.

3. Where barricades and warning signs do not provide adequate protectionfrom electrical hazards, an Attendant shall be stationed to warn andprotect Employees.

Powered Equipment Safety Rules

Electrical equipment is defined as cord or plug-type electrical devices, whichincludes the use of flexible or extension cords. Examples of portable electricalequipment included powered hand tools, powered bench tools, fans, radios, etc. Thefollowing safety rules apply to portable electrical equipment (PEE):

1. PEE shall be handled in such a manner as to not cause damage. Powercords may not be stapled or otherwise hung in a way that may causedamage to the outer jacket or insulation.



J5.8

2. PEE shall be visually inspected for damage, wear, cracked or spilt outer jackets or insulation, missing or damaged plugs, etc., before use or beforeeach shift. PEE that remains connected once put in place need not beinspected until relocated. Any defects; such as cracked or split outer

jackets, deformed or missing plug or insulation must be repaired, replacedor placed out of service until repairs can be made. When taken out of

service, ensure tag is placed on equipment identifying the damage. OnlyPEE that are color coded with the correct month color should be used. Ifequipment does not have the appropriate color code, it needs to bebrought to supervisor for appropriate inspection.

3. In the event a GFCI cannot be used as outlined in #8 below, all equipmentgrounding conductors used in that circuit shall be tested for continuity andshall be electrically continuous. These tests shall be done monthly, afterrepairs are made, or after cords in that circuit may be suspected ofdamage such as when it has been run over. PEE that does not meet therequirements of this section must be removed from service and not be

made available for use by employees.

4. If testing is required due to not using a GFCI, such tests shall be recordedas to the identity of the cords and/or receptacles that passed the test andshall include the date tested, the qualified person that performed thetest/inspection, and colored tape will be affixed to the cord indicating themonth of the inspection.

5. Always check the compatibility of cord sets and receptacles for properuse.

6. Ground type cord sets may only be used with ground type receptacleswhen used with equipment requiring a ground type conductor.

7. Attachment plugs and receptacle may not be altered or connected in away that would prevent the proper continuity of the equipment groundingconductor. Adapters may not be used if they interrupt the continuity of thegrounding conductor.

8. Use of Ground Fault Circuit Interrupters (GFCI) shall be utilized on all 120Volt, single phase, 15 and 20 ampere receptacle outlets on constructionsites, which are not part of the permanent wiring of the building or

structure and which are in use by employees. Receptacles on a two-wiresingle phase portable or vehicle mounted generator rated not more than5kW, where the circuit conductors of the generator are insulated from thegenerator frame and all other grounded surfaces, need not be protectedwith ground-fault circuit interrupters.

9. Only portable electrical equipment that is double insulated or designed foruse in areas that are wet or likely to contact conductive liquids may beused.



J5.9

10. Employees that are wet or have wet hands may not handle PEEs (plug-in,un-plug, etc.). Personal protective equipment must be used when handlingPEEs that are wet or covered with a conductive liquid.

11. Locking-type connectors shall be properly secured after connection to apower source.

12. Routing of lines shall be made in such a way where cords do not come incontact with water sources and do not obstruct walkways.

Electrical Circuit Safety Procedures

Electrical power and lighting circuits are defined as devices specifically designed toconnect, disconnect or reverse circuits under a power load condition. When thesecircuits are employed, the following rules apply:

1. Cable connectors (not of load-break type) fuses, terminal plugs or cablesplice connectors may not be used, unless an emergency, to connect,

disconnect or reverse in place of proper electrical circuits.

2. After a protective circuit is disconnected or opened, it may not beconnected or closed until it has been determined that the equipment andcircuit can be safely energized.

3. Overcurrent protectors of circuits or connected circuits may not bemodified, even on a temporary basis, beyond the installation safetyrequirements.

4. Only Qualified Employees may perform test on electrical circuits or

equipment.

5. Test equipment and all associated test leads, cables, power cords, probesand connectors shall be visually inspected for external damage beforeuse. Any damage or defects shall be repaired before use or placed out ofservice.

6. Test equipment shall be rated to meet or exceed the voltage being testedand fit for the environment in which it is being used.

7. Where flammable or ignitable materials are stored, even occasionally,

electrical equipment capable of igniting them may not be used unlessmeasures are taken to prevent hazardous conditions from developing.

Standard Operating Procedure

Electrical Pre-Work Procedure

Except in extreme cases, work on electrical equipment will be done with all electricalcircuits in the work area de-energized by following the Energy Isolation procedure.When working on or near energized electrical circuits with less than 30 volts to



J5.10

ground, the equipment need not be de-energized if there will be no increasedexposure to electrical burns or to explosion from electric arcs.

To prepare for work on electrical systems or components, the following procedureapplies:

Caution: Treat all electrical circuits as "Live" until they have been Tagged and

Locked Out and tested by the following procedure.

1. Obtain permission from supervisor to conduct work

2. Lockout and Tagout all sources of electrical power

3. Verify de-energized condition before any circuits or equipment areconsidered and worked as de-energized.

A. A qualified person shall operate the equipment operating controls orotherwise verify that the equipment cannot be restarted.

B. Verify proper operation of the Voltmeter at a live electrical source ofthe same rated voltage as the circuit to be worked.

C. Using the Voltmeter, check all exposed circuits phase to phase andphase to ground for evidence of voltage/current in the circuit.

D. Conduct work on the circuit only after determining that there is novoltage in any of the exposed circuits.

E. If voltage is detected in any exposed circuit, STOP, inform supervisor

and determine source and procedure to eliminate voltage.

4. Conduct work

5. Close up all exposed circuits, boxes, controls, and equipment.

6. Remove Lockout/Tagout.

7. Obtain supervisor permission to energize circuits

Working on or Near Exposed Energized Circuits

In the rare situation when energized equipment (or working in near proximity toenergized equipment) can not be de-energized, the following work practices must beused to provide protection:

Caution: Only Qualified Employees may work on electrical circuit parts orequipment that have not been deenergized. Such persons shall be madefamiliar with the use of special precautionary techniques, PPE, insulating andshielding materials and insulated tools.



J5.11

1. Obtain permission from Manager to work on or near energized electricalcircuits.

2. Lockout and Tagout all circuits possible

3. Treat all circuits as energized.

4. Remove all conductive clothing and jewelry (rings, watches, wrist/neckchains, metal buttons, metal writing instruments, etc.).

5. Use proper personal protective equipment, shields and/or barriers toprovide effective electrical insulation from energized circuits. This mayinclude electrically rated insulated gloves, aprons, rubber-soled shoes,insulated shields, insulated tools, and flash protection clothing as identifiedin Attachment 1, etc.

6. Provide adequate lighting. Do not enter areas with exposed energizedparts unless illumination (lighting) is provided so that Employee may work

safely. Do not reach around obstructions of view or lighting (blindly) intoareas where exposed energized parts are located.

7. Employees entering a Confined Space with exposed energized parts,must use protective barriers, shields, or equipment or insulated materialsrated at or above the present voltage to avoid contact.

8. Doors or other hinged panels shall be constructed and secured to preventthem from swinging into an Employee and causing contact with exposedenergized parts.

9. Housekeeping in areas of exposed energized parts may not be completedin areas with close contact unless adequate safeguards (insulationequipment or barriers) are present. Conductive cleaning material (SteelWool, Silicon Carbide, etc.) or liquids may not be used unless procedures(Lock and Tag Out, etc.) are in place and followed.

10. Station a safety observer outside work area. The sole function of thisperson is to quickly de-energize all sources of power or pull worker freefrom electrical work area with a non-conductive safety rope if contact ismade with an energized electrical circuit.

11. A person qualified in CPR must be readily available to the scene.

Re-energizing Electrical Circuits After Work Completed

These requirements shall be met, in the order given, before circuits orequipment are re-energized, even temporarily.

1. A qualified person shall conduct tests and visual inspections, asnecessary, to verify that all tools, electrical jumpers, shorts,grounds, and other such devices have been removed, so that thecircuits and equipment can be safely energized.



J5.12

2. Warn employees exposed to the hazards associated with re-energizing the circuit or equipment to stay clear of circuits andequipment.

3. Remove each lock and tag. They shall be removed by theemployee who applied it or under his or her direct supervision.However, if this employee is absent from the workplace, then the

lock or tag may be removed by a qualified supervisor designated toperform this task provided that:

A. The supervisor ensures that the employee who applied the lockor tag is not available at the workplace, and

B. The supervisor ensures that the employee is aware that the lockor tag has been removed before he or she resumes work at thatworkplace.

4. Conduct a visual determination that all employees are clear of thecircuits and equipment.

Working Near Overhead Lines

If work is to be performed near overhead lines, the lines shall be deenergized andgrounded, or other protective measures shall be provided before work is started. Ifthe lines are to be deenergized, arrangements shall be made with the organizationthat operates or controls the electric circuits involved to deenergize and groundthem. If protective measures, such as guarding, isolating, or insulating or provided,these precautions shall prevent employees from contacting such lines directly withany part of their body or indirectly through conductive materials, tools, or equipment.

When an unqualified person is working near overhead lines, in an elevated position,such as from an aerial platform, the person and the longest conductive object thatthey may be able to contact the line with must not be able to come within ten (10)feet of overhead line of voltages up to 50,000 volts. For voltages over 50,000 volts,an addition four (4) inches must be added to the ten (10) feet distance for everyadditional 10,000 volts. When unqualified persons are working on the ground in thevicinity of overhead lines, the above distances still apply. All Moreno Group LLC andSubsidiaries will be considered Unqualified for work around overhead lines.

Vehicular and Mechanical Equipment

Any vehicle or mechanical equipment, such as cranes and cherry pickers, capable ofhaving parts of its structure elevated near energized overhead lines shall beoperated so that a clearance of ten (10) feet is maintained. If the voltage is higherthan 50,000 volts, the clearance shall be increased 4 inches for every additional10,000 volts.



J5.13

Confined or Enclosed Work Spaces

When an employee works in a confined space that contains exposed energizedparts, the employer shall provide, and the employee shall use, protective shields,protective barriers, or insulating materials as necessary to avoid inadvertent contactwith these parts. Doors, hinged panels, and the like shall be secured to prevent theirswinging into an employee and causing the employee to contact exposed energized

parts.

Conductive Materials and Equipment

Conductive materials and equipment that are in contact with any part of anemployee’s body shall be handled in a manner that will prevent them from contactingexposed energized conductors or service parts.

Portable Ladders

Portable ladders shall have nonconductive side rails if they are used where the

employee or the ladder could contact exposed energized parts.

Work in Hazardous Locations

1. Only equipment that is approved for that application shall be used in areasthat have been designated as a hazardous (classified) location.

2. Equipment and associated wiring approved as intrinsically safe shallbe required in any classified location. The National Electric Code(NEC) defines an intrinsically safe circuit as: a circuit in which any spark orthermal effect is incapable of causing ignition of a mixture of flammable or

combustible material in air under prescribed test conditions.

NOTE: Hazardous locations most likely encountered in Exploration andProduction locations will be:

1. Class 1, Division 1

a. A location where ignitable concentrations of flammable gases orvapors exist under normal operating conditions;

b. Where ignitable concentrations of gases may exist frequently due to

repairs, maintenance, or leakage;

c. Where breakdowns or malfunctioning equipment or processes mightrelease ignitable concentrations of flammable gases or vapors, andmight also cause simultaneous failure of electrical equipment.

2. Class 1, Division 2



J5.14

a. A location where volatile flammable liquids or vapors are handled,processed, or used. These are normally confined within closedcontainers or systems;

b. Where ignitable concentrations of gases or vapors are normallyprevented by positive mechanical ventilation and which may becomehazardous if this ventilation failed;

c. Where the location is adjacent to a Class 1, Division 1 location whichmight communicate ignitable concentrations of flammable gases orvapors unless prevented by adequate positive pressure ventilationfrom a source of clean air and effective safeguards against ventilationfailure are provided.

3. Hazard classed areas are also organized into groups. The group mostinherent to E & P operations will be Group D, which includes flammableliquids, vapors, and gases.

4. All electrical equipment for hazardous locations shall conform to the NFPA70, National Electric Code specifications.

5. Equipment installed in classified areas shall be legibly marked by themanufacturer or testing agency indicating in what areas it is approved foruse.

6. The use of pigtails or drop cords that are not appropriately rated for thathazard class shall not be used unless a hot work permit has been issued.

Grounding and Bonding Procedure

A. Specific procedures as outlined herein are to be followed to ensureequipment is properly grounded and static electricity is minimized.

B. Supervisors are responsible for the implementation and enforcement ofthis policy.

Static Electricity Controls - Bonding and Grounding

1. Drums and Cans

A. When filling metal drums and cans with liquids having a flash point of100

oF or below or other liquids heated above their conductive flash

points, fill spouts, nozzles, or fill pipes, shall be kept continuously incontact with the edge of the fill opening. If this is not possible, thedispersing and receiving containers shall be bonded togetherwith a bonding wire.

B. Bonding is not required when a container is filled through a closedsystem.



J5.15

2. Storage Tanks

A. Avoid overshot “splash filling”. The outlet of the fill pipe shoulddischarge near the bottom of the tank with minimum agitation of thewater and sediment on the tank bottom.

B. Where the outlet of the fill line is attached to a “downcomer”, siphon

breakers that permit air or vapor to enter the downcomer should not beused. Avoid discharging product from a swing line elevated above theliquid level. Limit the velocity of the incoming liquid stream to three (3)feet per second until the fill outlet is well submerged.

C. Ungrounded objects, such as loose gauge floats, should be eliminated.

D. Avoid pumping substantial amounts of air or other entrained gas intothe tank through the liquid.

E. Metallic or conductive hand gauging tapes and sample cans or bottles

on chains may act as spark promoters and shall not be lowered intotanks that may contain flammable atmospheres during tank loading.

F. Personnel must wait at least five (5) minutes after loading is completedbefore conductive gauging or sampling materials are used in the tank.While gauging or sampling is being performed, the gauge line orsampling device must remain continuously in contact with the edge ofthe thief hatch to form a bond.

G. Bonding straps on gauging tapes shall not be removed and shall besecurely clamped to the thief hatch while gauging is being

accomplished.

H. Metallic tanks that are in contact with the ground are sufficientlygrounded as long as one of the following conditions are met:

1. A tank is connected without insulated joints to a grounded metallic pipingsystem;

2. A vertical cylindrical tank rests on earth or concrete and is at least 20 feet(6 meters) in diameter, or rests on bituminous pavement and is at least 50feet (15 meters) in diameter.

Grounding

1. Equipment Grounding:

A. The grounding of equipment is primarily for personnel protection and isrequired for all metallic housings, enclosures, and structures whichcontain electric conductors. Grounding should be interconnected tothe extent that a low potential difference is maintained between nearbymetallic objects.



J5.16

B. Equipment grounding applies to motor frames, enclosures for controls,transformer cases, transformer back fences, metallic houses, etc.

C. The NFPA 70, National Electrical Code and National Electrical SafetyCode should be referenced to ensure equipment groundingrequirements are met.

2. Ground Rods:

A. Information on location and applications requiring ground rods may befound in NFPA 70, National Electrical Code, and National ElectricalSafety Code.

B. Multiple rods provide a reduction in resistance but may not provideadequate performance.



J5.17

Attachment 1





J5.17.a.1

HAZARD RISK CATEGORY CLASSIFICATION TABLETask (Assumes Equipment is Energized, &Work is Done Within the Flash Protection

Boundary

HazardRisk

Category

V-RatedGloves

V-RatedTools

Panelboards rated 240V and below-Notes 1 and 3

- - -

Circuit breaker (CB) or fused switchoperation with covers on 0 N YCB or fused switch operation with cover off 0 N N

Work on energized parts, including voltagetesting

1 Y Y

Removal / installation of CBs or fusedswitches

1 Y Y

Removal of bolted covers (to expose bare,energized parts)

1 N N

Opening hinged covers (to expose bare,energized parts)

0 N N

Panelboards or switchboards rated >240Vand up to 600V (with molded case orinsulated case circuit breaders)-Notes 1 and 3

- - -

CB or fused switch operation with cover on 0 N N

CB or fused switch operation with cover off 1 N N


2* Y Y

600V class motor control centers (MCCs)-Notes2 (except as indicated) and 3

- - -

CB or fused switch or starter operation

with enclosure doors closed

0 N N

Reading a panel meter while operating ameter switch

0 N N

CB or fused switch or starter operationwith enclosure doors open

1 N N


2* Y Y

Work on control circuits with energizedparts 120V or below, exposed

0 Y Y

Work on control circuits with energizedparts >120V exposed

2* Y Y

Insertion or removal of individual starter"buckets" from MCC - Note 4 3 Y N

Application of safety grounds, after voltagetest

2* Y N


2* N N


1 N N



J5.17.a.2

HAZARD RISK CATEGORY CLASSIFICATION TABLE (cont.)Task (Assumes Equipment is Energized,

& Work is Done Within the FlashProtection Boundary

Hazard RiskCategory

V-RatedGloves

V-RatedTools

Other 600V class (277V through 600V,nominal) Equipment-Note 3

- - -

Lighting or small power transformers(600V, maximum)

- - -


2* N N


1 N N


2* Y Y


2* Y N

Revenue meters (kW-hour, at primaryvoltage or installation - - -

Insertion or removal 2* Y N

Cable trough or tray cover removal orinstallation

1 N N

Miscellaneous equipment cover removalor installation

1 N N


2* Y Y


2* Y N

NEMA E2 (fused contactor) motorstarters, 2.3 kV through 7.2 kV - - -

Contactor operation with enclosure doorsclosed

0 N N


0 N N

Contactor operation with enclosure doorsopen

2* N N


3 Y Y

Work on control circuits with energized

parts 120V of below exposed0 Y Y


3 Y Y

Insertion or removal (racking) of startersfrom cubicles, doors open

3 N N

Insertion or removal (racking) of startersfrom cubicles, doors closed

2 N N



J5.17.a.3

HAZARD RISK CATEGORY CLASSIFICATION TABLE (cont.)Task (Assumes Equipment is Energized, &Work is Done Within the Flash Protection

Boundary

Hazard RiskCategory

V-RatedGloves

V-RatedTools

Application of safety grounds, aftervoltage test

3 Y N

Removal of bolted covers (to expose bare,energized parts) 4 N NOpening hinged covers (to expose bareenergized parts)

3 N N

Metal-clad switchgear, 1 kV and above - - -

CB or fused switch operation withenclosure doors closed

2 N N


o N N

CB or fused switch operation withenclosure doors open

4 N N

Work on energized parts, including voltagetesting 4 Y Y

Work on control circuits with energizedparts 120V or below exposed

2 Y Y


4 Y Y

Insertion or removal (racking) of CBsfrom cubicles, doors open

4 N N

Insertion or removal (racking) of CBsfrom cubicles, doors closed

2 N N

Application of safety grounds, after

voltage test

4 Y N


4 N N

Opening hinged covers (to expose bareenergized parts)

3 N N

Opening voltage transformer of controlpower transformer compartments

4 N N

Other equipment 1 kV and above - - -

Metal-clad load interrupter switches, fusedor unfused

- - -

Switch operation, doors close 2 N N


4 Y Y


4 N N

Opening hinged covers (to expose bareenergized parts)

3 N N

Outdoor disconnect switch operation(hookstick operated)

3 Y Y



J5.17.a.4

HAZARD RISK CATEGORY CLASSIFICATION TABLE (cont.) Task (Assumes Equipment is Energized, &Work is Done Within the Flash Protection

Boundary

HazardRisk

Category

V-RatedGloves

V-RatedTools

Outdoor disconnect switch operation(gang operated, from grade)

2 N N

Insulated cable examination, in manholeor other confined space 4 Y N

Insulated cable examination, in open area 2 Y N

Legend:

V-rated gloves are gloves rated and tested for the maximum line-to-line voltageupon which work will be done.

V-rated tools are tools rated and tested for the maximum line-to line voltage uponwhich work will be done.

2* means that a double-layer switching hood and hearing protection are required forthis task in addition to the other Hazard Risk Category 2 requirements of Table 3.

Y = yes (required)

N = no (not required)

Notes:

1. 25-kA short-circuit current available, 0.03-second (2 cycle) fault clearing time.2. 65-kA short-circuit current available, 0.03-second (2 cycle) fault clearing time.

3. For > 10 kA short-circuit current available, the hazard risk category requiredmay be reduced by one number.

4. 65-kA short-circuit current available, 0.03-second (2 cycle) fault clearing time.5. 65-kA short-circuit current available, up to 1.0-second (60 cycle) fault clearing

time.6. For > 25 KA short-circuit current available, the hazard risk category required

may be reduced by one number.



J5.18

Attachment 2





J5.18.a.1

Monthly Electrical Cord Inspection Color Coding

January Red

February White

March Green

April Red

May White

June Green

July Red

August White

September GreenOctober Red

November White

December Green







Energy Isolation Procedure(Lockout / Tagout)


J6.1

Energy Isolation Procedure

Purpose

This procedure shall establish the minimum requirements of OSHA 29 CFR1910.147, “The Control of Hazardous Energy.” It will apply to all employees who areinvolved with the servicing and maintenance of equipment in which the unexpectedenergization, start-up or release of stored energy may occur.

Scope

The purpose of this procedure is to protect employees from injury caused by the

unexpected energization, start-up or release of energy. This procedure will apply toenergy sources such as, but not limited to:

Electrical

Mechanical

Gravity

Pneumatic

Hydraulic

Chemical

Thermal

The equipment that this may include are:

Process Vessels and Piping

Welding machines

Portable Powered Equipment

Lighting



J6.2

Responsibilities

The Facility / Site Manager is responsible for ensuring that the requirements of thisprocedure are met.

The Maintenance Department Supervisor is responsible for ensuring that:

Lockable isolating devices or equivalent means are installed on existingequipment where none are provided, as a minimum, when the equipment isoverhauled.

Maintenance employees affected by this procedure are trained prior to beinginvolved in any Lock, Tag and Try applications.

Personal locks and tags are obtained and issued for jobs involving Lock, Tagand Try applications.

The First Line Supervisor / Offshore Superintendent is responsible for ensuring:

Visiting with Client Representatives to establish, which Lockout / TagoutProcedure will be used. Moreno Group LLC and Subsidiaries will follow theirclient‟s procedure while on their client‟s location only if their procedure meetsor exceeds Moreno Group LLC and Subsidiaries‟ expectations.

Performing a Lockout / Tagout equipment assessment to ensure all energysources are properly lock and tagout. If Moreno Group LLC and Subsidiariesare following their client‟s procedure, this assessment shall be conducted withour client‟s operations personnel.

Employees who are affected by this procedure are trained prior to beinginvolved in any Lockout / Tagout applications.

Standardized locks and personal tags are obtained and issued for jobsinvolving Lockout / Tagout applications.

All affected personnel are notified of the Lock, Tag and Try application to takeplace.

The requirements of this procedure are complied with prior to performing workon equipment.

The Contractor Representative is responsible for ensuring:

Contractor employees affected by this procedure are properly trained prior tobeing involved in any Lock, Tag and Try applications; contractors providetheir own locks and tags

All affected contract personnel including sub-contractors, are notified of theLock, Tag and Try applications to take place.



J6.3

The requirements of this procedure are complied with prior to performing workon equipment.

Contractors are informed of the type of locks and tags specified for usein the Moreno Group LLC and Subsidiaries facilities / sites.

The Engineering Department is responsible for ensuring that all new machinery orequipment installed or existing equipment that has been overhauled has identified,lockable, isolating devices for each energy source involved.

The Safety, Health and Environmental Department is responsible for ensuringthat:

Training programs are made available to the Area / Department Managers forthe training of all facility / site personnel.

Periodic audits are performed to ensure procedure compliance.

The Employee is responsible for ensuring:

The requirements of this procedure are followed for work involved in, on oraround machines or equipment during repair, maintenance, operation or otherrelated activities.

Individual locks and tags are applied and removed ONLY by the employee towhom they are assigned.

Before starting work each authorized (exposed) employee shall verify (try)

that the equipment will not start by activating (or witnessing the activation) allof the start / stop switches.

Definitions

Affected Employee – An employee whose job requires the operation or use of amachine or equipment on which servicing or maintenance is being performed underlockout or tagout, or whose job requires him/her to work in an area in which suchservicing or maintenance is being performed.

Authorized Employee – A person who locks or implements a tagout system to

perform the servicing or maintenance on that machine or equipment. An authorizedemployee may be the same person when the affected employee‟s duties alsoinclude performing machine maintenance or service on a machine or equipment,which must be locked, or a tagout system implemented.

Capable of being locked out – An energy isolating device will be considered to becapable of being locked out either if it is designed with a hasp or other attachment orintegral part to which, or through which, a lock can be affixed, or if it has a lockingmechanism built into it. Other energy isolation devices will also be considered to be



J6.4

capable of being locked out, if lockout can be achieved without the need todismantle, rebuild or replace the energy-isolating device or permanently alter itsenergy control capability.

Energized – Connected to an energy source or containing residual or stored energy.

Energy isolating device – A mechanical device that physically prevents the

transmission or release of energy, including but not limited to the following: Amanually operated electrical circuit breaker; a disconnect switch; a manuallyoperated switch by which conductors and, in an addition, no pole can be operatedindependently; a slide gate; a slip blind; a line valve; a block; and any similar deviceused to block or isolate energy. The term does not include a push button, selectorswitch, and other control circuit type devices.

Energy source – Any source of electrical, mechanical, hydraulic, pneumatic,chemical, thermal, or other energy.

Lockout – The placement of a lockout device on an energy isolating device, in

accordance with an established procedure, ensuring that the energy isolating deviceand the equipment being controlled cannot be operated until the lockout device isremoved.

Lockout device – A device that utilizes a positive means such as a lock, key type, tohold an energy isolating device in the safe position and prevent energizing of amachine or equipment.

Normal production equipment – The utilization of a machine or equipment to performits intended production function.

Servicing and/or maintenance – Workplace activities such as constructing, installing,setting up, adjusting, inspecting, modifying, and maintaining and/or servicingmachines or equipment. These activities include lubrication, cleaning, unjammingmachine, equipment and making adjustments or tool changes, where the employeemay be exposed to the unexpected energization or startup of the equipment orrelease of hazardous energy.

Setting up – Any work performed to prepare a machine or equipment to perform itsnormal production operation.

Tagout – The placement of a tagout device on an energy isolating device, in

accordance with an established procedure, to indicate that the energy isolatingdevice and the equipment being controlled may not be operated until the tagoutdevice is removed.

Tagout device – A prominent warning device, such as a tag and a means ofattachment, which can be securely fastened to an energy isolating device inaccordance with an established procedure, to indicate that the energy isolatingdevice and the equipment being controlled may not be operated until the tagoutdevice is removed.



J6.5

Lockout/Tagout vs. Tagout Alone

The primary method of energy isolation shall be both lockout and tagout. Thelockout devices used in isolating the energy shall be distinctive and only used for thisprocedure. Lock shall be key operated and shall be capable of identifying theauthorized employee who is using the lock.

A tagout system alone does not provide positive means of controlling stored energy.This system shall only be used when an energy source is not capable of beinglocked out. Although, whenever major replacement, repair, renovation ormodification is performed and when needed equipment is purchased, the equipmentor machine shall be capable of accepting a lockout device.

Prior to implementing a tagout system the authorized employee(s) shall ensure thefollowing:

The energy isolation device(s) are not capable of being locked-out.

The energy isolation device(s) cannot be modified to accept a lockout device.

The tagout system meets the applicable provisions of this procedure.

Lockout Equipment

Locks – Locks will be silver with a blue stripe, key operated and shall only be usedfor this procedure. The locks shall identify each individual employee. The employeeshall be assigned a number set of locks which is inscribed on the lock. Thesupervisor of the employees shall maintain a list assigned locks.

I & E Division Lockout Locks – Locks will be yellow, key operated. The supervisorwill be the only one to apply these locks. These locks shall be utilized to preventequipment from being turned on when no one is working on the equipment.

I & E Division Operation Locks – Locks will be red, key operated and shall only beused for this procedure.

Hasps Scissors Devices – Lockout scissors are designed to hold a piece ofequipment in a „safe or off‟ position and are utilized when more than one lock mustbe attached to an energy isolating device or lockout box.

Chains – Various lengths of chains are used to tightly wrap around and/or throughvalve/hand wheel handles and a stationary object to prevent opening or closing thevalve. A scissors device shall be attached to the chain to secure it in place.Whenever a chain is used a scissors device and a lock shall be utilized.

Tagout Devices

Lockout/Tagout Tags – The tags used for energy isolation are standardized(“Danger Do Not Operate” tag, white in color). Tags are attached directly to the lockshank or by a tie-wrap. Each tag shall be identified with the authorized employee‟s



J6.6

name and date of placement. On those jobs where an energy isolation devicecannot be locked out, a tagging system shall be implemented.

Group Lockbox – A lockbox shall be a durable box fitted with a closure capable ofaccepting a scissors device. A lockbox will be used when implementing a GroupLockout Procedure.

Requirements

Each authorized employee shall survey the equipment to locate and identify allisolating devices to be certain which energy isolating device(s) needs a lockoutdevice. The following are some examples of energy isolation devices:

Block Valves (ball and gate valves)

Circuit Breakers

Plugs

More than one of the above energy isolating devices may be combined to isolate themachine or equipment, i.e. block valves and circuit breaker.

Prior to isolating the equipment each authorized employee shall understand theeffects of isolating the equipment, i.e. alarms, hazards of the energy beingcontrolled, and means of controlling the equipment.

The authorized employee shall notify the affected employee(s) of the intent toshutdown the equipment and the energy isolation procedure being used to isolatethe equipment. At this time the equipment may be shutdown by the normal

shutdown procedures.

Each authorized employee shall ensure the equipment is being isolated from itsenergy source. The following are some examples but are not limited to:

Turning an equipment‟s circuit breaker to its „off‟ position.

Removing the equipment‟s fuses.

Disconnecting lines.

Blocking the pneumatic pressure containing lines and gravity feed lines.(Remember to bleed off residual pressure.)

Each authorized employee shall verify each energy-isolating device is in a safe or offposition prior to affixing his or her personal lock(s) and yellow tag(s) on each energy-isolating device. The lockout device shall be placed on the energy isolatingdevice(s) to ensure it is held in a safe or off position. If the energy isolating device(s)are incapable of being locked, a yellow tag shall be positioned by each authorizedemployee on the energy isolating device(s) or located as close to the device(s).



J6.7

Each authorized employee shall maintain possession of their key at all times and fora tagout situation the yellow tag.

After isolating the machine or equipment, all potential hazardous stored or residualenergy shall be relieved, disconnected, restrained, and otherwise rendered safe. Ifthere is a possibility of re-accumulation of stored energy to a hazardous level,

verification of isolation shall be continued until the servicing or maintenance iscompleted or until the possibility of such accumulation no longer exists.

Lockout or Tagout Removal Procedure

Before lockout or tagout devices are removed and energy is restored to the machineor equipment, the authorized employee(s) shall ensure the following:

Inspect the work area to ensure that nonessential items (i.e. tools, parts, etc.)have been removed and to ensure that machine or equipment componentsare operationally intact.

The work area shall be checked to ensure that all employees have beensafely positioned or removed.

Before lockout or tagout devices are removed and before machines orequipment are energized, affected employees shall be notified that thelockout or tagout device(s) have been removed. Only the authorizedemployee who applied the lockout or tagout device(s) shall remove them.

If the authorized employee is not available to remove the lockout or tagout device(s),the device(s) may be removed by the supervisor of the employee or the supervisor

of the facility providing the following procedures are followed and documented:

Verification by the supervisor that the authorized employee(s) who applied thedevice are not at the facility.

Make a reasonable effort to contact the authorized employee to informhim/her that their lockout or tagout device(s) have been removed.

Ensure authorized employee(s) have the knowledge that their lockout ortagout devices(s) have been removed before they resume work at that facility.

If the situation the lockout or tagout device(s) need to be temporarily removed to testor reposition the machine or equipment, the following procedures shall be followed:

Clear the machine or equipment of tools or materials.

Remove employees

Remove the lockout or tagout device(s) per our Energy Isolation Procedure.



J6.8

Energize and proceed with testing or positioning.

Deenergize all systems and reapply energy control device(s) per our EnergyIsolation Procedure to continue the servicing and/or maintenance.

