HEALTH AND SAFETY PLAN

FOR THE

ECOCHLOR

BALLAST WATER
TREATMENT SYSTEM









March 2009
Revision 01
CONFIDENTIAL
Health and Safety Plan
Ecochlor

Ballast Water Treatment System

US Version_2 March 2009

TABLE OF CONTENTS

1.0 EMERGENCY TELEPHONE NUMBERS ............................................................................................ 2
2.0 INTRODUCTION ................................................................................................................................. 3
2.1 Statement of Policy .............................................................................................................. 3
3.0 PURPOSE ........................................................................................................................................... 4
3.1 Modifications to the HASP ................................................................................................... 4
3.2 Scope ................................................................................................................................... 4
3.3 Personnel ............................................................................................................................. 4
3.3.1 EcochlorTechnician ....................................................................................................... 5
3.3.2 Subcontractors/Visitors ..................................................................................................... 5
4.0 HAZARD RISK ANALYSIS ................................................................................................................. 6
4.1 Chemical Hazards ............................................................................................................... 6
4.1.1 Purate............................................................................................................................ 6
4.1.2 Sulfuric Acid ...................................................................................................................... 6
4.1.3 Chlorine Dioxide ............................................................................................................... 6
4.2 Physical Hazards ................................................................................................................. 7
4.2.1 Explosion and Fire ............................................................................................................ 7
4.2.2 Heat Stress ....................................................................................................................... 7
4.2.3 Cold Stress ....................................................................................................................... 8
4.2.4 Head Injuries .................................................................................................................... 8
4.2.5 Foot Injuries ...................................................................................................................... 8
4.2.6 Eye Injuries ....................................................................................................................... 8
4.2.7 Slip/Trip/Fall ...................................................................................................................... 8
4.2.8 Noise Exposure ................................................................................................................ 8
4.2.9 Heavy Equipment/Loading Activities ................................................................................ 8
4.2.10 Hand Injuries .................................................................................................................. 9
5.0 PERSONAL PROTECTIVE EQUIPMENT ........................................................................................... 9
5.1 Levels of Protection ............................................................................................................. 9
6.0 JOB SITE CONTROL .........................................................................................................................10
6.1 Communications ................................................................................................................ 10
7.0 DECONTAMINATION ........................................................................................................................10
8.0 SITE SAFETY AND HEALTH PROGRAM DOCUMENTATION ........................................................10
9.0 EMERGENCY PLANNING .................................................................................................................11
9.1 Injury or Exposure ............................................................................................................. 11
9.2 Emergency Equipment and First Aid Requirements ......................................................... 11
10.0 EMERGENCY RESPONSE PLAN ...................................................................................................11
11.0 OPERATING PROCEDURES ..........................................................................................................11
11.1 Operation of the Ecochlor

BWTS ................................................................................... 11
11.2 Maintenance of the Ecochlor

BWTS .............................................................................. 12
11.3 Chemical Re-Supply of the Ecochlor

BWTS ............................................................... 13
12.0 REVIEW OF HEALTH AND SAFETY PLAN SIGNATURE PAGE ...................................................15








CONFIDENTIAL
Health and Safety Plan
Ecochlor

Ballast Water Treatment System

US Version_2 March 2009

1.0 EMERGENCY TELEPHONE NUMBERS

Ambulance 911
Fire Department 911
Police Department 911

Ecochlor

Technical Manager (978) 298-1463

Ecochlor

Technical Representative (978) 298-1463

Ships First Mate/Captain-Phone numbers/radio communication procedures will be discussed when
boarding the ship.

Hospital
Based on the location of the ships berthing, hospital locations will change. The ships hospital will be
used unless it is a severe injury. In the case of severe injuries while onboard, the standard response
procedures implemented by ships crew will be followed.

