HEALTH, SAFETY, and SECURITY PROGRAM 110 INCIDENT REPORTING & INVESTIGATION

Document Number: HSP 110 PSM 11 Prepared By: Justin Barksdale Manager Approval: Hillary Garner Current Rev: 09/1/2015 Revision No. 8 Page 1 of 34 HEALTH, SAFETY, and SECURITY PROGRAM 110 INCIDENT REPORTING & INVESTIGATION 1.0 PURPOSE This program is designed to provide guidance for incident reporting and investigation that conforms to the requirements of OSHA 1910.119 Process Safety Management of Highly Hazardous Chemicals and EPA Risk Management and prevent reoccurrence of events. 2.0 SCOPE This program applies to all incidents that occur on the Axiall Plaquemine Complex property. 3.0 DEFINITIONS 3.1 Away From Work Injuries or illnesses resulting in one or more days or shifts as applicable away from work beginning the day or shift after the injury occurred or illness began. When a licensed health care professional recommends days or shifts away from work the days or shifts are counted even if the employee comes to work anyway. Days or shifts are not counted if a licensed health care professional has released the employee to return to work and the employee does not do so. Days are full calendar days or shifts. The count of days or shifts begins with the first full day or shift away from work. Days or shifts will be counted until the employee is released by a licensed health care professional to return to work, is terminated or retires. 3.2 Catastrophic Release - A major uncontrolled emission, fire, or explosion involving one or more highly hazardous chemicals that presents or could have caused serious danger to employees in the workplace. 3.3 Chemical Exposure Anytime an employee is exposed to a hazardous workplace chemical. In some cases this is through physical contact, inhalation, absorption, ingestion, or by injection. Other cases may involve chemical exposures where there was no physical contact, absorption, ingestion or injection and the proper PPE was being worn and only requires decontamination via a safety shower. 3.4 EHSS Compliance Event Any event with environmental, health, safety or security impact that triggers a governmental reporting obligation. These include events classified as Health and Safety Compliance Events, Environmental Compliance Events or reportable Environmental Spill and Release. 3.5 Event/Incident - Any event resulting in: First Aid Injury

Document Number: HSP 110 PSM 11 Prepared By: Justin Barksdale Manager Approval: Hillary Garner Current Rev: 09/1/2015 Revision No. 8 Page 2 of 34 HEALTH, SAFETY, and SECURITY PROGRAM 110 INCIDENT REPORTING & INVESTIGATION OSHA Recordable Injury or Illness Overnight hospitalization (including observation) Security Breach (violation of facility security plan) Catastrophic equipment failure (such as line or vessel rupture, complete or partial disintegration of rotating equipment, collapsed structure, etc.) Fire Explosion Near Miss Spill Environmental Release PSM Near Miss Hazard Recognition IH-Action Level Exceedance Chemical Exposure Mechanical Failure Minor RCMS Non-Conformance Non-Work Related PSM Near Miss Tier 1 PSM Near Miss Tier 2 PSM/RMP Power Loss/Dip Process Upset Vehicle Incident Accidental release from processes covered by the Risk Management Program Regulation that results in off-site deaths, injuries, evacuations, sheltering-in-place, property damage, or environmental damage; Catastrophic release of a "highly hazardous chemical" (as defined by the OSHA PSM Standard 29 CFR 1910.119); Release (loss of containment) of 5,000 lb. of a flammable material; or any other incident identified by management as requiring investigation. 3.6 Fatality - Injuries or illnesses resulting in death. 3.7 First Aid (FA) Treatment of minor injuries and illnesses by: (a) Using a nonprescription medication at nonprescription strength; (b) Administering tetanus immunizations; (c); Cleaning, flushing or soaking wounds on the surface of the skin; (d) Using wound coverings such as bandages; (e) Using hot or cold therapy; (f) Using any non-rigid means of support; (g) Using temporary immobilization devices while transporting an accident victim; (h) Drilling of a fingernail or toenail to relive pressure, or draining fluid from a blister; (i) using eye patches; (j) Removing foreign bodies from the eye using only irrigation or