In the event the authorized employee(s) need to start the machine or equipment toenable them to trouble shoot or conduct any tasks that require the machine or

equipment to be operational, the authorized employee(s) shall place a completedYellow Tag on the Control Panel of the machine or equipment. The authorizedemployee(s) shall detach the tag‟s serial number stub and maintain possession ofthe stub. The authorized employee(s) shall reapply the energy Isolation Procedurewhenever the machine or equipment no longer needs to be operational to conductthe servicing or maintenance.

Group Energy Isolation Procedure

The Offshore Divis ion o f Moreno Group LLC and Sub sidiar ies m ay ut i l ize the

fo l lowing procedure . Note: This proc edure wi l l only be used i f Moreno Group

LLC and Subsidiar ies ’ Client’s Lockout / Tagout procedure does not meet thisprocedure .

Group lockout or tagout devices shall be used in accordance with this writtenprocedure. The operator of the facility and the Moreno Group LLC and Subsidiariessupervisor shall be the authorized employees who are responsible for ensuring themachine or equipment energy is isolated.

Prior to isolating the machine or equipment the group shall understand the effects ofisolating the equipment, i.e. alarms, hazard(s) of the energy being controlled, andmeans of controlling the equipment.

The authorized employee (facility operator) shall notify the affected employee(s) ofthe intent to shutdown the machine or equipment and the Energy IsolationProcedure being used to isolate the energy. At this time the machine or equipmentmay be shutdown by the normal shutdown procedure.

The authorized employee shall ensure the machine or equipment is being isolatedfrom its source of energy.

The authorized employee shall verify each energy-isolating device is in „safe‟ or „off‟position prior to affixing the lock(s) and tag(s) on each energy-isolating device. The

lockout device shall be placed on the energy isolation device(s) to ensure it is held ina safe or off position. If the energy isolating device(s) are incapable of being locked,tags shall be positioned by the authorized employee on the energy isolatingdevice(s) or located as close to the device.

The authorized employee shall place the key(s) to the operation locks in the lockbox. At this time, the authorized employee shall review the energy isolation procedurewith the remainder of the employees. After the authorized employee reviews thesystem, shows the key(s) to the group, the authorized employee shall close thelockbox and place a scissors device on the lockbox.



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Each employee working on the machine or equipment has reviewed and agrees withthe system, they shall place their personal lock and yellow tag on the lockbox.These employees shall maintain possession of the key at all times.

Prior to starting work on machines or equipment that have been locked out or taggedout, the authorized employee(s) shall verify that isolation and de-energization of the

machine or equipment have been accomplished. Then the employee(s) may placetheir lock and tag in the lockout box.

Before lockout or tagout device(s) are removed and energy is restored to themachine or equipment, the employees shall ensure the following:

Inspect the work area to ensure that nonessential items (i.e. tools, parts, etc)have been removed and to ensure that the machine or equipmentcomponents are operationally intact.

The work area shall be checked to ensure that all employees have been

safely positioned or removed.

Before lockout or tagout device(s) are removed and before machines orequipment are energized, affected employees shall be notified that thelockout or tagout device(s) have been removed. Only the employee whoapplied the lockout or tagout device(s) shall remove the device(s).

If an employee is not available to remove the lockout or tagout device(s), thedevice(s) shall be removed following the above-mentioned Lockout or TagoutRemoval Procedure.

Shift Change

The authorized employee(s) shall remove their lockout or tagout device(s) prior toleaving the location. The oncoming authorized employee(s) shall review themachine or equipment per the Energy Control Procedure and attach their personallockout or tagout device(s) on the machine or equipment or in the group lockout box.

Cord and Plug Procedure

When work is being performed on cord and plug connected electrical equipment forwhich an exposure to the unexpected energization or start-up of the equipment is

controlled by unplugging of the equipment from the source, the plug must remain inexclusive control (in the employee‟s line of sight) of the employee performing theservicing or maintenance. If the employee is unable to maintain exclusive control ofthe cord or plug, the employee shall follow this procedure to control the energy.



J6.10

Periodic

Annually an inspection shall be conducted to ensure this energy control procedure isbeing followed properly. This inspection should include the following elements:

Date

Equipment being isolated

Employees and Inspectors Names

Major Replacement, Repair, Renovation or Modification of Equipment

Whenever major replacement, repair, renovation or modification of machines orequipment is performed and whenever new machines or equipment are installed,energy isolating devices for such machines or equipment shall be designed toaccept a lockout device.

Training

Upon hire New Employees will receive Lockout / Tagout training during the NewEmployee Orientation / SH&E Training. Refresher training shall be conductedannually by the First Line Supervisor. Upon a reassignment or a programdeficiencies retraining will be conducted.

Simple Procedure

Moreno Group LLC and Subsidiaries’ Energy Isolation Procedure

1. Each authorized employee(s) shall inform operations for the reason of theenergy isolation and review the work area.

2. Each authorized employee will affix their personal lockout or tagout devices) toeach energy isolating device so that it will secure the energy isolating device(s)in a „Safe‟ or „Off‟ position.

3. Each authorized employee shall ensure a completed yellow tag is attached toeach of their personal lock(s)

Prior to shift change and/or leaving the job location

4. Each authorized employee shall remove their personal energy isolating lockoutdevice(s) and shall attach to each energy isolation device a completed white„Do Not Operate‟ tag, meaning the equipment is secured for operationpurposes only.

5. Authorized employee(s) shall inform operations of the status of the job.



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Upon arrival to job location and prior to resuming incomplete task or relievingprevious shift

6. Each authorized employee shall inform operations of the reason for the energy-isolating task and review the work area.

7. Operator shall remove all operation lock(s) and associated, white „Do NotOperate‟ tags.

8. The authorized employee shall follow Steps 2-5.







Excavation andTrenching Procedure


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Excavation and Trenching Procedure

Purpose

This program outlines procedures and guidelines for the protection of employeesworking in and around excavations and trenches.

Scope

This program pertains to all projects that require any excavations or trenchingperformed by Moreno Group LLC and Subsidiaries or their Subcontractors.

RESPONSIBILITIES

The Facility / Site Manager, Superintendent or designee is responsible for:

Evaluating the trenching and shoring hazards at the facility / site.

Establishing minimum safety requirements for all personnel involved withtrenching and shoring activities at the facility / site.

Re-evaluating hazards when changes in the work activities may affectrequirements.

Monitoring and auditing compliance with this procedure.

Project Manager or designee is responsible for:

Understanding the requirements of this procedure.

Developing and maintaining site / job excavation procedures.

Conferring with appropriate personnel as to the hazards and safeguards ofany trenching and shoring job.

Conferring with personnel reporting to them as to the hazards of a job and therequired safeguards.

Monitoring the job and work area for compliance with this procedure.

Initiating the use of additional safeguards as specified in permits or SafeOperating Procedures (SOP’s).



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The First Line Supervisor i.e. (Designated Competent Person) or designee forexcavation activities is responsible for:

Making daily inspections of excavations, adjacent areas, and protectivesystems for evidence of a situation that could result in possible cave-ins,indications of failure of protective systems, hazardous atmospheres or other

hazardous conditions.

Making follow-up inspections as needed throughout the shift and after everyrainstorm or other hazard increasing occurrence.

Ensuring appropriate permits have been obtained prior to beginning work.

Initiating the use of additional safeguards as specified in permits or SafeOperating Procedures (SOP’s).

Removing personnel from the trench or excavation if there is evidence of a

situation that could result in a possible cave-in, failure of protective systems,hazardous atmospheres, or other hazardous condition.

Designate an employee(s) as flag person to direct vehicular or equipmenttraffic.


Arranging or performing Excavation and Trenching training.

Maintaining all SH&E Training Records pertaining to Excavation and

Trenching Training.

Perform periodic Jobsite Hazard Assessments of the Excavation andTrenching location.

Conduct periodic audits of this procedure



Conferring with supervision as to hazards involved and safeguardsassociated with this procedure.

Advising supervision of any suggestions to improve the safety of any job.

Direct vehicular or equipment traffic away from excavation or any hazardoussituations.



J7.3

Definitions

Benching - a method of protecting employees from cave-ins by excavating the sidesof an excavation to form one or a series of horizontal levels or steps, usually withvertical or near vertical surfaces between levels.

Cave-in - the separation of a mass of soil or rock material from the side of anexcavation, or the loss of soil from under a trench shield or support system, and itssudden movement into the excavation, either by failing or sliding, in sufficientquantity so that it could entrap, bury, or otherwise injure and immobilize a person.

Cemented Soil – means a soil in which the particles are held together by a chemicalagent, such as calcium carbonate, such that a hand-size sample cannot be crushedinto powder or individual soil particles by finger pressure.

Cohesive Soil – means a soil (fine grained soil), or soil with a high clay content,which has cohesive strength. Cohesive soil does not crumble, can be excavated withvertical sideslopes, and is plastic when moist. Cohesive soil is hard to break up

when dry, and exhibits significant cohesion when submerged. Cohesive soils includeclayey slits, sand clay, silty clay, clay and organic clay.

Competent Person - one who is capable of identifying existing and predictablehazards in the surroundings or working conditions, which are unsanitary, hazardous,or dangerous to employees, and who has authorization to take prompt correctivemeasures to eliminate them.

Dry Soil – means soil that does not exhibit visible signs of moisture content.

Duration of Exposure - the longer an excavation is open, the longer the other factors

have to work on causing it to collapse.

Excavation - any man-made cut, trench, or depression in an earth surface, formedby earth removal.

Fissured – means a soil material that has a tendency to break along definite planesof fracture with little resistance, or a material that exhibits open cracks, such astension cracks, in an exposed surface.

Granular Soil – means gravel, sand or silt, (coarse grained soil) with little or no claycontent. Granular soil has no cohesive strength. Some moist granular soils exhibit

apparent cohesion. Granular soil cannot be molded when moist and crumbles easilywhen dry.

Hazardous Atmosphere - an atmosphere which by reason of being explosive,flammable, poisonous, corrosive, oxidizing, irritating, oxygen deficient, toxic, orotherwise harmful, may cause death, illness, or injury.

Layered System – means two or more distinctly different soil or rock types arrangedin layers. Micaceous seams or weakened planes in rock or shale are consideredlayered.



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Moist Soil – means a condition in which a soil looks and feels damp. Moist cohesivesoil can easily be shaped into a ball and rolled into small diameter threads beforecrumbling. Moist granular soil that contains some cohesive material will exhibit signsof cohesion between particles.

Plastic – means a property of a soil, which allows the soil to be deformed or molded

without cracking, or appreciable volume change.

Protective System - a method of protecting employees from cave-ins, from materialthat could fall or roll from an excavation, or from the collapse of adjacent structures.Protective systems include support systems, sloping and benching systems, shieldsystems, and other systems that provide necessary protection.

Saturated Soil – means a soil in which the voids are filled with water. Saturationdoes not require flow. Saturation, or near saturation, is necessary for the proper useof instruments such as a pocket penetrometer or sheer vane.

Shield - a structure that is capable of withstanding the forces imposed on it by acave-in and thereby protects employees within the structure. Shields can bepermanent structures or can be designed to be portable and moved along as workprogresses. All shields must be in accordance with 29 CFR 1926.652(c)3 or (c)4.

Sloping - a method of protecting workers from cave-ins by excavating to form sidesof an excavation that are inclined away from the excavation to prevent cave-ins. Theangle of incline required to prevent a cave-in varies with differences such as soiltype, length of exposure, and application of surcharge loads.

Soil Classification System – means a method of categorizing soil and rock deposits

in a hierarchy of Stable Rock, Type A, Type B, and Type C, in decreasing order ofstability. The categories are determined based on an analysis of the properties andperformance characteristics of the deposits and the environmental conditions ofexposure.

Stable Rock - natural solid mineral matter which can be excavated with vertical sidesand remain intact while exposed.

Submerged Soil – means soil, which is underwater or is free seeping.

Surcharge Loads - generated by the weight of anything in proximity to the

excavation, push starts for a cave-in (anything up top pushing down). Commonsurcharge loads:

weight of spoil pile

weight of nearby buildings, poles, pavement, or other structural objects.

weight of material and equipment



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Trench - a narrow excavation below the surface of the ground, less than 15 feetwide, with a depth no greater than the width.

Type A Soil - is cohesive with an unconfined compressive strength of 1.5 tons persquare foot (tsf). Type A soils include clay, silty clay, sandy clay, clay loam, caliche,hardpan, and sometimes-silty clay loam and sandy clay loam. No soil should beclassified as Type A if it is fissured; subject to vibration from traffic, pile driving, orsimilar effects; previously disturbed; or part of a sloped, layered system where theslope is four horizontal to one vertical or greater.

Type B Soil - is cohesive soil with an unconfined compressive strength greater than.5 tsf but less than 1.5 tsf. Type B soils include granular cohesionless soils likeangular gravel, silt, silt loam, sandy loam, and sometimes silty clay loam and sandyclay loam; previously disturbed soils that are not Type C; fissured soils and soilssubject to vibration that would otherwise be classified as Type A; dry rock that is notstable; and material that is part of a sloped, layered system where the layers dip ona slope less steep than four horizontal to one vertical.

Type C Soil - is cohesive soil with an unconfined compressive strength of .5 tsf orless. Type C soils include granular soils such as gravel, sand, and loamy sand;submerged soil; soil from which water is freely seeping; submerged rock that is notstable; or material in a sloped, layered system where the layers dip into theexcavation at a slope of four horizontal to one vertical or steeper.

Unconfined Compressive Strength – means the load per unit area at which a soil willfail in compression. It can be determined by laboratory testing, or estimated in thefield using a pocket penetrometer, by thumb penetration tests, and other methods.

Undermining - undermining can be caused by such things as leaking, leaching,

caving or over-digging. Undermined walls can be very dangerous.

Vibration - a force that is present on construction sites and must be considered. Thevibrations caused by backhoes, dump trucks, compactors and traffic on job sites canbe substantial.

Wet Soil – means soil that contains significantly more moisture than moist soil, but insuch a range of values that cohesive material will slump or will begin to flow whenvibrated. Granular material that would exhibit cohesive properties when moist willlose those cohesive properties when wet.

Requirements

Before Excavating

Before anyone at this company begins excavating, we follow the steps below:

Contact the utility companies or property owners and ask the companies orowners to find the exact location of the underground installations in the area.



J7.6

If the utility companies or owners do not respond within 24 hours or the periodestablished by law or ordinance, or if they cannot establish the location of theutility lines, the excavation may proceed with caution only with the Client orOwner ’s approval. In this situation, employees shall be provided withdetection equipment or other safe and acceptable means to locate utilityinstallations. Some Client’s may require a Utility Representative Presentduring the excavation.

Remove or adequately support the following objects (i.e., trees, rocks, andsidewalks) in the excavation area that could create a hazard to employees.

Using Appendix A to 29 CFR 1926, Subpart P, classify the type of soil androck deposits at the site as either stable rock, Type A, Type B, or Type C soil.The soil classification is based on the results of at least one visual and atleast one manual analysis conducted by a competent person. Details of theacceptable visual and manual analyses are to be found in Appendix A of 29CFR 1926, Subpart P.

NOTE: Soil classification is not necessary if the excavation will be sloped toan angle of one and one-half horizontal to one vertical or if shoring is used.

Have the competent person choose the appropriate method for protectivesupport systems, as necessary. See the Protective Support Systems sectionfor the procedures he/she used for selecting this system.

Protective Support Systems

The company protects each employee in an excavation from cave-ins during anexcavation by an adequate protective system designed in accordance with OSHA

standards. Protective system options include proper sloping or benching of the sidesof the excavation; supporting the sides of the excavation with timber shoring oraluminum hydraulic shoring; or placing a shield between the side of the excavationand the work area. Moreno Group LLC and Subsidiaries has the following StandardOperating Procedures (SOP) regarding protective support systems for excavations,in accordance with safe practices and procedures and OSHA excavationregulations:

If the excavation is made entirely of stable rock, then no protectivesystem is necessary or used unless the Competent Person or theClient requires added safeguards.

If the excavation is less than 5 feet in depth (provided there is noindication of a potential cave-in), then no protective system isnecessary or used.

If the excavation is less than or equal to 20 feet in depth, then acompetent person shall choose the most practical design approach(that meets required performance criteria) for the particular



J7.7

circumstance and / or a registered professional engineer design allprotective systems for use in the excavation.

If the excavation is more than 20 feet in depth, then have a registeredprofessional engineer design all protective systems for use in theexcavation.

Sloping

When sloping is used to protect against cave-ins, these options can be chosen fordesigning sloping systems:

If a soil classification is not made, then slope the sides of the excavation to anangle not steeper than one and one-half horizontal to one vertical (34degrees). A slope of this gradation or less is considered safe for any type ofsoil.

Use the following table to determine the maximum allowable slope andallowable configurations for sloping systems. The soil type must bedetermined in order to use this option.

Maximum Allowable Slopes (H: V)For Excavations Less Than 20 Feet Deep

Stable Rock Vertical 90 degrees

Type A ¾:1 53 degrees

Type B 1:1 45 degreesType C 1 ½:1 34 degrees

Use other tabulated data approved by a registered professional engineer.

Have an engineer design and approve the system to be used. There are anumber of exceptions or special cases to these general sloping guidelines,which can be utilized by your company if the conditions meet the exception'srequirements. The exceptions and conditions are outlined below:

- In Type A soil, simple slope excavations which are open 24 hours or less(short term) and which are 12 feet high or less in depth may have amaximum allowable slope of 1/2 horizontal to 1 vertical.

- In Type A soil, all excavations 8 feet or less in depth, which have

unsupported vertically sided lower portions must have a maximum verticalside of 3.5 feet.

- In Type A soil, excavations over 8 feet but less than 12 feet in depth withunsupported vertically sided lower portions must have a maximumallowable slope of 1H:1V and a maximum vertical side of 3.5 feet.

- In Type A soil, excavations 20 feet or less with vertically sided lowerportions that are supported or shielded shall have a maximum allowable



J7.8

slope of 3/4 H:1V. The support or shield system must extend at least 18inches above the top of the vertical side.

- In Type B soil, all excavations 20 feet or less which have vertically sidedlower portions shall be shielded or supported to a height at least 18 inchesabove the top of the vertical side. The excavation shall have a maximumallowable slope of 1H:1V.

- In Type C soil, all excavations 20 feet or less which have vertically sidedlower portions shall be shielded or supported to a height at least 18 inchesabove the top of the vertical side. The excavation shall have a maximumallowable slope of 1-1/2 H:1V.

- When an excavation contains layers of different types of soils, the generalsloping requirements do not apply. The excavation must be slopedaccording to Appendix B-1.4 of 29 CFR 1926, Subpart P.

The competent person chooses the best option for sloping for the job at hand.

Benching

When benching is used to protect against cave-ins, these options can be chosen fordesigning benching systems:

Use Appendices A and B of 29 CFR 1926, Subpart P to determine themaximum allowable slope (also, see table in Sloping section) and allowableconfigurations for benching systems. The soil type must be determined inorder to use this option.

Use other tabulated data approved by a registered professional engineer.

Have an engineer design and approve the system to be used.

There are a number of exceptions or special cases to these general benchingguidelines, which should be utilized by your company if the conditions meet theexception's requirements. The exceptions and conditions are outlined below:

- In Type A soil, simple slope excavations which are open 24 hours orless (short term) and which are 12 feet high or less in depth may havea maximum allowable slope of 1/2 horizontal to 1 vertical.

- In Type A soil, all excavations 8 feet or less in depth, which haveunsupported vertically sided lower portions must have a maximumvertical side of 3.5 feet.

- In Type A soil, excavations over 8 feet but less than 12 feet in depthwith unsupported vertically sided lower portions must have a maximumallowable slope of 1H:1V and a maximum vertical side of 3.5 feet.



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- In Type A soil, excavations 20 feet or less with vertically sided lowerportions that are supported or shielded shall have a maximumallowable slope of 3/4H:1V. The support or shield system must extendat least 18 inches above the top of the vertical side.

- In Type B soil, all excavations 20 feet or less which have verticallysided lower portions shall be shielded or supported to a height at least18 inches above the top of the vertical side. The excavation shall havea maximum allowable slope of 1H:1V.

- In Type C soil, all excavations 20 feet or less which have verticallysided lower portions shall be shielded or supported to a height at least18 inches above the top of the vertical side. The excavation shall havea maximum allowable slope of 1-1/2 H:1V.

- When an excavation contains layers of different types of soils, thegeneral sloping requirements do not apply. The excavation must besloped according to Appendix B-1.4 of 29 CFR 1926, Subpart P.

The competent person chooses the best option for sloping for the job at hand.

Support Systems, Shield Systems, and Other Protective Systems

Timber Shoring

When trenches do not exceed 20 feet, timber shoring according to OSHAdesign specifications may be used. Designs for timber shoring in trenches forcompany work sites are determined by the competent person using thefollowing method(s):

Use the requirements set forth by OSHA in Appendices A and C of the 29CFR 1926, Subpart P. The design specifications for timber shoring providedby OSHA may be found in Tables C-1.1 through C-1.3 of Appendix C of 29CFR 1926, Subpart P. These tables refer to the actual dimensions and notnominal dimensions of the timber. If the competent person chooses to usenominal size shoring, they must use the additional tables found in Appendix Cof 29 CFR 1926, Subpart P. The soil type in which the excavation is mademust be determined in order to use the OSHA data.

NOTE: The specifications do not apply in every situation experienced in the field;

the data were developed to apply to most common trenching situations. If thespecifications do not apply to the situation encountered in the field, thecompetent person will make a determination of what approach to use to allowsafe protective support of the excavation.

Use data provided by the manufacturer of the support system.

Use other tabulated data approved by an engineer.



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Have a registered professional engineer design the system.

Aluminum Hydraulic Shoring

Determined by the competent person, each design for aluminum hydraulic shoring isbased upon the following method(s):

Use the manufacturer's tabulated data and design in accordance with themanufacturer's specifications, recommendations, and limitations. Deviationsfrom the manufacturer's specifications, recommendations, or limitations areonly allowed upon written approval of the manufacturer, which must beobtained by the competent person prior to implementation. The writtenapproval is kept at the job site during construction of the protective system.

Use the OSHA specifications found in Appendix D of 29 CFR 1926, SubpartP, if the manufacturer's tabulated data cannot be utilized.

NOTE: Before using the OSHA data, the soil type must be determined.



Other Support Systems

Designs for our support systems are determined by the competent person using thefollowing method(s):

Here are your options found under 29 CFR 1926.652(c):




Shielding

Determined by the competent person, designs for shielding are based upon thefollowing method(s):







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Other Protective Systems

Designs for our protective systems are determined by the competent person usingthe following method(s):





General Requirements for Excavations

The following rules are to be followed at all times by all employees working on, in, ornear excavations, as applicable:

Employees exposed to any vehicular or equipment traffic must wear warningvests or other suitable garments made of reflectorized or high-visibilitymaterial. The Competent Person shall identify an employee(s) as a flagperson to direct vehicular or equipment traffic.

The competent person inspects the excavation and the adjacent areas on adaily basis for possible cave-ins, failure of protective systems and equipment,hazardous atmospheres, or other hazardous conditions. Inspections are alsorequired after the occurrence of any natural (i.e. rain) or man-made events (i.e. blasting) that could increase the potential for hazards (see Attachment 1)Employees may not begin work until after being informed by the competent

person that these inspections are complete.

A warning system (i.e. flag person, barricades, stop logs etc.) is used to alertoperators of mobile equipment and other employees at the work site of theedge of an excavation.

Adequate protection is provided to protect employees from falling rock, soil, orother materials and equipment. Protection is provided by placing and keepingsuch materials or equipment at least 10 feet from the edge of excavations, orby the use of retaining devices that are sufficient to prevent materials orequipment from falling or rolling into excavations, or by a combination of both

if necessary.

Employees are not permitted under loads that are handled by lifting or diggingequipment. Employees are not allowed to work in the excavation above otheremployees unless the lower level employees are adequately protected.

While the excavation is open, underground installations are protected,supported, or removed as necessary to safeguard employees. Adjacentstructures are supported to prevent possible collapse.



J7.12

Employees are not permitted to work in excavations where water hasaccumulated or is accumulating unless adequate precautions have beentaken. Diversion ditches, dikes, or other means are used to prevent surfacewater from entering an excavation and to provide drainage to the adjacentarea.

Note: A Confined Space Permit shall be issued prior to entering the

excavation. Emergency rescue equipment is readily available and attendedwhen hazardous atmospheric conditions exist or may develop.

Sufficient means (i.e. ladders, stairway, ramp etc.) for exiting excavations 4feet deep or more are provided and are within 25 feet of lateral travel foremployees.

Guardrails are provided if there are walkways or bridges crossing over anexcavation.

Training

Training in excavating, trenching and shoring hazards and safeguards is required forall, new or existing, employees who are involved in these activities. Employees whohave not been trained in the hazards and safeguards are not allowed to performtasks or jobs involving these activities. Initial training and periodic refresher trainingis required and must include the following:

The requirements of this Policy-Procedure

Regulatory requirements

The proper use of excavating, trenching and shoring equipment

Care and storage of the equipment

The hazards and safeguards of excavating, trenching and shoringactivities

Training requirements for the First Line Supervisors or designees who are to bedesignated as “Competent” personnel. These are the people who may inspectexcavations and may complete the “Excavation Hazard Assessment Checklist.”“Competent” persons must receive specific training as required in the OSHA

Standard. This type of training is available from approved training organizationsidentified by the SH&E Department. The SH&E Department shall maintain alltraining documentation. Recorded information must include trainee’s name, date,and trainer’s name or names and will be maintained.

Inspection Procedures

The competent person inspects excavations daily and during poor weather. Ourinspection checklist is located in Attachment 1.



J7.13


We have determined that the following hazards that require personal protectiveequipment are possible in and around our excavations:

Cave-ins

Falls

Respiratory / fire hazards from hazardous atmospheres

Electrical shock

Physical strain

High noise levels (over 85 dBA)

For this reason, we require that our excavation workers wear the following minimumPersonal Protective Equipment (PPE) and equipment:

Hard Hat

Hearing Protection

Safety Glasses

Respiratory Protection (if Respiratory Hazard is present)

Fire Resistant Clothing

Gloves and

Steel Toes Shoes

All excavation workers required to wear this equipment are trained when it isnecessary; what equipment is necessary; how to properly put on, take off, adjust,and wear it; limitations of the equipment; and proper care, maintenance, useful life,and disposal of PPE.



J7.14

Non-excavation Worker Protection

As for those who don’t work in or around excavations, but who may becomebystanders, we require that the following minimum PPE is worn:

Hard Hat,

Safety Glasses,

Fire Resistant Clothing and

Steel Toed Boots

Recordkeeping

We keep a copy of the following documents at the job site during construction of aparticular excavation protective system and then store them at a designated locationwithin the facility where they will be readily available to OSHA upon request:

Tabulated data for designing any of our sloping or benching systems.

Designs of any sloping or benching systems approved by a registeredprofessional engineer.

Manufacturer’s specifications, recommendations, and limitations fordesigns of support systems, shield systems, and other protectivesystems drawn from manufacturer’s tabulated data.

Manufacturer’s approval to deviate from the specifications,recommendations, and limitations for designs of support systems,shield systems, and other protective systems drawn frommanufacturer’s tabulated data.

Tabulated data for designing any of our support systems, shieldsystems, and other protective systems.

Designs of all support systems, shield systems, and other protectivesystems approved by a registered professional engineer.



J7.15

Attachment 1





Moreno Group LLC and SubsidiariesExcavation Hazard Assessment Checklist

J7.15.a.1

Competent Person – FirstLine Supervisor

Job Number

Job Location

Customer Name

Date

A EMPLOYEE/PERSONAL PROTECTION/TRENCH INTEGRITY YES NO N/A

A1 Are employees protected from loose material that could fall into thetrench?

A2 Are walkways provided when employees or equipment are requiredto cross over excavations?

A3 Are walkways that are six feet or more above lower levels ofexcavations equipped with guardrails?

A4

Are employees provided with and are they required to wear proper

safety equipment?

A5 If a hazardous atmosphere is identified, is ventilation provided or isrespiratory protection in use?

A6 Have hazardous objects been removed from the excavation area orblocked securely?

A7 Is heavy equipment mounted on wooden mats to distribute weight?

A8 Are damaged materials or equipment removed from service?

A9 Is excavated material stored at least 2 feet from the edge of theexcavation?

A10 Has the soil type been classified?

A11 Is the location of the trench marked by banners, barricades, or othersignals?

REMARKS:

B ENTRANCE/EXIT PRECAUTIONS YES NO N/A

B1 Is a safe means of egress (i.e. stairway, ladder, ramp, etc.) providedin a trench four or more feet deep?

B2Is a ladder within 25 feet of all employees working in a trench 4 ormore feet deep?

REMARKS:



J7.15.a.2

C COMPETENT PERSON YES NO N/A

C1Does a competent person inspect the trench at the beginning ofeach day and throughout the day as needed?

C2 Is the trench inspected by a competent person following anyamount of rain?

REMARKS:

D UTILITY INVOLVEMENT YES NO N/A

D1Has the utility company been notified of the excavation workschedule and asked to establish the location of the utilityunderground installations?

D2 Has the location of underground utility lines been identified?

REMARKS:

E WATER ACCUMULATION YES NO N/A

E1Is the trench free of standing water or are adequate precautions inplace against the hazards of water accumulation?

E2 Is the proper water removal equipment operating under guidance ofa competent person?

E3 Are diversion ditches or dikes in place to prevent surface water fromentering the trench?

REMARKS:



J7.15.a.3

F SLOPING AND BENCHING YES NO N/A

F1 Is the sloping and benching system designed per OSHArequirements?

F2 Is the aluminum hydraulic shoring system designed per OSHArequirements?

F3 When a combination of sloping and shielding is used, does the

shield extend 18 inches above the bottom slope of the excavation?

REMARKS:

G HAZARDOUS ATMOSPHERES YES NO N/A

G1 Is the air quality in the trench tested if a hazardous atmosphere issuspected?

G2If excavation is 4 feet in depth or greater, has a Confined SpaceEntry Permit been issued prior to entry into excavation?

REMARKS:

H EMERGENCY RESPONSE/FIRST AID YES NO N/A

H1 Is an emergency response program in place?

H2Is emergency rescue equipment readily available, in working order,and attended when in use?

REMARKS:

I SHORING AND SHIELDING SYSTEMS YES NO N/A

I1 Are employees protected from cave-ins when entering and exiting ashield?

I2 Are protective support systems installed in a manner that protectsemployees?

I3 Are protective support systems dismantled from the bottom up?

I4 Is the timber shoring system designed per OSHA requirements?

I5 Is the excavation backfilled as the protective system is dismantled?

I6 Is the shielding system designed per OSHA requirements?

I7 Are shields free from damage or defects?

REMARKS:







Fall ProtectionPage: 1 of 15Original: 01/01/2001Revised: 10/01/2009

J8.1

Fall Protection

Purpose

To establish protective controls for personnel working at elevated heights that willprevent or minimize injury or death resulting from falls from elevated work locations.

Scope

This procedure establishes minimum requirements for working at unguardedelevated work locations that are six (6) feet or more above floor or grade level. Thisprocedure applies to all Moreno Group LLC and Subsidiaries’ employees and sub-contractors. It covers activities such as, but not limited to work in or on:

Pipe racks

Unguarded scaffolding

Suspended scaffolds

Tank tops

Process structures without guarded work platforms

Ladders

Work on + 10 Level offshore

Responsibilities



Evaluating the potential elevated work hazards at Moreno Group LLC andSubsidiaries facilities / sites, qualifying the level of risk of each job andestablishing the required safeguards.

Re-evaluating the potential elevated work hazards when changes in workareas may affect the safeguards required.

Monitoring work areas for compliance with this procedure and requiredsafeguards.



J8.2

Ensuring any additional precautions are included as necessary in permits.

Ensuring required auditing of this procedure is performed.

The First Line Supervisor / Offshore Superintendent (competent person)is responsible for:

Evaluating the need for personal fall protection as an integral part of pre-planning a job.

Ensuring inspections are performed by their personnel.

Ensuring the following is implemented when work must be performed atrecognized unguarded, elevated heights of six (6) feet or above:

Personal Fall Protection needs for all phases of the job, includingtraveling to and from elevated work areas, and during theperformance of work at elevated work areas, may be accompaniedby the use of:

Temporary scaffolding

Platforms

Guardrails

Removing from service any equipment subjected to the forces of a fall.

Monitor their project for compliance with fall protection requirements.

NOTE: With the selection of either option 1 or 2, precautions must be taken toprotect workers from free fall hazards while installing temporary or permanent fallprotection systems. Assuring all employees reporting to them who may berequired to use personal fall protection are properly trained and understand therequirements of the Elevated Work Safeguards Procedure.