Information and Response Organizations
Ecochlor

24-Hr Emergency Number (978) 298-1463

CHEMTREC (800) 424-9300
National Poison Control Center (800) 484-5842
Poison Control Center (Regional (800) 484-5151
TSCA Hotline (202) 554-1404
Center for Disease Control (CDC) (404) 452-4100
(404) 329-2888

National Response Center (800) 424-8802
EPA Environmental Response Team (ERT) (201) 321-8660
Resource Conservation and Recovery Act (RCRA) Hotline (800) 424-9346

EMERGENCY REPORTING
First contact agency required to control situation will be based on type of emergency (e.g., fire
department, police); then Ships First Mate/Captain (per procedure established upon boarding), then
Ecochlor

24-Hr Emergency Number (978) 298-1463

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2.0 INTRODUCTION
This Health and Safety Plan (HASP) has been prepared as a general plan for the safe operation of the
Ecochlor

Ballast Water Treatment System (BWTS) installed on various vessels. Because the Ecochlor

BWTS may be installed on various types of vessels located and calling on different US and international
ports, this HASP is the general guiding document for Ecochlor

technicians and/or representatives with

respect to safety issues. This guidance, along with vessel-specific safety considerations that may be
necessary to address relevant issues associated with a particular system, are followed by Ecochlor

technicians and/or representatives during system maintenance and chemical replenishment operations.
For generality purposes, this HASP is written assuming a vessel is calling on a US port.
This HASP includes health and safety procedures required to minimize potential risk to personnel who
will perform ballast water treatment system operations, maintenance, and chemical resupply. General
health and safety procedures are outlined below followed by the standard procedures for operation,
maintenance, and chemical re-supply. This HASP has been prepared to comply with local, state, and
federal guidelines in the United States.
Ecochlor

employees or representatives will use this HASP when performing any work activity on any
vessel a system is installed and operating on. Site specific hazards will be evaluated upon boarding the
vessel, prior to and during ballast water treatment system operations. Prior to any personnel performing
work on a vessel, this HASP will be acknowledged. A copy of this plan will be kept at the system and
available for review at all times.
Personnel will conduct a daily health & safety meeting to discuss work to be performed that day and
identify any potential hazards.
This HASP is intended for use by Ecochlor

personnel / representatives while working with the Ecochlor

BWTS. In addition to this HASP, all Ecochlor

personnel / representatives will become familiar with and

abide by the specific ships health and safety procedures and policies.
2.1 Statement of Policy
Ecochlor

recognizes its responsibility and the need to provide healthy and safe working conditions for all
personnel. It is the desire of Ecochlor

to emphasize safe working conditions and require all personnel to

adhere to all the policies and procedures set forth.
This HASP represents the minimum health and safety requirements to be observed by all personnel
engaged in BWTS activities. Accordingly, all persons entering the work area must follow the policies and
procedures established in this HASP.
It is Ecochlors

policy to:
Provide working conditions and work places that are protected against recognized hazards that
may cause injury;
Recognize that personnel health and safety is the primary factor to consider in the work place;
Allow personnel to stop any work activity without reprisal, when a health and safety threat, or
potential threat exists;
Train personnel in regard to safe work practices;
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Provide a safe drug and alcohol-free working environment; and
Comply with health and safety laws and regulations.
3.0 PURPOSE
The purpose of this HASP is to aid in the prevention of workplace injuries, illnesses and other incidents
that could adversely impact the safety and health of all personnel working with the Ecochlor

BWTS. The
HASP assigns responsibilities, establishes personal protection standards, mandatory safety requirements
and procedures, and provides for contingencies that may arise while operations are being conducted.
This HASP complies with, but does not replace, Federal Health and Safety Regulations as set forth in 29
CFR 1910 and 1915, state, and local regulations. This HASP is to be used by personnel as a
supplement to such rules, regulations, and guidance.
Ecochlor

will provide a copy of this HASP to any subcontractors working with the Ecochlor

BWTS in
order to fulfill its obligation to inform subcontractors of site hazards. Each subcontractor will be held
accountable for the safe and healthful performance of work by each of their employees, subcontractors,
or support personnel who may enter work areas, and shall have written procedures in place to meet all
required regulations.
3.1 Modifications to the HASP
Although the HASP focuses on the operation, maintenance, and chemical resupply, it must remain
flexible because conditions may change and unforeseen situations may arise that require deviations from
the original plan. This flexibility allows modification of the HASP by the onsite personnel and takes into
account changing work conditions such as new physical hazards, weather, and modifications to the
scope of work.
3.2 Scope
The scope of work associated with this HASP includes, the operation of the system, routine maintenance,
and re-supply of the ballast water treatment chemicals.
3.3 Personnel
All personnel equally share responsibility for the individual and collective health and safety of all
personnel at the work location. Additionally, all Ecochlor

