APLNG MODULE YARD PROJECT

HAZARD COMMUNICATION PROGRAM PROCEDURE

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Bechtel Confidential
© Bechtel Oil, Gas and Chemicals, Inc. 2012. All rights reserved.
This document contains information that is confidential and proprietary to Bechtel or its affiliates, clients or suppliers,
and may not be used, reproduced or disclosed without Bechtel’s prior written permission.

000 5/23/12 Issued for Use BKT BS TW

00A 5/17/12 Issue for Review BKT BS TW
REV DATE REASON FOR REVISION BY CK’D APPR
BECHTEL
JOB NO. 25605
OG&C INC.
BECHTEL DOCUMENT NO. REVISION
AUSTRALIA PACIFIC 240-GPP-GHX-00015 000
LNG MODULE YARD
PROJECT Client Document No.:
 APLNG Module Yard Project
Hazard Communication Program

TABLE OF CONTENTS

1.0 PURPOSE...........................................................................................................3

2.0 SCOPE................................................................................................................3

3.0 DEFINITIONS......................................................................................................3

4.0 REFERENCES....................................................................................................3

5.0 RESPONSIBILITIES...........................................................................................3
5.1 Site Manager......................................................................................................................... 3
5.2 Area Superintendent............................................................................................................. 3
5.3 HSE Manager........................................................................................................................ 3
5.4 Environmental Coordinator.................................................................................................... 4
5.5 Discipline Superintendent...................................................................................................... 4
5.6 Project Personnel.................................................................................................................. 4
6.0 REQUIREMENTS................................................................................................4
6.1 Ordering................................................................................................................................ 4
6.2 Asbestos................................................................................................................................ 4
6.3 Hazardous Substance Request.............................................................................................5
6.4 Hazardous Substance Register.............................................................................................5
6.5 Material Safety Data Sheets (MSDS's)..................................................................................6
6.6 Storage of Hazardous Substances........................................................................................6
6.7 Labelling................................................................................................................................ 7
6.8 Signage................................................................................................................................. 8
6.9 Emergency Response........................................................................................................... 8
6.10 Spills and Clean Up............................................................................................................... 8
6.11 Disposal................................................................................................................................ 8
7.0 EXPOSURE MONITORING AND HEALTH SURVEILLANCE..........................9

8.0 AUDITS...............................................................................................................9

9.0 RECORDS........................................................................................................10

10.0 INFORMATION AND TRAINING REQUIREMENTS.......................................10

11.0 RECORDS.........................................................................................................11

12.0 ATTACHMENTS................................................................................................11

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Hazard Communication

1.0 PURPOSE
To define applicable standards and set minimum requirements for the man- agement of
hazardous substances and dangerous goods.

2.0 SCOPE
This procedure applies to the APLNG Module Yard project.

3.0 DEFINITIONS
MYEMP – Module Yard Environmental Management Plan

Container - Object in which hazardous substances have been stored, en- closed or
packaged whether such container is partially or completely full or empty.

Hazardous Material –. Any material that poses a hazard to humans or the en-
vironment.

Hazardous Material Register – Log of hazardous materials stored and in use on-
site, including type, quantity, location and material safety data sheet (MSDS).

Material Safety Date Sheet (MSDS) – Document that states the substance’s
hazardous constituents, chemical and physical properties, health hazards, per- missible
exposure levels, first-aid procedures, emergency procedures, and the recommended
handling, use and disposal requirements. The manufacturer must provide an MSDS for
all potentially hazardous substances.

4.0 REFERENCES
Bechtel CP 202 Hazard Communication Program
Bechtel CP 200 General safe Working Practices
Compilation of the Environmental Legislative Regulations & Decrees by the Environmental
Impact Control Agency & DEPNAKERTRANS of Batam City.

5.0 RESPONSIBILITIES
5.1 Site Manager
 Responsible for the overall hazard communication program.
 Ensuring the procedure is implemented on the project.
5.2 Area Superintendent
 Hazardous substances brought on-site for defined scope of work.
 Ensuring the number and the amount of hazardous substances stored are
based on need.
 Ensuring only approved hazardous substances are brought on-site.
5.3 HSE Manager
 Providing information concerning the hazardous substance standard.