Document Number: HSP 110 PSM 11 Prepared By: Justin Barksdale Manager Approval: Hillary Garner Current Rev: 09/1/2015 Revision No. 8 Page 3 of 34 HEALTH, SAFETY, and SECURITY PROGRAM 110 INCIDENT REPORTING & INVESTIGATION cotton swab; (k) Removing splinters or foreign material from areas other than the eye by simple means (l) Using finger guards; (m) Using massages; or (n) Drinking fluids for relief of heat stress. 3.8 Health & Safety Compliance Event Any injury, illness, IH, PSM, Security or other HSS related event required to be reported or recorded to a government agency having jurisdiction at the site. 3.9 Highly Hazardous Chemical - A substance possessing toxic, reactive, flammable, or explosive properties and specified by paragraph (a) (1) of the OSHA PSM Standard 29 CFR 1910.119. 3.10 IH Monitoring Over Standard Industrial Hygiene air sample results that exceed a regulatory exposure limit, industry accepted exposure value, or in the absence of either of these occupational exposure limits, and Axiall Internal Permissible Exposure Limit and the employ was proper fitted and wearing the appropriate PPE. 3.11 IH Monitoring Over Standard Industrial Hygiene air sample results that exceed a regulatory exposure limit, industry accepted exposure value, or in the absence of either of these occupational exposure limits, and Axiall Internal Permissible Exposure Limit and the employ was proper fitted and wearing the appropriate PPE. 3.12 Legal Action Any legal action or notice of alleged violation from any Regulatory Agency to include Environmental, Health, Safety, Federal, Provincial, Transportation, Security or Product Compliance regulatory agencies. 3.13 Near-Miss Incident - An unplanned event that did not result in injury, illness or property damage, but had the potential to do so if conditions or time were different, or if the event was allowed to progress further. The scope of the near miss definition will related to health and safety incidents. There is/will be individual definitions of process safety and environmental near misses to cover spill and process events. A near miss is action or event-related. Identification of a physical hazard alone is not considered a near-miss 3.14 OSHA Medical Treatment- injuries or illness resulting in the management and care above and beyond First Aid as per 29 CFR 1904. Medical treatment does not include visits to a licensed health care professional solely for observation or counseling, or conducting diagnostic procedures.

Document Number: HSP 110 PSM 11 Prepared By: Justin Barksdale Manager Approval: Hillary Garner Current Rev: 09/1/2015 Revision No. 8 Page 4 of 34 HEALTH, SAFETY, and SECURITY PROGRAM 110 INCIDENT REPORTING & INVESTIGATION 3.15 Precautionary/No Treatment- an event or sequence of events that potentially resulted in an injury or illness where a person is sent for observation as a precautionary measure. In some cases only observation is recommended with no treatment, while others may require non-reportable diagnostics to be completed to verify the severity of the incident. 3.16 Process Safety Management Incident 3.16.1 Process Safety Incident PSI (Tier I): an incident that meets all four of the criteria: 3.16.1.1 A PSM and/or RMP listed chemical or covered chemical process involvement. 3.16.1.2 A PSM and/or RMP listed chemical or covered chemical process, including auxiliary equipment and technology needed for the production of the listed chemical, must have been directly involved in the damage caused. 3.16.1.3 An unplanned or uncontrolled release of material resulting in any of the following: An employee or contractor day(s) away from work injury and/or fatality or hospital admission and/or fatality of a third party (non-employee/contractor), or; An officially declared community evacuation or community shelter-in-place, or; Fires or explosions resulting in greater than or equal to $25,000 of direct cost to the company, or; An acute release of flammable, combustible or toxic chemicals from the primary containment greater than the Tier I chemical release threshold quantity (reference Axiall s Process Safety Management Incident and Near Miss Guidance Document Table 2). 3.16.1.4 Location: The incident occurs in production, distribution, storage, utilities or pilot plants of a covered process. 3.16.1.5 Acute release: The release of material reaches or exceeds the reporting threshold in 1-hour or less.

Document Number: HSP 110 PSM 11 Prepared By: Justin Barksdale Manager Approval: Hillary Garner Current Rev: 09/1/2015 Revision No. 8 Page 5 of 34 HEALTH, SAFETY, and SECURITY PROGRAM 110 INCIDENT REPORTING & INVESTIGATION 3.16.2 Process Safety Event PSE (Tier II) : an incident that meets all four of the criteria: 3.16.2.1 A PSM and/or RMP listed chemical or covered chemical process involvement. 3.16.2.2 A PSM and/or RMP listed chemical or covered chemical process, including auxiliary equipment and technology needed for the production of the listed chemical, must have been directly involved in the damage caused. 3.16.2.3 An unplanned or uncontrolled release of material resulting in any of the following: 3.16.2.4 Location: 3.16.2.5 Acute release: An employee, contractor or subcontractor recordable injury, or; A fire or explosion resulting in greater than or equal to $2,500 of direct cost to the company, or; An acute release of flammable, combustible or toxic lesser than the threshold quantity for PSI but greater than the Tier II chemical release threshold quantity (reference Axiall s Process Safety Management Incident and Near Miss Guidance Document Table 2). The incident occurs in production, distribution, storage, utilities or pilot plants of a covered process. The release of material reaches or exceeds the reporting threshold in 1-hour or less. 3.16.3 Process Safety Near Miss (PSNM): A Process Safety Near Miss is an undesired, unplanned event involving chemical production, distribution, storage, utilities within a covered area. It does not meet the threshold for a Process Safety Incident (Tier I) or a Process Safety Event (Tier II) but could have, under different circumstances, resulted in harm to people, damage to property, equipment or the environment or was a loss of primary containment of a PSM and/or RMP covered chemical.