employees, representatives, subcontractors,

and visitors are equally responsible to work in a safe manner and continually identify hazards associated
with the work being performed.
All personnel are empowered to stop their own work or that of another worker if the conditions or
activities are considered unsafe. This concept is known as the Stop Work Authority and is essential to
the concept of proactive safe operations. Work must be stopped whenever conditions are considered
hazardous or behaviors are questionable. Work will not start again until the concern has been discussed
and mitigated.
Ecochlor

personnel performing tasks under this plan include Ecochlor

Technicians, Field
Representatives and/or subcontractors (at times).
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3.3.1 Ecochlor

Technician
The Ecochlor

Technician is responsible for ensuring that day-to-day on-site activities are performed in
accordance with this HASP, applicable ship safety procedures, and applicable regulations. He/she has the
authority to stop work if actions or conditions are judged unsafe or not in conformance with the HASP,
including, but not limited to, inadequate or improper use of required personal protective equipment (PPE).
The responsibilities of the Ecochlor

Technician are:
Review the ships health and safety procedures and policies with team prior to initiating work
activities;
Establish communication plan with ships crew in case of an emergency;
Establish and inform location of nearest hospital;
Assure that appropriate PPE is available and is properly utilized;
Assure that personnel are aware of potential hazards associated with the work tasks;
Interface with the applicable ships officers/supervisor to address emergency response process
and procedures;
Immediately stop work and correct any work practices or conditions that may result in injury or
unsafe conditions;
Maintaining an adequate stock of and control over all first aid supplies and other safety
equipment to insure their immediate availability; and
Maintaining an adequate stock of and control over all spill response kits that pertain to the
Ecochlor

BWTS.
3.3.2 Subcontractors/Visitors
The Ecochlor

Technician will supervise any work being conducted by subcontractors and will escort any
visitors as needed. Subcontractors and visitors are bound by all health and safety requirements provided
in this HASP. It is the responsibility of the Ecochlor

Technician to ensure subcontractors comply with

and uphold the HASP. Subcontractors and visitors have the following additional responsibilities:
Sign-in and sign-out on log sheet;
Subcontractor will designate a qualified safety representative and experienced team leader for
the work tasks and can make the necessary changes in work practices, if necessary;
Visitors will be oriented with the HASP requirements and will remain outside of potential
hazardous work areas;
Report all accidents and injuries to Ecochlor

immediately, regardless of perceived

insignificance;
Subcontractors will conduct initial and periodic equipment inspections in accordance with
manufacturer guidelines;
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Provide a copy of all Material Safety Data Sheets (MSDS) to Ecochlor

for materials brought to

the work location; and
Acknowledge that they are familiar with and will abide by the ships health and safety procedures
and policies
4.0 HAZARD RISK ANALYSIS
The field activities to be conducted onboard present a variety of chemical and physical hazards. Actual
personal exposures to these hazards are dependent upon the specific work task, weather conditions,
level of protection utilized, and personal work habits. Control of these hazards shall be accomplished
through site reconnaissance and hazard identification, training of site personnel, PPE, air monitoring (if
required), and supervision of site activities.
4.1 Chemical Hazards
Chemicals associated with the operation of the treatment system include Purate

, sulfuric acid, and

chlorine dioxide. The properties, potential health hazards, handling, spill response procedures, and fire
fighting procedures associated with each of the known substances are contained in the attached MSDS
sheets. Copies of the MSDS are maintained with the ballast water treatment system. Additionally spill
response kits are located at the system.
4.1.1 Purate
Purate

is one of the two precursor chemicals utilized for the generation of chlorine dioxide. Purate

is a
proprietary formulation from Eka Chemicals containing 40% by weight sodium chlorate (NaCl0
3
) and 8%
by weight hydrogen peroxide (H
2
O
2
). Specific information is included in the attached MSDS sheets.
The only time personnel may come into contact with Purate

