1 Procedure No.: CTC-SAF-006 Page: 1 of PURPOSE To establish requirements for a Personal Protective Equipment (PPE) program for the Charlotte site. This program is to include selection, supply, use, and maintenance of PPE equipment. 2. DEFINITIONS 2.1. Immediately Dangerous to Life or Health (IDLH) represents the maximum concentrations of a chemical from which, in the event of respirator failure, one could escape within 30 minutes without a respirator and without experiencing any escape-impairing or irreversible health effects. 3. SCOPE This procedure applies to the BASF Charlotte site and all personnel utilizing personal protective equipment. 4. PROCEDURE 4.1. General Requirements A hazard assessment will be performed to determine the need and selection of PPE. The hazard assessment will identify the work area, person certifying assessment, the positions of people assigned to work in that area, the date of the hazard assessment, and the PPE required for the area. PPE needs will be reviewed annually The use of PPE will be written into standard operating procedures and/or JSA's PPE required for use by site personnel will be provided by BASF. A corporate catalog of approved PPE and suppliers is available for use to sites. Protective equipment must be approved and/or specified/reviewed for the particular work by BASF supervision/ehs. All PPE must meet the required ANSI, OSHA, and/or NIOSH standards. Contractors are responsible for supplying the PPE needs of their employees All PPE shall be maintained and worn in the prescribed manner. Damaged or defective PPE shall not be used. PPE shall all be properly fitted prior to use.
2 Procedure No.: CTC-SAF-006 Page: 2 of Training Initial Training A. Charlotte site personnel shall receive on the job PPE training, prior to using PPE. PPE classroom or computer based training records will be maintained in the Learning Management System (LMS). The training will cover when PPE is necessary, what PPE is necessary, PPE limitations, PPE inspections prior to use, PPE wearing / fit, proper PPE care, proper decontamination (if applicable), and demonstration of understanding. B. Laboratory personnel will receive periodic PPE training, based on EHS curriculum, which will be documented through the LMS system Demonstration of Understanding A. Each employee requiring the use of PPE will demonstrate an understanding through the use of a Question & Answer quiz or by showing competency. Certification can be through LMS Retraining A. Retraining for employees will occur periodically, or if there are changes in the workplace that make previous training obsolete, or if personnel demonstrates a lack of competency in using the PPE properly Eye and Face Protection General Requirements A. Each Charlotte person will use the appropriate eye and face protection when exposed to eye and face hazards: from flying particles, pointed objects, molten materials, liquid or vapor chemicals, light radiation, electrical hazards, etc Safety Glasses and Contact Lenses A. Safety glasses with side shields will be worn in all designated areas to prevent eye injuries from flying objects/droplets/splashes. At the Charlotte site, these areas are the laboratories, Maintenance Shop
3 Procedure No.: CTC-SAF-006 Page: 3 of 11 Area during work, monomer shed and the waste chemical storage areas. Safety glasses must meet the specifications of ANSI Z87.1. Contact lenses are allowed in the office areas and in the forementioned designated safety glasses areas with prior approval of supervision/safety and notification to the First Aid Team. If a contact wearer sustains an eye injury, initial eye irrigation should be immediately performed using a primary eyewash station. Flush the eyes continuously for a minimum of 15 minutes until a first responder arrives at the scene. If the individual can remove their contact lens easily, they should do so. If unable to remove contact lens then medical personnel should be informed upon arrival Goggles and Face Shields A. Selection A.1. Exposure to thermal hazards such as liquid nitrogen, chemical splash hazards such as mixing chemicals, or flying particles such as the use of grinding equipment, require the use of eye and face protection. All eye and face protection must meet ANSI Z87.1standards. B. Use Specification B.1. Use of face shield and goggles will be written into JSA (Job Safety Analysis sheets) where appropriate and may be required when working with hazards such as but not limited to those listed in A.1 above Welding Protection A. Maintenance personnel engaged in or helping with welding-type operations, where light radiation may cause injury to the eyes or face, must use welding helmets that have lenses with a shade number appropriate for the work being performed. Refer to the table in 29 CFR (a) (5). These welding helmets will also meet ANSI Z87.1standards Respiratory Protection General Requirements
