HEALTH AND SAFETY PROGRAM 103 PLANT ENTRY REQUIREMENTS

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1 Page 1 of PURPOSE This procedure has been developed to ensure all personnel, other than Axiall employees, entering the plant have the proper security identification and receive a minimum level of site orientation and have attended a basic safety orientation of OSHA rules and regulations facilitated by an ARSC council. 2.0 SCOPE This program applies to all non-axiall employees including contractors, visitors, vendors, truck drivers and other personnel who will be entering the plant facility to conduct business. 3.0 DEFINITIONS ARSC Association of Reciprocal Safety Councils. Council representatives to ARSC work together to develop and revise current training programs that meet a significant portion of OSHA requirements, as defined within the standards. This allows councils that perform site orientations, to work with industrial facility representatives, in reducing the amount of redundant information in their site orientations thereby increasing the effectiveness of the training while reducing the cost of development. A list of ARSC councils can be found at Site-Specific Orientation - Detailed orientation session designed for contractors and maintenance personnel. The session covers Axiall Plaquemine safety and emergency response policies and procedures that are common to the entire complex and includes an introduction to each of the process areas. Transportation Worker Identification Credential (TWIC) The TWIC is a personal identification card as defined and explained in 49 CFR 1572 and issued by the Transportation Security Administration, Department of Homeland Security. Every one entering the site will be required to have a TWIC card or be escorted while in the secure/restricted areas of the facility. Visitor Orientation - Short orientation session designed to educate visitors, vendors, and truck drivers on the safety and emergency response aspects that are important for their well being while onsite.

2 Page 2 of RESPONSIBILITIES 4.1 Health, Safety and Security Develop, conduct and maintain up-to-date and informative orientation courses as required by this procedure Conduct periodic random field surveys of personnel within the plant to inspect the effectiveness of this procedure. Documentation of these surveys will be maintained by Security for one year. 4.2 Engineering Enforce this procedure with all personnel contracted through their department to perform services onsite Maintenance Enforce this procedure with all personnel contracted through their department to perform services onsite. 4.4 Operations Enforce this procedure with all personnel contracted through their department to perform services onsite. 4.5 Contractors Ensure all contract employees attend the required orientations prior to starting work onsite Provide personnel who have completed all applicable OSHA training Ensure that all employees have obtained and are carrying their TWIC.

3 Page 3 of PROCEDURE All personnel performing work will be required to present the following credentials for entry: Course Basic Orientation Plus OR Basic Orientation Plus Refresher OR Basic Orientation 3-yr Test Axiall Plaquemine Site-Specific Location Training Administered Alliance Safety Council or other ARSC council Alliance Safety Council or other ARSC council ARSC Course Code 12BR 12BR1 12GBRE 12AXLPLQ TWIC TWIC office N/A If personnel do not possess a TWIC, they will be required to be escorted by a TWIC holder that has a current TWIC on their person. This will apply to all visitors and vendors who will enter the plant premises. All contractor employees shall have a current TWIC on their person to enter. 5.1 Visitor Orientation All visitors, vendors and truck drivers who will be onsite for short durations with limited activity will attend the Visitor Orientation course covering minimum safety and emergency response requirements The orientation will be valid for one year from the date of completion. Reorientation will be required annually following the expiration date of the original course NOTE: Neither Basic Orientation Plus nor the Axiall site-specific orientation is required for visitors Alliance Safety Council visitor course code: 12AXLV 5.2 Site-Specific Orientation All personnel who will be performing work onsite within operations, maintenance or construction area will attend the site-specific orientation covering basic safety rules and regulations and emergency response procedures. This orientation also includes a process overview as required by OSHA 29 CFR Process Safety Management and emergency response protocols specific to the unit.