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 Assisting the Site Manager with performing hazardous substance regis- ter
surveys.
5.4 Environmental Coordinator
 Reviewing and approving chemicals and MSDS
 Approving hazardous substances for purchase.
 Maintaining the Hazardous Substance register.
 Maintaining Material Safety Data Sheets (MSDS’s) for the project.
5.5 Discipline Superintendent
 Ensuring that all hazardous substances are properly labelled, stored, and
disposed of in accordance with the MSDS and project procedures.
 Conducting training of team members in the safe use of hazardous
substances for routine and non-routine tasks.
5.6 Project Personnel
 Handling, storing and using hazardous substances in the proper man- ner at
all times.
 Reporting any problems/issues/concerns/incidents/spills regarding haz- ardous
substances.

6.0 REQUIREMENTS
6.1 Ordering
Hazardous substances should not be ordered in excess, nor should bulk containers
be specified where an excess will be left over. Choose the cor- rect size container
that will meet the estimated quantity required.
6.2 Asbestos
No materials containing asbestos are to be brought to the project site.

In the event a team member finds material that contains or is suspected to

contain asbestos the following actions are to be taken:

 Cease work in the area

 Barricade the immediate area
 Notify the Area Superintendent and HSE Manager

An appropriate course of action in line with Legislative and Indonesian Standards

will be developed.

Removal of asbestos materials is to be undertaken by personnel with the required

certification level as stated in the legislation. A detailed work plan approved by
the Site Manager is to be in place prior to the commence- ment of any asbestos
removal task.

No asbestos material is envisaged to be encountered on the project

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6.3 Hazardous Substance Request

All hazardous substances to be brought on-site must be evaluated for hazard
potential, possible substitutes, use, handling, storage and disposal requirements.
Hazardous substances can be brought onto site after a Hazardous Substances
Request for the substance has been approved by the Environmental Coordinator.

The request is to be completed by the team member requiring the haz- ardous
substance on-site and forwarded with a copy of the MSDS to the Environmental
Coordinator. The Environmental Coordinator will evaluate each hazardous
substance prior to being brought on-site. In performing the evaluation, the
Environmental Coordinator will utilize available infor- mation such as project
drawings and documentation, current online and/or hard copy MSDS and other
available references.

In addition, hazardous substance evaluations will be based on applicable

legislative requirements for the management of the substance, training of team
members, recognized HSE standards and information in the MSDS.

Once the evaluation is complete, the request may be approved, approved with
restrictions or rejected.

When a hazardous substance is rejected for use on-site, the reason(s) for the
rejection and an alternative substance will be suggested.

If an unapproved hazardous substance is received on-site, the hazardous

substance will be appropriately stored in a quarantine area and not re- leased until
an approval has been obtained or shall be removed and dis- posed of in
accordance with the project CEMP.

6.4 Hazardous Substance Register

The Hazardous Substance Register is the master list of all approved haz- ardous
substances on-site. The register will contain the following informa- tion:

 Register number
 Generic name/product type
 Trade name
 HAZCHEM code
 Dangerous good code
 Packaging group
 Applicant
 Comments/restrictions
 Location stored
 Quantity on hand
 Annual usage

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 MSDS received
 MSDS manufacturer issue date
 Contractor name

The Hazardous Substance Register will be developed and maintained by the

Environmental Coordinator for all hazardous substances. The register will be
updated each time a hazardous substance is approved.

The Environmental Coordinator will perform an annual physical inventory of all

hazardous substances on-site and will compare this to the Hazard- ous Substance
Register to ensure accuracy. Substances no longer stored or used on-site will be
moved from the register to a redundant file.

Contractors are required to maintain a register of approved hazardous substances

relevant to their scope of work. Once a contractor has fin- ished with a substance
they are to remove any residual stock from the project and notify the
Environmental Coordinator for the project manifest to be updated.

6.5 Material Safety Data Sheets (MSDS's)

MSDS’s are to be retained for each approved hazardous substance on- site.
MSDS’s for hazardous substances no longer being stored or used onsite shall be
filed and retained.

MSDS’s shall be available and accessible to team members, including first

aid attendants and medical personnel, during all work shifts in rea- sonable
proximity to the work location.

Hazardous substances observed during inspections without the proper MSDS

shall be tagged Out of Service by the person conducting the in- spection and
stored separately from products in use until such time an MSDS for the substance
is provided or the substance is removed from the site.

6.6 Storage of Hazardous Substances

Hazardous substances must be stored in a manner that adequately pro- tects both
human health and the environment from unintended exposure to the substance.
The exposures may include explosion, fire, reactivity, toxicity or any combination
of the hazards.

Storage areas for hazardous substances will be reviewed and approved by the
Environmental Coordinator prior to receipt of the substances on the site. Criteria
for the location of suitable storage areas include:

 Located away from high traffic areas on-site and protected from poten- tial
impact by vehicles/plant, guardrails, fences, or other structural con- trols.