Document Number: HSP 110 PSM 11 Prepared By: Justin Barksdale Manager Approval: Hillary Garner Current Rev: 09/1/2015 Revision No. 8 Page 6 of 34 HEALTH, SAFETY, and SECURITY PROGRAM 110 INCIDENT REPORTING & INVESTIGATION Examples of Process Safety Near Miss: Demands on safety systems (pressure relief devices, safety instrumented systems, mechanical shutdown systems): Activation or failure of a safety system Primary containment inspection or testing results outside acceptable limits Discovery of a failed safety system upon testing Discovery of a defeated safety system Procedural errors Unexpected / unplanned equipment condition Physical damage to primary or secondary containment Process deviation or excursion outside of safe operating limits 3.17 Restricted / Modified Duty- injuries or illnesses resulting in days or restricted or modified activity or job transfer beginning the day or shift as applicable after the injury occurred or illness began. Restricted activity occurs when, due to the recommendation of a licensed health care professional, the employee is either transferred to a different job or kept from performing one or more of the routine functions as outlined by the job duties analysis of the job he or she was performing at the time of the injury. Days are full calendar days or full shifts as applicable. The count of days or shifts begins the first full day or shift of restricted work or job transfer. Restricted activity days or shifts continue until the employee is released by a licensed health care professional to return to work with no restrictions, is given permanent restrictions, retires or is terminated. 3.18 RCA Facilitator- An individual who has completed training on Apollo Root Cause Analysis for Practitioners. 3.19 Third Party Audit/Inspection On-site audit or inspection conducted by a party, or person who is an employee of a local, state, federal or provincial agency. 3.20 Work Environment- the work environment is defined as the establishment and other locations to include any land, premises, location or thing at, upon, in or near which one or more employees are working indoors or out or are present as a condition of their employment. The work environment includes not only physical locations, but also the equipment or materials used by the employee during the course of his or her work.

Document Number: HSP 110 PSM 11 Prepared By: Justin Barksdale Manager Approval: Hillary Garner Current Rev: 09/1/2015 Revision No. 8 Page 7 of 34 HEALTH, SAFETY, and SECURITY PROGRAM 110 INCIDENT REPORTING & INVESTIGATION 3.21 Apparent Cause Investigation Apparent cause investigation are the most basic investigations and shall include at a minimum, the supervisor and the employees involved in the incident. The investigation shall determine and identify the sequence of events leading up to the incident, causal factors, and action steps and or corrective actions needed to be addressed to prevent reoccurrence. A 5-Why analysis should be utlizied for these investigations. 3.22 Root Cause Analysis Investigation of an event or incident via an investigation team using a formal cause and effect root cause analysis methodology such as Apollo or other industry recognized methodology. This process must be documented and should be uploaded into the EHSS electronic platform. Investigation materials with potential outside legal implications must be cleared with the EHSS Leadership Team. 3.23 Expanded/Detailed Root Cause Analysis Investigation of an event or incident via an investigation team sponsored by the Site Manager or Unit Manager, assembled by local Management, Corporate EHSS or Business Group. Apollo or other formalized/established root cause methodology will be utilized. Expanded team members may be comprised of subject matter experts with technical backgrounds, employees with experience and knowledge of the process involved, and may include outside consultants. This process shall be documented and uploaded into the EHSS electronic plantform as cleared by Axiall Legal. 4.0 RESPONSIBILITIES 4.1 Employees/Contractors 4.1.1 Report all on the job incidents to your immediate supervisor. Incidents may require contractor participation if they were involved in the incident. 4.1.2 Assist the supervisor in completing the electronic tracking system (Enablon) incident report. Appendix B - EHSS-08-FRM.002 Preliminary H&S Investigation Tool can be used to gather the information needed to complete the incident report 4.1.3 Cooperate with the Incident Investigation Team in any subsequent investigations. 4.2 Supervisors