4 Page 4 of The site-specific orientation is conducted by the Alliance Safety Council or other Association of Reciprocal Safety Council (ARSC) This orientation will be required to be retaken if the contractor is away from the site for one (1) year or more Every effort shall be made by the contractor to take this course at the Alliance Safety Council or other ARSC council. 5.3 Basic Orientation Plus / Plus Refresher A basic plant safety orientation is required for all contractors whose job duties require them to work within an operations, maintenance or construction area Axiall currently accepts safety orientations conducted by the Baton Rouge/Addis/Gonzales Safety Council or any safety council associated with the ARSC This course will not be facilitated at Axiall for any reason Company internal safety orientations may be submitted to Axiall s Health and Safety Department for review for those companies that are not located near a safety council offering the this reciprocal course (i.e. out-of-town contractors) This orientation will be required to be retaken if the contractor is away from the site for one (1) year or more. 5.4 Communication Requirements In order to ensure the safety and well being of all personnel entering our complex it is important that they are capable of comprehending all plant warning signs as well as verbal and written instructions. For this reason, personnel must possess a minimum level of proficiency in the English language to be allowed access into the plant. This minimum level will be gauged by requiring successful completion of all orientation documentation and tests without assistance or coaching from others.

5 Page 5 of Temporary Waiver If a contract employee does not possess on his/her person the required entry requirements, the Contractor Entrance Requirements Waiver (Appendix A) may be completed and approved. All signatures are required for the waiver to be approved. All efforts to obtain the proper requirements shall be exhausted before the waiver can be filled out and routed for approval. This also applies to entry for emergency work verbal approvals are only allowed for emergency work. 5.6 Yellow Cards from the Alliance Safety Council 6.0 RECORDS Cards from an ARSC Safety council will be yellow for the following reasons: 6.1 Visitor Orientation year test out option for the basic orientation plus. The card will be a yellow front and the course code on the back shall be 12GBRE. This is an accepted card at Axiall Plaquemine. The Axiall site-specific shall also be on the back (12AXLPLQ) The card will have a yellow front and have NO ARSC printed on the front. This means they have not taken the Basic Orientation Plus. This employee will not be allowed to enter for work without an approved waiver The card will have a yellow front and have the Axiall sitespecific on the back. This means they have taken the BOP, but has expired. This employee will not be allowed to enter for work without an approved waiver Attendance Log An attendance log will be completed for all personnel attending the Visitor Orientation Course offered at the Main Gate Security Training Room. The log will be maintained by Security for one year. After one year all records will be disposed of in accordance with company policy Testing To ensure personnel comprehend and understand the orientation subject matter a short test will be administered following each course. A score of 80% will be required for successful completion of the course. All incorrect responses will be reviewed with personnel to ensure correct

6 Page 6 of 16 understanding of subject matter. The completed tests will be maintained by Security for one year. After one year all records will be disposed of in accordance with company policy Visitor Orientation Card All personnel successfully completing Visitor orientation will be issued a Visitor Orientation Card. The card will be valid for one year from the date of issue and is required to be presented to Security for plant access. Visitor cards will be yellow in color. 6.2 Site-Specific Orientations Attendance Log An attendance log will be completed for all personnel attending the General Plant Orientation course. The attendance log will be maintained by Security for one year. In addition the Visitor Orientation completion date will be entered into the orientation computer system for tracking purposes. After one year all records will be disposed and purged from the system in accordance with company policy Testing To ensure personnel comprehend and understand the orientation subject matter a short test will be administered following each course. A score of 80% will be required for successful completion of the course. All incorrect responses will be reviewed with personnel to ensure correct understanding of subject matter. The completed tests will be maintained by Security for one year. After one year all records will be disposed of in accordance with company policy Plant Entry and Non-Disclosure Agreement All contract personnel will be required to read and sign a Plant Entry and Non-Disclosure Agreement (see Appendix B) prior to being allowed access into the plant. 7.0 PROGRAM REVIEW 7.1 This Program will be reviewed at least every three years. Health, Safety and Security will ensure this review is performed. The purpose is to assess compliance, to ensure that all employees who should be included are, and to evaluate program effectiveness. The review will evaluate:

7 Page 7 of The current program effectiveness Spot checks of personnel training records Employee awareness; and Contractor awareness. 7.2 Following the review, the program will be revised to include any necessary changes. Review results will be documented. All employees will be informed of any changes made in the plan. 7.3 Department Managers will be informed of audit results. 8.0 REFERENCES Occupational Safety and Health Administration 29 CFR Occupational Noise Exposure Occupational Safety and Health Administration 29 CFR Process Safety Management of Highly Hazardous Chemicals Occupational Safety and Health Administration 29 CFR 1910 Subpart I Personal Protective Equipment Occupational Safety and Health Administration 29 CFR Specifications for Accident Prevention Signs and Tags Occupational Safety and Health Administration 29 CFR Permit-required Confined Spaces Occupational Safety and Health Administration 29 CFR The control of hazardous energy sources (lockout/tagout) Occupational Safety and Health Administration 29 CFR Hazard Communication Axiall Intercompany Memo Revised Contractor Plant Entry Requirements (July 25, 1995). Axiall Intercompany Memo Contractors - Language Problems (August 23, 1996)

8 Page 8 of APPENDICES Appendix A Contractor Entrance Requirements Waiver form Appendix B - Plant Entry and Non-Disclosure Agreement

9 Page 9 of 16 Appendix A Contractor Entrance Requirement Waiver

10 Page 10 of 16 EHS&S - PLAQUEMINE CONTRACTOR ENTRANCE REQUIREMENT WAIVER * Mandatory data entry field Contractor / Company Name*: Contact Name*: Telephone Numbers: Business: Cell: Address: City, State: Zip Code: Describe scope of work / type of work* (be specific): Axiall Facility: Plaquemine Axiall Contact*: Contract Number: Phone Number: Every effort shall be made to ensure that the contract employee has the entry requirements required. This includes going to a safety council to take the required courses. After all efforts have been exhausted and the employee must still enter use this waiver form.

11 Page 11 of 16 Waiver for Contractor Entrance Requirements Waiver Request Dates:* / / thru / / The following entrance criteria have been waived on the below mentioned personnel: Name* Company* ID #* Check all that apply* Basic Orientation Plus Axiall Plq Site-Specific Reason for Waiver* Measures taken to assure equal or better protection than meeting the original requirements:

12 Page 12 of 16 Your signature below confirms that you are authorizing the contractor to perform the scope of work at this facility without meeting all of the minimal requirements. EHS&S Department Review ALL Entrance Waivers* Name Signature Title Date Contractor Supervision Approval ALL Contractor Entrance Waivers* Name Title Contractor Representative Signature Date ALL Entrance Waivers* Site Management Approval Name Dept./Unit Manager or designee Signature Title Date ALL Entrance Waivers* Name EHS&S Manager or designee Signature Title Date

13 Appendix B Plant Entry and Non-Disclosure Agreement

14 Axiall Corporation PLANT ENTRY AND NON-DISCLOSURE AGREEMENT In consideration of being admitted to a Axiall CORPORATION) office and/or plant (hereinafter referred to as "Plant"), the undersigned (hereinafter referred to as "VISITOR") agrees as follows: ARTICLE 1 PLANT ACCESS 1.1 VISITOR acknowledges that access to the Plant may provide VISITOR access to certain Confidential Information (as that term is hereinafter defined) with respect to which Axiall claims a proprietary interest, and VISITOR acknowledges that restrictions on the use and disclosure of said Confidential Information are reasonable and necessary in order to maintain and protect Axiall's proprietary interest. 1.2 VISITOR acknowledges that VISITOR has been given access to the Plant in exchange for an agreement to be bound by the non-disclosure provisions of this Agreement. 1.3 VISITOR agrees to wear appropriate protective clothing (e.g. hard hat, glasses) and further agrees to abide by all rules and regulations regarding safety within the Plant. ARTICLE 2 NON-DISCLOSURE 2.1 As used herein "Confidential Information" shall mean any and all trade secrets and know-how, including but not limited to proprietary technical, engineering, operational, marketing, accounting or economic knowledge, information or data, relating to the Plant and/or Axiall's business. 2.2 VISITOR shall treat as confidential and shall not, at any time, directly or indirectly use or disclose Confidential Information, whether received prior to, during, or subsequent to the visit to the Plant: which (a) is revealed to VISITOR in writing; (b) is disclosed to VISITOR verbally; or (c) is observed by VISITOR while inside the Plant; without prior written permission of Axiall. 2.3 The provisions of Paragraph 2.2 above shall apply except as to: (a) Confidential Information which VISITOR can demonstrate by written evidence was in VISITOR'S possession prior to the date of disclosure, from other than a party who had restrictions on disclosure of such information; (b) Confidential Information which, at the time of disclosure or later, is published or becomes otherwise available to the general public as part of the public domain through no act or failure to act on the part of the party receiving the disclosure and without breach of this Agreement; and (c) Confidential Information that VISITOR can demonstrate by written evidence came into VISITOR'S possession from a third party that had a bona fide right to make such information available without restriction.