Understanding and following the requirements of the Elevated WorkSafeguards Procedure.

Bringing any questions or concerns about the type of personal fall protectionequipment or system installation on any job to the attention of supervision.

Inspecting the personal fall protection system anchor points, connectingmeans, lanyards, harnesses, etc. prior to use. This inspection should bethorough and any problems should be immediately brought to the attention ofsupervision.



J8.3

Reporting any fall to supervision immediately.

Removing from service any equipment subjected to the forces of a fall.

Definitions

Anchorage – a secure point of attachment for lifelines, lanyards or deceleration

devices.

Body Harness -- Straps which may be secured about the employee in a manner thatwill distribute the fall arrest forces over at least the thighs, pelvis, waist, chest andshoulders with means for attaching it to other components of a personal fall arrestsystem.

Competent Person – An individual designated by the employer to be responsible forthe immediate supervision, implementation, and monitoring of the employer’smanaged fall protection program who, through training and knowledge, is capable ofidentifying, evaluating, and addressing existing and potential fall hazards, and who

has the employer’s authority to take prompt corrective action with regard to suchhazards.

Controlled Access Zones – An area in which certain work may take place without theuse of guardrail systems, personal fall arrest systems or safety net systems andaccess to zone is controlled.

Deceleration Device – Any mechanism, such as a rope grab, rip stitch lanyard,specially woven lanyard, tearing or deforming lanyards, automatic self-retractinglifelines/lanyards, etc., which serves to dissipate a substantial amount of energyduring a fall system or otherwise limit the energy imposed on an employee during fall

arrest.

Deceleration Distance means the additional vertical distance a falling employeetravels, excluding lifeline elongation and free fall distance, before stopping, from thepoint at which the deceleration device begins to operate. It is measured as thedistance between the location of an employee’s body belt or body harnessattachment point at the moment of activation (at the onset of fall arrest forces) of thedeceleration device during a fall, and the location of that attachment point after theemployee comes to a full stop.

Free fall means the act of falling before a personal fall arrest system begins to apply

force to arrest the fall.

Free fall distance means the vertical displacement of the fall arrest attachment pointon the employee’s body belt or body harness between onset of the fall and justbefore the system begins to apply force to arrest the fall. This distance excludesdeceleration distance, and lifeline / lanyard elongation, but includes any decelerationdevice slide distance or self-retracting lifeline / lanyard extension before they operateand fall arrest forces occur.



J8.4

Guardrail system means a barrier erected to prevent employees from falling to lowerlevels.

Lanyard – A flexible line of rope, wire rope, or straps which generally has aconnector at each end for connecting the body harness to a deceleration device,lifeline or anchorage.

“Y” Lanyard – Two lanyards sharing a common shock absorbing device.

Leading Edge – The edge of a floor, roof or formwork for a floor or other walking /working surface (such as the deck), which changes location as additional floor, roof,decking or formwork sections are placed, formed or constructed to be an“unprotected side and edge” during periods when it is not actively and continuouslyunder construction.

Lifeline – A component consisting of a flexible line for connection to an anchorage atone end to hang vertically (vertical lifeline) or for connection to anchorages at bothends to stretch horizontally (horizontal lifeline) and which serves as a means forconnecting other components of a personal fall arrest system to the anchorage.

Personal Fall Arrest System – A system used to arrest an employee in a fall from aworking level. It consists of an anchorage, connectors, and a body harness whichmay include a lanyard, deceleration device, lifeline or suitable combinations of these.

Qualified Person – A person with a recognized degree or professional certificate andwith extensive knowledge, training, and experience in the fall protection and rescuefield who is capable of designing, analyzing, evaluating and specifying fall protectionand rescue systems to the extent required by the standard.

Rope Grab – A deceleration device that travels on a lifeline and automatically by

friction, engages the lifeline and locks so as to arrest the fall of an employee. A ropegrab usually employs the principle of inertial locking, cam/level locking or both.

Safety Monitoring – A safety system in which a competent person is responsible forrecognizing and warning employees of fall hazards.

Self-Retracting Lifeline/Lanyard – A deceleration device containing a drum-woundline, which can be slowly extracted from or retracted onto, the drum under slighttension during normal employee movement and which after onset of a fall,automatically locks the drum and arrests the fall.

Unprotected sides and edges means any side or edge (except at entrances to pointsof access) of a walking / working surface, e.g., floor, roof, ramp, or runway wherethere is no wall or guardrail system at least 39 inches (1.0 m) high

Walking / working surface means any surface, whether horizontal or vertical onwhich an employee walks or works, including, but not limited to, floors, roofs, ramps,bridges, runways, formwork and concrete reinforcing steel but not including ladders,vehicles, or trailers, on which employees must be located in order to perform their

job duties.



J8.5

Requirements

This policy provides for continuous fall protection, when the possibility of a fall of 6feet or greater exists. This may occur when work activities include traversing,climbing, descending, etc. The First Line Supervisor shall be responsible forrecognizing fall hazards, communicate and monitor the hazard. Fall Hazards includebut not limited to, uneven surfaces, obstacles or clutter, elevated work areas,

inadequate handrails, inadequate barricades around a deck opening or edge,improper climbing equipment, or fall protection equipment failure.

Fall prevention incorporates methods and practices that eliminate the possibility of afall. Wherever possible, eliminating the possibility of a fall through design changesor a change in work procedures is preferred. Engineering out the hazards duringdesign of a work location, or modification to an area can eliminate the fall hazardentirely. Where design modifications are not practical, or cannot totally eliminate thehazards, traditional fall protection equipment such as handrails and guardrails is themost effective risk reduction measure. Where traditional fall protection is notpossible, fall restraint and personal fall arrest systems shall be required.

When a Personal Fall Arrest System is utilized for fall protection, it must meet thearresting force identified in the equipment section of this procedure and installed insuch a manner to prevent the employee from free falling more than 6 feet or contactthe lower level.

Equipment

A full body harness is required to properly distribute fall arrest forces tominimize potential injury to the body in the event of a fall. The maximumarresting force on an employee shall be limited to 1,800 lbs. The harness

must be made of polyester material, and be ANSI Z359.1 approved.Harnesses shall be capable of supporting 5,000 lbs.

“Y” lanyards a maximum of 6 feet in length are required. Lanyards must be ANSI Z359.1 approved. Lanyards must have a shock absorbing deviceintegral to them. Shock absorbers shall allow for a maximum decelerationdistance of 3.5 feet, and limit fall arrest forces to 900 lbs. All snap hooksintegral to lanyards shall be of the self-locking/self-closing design, whichmeets ANSI Z359.1-2007. Lanyards shall be capable of supporting 5,000 lbs.Lanyards shall be tied off to a suitable anchor point 100% of the time and alsoduring travel.

Anchor Point

An anchor point is a secure point of attachment for lanyards, lifelines, or othercomponents of a personal fall protection system. Anchor points shall becapable of supporting 5,000 lbs. per employee attached, or shall be designedwith a safety factor of at least two by a qualified person. An anchor pointshould be as directly overhead as possible, or attachment to the anchor pointshould be chosen as to not allow a free fall of greater than 6 feet. In caseswhere the anchor point is lower than the attachment point of the harness, a



J8.6

shorter lanyard or other fall arrest device (i.e. Retractable lifeline) should beused. Handrails, barricades, tubing, cable trays, small diameter piping (i.e. 2” O.D. or less) shall not be used as an anchor point.

Additional Fall Protection

Horizontal LifelineHorizontal lifelines must be of a designed system (i.e. pre engineered system)

and installed under the supervision of a competent person. A QualifiedPerson will design and approve the installation and use of all horizontallifeline systems, whether permanent or temporary. Because forces on theanchorage points at each end of the horizontal lifeline can be much greaterthan those on a vertical plane, only engineered systems may be used.Horizontal lifelines can be rated for one or more persons depending on thecertification by the Qualified Person and must maintain a safety factor of atleast two. (1926.502 (d)(8)). Refer to 1926 subpart M, appendix C forguidelines.

Vertical Lifeline

When vertical lifelines are used, each employee shall be attached to aseparate lifeline. Components of the vertical lifeline system shall be capableof supporting 5,000 lbs. The attachment point of the fall arrestor shall be atthe dorsal dee-ring of the harness. When permanently installed ladderclimbing systems are used, the fall arrestor shall be attached at the chestdee-ring of the harness.

Self Retracting Lanyard (SRL)SRL’s shall be installed using ANSI Z359.1 approved connectors (i.e.carabineers or anchor pads/straps), to an anchor point capable of supporting5,000 lbs. The attachment point of the SRL shall be at the dorsal dee-ring of

the harness. Users of SRL’s shall not connect the snap hook of their lanyardto the snap hook of a SRL. SRL’s should be used when the potential free falldistance is greater than 6 feet, or when the height of the walking/workingsurface is less than 12 feet from ground level. ( A shorter lanyard may also beused in the above situation.)

Inspection

Personal fall arrest systems shall be inspected prior to each use for wear, damage,or other deterioration, and defective components shall be removed from service. Allsystems and components involved in a fall shall be removed from service, tagged

“Out of Service” and turned into the SH&E Department.

Fall Protection shall have documented inspections on an Offshore Tool HouseChecklist prior to going offshore by a Competent Person. While offshore, fallprotection documented inspections shall be performed utilizing the Offshore ToolHouse Checklist monthly. For onshore locations, a Competent Person will performdocumented inspections prior to fall protection being issued and quarterly utilizingthe inspection checklist in Attachment 2 unless a more stringent documentedinspection is being utilized per tool room requirements.



J8.7

Maintenance and Storage

Fall protection equipment should be cleaned with cool soapy water, and rinsed withclear cool water. Equipment should be hung by the dee-ring to dry. Equipment shallnot be force-dried.

When not in use, equipment should be hung in a clean, dry area by the dee-ring.

Work Practices

Hazard Analysis

When a job task will create the possibility or potential for a fall the First LineSupervision should consider methods in which to address fall hazards in thefollowing order:

Fall Elimination

Eliminate the need to perform elevated work.

Fall Prevention

Fall prevention may be accomplished by the use of manlifts, scaffolds, ortemporary access ways with hand-rails, midrails, and toe boards.

Fall Protection

Use of proper fall arrest systems such as: full body harnesses, “y”lanyards, lifelines (both vertical and horizontal), retractable lifelines, etc.This equipment shall be made available to employees.

Note: Where conventional fall protection systems can not be implemented, the First

Line Supervision must classify this area as a controlled access zones. Supervisionshall identify designate those employees who are authorized to work within this zoneand designate a safety monitoring system. The safety monitoring system will beassigned to:

Recognize fall hazards

Warn employees if they are unaware of a fall hazard or is acting in an unsafemanner.

Be on same working surface and in visual sight.

Stay close enough for verbal communication

Not having other assignments that would take monitors attention from themonitoring function.



J8.8

Climbing

Tools and other materials shall not be carried by hand while climbing aladder.

Special precautions shall be taken when wet or other slippery conditionsexist.

Vertical beams shall not be climbed.

When climbing stairs, one hand shall be free to use the handrails.

Climbing on equipment such as pumps, exchangers, valve hand wheels,transformers, electric motors, hand rails, structures, or any other facilities notdesigned for climbing should be avoided. Climbing on conduit, cable trays, orother equipment not capable of supporting the weight of a person isprohibited.

Climbing on a ladder while another person is above or on the same section ofthe ladder is prohibited.

When working from a ladder, the ladder shall be secure at both ends and fallprotection shall be utilized above 6’ or in close proximity of a handrail wherethere is potential for an individual to fall over the handrail.

When climbing a ladder over 24 feet in height, fall protection tie off systemshall be utilized.

Adequate support should be available when walking in pipe bands to providea safe walking/working surface without causing damage to the piping,insulation or heat tracing.

Personal fall arrest systems must be used and anchored to a designatedanchor point when using, traveling on or working from mobile work platformssuch as:

Spiders,

Manlifts,

Scissor-lifts and/or

Crane baskets

Working over Water

When offshore working over water, where there are potential fall hazards,such as and not limited to the following:

o Plus 10 level when no guardrails are present,



J8.9

o Boat landing or

o Working over the side of a platform

A fall arrest system and a USCG approved life jacket / work vest shall utilized.

The fall arrest system shall be secured to proper anchor points located above

the worker.

Scaffold Erection

During scaffold erection, a fall arrest system will be utilized. The preferredmethod of tie-off shall be a structural member anchor point with an attachedSRL. In those cases, where an anchor point is unavailable above thescaffolding location and a SRL can not be utilized, scaffold builders shall tieoff to the vertical scaffold member rosettes.

Lanyards and Anchor Points

When not in use, lanyards should be attached back to the harness in such away as to not present a tripping hazard. The ends of lanyards should not bedragged on the ground.

Lanyards should be attached to the best possible anchor point (one that iscapable of supporting the forces of a fall), directly above the employee. Theanchor point should not be chosen if connecting to it presents a fall hazard.Information concerning anchor point requirements should be obtained fromthe client representative.

Anchor points shall be at least as high as the attachment point of the harnessin order to comply with 1926 M.

Lanyards shall be protected from cuts or abrasions. When a direct snap hookto anchorage connection cannot be achieved, an anchorage connector shouldbe used.

Snap hooks should always be fixed to an anchorage as to not allow a sideload on the hook.

Knots shall not be tied in lanyards.

The snap hooks of a “y” lanyard shall not be connected to each other.Lanyard snap hooks can not be connected back to the lanyard webbingunless a lanyard is designed with tie-back features.

Same Level Fall Protection

Good housekeeping is the key to the prevention of same level falls



J8.10

Usable and waste material shall be stored out of walking / working surfacesand shall not congest a work area

Surfaces shall be kept free of slipping hazards

Floor holes and openings shall be covered as not to create tripping hazards.Hole covers must be capable of supporting at least twice the maximum loadthat may be imposed on them. Covers must be secured and marked “HOLE”

or “COVER”.

Materials shall not be allowed to collect around work tables, desks, threadingmachines, etc.

Leading Edges

Protection

Adequate barricades must be erected in such a manner as to restrict accessto the area by all personnel except those required to work in the area. The

barricade shall have a toprail that is 42 inches plus or minus 3 inches abovethe walking/working level. The midrail shall be installed at a height midwaybetween the top and the walking/working level. In some situations a toeboardmay be required to be installed.

Access

In areas where the leading edge is left unguarded, use control lines to limitaccess to the leading edge.

This control line must extend along the entire length of the exposed edge

and be approximately parallel to it.

Must be sufficient strength to support a person who may inadvertentlycome into contact with it and have a minimum breaking strength of 200pounds.

Be no less than 10 feet or no more than 15 feet from the edge.

Rigged in such a way that its lowest point is no less than 39 inches fromthe walking surface and no more than 45 inches at its highest point.

Safety Monitor

When control lines are not utilized to protect leading edges a safety monitorshall be posted.

Safety Monitor shall be competent to recognize fall hazards.

Safety Monitor shall warn the employee when it appears that theemployee is unaware of a fall hazard or is acting in an unsafe manner.



J8.11

Safety Monitor shall be on the same walking/working level and withinvisual sight distance of the employee being monitored.

Safety Monitor shall be close enough to communicate orally with theemployee.

Safety Monitor shall not have other responsibilities, which could take themonitor’s attention from the monitoring function.

Each employee working in a controlled access zone shall be directed tocomply promptly will fall hazard warnings from safety monitors.

Safety monitors will be designed by the First Line Supervisors ordesignees.

Open Holes

All open holes shall be covered or barricaded. Barricade must be able to support200 lbs. pushing force.

Any time a cover will be utilized for an open hole, it shall be of adequate sizeand strength, be secured to prevent displacement and be identified as acover.

When using wire rope for barricading, it shall have a diameter of at least 3/8”wire rope and should be covered with high visibility orange mesh hurricanefencing. The barricade shall have a toprail that is 42 inches plus or minus 3inches above the walking/working level. The midrail shall be installed at a

height midway between the top and the walking/working level. In somesituations a toeboard maybe required to be installed.

Barricades shall be in place, prior to anyone creating an open hole.Barricades need to be setup on all unprotected sides or edges of the openhole and shall provide enough room to perform work safely.

Anytime anyone is inside the barricade, they must wear and utilize fallprotection. This individual will be tied off 100% of the time while inside thebarricade.

Anytime an open hole is not barricaded, someone shall be present at all timesuntil the hole is either covered or barricaded.

Fall Protection Plan

A fall protection plan shall be developed anytime leading edge work is beingperformed and it can be demonstrated that it is infeasible or it creates a greaterhazard to use conventional fall protection equipment. The plan shall be developed



J8.12

and approved by a qualified person. This plan shall be implemented and maintainedonsite per section 1926.502(K).

Rescue Plan

(see Attachment 1)

Post Rescue Techniques

After a person has been promptly rescued the following post rescue techniquesneed to be followed:

Communicate with the person and establish the level of consciousness andevaluate injuries.

Continuously monitor the person.

If emergency medical personnel are onsite, ensure they are contacted toassist in any medical needs.

Ensure the person remains in a sitting or kneeling position for approximately45 – 60 minutes following the rescue.

All employees need to be medically evaluated at a preferred medical clinicfollowing a fall, even if there appears to be no injury to the individual.

Training

Any employee who might be exposed to fall hazards shall be trained by a competentperson in the following areas:

The nature of fall hazards in the work area.

The correct procedures for erecting, maintaining, disassembling, andinspecting the fall protection systems to be used.

The use, operation and inspection of personal fall arrest systems and rescueequipment.

The standards contained in subpart M.

All employees identified as Supervisors shall be trained to the Fall ProtectionCompetent Person level.

Certification of Training

Fall protection training shall be verified by preparing a written certificationrecord.



J8.13

The record shall contain the name or other identity of the employee trained,the date, and the signature of the person who conducted the training.

Retraining

Retraining is necessary when it is believed that an employee has notunderstood the training requirements.

Retraining is necessary when changes in the work place render previoustraining obsolete.

Retraining is necessary when changes or additions in the types of fallprotection equipment to be used render previous training obsolete.

This fall protection policy was written as a minimum requirement to meet the criteriaof 29 CFR 1926 Subpart M. Compliance with this policy is in the best interest ofMoreno Group LLC and Subsidiaries and its clients. Any efforts to exceed therequirements of this policy are encouraged, and in some cases mandatory as

required by Moreno Group LLC and Subsidiaries’ clients.

Any incident involving fall protection shall be reported and investigated per MorenoGroup LLC and Subsidiaries policies.





J8.14

Attachment 1





J8.14.a.1

Rescue Plan

Fall Protection Rescue Procedure

This procedure was written as the standard rescue procedure for a fallenMoreno Group LLC and Subsidiaries employee. Deviation from this proceduremay at times be necessary due to the nature of the work environment and

other conditions present.

It is recommended that employees practice this procedure in a controlledenvironment at regular intervals before being in an actual situation.

Any questions regarding this procedure should be directed to the MorenoGroup LLC and Subsidiaries SH&E Department.

Responsibilities and Procedures

It is the responsibility of the Moreno Group LLC and Subsidiaries

Management to insure that all employees are trained in the proper use of therescue equipment to be used by Moreno Group LLC and Subsidiaries.

It is the responsibility of Moreno Group LLC and Subsidiaries Management toappropriate the funds to insure that the necessary rescue equipment is madeavailable at each job site.

It is the responsibility of all effected Moreno Group LLC and Subsidiariesemployees to insure that rescue equipment is used only for the purpose ofRESCUE.

Scope

(d) (20), which states that the employer shall provide for the prompt rescue ofemployees in the event of a fall. Due to the nature of the work performed byMoreno Group LLC and Subsidiaries, the company has allowed for the safestand most efficient method of rescue.

Definitions

Aerial Lift - A mobile aerial work platform

Anchorage (anchor point) - A secure point of attachment.

Anchorage Connector - A device used to attach equipment components to ananchor point.

Connector (Carabineer) - A device used to couple parts or components of asystem together.



J8.14.a.2

Remote Hook - A device used to make connection to a fallen worker’s dorsalDee-ring.

Manbasket - A suspended personnel platform (manbaskets), which is triallifted and proof tested for the personnel.

Pole Adapter - A device used to hold a remote hook.

Recovery Pole - An extendable fiberglass pole used to lower a remote hookto the location of attachment of a fallen worker.

Rescue Block and Tackle - The recovery system used to raise a fallenworker.

Guide Lines For Rescue Procedure:

Guide Lines For MSA Rescue Poles

1. Determine the extent of the injury to the fallen worker.

2. Locate an anchor point as directly over the fallen worker as possible.

3. Attach the anchor connector to be used to the anchor point.

4. Attach the top of the rescue block and tackle to the anchor connector.

5. Attach the pole adapter to the end of the recovery pole.

6. Attach the remote hook to the pole adapter.

7. Attach the bottom of the rescue block and tackle to the remote hook.

8. Lower the remote hook to the fallen worker’s Dee -ring. Once engaged,pull in an upward motion to lock the remote hook into place.

9. Begin raising the fallen worker by pulling on the free end of the rope onthe rescue block and tackle. (It may be necessary to cut or disconnect thelanyard from the anchorage.)

10. Once the fallen worker can be physically reached, tie the free end of therope to the nearest structure. (If more than one rescuer is available, this

step can be eliminated.)

11. Pull the fallen worker to safety.

Note : An Aerial Lift or Manbasket may be used to rescue fallen individual if they canbe reached safely and in a timely manner.



J8.14.a.3

Guide Lines For Web Devices Rescue Poles

1. Remove pole and rope from stowage bag.

2. Release hitch in rope at rope block.

3. Loosen pole lock nut (above label).

4. Pull slack in rope through blocks and extend pole to desired length (up to15').

5. Tighten pole lock nut.

6. Unhook carabineer from pole handle strap.

7. Secure anchor sling (choke or basket) around a suitable anchor point andattach carabineer/block. The anchor point should be overhead anddirectly above the victim, if possible.

8. As the pole is extended, hold the pole and rope so that the rescue hookdoes not release prematurely. If the hook should inadvertently release,reattach by opening the hook latch and place in bracket.

9. With a firm grip on the pole and rope (4 parts), extend the hook to thevictim's rear dorsal D-Ring and engage by pulling back on the pole. Laythe pole aside in a secure place.

10. With the rescue hook and anchor sling attached, begin hoisting the victim.CAUTION, it may take more than one rescuer to hoist the victim. As an

added precaution, the rope should be "tailed" around a suitable tie-offpoint.

11. After the victim has been rescued, remove the block and tackle.

Note : An Aerial Lift or Manbasket may be used to rescue fallen individual if they canbe reached safely and in a timely manner.





J8.14.a.4

Overview of Job: ____________________________________________________________________

Quantity Equipment Needed Inspected By

MSA Rescue Pole, Block / Tackle,

Remote Hook, Pole Adapter ___________________________________

Web Device Rescue System ___________________________________

Ladder (See Note) ___________________________________

Stand by Spider (See Note) ___________________________________

Aerial Lift (See Note)

Anchor Connector for Rescue System

NOTE: Ladder to remain in immediate work area and only to be used for rescue.

NOTE: If aerial lift is being used for rescue, aerial lift needs to be in immediate work area.

NOTE: If Spider is to be used for rescue, it needs to be setup in immediate work area.

Steps Assigned To

1

2

3

4

5

6

7

8

9

10

Steps Assigned To

1

2

3

4

5

6

7

8

9

Steps Assigned To

1

2

3

4

When job is complete, all equipment used in the fall needs to be taken out of service

and turned into the SH&E Department.

Make sure man is secure in basket and has adequate fall protection. (It may be necessary to cut or disconnect

the original lanyard from the anchorage).

Lower the fallen worker to safety.

Detailed Steps of Rescue Plan for MSA Rescue System

Fall Rescue Plan

Spider Recue

Determine the extent of injury to the fallen worker.

Move spider under the injured worked and place fallen worker in the spider.

Secure anchor sling (choke or basket) around a suitable anchor point and attach caribiner / block. The anchor

point should be overhead and directly above the fallen worker.

As the pole is extended, hold the pole and rope so the at the rescue hook does not release prematurely. If the

hook should inadvertently release, reattach by opening the hook latch and place in bracket.

With a firm grip on the pole and rope, extend the hook to the victim's D-ring and engage by pulling back on the

pole. Lay the pole aside in a secure place.

With the rescue hook and anchor sling atached, begin hoisting the victim. It may take more than one rescuer

to hoist the victim. As an added precaution, the rope should be tied off to a suitable anchor point.

Loosen pole lock nut (above label).

Pull slack in rope through blocks and extend pole to desired length (up to 15 ")

Tighten pole lock nut. Unhook carabiner from pole handle strap.

Detailed Steps of Rescue Plan for Web Device Rescue System


Remove pole and rope from stowage bag. Release hitch in rope at rope block.

Lower the remote hook to the fallen worker's D-ring. Once engaged, pull in an upward motion to lock the

remote hook into place.

Begin raising the fallen worker by pulling on the free end of the rope on the block and tackle.

Once the fallen worker can be physically reached, tie the free end of the rope to the nearest structure. (If more

than one worker is involved in the process, this step can be eliminated by havng the other worker hold tension

on the rope while the fallen worker is pulled to safety.

Attach the top of the recue block and tackle to the anchor connector.

Attach the pole adapter to the end of the recovery pole.

Attach the remote hook to the pole adapter.

Attach the bottom of the rescue block and tacke to the remote hook.

Attach the anchor connector to be used to the anchor point.

Locate an anchor point as directly above the fallen worker as possible.


Rescue Team





J8.15

Attachment 2





J8.15.a.1

Onshore Fall Protection Quarterly Inspection by Competent Person

NameDII Harness /

Lanyard #Condition (see below)

InspectionDate

Supervisor Competent Person

Inspection Criteria: Web Device product with legible identification numbers? Webbing: No cuts, fraying, burns, stitching condition, chemical exposure?

Buckles: Deformed, corrosion, rust, chemical exposure, stitching? Snaps: Gates work freely, double lock works, deformed, corrosion, rust, chemical exposure?

In Service Date less than 5 years?







Fire Prevention PlanPage: 1 of 7Original: 01/01/2001Revised: 05/01/2008

J9.1

Fire Prevention Plan

Purpose

The purpose of this plan is to establish the minimum requirements for fire preventionand protection at Moreno Group LLC and Subsidiaries facilities. While minimizingpersonal injury, illness, or property damage resulting from fires and / or the productsof combustion.

Scope

The scope of this procedure establishes minimum requirements for fire preventionand protection at the Moreno Group LLC and Subsidiaries facilities. This procedureapplies to all Moreno Group LLC and Subsidiaries employees, clients, sub-contractors and vendors / visitors. For more information on this procedure contactthe Moreno Group LLC and Subsidiaries’ Safety, Health and EnvironmentalDepartment.

Responsibilities


Implementing this procedure.

Evaluating the fire hazards and safeguards at the Moreno Group LLC andSubsidiaries facilities. Re-evaluating the fire hazards and safeguardsannually or when changes may affect the hazards.

Ensuring that personnel are informed of fire prevention and protectionrequirements.

Monitoring compliance with this procedure.

Assuring that plot plans are maintained and available noting the location of

fire hazards, fire suppression equipment and isolation points for all utilities.

Making arrangements with outside sources (such as the local FireDepartment) for assistance during emergency response situations.





J9.2

Conferring with other facility personnel as to fire hazards and safeguards on a job.

Communicating to personnel reporting to them as to fire hazards andsafeguards on a job.

Monitoring jobs and work areas for compliance with this procedure.

Initiating the use of additional precautions as specified in permits or SafeOperating Procedures (SOP’s).



Conferring with supervision as to the fire hazards and safeguards associatedwith the job.

Advising supervision of any suggestions to improve the Fire Prevention andProtection Procedure.

Definitions

Approved - accepted, certified, listed, labeled or otherwise determined to be safe bya nationally recognized testing laboratory.

Combustible Liquids - any liquid having a flashpoint at or above 100 0F (37.80C).Combustible liquids shall be divided into two classes as follows:

Class II Liquids - shall include those with flashpoints at or above 1000F(37.8

0C) and below 140

0F (60

0C), except any mixture having components

with flashpoints of 2000F (93.30C) or higher, the volume of which make up99 percent or more of the total volume of the mixture.

Class III Liquids - shall include those with flashpoints at or above 1400F

(600C). Class III liquids are sub-divided into two subclasses:

Class IIIA Liquids shall include those with flashpoints at or above 140 0F(60

0C) and below 200

0F (93.3

0C), except any mixture having components

with flashpoints of 2000F (93.3

0C), or higher, the total volume of which

make up 99 percent or more of the total volume of the mixture.

Class IIIB Liquids shall include those with flashpoints at or above 2000F

(93.30C).

Extinguisher Classification - the letter classification given an extinguisher todesignate the class or classes of fire on which an extinguisher will be effective.



J9.3

Fire Brigade (private fire department, industrial fire department) – an organizedgroup of employees who are knowledgeable, trained and skilled in at least basic firefighting operations.

Fixed Extinguishing System - a permanently installed system that either extinguishesor controls a fire at the location of the system.

Flammable Liquids (Class I) - any liquid having a flashpoint below 1000F (37.80C).

Incipient Stage Fire - a fire which is in the initial or beginning stage and which can becontrolled or extinguished by portable fire extinguishers.

Inspection - a visual check of fire protection systems and equipment to ensure thatthey are in place, charged and ready for use in the event of a fire.

Vapor Density - the weight of a vapor or gas compared to the weight of an equalvolume of air. Materials lighter than air have vapor densities less than 1.0(acetylene, methane, hydrogen). Materials heavier than air (propane, hydrogen

sulfide, ethane, chlorine) have vapor densities greater than 1.0. Lighter vapors andgases will tend to rise while heavier vapors are likely to concentrate in low places.

Requirements

A current plot plan of the fire extinguishers noting the location evaluation and of allfire extinguisher shall be maintained.

Fire drills will be conducted at least twice a year. The results of these drills will bedocumented and critiqued. Drawings of emergency evaluation routes shall beposted and maintained within all office buildings.

Good housekeeping practices shall be implemented at all work sites.

Combustible materials, such as oil soaked rags, wastes and shavings shall be keptin metal containers with lids or in an area far away from any other flammablematerials. All containers should be emptied at regular intervals.

Paper and other combustible materials shall not be allowed to accumulate.Weeds and other combustible vegetation should be maintained near and aroundCompany property.

Flammable liquids such as gasoline, kerosene, paint and lacquer thinner, etc. shallnot be used for cleaning purposes unless approved methods are employed for theirsafe use

All solvents and flammable liquids shall be kept in approved and accurately labeledcontainers per Hazard Communication program.

When pouring or pumping gasoline or other highly volatile solvents from onecontainer to another, bonding shall be maintained between the receiving and pouring



J9.4

containers at all times to eliminate the possibility of static sparks when refueling. Any motorized equipment must be turned off before it is refueled.

Employees shall not smoke in close proximity (i.e. within 35 feet) to flammableliquids or gases either on Company property or elsewhere.

In general, open burning is not recommended and may be done only where

permitted by law. During winter months, no fires are allowed on the job site forpersonal warmth unless approved by facility management.

Bulk storage areas for flammable fuels and liquids must be located at least 20 feetfrom any building and free from weeds, debris and other combustible materials.

The grading around a flammable liquid storage area should divert possible spillsaway from buildings or other exposures. A curb or dike may also be required.

Small quantities of flammable liquids used on the job must be stored in UL Approvedand properly labeled safety cans.

NO SMOKING signs must be posted at the perimeter of bulk fuel storage areas, re-fueling areas and locations where flammable liquids are transferred or used.

Inside storage of flammable and combustible liquids must be done using approvedstorage cabinets and must comply with OSHA Standard 1910.106 – Flammable andCombustible Liquids or other applicable regulations.

Portable Fire Extinguishers

Only fire extinguishers approved by Factory Mutual (FM), Underwriters Lab (UL), the

U.S. Coast Guard (USCG) or other nationally recognized testing lab (NRTL) shall beused and they must be readily and safely accessible at all times. No extinguishersusing carbon tetrachloride or chlorobromoethane extinguishing agents are permitted.

Portable fire extinguishers must be maintained in fully charged and operablecondition at all times.

Fire extinguishers should be placed so that the maximum travel distances, unlessthere are extremely hazardous conditions, do not exceed 75 feet for Class Aextinguishers or 50 feet for Class B.