is when maintenance is being conducted on

transfer lines or during chemical re-supply. Safe work practices and proper PPE will eliminate the
potential for the chemical to come into contact with the skin or eyes.
Routes of exposure are dermal, inhalation, and ingestion. All these routes of exposure are mitigated
through proper personal protection equipment use. Section 5.0 describes the required PPE needed to
protect personnel from exposure.
4.1.2 Sulfuric Acid
The sulfuric acid (H
2
S0
4
) used to generate chlorine dioxide is industrial grade 78% by weight. Specific
information is included on the attached MSDS sheets. The only time personnel may come into contact
with Sulfuric Acid is when maintenance is being conducted on transfer lines or during chemical re-supply.
Safe work practices and proper PPE will eliminate the potential for the chemical to come into contact with
the skin or eyes. Routes of exposure are dermal, inhalation, and ingestion. All these routes of exposure
are mitigated through proper personal protection equipment use. Section 5.0 describes the required PPE
needed to protect personnel from exposure.
4.1.3 Chlorine Dioxide
Chlorine dioxide is the ballast water treatment chemical and information on this chemical is included on
the attached MSDS sheet. Chlorine dioxide is only present during ballasting operations, is generated in
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an enclosed system and injected directly into the ballast stream. Therefore direct contact with the
chlorine dioxide is not expected. Because the system in not operational during maintenance activities
and there is no chlorine dioxide being generated there is no potential for exposure.
4.2 Physical Hazards
The physical hazards that may be encountered at any work location include:
Explosion and fire
Temperature Stress
Head Injuries
Foot Injuries
Eye Injuries
Slip/Trip/Fall
Pinch Point
Noise Exposure
Heavy Equipment/Cargo Activities
Hand Injuries
4.2.1 Explosion and Fire
Although fire and explosions are unlikely, the attached MSDS sheets describe procedures and media to
be utilized in case of a fire or explosion during operations of the treatment system. The stored chemicals
are incompatible with certain materials and good housekeeping procedures need to be employed to keep
the system area free from debris, trash, and any materials listed on the MSDS as being incompatible.
In the event of a fire or explosion, the ships crew will be notified. Shipboard fire procedures will be
followed and proper firefighting procedures described in the MSDS will be followed if it is safe to do so. If
it is unsafe the proper firefighting authorities will be alerted. No smoking will be permitted during or near
work activities. No cutting, welding, or hot work is expected to be performed during normal work
activities. If there is a need to perform hot work, the Ecochlor

personnel will consult with the ships

crew and follow the ships procedures for conducting any hot work.
4.2.2 Heat Stress
Depending on the time of year and location of the ship there is the potential for elevated temperature to
affect the work location. The most common symptoms of heat stress can include heat rash,
lightheadedness, and headache, thirst, disorientation, nausea, and muscle cramps. Heat exhaustion
symptoms may include many of those listed above as well as flushed clammy skin, vomiting and
unconsciousness. Heat stroke is the most serious form of heat stress. Symptoms of heat stroke can
include hot dry skin, unconsciousness, irregular heartbeat, heart attack and death. Scheduled work-rest
cycles and regular consumption of liquids and food are very effective means of controlling and minimizing
the onset of heat stress. Heat stress symptoms and control measures will be reviewed according to the
site-specific conditions.
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4.2.3 Cold Stress
Cold stress occurs when the body core temperature falls below 96.8F (36C) as a result of working in
temperatures below 40F (~5C) for extended periods. Cold stress can also occur at higher ambient
temperatures in the presence of wind in velocities approaching 25 mph. Signs of cold stress can include
numbness of body extremities, shivering, and bluing of the skin. Symptoms include extreme shivering
and a reduced body core temperature to below 91.4F (33C). Cold stress can be managed by wearing
appropriate layers of clothing during cold conditions and protecting the body extremities such as the
hands, feet, and head from undue exposure.
Personnel shall be encouraged to take rest breaks as necessary. This approach has been found very
effective because individual tolerances to heat or cold vary considerably. Specific areas or activities shall
have all work halted temporarily in extreme conditions.
4.2.4 Head Injuries
All personnel shall be required to wear a hard hat at all times. Hard hats must be worn properly and not
altered in any way that would lessen the degree of protection offered.
4.2.5 Foot Injuries
Employees are required to wear steel-toed safety shoes that also provide adequate ankle support.
4.2.6 Eye Injuries
The minimum requirement for all personnel is safety glasses with side shields. During chemical handling,
acid rated safety glasses and/or full face shields will be worn. Task specific safety glass requirements are
contained in section 5.
4.2.7 Slip/Trip/Fall
By enforcing good housekeeping practices and safe work practices, many of the situations that contribute to
these injuries can be eliminated. Proper preparation of work areas and awareness of your surroundings will
help reduce slip/trip/falls. Pipes and/or other trip hazards will be removed from the work area if possible. If
not possible they will be made known and marked if possible.
4.2.8 Noise Exposure
All personnel shall wear hearing protection when noise exceeds 85 decibels. As a rule of thumb, 85 decibels
has been exceeded if employees are unable to converse at a distance of 3 feet or less. The inability to
converse with understanding will necessitate the need for hearing protection. It is Ecochlors