4 Procedure No.: CTC-SAF-006 Page: 4 of 11 A. Respiratory protection shall be used to maintain employee exposures below permissible exposure levels when: (1) engineering controls, such as ventilation, and work practice controls are not feasible. (2) While engineering controls are being installed. (3) During maintenance or emergency activities which are extraordinary to normal operation. B. Contractors are responsible for providing respiratory protection equipment and the required medical monitoring, fit-testing, training and record-keeping for their employees Charlotte Requirements A. BASF will supply all required respirators provided need is established, the user is medically cleared, and the respiratory protection is fit-tested. The user must be trained for use and maintenance of the respirator. This training must be documented. Respiratory devices worn for comfort or voluntary purposes must be approved by supervision and EHS, with clearances and training based on device type. B. Selection of respiratory PPE will be based on potential chemical exposure, and concentrations. No respirator shall be used in any environment that is immediately dangerous to life and health. No respirators will be used for protection from chemicals or chemical concentrations for which they were not designed. Chemical suitability will be based on respirator design and manufacturer data. A document certifying the respirator suitability, from the manufacturer, will be given to the user and also filed in the safety office. The presence and concentration of chemicals will be verified by actual monitoring data. Respirators and SCBA's (Self- Contained Breathing Apparatus) are not in required use for exposure control in Charlotte. C. NIOSH-approved dust masks are provided to employees upon request for comfort purposes. Dust masks here are defined as non-elastomeric, cloth or paper construction, protection from nuisance dusts. Medical and fit evaluations are not required. Users are required at dust mask issue to read and sign a copy of OSHA standard 29 CFR , Appendix D. A copy of this signed document will be filed in the safety office. Where air
5 Procedure No.: CTC-SAF-006 Page: 5 of Head Protection supplied devices are used for comfort purposes, Appendix D will still be signed. D. Issued respirators must be inspected monthly by the users. If the respirator is used during the month, it must be washed with soap and water, the cartridges replaced, and stored in a clean, plastic bag. If the respirator is not used, it may be swabbed out with a cleaning wipe, inspected, and returned to a clean, plastic bag. Respirators with defects found during the monthly inspection will be replaced. Respirators will be fit-tested annually, where required. Personnel using air supplied devices for comfort purposes will still be required to monitor the equipment and will track monthly inspections of personal devices. E. The use of respirators at the Charlotte site, in accordance with health assessment procedures, will be investigated and documented (if use is initiated) annually Selection A. Based on the hazard assessment, hard hats will be worn in areas and for tasks as necessary where there is a reasonable potential for injury to the head from falling, or swinging objects and / or electrical shock Specifications 4.6. Foot Protection A. All hard hats issued must meet the specifications of ANSI Z89.1. Hard hats constructed of aluminum alloy will not be issued or used Selection A. Laboratory, Shipping & Receiving, and Maintenance areas are designated as safety shoe recommended areas, where safety shoes are recommended for personnel assigned to work in those areas. For job tasks that are known foot hazards such as moving gas cylinders, heavy equipment, etc., safety shoes are required during performance of the task. Visitors to these areas who are not assigned to work in these areas, and who are not exposed to any
6 Procedure No.: CTC-SAF-006 Page: 6 of 11 potential foot injury while visiting these areas, are not required to wear safety shoes. All Charlotte personnel who are exposed to potential compression/puncture foot injury during job tasks are required to wear safety shoes. Open toed or open heeled shoes (such as; sandals, sling backs, slides), open or mesh topped shoes, and other footwear that does not fully cover the foot are not allowed when working in the maintenance, shipping, or laboratories areas, in order to protect against chemical spills. Shoes worn in labs should be made of materials resistant to penetration by chemicals, ex. leather or suede as opposed to canvas or mesh(which quickly absorbs or allows pass through). High heeled shoes with heels longer than 2 ¼ are not to be worn while