Portable fire extinguishers must be placed at strategic locations throughout thefacility. At least one portable fire extinguisher with a minimum rating of 2A should beprovided for each 3,000 square feet of protected area.

One or more portable fire extinguishers with a minimum rating of 2A should belocated adjacent to any stairway.

At least one portable fire extinguisher with a minimum rating of 20B should be keptreadily accessible to areas where flammable gases or liquids are stored or handled.



J9.5

Fire extinguishers must be provided and maintained on all owned or leased mobileequipment.

Fire extinguishers shall be visually inspected monthly and documented.

Inspection and Maintenance

Fire Extinguishers

All portable fire extinguishers must be hydrostatically tested at appropriate intervals.Portable fire extinguishers must have an annual maintenance check. The annualmaintenance date should be recorded and the record retained for one year after thelast entry or the life of the extinguisher, whichever is less. Only qualified personsshall make these inspections.

Inspection of Fixed and Portable Fire Suppression Equipment

Monthly, documented inspections should be made of all portable fire suppression

equipment to ensure the equipment is accessible and ready for immediate use.

All portable fire suppression equipment should be given a thorough documentedmaintenance check by qualified service personnel at least annually.

Use

Detecting and extinguishing a fire in its incipient stage is critical. Failure to do somay result in a much larger, more serious fire with a greater potential for personnelinjuries and property damage. All employees responding to fires will be trained in thecare, use and limitations of portable fire extinguishers. They will be expected to

report and respond to fires in the incipient stages in their areas. Wheneverpossible, fire fighting will be done using hand held portable fire extinguishers. Firesbeyond the incipient stage will be handled by the local fire department.

General Guidelines for Responding to Small Fires in the Incipient Stages are asFollows:

Immediately call for help. Alert personnel in the area. Never try to extinguish a firewithout first summoning help.

If it is safe to do so, try to extinguish the fire using portable fire extinguishers. If it is

not practical or possible, keep personnel out of the area until help arrives.

NOTE: If a fire is being fueled by a flammable liquid or gas, shut off the fuel supplybefore trying to extinguish the fire. Failure to do so might result in the spread of agas or vapor cloud, which would travel a considerable distance before reaching asource of ignition.

Try to limit the spread of fire by cooling or removing adjacent flammable orcombustible materials.



J9.6

Direct emergency response personnel to the area and assist them to the extent ofyour training.

Extinguishing Methods and Agents include the following:

Class "A" Fires (Cloth, wood, paper, etc.). Water is the best-extinguishing agent forClass "A" fires. Dry chemical extinguishers containing an ABC multi-purpose agent

will also put out Class "A" fires.

Class "B" Fires (Flammable and Combustible Liquids and Gases). ABC or BC drychemical is the best agent for Class “B” fires. CO2 can be used in some cases butmay be ineffective in outside windy locations. Foam extinguishes may be effectiveon small spill or pools fires of flammable or combustible liquids.

Fires involving flammable gases should not be extinguished until the fuel feeding thefire is shut off. Failure to do so may result in a flammable gas or vapor cloudtraveling a considerable distance to a source of ignition. Water spray and fog can beused to cool adjacent equipment and protect personnel. Once the fuel has been shut

off, any remaining fire can be extinguished using a water spray or fog.

Class "C" fires involve energized electrical equipment. Only portable fireextinguishers containing a nonconductive fire extinguishing agent such as drychemical, carbon dioxide or Halon should be used. The products of combustion ofelectrical insulating materials are usually very toxic and should not be inhaled.

When responding to an electrical fire, every reasonable effort should be made toshut off the electrical supply to the circuit or equipment. If unable to shut off theelectrical supply, call an electrician to do so. Once the electrical supply has beenturned off, it is safe to use water based extinguishing agents on the fire.

Class “D” fires involve burning metals such as magnesium and only Class Dextinguishers that contain dry powder should be used.

Carbon dioxide displaces oxygen and should not be used where the operator mustenter very confined spaces or enclosures without self contained breathingequipment. Likewise, high concentrations of Halon 1211 can be harmful if inhaled.

Hot Work Permits for work in areas identified as fire potential hazards must beobtained from facility management or designee.

Employee Alarm Systems

The employee alarm system / PA system shall provide warning for necessaryemergency as called for in the action Emergency Preparedness Plan , or for reactiontime for safe escape of employees from the workplace or the immediate work areaor both.

The employee alarm shall be capable of being perceived above ambient noise orlight levels by all employees in the affected portions of the workplace.



J9.7

The employee alarm shall be distinctive and recognizable as a signal to evacuate thework area or to perform actions designated under the emergency action plan.

Moreno Group LLC and Subsidiaries’ Management or designee shall explain to eachemployee the preferred means of reporting emergencies, such as manual pull boxalarms, public address systems, radio or telephones.

Training

All employees upon assignment to their initial assignment shall receive training toeducate them on the general principles of fire extinguisher use and hazards involvedin incipient stage fire fighting.

Employees shall attend an annual refresher training on the above mentioned topics.

Training Records shall contain the following:

– Name of employee

– Date of Training

– Signature of Trainer







Forklift ProgramPage: 1 of 8Original: 01/01/2001

Revised: 10 /01/2009

J10.1

Forklift Program

Purpose

The purpose of this procedure is intended to promote the safe operation of forklifttrucks in accordance with 29 CFR 1910.178.

Scope

Moreno Group LLC and Subsidiaries’ policy requires that all personnel operatingand/or performing maintenance of forklift trucks shall be properly trained in forklifttruck operations.

Responsibilities



Evaluating mobile equipment needs for the facility / site, preparing detailedpurchase / rental specifications and providing sufficient equipment to supportthe needs of Moreno Group LLC and Subsidiaries.


Assuring that equipment operators are properly trained and qualified tooperate specific machines.

Ensuring that no modifications or additions are made to equipment withoutthe manufacturer’s written approval.

Ensuring that all accident investigations, significant incidents, propertydamage reports, and general information regarding mobile / motorized

equipment is communicated to applicable employees.

Informing all Contractors of this procedure during the project meeting andensure the Contractor follows the requirements of this procedure.





J10.2

Conferring with personnel reporting to them as to the hazards of specific jobsand the forklift to be used.

Assuring that equipment is inspected, operated and maintained in accordancewith this procedure and the manufacturer’s recommendations.

Assuring that only trained, authorized and physically fit personnel operate and

maintain equipment.




Remaining alert and not operating equipment if mentally or physicallyimpaired. Consulting with the supervisor if taking either over-the-counter orprescription medication.


Surveying the work areas for hazards and erecting barricades as necessary.

Wearing seat belts while operating forklifts, if equipped.

Obeying all traffic rules including speed limits, signals and warning signs.


Reading and being familiar with the manual for the equipment being operatedand operating the equipment as intended by the manufacturer.



Notifying supervision of any significant incidents, property damage or nearmisses with regards to mobile / motorized equipment.

The Personnel Working Around Equipment are responsible for:







J10.3

Remaining alert and responding as necessary when an equipment back-up warningdevice is heard.


Definitions

Unattended Forklift Truck - When the operator is 25 feet or more away from theforklift truck which remains in their view or whenever the operator leaves the vehicleand it is not in their view.

Operator - An individual who has successfully completed a Forklift Truck SafetyTraining Course.

Approved Truck or Forklift Truck - Truck that is lifted or approved for Fire Safetypurposes for the intended use by nationally recognized testing laboratory, usingnationally recognized testing standards.

Requirements

Approved trucks shall bear a label or some other identifying mark indicating approvalby the testing laboratory. Capacity of the forklift will be stenciled in a visible location.This stencil is in addition to the manufacturer’s label.

Modification and additions, which affect the capacity and safe operation of the forklifttruck, shall not be performed without the manufacturer’s prior written approval.Capacity, operation, and maintenance instruction plates, tags or decals shall bechanged accordingly.

The forklift truck shall not be equipped with a front-end attachments other than thefactory installed attachments. The truck shall be marked to identify the attachmentand show the approximate weight of the truck and attachment combination atmaximum elevation with the load laterally centered.

The forklift truck name plate(s) markings shall be in place and legible.

Only trained authorized operators who have successfully completed the ForkliftTruck Safety Training may operate forklift trucks.

Safety Checklist

At the beginning of each day , the “Daily Forklift Checklist” shall be completed priorto operating the forklift truck (see attachment 1).

When a deficiency(ies) is noted during the inspection, conduct the following:

Repair Deficiency(ies) if authorized to perform maintenance.

Explain Deficiency(ies) in Remarks.



J10.4

Remove forklift truck from service, if deficiency(ies) cannot be repaired.

Place a completed White “Do Not Operate” tag on the steering wheel.

Submit completed checklist to supervisor for handling.

Safe Operation

The driver shall be seated at all times with the seat belt fastened. Arms and legsshall remain within the confines of the forklift truck during operation.

The operator shall not allow anyone to ride or stand on the forklift truck. Theoperator shall not approach an object while an individual is standing in front of anobject.

All traffic regulations shall be observed (i.e. posted speed limits, yielding topedestrians.) The operator shall maintain a safe following distance from the vehiclein front of the forklift truck. This distance is approximately three truck lengths. The

forklift operator shall not pass other vehicles traveling in the same direction.

Under all travel conditions the truck should be operated at a speed that will permitthe operator the ability to stop the forklift truck in a safe manner.

When negotiating turns the operator shall reduce the forklift truck’s speed to a safelevel.

The operator shall maintain control of the truck at all times. Horseplay or stuntdriving is prohibited.

The operator shall slow down and sound the horn at cross aisles and other locationswhere the operator’s vision is obstructed. If the load is obstructing the operator’sforward vision, the operator shall travel with the load trailing the forklift truck. Theoperator shall look in the direction and keep a clear path of their travel.

The operator shall slow down when approaching wet or slippery areas.

The operator shall maintain a safe distance from the edge of ramps or platformswhile on any elevated dock or platform or freight car.

Forklift trucks shall not be used to open or close freight doors.

To minimize the possibility of a load or part of it from falling rearward, if this potentialexists, a load backrest extension shall be used.

The parking brake shall be set at all times when the operator is not occupying thedriver’s seat. The operator shall ensure the brake is holding the truck, in an idlegear, prior to dismounting the forklift truck.



J10.5

When the unattended forklift truck is left, load-engaging means shall be fullylowered, controls shall be neutralized, power shall be shut off, and brakes set. Thewheels shall be blocked if the truck is parked on an incline.

When the forklift truck’s operator is within 25 feet and still in view of the forklift truck,the load engaging means shall be fully lowered, controls shall be neutralized andbrakes set.

The operator shall not allow anyone to pass or stand under the elevated portion ofthe forklift truck (loaded or unloaded).

The lifting of personnel shall not be conducted unless an approved personnel liftingdevice is attached to the forklift truck.

Grades shall be ascended or descended slowly and when the grade is in excess of10% the loaded truck shall be driven with the load upgrade.

On all grades the load and load engaging means shall be tilted back if applicable,

and raised only enough to clear the road surface.

The operator shall not park or block fire exits or aisles, access to stairways, and/orfire equipment with the forklift truck.

Dockboard shall be properly secured before being driven over. Dockboards orbridgeplates shall be driven over carefully and slowly. The rated capacity shall notbe exceeded.

The operator shall avoid running over loose objects.

Maintenance

Any forklift truck not in a safe operating condition shall be removed from service.

All repairs shall be conducted by authorized personnel.

Any forklift truck that is overheating shall be removed from service until the cause ofthe overheating has been eliminated.

The forklift truck shall be kept in clean condition (i.e. excess oil and grease.)

Forklift trucks in need of repair to the electrical system shall have the batterydisconnected prior to conducting the repair.

Fueling

Fuel tanks shall not be filled while engine is running.

Do not operate forklift trucks with leaks in the fuel system.



J10.6

Loading/Off Loading

Never exceed the allowable weight and load centers of the forklift truck. Theallowable limits are indicated on the forklift truck nameplate.

Only stable or safely arranged loads shall be handled. Exercise caution whenhandling off-center loads which cannot be centered. Long or high, including multiple

-tiered loads, which may affect capacity or stability, shall be adjusted.

No load that is not designed (must have two closed channel to receive the forks) tobe lifted by a forklift.

The engaging means shall be placed under load, the forks shall extend past theload. The mast shall be carefully tilted backward to stabilize the load. Use extremecare while tilting the load forward or backwards, especially multiple-tiered loads.

Elevating shall be prohibited while a load is tilted forward, except to pick up the load.

Tilting forward while a load is elevated is prohibited except when the load is in adeposit position over a rack or stack.

When stacking or tiering, use only enough backward tilt to stabilize the load.

No loading or unloading of equipment and/or material is allowed after normalworking hours without Management's approval.

Delivery drivers shall be placed within the designated safe area during the loadingand offloading of their vehicles / trailers. Trailers that are not attached to a vehicleshall be chocked prior to loading or offloading of the trailer.

Certification of Training

Upon completion of a Forklift Training (written and hands on examination), theinstructor shall certify employees by preparing a written certification record byplacing the individual’s name on the company’s approved Forklift OperatorLog.

The record shall contain the name or other identity of the employee trained,the date of the training (classroom and hands on evaluation) and the

signature of the person who conducted the training.

Retraining

An evaluation of each forklift operator’s performance shall be conducted atleast once every 3 years

Retraining will be preformed if the forklift operator is involved in an incident(i.e. Near Miss, Property Damage, etc.) involving the use of a forklift.



J10.7

Retraining is necessary when it is believed that an employee has notunderstood the training requirements or has been observed or evaluatedoperating a forklift in an unsafe manner.

Retraining is necessary when changes in the work place render previoustraining obsolete.

Retraining is necessary when changes, additions in the types of equipment ordifferent type of forklift to be used render previous training obsolete.





J10.8

Attachment 1





Moreno Group LLC and SubsidiariesForklift Checklist

J10.8.a.1

DATE:

OPERATOR: TRUCK #

VISUAL CHECKS:

N/A OK

NEEDS

REPAIR N/A OK

NEEDS

REPAIR

ENGINE OIL LEVEL HORN

FUEL LEVEL STEERING

RADIATOR LEVEL SERVICE BRAKES

TRANSMISSION OIL LEVEL PARKING BRAKES

HYDRAULIC OIL LEVEL ENGINE OIL PRESSURE

BATTERY ELECTROLYTE LEVEL TILT CONTROLS

OVERHEAD/ENGINE GUARDING IN PLACE LIFT ASSEMBLY CONTROLS

TIRE CONDITIONS DRIVE TRANSMISSION

CONTROLS

NAME PLATE LEGIBLE ATTACHMENT OPERATIONAL

FREE OF LINT, EXCESS OIL AND GREASE HEAD/TAIL LIGHTS

SEATBELT CONDITION (NO CUTS OR TEARS) AMMETER OPERATING

HYRAULIC LEAKS (CYLINDER, HOSES,VALVES, ETC.

WARNING LIGHTS/SIGNALS

BACK UP ALARM FIRE EXTINGUISHER

1. Repair Deficiency(ies) if authorized to perform maintenance.2. Explain deficiency(ies) in REMARKS.

3. Remove forklift from service4. Place a completed white “DO NOT USE” tag on the steering wheel. 5. Submit checklist to supervisor for handling.6. Was a Work Order completed and turned in on deficiency(ies)? Yes No

REMARKS:





Moreno Group LLC and SubsidiariesPropane / Natural Gas Powered

Forklift Checklist

J10.8.a.2

DATE:

OPERATOR: TRUCK #

VISUAL CHECKS:

N/A OKNEEDSREPAIR N/A OK

NEEDSREPAIR

ENGINE OIL LEVEL HORN

FUEL LEVEL STEERING

RADIATOR LEVEL SERVICE BRAKES

TRANSMISSION OIL LEVEL PARKING BRAKES

HYDRAULIC OIL LEVEL ENGINE OIL PRESSURE

BATTERY ELECTROLYTE LEVEL TILT CONTROLS

OVERHEAD/ENGINE GUARDING IN PLACE LIFT ASSEMBLY CONTROLS

TIRE CONDITIONS DRIVE TRANSMISSIONCONTROLS

NAME PLATE LEGIBLE ATTACHMENT OPERATIONAL

FREE OF LINT, EXCESS OIL AND GREASE HEAD/TAIL LIGHTS

SEATBELT CONDITION (NO CUTS OR TEARS) AMMETER OPERATING

HYRAULIC LEAKS (CYLINDER, HOSES,VALVES, ETC.

WARNING LIGHTS/SIGNALS

BACK UP ALARM FIRE EXTINGUISHER

LPG TANK AND LOCATOR PIN CONDITION LPG TANK HOSE CONDITION

HOUR METER ENGINE COOLANT LEVEL

WATER TEMPERATURE GAUGE LIFT CHAINS AND ROLLERS

7. Repair Deficiency(ies) if authorized to perform maintenance.8. Explain deficiency(ies) in REMARKS.9. Remove forklift from service10. Place a completed white “DO NOT USE” tag on the steering wheel. 11. Submit checklist to supervisor for handling.

12. Was a Work Order completed and turned in on deficiency(ies)? Yes NoREMARKS:







Line-Opening / BlindingProcedure


J11.1

Line Opening / Blinding Procedure

Purpose

To minimize the risk of personnel injury, property damage or damage to theenvironment while opening process equipment and piping.

Scope

This policy applies to all Moreno Group LLC and Subsidiaries personnel openingprocess equipment and piping.

Responsibilities

The Facility Manager or Yard Manager / Offshore Manager or Designee isresponsible for ensuring compliance with the requirements of this procedure andholding those individuals accountable for their actions.


Inspecting the work area and the system to be isolated.

Verifying authorized personnel have closed the correct isolation valves,confirming stored energy has been released and confirm that the appropriate

Lockout / Tagout devices have been applied to all isolation systems.

Receiving appropriate permits for line opening or associated activities.

Developing a Job Safety and Environmental Analysis (JSEA) for the task beingperformed. Ensure all employees are aware of all phases of work beingperformed.

Verifying location of line opening or blinding has been marked to communicatethe proper location to open the process equipment or piping.

Obtaining and providing the proper personal protective equipment for the lineopening.

Verify that all work is completed safely and per the JSEA.

Obtaining and providing containment during the line opening procedure.



J11.2

Upon completion of the work, verifying that the work has been left in asafe, clean condition and the authorized personnel have removed theirlockout / tagout devices from the system.


Reviewing, understanding and signing the permit prior to beginning work.If there is any question concerning the SH&E of the plan, all issue(s) mustbe resolved prior to starting work.

Placing their personal locks and tags on all required locations.

Reviewing, approving, signing and following the task’s Job Safety andEnvironmental Analysis (JSEA).

Inspecting all required Personal Protective Equipment, ensuring defective

personal protective equipment is not used and reporting any discrepanciesto the First Line Supervisor.

Identifying the location of the nearest safety shower and eye wash stationand checking its operation.

Treating any line or piece of equipment as full, under pressure orcontaining product. Requiring that the following actions be taken for anybreaking activity:

o Assuring there is a free and clear escape route from the work

location.

o Using required safety equipment.

o Using containment for liquids and solids that may still be in thesystem.

Following completion of the work, cleaning work area, removing theirlocks, and notifying their First Line Supervisor that the work is complete.

Reporting unsafe conditions or plans to deviate from the JSEA.

Definitions

Blank / Blind Flange - the solid plate or “cap” which completely covers the bore ofa pipe, line, etc. The blank / blind must absolutely close the line, pipe, etc., mustbe capable of withstanding the maximum upstream pressure and be fabricatedfrom compatible materials.



J11.3

Double Block and Bleed - two locked and tagged closed valves with a locked andtagged open drain or vent between them.

Energy Isolating Device - a mechanical device that physically prevents thetransmission or release of energy including, but not limited to, the following: A

manually operated electrical circuit breaker, a disconnect switch; a manuallyoperated switch by which the conductors or a circuit can be disconnected from allungrounded supply conductors and, in addition, no pole can be operatedindependently; a slide gate; a slip blind; a line valve; a block; and any similardevice used to block or isolate energy. The term does not include a push button,selector switch or other control circuit type devices.

Equipment Owner - the owner, operator of the equipment.

Slip Blind - a metal disc with a short handle, which is used to block the flow ofmaterial in a pipe. It is to be slipped between two flanges and bolted in place.

Requirements

When performing maintenance or repair to process equipment or piping or whenperforming a confined space entry, the equipment must be isolated from allenergy sources and must be controlled. Isolation is a process of physicallyclosing or disconnecting or both, pipes, lines and energy sources from theequipment where exposure may be present. Isolation may be accomplished byseveral means but not limited to the following:

- Blanking

- Blinding

- Misaligning or removing sections of lines or pipes

- Blocking or disconnecting all mechanical linkages

- Closing a line valve

- Inserting a blocking device to prevent a release of an energysource.

Note: If a valve is leaking, it should not be considered to be an adequate isolationdevice and an alternative isolation method shall be used.

The method of isolation must be selected properly for the energy sourcesassociated with the process or equipment and the job task. An example of thiswould be the use of Double Block and Bleed. The use of Double Block and Bleedduring a confined space entry is prohibited.



J11.4

Preparation of the Flanged Joint for Opening

Determine what product or material has been contained in the processequipment or piping. Obtain a Material Safety Data Sheet (MSDS) to ensure

proper precautions and personal protective equipment is used during thisprocedure.

Verify the exact location(s) where blinding is necessary. These locations shouldbe marked to identify the correct location (i.e. side of the valve) to break the lineand/or blind. Blinds will be installed on the side of the block valve that is mostconsistent with pressure testing requirements.

First Line Supervisor shall have the designated operator demonstrate (i.e.lockout/tagout, gauges, needle valves, etc.) that the process equipment or pipingis properly isolated and stored energy has been released. Once this

demonstration has been conducted the First Line Supervisor shall ensureoperations is ready to release the equipment for this procedure. Verify that theblinds are correctly sized, both in diameter and thickness for the maximumpressure that it could be expected to hold. Blinds must be of the correct materialsof construction and pressure rating. Pressure ratings for blanks and blinds mustbe equal to or greater than the pipe / equipment pressure rating. Nuts and boltsmust also be of the correct materials of construction, temperature rating andtensile strength. Gaskets required for the job must be of the correct size andmaterials of construction. A blind may have a gasket installed on both sides buta minimum of one gasket should be installed on the pressure side of the blind.

Verify that lines and equipment have been depressured and drained. Ensure thatdrain valves are open by using proper rod-out equipment. Note: In thosecircumstances that the system is not able to be verified to be pressure, liquid orgas free, the following personal protective equipment shall be used:

- Hard Hat

- Chemical / Impact Goggles

- Face Shield

- Tyvek Suits

- Gloves

- Steel Toed Shoes

When available a nitrogen purge should be used to purge the hydrocarbon vaporfrom a vessel or line.



J11.5

Inspect the area above, below and adjacent to the work area (at least 35 feet inall directions) for any potential hazards, people, equipment or operations thatcould adversely affect the work to be performed or could be adversely affectedby the work. Take the appropriate precautions (i.e., barricade the area, cover

equipment and cable trays, stop all hot work, etc.)

A Job Safety and Environmental Analysis (JSEA), Lockout / Tagout and theFacility’s Permit systems shall be implemented prior to the beginning of theblinding or line opening procedure.

Breaking of the Flanged Joint

Ensure all employees have the correct Personal Protective Equipment dictatedby the circumstances. When opening flanges suspected to contain toxic gases,self-contained breathing apparatus or supplied air respirator with an egress bottle

is to be worn unless it has been definitely established through testing that notoxic gases are present.

Ensure a containment system (i.e. bucket, drip pan, etc.) is placed underneaththe flange to capture any trapped liquid.

To remove flange bolting, the employee should loosen only one bolt at a timestarting with the bolt down and away from the workers, so any sudden releasewill be directed away from any personnel. Note: Should any trapped liquid orpressure is experienced, the task shall be shut down and the system shall bereevaluated to ensure the system is properly isolated. Remove the entire flangebolting except for a minimum of two (2), then loosen these bolts withoutcompletely removing the nuts, and spread the flanges to install the blind.

Note: When vapors are present and cannot be eliminated, brass equipment (i.e.hammers, wedges, etc.) shall be used to eliminate the potential for sparks to beproduced while opening the process equipment or line.

Installation of Blinds

The flanges should only be open a minimum length of time consistent with thesafe installation of the blind.

Blinds will be installed at the flange closest to the vessel, tank or equipmentunder consideration.

When vessels or process equipment is interconnected in such a way that blindingof each is not possible or practical, the combination is to be considered as onevessel. The combination will be appropriately blinded and prepared as a unit.



J11.6

When it is necessary for personnel to climb onto the tops of fixed-roof storagetanks to install blinds, scaffolding shall be used to minimize the likelihood thatpersonnel might step through a weak spot.

Blinds should be tagged with the location of the blind, the person installing the

blind, and the date the blind was installed.

Upon completion of the job, clean up the work area; notify your First LineSupervisor, so any related permits may be cancelled.





Permit to WorkPage: 1 of 12Original: 01/01/2001

Revised: 10 /01/2006

J12.1

Permit to WorkPurpose

The purpose of a Permit to Work system is to reduce the risk of an incident or exposureto a hazard during simultaneous operations within Dynamic Industries, Inc. facilities.This procedure should assist in the coordination and minimization of hazards associatedwith simultaneous operation within Dynamic Industries, Inc. facilities.

Scope

This procedure outlines provides a permitting system for simultaneous activities withinDynamic Industries, Inc. facilities and outlines responsibilities, requirements andauthorization for this Permit to Work system. Below are examples of Simultaneous

operations covered by this system:

Testing of equipment with hydrocarbons and Hot Work

Sandblasting or Coatings Operations and other craft activities in the sameimmediate area (i.e. same level of platform or module)

Hydrostatic Testing and other craft activities

Coordination of the commissioning of electrical components and the installation,maintenance or servicing of electrical components.

X-ray activities outside designated areas

Note: Confined Space Entries will be performed and conducted in accordance withDynamic Industries, Inc. Confined Space Entry Safe Work Practice.

Responsibilities

The Facility / Site Manager or Designee is responsible for overall programadministration including:

Provide resources to fully implement this program.

The SH&E Department or designee (Authorized Permit to Work Issuer) is responsiblefor:

Assessing the work area a long with the First Line Supervisor to ensureproper controls are in place and a need of a Permit to Work, prior to theissuing of a permit.

Confirm that all isolations are in place, tagged and where appropriate locked

The issuing of a Permit to Work at the jobsite to First Line Supervisors andtheir crew for the covered activity.



J12.2

Discussing and verifying that all requirements are understood by the FirstLine Supervisor and their crew performing the covered work activity.

Closing out of permit with First Line Supervisor

Training additional individuals to issue Permit to Work, if required byManagement

Maintaining a list of Authorized Individuals who can issue Permit to Work

Assess the effectiveness of the Permit to Work system and provideassistance to Facility Management as needed.

The First Line Supervisor is responsible for:

Evaluating the safety aspect of these activities as an integral part of pre-planninga job.

Ensuring all employees reporting to him / her who are involved in these activitiesare properly trained and understand the requirements of this procedure and thehazards and safeguards involved.

Ensuring proper isolation of equipment, if required, is performed beforerequesting a Permit to Work

Notifying the SH&E Representative or designee to request a Permit to Work.

Obtaining a Permit to Work for activities covered under this procedure

Reviewing the conditions of the Permit to Work with their employees involved inthe covered activity.

Monitoring the work for compliance of this procedure

Ensuring the Permit to Work is revoked if conditions change that may createunidentified hazards.

Inspecting the work area when the work is completed and closing out of thepermit.

The Employee involved in hot work activities is responsible for:

Inspecting equipment and the work area before beginning work. This inspectionshould be thorough and any problems should be immediately brought to theattention of the supervisor.

Bringing any questions or concerns about the usage and choice of equipment onthe job to the attention of supervision or the Safety, Health and EnvironmentalDepartment.



J12.3

Following safe practices while performing their covered work activities. Thisincludes:

Practicing good housekeeping

Wearing proper clothing / PPE including any necessary respiratory protection

Reading and following safeguards on Material Safety Data Sheets (MSDS) orproduct labels as applicable

Posting warning signs or barricades as necessary

Using equipment per manufacturer’s instructions

Ensure equipment is properly isolated, tagged and locked out if required.

Following conditions specified on the Permit to Work.

Understanding and following the general and specific requirements outlined inthis procedure.

Signing the Permit to acknowledge acceptance of Permit requirements

Stopping Work and notifying their immediate Supervisor if conditions change withtheir work activities or work environment.

Requirements

This Permit to Work system shall be implemented at Dynamic Industries, Inc. facilityanytime one of the following work activities is performed and can affect or exposeanother work activity that is within its immediate work area.

Abrasive Blasting

Coating operations

Hot Work (only when hydrocarbons is introduced to the system or adjacent tocoatings operations)

Hydrostatic Testing

NDT Activities – X-ray

Testing of Electrical Components

Abrasive Blasting / Coasting Operations

Anytime abrasive blasting / coating operations are being performed next to or adjacentto other operations outside the designated blast area, a Permit to Work shall berequired. The only time a Permit to Work would be required within a designatedblasting area is if another work activity other than painting or blasting was beingperformed.



J12.4

Precautions shall be taken to minimize the affects of this type of operations with others.

Blast screens shall be installed to minimize the affects on other operations prior to thePermit to Work being issued to the First Line Supervisor. Addition to blast screens,firewatch with gas detectors shall be required if hot work is being performed within 35feet radius of the painting operations.

NOTE: Paint brushing operations is exempted from this requirement

Hot work

Hot work activities include welding, open flame cutting, gauging, grinding, mechanicalbuffing or other spark producing activities.

Hot work activities shall require a Permit to Work during the following situations:

Being performed within 35 feet radius of a coatings operations (paint brushingoperations is exempted from this requirement)

Being performed on a platform, module or structure that contains hydrocarbons

within the system whether placed within the system for testing purposes orpermanently maintained within the system.

All precautions shall be taken to minimize the affects of hot work operations with others.

No Hot Work will be allowed within 10 feet radius of any system containinghydrocarbons or coatings activities. Note: Consider the 10 feet radius is a vertical conethat is 10’ in diameter to help determine if any system falls wi thin this requirement.

Slag, sparks or other burning materials shall be prevented from contacting equipmentwhich contains flammable in an area within 35 feet of the work or any level below where

sparks may reach. Metal shields, flame resistant guards or curtain may be used toprevent contact if the equipment cannot be relocated from the work area.

Firewatch shall be required a condition of this Permit to Work. The Firewatch shall havefire extinguishing equipment and a portable gas detection meter readily available and betrained in their use. These individuals shall be on each level of the structure that thehot work can affect.

They shall be familiar with procedures for initiating the emergency evacuation procedurein the event of a fire. They shall only attempt to extinguish a fire when the fire isobviously within the capacity of the equipment available. A fire watch shall be

maintained for 30 minutes after the completion of welding or cutting operations to detectand extinguish smoldering fires.

Note: If the coating operations are completed prior to the welding operations, thefirewatch shall remain 30 minutes after the completion of the painting operations iscompleted. The Permit to Work maybe closed at the completion of either one of theseactivities, which ever is completed first.



J12.5

Hydrostatic Testing

All hydrostatic testing activities performed within Dynamic Industries, Inc. facilities shallrequire a Permit to Work when simultaneous operations are occurring adjacent to thehydrostatic test. Should a hydrostatic test be performed on a platform or any other typeof structure, then the simultaneous activities will be required to be shut down. No

simultaneous activities will be allowed on any platform or structure where hydrostatictesting is being performed. If a system, is being testing affect two levels of the platformor structure, then no activities maybe performed on these levels except for thehydrostatic testing.

All hydrostatic tests shall follow the hydrostatic test procedures outlined by theHydrostatic Test Pack.

Barricades

Precautions shall be taken to ensure that hydrostatic testing is performed safely. The

area surrounding the hydrostatic test shall be cordon off with red “Danger” barricadedtape. The distance in which will be cordon off will be determined by the First LineSupervisor and Issuer of the Permit to Work.

Barricades shall be erected to prevent employees, visitors, equipment and vehicle trafficfrom accidentally entering the hydrostatic testing work area.

No one shall enter the hydrostatic testing area unless is authorized by the First LineSupervisor, has read and understood both the JSEA and Permit to Work.

Anyone entering the barricaded area without authorization shall be asked to

immediately leave the authorized area and the Facility Management or SH&EDepartment shall be notified.

No one shall remove or modify the barricaded area without authorization from the FirstLine Supervisor. Should this activity occur during night time hours, enough lightingshould be present to ensure the barricade is visible.

