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Retail Safe System of Work

Retail Safe System of Work. May 2007 – U.S. Version 1.0. Agenda. Purpose Applicability Effective Date Requirements. I. Purpose.

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Retail Safe System of Work

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  1. Retail Safe System of Work May 2007 – U.S. Version 1.0

  2. Agenda • Purpose • Applicability • Effective Date • Requirements

  3. I. Purpose The purpose of this document is to communicate the “Safe System of Work” (the “System”) that contractors shall comply with when retained by one or both of the companies to perform work on or about Shell branded retail locations and/or work for Environmental Services.

  4. I. Purpose • This system is used to coordinate required hazard controls before the contractor begins work, and supplements the contractor’s own HSE procedures and work practices. • This System requires the contractor to do the following: • Complete a Job Clearance form (see Appendix A) • Complete a Job Safety Analysis (JSA) for all “medium” and “high” risk activities as defined by this System

  5. I. Purpose • Complete a Permit to Work (PTW) form (see Appendix B) for the following “high” risk activities: • OSHA Permit Required Confined Space (PRCS) Entry • Hot Work • Excavation Work • Hoisting/Rigging Operations • Working at Heights (work performed where a potential fall distance of six feet or more exists)

  6. I. Purpose • Implement the contractor’s own internal policies, procedures and work practices. • NOTE: Additionally, Contractors shall implement their own PTW system that includes the elements outlined in the Requirements section below.

  7. II. Applicability This System shall apply to: • All contractors, vendors, and third partieswho perform work and/or environmental services on or about Shell branded retail locations • And their respective employees, workers, agents, subcontractors and representatives (collectively hereinafter the “Contractor” or “Contractors”). • Responsibility for compliance shall be cascaded in contracts between the Contractors and their respective subcontractors and vendors who are retained to perform work covered by this System.

  8. II. Applicability • This System is in addition to the contractor’s own policies, procedures and work practices, which shall comply with all applicable laws and be consistent with the requirements of this System. • In the event of any conflict or contradiction between the provisions of this System and applicable law, applicable law shall prevail.

  9. III. Effective Date The effective date for this system is June 30, 2007

  10. Compliance with Laws and References • The Contractor shall comply with all applicable Federal, state and local applicable laws • The Contractor shall comply with all applicable Shell Oil Products US and/or Motiva Enterprises LLC requirements without limitation: • Shell Oil Products US and Motiva Enterprises LLC Standards’ 225 - Work Permits • The Contractor should refer to the following API reference for additional information: • API Recommended Practice 1646 – Safe Work Practices for Contractors Working at Retail Petroleum/Convenience Facilities, First Edition, August 2006 https://worksafe.api.org(LINK)

  11. IV. Requirements • Job Clearance Form • Job Safety Analysis (JSA) • Permit to Work (PTW) • Safe System of Work Orientation • Monitor, Contract Compliance Audits & Review • Records

  12. 1. Job Clearance Form • Work of any kind shall not commence until the work crew has identified themselves and the nature of their work to the Site Representative. • A Job Clearance Form (Appendix A) shall be completed by the Contractor, reviewed and signed by the Site Representative before work commences. • For work scopes taking longer than one day, the work crew shall complete a new Job Clearance Form and identify themselves each day to the Site Representative before any work commences.

  13. 2. Job Safety Analysis (JSA) A JSA shall be required for all “Medium” and “High” risk activities as defined by this System. These activities include, but are not limited to the following: OSHA PRCS Entry Hot Work Excavation Work Hoisting/Rigging Working at Heights Barricading and Work Area Isolation Lock-out/Tag-out Live electrical work(Note: Live electrical work is allowed for diagnostic testing only. Lock-out/Tag- out procedures must be used for all other electrical work.)

  14. 2. Job Safety Analysis (JSA) The JSA shall be reviewed before commencing work and when work conditions change such as: • Changes in weather • Job scope or equipment • Conflicting work being undertaken by another contractor • Fuel Delivery • Change in work crew

  15. 2. Job Safety Analysis (JSA) Additionally, the Contractor shall communicate with the Site Representative to: • Identify site-specific hazards not covered in the JSA • Identify any other work on site by another contractor. • Obtain information required by HAZCOM Standards including hazards and precautionary information contained in relevant Material Safety Data Sheets (MSDS). The Contractor shall document this information accordingly on the Job Clearance Form or JSA.