15 2.4 Confidential Information shall not be deemed to be within the exceptions set forth in Paragraph 2.3 above merely because it is embraced by more general information in the public domain or in the prior possession of VISITOR. In addition, any combination of features shall not be deemed to be within the foregoing exceptions merely because individual features are in the public domain or in the possession of VISITOR, but only if the combination itself and its principle of operation are in the public domain or in the possession of VISITOR. 2.5 Subject to the provisions of Paragraphs 2.3 and 2.4 above, it is specifically understood and agreed that VISITOR shall not be permitted to disclose Confidential Information to any fellow employees or to VISITOR'S employer, unless each of said fellow employees or VISITOR'S employer, as the case may be, has previously entered into appropriate confidentiality agreements with Axiall. ARTICLE 3 PHOTOGRAPHS AND RECORDINGS PROHIBITED 3.1 VISITOR shall not be permitted to take photographs while inside the Plant nor make any recordings while in said Plant. All photographic and recording equipment must be secured in an appropriate area prior to VISITOR's entry into the Plant. ARTICLE 4 LIMITATION 4.1 Nothing contained in the Agreement shall be construed as a grant of any right or license or an offer to grant any right or license by Axiall to VISITOR with respect to the Confidential Information, except as expressly set forth herein. ARTICLE 5 INJUNCTIVE RELIEF 5.1 VISITOR acknowledges and agrees that in the event the non-disclosure provisions of this Agreement are violated, the damage and loss to Axiall will be immediate, irreparable, and incalculable. As such, VISITOR agrees that in the event of a violation of the non-disclosure provisions of this Agreement, Axiall shall be entitled to specific performance of this Agreement and to injunctive relief, whether mandatory or prohibitory, to prevent the loss of, the unauthorized use of, or the dissemination of Confidential Information. Nothing contained herein, however, shall restrict Axiall's rights to recover money damages, both compensatory and punitive, in addition to or independent of injunctive relief sought by Axiall in the event of violation by VISITOR of the provisions of this Agreement. ARTICLE 6 RELEASE 6.1 VISITOR acknowledges that VISITOR has been provided with information regarding appropriate safety procedures that must be followed at the Axiall plant. VISITOR hereby assumes full responsibility for and risk of bodily, injury, death or property damage due to VISITORS violation of any Axiall procedure or negligence of VISITOR while at the Plant.

16 ARTICLE 7 CONSTRUCTION 7.1 The provisions of this Agreement are intended to be as broad and inclusive as permitted by law, and it is agreed that if any portion hereof is held to be invalid, that the balance shall, notwithstanding, continue in full legal force and effect. This Agreement contains the entire understanding between the parties hereto and the terms of this Agreement are contractual and not a mere recital. 7.2 VISITOR acknowledges that VISITOR has carefully read the foregoing and knows the contents thereof and signs this Agreement as VISITOR'S own free act. Please Print: Name : Employed by: Signature: Date: revised 04/30/14