Document Number: HSP 110 PSM 11 Prepared By: Justin Barksdale Manager Approval: Hillary Garner Current Rev: 09/1/2015 Revision No. 8 Page 8 of 34 HEALTH, SAFETY, and SECURITY PROGRAM 110 INCIDENT REPORTING & INVESTIGATION 4.2.1 Obtain appropriate initial medical care for injured employees, mitigate hazard and release scene as soon as possible. All injured employees must be referred to the Medical Department or Medical Emergency Response Team for Evaluation and/or treatment regardless of the severity of the accident. 4.2.2 Notify the appropriate Department Manager(s) and Environmental, Health and Safety. 4.2.3 Mitigate the incident safely and red barricade the area for preservation of evidence. Take photos of all evidence relating to the incident. Start the investigation. 4.2.4 Prior to the end of the shift enter the incident into the electronic tracking system (Enablon) or complete Appendix A - EHSS-08-FRM.001 Preliminary Investigation Form and Appendix B EHSS-08-FRM.002 Preliminary H&S Investigation Tool. 4.2.5 Cooperate with the Incident Investigation team in any subsequent investigations. 4.3 Unit Managers or Department Heads 4.3.1 Ensure the incident has been entered into electronic tracking system and information is correct. 4.3.2 Depending on the severity of the incident, notify appropriate Axiall Management and EH&S. 4.3.3 Assign an Investigation Team Leader. 4.3.4 Assign recommendations and corrective actions resulting from incident investigation to responsible parties in the electronic tracking system. 4.3.5 Ensure incident reports are reviewed with affected personnel and contractors. 4.4 Investigation Team Leader 4.4.1 Shall form an investigation team.

Document Number: HSP 110 PSM 11 Prepared By: Justin Barksdale Manager Approval: Hillary Garner Current Rev: 09/1/2015 Revision No. 8 Page 9 of 34 HEALTH, SAFETY, and SECURITY PROGRAM 110 INCIDENT REPORTING & INVESTIGATION 4.4.2 Shall assign an RCA Facilitator who not associated with unit. Appendix G On-Site Facilitators for list of site RCA Facilitators. 4.4.3 Responsible for adding all Investigative Evidence into Enablon. This includes RCA Final Report, pictures, permit, etc. 4.4.4 Ensure all hand written reports are entered in the electronic tracking system. 4.4.5 Enter the Action Items from the Root Cause Analysis into the electronic tracking system. 4.5 RCA Facilitators 4.5.1 Facilitate the Root Cause Analysis. 4.5.2 Prepare the Root Cause Analysis Report, review, finalize the report with the Unit or Department Manager, and turn over report to Investigation Team Leader. 4.5.3 Ensure all evidence is available when performing the RCA. 4.5.4 Ensure that the solutions meet the solution criteria. Solution Criteria Solutions from RCA studies must meet the following: Does it prevent reoccurrence Is it within our control Does it meet our goals and objectives 4.5.5 Submit the Root Cause Analysis investigation report to the Unit Manager. 4.6 Environmental, Health, Safety and Security 4.6.1 Ensure that environmental, health, safety, and security information is

Document Number: HSP 110 PSM 11 Prepared By: Justin Barksdale Manager Approval: Hillary Garner Current Rev: 09/1/2015 Revision No. 8 Page 10 of 34 HEALTH, SAFETY, and SECURITY PROGRAM 110 INCIDENT REPORTING & INVESTIGATION entered correctly into the electronic tracking system. 4.6.2 Assist in RCA s as needed. 4.6.3 Advise as needed in all incidents. 4.6.4 Determine if the incident is Attorney Client Privileged. 4.7 Medical Emergency Response Team Member 4.7.1 Injured/ill employees should be evaluated and treated in keeping with current medical protocols and the team member s scope of practice. 4.8 Visitors 4.8.1 Report all incidents to supervisor and Axiall contact person. 4.9 Site Manager 5.0 PROCEDURE 4.9.1 Review all RCA findings and corrective actions. 5.1 Preliminary Investigation & Communication Phase 5.1.1 Personnel must report all incidents to supervision. When an accident/incident occurs, the primary focus shall be obtaining appropriate treatment for injured people and securing the scene to prevent additional hazards or injuries. 5.1.2 Once the injured personnel have been cared for and the scene has been secured, it will be necessary to initiate a formal investigation of the accident/incident to determine the extent of damage, causal factors, and corrective actions to be implemented. 5.1.3 Supervisors are responsible for completing and communicating the Preliminary Event/Investigation Phase findings and shall assign an event owner (Unit Manager) for approvals. 5.1.4 The initial investigation data for every incident which occurs shall be entered into our electronic tracking system (Enablon) prior to the end of the shift. Appendix E Enablon Incident Workflow