Warning signs shall be installed on barricades to appropriate communicate to otherswithin the area. The signs shall read “Danger High Pressure Equipment, KEEP AWAY”

Equipment

All equipment used for the hydrostatic testing shall be rated for the appropriate pressureratings for the test procedure including but not limited to existing piping andconnections.

All hoses are to be fully secured with tie-down devices capable of withstanding theforces used in the test. All hoses shall have both safety pins and whip checks installedon them to help prevent the possibility of them parting and whipping freely.



J12.6

All gauges shall be calibrated and applicable for the pressures to be used during thehydrostatic test.

Pressure relief valves on the pump have been tested and capable of handling thepressures needed for the test.

During the Test

Only those individuals directly involved with and who have signed the Permit to Work

shall be allowed in the barricaded area.

Those test involving high pressure, the systems test pressure shall be reached instages, allowing each stage to stabilized, then check for leaks.

Should a leak occur during the test, the test will be STOPPED and the system will bedepressured. Once the system has been fully depressured, employee(s) will be allowedto investigate the reason for and/or correct any issue surrounding the leak.

Communication shall be established between all employees involved with thehydrostatic test procedure. At a minimum, hand signals shall be used to help minimize

miscommunication during this procedure.

Non Destructive Testing (NDT) X-Ray

All NDT X-ray testing performed outside designated areas within Dynamic Industries,Inc. facilities shall require a Permit to Work.

The barricade tape shall meet the requirements within Dynamic Industries, Inc.Barricading procedures. Barricades shall be erected to prevent employees, visitors,equipment and vehicle traffic from accidentally entering the regulated work area. Toutilize cones for barricades the Facility Manager’s approval is required. NDT Company

First Line Supervisor shall be responsible for calculating the safe distance for the publicexposure to this operation. The erecting the barricade shall be erected to the 2 mr/hrtime weight calculation within any hour.

Warning signs shall be installed on barricades to appropriate communicate to others thehazards of this operations. The signage shall have the words “Caution Radiation Area

Authorized Personnel Only” that includes the 3 bladed radiation symbol.

No one shall enter the regulated area unless is authorized by the NDT Company FirstLine Supervisor and has read and understood both the JSEA and Permit to Work.

Anyone entering the barricaded area without authorization shall be asked toimmediately leave the authorized area and the Facility Management or SH&EDepartment shall be notified.

No one shall remove or modify the barricaded area without authorization from the NDTCompany First Line Supervisor. Should this activity occur during night time hours,enough lighting should be present to ensure the barricade is visible.



J12.7

Testing of Electrical Components

All testing and/or commissioning of electrical components shall require a Permit to Workto be issued to only qualified electricians.

The First Line Supervisor shall be responsible for creating a lockout / tagout list of allenergy sources that are required to be isolated on a system. Each employee working on

the isolated system shall verify the system is properly isolated by trying the system priorto installing their personal locking device and tag prior to a Permit to Work being issued.

If a job is discontinued before it is completed (i.e. end of shift), each employee mustremove their personal lock and tag and re-apply them prior to recommencement ofwork. The First Line Supervisor shall place an operational lock on the system to ensurethe system is not activated prior to the work being completed.

Should the isolation consist of a number of employees, a group lockout proceduremaybe utilized. The isolation list shall be placed within the group lockout / tagout box.

All Energy Isolation shall be performed accordance with Dynamic Industries, Inc.

Energy Isolation Procedure.

Any electrical lines being removed adjacent to any live lines shall be fully labeled every5 feet to indicate which line to be removed.

Barricades

Precautions shall be taken to ensure that electrical testing is performed safely. Thearea surrounding the electrical test shall be cordon off with red “Danger” barricadedtape. The distance which will be cordon off will be determined by the First Line

Supervisor and Issuer of the Permit to Work.

Barricades shall be erected to prevent employees, visitors, equipment and vehicle trafficfrom accidentally entering the electrical testing work area.

No one shall enter the electrical testing area unless is authorized by the First LineSupervisor, has read and understood both the JSEA and Permit to Work.

Anyone entering the barricaded area without authorization shall be asked toimmediately leave the authorized area and the Facility Management or SH&EDepartment shall be notified.

No one shall remove or modify the barricaded area without authorization from the FirstLine Supervisor. Should this activity occur during night time hours, enough lightingshould be present to ensure the barricade is visible.

Warning signs shall be installed on barricades to appropriate communicate to otherswithin the area. The signs shall read “Danger High Voltage Equipment, KEEP AWAY”



J12.8

During the Test

Only those individuals directly involved with and who have signed the Permit to Workshall be allowed in the barricaded area.

Communication shall be established between all employees involved with the highvoltage test procedure. At a minimum, hand signals shall be used to help minimizemiscommunication during this procedure.

PPE

All individuals directly involved in the high voltage testing shall have the appropriatePPE for arc protection (i.e. Face shields, rubber gloves, etc.).

Training and Appointment Requirements

Permit to Work shall be the issued by the SH&E Department. Should a need arisewhere additional individuals are needed to issue Permit to Works, these individuals shallbe identified and authorized by Facility Management.

The scope of the authorization shall be clearly defined and shall not extend beyond therange of situations that would be expected to occur in the normal performance of theperson’s duties.

Before appointment, candidates shall demonstrate by written tests that they possess thefollowing:

Sufficient knowledge of the relevant facility activities and Permit to WorkProcedures

A responsible attitude towards and visible demonstration of their commitment tosafe working conditions and understanding of these requirements.

At the option of the SH&E Department, a period of mentoring may be requiredwhere the appointee works with an authorized permit issuer.

Training for Authorized Permit to Work Issuers shall consist of but is not limited to thefollowing:

Formal Classroom Training on this Permit to Work system

Successfully passing of a written examination on this Permit to Work system

Undertaking practical training under the direct supervision of an AuthorizedPermit Issuer and completion of permits correctly.

Final Practical will consist of the preparation of a permit overseen by another

Authorized Permit Issuer and

Training for First Line Supervision and employees who will be or has the potential toworking under the requirements of this Permit to Work System, shall consist of thefollowing:

Formal Classroom training in the requirement of and use of this Permit to WorkSystem.



J12.9

Multiple Jobs

Multiple jobs are allowed at the discretion of the Authorized Permit to Work Issuer.

A given Permit may cover one job or a group of jobs in the same general area however,separate Permits will be required for 3 or more simultaneous activities within the samegeneral area.

Each First Line Supervisor of the employees performing the simultaneous activities shallsign as the Responsible Person on the Permit to Work.

Issue of Permit to Work

The First Line Supervisor shall be responsible for requesting a Permit to Work from theSH&E Department prior to the start up of their task that may require this system to beimplemented.

The SH&E Department Representative shall initiate a Permit to Work System after

considering the following questions:

Identifies with the First Line Supervisor that the operation to be performedcreates simultaneous operations and requires a Permit to Work System to beimplemented. If yes, review the next question.

Identifies with the First Line Supervisor if the operations can be scheduleddifferently to not create simultaneous operations. If the operations can not berescheduled, a Permit to Work System shall be initiated. . If supplementaryPermit (i.e. confined space) is required, the entry should be rescheduled wherethe simultaneous operations can not affect the entry being performed safely.

The SH&E Department Representative shall initiate a Permit to Work by:

Verifying the job can be performed safely and that all necessary isolations (i.e.lockout / tagout, screens, firewatch, etc.) are in place prior to;

Completing all sections of the Permit to Work and authorizing for the work toproceed

The First Line Supervisor and his crew shall:

Reviewing, Understanding and Signing the Permit to Work

Discuss hazards and precautions with the SH&E Department Representative as

part of the task Job Safety and Environmental Analysis (JSEA)When required, obtain, review, understand and sign any required supplementarypermit (i.e. Confined Space) that maybe required in addition to the Permit toWork

Upon completion of the Permit to Work, the SH&E Representative shall provide theoriginal (top) copy of the Permit to Work to the First Line Supervisors to post at the

jobsite where the simultaneous operations is being preformed. The middle copy of thePermit to Work shall remain “open” in the SH&E Department Office until the completion



J12.10

of the task or until the end of the shift (or extension). The bottom copy of the Permit toWork shall remain in the Permit to Work Booklet.

Withdrawal of Permit to Work

Should there be a change in conditions, which introduces a new or identified hazard tothe permitted simultaneous operations or render stated precautions inadequate, theemployees and/or the First Line Supervisor shall STOP WORK and notify the SH&ERepresentative.

If the scope of the jobs under the Permit to Work changes after it has been issued, theemployees and/or First Line Supervisor shall STOP WORK and notify the SH&EDepartment. SH&E Department shall modify the Permit to Work to reflect the change(s)in the scope of work. The change(s) may require the SH&E Department to close theoriginal Permit to Work and issue a new Permit to Work.

The Facility Management and/or the SH&E Department shall have the authority toSTOP any WORK and withdraw the Permit to Work at anytime.

Every person onsite has the right to discuss the withdrawal of a Permit to Work at

anytime with the Facility Management or SH&E Department.

Duration of Permit to Work

The normal period of validity for a Permit to Work is the duration of a shift (i.e. 12hours). The SH&E Representative may extend the Permit to Work, if the simultaneousoperations is incomplete when the Permit expires for only two (2) additional hours,provided the same employees and supervision is still performing the operations, there ano additional hazards, and the precautions specified on the original Permit to Work shillapply.

The extension of the Permit to Work can be provided by completing the ExtensionSection of the Permit to Work. The extension must be initialed by both the SH&ERepresentative and First Line Supervisors involved with the simultaneous operations.By initialing the extension portion of this permit means that no changes within the jobscope, personnel involved within the task or hazards associated with the simultaneousoperations.

In the event of a Firewatch’s gas detection meter alarm or any other emergencyrequiring the stopping of the work under the Permit to Work, the First Line Supervisorshall discuss the conditions with the SH&E Department prior to recommencing work.

Permit to Work Issuer or Recipient

Anytime additional employee(s) may arrive to the jobsite, this employee(s) shall reviewwith the First Line Supervisor the task JSEA and Permit to Work requirements. Uponcompletion of this review, the employee(s) shall sign the Permit to Work and associatedJSEA to indicate they have reviewed and understands the requirements of both thePermit to Work and job JSEA.

If a new Permit to Work Issuer (i.e. shift change, etc.) is present during the duration ofthe Permit to Work, the new issuer shall countersign the original Permit to Work, after



J12.11

they have verified the permit and permit conditions are still being met and the permit isstill valid.

Completion of Simultaneous Operation

At completion a job or jobs that created the presents of simultaneous operations, theFirst Line Supervisor(s) shall ensure that the jobsite is left in a safe manner and in an

appropriate level of housekeeping. The First Line Supervisor shall sign the completionsection of the Permit to Work and bring the signed Permit to Work back to the SH&EDepartment office.

The SH&E Department shall attached the original Permit to Work with the middle copy,which was posted in the office and filed for 1 year.





J12.12

Attachment 1





MORENO GROUP LLC AND SUBSIDIARIESPermit to Work

Date: _________________________ Time: _____________________

Location in Facility: ________________________________________________

Work Activities to be Performed:

This permit is valid from: Date: __________ Time: _______ To Date: __________ Time: _______

Gas Tests: O2%: __________ LEL%: __________ N/A: __________

Extension (2 hrs only) To: Date: __________ Time: _______Gas Tests: O2%: __________ LEL%: __________ Supervisor:_____________

Abrasive Blasting / Coating Operation (outside designated area)

____ Blast screen in place surrounding operations

____ Hoses organized with safety pins and whip checks

____ JSEA in place for simultaneous operations requiring this permit

Hot Work (When any system containing hydrocarbons)

____ No activities within 10’ radius of any system containing hydrocarbons

____ Fire Watch designated at each affected level w/ Fire Extinguisher

____ Fire Watch remains 30 minutes after hot work operation stops.

____ Gas detector onsite

____ Welding leads and torch hoses organized

____ Flammable or Combustibles materials within 35 feet relocated or shielded


Hydrostatic Testing (outside designated area)

____ Hydrostatic Test Pack onsite

____ Barricade in place with appropriate signage (“Danger High Pressure Equipment, Keep Away”)

____ Barricades in place a stairways (if needed)

____ Communication between Hydrostatic Test Personnel will be _____________________________


____ NOTE: No simultaneous activities allowed within hydrostatic area

NDT Activities – X-Ray (outside designated area)

____ Barricades erected per exposure requirements (2 mr/hr) or Use of Cones with Facility Mgr. Approval

____ Caution Radiation Area Authorized Personnel Only signs in place


Test of Electrical Components ____ Barricade in place with appropriate signage (“Danger High Voltage Equipment, Keep Away”), IF

REQUIRED FOR ACTIVITY







Personal ProtectiveEquipment


J13.1


Purpose

The purpose of this policy is to meet the minimum standard for Personal ProtectiveEquipment at Moreno Group LLC and Subsidiaries facilities and client locations.

Scope

Personal Protective Equipment is primarily intended for use as the last line ofdefense. Where practical, hazards should be addressed by engineering, elimination,guarding, etc. before PPE is required.

This procedure establishes minimum requirements for the selection, use of personalprotective equipment at all sites / projects and reimbursement of Personal ProtectiveEquipment. This procedure applies to all Moreno Group LLC and Subsidiariesemployees, sub-contractors, clients, vendors and visitors.

The procedure specifically covers the following:

Work clothing

Head protection

Eye and face protection

Hand protection

Foot protection

Personal Floatation Device

Note: Refer to specific programs concerning Fall Protection, Hearing Protectionand Respiratory Protection.

Responsibilities

The Facility / Site Manager or Offshore Manager is responsible for:

Evaluating the hazards associated with Moreno Group LLC and Subsidiariesfacilities / sites as to the PPE required, and documenting and certifying thehazard assessment.



J13.2

Establishing minimum PPE requirements for all personnel entering / workingin the facility / site.

Re-evaluating hazards when changes in the work area may affect PPErequirements.

Conferring with supervisors and employees to identify the hazards and whatPPE is required for a job.

Monitoring compliance with the use and condition of proper PPE.

Ensuring audits are periodically performed concerning use of PPE.

Maintaining facility / site expertise relating to PPE.

Providing First Line Supervisors or Superintendents the resources toimplement and maintain the requirements of this program.


Understanding and implementing the requirements of this program.

Conferring with other Moreno Group LLC and Subsidiaries personnel or sub-contractors as to the PPE required for a job.

Providing replacement PPE, per our replacement PPE procedure

Conferring with personnel reporting to him / her as to the hazards of a job andthe PPE required.

Obtaining special PPE when required for a specific job.

Monitoring the job and work area for compliance with PPE requirements andcondition of PPE.

Initiating the use of additional PPE as specified in permits.


Complying with this procedure and using required PPE.

Conferring with supervision as to hazards involved and PPE requirementsassociated with the job.

Inspecting PPE prior to each use for proper fit and maintaining PPE in a goodand clean condition.

Advising supervision of any suggestions to improve the use or selection ofPPE and alerting them to any problems concerning PPE.



J13.3

Requirements

Appropriate clothing shall be worn to provide adequate protection. Proper clothingmay vary from job to job. The following outlines general clothing requirements:

Loose clothing, neckties and jewelry shall not be worn while working aroundmoving machinery.

No jewelry, except for watches, shall be worn while performing any worktasks outside of the office or living quarters. Examples of jewelry are, but notlimited to, rings, loop earrings, piercing (whether exposed or not) ornecklaces. Watches shall be removed when welding or working around anyelectrical sources.

Shirts or blouses shall be worn at all times. Tank tops, fish net or sleevelessshirts shall not be worn.

Shorts, short pants or cut offs shall not be worn.

Clothing that becomes saturated with flammable liquids or chemicals shouldimmediately withdraw to an area safe from fire hazards, change clothing andtake appropriate steps of decontamination.

Note: When specific protective clothing, equipment or barrier creams are required,the supervisor will provide them.

Employees should inspect their PPE each day prior to use. Any defects or damagethat is identified by the employee supervisor shall be removed for service andreplaced.

Issuing of Personal Protective Equipment

Each employee shall receive the following required Personal Protective Equipmentat “No Charge” upon their successful completing of their New Employee Orientation / SH&E Training:

Hard Hat

Safety Glasses

Respirator (Blasters and Painters)

Gloves (Rigging and Welding)

Work Vest (offshore employees)

Moreno Group LLC and Subsidiaries will replace the above mentioned PersonalProtective Equipment at No Charge to the employee, if the employee follows theproper PPE replacement procedure. This procedure is as follows:



J13.4

The employee will be responsible for bring their damaged or worn PPE to their YardSuperintendent, Offshore Superintendent or designee. Upon receiving the damagedPPE, the issuing authority will be responsible for providing the replace PPE, at NoCharge, to their employee.

Should the employee not provide to the issuing authority at the time their PPEreplacement request, their damaged or worn PPE, the employee will be payroll

deducted for the replacement PPE.

Head Protection

Moreno Group LLC and Subsidiaries will furnish to all employees the appropriatehead protection (hard hats). All employees shall wear hard hats while on the joblocation except offices, vehicles, helicopters, crew boats and other areas that maybe exempted by facility policy. Offshore welders will be required to wear a hard hatwhile welding.

All hard hats shall meet ANSI Z89.1 “Safety Requirements For Industrial Head

Protection.” Hard hats shall not be worn which are made of metallic material.Employees will be responsible for keeping their hard hats clean and in good repairand shall not alter the hard hat by drilling, painting, cutting or carving. All damagedhard hats shall be returned to the employee’s supervisor for replacement.

Hard hats will be provided upon hire and then every five years.

Ears

Appropriate hearing protection is provided by Moreno Group LLC and Subsidiaries.Hearing protection shall be worn in all designated areas or area that are suspected

of excessive noises level because of an individual task being performed in that area.

Eye Protection / Face Protection

All employees and visitors must wear approved safety glasses at all times outside ofoffices, vehicles, break rooms and tool rooms. Eye protection shall meet ANSI Z87.1specifications.

Safety glasses will be provided upon hire and once a quarter there after.

Wearing of contact lenses is discouraged, although wearers of contact lenses shall

inform their First Line Supervisor or Superintendent that they are wearing contactlenses so that proper emergency care can be given if necessary.

Contact lenses shall not be worn in places where there is a risk of liquid spray fromhydrocarbons, chemicals, H2S, paints, acids, caustics or liquid substances that canburn or be corrosive to the eyes.

Employees who wear prescription glasses will be required to wear prescriptionsafety glasses with side shields at all Moreno Group LLC and Subsidiaries ’ facilitiesor client locations. The company will provide prescription safety glasses with



J13.5

permanent side shields to these employees, whose job requires safety glasses,under the following guidelines:

The employee will be required to furnish, at his/her expense, a current eyeglass prescription.

The prescription shall not be older than 12 months old.

New employees will be required to purchase, at their expense, theirprescription safety glasses. However, upon completing 90 days of continuousemployment, the company will reimburse the employee for their prescriptionsafety glasses.

Employees will receive only one pair of clear-lens prescription safety glassesper year. To receive more than one pair of prescription safety glasses, theemployee must receive approval from their First Line Supervisor or OffshoreManager.

Note: Receipt indicating the cost of the prescription safety glasses will be required inorder for proper reimbursement.

Impact goggles or safety glasses shall be worn with a faceshield when engaging inany activity that involves hazards to the unprotected eye or face from chipped orflying particles. Examples are chipping, scrapping, buffing, grinding, burning, etc.

Chemical goggles shall be worn with a faceshield when employees are handlingopen hazardous chemicals, liquids, powders, and vapors or when the MaterialSafety Data Sheet (MSDS) of the product specifies this protection.

Hand Protection

Gloves shall be worn to minimize and/or eliminate the potential for injuries to handsand/or the fingers. It is important to match the type of glove used to the mechanicaland contact hazards that may be encountered. Some examples, but are not limitedto, are tools, sharp objects or wire rope etc. Appropriate gloves shall be worn whenmaterial handling, handling chemicals or hazardous materials. Impermeable glovesshould be selected to provide adequate protection against the liquid material beinghandled. The Material Safety Data Sheet shall be referred to prior to handling thematerial. Some examples of gloves are:

Welding Gloves for protection against hot material.

Latex Gloves for protection against Bloodborne Pathogens

Leather Gloves for material handling

Cotton Gloves for material handling

Nitrile for handling chemicals



J13.6

The employee shall be responsible for inspecting protective equipment prior to andafter use. The inspection should identify any cuts, tears or abrasions. If protectiveequipment is found defective the employee shall properly dispose of the items. Theemployee is also responsible for utilizing, cleaning and maintaining protectiveequipment provided by the company.

Material handling gloves will be provided upon hire and once a quarter there after.

Foot Protection

Safety-toe footwear that complies with ANSI-Z41.1 shall be worn in all field and shoplocations; this is a condition of employment.

Footwear shall be substantial in construction and made of solid impermeablematerial in the soles and uppers that offer good protection against penetration ofliquids and sharp objects.

Additional foot protection such as rubber boots may be needed during operations

involving cleaning chemicals, caustics or solvents. The Company in thesecircumstances shall provide rubber boots.

Footwear such as sandals, canvas shoes “tennis shoes” and other styles that do notprovide proper support or protection shall not be worn on Company Operations.

Personal Floatation Devices (Workvests / Life Jackets )

Employees who are working over or near the water except when protected by ahandrail or boarding or disembarking a vessel or working aboard a vessel (boat orbarge) shall wear a fully secured workvest or USCG approved Type I floatation

device.

Inflatable life jackets are provided by transportation companies and shall be wornwhile traveling by an aircraft over water.

USCG approved Type I floatation device shall be worn while conducting platformabandonment.

Employees visiting an offshore platform are required to wear a fully secured flotationdevice when at the plus 10 level or below the lowest working level.

The immediate supervisor shall confirm with the facility operator if and whenemployees may deviate from this requirement. Anytime a flotation device is nolonger an effective flotation device shall be taken out of service, reported to facilityowner or supervisor and replaced.

Employee Owned Personal Protective Equipment

Any PPE which is employee owned shall be inspected, maintained and cleaned inoccurrence with all regulatory and company requirements.



J13.7

Any defective PPE shall be replaced immediately.

Training

Each employee will receive Personal Protective Equipment Training during the NewEmployee Orientation / SH&E Training. Refresher training will be conducted by theFirst Line Supervisor annually and during the daily Job Safety and Environmental

Analysis or anytime the following occurs:

Changes in the workplace render previous training obsolete.

Changes in the types of PPE to be used render previous training obsolete.

Inadequacies in an affected employee’s knowledge or use of assigned PPEindicate that the employee has not retained the requisite understanding orskill.

Personal Protective Equipment Hazard Assessment

Moreno Group LLC and Subsidiaries will conduct and maintain a Personal ProtectiveEquipment Hazard Assessment. This assessment will help Moreno Group LLC andSubsidiaries maintain a current Personal Protective Equipment Program. Theassessment will include the following elements:

Certifier’s name

Certifier’s signature

Date of the assessment

Identification of assessment documents.







Powered Work PlatformSafety


J14.1

Powered Work Platform Safety

Purpose

The purpose of this procedure is to establish and implement safe work practices foremployees that utilize Powered Work Platforms.

Scope

The scope of this program applies to all Moreno Group LLC and Subsidiariesprojects and employees utilizing powered work platforms while performing job tasks.

This program also applies to all subcontractors, working under the direction of

Moreno Group LLC and Subsidiaries, utilizing powered work platforms whileperforming job tasks.

Responsibilities


Providing support to supervisors and employees to implement the provisionsof the procedure.

Ensuring that all employees working out of powered work platforms are

trained prior to operations of equipment.




Ensuring that only properly trained employees are operating powered liftplatforms.

Ensuring that all trained employees have a numbered hard-hat sticker thatidentifies training.

Coordinating with the Yard Manager and the SH&E Department when there isa need for additional training due to changes in work activity of addition ofnewly hired employees.



J14.2


Coordinating with First Line Supervisor to determine which projects andemployees will be working out of powered lift platforms and ensuring that onlytrained employees are allowed to operate these machines.

Communicating with the Yard Manager on the need for additional training.

Assisting in training on related SH&E issues, such as fall protection, whileworking out of powered lift platforms.



Reporting to his immediate supervisor any problem, which may arise, or anyunsafe condition while utilizing powered lift platforms.

Ensuring that powered lift platforms are properly inspected before each useand all functional alarms are operational.

DEFINITIONS

Aerial devices - any vehicle-mounted device, telescoping or articulating, or both,used to position personnel.

Articulating boom platform - an aerial device with two or more hinged boomsections.

Extensible boom platform - an aerial device (except ladders) with a telescopic orextensible boom. Telescopic derricks with personnel platform attachments areextensible boom platforms when used with a personnel platform.

Mobile unit - a combination of an aerial device, its vehicle, and related equipment.

Platform - any personnel-carrying device (basket or bucket) which is a componentof an aerial device.

Vehicle - any carrier that is not manually propelled.

Vertical tower - an aerial device designed to elevate a platform in a substantiallyvertical axis.

REQUIREMENTS

Aerial lifts acquired for use on or after January 22, 1973 shall be designed andconstructed in conformance with the applicable requirements of the AmericanNational Standards for "Vehicle Mounted Elevating and Rotating Work Platforms,"



J14.3

ANSI A92.2-1969, including appendix. Aerial lifts acquired before January 22, 1973which do not meet the requirements of ANSI A92.2-1969, may not be used afterJanuary 1, 1976, unless they shall have been modified so as to conform with theapplicable design and construction

Equipment shall be used in its stock configuration and only as it was intended to beused. "Field modifications" shall only be made if written certification from the

manufacturer or a nationally recognized testing laboratory has been received.

Any articulating boom and extensible boom platforms, primarily designed aspersonnel carriers, shall have both upper and lower controls for the platform.

Upper controls must be in or beside the platform within easy reach of the operator.Lower controls must provide for overriding the upper controls. Controls shall beplainly marked as to their function. Lower level controls shall not be operated unlesspermission has been obtained from the employee in the lift, except in case ofemergency.

Follow the American National Standards Institute (ANSI) requirements whenperforming electrical tests or inspecting all critical hydraulic and pneumaticcomponents.

Employee instructions

Employees shall be informed on the safe use of powered platforms. The guidelinesthat follow were obtained from rules covering several types of powered platforms.

Employees shall:

Test lift controls each work shift before using to determine that they are insafe working condition;

Are trained on and before operating the equipment;

Wear a full body harness and a lanyard attached to designated anchor pointin the basket; and do not "tie off" to an adjacent pole, structure, or equipmentwhile working from an aerial lift;

Always stand firmly on the floor of the basket, and do not sit or climb on theedge of the basket or use planks, ladders, or other devices for a work

position;

Do not exceed boom and basket load limits specified by the manufacturer;

Move this equipment:

with people in the basket or platform, only if it is specifically designed forthis type of operation;



J14.4

only after inspecting the boom(s) to see that it is properly cradled andoutriggers are in stowed position;

only after securing the aerial device.

set brakes and outriggers, when used, on pads or a solid surface. Wheelchocks shall be installed before using an aerial lift on an incline.

Ensure that the equipment is being operated in the safe working envelope atall times and are not relying solely on the EMS warning system .

Not utilize the aerial lift as an elevator. Aerial lifts are to be used for theirintended purpose only. Employees shall not climb out of the aerial lift, otherthan under those circumstances that have been approved by the FacilityManager (i.e. to get into pipe racks that cannot be accessed by any othermeans). In these circumstances, employees shall be properly secured withfall protection at all times, with 100% tie-off when climbing in and out ofbasket.

If the back up alarm is not operational, a spotter shall walk in front of theaerial lift when it is being backed up.

Aerial lifts shall maintain a Safe Distance of 10 feet from all powerlines lines

Required inspections before each use

Before each use, the machine shall be visually inspected by the operator. A formalinspection shall be done once a day and use of pre-use inspection form shall beutilized for that inspection record. The formal inspection shall be done by a

competent person that has been identified by the facility manager.

Keep a certification record of each inspection which includes the date of theinspection, the signature of the person who performed the inspection, and the serialnumber, or other identifier, of the machine which was inspected.

The EMS system on the unit shall be tested before each use. Daily EMS functiontesting shall be done daily to ensure that this system is functioning properly and allalarms are in proper working order.

Pre-use inspections shall be documented on the appropriate inspection form (see

Attachment 1) and turned in to the Facility Manager on a daily basis.

SPIDER LIFTS (ADJUSTABLE SUSPENSION SCAFFOLDING)

Inspection

Employers should require a competent person to inspect all scaffolds and scaffoldcomponents for visible defects before use on each workshift. Scaffolds should be



J14.5

erected, moved, dismantled, or altered only under the supervision of a competentperson.

All components of personal fall protection equipment (including harnesses, lanyards,lifelines, trolley lines, and points of anchorage) should be inspected by a competentperson before use. Any visibly damaged or worn equipment should be removed fromservice immediately.

All inspections of equipment shall be documented on the appropriate inspection formand be turned in to the First-Line Supervisor / Offshore Superintendent on a dailybasis (see Attachment 2).

Use of Fall Protection Equipment

Fall protection systems shall be utilized by all workers on adjustablesuspension scaffolds and employees must be protected by a harness systemthat is anchored independent of the scaffold anchorage.

Each person on a suspended powered scaffold must be attached to aseparate fall arrest system unless the installation was specifically designednot to require one.

Each lifeline must be fastened to a separate anchorage capable of holding aminimum of 5000 pounds.

Do not wrap lifelines around structural members unless lifelines are protectedand a suitable anchorage connection is used.

Protect lifelines at sharp corners to prevent chaffing.

Rig fall arrest systems to prevent free fall in excess of six (6) feet.

Use lifelines of size and construction that are compatible with the rope grabbeing used.

Assure a properly attached rope grab is installed on each lifeline. Install inaccordance with the manufacturer’s recommendations.

Keep fall arrest device positioned above head level.

Use only full body harnesses of the proper size and that are tightly fastened.

Assure full body harness has lanyard attachment with D-ring at the center ofyour back.

Consult fall protection supplier for inspection procedure. Inspect fallprotection anchorage/equipment before each use.



J14.6

When a secondary wire rope system is used, a horizontal lifeline secured to two ormore structural members of the scaffold may be used in lieu of vertical lifelines

Use of Structural Members as Anchor Points

Structurally sound portions of structural beams, pipes, pad-eyes, etc. must be usedto anchor lifelines for harness systems and tiebacks for suspension scaffold support

devices. Lifelines and tiebacks should be secured to separate anchor points ofstructural members. Competent persons shall identify and communicate strategicallylocated anchor points on structural members of the platform for maintenance andrepair work. Anchor points shall have the strength to support over 5300lbs to serveas an adequate anchor point.

GENERAL GUIDELINES

1. Post these safety guidelines in a conspicuous place and be sure that allpersons who erect, use, locate, or dismantle suspended scaffold systems arefully aware of them and also use them in tool box safety meetings.

2. Follow all equipment manufacturers’ recommendations as well as all state,local and federal codes, ordinances and regulations relating to suspendedpowered scaffolding.

3. Survey the jobsite. A survey shall be made of the jobsite by a competentperson for hazards such as exposed electrical wires and obstructions thatcould overload or tip the suspended powered scaffold when it is raised orlowered. Those conditions should be corrected before installing or using orinstalling powered suspended scaffold systems.

4. Inspect all equipment before use. Never use any equipment that is damagedor defective in any way. Mark it or tag it as damaged or defective equipmentand remove it from the jobsite.

5. Erect and dismantle suspended powered scaffold equipment in accordancewith design and/or manufacturer’s recommendations.

6. Do not erect, dismantle, or alter suspended powered scaffold systems unlessunder the supervision of a competent person.

7. Do not abuse or misuse suspended powered scaffold equipment. Never

overload platforms or hoists.

8. Never take chances! If in doubt regarding the safety or use of suspendedscaffolds, consult your supervisor and scaffold supplier and utilize your stopwork authority! Never used suspended scaffold equipment for purposes or inways for which it was not intended.

9. Care should be taken when operating and storing equipment during windyconditions. All operations shall be shut down when wind speeds are equal toor greater than 25 mph.



J14.7

10. Shield scaffold suspension ropes, cables, and harness system lifelines(lifelines) from hot or corrosive processes, and protect them from sharp edgesor abrasion.

11. Inspect all scaffolds, scaffold components, and personal fall protection

equipment before each use.

12. Provide personal fall arrest system components and make sure that it is usedby all workers on adjustable suspension scaffolds.