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 Provided with a means to control access to the substances in order for

authorized (e.g., trained) team members to remove and use the sub- stances.
 Located away from fence line locations immediately adjacent to envi-
ronmentally sensitive resources (e.g. wetlands, streams, archaeological sites).
 Provided with secondary containment in the form of a bund with the capacity
of 110% of the maximum storage level.
 Provided with a means of segregating combustible and flammable sub- stances
from oxidizing agents and other sources of ignition.
 Provided with a means of preventing water reactive and pyrophoric substances
from coming in contact with accumulated water.
 Appropriate signage to highlight the storage location, the hazardous, codes and
controls for the risk associated with the storage space (i.e., No Smoking).

The Environmental Coordinator may review additional guidance informa- tion on

the location, design, and maintenance or hazardous substances storage areas as
contained in governmental regulations, requests, and/or the Module Yard
Environmental Management Plan (MYEMP).

Contractors shall manage, store, and transport to site location of all haz- ardous
materials generated, handled or disturbed by contractors during its work in
accordance with applicable legislation and all other requirements outlined in the
Module Yard Environmental Management Plan (MYEMP). This includes, but is
not limited to, waste minimization; hazardous materi- als registration; hazardous
materials inventory with Material Safety Data Sheets (MSDS) for each hazardous
material on-site; employee training; hazardous materials spill management and
reporting; proper storage of hazardous materials; LDGL registration, equipment
decontamination and on-site transport of hazardous materials.

All hazardous substances and dangerous goods locations are strictly no smoking
areas. All potential ignition sources are banned from the areas.

6.7 Labelling
All hazardous substances are to be legibly labelled with the product name,
relevant risk and safety phrases and the name and address of the manufacturer or
supplier. All hazardous substances which are decanted into another container and
not used immediately are to be labelled in the same manner. Labels are not to be
removed or modified for any reason.

Any container of a substance found not having a label is to be tagged with an Out
of Service with the words “UNKNOWN SUBSTANCE – DO NOT USE” and
reported to the Environmental Manger/Coordinator or HSE de- partment.

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A hazardous substance contained in an enclosed system, such as a pipe, piping

system, process or reactor vessel, shall be identified by having signs, placards, or
other appropriate signage attached containing the same information as a
manufacturer’s original label.

6.8 Signage
Signs are to be placed in appropriate locations to provide information to those
entering the area or use the substances and for emergency re- sponse.

A site HAZCHEM sign will be displayed and the manifest kept in a weather
proof container at the site entrance for the information of external emergency
services.

6.9 Emergency Response

Emergency procedures for a spill, fire, leak or explosion involving hazard- ous
substances are to be developed as part of the work method state- ment process and
refer to the actions contained in the Emergency Pre- paredness and Response
Plan.

Where a risk assessment has identified a need for eye protection to pre- vent eye
injuries from hazardous substances, provision for eye wash sta- tions must be
made.

Handling of corrosive or reducing agents will require eye wash stations and
safety showers be located within close proximity to the work area. The safety
stations will be denoted by the appropriate signage and the eye wash and shower
tested before handling of any substances.

6.10 Spills and Clean Up

Information on spills and clean-up can be found in the relevant Material Safety
Data Sheet, Project Waste Management Procedure and Emer- gency Preparedness
and Response Plan (EP&RP).

All spills are to be reported and promptly cleaned up. Spills with the po- tential to
cause significant environmental harm or injury shall be immedi- ately reported to
the emergency response team. All efforts should be made to contain the spill or
prevent further leakage.

6.11 Disposal
Land fill disposal of hazardous substances will not be accepted unless
specifically authorized by the Environmental Coordinator. All excess haz-
ardous materials and the containers must be removed from site as each phase of
the project is completed.

All contaminated soil from chemical spills must be reported to the Project
Environmental Department before being removed from site. Documented

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evidence of disposal methods are to be maintained. Refer to the Project Waste

Management Procedure for more detail.

7.0 EXPOSURE MONITORING AND HEALTH SURVEILLANCE

If a risk assessment, MSDS or legislation indicates there is a significant risk to the
health of team members from dusts, mists or fumes, atmospheric monitor- ing shall be
undertaken. For substances absorbed through the skin or in- gested, biological
monitoring may be required.