Document Number: HSP 110 PSM 11 Prepared By: Justin Barksdale Manager Approval: Hillary Garner Current Rev: 09/1/2015 Revision No. 8 Page 11 of 34 HEALTH, SAFETY, and SECURITY PROGRAM 110 INCIDENT REPORTING & INVESTIGATION Note Management and EHS&S will automatically be notified via email that an incident has taken place once the event is entered into the electronic tracking system. 5.1.5 Certain tools could be required to investigate incidents. The following items should be kept on hand, easily accessible, to avoid delay in investigation. Barricade tape, and identification tags Camera Flashlight with batteries Notebook or clipboard with pens, pencils Measuring tape/ Ruler Gloves 5.1.6 Preliminary Event/Incident Investigation shall capture and document information such as the following: Incident Summary Material involved Equipment involved Area of the Incident/Event Date/Time of day of the Incident/Event PSM incident if known RMP incident if known Employee (s), Contractor(s) or Visitor(s) involved Witness(es) hand written statements Individual(s) hand written statements who were directly involved in the incident Pictures Permit JSA Isolation Lists Work order description 5.1.7 Preliminary Investigation Tool Appendix A- EHSS-08- FRM.001Preliminary Investigation Form and Appendix B EHSS-08- FRM.002 Preliminary H&S Investigation Tool is available to use as a tool

Document Number: HSP 110 PSM 11 Prepared By: Justin Barksdale Manager Approval: Hillary Garner Current Rev: 09/1/2015 Revision No. 8 Page 12 of 34 HEALTH, SAFETY, and SECURITY PROGRAM 110 INCIDENT REPORTING & INVESTIGATION to gather this appropriate information. Information collected and documented during this step will serve as a foundation for the formal investigation team and process. 5.1.8 In some cases, immediate mitigating steps and sharing and communication at the facility should occur prior to the end of shift (to include follow up with all shifts ASAP); with longer term corrective and preventative action being developed and addressed as part of the formal investigation & RCA processes. 5.2 Investigation Phase 5.2.1 Unit managers shall assign an Investigation Team Leader. 5.2.2 Once the Investigation Team Leader has been selected, it is his/her responsibility to form an investigation team. 5.2.2.1 Investigation Team members shall include but may not be limited to the following: The employee(s), contractor(s), or visitor(s) involved in the event or incident if available The shift supervisor Where applicable, individuals who have experience and are considered SME s on the specific subject, tasks or process involved in the specific incident Member(s) of the site s EHSS group Outside members or team leads may be assigned or dictated by the severity of the impact consequence. 5.2.3 Investigation team members shall be identified by name on the investigation report. 5.2.4 The Investigation Team Leader or his designee is responsible for uploading all relevant Investigation documentation to the electronic EHSS platform (Enablon). In some cases investigation information may need to be cleared by Axiall Legal prior to uploading. 5.2.5 Investigations for EHSS Compliance Events must be initiated within 24

Document Number: HSP 110 PSM 11 Prepared By: Justin Barksdale Manager Approval: Hillary Garner Current Rev: 09/1/2015 Revision No. 8 Page 13 of 34 HEALTH, SAFETY, and SECURITY PROGRAM 110 INCIDENT REPORTING & INVESTIGATION hours of the event and completed within 14 days of the event date. 5.2.6 Investigations for all other events must be initiated within 24 hours and completed within 90 days from the event date. 5.3 Analysis Phase 5.3.1 There are 3 levels of Analysis that may be utilized as part of the investigation process. They are as follows: 5.3.1.1 Apparent Cause Investigation (5-Why) 5.3.1.2 Root Cause Analysis (RCA) 5.3.1.3 Expanded / Detailed Root Cause Analysis (RCA) 5.3.2 The table Appendix C Analysis Metric details which each type of Analysis should be employed. 5.3.3 The level of Analysis may be elevated based on the severity or perceived risk of impact consequence. This may be done at the discretion of local site management, Corporate EHSS or Sr. Management. 5.3.4 The Investigation Team Leader shall assign a RCA Facilitator and RCA investigation team members. 5.3.5 RCA investigation shall identify and document root causes leading to the incident. 5.3.6 RCA s for EHSS Compliance Events must be completed within 30 days from the Investigation completion date. 5.3.7 Analysis for all other events must be completed within 90 days from the event date. 5.3.8 Action plans and corrective actions shall be developed and documented for each Analysis. Due dates for action items will be based on the severity rating of the incident/event as depicted on Appendix C. Each of these will be uploaded into Enablon. 5.3.9 Appendix F- 5 Why Investigation Form is the template to document all aspects of an Apparent Cause Investigation. 5.3.10 Appendix D Root Cause Analysis Report Form is the template to document all aspects of a Root Cause Analysis or Expanded/Detailed Root Cause Analysis.