recommendation that personnel have hearing protection available at all times during vessel operations
because the close quarters will intensify the noise, and periodic simultaneous vessel operations will exceed
85 decibels.
4.2.9 Heavy Equipment/Loading Activities
Ecochlor

does not anticipate operating any heavy equipment, but personnel will be in the vicinity of
heavy equipment/cargo operations (forklifts, cranes, conveyor belts, etc.). Operation of heavy equipment
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during work activities presents potential physical hazards to personnel. All Ecochlor

personnel and
subcontractors will follow the ships safety procedures for working around heavy equipment and loading
activities. In addition, the following Ecochlor

procedures will be utilized when working around heavy

equipment (cranes).
Communicate with crew on potential operations (i.e. be informed);
Listen for backup alarms;
Never work under suspended loads or within the fall radius of overhead loads;
Notify ships crew if you will be accessing an area where heavy equipment is being used or cargo
operations are underway;
Stay clear from elevated loads; and
Do not interfere with spotters/operators while equipment is operating.
4.2.10 Hand Injuries
Hand injuries can occur at any time while performing a variety of tasks. It is recommended that while
performing tasks all personnel wear the appropriate hand protection. Specific hand protection may be
determined by the type of work being conducted or the material being handled (chemical, tools, etc).
Section 5.0 describes the minimum required hand protection depending on task.
5.0 PERSONAL PROTECTIVE EQUIPMENT
5.1 Levels of Protection
The levels of protection are dependent on the type of operation being undertaken. At a minimum all
personnel are to don level D protection when boarding the ship. Specific levels of protection for each
task (operation, maintenance, and chemical resupply) are described below.
Operation of the Ecochlor

BWTS:
Minimum Level of Protection for routine activities is Standard Level D
Long pants, sleeved shirt
Steel-toed boots
Safety glasses
Gloves (appropriate for the task)
Nitrile or similar glove for sample collection
Maintenance of the Ecochlor

BWTS:
Standard Level D
Long pants, sleeved shirt
Steel-toed boots
Safety glasses
Gloves (appropriate for the task)
When performing maintenance on chemical transfer equipment and/or chemical piping
Chemical resistant gloves
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Chemical resistant suit-jacket and pants
Full face shield in addition to safety goggles
Chemical Re-Supply of the Ecochlor

BWTS:
Modified Level D (with dermal protection)
Long pants, sleeved shirt
Steel-toed boots
Chemical suit-jacket and pants
Safety goggles and full face shield
Chemical resistant gloves
6.0 JOB SITE CONTROL
The work area is defined as the immediate areas were the treatment system is located. Only authorized
personnel are permitted in this area during operation, maintenance, and re-supplying activities are being
conducted.
6.1 Communications
Telephone(s) There are no landlines on the ship for use. Cellular phones will be used for emergency
communications if needed.
Portable Radios Hand-held portable radios shall be available for utilization by personnel for
communications between ships crew and Ecochlor