Where and how monitoring of the substances shall be performed shall depend on the
location and the nature of the substances. Monitoring may be by per- sonal dosimeter
or area analysis or a combination of both. The qualified per- son performing the
monitoring shall decide, in consultation with the project En- vironmental Coordinator,
upon the monitoring technique to be used.

Atmospheric monitoring shall, as a minimum, comply with legislative require- ments

and personnel performing monitoring shall be suitably trained in moni- toring
techniques. (refer to CP 313 - Air Surveillance Program)

Records of monitoring shall comply with the following:

 Record of the dates, exact locations and results taken of the monitoring.
 Any worker who has been or could be exposed to a hazardous substance which is
subject to monitoring, shall be provided with the results of the monitoring.
 A record of monitoring will be available to project personnel.
 Records of monitoring requiring follow up shall be kept for thirty (30) years.
 Results not requiring follow up shall be kept for five (5) years.

Health surveillance requirements for specific hazardous substances will be de- pendent
on the health effect and the existence of a valid technique to detect signs of the effect.

All health surveillance is to be conducted by or in consultation with the Nomi- nated

Medical Attendant.

Monitoring and surveillance requirements are to be implemented by the con- tractor in

control of the use and storage of the hazardous substance.

8.0 AUDITS
To ensure hazardous substances are stored, labelled, signed, transported and disposed
of in accordance with the procedures and legislative requirements, all workplaces and
vehicles transporting hazardous substances shall be sub- ject to audit. Audits shall be
performed by suitably qualified and trained team members, or suitably qualified
external consultants appointed by the HSE Manager or Environmental Coordinator.
All managers shall be notified of the results of the audit and any remedial action
required.

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9.0 RECORDS
The following records are to be retained as long as the project is active:

 Copy of procedure
 Team members training records
 Hazardous substances requests
 MSDS’s
 Current Hazardous Substance Register
 Risk assessments

10.0 INFORMATION AND TRAINING REQUIREMENTS

Information and training will be provided to team members:

 During the project orientation for new team members

 When new team members are first assigned to a work area they may be exposed
to hazardous substances under normal working conditions or in a foreseeable
emergency.

Additionally, when a new hazard is introduced into the work area. Example of new
hazards are:

 A new substance is to be used, and,

 A previously used substance is to be used in a different manner poses a new
hazard

The following general information is to be provided to all team members:

 Rights to access and obtain information.

 Location and availability of the Hazardous Substances Register and MSDS’s.
 Operating in work areas where hazardous substances are used.
 The person(s) to contact for further information.
 Hazardous substances and states of matter ( e.g., liquid, solid, gas).
 Chemical physical, and health hazards.
 Routes of entry (e.g., inhalation, ingestion, absorption).
 Exposure limits and ways to control exposure.
 Personal protective equipment and engineering controls.
 Labelling requirements.
 MSDS’s, contents and use.

Visitors will be provided with the same general topics of information as team
members. Visitors entering areas where hazardous substances are used, will be fully
advised of the potential hazards and given the opportunity to review the MSDS’s.

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11.0 RECORDS
 Hazardous Substance Request

12.0 ATTACHMENTS
Attachment A - Hazardous Substance Request Form

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REQUEST
Contractor:
Name: Position:
Signature: Date:
SUBSTANCE DETAIL
Trade Name:
Hazchem Code: DG Code:
Known Hazards:
Intended Use:
Location - Use:
Location - Storage:
Order Quantity:
Estimated Usage:
MANUFACTURER/SUPPLIER
Name:
Address:
Phone: Fax:
EVALUATION
Are less harmful substances/materials available? Yes/No
Storage compatibilities assessed? Yes/No
Can the substance/material be used in a less harmful form? Yes/No

Control measures currently in use?

New control measures required?

Changes to work practices required?

Additional PPE required?

Risk Score: Refer to project risk matrix

Submit form and current MSDS to HSE Department

………………………………………………………………………………………………………………………………………….....
HSE Manager Evaluation Only

Approval/Rejection by Environmental Co-ordinator

YES – THE PRODUCT IS APPROVED FOR USE ON SITE.
It must be used in accordance with the MSDS and the additional controls listed above. A current MSDS
must be available for the user and all exposed team members must be trained in its contents.
YES – THE PRODUCT IS APPROVED FOR USE WITH THE FOLLOWING RESTRICTIONS:
Exposure is maintained to 10% of the allowable limit identified on the MSDS
The defined engineering controls and personal protective equipment are used.
NO – THE PRODUCT IS NOT APPROVED FOR USE.

Reason –

Suggested Alternative –
Name: Position:
Signature: Date:

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