13. Use structurally sound structures to anchor lifelines for harness systems andtiebacks for suspension scaffold support devices. Lifelines, vertical life lines,and tiebacks should be secured to separate anchor points on structuralmembers.

14. Provide proper training for all workers who use any type of adjustable

suspension scaffold or fall protection equipment.

15. Follow scaffold manufacturers' guidance regarding the assembly, rigging, anduse of scaffolds.

16. Suspension ropes and lifelines for harness systems should be shielded from

a. heat-producing processes such as welding,

b. acids or other corrosive substances, and

c. sharp edges or abrasions.

17. Such ropes should be made from material that is not adversely affected byheat or by acids or other corrosives.

18. Suspended powered platforms must never be operated near live power linesor sources unless precautions are taken.

19. Do not work on or install suspended powered scaffolds if your physicalcondition is such that you feel dizzy or unsteady in any way, or under theinfluence of alcohol or illegal drugs.

20. When welding from suspended powered scaffolds:

a. Assure platform is grounded to structure.

b. Insulate wire rope above and below the platform.

c. Insulate wire rope at suspension point and assure wire rope does notcontact structure along its entire length.

d. Prevent the bitter end from touching the ground.



J14.8

21. Inspect all rigging equipment and suspended powered platform systems daily.

22. Do not overload, modify or substitute equipment.

23. Inspect wire rope during each ascent or descent for damage.

24. Use care to prevent damage to equipment by corrosive or other damagingsubstances.

25. Clean and service equipment regularly.

26. Always maintain at least four (4) wraps of wire rope on drum type hoists.

27. Do not join platforms unless the installation was designed for that purpose.

28. When rigging for another drop, assure sufficient wire rope is available beforemoving the suspended scaffold system horizontally.

Proper Training of Workers

Moreno Group LLC and Subsidiaries provides workers with proper training, includingthe manufacturers' recommendations for installing and operating adjustablesuspended scaffold systems and for using personal fall protection equipment.Untrained personnel should never be permitted to work from any type of suspensionscaffold.



J14.9

Attachment 1





J14.9.a.1

MORENO GROUP LLC AND SUBSIDIARIES

ARTICULATING BOOM CHECKLIST

* Indicate unit serial number of unit on this inspection checklist.





J14.10

Attachment 2





J14.10.a.1

MORENO GROUP LLC AND SUBSIDIARIESPOWERED STAGING PLATFORM (SPIDER) CHECKLIST

A SAFETY HARNESSES YES NO N/A

A1 Does the harness have frayed edges, broken fibers, pulledstitches, cuts or chemical damage?

A2 Are buckles and D-rings firmly attached?

A3 Does the roller turn freely on the frame of the buckle?

A4 Are there any sharp edges on buckles or D-rings?

A5 On sliding bar buckles, are there any cracks, distortions or sharpedges on the frame and sliding bar?

A6 Are grommets still in place on belt ends? Belts w/ grommet-lessholes should be checked for torn or elongated holes.

A7 Are exits & aisles unobstructed?

REMARKS:

B LIFELINES/SUPPORT LINES YES NO N/A

B1

Are there any broken strands, rust and kinks that mayweaken wire ropes? Ropes should be lubricated frequently,especially before use in acidic temperatures or beforeexposure to salt water.

B2 Are wire rope strands cleaned and coated with oil after eachuse?

B3 Are lifelines carefully checked before and after each use? Ifany lifelines are in use, they should be checked for wear,broken or frayed cords and chemical damage

B4 Are lines being maintained per manufacturer’s instructions?

REMARKS:



J14.10.a.2

C PLATFORM INSPECTION YES NO N/A

C1Has the platform been inspected prior to use? Unit should bechecked for proper condition, open holes in bottom ofplatform, rust or wear and all function controls workingproperly.

C2 Are all function controls on platform properly labeled?

C3Has operator of platform been properly trained beforeoperating? All employees should be properly trained beforeallowed to operate all Spiders.

C4Has proper anchorage points been identified within theplatform and are all employees utilizing proper anchoragedevices?

REMARKS:

SERIAL NUMBER OR UNIT IDENTIFICATION NUMBER: ____________________________

*ALL UNSAFE OR DAMAGED EQUIPMENT NEEDS TO BE TAKEN OUT OF SERVICE AND

TAGGED OUT. ALL UNSAFE OR DAMAGED EQUIPMENT IS TO BE CHECKED BY A

QUALIFIED SERVICE REPRESENTATIVE AND PLACED BACK IN PROPER WORKING

CONDITION BEFORE THE EQUIPMENT IS UTILIZED.





ScaffoldingPage: 1 of 10Original: 01/01/2001Revised: 3/12/2009

J15.1

Scaffolding

Purpose

To establish the minimum guidelines for the erection, dismantling and use ofscaffolds. The intent of this guideline is to meet or exceed 29 CFR 1910.28 – 1910.29 and 29 CFR 1926.451.

Scope

The scope of this program is to provide guidelines to improve Moreno Group LLCand Subsidiaries scaffolding systems.

Responsibilities


Overseeing this Policy to ensure that all assigned duties are being carriedout.

Being knowledgeable current with the requirements of OSHA as they pertainto this procedure.

Reviewing all audits for compliance with this procedure.

Approval variances to apply green tags instead of yellow tags.

The Yard Foreman / Offshore Superintendent is responsible for:

Evaluating the safe use of scaffolds as an integral part of preplanning a job.

Assuring all employees reporting to them who may be required to usescaffolds are properly trained and understand the requirements of thisprocedure.

The First Line Supervisor / Offshore Superintendent (Competent Person) isresponsible for:

Evaluating and managing conditions located at jobsite.

Inspecting scaffolding to ensure it is in good condition.

Erecting scaffold per manufacturers’ specifications.



J15.2

Ensuring scaffold structures / components will adequately support the loadsto be imposed.

Using sound judgment when planning scaffold erection.

Providing adequate foundations, proper access, bracing, handrails andtoeboards and adequate decking materials.

Placing a tag on the scaffold indicating when it is “Under Construction” orready to be utilized.

Provide direction to those employees who may be assisting them in theerecting or dismantling of a scaffold.

Develop variance and provide to Facility Manager or Offshore Manager ordesignee to green tag scaffolding.



Inspecting scaffolds and ladders prior to use and reporting deficiencies totheir supervisor.

Bringing any questions or concerns about the usage and choice of scaffoldsand ladders on the job to the attention of supervision.

Following safe practices while working on scaffolds.

Definitions

Competent Person – 1926.32(f) – means one who is capable of identifying existinghazards and predictable hazards in the surrounding or working conditions which areunsanitary, hazardous, or dangerous and who has authorization to take promptcorrective action to eliminate them.

Qualified Person - 1926.32 (I) – means one who, by possession of a recognizeddegree, certificate, professional standing or who, by experience, has successfullydemonstrated an ability to solve or resolve problems relating to the subject matter,the work or the project.

Scaffold User - 1926.454 (a) – anyone that performs work on a scaffold.

Safety Factor - 1926.32 (m) – means the ratio of the ultimate breaking strength of amember or piece of equipment to the actual working stress or safe load when in use.



J15.3

Requirements

It shall be the responsibility of all Moreno Group LLC and Subsidiaries employees toread and comply with the following guidelines, which are designed to promote safetyin the erecting, dismantling and use of scaffolds. These guidelines are not all-inclusive and do not replace other additional guidelines that may be more rigid.Precautionary measures shall be taken when unusual conditions occur that may not

be covered by these guidelines. If these guidelines conflict with applicable federal,other governmental statute or regulation which is more rigid, the statute or regulationshall supersede these guidelines and it shall be the responsibility of the erector oruser to comply.

Personnel Qualifications

Scaffolds shall be erected, dismantled, moved and altered under the supervision of aScaffold Competent Person. The Scaffold Competent Person shall inspect and tagall scaffolds accordingly. Employees designated as Scaffold Builders shall betrained as per the training requirements of 1926.454(b).

Personnel who have successfully completed scaffolding training that encompasseseducation of scaffolds up two bucks or less than 14’ vertical height to the workplatform, may direct and/or perform the erection, modification or dismantling ofscaffolds up to this height.

Scaffold General Guidelines

All types of scaffold shall meet the following General Guidelines:

No scaffold shall be erected, moved, dismantled or altered except under the

supervision of a competent person.

Supported scaffold poles, legs, posts, frames and up-rights shall bear on base platesand mudsills or other adequate firm foundation.

Runners shall be as close to the base as possible on all Company scaffolds.

Scaffolds shall be erected plumb and square.

Scaffolds shall be braced and rigid at all times.

The competent person should determine the feasibility and safety of providing fallprotection for employees erecting or dismantling supported scaffolds. Employersare required to provide fall protection for employees erecting or dismantlingsupported scaffolds where the installation and use of such protection is feasible anddoes not create a greater hazard.

All scaffolds shall be equipped with a handrail, midrail and toeboard. Handrail heightshall be 42 inches to 45 inches.



J15.4

All scaffolds shall be equipped with proper access. Dual access/egress shall beconsidered when working in operating units per National Fire Protection Association101 Life Safety Code. Scaffold access ladders shall extend three feet beyond thedeck. Scaffolds more than thirty feet in height shall be provided with a ladder breakand rest deck with additional breaks and decks every thirty feet, thereafter. Theemployer shall have a competent person determine whether it is feasible or wouldpose a greater hazard to provide and have employees use a safe means of access.

) When an overhead hazard exists, overhead protection shall be provided for personserecting scaffolds.

Slippery conditions on scaffold decks shall be removed or corrected as soon aspossible

When erecting scaffolds, barricade tape shall be used.

When persons are required to work or pass under scaffolds, barricades (a minimumof six feet outside the base of the scaffold) may be used instead of the screen if

personnel do not cross the barricade. When objects center of gravity does notextend over the toe boards, is too large, heavy or massive to be contained ordeflective by the barriers, those materials shall be secured as necessary to preventtheir falling.

Scaffolds in pipe racks that require travel between scaffolds shall have walkways of not less than 18 inches wide, except where scaffolds must be used in areas sonarrow that platforms and walkways cannot be at least 18 inches wide, suchplatforms and walkways shall be as wide as feasible and employees on thoseplatforms and walkways shall be protected from fall hazards by the use of guardrailsand or personal fall arresting system. Means of access/egress shall not be more

than 50 feet from the farthest point, per NFPA 101 and 1910.37.

All scaffolds should be tagged. A Red Tag shall indicate that the scaffolding is notsafe to be used. A Yellow Tag shall indicate that the scaffolding can be used withcaution and protection measures implemented (i.e.: 100% Fall Protection).

A Green Tag shall indicate that the scaffolding is safe to be used. Scaffolding maybe green tagged when these scaffolds are built at heights less than 6 feet and builtto green tag specifications. Should a scaffold not be built to green tag specifications,then fall protection will be required with a yellow tag.

Any scaffold, no matter height, that is built next to or within its tipping radius of thehandrail to deck or platform shall be yellow tagged and require fall protection to beworn.

Employee shall follow all instruction and color of the scaffolding tag.

Attachment 1 contains a sample scaffolding tag that can be used. Moreno GroupLLC and Subsidiaries will tag all scaffolding with Yellow Tags requiring 100% fallprotection even though the scaffolding is built to Green Tag specifications.



J15.5

Scaffolding shall be inspected by a competent person prior to each shift or prior touse if the scaffolding has been modified.

Any part of scaffolding that shows any sign of deterioration shall be immediatelyremoved from service.

No loose scaffolding material shall be allowed on any completed scaffold.

Each end of a platform, unless cleated or otherwise restrained by hooks orequivalent means, shall extend over the centerline of its support at least 6 inches.

First line supervision may request a variance to tag a scaffold green when scaffold isbuilt to green tag specifications in those circumstances where there are notappropriate anchor points for fall protection. This variance must be approved by theFacility Manager, Offshore Manager or designee.

Each end of a platform 10 feet or less in length shall not extend over its supportmore than 12 inches unless the platform is designed and installed so that the

cantilevered portion of the platform is able to support employees and/or materialswithout tipping, or has guardrails which block employee access to the cantileveredend.

On scaffolds where platforms are overlapped to create a long platform, the overlapshall occur only over supports, and shall not be less than 12 inches unless theplatforms are nailed together or otherwise restrained to prevent movement.

All planks shall be visually inspected before each use and any plank showing anysign of deterioration shall be removed from service.

All planks used on scaffolds shall be scaffold grade for the species of wood used orequivalent.

All planks used on a scaffold shall meet the requirements of 1910.28 (a)(9) and1926.451 (a)(10).

Scaffolds and their components shall be capable of supporting four (4) times themaximum intended load without failure.

Engineered scaffolds shall be erected in accordance with the engineered drawingand shall not be altered without written consent of the engineer. Engineers shall be

qualified and competent in this field.

Only qualified and competent personnel are allowed to modify scaffolding systems. Any employee who modifies a scaffolding system who is not qualified and competentor working under their direction should be disciplined.

Work shall not be performed on scaffolds during storms, high winds or other weatherhazards as deemed by the competent person.

Scaffold material shall be used according to manufacturer's specs.



J15.6

There are numerous different scaffold combinations; these scaffolds shall be built tothe requirements of these guidelines and the existing OSHA Regulations for thattype of scaffold.

During the erection or dismantling of scaffolds, a fall arrest system will be utilized.The preferred method of tie-off shall be a structural member anchor point with an

attached SRL. In those cases, where an anchor point can not be utilized, scaffoldbuilders shall tie off to the vertical scaffold member rosettes.

When erecting or dismantling scaffolds, workers will erect and dismantle scaffold in10 feet stages to ensure scaffold builders have proper working surfaces (scaffoldboards) and access ladders. When erecting or dismantling scaffolds, workers shallnot work off a bare bar, unless it is impractical, approved by a competent person andidentified in the JSEA.

The throwing of scaffold material (up or down) is not permitted.

The use of leather gloves while working with scaffolds is required.

System Scaffolds

Flight bars shall be installed at intervals between six foot, six inches and seven-footunless otherwise specified by a registered professional engineer or customercompetent in this field.

System scaffolds that are multi-deck shall be built in accordance with 1926.451 © (4)(5) and tables L-10, L-11 and L-12, and 1910.28 (4) (5), D-13, D-14 and D-15.

Engineered systems scaffolds shall be built in accordance with engineereddrawings. Scaffolds may be erected by a plan view sketch drawn by the engineerand may be changed during the building process only with written approval of theengineer. Upon completion of the scaffold, the scaffold shall be inspected and thedrawing made available to the end user.

Scaffolds of unusual design or purpose shall be approved by the engineeringdepartment and/or the safety department.

Tubular Welded Frame Scaffolds

Tubular welded frame scaffolds are available in many sizes, designed for manydifferent uses and shall be erected in accordance with that particular manufacturer’srecommendations.

Tubular Welded Frame erected more than one-hundred twenty-f ive feet (125’) abovethe base plates shall be designed by a registered professional engineer competentin this field.

Engineered Tubular Welded Frame Scaffolds shall be erected in accordance withthe drawing. These drawings shall be readily available for inspection.



J15.7

Tubular Welded Frame Scaffold shall meet the requirements of 1926.451 (d) and1910.28 (d).

Manually Propelled Mobile Scaffolds

Manually Propelled Mobile Scaffolds may be erected with Tubular Welded Frames,

Tube and Coupler, Systems Scaffold or various types of manufactured mobile units.

All Manually Propelled Scaffolds are required to meet the following applicableregulations: 1926.451 (d), Manually Propelled Scaffolds; 1910.29 (A), GeneralRequirements, (B) Mobile Tubular Welded Frame Scaffolds, (C) Mobile TubularWelded Sectional Folding Scaffolds, (D) Mobile Tube And Coupler Scaffolds And (E)Mobile Work Platforms.

All casters on a mobile scaffold shall be equipped with a working brake, shall belockable and shall be locked at all times when not in motion.

Casters shall be rigidly affixed to the legs of the mobile scaffold. The use of droppins, pig tail pins and bolts is permissible.

Mobile scaffolds shall be square and rigid. A horizontal diagonal brace shall beaffixed to the bottom of the scaffold and every third deck thereafter in an opposingdirection. A minimum requirement of two (2) horizontal diagonal braces shall beemployed on all mobile scaffolds.

Mobile scaffolds shall have a ladder or stairway. Ladders shall be on the leastbased dimension side. If a stairway is employed, the scaffold shall have a trap doorin the deck.

The decks of the mobile scaffold shall be tightly planked.

Mobile scaffolds shall be securely braced and maintained plumb.

Mobile scaffolds should only be moved on level surfaces free of holes andobstructions or surfaces that do not exceed 3 degrees.

The force used to move mobile scaffolds shall be applied at the base.

No person shall be allowed to ride a mobile scaffold.

The height of a mobile scaffold shall be no more than four (4) times the minimumbase dimension. California requires three (3) times the minimum base dimension.

Mobile scaffolds more than forty feet (40’) in height shall be designed by a registeredprofessional engineer competent in this field.

System Caster Adapters shall be used on all scaffold systems.



J15.8

Mobile scaffolds shall have the adjustable screwjacks affixed to the scaffold leg insuch a way as not to drop down out of the leg.

Mobile scaffold legs shall be pinned or bolted together to prevent uplift.

Poly or tarps shall not be used to enclose freestanding mobile scaffolds withoutapproval of the scaffold engineering department.

Cantilevers on mobile scaffolds shall not be allowed, unless designed by aregistered professional engineer competent in this field.

Erection of mobile scaffolds on the deck of a platform or barge will be performed ona case by case basis. If an employee requests a mobile scaffolding on either aplatform or barge, Management and the SH&E Department will evaluate thissituation if a mobile scaffolding is warranted. If a mobile scaffold is erected within 6’of a handrail or edge of a barge employee shall wear fall protection, even if the workplatform of the scaffolding is below 6’.

Putlogs and Trusses

Place recommended bracing between putlog/truss no more than twelve feet (12’).

Aluminum Beams

Spans and widths of decks placed on aluminum beams must not exceedmanufacturers’ recommendations. The use of aluminum beams shall be under thedirection of the engineering department. Decorator planks (pick boards) shall not bebridged together by planking to form a deck.

Hanging Scaffolds (Tube and Clamp Systems)

Hanging scaffolds shall meet the Requirements of scaffolding.

The area below a hanging scaffold shall be barricaded.

Training

All employees involved in erecting, dismantling, moving, operating, repairing,maintaining, or inspecting a scaffold shall be trained by a Scaffold Competentperson to recognize any hazards associated with the work in question.

The training shall include the following:

The nature of scaffold hazards

The correct procedures for erecting, disassembling, moving, operating,repairing, inspecting and maintaining the type of scaffold in question

The design criteria, maximum intended load-carrying capacity and intendeduse of the scaffold

Moreno Group, LLC and Subsidiaries Scaffolding Procedure



J15.9

All employees who perform work while on a scaffolding shall be trained by aqualified trainer within the SH&E Department or qualified third party.

The training shall include the following:

Recognize the hazards associated with the type of scaffolding being used.

Understanding the procedures to control or minimize those hazards.

Corrective procedures for dealing with electrical hazards, erecting,maintaining and disassembling the fall protection systems and falling objectprotection system being used.

Proper use of the scaffolding.

Proper handling of material on the scaffolding.

Maximum intended load and the load-carrying capacities of the scaffolding

used.

Training Records shall contain the following:

– Name of employee

– Date of Training

– Signature of Trainer

Retraining

Any time supervision believes an employee lacks the skill or understanding neededfor safe work involving the erection, use or dismantling of scaffolding, the employeeshall be retrained.

Retraining is required in the following situations:

Changes at the worksite present a hazard about which an employee has notbeen trained.

Changes in types of fall protection, scaffolding, falling object protection or

other equipment present hazards about which an employee has not beentrained.





J15.10

Attachment 1





J15.10.a.1

SAMPLE OF SCAFFOLDING TAGS

G R E E N

Y E L L O W

R

E D







Vehicle SafetyPage: 1 of 6Original: 01/01/2001Revised: 04/01/2005

J16.1

Vehicle Safety

Purpose

The purpose of this policy is to promote the safe usage of all Moreno Group LLC andSubsidiaries company vehicles.

Scope

This policy addresses the responsibilities of individuals who drive company vehicles.

All drivers shall exercise Safe Driving Techniques while driving. A safe driver is onewho commits no driving errors and makes allowances for the lack of skill or improper

driving practice of the other party. The driver will adjust his/her own driving tocompensate for unusual weather, road, and traffic conditions. The safe drivershould recognize the need for preventive action in advance and should take thenecessary precaution to prevent the accident.

Responsibilities

The Facility / Site Manager / Transportation Manager or Designee is responsiblefor :

Implementing the provisions of this procedure.

Ensuring that all vehicle operators have a valid operators or commercialdrivers license and insurance card located within the vehicle glove box for thetype of vehicle they will operate.

Ensure vehicle operators complete the Moreno Group LLC and SubsidiariesVehicle SH&E Policy Acknowledgment Form. (see Attachment 1)

Ensuring that all commercial vehicle operators meet the applicable DOT orother regulatory requirements.


Periodically reviewing the driving records of vehicle operators, takingappropriate action to address non-conformance to this procedure.

The Company Vehicle Operator is responsible for:

Complying with this procedure and operating company vehicles safely.



J16.2

Never operating a company vehicle that is unsafe and / or in need of repair.

Performing and documenting scheduled inspections of vehicles they operate.

Keeping assigned vehicle in a clean and serviceable condition.

Advising supervision of any suggestions to improve safety.

Notifying supervision of any incidents or property damage with regard tocompany vehicles.

Requirements

All operators of company motor vehicles must practice safe driving when operatingthose vehicles.

All operators of company vehicles must have a valid, appropriate driver’s license.

The certificate of registration and other required documents, along with company

accident forms should be carried in all company owned vehicles. All accidents shallbe reported to your immediate supervisor as soon as possible (see Attachment 2).

All drivers of company motor vehicles must be familiar with and abide by state,federal and local traffic regulations.

All occupants of the vehicle must wear seat belts.

Equipment on all company motor vehicles must conform to state, federal, andDepartment of Transportation (DOT) regulations.

Picking up hitchhikers is dangerous and PROHIBITED.

Any automotive accident involving a company owned, rented or leased vehicle,major or minor, must be reported as soon as possible to the immediate supervisorand required company, federal and state accident forms must be completed.

A driver should make it a habit to look around the vehicle for potential hazardsbefore entering it and putting it in motion.

When a vehicle is to be maneuvered in confined areas, precautions should be takento ensure that the way is clear and that the driver can see the entire area. If the

driver does not have clear visibility, help should be obtained from someone who hasan unobstructed view.

When possible, park so backing is not required.

If an employee driving a company vehicle should feel drowsy, another qualifiedemployee should drive. If there is no other qualified driver available, the employeeshould not operate the vehicle until capable of doing so safely.



J16.3

Never attempt to perform work or drive a vehicle when you are impaired by alcohol,medication or drugs. Individuals driving Company vehicles shall not be allowedto or transport anyone, who is carrying or possessing Drugs, Alcohol, Firearms or

etc.

Before starting out in your vehicle in the morning, clear all windows of any frost ordew. Cleaning only a small place on a windshield does not allow for adequate

visibility. For vehicle not permanently assigned to an employee, the Daily TruckChecklist shall be completed (see Attachment 3).

Unsafe and discourteous driving practices such as road- hogging, disregarding therights of pedestrians, violating traffic regulations, and deliberate recklessness of anykind are prohibited.

Drivers of automotive equipment operating on company property must adhere to allapplicable traffic regulations.

Getting in and out of a vehicle while it is in motion is prohibited, as is riding

anywhere on the vehicle not designed for passengers. Do not get out of a vehicleand leave the motor running, or drive a vehicle with a door open.

Allowing individuals to ride in the bed of a truck will only be allowed within MorenoGroup LLC and Subsidiaries facilities and not on any roads and/or highways outsideour facility gates. Individuals riding within a bed of a truck must remain seated at alltimes not leaning against the tailgate of the truck or may there be any loose materialin the bed of the truck while employees are riding in the bed of the truck.

Driving at the posted speed limit can be too fast for safety in some situations. Thedriver should use good judgment and proceed at a pace suitable to the conditions of

the vehicle, the road, the traffic and the weather.

Never add gasoline or diesel fuel to the fuel tank of a motor vehicle while the engineis running.

Smoking is prohibited near a vehicle being refueled.

All hazardous materials must be carried in approved containers, appropriatelylabeled and they must contain shipping papers. Flammable liquids or combustibleliquids are not to be carried in trunks of vehicles or within the passenger area of thevehicle.

Except in emergencies, gasoline must not be carried inside passenger cars or thecabs of trucks. When an emergency requires that it be carried in these places, itshould be in an Underwriters Laboratories (UL) approved container that is sealedtight to prevent the leakage of gasoline or gasoline vapors.

It is recommended that cellular phones are not being utilized by the driver whilevehicle is in motion, unless hands free unit has been installed in vehicle.





J16.4

Attachment 1





J16.4.a.1

Moreno Group LLC and SubsidiariesVehicle SH&E Policy

Acknowledgment Form

I hereby acknowledge the following:

1. I understand that safe operation of a company vehicle is a condition ofemployment and I am expected to operate the vehicle safely, courteouslyand responsibly.

2. I do have a valid operator driver’s license.

3. I have read and understood the Vehicle Safety Policy.

4. I am and will continue to be physical fit and mentally alert to operate a

vehicle. Vehicles are not to be operated while under the influence ofalcohol or drugs. If medication that affects my driving ability is taken, Ishall not drive. If an employee suspects that he/she is physicallyincapable of operating a vehicle safely, he/she shall notify theirsupervisor.

5. I will check the vehicle for proper operations and not drive the vehicle ifthere is a reason to believe the vehicle is not safe to drive.

6. I will comply with all regulations applicable to the area in which I will beoperating the vehicle.

7. I will report all accidents as soon as possible to my immediate supervisor.

8. I understand failure to operate a vehicle safely will subject me todisciplinary action.

9. I understand that this form will be filed in my personnel file fordocumentation.

Employee’s Name (Print) ______________________________________________

Employee’s Social Security Number ______________________________________

Employee’s Signature _________________________________________________

Supervisor’s Signature ________________________________________________

Date ______________________________________________________________





J16.5

Attachment 2





J16.5.a.1

C o m p a n y

V e h i c l e

Name of Driver: SSN:

Company Address: Was Employee Injured?

Yes No

Telephone Number:

Home Work

T i m e &

P l a c e o f

A c c i d e n t Date: Time: Location of Accident

D a m a g e t o

V e h i c l e

Company VehicleIdentification Number (VIN):Description of Damage:

D a m a g e t o O t h e r

V e h i c l e

Name of Owner: Address:

Name of Driver: Address:

Telephone Number: License Number of Vehicle:

Description of Damage:

Make of Vehicle: Model: Year:

W i t n e s s e s

Name: Address:

Telephone Number:

Name: Address:

Telephone Number:

O c c u p a n t s o

f

V e h i c l e s

Name: Address:

Telephone Number:

Name: Address:

Telephone Number:

VEHICLE ACCIDENT REPORT



J15.5.a.2

Drivers Description of Accident

Description of Injuries to any Parties

Were Ambulance Services Required? Yes No

Employee’s Name:

Employee’sSignature: Date:

VEHICLE ACCIDENT REPORT



J16.6

Attachment 3





J16.6.a.1

DRIVER'S VEHICLE INSPECTION REPORT AS REQUIRED BY THE D.O.T. FEDERAL MOTOR CARRIER SAFETY REGULATIONS

DATE: TIME: A.M. P.M

TRACTOR/TRUCK NO. ODOMETER READING

Air Compressor Horn Suspension System Air Lines Lights StarterBattery Head - Stop SteeringBody Tall - Dash TechographBrake Accessories Turn Indicators TiresBrakes, Parking Mirrors Tire ChainsBrakes, Service Muffler TransmissionClutch Oil Pressure Wheels and RimsCoupling Devices Radiator WindowsDefroster/Heater Rear End Windshield WipersDrive Line Reflectors OtherEngine Safety EquipmentExhaust Fire ExtinguisherFifth Wheel Reflective TrianglesFrame and Assembly Flags - Flares - FusesFront Axle Spare Bulbs & FusesFuel Tanks Spare Seal Beam

TRAILER(S) NO.(S)Brake Connections Hitch TarpaulinBrakes Landing Gear TiresCoupling Devices Lights - All Wheels and Rims

Coupling (King) Pin Roof OtherDoors Suspension System

REMARKS: ________________________________________________________

CONDITION OF THE ABOVE VEHICLE IS SATISFACTORYDRIVER'S SIGNATURE:

ABOVE DEFECTS CORRECTED

ABOVE DEFECTS NEED NOT BE CORRECTED FOR SAFE OPERATION OFVEHICLE

MECHANIC'S SIGNATURE: DATE:

DRIVER'S SIGNATURE: DATE:



J16.6.a.2

Personnel Van Trip Log

DRIVER ___________________________________________

DATE: ______________________ JOB# ________________

VEHICLE #: ________________________________________

STARTING MILEAGE: _______________________________ENDING MILEAGE: _______________________________

CUSTOMER: _______________________________________ORIGIN: __________________________________________

DESTINATION: _____________________________________

PICK-UP TIME: __________ DROP-OFF TIME: __________WAITING TIME: ____________________________________ _________________________________________________

PRE-TRIP INSPECTIONOIL _______ LIGHTS ______

WATER _______ HORN ______TIRES _______ MIRRORS ______BELTS _______ BRAKES ______SAFETY EQUIPMENT ______WINDSHEILD WIPERS ______





Waterfront SafetyProcedure


J17.1

Waterfront Safety Procedure

Purpose

The purpose of this procedure is to establish a formal process for working nearwaterfronts at Moreno Group LLC and Subsidiaries facilities.

Scope

This is intended to be a minimum standard for Moreno Group LLC andSubsidiaries facilities for the safe work practices and procedures while workingnear waterfronts.

The Facility / Site Manager / Offshore Manager or Designee is responsiblefor :

Provide the needed leadership, commitment, employee empowerment, andhold personnel accountable for the implementation of this procedure.



Notifying of the Marine Chemist to perform a barge evaluation and issuing ofa Gas Free Certificate.

Being knowledgeable of the applicable safety and health regulationsassociated with this program.

The First Line Supervisor is responsible for:


Ensuring that all employees are working safely while waterfront work

operations are being conducted and perform a pre-job check of all equipmentand PPE before work commences.

Conduct pre- job safety meetings and JSEA’s with all affected personnel toidentify scope of work, associated job hazards involved, proper precautionsfor work planned and PPE.



J17.2

If scope of work changes, Stop All Work and relate information to all affectedpersonnel by means of safety meeting and JSEA.

Continually communicate employee’s responsibility to use their Stop Work Authority for unsafe and environmentally unfriendly conditions.

The Safety, Health and Environmental Department or Designee isresponsible for:

Training or coordinating the training of managers, supervisors and hourlyemployees on the Waterfront Safety Procedure.

Issuing of Hot work Permits for all barges.

Periodically auditing the quality of checklists, JSEA’s and safety meetingforms to ensure they reflect safe practices.

Periodic auditing of waterfront work activities to ensure that all applicableprecautions indicated on the JSEA are being implemented and that all safework practices are being followed.

Participating in pre- job safety meetings and JSEA’s on a periodic basis toensure compliance.


Actively participating in the development and review of the Waterfront Safety

Program.

Performing pre-job check of all equipment and PPE to ensure that they are ina safe condition.

Ensuring that all safe work practices are being implemented while performingwaterfront work tasks and report all incidents associated with waterfront workoperations. Employees are also responsible for using Stop Work Authority anytime a condition arises that is potentially unsafe.

Completing assigned activities in a safe manner.




J17.3

Requirements

The Waterfront Safety Procedure is to implement Safe Work Practices andcontrols when working around waterfront locations with employees, material andequipment.

The Facility Manager is responsible for the implementation & enforcement of thisprocedure, as well as other procedures that pertain to the scope of work beingperformed. The SH&E Department shall assist in routine auditing of theprocedure and implementation of the procedure to ensure that the procedure isbeing complied with.

Hazards

The following hazards are found while working around waterfront locations.

1. Falling into waterway from bulkhead locations.

2. Falling off of walkways onto barges that are in slips.

3. Walkways falling off of barges that are not properly secured.

4. Machinery working on barges that have the potential of falling intowaterways.


Methods of compliance that reduce or eliminate the risk of exposure includeEngineering Controls, Administrative Controls, Medical Surveillance, Safe WorkPractices, and Training in the use of Personal Protective Equipment (PPE) andany associated equipment.