  16. 2. Job Safety Analysis (JSA) • Shell branded retail locations covered by this System present or may present various hazards. These hazards are detailed in the JSA section on the document.

  17. 3. Permit to Work (PTW) A Permit is required by this System for the following types of work: • OSHA PRCS Entry • Hot Work • Excavation Work • Hoisting/Rigging Operations • Working at Heights(work performed where a potential fall distance of six feet or more exists)

  18. 3. Permit to Work (PTW) • Standardized permit forms that may be used are provided in Appendix B • A copy of the PTW shall remain at the jobsite for the duration of the work and be available for review and inspection • A filing system for permits and associated documents of work must be maintained and accessible for a minimum period of two years

  19. 3. Permit to Work (PTW) Elements The PTW System includes the following elements: • Contractor Permitting • Self-Permitting • Remote Permitting • Blanket Permitting • Permit Validity

  20. 3. Permit to Work (PTW) Elements 3a. Contractor Permitting • Contractors shall implement their own PTW system that shall comply with all applicable federal, state and local laws and regulations, including without limitation, the OSHA Permit Required Confined Space Entry Standard. • An individual may issue a Permit to another person in the same Contractor organization ONLY if ALL of the following criteria are satisfied: • The Permit Issuer (PI) is not a member of the work crew scheduled to perform the permit controlled work; • The PI has attended the Shell Retail Safe System of Work Orientation • The PI has successfully completed the PI employer’s PTW System training, as applicable.

  21. 3. Permit to Work (PTW) Elements 3b. Self-Permitting • No one is allowed to issue a Permit to him or herself 3c. Remote Permitting • Remote permitting is not allowed • Permit Issuers shall be on site to review site conditions and issue the permit 3d. Blanket Permitting • Blanket permitting is a process of issuing one PTW for the same activity across multiple locations • Blanket permitting is not allowed for work activities

  22. 3. Permit to Work (PTW) Elements 3e. Permit Validity • Permits are valid for a maximum of 1 day • A new permit must be issued if: • The work extends beyond 1 day • The scope of work changes • The work conditions change • There is a shift change 3f. OSHA Permit Required Confined Space Permit • Entry into the space is permitted only through • The Contractor’s compliance with a permit space program meeting the requirements of the OSHA PRCS Standard (29 CFR 1910.146) or state equivalent, as applicable • The requirements set forth in the Retail Safe System of Work Document

  23. 4. Safe System of Work Orientation • Shell Retail shall hold an orientation session on the requirements of this System prior to the effective date and an annual refresher thereafter. • Contractors shall provide training to their: • Employees / Workers • Subcontractors • Vendors • Training shall consist of the requirements of this Policy as well as their own PTW System requirements and require compliance with both at all times when performing the work.

  24. 5. Monitor, Contract Compliance Audits & Review 5a. Monitor • Contractors shall periodically monitor work under Permit control, including spot checks of work sites, Permit completion and supporting documentation • Typical questions contractors should ask are: • Is the Permit prominently displayed at the work site where all Contractor employees can see it? • Has the Permit been properly completed? • Are the controls adequate and being implemented? • Has the work party been briefed and do they fully understand the Permit controls?

  25. 5. Monitor, Contract Compliance Audits & Review 5b. Contract Compliance • Contract compliance audits shall be conducted as part of Shell Retail’s HSSE audit program (e.g. Safety Snap Shot) • Contractors shall also conduct their own independent audits to ensure compliance with this System

  26. 5. Monitor, Contract Compliance Audits & Review 5c. Review • Shell Retail shall review the effectiveness of this System and modify it where necessary as part of continuous improvement of HSSE management. Factors to be taken into account, as applicable include: • Changes in legislation • Industry and Shell/Motiva guidance • Review of Incident Reports • Inspection & Audit findings • Feedback from users

  27. 6. Records Copies of Job Clearance Forms, JSAs, PTWs and any associated documentation shall be maintained by the Contractor for a minimum of two years following the completion of the work.

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