personnel.
Hand Signals Hand signals shall be employed by field personnel to communicate emergency
information and to assist in the operation of loud mechanized equipment. The hand signals will be
discussed with all field personnel prior to commencement of field operations and shall be reviewed during
the safety briefings.
7.0 DECONTAMINATION
Should personnel decontamination be necessary, the attached MSDS sheets for proper decontamination
procedures for each chemical will be followed. Each MSDS has specific decontamination procedures for
skin, eyes, inhalation, and ingestion.
8.0 SITE SAFETY AND HEALTH PROGRAM DOCUMENTATION
9.1 Site and Health Plan: All site work will be performed in accordance with the provisions stated in the
HASP.
9.1.1 Site Visitors: Visitors will be discouraged from entry inside the work area and under no
circumstances will they be allowed inside the work area unless they are escorted. Visitors that require
entry into the work zone will attend a safety briefing prior to entry. Visitors will review the site health and
safety plan and sign the sign in sheet acknowledging understanding of these documents.
9.1.2 Material Safety Data Sheets (MSDS): These documents for the chemicals associated with the
Ecochlor

BWTS (Purate

, sulfuric acid and chlorine dioxide) are kept with the BWTS, are attached to
this HASP, and the vessels master maintains a copy. MSDSs are also provided with every chemical
shipment.
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9.0 EMERGENCY PLANNING
It will be the responsibility of the Ecochlor

Technician to determine the appropriate response to an

emergency incident with consultation of the appropriate ships representative. The response will be as
follows:
Designate a safe muster point for all personnel;
Remove all personnel from the source of the chemical or physical hazard;
Assess the severity of the incident; and
Immediately contact the vessel master and follow their established emergency procedures

9.1 Injury or Exposure
Personnel are required to notify management of any injury or suspected chemical exposure as soon as
possible following the occurrence. In the event of an injury or suspected chemical exposure, personnel
will contact the appropriate hospital and ambulance service if necessary, through 911 or the emergency
number provided in this plan.
9.2 Emergency Equipment and First Aid Requirements
On-site emergency equipment will primarily include items that are available for general safety use and
standard first aid supplies. These supplies include: spill kits for sulfuric acid and Purate
,
(includes
absorbents media and pads, , chemical goggles, chemical resistant gloves and body wear), first aid kits,
fire extinguishers, two-way radios, cell phones, eye wash stations, and any other required equipment
outlined in the MSDS forms.
10.0 EMERGENCY RESPONSE PLAN
It is the objective of this emergency response plan to minimize chemical or physical hazards and
operational incidents. The following directions are provided to ensure that personnel respond to
emergency situations (whether or not an Ecochlor

incident) in a calm, reasonable manner. In the event

of an emergency situation such as a fire, explosion, substance release, etc., radio communications will be
the primary means to inform the personnel of an emergency. Personnel will muster as directed and follow
the ships plan for emergency situations and evacuations (if needed).
11.0 OPERATING PROCEDURES
The following procedures have been developed to ensure all personnel perform the work task in a safe
manner. This HASP has been developed as a general HASP for the operation, maintenance, and chemical
re-supply operations of the Ecochlor

BWTS. Although the following procedures are specific to each task, a
detailed review of the specific working conditions should be conducted prior to initiating the task. If any
deviations from the following procedures are necessary the work team must discuss prior to beginning work.
11.1 Operation of the Ecochlor

BWTS
The Ecochlor

BWTS was designed to require minimal input from technicians and/or crew members. In
most installations, the system is kept in an enabled or idle state until the PLC detects a ballasting
operation.
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Operation of the Ecochlor

BWTS does not require technician or ships crew involvement, unless the
ships ballast system is manual in nature and is not capable of providing electronic signals regarding the
ballast system status. Even in such an installation, a crew member would only be required to push a
remote start button and possibly adjust ballast system valves (designed to be located in the ballast
pump room away from the Ecochlor

BWTS). In either case, the BWTS automatically delivers the

preparation chemicals and the active substance, and no technicians or crew members are required to be
at the location of the BWTS while in operation. The BWTS automatically starts, stops, and doses the
correct amount of chlorine dioxide. At no time during the normal operation of the system are Ecochlor

technicians or ship crew members required to handle chemicals.
After the system is installed and operational, Ecochlor