working in labs, as protection against trip/falls. Safety shoes are required for designated lifting & moving purposes, as protection against impact injuries. The site PPE grid lists additional details regarding required laboratory footwear tasks Specifications 4.7. Hand Protection A. All safety shoes issued must meet the specifications of ASTM F 2412, F 2413 (previously ANSI Z41) Selection A. Gloves must be selected and worn to protect against the specific hazard the gloves are designed to protect against. Hazard Type Examples: Skin absorption of harmful chemicals, cuts/abrasions, punctures, thermal burns, and electrical burns. Site glove chart can be used for guidance. Before use, gloves should be inspected for evidence of degradation, pinholes, and punctures that may cause penetration of harmful chemicals. B. Selection of the proper glove shall be based on chemical compatibility with the chemicals involved, contaminant penetration, physical durability, and dexterity requirements. The glove should match the hand size, noting that too small of a glove will cause stretching of material and may compromise integrity of glove, while too large of a glove will decrease tactile response due to excessive glove material. A glove chart containing glove type vs. application
7 Procedure No.: CTC-SAF-006 Page: 7 of 11 information is located under Safety section of the shared Y:Drive. C. When handling hazardous chemicals, gloves should be used as splash protection and not as immersion protection. If hazardous chemicals contact the gloves then they should be immediately rinsed off and removed before permeation to the skin can occur. This should be done immediately after rinsing if permeation rate for the chemical is insufficient or unknown Electric Hazards A. Maintenance personnel should direct all electrical work. High voltage/amp work will be performed by contractors properly trained and fitted with appropriate electrical rated PPE. These contractors will use hand protection specified for protection against electrical hazards Protective Clothing Selection Use 4.9. Hearing Protection A. For each task described in a JSA (Job Safety Analysis), the hazard analysis portion of the JSA will be used to determine the appropriate type of protective clothing to be worn. A. Protective clothing shall be worn so that it provides the protection for which it was intended. Closures shall be used and the clothing shall not be cut or otherwise modified. Charlotte lab personnel are provided with long sleeved lab coats, which are laundered by a service. Lab aprons are provided based on need. Special protective clothing, such as walk-in freezer cold gear is provided to affected persons only, after safety approval Determination of Hearing Protection Need A. Areas where noise problems are recognized will be monitored for noise levels. Site Safety will maintain monitoring data. This may include operating all machinery in the area to create a worse case
8 Procedure No.: CTC-SAF-006 Page: 8 of Hearing Protectors Fall Protection scenario for entire work areas where noise level is deemed a probable hazard. This will be done to identify where hearing protection will be needed, and to identify those employees, which may have exposures to high noise levels. Whenever possible, noise levels will be maintained below 85 dba using engineering and or work practice controls. Areas where hearing protection is required will be designated as such by appropriate signage. A. Hearing protection, such as ear plugs or muffs should be worn by employees in areas anytime the 85 dba noise level is met or exceeded. All hearing protectors must conform to the specifications of OSHA CFR Hearing protection shall be replaced as necessary. Exposure levels will also be evaluated to determine if additional or different types of hearing protection are required. Several types of ear plugs are offered for Charlotte personnel and ear muffs are available, upon request. Personnel working off site are to wear hearing protection based on area signage Selection A. Personal fall protection systems, including body harnesses, lanyards, and associated equipment shall meet the requirements of OSHA 29 CFR Body belts and non-locking snap hoods are not allowed. Fall protection is required when working in a manlift, or when working at a height of 4+ feet from the floor level, or working on the roof within 6 of the roof edge Inspections A. All personal fall protection systems will be inspected thoroughly for integrity prior to each use. Defective equipment will be replaced. Note: Approval of safety shoes, prescription eyewear and lab coat PPE purchase is typically documented using the PPE Request form available from Facility Services. There are no Emergency use body suits at the Charlotte site as emergency response is external.