Document Number: HSP 110 PSM 11 Prepared By: Justin Barksdale Manager Approval: Hillary Garner Current Rev: 09/1/2015 Revision No. 8 Page 14 of 34 HEALTH, SAFETY, and SECURITY PROGRAM 110 INCIDENT REPORTING & INVESTIGATION 5.4 Action Steps/Corrective Action 5.4.1 All investigations shall include action steps/ plans or corrective actions to be developed to facilitate prevention of similar incident/event. 5.4.2 All action steps/corrective actions shall be uploaded into Enablon. 5.5 Review & Approval Phase 5.5.1 All investigation requiring a RCA or expanded/detailed RCA must be reviewed and approved by the production unit manager. Corrective action shall be review with the site manager or designee. 5.5.2 All RCA s shall be documented, reviewed and communicated with all applicable shifts, units, area employees to include effected contractors. 5.6 Reporting & Communication Phase 5.6.1 All Events/Incidents and associated Analysis documentation shall be uploaded to Enablon. In some cases a summary may be developed to communicate to site management and or to be used for sharing and training. 5.6.2 Some incidents and associated investigations may require communication and review with all sites within the Axiall organization to discuss best practices and provide opportunity for lessons learned discussions. The H&S Department will be responsible for distributing these lessons learned. 5.7 Event Closure 5.7.1 Event or Incident shall be closed after all investigation have been completed, approved and uploaded into Enablon. 5.7.2 Event or Incident shall be closed after all action steps/plans and or corrective actions have been completed, reviewed and approved. 5.7.3 Appendix E Enablon Incident Workflow is available for reference. 6.0 RECORD KEEPING

Document Number: HSP 110 PSM 11 Prepared By: Justin Barksdale Manager Approval: Hillary Garner Current Rev: 09/1/2015 Revision No. 8 Page 15 of 34 HEALTH, SAFETY, and SECURITY PROGRAM 110 INCIDENT REPORTING & INVESTIGATION 6.1 All incident investigation reports will be maintained in the electronic tracking system. This shall also include all associated evidence such as photos, permits, statements etc. 6.2 All investigation reports will be maintained as required by Axiall Corporation. Following the retention period all reports will be disposed of in accordance with company policy. 6.3 All 5 Why Investigations and other documented analyses will be maintained within their respective departments and within the electronic tracking system. 6.4 If litigation exists due to incident, then retention time may be longer. 7.0 PROCEDURE REVIEW 7.1 This program will be reviewed at least every three years in connection with the Process Safety Management and Risk Management Plan compliance audit. H&S will ensure this audit is performed. The purpose is to assess compliance and to evaluate program effectiveness. 7.2 Following the review, the program will be revised to include any necssary 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 review results. 8.0 TRAINING 8.1 Employees will receive initial training on this procedure upon hire. 8.2 Supervisor will be trained in the fundamentals of completing an investigation annually. 8.3 RCA Facilitators will receive Apollo Root Cause Facilitator Training. 9.0 APPENDICES

Document Number: HSP 110 PSM 11 Prepared By: Justin Barksdale Manager Approval: Hillary Garner Current Rev: 09/1/2015 Revision No. 8 Page 16 of 34 HEALTH, SAFETY, and SECURITY PROGRAM 110 INCIDENT REPORTING & INVESTIGATION Appendix A EHSS-08-FRM.001 Preliminary Investigation Form Appendix B EHSS-08-FRM.002 Preliminary H&S Investigation Tool Appendix C - Analysis Metric Appendix D - RCA Report Form Appendix E - Enablon Incident Workflow Appendix F 5 Why Analysis Form Appendix G List of Onsite RCA Facilitators

APPENDIX A EHSS-08-FRM.001 Preliminary Investigation Form

EHSS-08-FRM.001 PRELIMINARY INVESTIGATION FORM This form must be filled out immediately after incident occurrence (but no later than end of shift) Fill Out All Applicable Sections. Be as specific as possible and include drawings, photos, additional narrative, as needed. INCIDENT TYPE Injury/Illness Fire/Explosion Equipment/Property Damage Hazard Recognition Act of Violence Environmental Near Miss HS&S Near Miss Spill/Release Other: GENERAL INFORMATION Reporting Supervisor / Investigator Name: Dept.: Date of Incident: Time of Incident: a.m. p.m. Time of Report: a.m. p.m. Date of Report: Basic Incident Description: Specific Work being performed: Specific Location of Incident: Contractor/Temporary Employee involved? If yes, name and contact information: ENVIRONMENTAL INFORMATION Agency Notified?Yes No Name of Agency: Name of Agency: Time of Notification: Time of Notification: Contact: Contact: Chemical(s) Involved: 1. >RQ?Yes No Spill outside primary containment?yes No Mitigated?Yes No 2. >RQ?Yes No Spill outside primary containment?yes No Mitigated?Yes No 3. >RQ?Yes No Spill outside primary containment?yes No Mitigated?Yes No INJURED PARTY If no injury, check box & skip this section. No Injury Name of Treating Physician: Injured Employee s Name & Job: Address of Clinic/Hospital: Treated in ER?Yes No Overnight Hospitalization? Yes No Employee go home during shift?yes No Time Employee Began Work: Consecutive Days Worked: Injury Severity First Aid Medical Only Modified Duty Days Away from Work Injury Type: Laceration Avulsion Foreign Body Heat-Related Symptoms Contusion Chemical Burn/Irritation Fracture Inhalation Abrasion Thermal Burn Sprain/Strain Other: Injury Mechanism: Struck By Pinch Point Contact with Hot Object Fall to Same Level Struck Against Chemical Contact Fall to Lower Level Other: Injury Classification First Aid US Medical Treatment CD Critical Injury CD Medical Treatment Modified Duties Lost Time Demographics: Shift: Job Yrs. Service: Plant Yrs. Service: On Overtime? Yes No PROPERTY DAMAGE List property / material damaged : Nature of damage: EVIDENCE Indicate evidence that has been collected and saved Applicable JSA (attached) Employee Statement (attached) Witness Statement(s) (attached) Physical Evidence Storage Location: Drawings - File Location: Photographs File Location: Field Notes / Sketches File Location: PPE (Only if significant for this incident) Protective suit worn Yes No Type: Hard Hat worn Yes No Type: Fall Protection worn Yes No Type: Gloves worn Yes No Type: Respiratory Protection Yes No Type: Protective boots Yes No Type: Face/Eye protection Yes No Type: Other:

Injured Employee Written Statement Describe the events leading up to the incident (describe the job, specific location, why was it being done, what were the conditions in the area, what permits and other job planning preceded the task): Describe specifically what occurred at the time of the incident (how exactly did the incident occur): Witness Written Statements Witness 1: Name: Witness 2: Name:

APPENDIX B EHSS-08-FRM.002 Preliminary H&S Investigation Tool

EHSS-08-FRM.002 FORM 2 PRELIMINARY H&S INVESTIGATION TOOL INJURY DESCRIPTION Body Diagram Name of Injured Person: Body Part Affected: Instructions: Injured employee completes this section. On the body diagram below, please indicate where your pain is located at the present time as well as the type of pain (pins/needles, ache, stabbing, numbness, etc.). Please do not indicate areas of pain that are not related to your present injury or condition. Nature of injury: (select all that apply) Abrasion, scrapes Absorption Amputation Bodily reaction Broken/fractured bone Burn (heat) Burn (chemical) Concussion Contusion (bruise) Cut, laceration, puncture Heat stress/exhaustion Hernia Hypothermia Inhalation Muscular skeletal disorder Sprain, strain Other Type of Pain +++ Achiness /// Stabbing pain xxx Tightness/stiffness === Burning sensation Pins & needles Numbness ^^^ Weakness ### Cramping Right Left Left Right Indicate on the line below how you would describe your present pain level by placing a mark on the line between the two extremes of experiencing no pain at all and experiencing the worst pain you have ever felt. 0 1 2 3 4 5 6 7 8 9 10 No Pain Worst Pain Has this body part been injured previously? If yes, describe: Are there any activities outside of work that will be impacted by this injury?

APPENDIX C Analysis Metric

Appendix C Analysis Metric Health & Safety Impact Consequence Severity PSM Points allocation Level of RCA Investigation Final Action Items Completed Within Chemical Exposure 7 0 Apparent Cause (may be escalated) 360 Days IH Monitoring Over Standard 7 0 Apparent Cause (may be escalated) 360 Days IH Monitoring Over Exposure 7 0 Apparent Cause (may be escalated) 360 Days Security 7 0 Apparent Cause (may be escalated) 360 Days Drill 7 0 Apparent Cause (may be escalated) 360 Days Vehicle 7 0 Apparent Cause (may be escalated) 360 Days Precautionary / No Treatment 6 0 Apparent Cause (may be escalated) 270 Days First Aid 6 0 Apparent Cause (may be escalated) 270 Days Canadian Medical Treatment 6 0 Apparent Cause (may be escalated) 270 Days HS&S Near Miss (PSNM) 6 0 Apparent Cause (may be escalated) 270 Days Medical Treatment 4 1 Root Cause 180 Days Restrictive / Modified Duty 4 1 Root Cause 180 Days Days Away From Work (hospitalization) 3 3 Root Cause 180 Days Fatality 2 9 Expanded / Detailed Root Cause 180 Days Off-site fatality 1 27 Expanded / Detailed Root Cause 180 Days Environmental Permit Deviation (Non-Reportable) 7 0 Apparent Cause (may be escalated) 360 Days Environmental Near Miss 6 0 Apparent Cause (may be escalated) 270 Days