Engineering Controls, methods of isolating or removing a hazard from theworkplace, are one of the most effective methods of hazard reduction.Engineering controls should be employed first and, if the hazard remains,personal protective equipment will also be used.

Designated walkways shall be placed on each loadout or load-in barge.This shall be done by the use of scaffold poles or use of 3/8” wire rope sothat all employees working on the structures on the deck of the barge willnot have to don PFT’s.

Temporary handrails shall be posted along the sides of the barge, ifpossible and/or feasible, so that employees working on the deck of the



J17.4

barge will not have to don PFT’s. This shall be accomplished by the useof scaffold poles and/or 3/8” wire rope.

Walkways on all structures in the waterways shall be secured to structurewith the use of two padeyes and shackled to the padeye with the use of

wire rope.

Tarping off of structures being blasted on over or near waterways shall beaccomplished by the following:

o All structures being blasted on while over waterways shall be tarppedoff with scaffold poles and wrapped with blasting tarps. This shall bedone to minimize the amount of material being emitted from blastingoperations.

o Structures shall not be placed within 6’ of bulkhead areas to minimize

any emissions into waterway from blasting operations. Any materialthat is near any bulkheaded area shall be enclosed with blastingscreens to minimize emissions to the waterways.


Auditing of work sites to ensure a safe work area.

Signs shall be posted along bulkheaded areas identifying that nounauthorized employee is allowed within 6’ of bulkheads.

Signs shall be posted 90’ apart and will be posted on poles alongbulkhead.

Signs shall be 36” x 24” in size.

Machinery working on barges shall be accompanied by a spotter. Anytimeany machinery shall be moved on barges, a designated spotter shall be inplace to flag the equipment to prevent machinery from being driven off ofbarges.

Each barge will be evaluated and receive a Gas Free Certificate from a

Marine Chemist prior to any hot work being performed on the barge. Eachday after the evaluation and issuing of the Gas Free Certificate by theMarine Chemist, a gas detection evaluation and hot work permit shall beissued by the SH&E Department or designee prior any hot work beingperformed on the barge.



J17.5


The main type of protection for personnel while working on or around waterfrontlocations is an USCG (United States Coast Guard) approved PFT (PersonalFlotation Device). The PFT shall be used at all times when there is exposure to

employees and where there is a chance of employees falling into waterways.

Rescue Equipment

Employees working on any structure in the waterway shall don PFT’s thatare properly secured at all times.

Life ring buoys shall be posted along bulkheaded areas at 90’ intervalswith at least 45’ of polypropylene rope.

Rescue ladders shall be readily available on all waterfront properties

during work activities being conducted in waterways. These ladders shallbe posted at the point of work activities.

At least one lifesaving skiff shall be immediately available at locationswhere employees are working over or adjacent to water:

1. The skiff must be in the water or capable of being quickly launched byone person.

2. There must be at least one person present and specifically designatedto respond to water emergencies and operate the skiff at all times

when there are employees above water.

3. When the operator is on break another operator must be designated toprovide the requisite coverage while employees are above water.

4. The designated operator must either man the skiff at all times orremain in the immediate area such that the operator can quickly reachthe skiff and get underway.

5. The skiff operator may be assigned other tasks provided the tasks donot interfere with the operator's ability to quickly reach the skiff and get

underway.

6. The communication system, such as a walkie-talkie, must be used toinform the skiff operator of an emergency and to inform the operatorwhere the skiff is needed.

7. The skiff must be equipped with both a motor and oars.







Welding, Burning, CuttingAnd Hot Work


J18.1

Welding, Burning, Cutting and Hot Work

Purpose

To establish procedures for safely conducting welding, burning, cutting and other hotwork activities. To provide a hot work permitting system for high risk facility / siteareas.

Scope

This policy establishes minimum requirements for burning, welding and hot workactivities at all Moreno Group LLC and Subsidiaries facilities.

Responsibilities

The Facility / Site Manager or Designee is responsible for overall programadministration including:

Provide resources to fully implement this program.


Evaluating the safety aspect of these activities as an integral part of pre-planning a job.

Ensuring all employees reporting to him / her who are involved in theseactivities are properly trained and understand the requirements of thisprocedure and the hazards and safeguards involved.

Issuing the Burning, Welding and Hot Work Permit anytime activities arewithin 35 feet of flammable materials (Attachment 1). This includes:

Inspecting the work area

Filling out the permit form

Reviewing the permit conditions with employees involved

Monitoring the work for compliance

Revoking the permit if conditions change that may create hazards

Inspecting the work area when the work is completed and closing out thepermit



J18.2

The Employee involved in hot work activities is responsible for:

Inspecting equipment and the work area before beginning work. Thisinspection should be thorough and any problems should be immediatelybrought to the attention of the supervisor.

Bringing any questions or concerns about the usage and choice of equipmenton the job to the attention of supervision or the Safety, Health andEnvironmental Department.

Following safe practices while performing welding, cutting or brazing. Thisincludes:

Practicing good housekeeping

Wearing proper clothing / PPE including any necessary respiratoryprotection

Reading and following safeguards on Material Safety Data Sheets(MSDS) or product labels as applicable

Posting warning signs or barricades as necessary

Using equipment per manufacturer’s instructions

Following other related procedures such as the Moreno Group LLC andSubsidiaries’ Confined Space Entry Procedure.

Following conditions specified on the Burning, Welding Hot Work Permit

Issuing the Hot Work Permit


Requirements

The following procedures apply to all burning, welding Hot Work activities:

If the object to be welded cannot be readily moved, all movable fire hazards in thevicinity shall be removed. Where practicable, all flammable and combustibles shallbe relocated at least 35 feet from the work site. If the object cannot be moved andall the nearby fire hazards cannot be removed, then guards shall be used to confinethe heat, sparks, and slag, and to protect the immovable fire hazards. If theseconditions cannot be met then welding or cutting shall not take place. A hot workpermit is required before any hot work is done.



J18.3

Fire extinguishers shall be maintained in a state of readiness for instant use. Thetype of extinguisher required is determined by the type of fire hazards nearby.Whenever there are cracks or holes in the floor, nearby windows, open doorways,etc., precautions shall be taken such that no readily flammable or combustiblematerials on the other side shall be exposed to sparks.

Fire watch shall be required whenever welding or cutting is performed in location not

designated as safe welding and burning area. Fire watch shall have fireextinguishing equipment readily available and be trained in their use. They shall befamiliar with procedures for initiating the emergency evacuation procedure in theevent of a fire. They shall only attempt to extinguish a fire when the fire is obviouslywithin the capacity of the equipment available. A fire watch shall be maintained forhalf an hour after the completion of welding or cutting operations to detect andextinguish smoldering fires.

No hot work shall take place without authorization by the Moreno Group LLC andSubsidiaries Supervisor/Superintendent or designated client personnel responsiblefor such operations. This person shall designate specific precautions to be taken in

the form of a written hot work permit.

Any Moreno Group LLC and Subsidiaries Supervisor or designee who is expected toissue hot work permits shall be trained in permit issuing and gas detectionmonitoring.

Hot work permits shall be issued by the supervisor or trained designee. The permitshall only be issued till the end of the shift. Operation shall be stopped if anyconditions or situations occur which is not addressed on the permit.

The Moreno Group LLC and Subsidiaries Offshore Superintendent shall ensure all

MMS requirements are met prior to accepting a Hot Work Permit from a clientrepresentative. These requirements are as follow:

Slag, sparks or other burning materials shall be prevented from contactingequipment which contains flammable in an area within 35 feet of the work orany level below where sparks may reach. Metal shields, flame resistantguards or curtain may be used to prevent contact if the equipment cannot berelocated from the work area.

If hot work is within 10 feet of the well bay, all wells must be shut in at theSurface Safety Valve.

If hot work is within 10 feet of production equipment, tanks or flanged piping,production shall be shut in at the Surface Safety Valve.

If drilling, well completions, workovers, well servicing or wireline operationsare in progress, no hot work will be allowed unless the well contains killweight fluid or the well is plugged and formation hydrocarbon entering the wellbore precluded.



J18.4

Personnel performing fire watch will remain on duty for a period of 30 minutesafter hot work operations have been completed.

Hot work shall not take place in unauthorized areas, in sprinkled buildings while suchprotection is impaired, in the presence of explosive atmospheres or in areas wheresuch an atmosphere may develop, or near large quantities of exposed, readilyignitable material.

Facility / Site Management shall recognize its responsibility for the safe usage ofwelding and cutting equipment by designating an individual responsible forauthorizing cutting and welding operations and by ensuring that cutters and weldersand their supervisors are suitably trained in the safe operation of their equipment.

Also, management must advise all contractors about flammable materials orhazardous conditions onsite of which they may not be aware.

Welding or cutting shall not be performed on used containers such as drums, barrelsor tanks until such containers have been thoroughly cleaned to ensure that nomaterials remain that might ignite or produce toxic vapors. Any pipe lines or

connections to the drum or vessel shall be disconnected or blanked. All hollowspaces, cavities, or containers shall be vented to permit the escape of air or gasesbefore preheating, cutting, or welding. Purging with inert gas is recommended.

Adequate ventilation shall be provided at all times. A number of potentiallyhazardous materials are employed in fluxes, coatings, coverings, and filler materialsused in welding or cutting. These include, but are not limited to, the following:

Cadmium

Fluorides

Hexavalent Chromium

Zinc

Lead

Beryllium

Mercury

In all cases where these or other hazardous materials are present, specialprecautions must be taken. Ventilation usually must be increased, and in no caseshould these fumes be inhaled. Oxygen must NEVER be used for ventilation.

Potential hazards from burning and welding activities must be evaluated and propersafeguards taken. Potential hazards include:

Electric shock, burns, radiant energy, fires and explosions. All precautionsshall be taken to guard against these hazards.



J18.5

High noise levels (over 85 dBA).

Respiratory hazards from fumes, vapors, gases or dusts.

Oil and grease must be kept away from oxygen systems. Gauge connections,valves, etc. must not be coated with oil or grease (oil + oxygen = fire).

Compressed gases shall be used only by experienced and properly trained persons.

When welding or burning in elevated positions, precautions should be taken toprevent sparks or hot metals from falling onto persons or flammable materials below.

Matches and cigarette lighters shall not be carried by welders or helpers whenengaged in burning operations. In dusty or gaseous spaces or if the smell of paint orthinner is very strong and the danger of explosion exists, welding or burningequipment shall not be used until the space is adequately ventilated and theatmosphere has been tested for flammables, % oxygen and toxics.

Gas cylinder shutoff - In order to eliminate the possibility of gas escaping throughleaks of improperly closed valves, when gas welding or cutting, the torch valves shallbe closed and the fuel-gas and oxygen supply to the torch positively shut off at somepoint outside the confined area whenever the torch is not to be used for a substantialperiod of time, such as during lunch hour or overnight. The torch and hose shallalso be removed from the confined space.

Suitable eye protection, guards and clothing shall be worn during welding or cuttingoperations or while clearing scale from walls or boards. A friction lighter orstationary pilot light shall be used to light a torch.

Hoses shall not be repaired with tape but should be replaced.

When welding equipment is not in use, the cylinder valves shall be in the closedposition.

Inspect all leads, grounds, clamps, hoses, gauges, torches, welding machines andcylinders prior to use each day.

Safeguards from the above hazards may include the following:

Proper clothing, aprons, gloves, etc.

Goggles, hard hats, helmets and shields


Local exhaust or forced ventilation

Cylinder handling equipment



J18.6

Hearing protection

Following safeguards on MSDS and product labels

Using equipment per manufacturer’s recommendations

Clothing worn by personnel involved in burning and welding activities should:

Be made of cotton or wool rather than a synthetic fabric

Have long sleeves and button collars

Have no open front pockets or turn-up cuffs

Protective clothing required for welding, cutting and brazing activities may include:

Leather or other suitable gloves (may be insulated)

Aprons of leather or other suitable material

Leggings or high boots (for heavy work)

Safety shoes

Hard hats

Hearing protection

Eye protection is required for both welders and helpers involved in welding andcutting activities. ANSI approved safety glasses with side shields must be worn inaddition to the welder’s helmet with the appropriate shaded lenses or face shield.

Mechanical ventilation must be used when natural ventilation is unacceptable or theconcentration of contaminants is too high for welders and co-workers. Types ofmechanical ventilation include:

Local exhaust (preferred method)

Local forced air (such as a fan)

General area (such as roof exhaust fans)

The manufacturer’s instructions are to be followed for all equipment used in burningand welding activities.

Fire Protection required for hot work activities must be evaluated for each job andprecautions specified on the Permit. The following precautions may be required:



J18.7

Good housekeeping must be practiced

Flammable and combustible materials should be kept at least 35 feet from thewelding, cutting and brazing activities.

Offshore locations requires that producing wells to be shut-in at the surfacesafety valve when hot work is performed within 10’ of production or well bay

areas.

When combustible materials cannot be removed, suitable covering orprotection must be used to protect the materials.

The proper type and size of fire extinguisher should be provided whenevernecessary. Designated Fire Watch must be trained in the use of fireextinguishers and responsibilities of a Fire Watch.

Handling of compressed gas cylinders must be done in accordance with thefollowing rules.

Cylinders must be handled with extreme care to avoid damage to thecylinders and to avoid possible back injuries.

Protective caps must be in place except for cylinders in use which thenshould have a regulator on the cylinder valve.

Cylinders must be secured to prevent upsetting them.

Oxygen and fuel gas cylinders shall not be taken into confined spaces.

Cylinders may be rolled on their bottom edge or moved with hand trucks butnever dragged.

Cylinders or valves must not be modified.

Cylinders must not be used for other purposes such as “rollers”, supports, etc.

Slings must not be used to lift/move cylinders. Bottle racks should be used.

Empty cylinders should be clearly marked as EMPTY.

Never consider cylinders as completely empty or without internal pressure. Always use extreme care when handling cylinders.

Storing of compressed gas cylinders must be in accordance with the following rules:

Cylinders must be secured in an upright position.

Storage areas must be well-ventilated and safe areas reserved only forstorage of cylinders.



J18.8

Flammable or hazardous materials must not be stored in the same area.

Cylinders must not be stored in areas where other work activities maydamage them.

Oxygen cylinders must not be stored within 20 feet of combustible or

flammable materials. If closer than 20 feet, a fire-resistive partition at least 5feet high must be used to separate the cylinders from the materials.

Acetylene and liquefied fuel gas cylinders must be stored (and used) with thevalve end up.

Storage areas should be dry to prevent rusting of cylinders.

Storage areas should be ventilated to prevent temperature over 130°F (54°C). Also, ventilation should prevent the possibility of the accumulation of any gasresulting from leaking cylinders.

Usage of compressed gas cylinders must be in accordance with the following rules:

Cylinders must be used in an upright position and secured from beingknocked over.

The protective cap must be in place when cylinders are being moved or not inuse.

Threads on the cylinder valve and the regulator must be inspected before useand only used if in good condition.

Cylinder valves must be opened slowly.

Cylinder valves should be “cracked” open for an instant to clear the openingof dirt or dust prior to installing the regulator. This should not be done aroundignition sources.

Regulators and pressure gauges should only be used with gases for whichthey are designed and intended.

Repair of cylinders or regulators should be done by the manufacturer.

Cylinders or attachments should not come in contact with sparks, moltenmetal, electric current, excessive heat or flames.

Pneumatic tools must never be operated from compressed gas cylinders.

Compressed gas cylinders must never be taken into an unventilated room,tank or confined space.



J18.9

Gas cylinders must only be used for the purpose intended by the supplier.

Cylinder valves must be closed when the work is finished, the gas releasedfrom the regulator, the regulator removed, and the protective cap installed.

Leaking gas cylinders should:

Be taken out of use immediately

Have the valve closed

Properly tagged & supervision notified.

Warning signs posted as necessary.

The supplier notified and their instructions followed.

Regulators used with compressed gas cylinders must meet with the following

requirements.

Only regulators approved by recognized testing agencies such UnderwritersLaboratories, Inc. or Factory Mutual should be used at Moreno Group LLCand Subsidiaries Facilities / Sites.

Regulators should have both high and low pressure gauges.

Oxygen regulators should have a safety relief valve and safety vent covers onthe high pressure gauge.

Regulator treads should conform to industrial standards. (ANSI / CGA V-1-1987).

Regulators should be clearly marked as to their type of service.

Regulators must always be handled carefully and repaired only by themanufacturer.

Leaky and damaged regulators or regulators showing “creeping” pressurechanges must be taken out of service and repaired.

The pressure-adjusting device should be released whenever regulators areconnected but not in use.

Cylinder valves should never be opened until the regulator is drained of gasand the pressure-adjusting device is fully released.

All regulators shall contain a check valve and a flash back arrestor.



J18.10

Hoses and hose connections used with compressed gas cylinders must meet thefollowing requirements.

Hoses and connections must be properly identified. Color codes for hosesshould be:

Red - fuel-gas hose.

Green - oxygen hose.

Black - inert gas or air hose.

Connection marking are usually as follows:

Std-Oxy for oxygen.

Std-Acet for acetylene.

The following safety rules apply to the use of hoses in welding and cuttingactivities.

Backflow protection shall be provided by an approved device that willprevent oxygen from flowing into the fuel-gas system or fuel from flowinginto the oxygen system. (Follow vendor installation instructions)

Flash-back protection shall be provided by an approved device that willprevent flame from passing into the fuel-gas system. (Follow vendorinstallation instructions)

Do not use hoses that are longer than necessary.

Prevent kinking of hoses.

Prevent hose damage from vehicular or pedestrian traffic.

Repair or replace damaged or leaking hoses at once. (Do not repair withtape.)

Inspect hoses frequently. Test for leaks with normal pressure using asoapy water solution.

Protect hoses from sparks, slag, grease, oil, chemicals, etc.

Torches used for welding and cutting must meet the following requirements.

Only torches approved by recognized testing agencies such as UnderwriterLaboratories, Inc. or the Factory Mutual should be used.

The following safety precautions are to be followed when using torches:



J18.11

The proper torch must be used for the work to be done. Themanufacturer’s inf ormation should be checked.

Before changing torches, the gas must be shut off at the regulator. -- NOTby crimping the hose.

Torches should be lit in a manner which does not endanger personnel,equipment or nearby objects.

A torch should not be put down until it is completely shut off.

Torches should NOT be hung on regulators or cylinders.

Torches must be operated per the manufacturer’s recommendations.

When welding or cutting is to be stopped for some period of time (such aslunch break or over night) the following is required.

All torches shall contain a check valve and a flash back arrestor.

Oxygen and acetylene cylinder valves must be closed.

Torch valves must be opened and all gas pressure relieved from the hosesand regulator.

Then close the torch valves and release regulator pressure screws.

Arc welding and cutting must meet the following requirements.

The personnel using this equipment must be knowledgeable of themanufacturer’s operating instructions and the equipment must be operated inaccordance with the manufacturer’s recommendations.

Welding cables must be inspected frequently and maintained in goodconditions. Defective or damaged cables should be replaced immediately.

All electrical connections should be securely fastened.

Welding cables should be kept orderly to minimize tripping hazards and

should not lie in water, oil or spilled materials.

When arc welding is performed in wet or damp conditions, specialprecautions must be taken to protect the welder from electric shock.

Safety shields or barricades shall be placed around welding jobs whereneeded to protect others from direct rays of electric arc. These direct raysmay cause flash burns and / or eye damage.



J18.12

Electrodes and holders must meet the following requirements.

The proper size holder must be used for the electrode to be used.

Hot electrode holders must NOT be dipped in water.

The following precaution should be taken to prevent electrical shock.

The welder / operator should be insulated from both the “work” and themetal electrode and holder.

The electrode should not contact the operator’s bare skin or wet clothing.

Never change electrodes with bare hands or wet gloves.

The welding unit should be properly grounded.

Keep cables and electrode holders in good condition and clean and dry.

Keep welding cables away from other sources of electrical power.

Never coil or loop welding cables around the body.

First Aid

First aid kits shall be maintained on site at all times per section H, Incident Reportingand Investigation, of this manual.



J18.13

Attachment 1





J18.13.a.1

Moreno Group LLC and Subsidiaries Hot Work Permit

Date:

Start time ofwork

Ending time ofwork

Facility Name

Description of Work

To be Initialed by the Person in Charge Yes N/AWork has been communicated to all affected personnel

Has the equipment been cleaned

Equipment being worked on has been bled to –0- psi andrendered inert

Equipment has been properly isolated (i.e. blinding,disconnected, locked out and tagged)

Flammable or combustible materials in hot work area

removed or shielded.Welding machines are properly grounded, have leadsinsulated.

Oxygen and fuel bottles properly secured, hoses andvalves in good condition & hoses equipped with checkvalves

Appropriate number of Fire Extinguishers Available

Trained Fire Watch designed for entire hot work job and 30minutes after hot work stops

All personnel have been informed about hazards of the job.

Personal Protective Equipment Required for Job Yes or No Yes or No

Hard Hat Safety Glasses

Face Shield Gloves

Steel Toe Boots Protective Clothing

Safety Harness Other:

Initial gas concentrations must be zero percent LEL before any hot work can begin.The fire watch shall conduct continuous monitoring with a portable gas detector.Permit issuer shall document the initial readings below:

LEL %

Oxygen

All Precautions Listed On This Permit Are Understood, Implemented And Wil l Be

Maintained Unti l The Hot Work Is Complete

Person PerformingHot work

Company

Fire Watch Company

Designated Personin charge

Company

Permit Issued By Company





Moreno Group LLC

and Subsidiaries

SH&E Management

System

Safety, Health andEnvironmental Meeting

Page: 1 of 5


Revised: 01/01/2008

K1.1

Safety, Health and Environmental Meeting

Purpose

The purpose of the Safety, Health and Environmental Meeting is to provide amethod of reemphasizing SH&E Training, to encourage feedback, discussion onsafety concerns, perform Job Safety and Environmental Analysis (JSEA) and toreview action items from past investigations.

Scope

Safety meetings are essential to the success of Moreno Group LLC and

Subsidiaries’ Safety, Health and Environmental program. The meetings should beconducted to encourage feedback and discussions from participants.

Responsibilities

The Moreno Group Executive SH&E Team is responsible for:

Leading the development of an SH&E Management System that is relevantand appropriate to the Business Units while focusing on the welfare of theindividual

Communicating expectations for SH&E performance for our organization andstakeholders

Visibly demonstrating our personal commitment to achieve an Injury andIncident Free (IIF) work environment and seeking the same level ofcommitment from the entire organization

Challenging and empowering the Business Units to make SH&E happenthrough personal relationships and teamwork

Ensuring that we have the resources necessary to achieve World ClassSH&E performance

Monitoring the organization’s SH&E performance to ensure we are deliveringon our IIF commitments

Implementing timely mid-course corrections, if necessary

Identifying and benefiting from Lessons Learned from other organizations,and our Business Units

Acknowledging and celebrating group and individual accomplishments



K1.2

Communication SH&E incidents to the Organization and other stakeholders

Providing assistance and support to our Business Unit Teams

Quarterly, as an executive SH&E Team audit a Business Unit’s facility

Discuss, declare and expedite proper course of action for undecidedsystems, procedures, ideas and/or situations identified at Business Unit

Management Teams

The Facility / Site Manager or Designee is responsible for :

Overall coordination and implementation of this procedure.


Conducting and documenting Monthly SH&E Management and First LineSupervisor Meetings

Including SH&E related matters as a specific topic at all safety meeting

The First Line Supervisor / Superintendent is responsible for:

Conducting and documenting safety, health and environmental meetings withtheir personnel on a regular basis.

Conducting and documenting regular tailgate Safety, Health andEnvironmental meetings with their personnel using a Job Safety &Environmental Analysis (JSEA)

Including SH&E related matters as a specific topic at all safety meeting

Jointly performing and periodically reviewing with their personnel Job Safety& Environmental Analysis for current jobs with high risk potential, new orrevised jobs or jobs that have produced serious accidents or Near MissIncidents.

Incorporating the results of JSEA's into applicable Safe Work Practices.


Actively participating in safety meetings, Tailgate Safety, Health andEnvironmental Meetings and JSEA's.

Incorporating the results of the pre-job safety briefings and JSEA's into theirdaily activities.

Advising their supervisor when new or revised JSEA's are needed.



K1.3


Training, or coordinating the training of managers, supervisors and hourlyemployees on conducting safety meetings, tailgate safety meetings / taskhazard analyses and JSEA's.

Periodically auditing the quality of supervisors' safety meetings, tailgate

safety meetings and JSEA's providing constructive feedback as necessary.

Assisting managers and supervisors with the selection of those jobs thatrequire a JSEA.

Participating in the performance of selected JSEA's and reviewing andcommenting on all new or revised JSEA's.

Providing facility / site personnel with safety meeting topics and supportingmaterials.

Requirements

The Moreno Group Executive SH&E Leadership Team is to provide the leadershipto our companies to maintain and demonstrate SH&E as a Core Business Value.Our leadership will be demonstrated through our visible commitment andparticipation within our SH&E Management Systems.

The vision of the Moreno Group Executive SH&E Leadership Team is to provide theknowledge, leadership and resources to our companies that enables them to berecognized and admired worldwide for Safety, Health and Environmental excellenceby all industries and the communities in which we operate. This Executive SH&ELeadership Team is committed to providing the needed support to create a culturethat values an Incident and Injury Free mindset through our personal core values.Our success will consist of each worker going and arriving home safely and healthyat the end of every shift, without damage to the environment and performing ourwork on schedule.

Safety, Health and Environmental Meetings

Moreno Group LLC and Subsidiaries employees are required to attend all Safety,Health and Environmental meetings provided by Moreno Group LLC andSubsidiaries’ Management or Supervision or Customers.

Employees located at Moreno Group LLC and Subsidiaries facilities will be requiredto attend any Safety, Health and Environmental meeting held by the First LineSupervisor (see Attachment 1). At least monthly, a Safety, Health andEnvironmental meeting include refresher training. The Safety, Health andEnvironmental Department will conduct this meeting.



K1.4

Monthly with the assistance from the Safety, Health and Environmental Department,Management will conduct and document a SH&E Management and Supervisormeeting.

Onshore employees will be recertifying their Annual Fitness to Work Certification byutilizing; initialing and signing the Onshore SH&E Meeting Form (see Attachment 1).

Tailgate Safety Meetings

Daily Tailgate Safety, Health & Environmental Meetings are to allow all employeesto discuss the Daily Operation and to evaluate their work environment for safetyhazards.

To prepare employees for the daily operation, the First Line Supervisor orSuperintendent prior to beginning work shall conduct a Daily Tailgate SafetyMeeting (see Attachment 1).

The Tailgate Safety Meeting allows employee(s) and / or supervisor(s) to discuss

the task at hand, hazard(s) associated with the task, elimination of the hazard(s) orminimizing the exposure to the hazard(s) (i.e. Job Safety & Environmental Analysis).

The tailgate meeting which are conducted offshore or off-site shall be documentedon the SH&E Meeting Form.



K1.5

Attachment 1





K1.5.a.1


Meeting Minutes (Offshore)

Date: Individual Facilitating Meeting:Location: Today’s Safety Watch:

Time: Customer:

Meeting Content:

Safety Suggestion or concerns discussed and corrected:

Were PPE, tools and equipment cleaned and inspected? Yes N No

Were any incidents or near misses experienced since the last SH&E meeting? Yes N No

(Initial Next to Signature if You Have Not Experienced an Incident)If yes, explain:

Was a Job Safety & Environmental Analysis reviewed or developed? Yes N No

Name of AttendeesSignature of Attendees

InitialName of

AttendeesSignature of Attendees

Initial





K1.5.a.2


Meeting Minutes (Onshore)

Date: Individual Facilitating Meeting:

Location: Today’s Safety Watch:

Time: Customer:

Meeting Content:

Safety Suggestion or concerns discussed and corrected:

Were PPE, tools and equipment cleaned and inspected? Yes N No

Were any incidents or near misses experienced since the last SH&E meeting? Yes N No(Initial Next to Signature if You Have Not Experienced an Incident)If yes, explain:

Has anything changed from your initial (annual) Fitness to Work Certification? Yes N No

Initial next to signature if your Fitness to Work Certification has not changed, if it has see yoursupervisor to complete a new Fitness to Work Certification.

Was a Job Safety & Environmental Analysis reviewed or developed? Yes N No

Name of Attendees

Signature of Attendees

Initial Name of Attendees

Signature of Attendees

Initial







Safety, Health andEnvironmental Performance

Reviews


L1.1

Safety, Health and Environmental Performance Reviews

Purpose

The purpose of this document is to provide guidance regarding reporting andcommunication of Safety, Health and Environmental Management SystemPerformance results.

Scope

The scope of this program is to provide a system to Moreno Group LLC andSubsidiaries’ management to monitor, measure and manage Moreno Group LLC

and Subsidiaries Safety, Health and Environmental Performance.

The Facility / Site Manager / Offshore Manager or Designee is responsible for:

Hold subordinates accountable for their participation and their employee’sSafety, Health and Environmental performance (See Attachment 3).

Utilize subordinate SH&E Performance Review Score Card duringemployee’s performance review/appraisals

Utilize performance measure both the monthly targets and quarterly

assessments to help establish Safety, Health and EnvironmentalManagement System performance monitoring, measuring and managingmeetings.

Utilize performance measure to assistance during annual Safety, Health andEnvironmental Management System goal and objective meeting.

Develop Monthly SH&E Targets during the Monthly Supervisor ManagementMeeting and/or Leadership Meetings.


Discuss SH&E Performance Review Scorecard and SH&E PerformanceTargets Scorecard at Safety, Health, and Environmental meetings

Understanding and utilizing their Manager’s feedback to improve their SH&EPerformance.



L1.2


Compile and generating the quarterly SH&E Performance Review Score Cardreport for management’s utilization during SH&E Management Meetings(see Attachment 1).

Compile and generating the monthly Month SH&E Performance Targets

Scorecard (see Attachment 2)

Provide support to management with measuring, monitoring and managingSH&E performance

Posting a copy of SH&E Performance Target Scorecard



L1.3

Attachment 1





L1.3.a.1

Moreno Group LLC and Subsidiaries SH&E Performance Measures Scorecard

Divisions

Quarters Quarters Quarters Quarters Quarters

1st 2

nd 3

rd 4

th 1

st 2

nd 3

rd 4

th 1

st 2

nd 3

rd 4

th 1

st 2

nd 3

rd 4

th 1

st 2

nd 3

rd 4

th

Number of SH&E

Meetings

Number ofJSEA’s

Number ofBSP Observations

Number of TeamBSP Observations

Number of Weekly Audits

Number of Monthly Audits

Number of NearMiss Incidents

Number of SH&EIncidents

Number ofEnvironmentalIncidents

Number of WorkGroup Investigations





L1.4

Attachment 2





L1.4.a.1

Moreno Group LLC and Subsidiaries Monthly SH&E Performance Targets Scorecard

Week 1 Week 2 Week 3 Week 4 Totals

Actual Targets Actual Targets Actual Targets Actual Targets Actual Targets

Number of STOP WORKAUTHORITY UsedNumber of BSPObservations

Percent Feedback for BSPObservations

Number of Near MissIncidents

Number of SH&EMeetings

Number of JSEA’s

developed

Number of Team BaseManagementObservations – (2observations per team a

week) Number of Weekly HazardAssessments (I per shop /operating area per week)

Number of ManagementMonthlyHazard Assessments (1 per facility per month)

Number of Pre UseEquipment Inspections(crane, forklift, crawlercrane, personnel basket,etc.)





L1.5

Attachment 3





L1.5.a.1

SH&E PERFORMANCE REVIEW COMMUNICATION PROCESS

DATE OF SH&E PERFORMANCE REVIEW: ___________________________________

SUPERVISOR / SUPERINTENDENT'S NAME: (PLEASE PRINT) ______________________

REVIEWING MANAGER'S NAME: (PLEASE PRINT) ________________________________

JSEA SCORECARD SCORE: ___________________________________________

AREA(S) IN NEED OF IMPROVEMENT ON JSEA'S:

__________________________________________________________________

__________________________________________________________________

__________________________________________________________________

__________________________________________________________________

__________________________________________________________________

WAY(S) TO ADDRESS AREAS IN NEED OF IMPROVEMENT ON JSEA'S:

__________________________________________________________________

__________________________________________________________________

__________________________________________________________________

__________________________________________________________________

__________________________________________________________________

WAY(S) TO ADDRESS AREAS IN NEED OF IMPROVEMENT IN SH&E MEETINGS:

__________________________________________________________________

__________________________________________________________________

__________________________________________________________________

__________________________________________________________________

__________________________________________________________________

SUPERVISOR / SUPERINTENDENT SIGNATUREREVIEWING MANAGER'S SIGNATURE






SH&E ManagementSystems

New EmployeeOrientation/Safety, Health& Environmental Training


M1.1

New Employee OrientationSafety, Health & Environmental Training

Purpose

The purpose of Moreno Group LLC and Subsidiaries’ New Employee Orientation/Safety, Health & Environmental Training is to provide a method that allows MorenoGroup LLC and Subsidiaries to establish an interactive relationship and develop aproper safety culture.