9 Procedure No.: CTC-SAF-006 Page: 9 of RESPONSIBILITIES 5.1. It is the responsibility of all site residents to follow this procedure concerning PPE The Site Manager has the primary responsibility for the initiation & administration, of this procedure Charlotte site management has the primary responsibility for the implementation and enforcement of this procedures EHS&S will assists with interpretation of this procedure. EHS&S will assist in assignment of Hearing Conservation training and provision of Occupational Noise Standard to associated personnel and maintenance of records used to determine Hearing Conservation applicability. 6. RELATED DOCUMENTS 7. REVISION HISTORY BC Personal Protective Equipment ANSI Z41- Foot Protection ANSI Z87- Eye and Face Protection ANSI Z89.1- Head Protection OSHA 29 CFR Noise Hazardous waste and emergency response operations Personal Protective Equipment Electrical Fall protection NIOSH 42 CFR Part 84 New respirator classifications BASF Respiratory Protection Compliance Guide BASF Corporate PPE Catalog access via BC above BC Contractor selection, Oversight and Safety Date Revision Summary of Change By 12/02 JSF Contact lens notification to medical personnel. 3/04 JSF B Annual training notation, A Contact wearers & F.A.T B Glove chart statement, PPE form statement added 9/05 JSF Additional paragraph of shoe requirement descriptions
10 Procedure No.: CTC-SAF-006 Page: 10 of 11 3/09 JSF High voltage work by contractors only Lab coats and other over clothing provided by BASF. 10/09 JSF 4.6.1A Added purposes for each shoe requirement, 4.7.2A Removed OSHA electrical regulation # reference, Added statement about 8ft markings 9/28/10 JSF Clarification on prohibited shoe types. 9/11 JSF Addition of electrical references. 12/11 (Rev 8) JSF A.4 deleted, 4.2 deleted hardcopy references, moved contractor sentence to end of paragraph 6/26/13 (Rev 9) JSF A reworded are not allowed notation, A Added Respiratory devices type., B Added not in required use, C where air supplied still be required D personnel using air of personal devices., A Several types of upon area signage. 9/9/13 (Rev 10) JSF A Addition of statement regarding glove inspection before use, B Addition statement for proper size selection of glove, C Addition of statement for removal of gloves when contaminated. 10/2/2014 Rev. 11 JO Added Table 1 6/15/2015 Rev 12 JSF Clarified wording on laboratory shoe materials. Mbird to LMS. # Site Specific Reminders Table 1: Site-specific notes 1 PPE Program Administrator. EHS Representative- Scott Foxx 2 Site PPE Written Program Location. Documentum system- Manual/CTCSAF006 Personal Prot. Equip. 3 PPE Assessment Charlotte Laboratories Y:\GROUPS\EVERYONE\SAFETY\PPE by Work Group & job tasks 4 Job-specific procedures detailing the use of PPE at the Site for various tasks (i.e. JSAs, TJAs, Operating procedures) Job Safety Analysis are created by the groups assigned the work tasks and include: PPE and safe work information. JSA s are held by labs. Operating instructions/lab tests also contain PPE required. 5 Non-individually issued PPE at the Site. General PPE; gloves, hearing plugs, etc. are available in supply 6 Site process that ensure employee demonstration of proper donning and doffing of assigned PPE. cage near Maintenance/Facility offices. Donning and doffing technique for PPE is shown during initial Issuance, reinforced by lab mentors and reviewed during periodic F2F training of PPE as a monthly lab safety topic. 7 Chemical goggles use. Lab use of goggles requires the headband be on the head and not around a hat or other obstruction. Hard hat users will Not attach them to a hard hat. This use is extremely rare for Charlotte. 8 Prescription safety glasses with side Complete prescription glasses form, from site receptionist/ehs, &
11 Procedure No.: CTC-SAF-006 Page: 11 of 11 shields. 9 Site contact lens policy and procedures for use. 10 Safety shoes and chemical protective footwear. return form to receptionist after obtaining glasses. Contact lens can be worn in all work areas including labs. Personnel wearing contacts in labs are to inform site safety & First Aid Team of the use of contacts in this area. Obtain safety shoes form from Y:Drive (receptionist can assist as contact point) & complete and follow form. Return form to receptionist after obtaining PPE. 11 Fitting and issuance of hearing protection (i.e. ear muffs, fitted and disposable earplugs). Multiple types of ear plugs are available from supply cage and at higher noise locations. Ear muffs can be ordered with supervisory approval (EHS representative can assist with fitting needs and periodically provides training on rolling and fitting ear plugs.) 12 Disposal of used PPE. Gloves should be disposed long before breakthrough time, after Contact with hazardous chemicals. Gloves are for splash protection against hazardous chemicals in the labs, not emersion. 13 Decontamination, cleaning, inspection and storage of reusable PPE. 14 Use of flame-resistant clothing (FRC) for protection against flash fire, where applicable. 15 Use of fall protection equipment by authorized personnel. 16 Annual review and modification (as needed) of the PPE Hazard Assessment. Site PPE procedure covers reuse of PPE. Lab coats are cleaned by site vendor and are Not to be taken home. Only Facilities personnel or contractors are allowed to open electrical panels and work in them. FRC clothing has been provided to Facility for minor breaker throw tasks and contractors w do all other work. Only the Polymerization lab/facility personnel are allowed to work at heights and will be required to use fall protection, ex. lanyards. These personnel are trained on inspection and life span of the equipment. Laboratories are to inform site EHS of chemical changes via the MOC system and Chemical Approval System. These systems allow EHS to know when changes occur and to update associated assessments.