Impact Consequence Severity PSM Points allocation Level of RCA Investigation Final Action Items Completed Within Numerical Permit Exceedance 5 0 Root Cause 180 Days Permit Deviation (Reportable) 5 0 Root Cause 180 Days Other Environmental Compliance Events (e.g. OEL, Control Device Bypass, Recordkeeping, etc.) 5 0 Root Cause 180 Days Release > RQ 5 0 Root Cause 180 Days Reportable Releases < RQ 5 0 Root Cause 180 Days Release of 112r flammable>5000lb 5 0 Root Cause 180 Days Off-site impact resulting in $25,000 Acute Environmental Remediation Cost < $250,000. 4 1 Root Cause 180 Days Off-site impact resulting in $250,000 Acute 3 3 Root Cause 180 Days Environmental Remediation Cost < $2,500,000, or Small-scale injury or death of aquatic or land-based wildlife 3 3 Root Cause 180 Days Off-site impact resulting in $2,500,000 Acute Environmental Remediation Cost < $25,000,000, or Medium-scale injury or death of aquatic or land-based wildlife. Off-site impact resulting in $25,000,000 of Acute Environmental Remediation Costs, or 2 9 Expanded / Detailed Root Cause 180 Days 2 9 Expanded / Detailed Root Cause 180 Days 1 27 Expanded / Detailed Root Cause 180 Days Large-scale injury or death of aquatic or land-based wildlife. Fire / Explosion 1 27 Expanded / Detailed Root Cause 180 Days Slight ( <= $2,500) 6 0 Apparent Cause (may be escalated) 270 Days Minor ($2,501 $25,000) 5 0 Root Cause 180 Days Medium ($25,000 - $100K) 4 1 Root Cause 180 Days

Impact Consequence Severity PSM Points allocation Level of RCA Investigation Final Action Items Completed Within Major ($100K $1 Million) 3 3 Root Cause 180 Days Severe ($1Million $10 Million) 2 9 Expanded / Detailed Root Cause 180 Days Catastrophic ( > $10 Million) 1 27 Expanded / Detailed Root Cause 180 Days PSM 1X to 3X TQ (PSM) 4 1 Root Cause 180 Days 3X to 9X TQ (PSM) 3 3 Root Cause 180 Days 9X to 20X TQ (PSM) 2 9 Expanded / Detailed Root Cause 180 Days >20X TQ (PSM) 1 27 Expanded / Detailed Root Cause 180 Days Community Officially declared shelter-in-place or public protective measures (e.g., road closure) for 3 Hrs 4 1 Root Cause 180 Days Officially declared shelter-in-place or public protective measures (e.g., road closure) for > 3 Hrs 3 3 Root Cause 180 Days Officially declared evacuation > 3 hrs < 24 Hrs 3 3 Root Cause 180 Days Officially declared evacuation > 24 hrs < 48 Hrs 2 9 Expanded / Detailed Root Cause 180 Days Officially declared evacuation > 48 Hrs 1 27 Expanded / Detailed Root Cause 180 Days

APPENDIX D Root Cause Analysis Report Form

Prevention Not Blame Axiall ROOT CAUSE ANALYSIS Tracking No. RCA DATE: FACILITATOR: TEAM MEMBERS: LENGTH OF INVESTIGATION: DEPT. MANAGER APPROVAL: DATE: I PROBLEM DEFINITION A B What: Summary (from the Enablon Report): C D When: Where: E Significance: i Safety ii Environmental iii Costs a Revenue Loss - b Total Cost ~ E. Frequency:

II CAUSE AND EFFECT SUMMARY III SOLUTIONS CAUSE AND EFFECT CHART (see attached chart) Cause/Effect Solution/Corrective Action P R W C G O Responsible Person Expected Completion Date 1 2 3 4 5 Abbreviations: PR = Will the solution prevent recurrence? WC = Is the solution within our control? GO = Does the solution meet GGC goals and objectives?

APPENDIX E Enablon Incident Workflow

ENTER INCIDENT INFORMATION IN ENABLON CREATE ENTER IMPACTS Enter all impacts that resulted from the incident CONDUCT INVESTIGATION If required, complete 5-Why or RCA Investigation DRAFT ENTER STATEMENTS Attach any statements taken from witnesses, etc. ENTER EVIDENCE Attach 5-why or RCA Report, photos, documents, graphs, etc. ENTER ACTION PLANS COMPLETE ACTION PLANS Complete all assigned action items and submit for Event Owner approval CLOSE ACTION PLANS Event Owner approves & closes action plans. When ALL action plans are closed, send EVENT for Event Owner Review

SUBMIT EVENT OWNER REVIEW REVIEW EVENT Review the entire event and either reject back to INVESTIGATION phase or Approve & Submit to EHS Review APPROVE EHS REVIEW REVIEW EVENT Review the entire event and either reject back to the Event Owner or Approve & Close APPROVE AND CLOSE

APPENDIX F 5 Why Investigation Form See attached Appendix on PLQ. Connect Page for 5 WHY Form

APPENDIX G On-Site RCA Facilitators See attached Appendix on PLQ. Connect Page for Matrix of Trained RCA Facilitators