Scope

This program outlines the minimum Safety, Health and Environmental (SH&E)

responsibilities of Moreno Group LLC and Subsidiaries’ Management andSupervision within the New Employee Orientation / Safety, Health andEnvironmental Training process and the requirements the new employee must meetprior to starting work.

Responsibilities



The Yard Foreman / Offshore Manager or Designee is responsible for:

Process new employee per this plan.

Communicate to new employee the job specific requirements.

Arrange employee for New Employee Orientation / Safety, Health andEnvironmental Training (see Attachment 1)

Provide assistance with supporting departments in the proper processing ofnew employee.

Communicating to the new employee their roles and responsibilities as aMoreno Group LLC and Subsidiaries’ employee.

Identify additional training needs for employees underneath their supervision.



M1..2


Providing assistance to the hiring manager in the proper processing of newemployee.

Scheduling and Coordination of new employee to receive required medical

examinations.

Fully review all policies and procedures to new employee, as well ascommunicate company benefit.


Scheduling, Coordinating, Conducting and Documenting the New EmployeeOrientation / SH&E Training.

Providing assistance to the hiring manager in the implementation of this

program.



Conferring with supervision regarding any training not clearly understood.

Communicating to supervision any suggestions to improve the trainingprograms.

Requirements

One of the most important assets for Moreno Group LLC and Subsidiaries is itsemployees. To ensure we protect this asset, all new employees shall receive theMoreno Group LLC and Subsidiaries’ New Employee Orientation and related SH&ETraining.

Offshore New Employees

Prior to going offshore, all Moreno Group LLC and Subsidiaries’ new offshoreemployees shall complete the Moreno Group LLC and Subsidiaries New Employee

Orientation / SH&E Training course (see Attachment 1).

NOTE: The Moreno Group LLC and Subsidiaries New Employee Orientation / SH&ETraining which is identified within Attachment 1 may be required to be shortened bysome subsidiaries, due to the nature of their work environment. If the New EmployeeOrientation / SH&E Training is required to be shortened or changed, the changesmust include all regulatory training and be approved by upper management, prior toany changes occurring.



M1.3

Upon assignment, their immediate Job Superintendent shall be responsible forassigning the new employee to a mentor per Moreno Group LLC and Subsidiaries’Short Service Employee program (see Short Service Employee program).

New Employees for the I & E Division will be required to pass a T-2 Assessmentprior to being hired.

Onshore New Employees

All onshore new employees shall receive at a minimum a General SH&E Orientation,provided by their First Line Supervisor until the next scheduled Moreno Group LLCand Subsidiaries’ New Employee Orientation / SH&E Training is scheduled. Theimmediate supervisor shall be responsible for assigning the new employee to amentor per Moreno Group LLC and Subsidiaries ’ Short Ser vice Employee program.

Prior to a Manager or Supervisor placing a new employee, the New Employee Hiring

Checklist (see attachment 2) shall be completed and filed within the employee’spersonal file located in the Human Resource department.

Training is usually required when:

New procedures and / or equipment are installed

Existing equipment or procedures are upgraded

New methods and procedures are implemented

Existing methods and procedures are revised





M1.4

Attachment 1





M1.4

Moreno Group LLC and Subsidiaries New Employee Orientation / Safety, Health andEnvironmental Training Requirements

New Employee Orientation / SH&E Training Requirements:

History and GoalsMoreno Group LLC and Subsidiaries Orientation (Handbook)

Reporting incidents, Alcohol and Drug Policies, Firearms Policies, Back Injury Preventionand Stop Work Authority

Hearing Conservation Accident Prevention Signs, Tags and LabelsFire Prevention / Portable Fire ExtinguisherWelding, Cutting and Brazing / Fire WatchControl of Hazardous Energy (Lockout/Tagout)Fall Protection

Access to Medical RecordsPersonal Protective Equipment

API RP 2d RiggingElectrical Safety for Non – Electrical Workers

Confined Space Entry (Awareness)Hazard CommunicationHAZWOPER / DOT HM 126f (Awareness Level)Scaffolding (End User)Evacuation PlanBloodborne PathogensHand Injury PreventionJob Safety and Environmental Analysis (JSEA)Behavior Based SafetyOffshore OrientationMarine Debris AwarenessManagement of Change (MOC) Awareness

Spider Work BasketHilti GunFacility SecurityIncident and Injury Free Orientation

SH&E Job-site Specific Training Requirements:

Confined Space Entry and AttendantOffshore Crane per API 2dElectrical Safety for Electrical Workers (i.e. Electricians)ForkliftRCRA (Painters / Blasters)

HUET / Water SurvivalDOT HM 126 F (i.e. Truck Drivers)Mobile Equipment (i.e. Aerial Lift, Cherry Picker, Crawler Crane, etc.)Defensive Driving (i.e. Truck Drivers and Salesmen)Fall Protection Competent Person (Superintendents)Fall Protection Rescue System (Superintendents)First Aid / CPR and Bloodborne Pathogens (i.e. Supervisors and Superintendents)Spill Prevention, Control and Countermeasures (covered facilities)Stormwater Prevention Plan (covered facilities)T-2 Production Safety Systems (i.e. I & E Offshore Division)

Additional Training for Supervisors

First Aid / CPRBloodborne Pathogens

Fall Protection Competent Person / RescueScaffolding Competent PersonMoreno Group LLC and Subsidiaries Safe WorkPractices

Additional Training for Painters and Blasters

Respiratory Protection (i.e. Painters & Blasters)RCRAWaste Minimization

Abrasive Blasting





M1.4

Attachment 2





M1.5.a.1







Short Service Employee(SSE) Program


M2.1

Short Service Employee (SSE) Program

Purpose

This procedure provides Moreno Group LLC and Subsidiaries and its Contractorsguidelines to appropriately supervise, train and monitor new and/or inexperiencedemployees.

Scope

This section applies to all Moreno Group LLC and Subsidiaries employees,contractors and contractors’ sub-contractors on Moreno Group LLC and Subsidiariesor their clients’ locations.

Responsibilities

The Facility / Site Manager / Project Manager / Offshore Manager or Designeeor Contractor Management is responsible for:

Communicate the requirements of this program to the First Line Supervisor /Superintendent / Contractors or Sub-Contractors during Pre-Job meetings.

Ensure Mentor identification form is completed per this program. (OffshoreManager and Contractor Management)

Ensure Moreno Group LLC and Subsidiaries Onsite Representative is notifiedof any SSE.

The First Line Supervision / Offshore Superintendent or Contractor First LineSupervision is responsible for:

Ensure Mentor Identification form is completed and the appropriate mentor isassigned a SSE to train. (Offshore Superintendent & Contractor First LineSupervision)

Ensure Short Service Employee Mentor maintains proper knowledgeable andskills in the particular operations.

Ensure Short Service Employee Mentor is adequately training SSE

Ensure Short Service Employee is gaining the particular knowledge and skillsin the particular operations.

Ensure SSE is appropriately identified per this plan.



M2.2


Providing monthly a list to each operational department of those employeewho have been with the company longer than six months.

The Short Service Employee Mentor is responsible for:

Have the desire, a patient disposition, and be willing to devote the necessary

time to succeed as a mentor

Possess knowledge and skills in a particular contractor operations

Be willing and able to effectively listen to the SSE to determine if the SSE islearning and retaining the knowledge being shared

Be willing to watch a SSE perform a job without interfering as long as the SSEis not in a position to hurt themselves or others or damage equipment

Provide a positive SH&E attitude, avoid criticism, and strive to buildconfidence and self-esteem in the SSE

Be able to teach the SSE the proper way to create a quality JSA and to followthat JSA in performing task

Keep abreast of new equipment in their field of expertise

Refrain from taking short cuts and doing anything hazardous to your health orsafety

Demonstrate a positive work ethic at all times

The Short Service Employee (SSE) is responsible for:

Be willing to watch and listen to the Short Service Employee Mentor

Establish a positive HS&E attitude toward particular contractor’s operations

Participant and learn the proper development of JSEA’s and to follow JSEA'sin performing task

Be willing to gain the knowledge and skill in a particular contractor’s operationto be able to perform in a safe and environmentally sound manner.

Participant in daily Safety Meetings.

Definitions

Mentoring – Mentoring is a process of transferring skills and knowledge from oneperson to another in a work environment. The process relies on a trustingrelationship and can occur between people with varying degrees of experience. The



M2.3

person providing the training is the mentor, and the learner is the Short ServiceEmployee (SSE). Mentoring is recognized as a valuable component of the learningand training process.

Moreno Group LLC and Subsidiaries Facility Manager or Project Manager – TheMoreno Group LLC and Subsidiaries employee who originated the project/jobprocess (i.e. Offshore Manager, Yard Foreman, etc).

Moreno Group LLC and Subsidiaries First Line Supervisor or Superintendent – Individual responsible for the onsite supervision of employees. This individual shalldemonstrate leadership abilities, knowledge and skills within designated operationsto lead and teach personnel.

Short Service Employee (SSE) – Moreno Group LLC and Subsidiaries and / orContractor Employee with less than (6) six months in the same type of job, oremployment with their employer.

Short Service Employee Mentor – Each Short Service Employee (SSE) shall be

assigned a Mentor. This Mentor shall be an employee with at least one (1) yearexperience working experience with employer.

Requirements

Notification

The Moreno Group LLC and Subsidiaries Facility Manager or Project Manager orContractor Management will ensure that the affected Offshore Superintendent isnotified of any SSE on their project/job. This notification shall be through thesubmitting of the “Moreno Group LLC and Subsidiaries Short Service Employee

Notification” form (see Attachment 1) for all offshore employees and contractemployees.

The Moreno Group LLC and Subsidiaries First Line Supervisor, OffshoreSuperintendent or Contractor Management must assign an appropriate mentor tothe SSE before this SSE arrives to a work-site.

The Moreno Group LLC and Subsidiaries Offshore Superintendent or ContractorManagement must document the Mentor assignment on the “Moreno Group LLCand Subsidiaries Short Service Employee Notification” form.

Short Service Employee Orientation Requirements

Contract Personnel

Each Short Service Employee shall be provided a Safety, Health and Environmental(SH&E) orientation upon arrival to Moreno Group LLC and Subsidiaries’ facilities.

Moreno Group LLC and Subsidiaries Personnel



M2.4

Prior to assignment to their designated position, the new employee will receive aGeneral SH&E Orientation by the Hiring First Line Supervisor or Manager. This isdocumented on the “Conditional Job Offer” form. Upon completion of this orientationthe employee will receive an Employee Benefit Orientation from the HumanResource Department. At this point, the employee will be scheduled for nextscheduled “New Employee Orientation / SH&E Training” for their position. All newemployees hired for offshore will be unavailable for their work assignment until theyhave completed their required training.

Those employees whose work assignment is in the office shall receive an OfficeOrientation from their Manager or their Project Manager.

Short Service Employee Training Requirements

Moreno Group LLC and Subsidiaries Facility Manager or Project Manager shall beensure that each Short Service Employee (SSE) is properly trained in:

The hazards present in the work place.

The procedures, processes and personal protective equipment developed toprevent these hazards from causing injuries, properly damage and / orenvironmental incidents, and

The skills necessary to conduct their assigned jobs safely and efficiently whileproviding product quality and economy.

The Facility Manager or Project Manager or particular Contractor Management shallensure that each Short Service Employee (SSE) is properly trained as per Federal,State and Industry requirements before starting work, when:

The employee is first hired

The employee is appointed a new job assignment, and

The employee is exposed to new substances, processes, procedures,equipment, etc. that represent a new hazard to the employee.

Moreno Group LLC and Subsidiaries Facility Manager shall refer to MorenoGroup LLC and Subsidiaries’ New Employee Orientation / SH&E TrainingProgram and the Contractor Management shall refer to the Moreno GroupLLC and Subsidiaries Contractor SH&E Program for minimum facility

requirements.

Short Service Employee Supervision

A “SSE.” sticker must identify each Short Service Employee. This sticker shallbe placed on both the left and right sides of the SSE’s Hard Hat. MorenoGroup LLC and Subsidiaries’ Contractors may use their own method ofidentifying their SSE. Contractor First Line Supervisor will be responsible for



M2.5

informing Moreno Group LLC and Subsidiaries’ First Line Supervisor orOffshore Superintendent of their method to identify SSE.

The Moreno Group LLC and Subsidiaries First Line Supervisor or OffshoreSuperintendent or Contractor First Line Supervisor and the SSE Mentor shallprovide close supervision and not allow the SSE to perform any task in whichthey have not been properly trained. The First Line Supervisor or

Superintendent or Contractor First Line Supervisor and the SSE Mentor shallensure that the SSE understands the task to be performed and theassociated hazards.

Short Service Employee Graduation

Monthly the Human Resource Department will submit to each Department a list ofthose employees who have been with Moreno Group LLC and Subsidiaries forseven months. Employees will no longer be considered a Short Service Employee(SSE) if they meet the following criteria’s:

Employee has been with Moreno Group LLC and Subsidiaries a minimum ofsix months.

Employee has not experienced an OSHA Recordable Incident during theirfirst six months with the company.

Employee has not received any unsatisfactory employee evaluation from theirFirst Line Supervisor.

Employ has not received any disciplinary action for unsafe work activities ornot following company policies and / or procedures.

Documentation

The Moreno Group LLC and Subsidiaries Facility Manager or Project Manager orparticular Contractor Management shall ensure the Moreno Group LLC andSubsidiaries Offshore Superintendent or Contractor First Line Supervisor receives acompleted “Moreno Group LLC and Subsidiaries Contractor Short Service EmployeeNotification Form” prior to allowing SSE on location.





M2.6

Attachment 1





M2.6.a.1

Moreno Group LLC and SubsidiariesShort Service Employee Form

Complete and submit form to the Operator location supervisor for approval prior to arrival on location.The Operator location supervisor (Field Supervisor, Drilling Supervisor, OIM) must approve theindividual SSE before he/she arrives on location.

I. SSE InformationContractor CompanyName:

RequestDate:

SSE Name:

Date ofEmployment: Current Job Title

Years Oil FieldExp

Experience in CurrentPos Yrs

Mos

Is this employee in compliance with your Substance AbusePolicy?

Yes

No

Have site contractor and SH&E policies been reviewed with SSE?Yes

No

Who has been assigned as the SSE’smentor?

Mentor’s Experience: Yrs Mos

List all training provided to the SSE: List any previous special training:

SSE(s) identifiedby: Hard Hat – Hi Vis Orange

II. SSE Crew Composition Requirements

Choose one of the crew types below

Single person crew – cannot be an SSE

2 – 4 person crew – no more than one SSE

5 or more person crew – no more than 20% SSE(s) per crew

Exceeding 20% SSE per crew

III. SSE Review and ApprovalMoreno Group LLC andSubsidiaries’ Manager: Date





Moreno Group LLC

and Subsidiaries

SH&E Management

System

Subpart O Training PlanPage 1 of 9


Revised: 05/1/2009

M3.1

Subpart O Training Plan

Purpose

This plan defines the training program for Moreno Group LLC and Subsidiariesemployees and contractors engaged in Production Safety Systems and fulfills therequirements of 30 CFR Part 250, Subpart O to provide and implement a writtentraining plan for Production Safety Systems.

Scope

This program is for all employees of Moreno Group LLC and Subsidiaries who areassigned to perform or supervise production operations (installation, repair, testing,

maintenance, or operation of surface or subsurface safety devices) [authorizedemployees]. It prescribes the type, methods, length, frequency, and content oftraining required, to be successfully completed, by all such employees.

Responsibilities



The Offshore Manager or Designee is responsible for:

Process new employee per this plan.

Determine if Production Safety Systems Training is required.

Coordinate Production Safety Systems Training with Approved Vendor forNew Hire employees who need training.

Issue Pre-Qualification Test to New-Hire employees who have currentProduction Safety Systems Training.

Grade Pre-Qualification Test and if a passing score, make copies of TrainingCards and provide to SH&E Department. If a failing score, coordinate

Production Safety Systems Training with Approved Vendor.

Evaluating employees on an annual basis to ensure employee competencyand perform Pre-Test on employees on an annual basis.



M3.2


Evaluating and approving Training Vendors.

Providing assistance to the hiring manager in the implementation of thisprogram.

Record-keeping for all training documentation related to this plan.

Evaluating this plan to ensure compliance.



Conferring with supervision regarding any training not clearly understood.

Communicating to supervision any suggestions to improve the trainingprograms.

Goal

The training plan’s goal is to promote safe and environmentally sound OuterContinental Shelf (OCS) operations. This plan will ensure that Moreno Group LLCand Subsidiaries personnel engaged in production safety systems operations willunderstand and can properly perform their duties.

Overview

Competency will be determined for Moreno Group LLC and Subsidiaries employees[authorized employees]. Employees who are designated as authorized personnel toperform duties associated with installation, repair, testing, maintenance, or operationof surface or subsurface safety devices (production safety systems), will have theircompetency evaluated. Authorized employees will have their specific dutiesexplained and have completed appropriate portions of the program, prior to theirperforming any well control, well servicing or production safety system duties.

In order to reach all types of learners and assure the best retention for productionsafety system information and practices, we propose to use various presentationmedia and methods such as:

Pre-testing of employees to determine deficiencies, to target learning needs

Instant scoring of pre-testing

Pre-instruction course goal setting with employee

Face-to-face instruction



M3.3

Off-site and on-site reading materials

Off-site and on-site hands-on, group and individual instruction

Off-site and on-site hands-on, group and individual practice

Specific vendor and/or equipment manufacturer supplied operationalinformation, including hands-on instruction, as appropriate

Operating process models of production, control and safety equipment

Pictorial representations and drawings of operational equipment, processes,and methods of operation

Case studies and MMS Safety Alert publications

Face-to-face and other means of evaluation of hands-on activities

Written examinations consisting of scrambled questions, so tests are differentfor each employee

Scoring of all examinations

Advise employee of examination results, immediately, to target additionallearning opportunities

Set date, location and other specifics for next evaluation or course

Employees

New Hire employees who have a Production Safety Systems (T-2) certificate ofcompletion from a third party training company will be required to take a pre-qualification test (See Attachment 1) and have a score of 80%. That employee willthen be considered an authorized employee. If the employee does not have aProduction Safety Systems (T-2) certificate of completion from a Moreno Group LLCand Subsidiaries recognized training vendor, he/she will be required to complete abasic (T-2) course (3 days) before being designated as an authorized employee.Each authorized employee will have their T-2 knowledge and skills evaluated atleast once every 12 months for those duty areas that he/she is responsible.

Production Safety Systems (T-2) knowledge and skills will be evaluated at leastonce every 12 months for those duty areas that he/she is responsible.

Training Outline for Production Safety Systems / T-2

Elements of the Course: Training will include:

The effect of the four variables: flow, pressure, level and temperature in controllingfor production of oil and gas.



M3.4

The eight undesirable events and how they effect safe production:

Over pressure

Underpressure

Liquid overflow

Gas blow-by

Leak

Excess temperature in a fired component

Direct ignition

Excess combustibles in a firing chamber

What a process safety system is and how its works.

Definitions and terminology of terms used in the offshore environment.

What an emergency support system is and what it does.

What type devices are used to protect us from these undesirable events.

Level Safety High/Low

Pressure Safety Hi/Low

Pressure Safety Valve

Flow Safety High/Low

Shut down and Blow down valves

Surface Safety Valves

Flow Safety Valve

Temperature Safety High/Low

Burner Safety High/Low

Subsurface Safety Valves

Gas Detection equipment



M3.5

Other Support systems covering containment, fire loop, other fire detectionand prevention equipment, and facility machinery, such as offshore cranes,compressors, pumps, generators, chemical injection, and flaring equipment.

How to use the API-14C in determining what safety devices that will be needed toprotect us from these events and where they need to be located. The testingrequirements and tolerances. The categorizing of all process components. Primary

and Secondary protection. Limitations, malfunction, and failures of safety devices.

How to fill out a “Safety Analysis Function Evaluation” chart and what its use is.

How to used the Safety Analysis Checklist.

How to identify safety devices and components and what symbols are used toindicate these on required drawings.

What the Emergency Support System is and what it does.

30 CFR Rules and regulations concerning the safe production of oil and gas inO.C.S. waters. Pollution prevention, waste requirements, and reportingrequirements.

Hands on & classroom lessons on actual safety devices.

How to read flow diagrams and pneumatic schematics.

Proper record keeping and procedures as associated with their forms.

Government inspection criteria and associated pinc list for references on

guidelines of inspections.

Teaching and Presentations Methods:

Method used during the course will include a presentation layout that follows theformat of the training manual.

Methods used include a computer presentation projected on a television set, wherethe trainee follows along in the manual. Presentation will be supported by verballecture. Class participation is encouraged and trainees are encouraged to askedquestions during all phases of the course.

During the course progression, slide projection will also be used as additionalsupport to the subject matter. Discussion of the slide projection will also beencouraged. Additional handout material is used on some of the presentationprocess, along with and slide projection to support the areas being discussed.

The course incorporates 4 (four) learning aides. Lecture (verbal), PowerPoint(visual), slide projection (visual, verbal, and written) and Handouts (written, whichincludes practice worksheets).



M3.6

During discussion of pressure safety device set points and tolerance, which requiressome math skills, worksheets are handed out for additional exercise purposes.

Hands on training is done is small groups. Usually an experienced trainee is groupwith a less experienced trainee.

Any “tricks of the trade”, or “lessons well learned”, is encouraged and passed on tothe less experienced trainee. Class discussion of these “lessons” shows humanerror, malfunctions, failures or other possible causes of safety device problems.

Training guidelines now follows “option 2” of the new Subpart “O” as per 30 CFRSubpart 250.1500.

Employee Competency Verification

All authorized employees will be given the Pre-Test, which will be a timedexamination of multiple choice, true / false and hands-on questions and/or cases

which will be of sufficient length to confirm the employee’s competency.

All authorized employees will take the basic training final competency examinationwhich will be a timed examination of multiple choice, true / false and hands-onquestions and/or cases which will be of sufficient length to confirm the employee’scompetency and understanding of the topics covered. The examination will bedesigned so the probability of like examinations will be reduced. A test score of80% or greater will be required for successful completion. Each Moreno Group LLCand Subsidiaries employee must have successfully completed examinations or“practicals” for those duty levels for which he/she is responsible, before assumingthe authorized employee duties. If the authorized employee misses any portion of

the session, the missed instruction time must be completed prior to the beginning ofthe final examination.

Employees will be required to solve practical operational case studies includingperforming prescribed hands-on operations, either as a “pre-test” or uponcompletion of a formal training session. In some cases, the authorized employeemay be asked to demonstrate the correct operation(s) and/or “practicals”, withoutactually performing the operation(s), to assure workplace safety.

Internal Audit of Authorized Employee’s Production Safety Systems Training

Moreno Group LLC and Subsidiaries will use internal auditing or third party auditorsto audit our Production Safety System Training Program annually. These auditsmay include the following:

Audit of training program and plan for applicability with current operations andregulatory requirements.

Audit of instructor credentials



M3.7

Audit of course and contents

Audit of text

Audit of classroom facility and laboratory

Audit of teaching methods

Audit of testing methods, including hands-on testing

Audit of practical operations testing and performance standards

Audit of attendance, training and completion records

Audit of the authorized employee’s safety performance

Audit of our company’s safety performance standards and records

Audit the scheduled date for the authorized employees’ Production SafetySystem evaluation.

Record keeping and Documentation

A dated record of the authorized employees’ attendance, written and hands-on testscores/ rating will be prepared and signed by the instructor upon completion of thecourse. These records will be maintained for 5 years at our primary training agency.

A copy of the completed course outline and the completed course text will be

maintained for 5 years at our primary training agency.

The date of the next competency determination for the authorized employee will bedetermined and available for inspection by internal and/or external auditors.

MMS or its authorized representatives may audit and test employees to ensurecompetency and compliance with this training program.

Only the training methods listed in this program will be utilized. There will not be anyalternative training methods utilized.



M3.8

Designated Training Agencies

J. SCHNEIDER & ASSOCIATES, LTD.325 Industrial ParkwayLafayette, LA 70508Phone: (33) 237-9486

Training and Compliance ServicesRocky DuplichanPhone: (337) 457-2497Fax: (337) 457-0034

Natco Group Education Centers1010 Highway 90 WestNew Iberia, Louisianaor other Natco Group Education Center locations

Phone 337-365-9228 Telefax 337-365-8135

Occupational Safety Training, Inc.1209 Tool DriveNew Iberia, LA 70560Phone 337-365-6595Fax 337-365-7879Contact: Bryan Aucoin



M3.9

Attachment 1





M3.9.a.1

Name ___________________________________ Date ____________________

Production Safety Systems Pre-Qualification Test / Pre-Test

1. An abnormal operating condition

a. causes an ESDb. is detectablec. occurs in a process component when an operating variable ranges

outside of its normal operating ranged. may be a flow safety

2. An abnormal operating condition that can be automatically detected is a

a. detectable abnormal conditionb. process shutdownc. vacuum

d. vent

3. What is the detectable Abnormal Condition for Liquid Overflow in a pressurevessel?

a. High Levelb. High Pressurec. High Temperatured. High Fuel

4. What is the detectable Abnormal Condition for Direct Ignition Source (hot

surfaces)?

a. High Temperatureb. Low Temperaturec. High Leveld. Low Pressure

5. What is the Detectable Abnormal Condition for Under Pressure in anatmospheric vessel?

a. Low Level

b. High Pressurec. Low Temperatured. Low Pressure



M3.9.a.2

6. What Undesirable Event is indicated by high pressure in a pressure vessel?

a. High Levelb. Over Pressurec. High Temperatured. Low Pressure

7. High temperature is the Detectable Abnormal Condition for

a. Low Air Flowb. Over Temperaturec. Direct Ignition Source (natural draft)d. Low Level

8. The Primary and Secondary protection for a leak in an atmospheric vessel is

a. LSL and PSL

b. LSH and ASHc. LSL and TSHd. LSL and ESS

9. What is the Primary and Secondary protection for Liquid Overflow (pressurevessel)?

a. LSH and PSLb. ASH and ESSc. LSH and PSHd. LSH and Downstream Devices

10. The discharge of gas from a process component through a liquid outlet iscalled

a. Liquid overflowb. Low liquidc. Gas discharged. Gas blowby

11. The Primary and Secondary protection for Under Pressure (pressure vessel)is

a. Gas Make-up System and PSHb. PSL and LSLc. LSH and Gas Make-up Systemd. Gas Make-up System and PSL



M3.9.a.3

12. What is the Primary and Secondary protection for Under Pressure(atmospheric vessel)?

a. PSV and Gas Make-up Systemb. PSL and PSVc. Gas Make-up System and PSH

d. Vent and 2nd (vent)

13. The Primary and Secondary protection for excess temperature (stack) are

a. TSH (stack) and Low Flowb. TSH (stack) and ESSc. TSH (medium) and BSLd. None of the above

14. Improper performance of a device or equipment item that preventscompletion of its design function is called a

a. shutdownb. failurec. fire loopd. back flow

15. Any condition of a device or an equipment item that causes it to operateimproperly, but does not prevent the performance of its design function is

a. under pressureb. process shutdown

c. malfunctiond. platform safety system

16. Which of the following contains an item that is NOT one of the eightundesirable events?

a. Over Pressure, Leak, Liquid, Overflowb. Gas blowby, Under Pressure, Vacuumc. Direct Ignition Source, Excess Temperatured. Excess Combustible Vapors in the Firing Chamber (firing component)

17. When testing with a hand pump, why is it important to reduce pressure usingthe bleed off needle valve instead of using the pump vent valve?

a. Reduce the risk of bringing debris into the pump valveb. Protect the pump from being pressuredc. Both a and bd. None of the above

18. What step(s)should be completed before moving a nitrogen bottle



M3.9.a.4

a. Bottle emptiedb. Capped and secured upright to a dollyc. Remove cap and attach test manifoldd. Bleed down to manifold

19. Piping that directs the well stream from the process well head to the firstdownstream process component is known as

a. Vent Systemb. Flowlinec. Sensing Lined. Header System

20. The highest operating pressure allowable at any point in a pipeline systemduring normal flow or static conditions is the

a. Minimum operating pressureb. Maximum allowable operating pressure

c. Over pressured. Containment

21. Flowlines are equipped with high and low-pressure sensors. But in all cases,the high pressure shut in sensor shall be set

a. Above the maximum well head shut in pressureb. At the same pressure as the maximum well head shut in pressurec. Sufficiently below the maximum well head pressure to insure activation

of the SSVd. None of the above

22. The high pressure shut in sensor located on a pressure vessel should be set

a. 10% above the highest operating pressure of the vesselb. 20% above the highest operating pressure of the vesselc. 5% or 15 psi above the highest operating pressure of the vesseld. 15% or 5 psi whichever is greater, above the highest operating

pressure of the vessel

23. At what pressure should the manifold be when switching from test tooperate?

a. 20% of vessel operating pressureb. 80% of vessel operating pressurec. Current operating pressure of the vesseld. PSH/L set point



M3.9.a.5

24. What is Dead Band?

a. The difference between pressure at the beginning and end of the testmanifold

b. The difference between a sensor’s actuation point and it’s reset point. c. The difference between PSH and PSL readings

d. A punk rock group

25. When conducting a PSH/L test, why should pressure be increased andreleased slowly?

a. To get more accurate readingsb. To protect the pressure gaugec. To protect the system from pressure shockd. All of the above

26. If a quick connector will not plug into the test panel, you should

a. Oil the connectorb. Bleed off the pressure and check connector for debrisc. Push harderd. Use pliers

27. When testing a system with a PSH of 1150 and a PSL of 850, you should usea gauge with a range of

a. 0 – 1,000 psib. 0 – 5,000 psi

c. 0 – 3,000 psid. 0 – 1,500 psi

28. The Surface Controlled Subsurface Safety Valve (SCSSV) shall close in notmore than ______________ after the closure of the closure of Surface SafetyValve (SSV).

a. 45 secondsb. 1 minute 45 secondsc. 2 minutesd. None of the above

29. During a Platform Process Shutdown, which valve(s) will automatically closeon each flowing well?

a. Surface Safety Valve (SSV)b. Surface Controlled Subsurface Safety Valve (SCSSV)c. Manual Wing Valved. Crown Valve



M3.9.a.6

30. A control system that monitors the concentration of combustible gases andinitiates an alarm and shutdown function at predetermined concentrations isknown as

a. Direct Ignition Systemb. ESP Systemc. Fusible System

d. Gas Detection System

31. Fuel or power for firewater pump drivers shall be available for at least _____minutes of run time during platform shut in.

a. 15b. 25c. 30d. 60

32. The test interval for SCSSV’s is

a. Every 3 monthsb. Monthlyc. Annuallyd. Every 6 months

33. The test interval for SSV’s and USV’s is

a. Annuallyb. 6 monthsc. Monthly

d. None of the above

34. The test interval for SDV’s and BDV’s is

a. Quarterlyb. Weeklyc. Monthlyd. Daily

35. The test interval for LSH/L’s is

a. Dailyb. Weeklyc. Bimonthlyd. Monthly



M3.9.a.7

36. The test interval for ASH is

a. 30 daysb. Semi annuallyc. Every 3 monthsd. Monthly

37. The test interval for PSV’s is

a. annuallyb. Semi annuallyc. Quarterlyd. Monthly

38. What is the test interval for flowline FSV’s?

a. Annually

b. Dailyc. Weeklyd. Monthly

39.What is the test interval for ESD’s?

a. Annuallyb. Dailyc. Weeklyd. Monthly

40. The lessee for each surface and subsurface device shall maintain records fora period of

a. 5 yearsb. 2 yearsc. 1 yeard. 7 years

41. Offshore platforms in federal waters of the Gulf of Mexico are regulated bythe U.S. Department of the Interior through the

a. Environmental Protection Agencyb. Minerals Management Servicec. Texas Railroad Commissiond. Housing and Urban Development