Technician may periodically visit the ship and

review operating procedures with the ships crew during routine maintenance visits. All safety
procedures outlined in the HASP must be followed during any visit to the Ecochlor

BWTS regardless of
reason for visit. Proper PPE will be worn at all times and radio communications will be maintained when
visiting the system.
11.2 Maintenance of the Ecochlor

BWTS
The chlorine dioxide generator requires approximately 6 hours of preventative maintenance per year.
Ecochlor

technicians will conduct this service during routine technical service visits. The scheduled
maintenance can easily be accomplished during a typical port call and will be conducted when the BWTS
is not needed for treatment of ballast water. Technical maintenance procedures are contained in the
system operations manual for each part of the system. Personnel will reference operations manual when
performing any and all maintenance on the system. All maintenance and/or repairs will be documented
on the Ecochlor

field report.
Ecochlor

provides technical support personnel who conduct periodic reviews of the BWTS, but are not
required to operate the system. The primary goal of the periodic reviews is to:

Conduct a physical inspection of all components of the BWTS, (chemical storage tanks,
generation module, piping, vent lines, pumps, electrical components, etc.);
Ensure proper cleanliness and housekeeping around the BWTS;
Review the system operation with the ships Captain, Officers and crew;
Correlate the amount of ballast water treated with the consumption of the precursor chemicals;
Check chemical pump calibrations to assure target dosages of chlorine dioxide are being met;
Document chemical inventory and schedule re-supply of the precursor chemicals as needed;
Conduct the chemical re-supply activity (only performed by Ecochlor

technicians or properly
trained representatives-see below);
Perform the required preventative maintenance on the chlorine dioxide generator (performed
during system idle time); and
Sample treated ballast water tanks for onboard and/or land based performance tests as needed.
Under normal operating conditions, Ecochlor

technicians will perform these periodic reviews

approximately quarterly, depending upon ballasting cycles, shipping schedules, and times the ship is
available to technicians. Ecochlors

business plan includes regular system service and involvement with

installed systems under a contractual agreement to ensure proper system usage and performance on a
long term basis.
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Maintenance that involves chemical inventory or re-supply will always be handled by Ecochlor

technicians, and never ships crew.
During these maintenance operations the BWTS will not be in run mode and not generating chlorine
dioxide. Therefore, exposure to chlorine dioxide cannot occur.
Ecochlor

technicians may have potential for exposure to small amounts of the precursor chemicals
during BWTS maintenance or chemical re-supply operations. During the maintenance visit the Ecochlor

Technician will document the condition of the system and report any deficiencies to the proper
manufacture (pumps, valves, etc). If repairs are needed to any piece of equipment, the Ecochlor

Technician will consult the operations manual and follow all manufactures safety procedures (found in the
operations manual) as well as all safety requirement contained in this HASP when working on the
equipment. If extensive repairs are needed a representative from the manufacturer will perform the
repairs and follow the required safety procedures contained in this HASP as well as the safety
procedures contained in the manufactures operations manual.
All required PPE must be worn based on the task being performed. See section 5.0 for proper PPE.
11.3 Chemical Re-Supply of the Ecochlor

BWTS
Re-supply of the precursor chemicals will be the only time these chemicals are ever handled during the
use of the Ecochlor

BWTS. The logistical details involved will vary based on a variety of factors for each
specific ship such as the type of vessel, the geographic location where re-supply will occur, and where
the fill station is installed on the vessel. Ecochlor

is capable of conducting chemical re-supply

operations at port facilities worldwide. ONLY Ecochlor

technical representatives or highly qualified

contractors trained by Ecochlor

will perform re-supply operations. Ships crew, longshoremen,

stevedores, and any other port facility workers will never be required to handle the precursor chemicals at
any time.
All chemical transfer lines, pumps (if used), connections, and hoses are designed to be compatible with
the specific chemical.
For general safety, awareness training of the ships crew is required and performed by Ecochlor

or its
trained representatives.
Venting: The Ecochlor

system does not give off fumes or gases during normal operation. However, a
small amount of fumes may be displaced when the chemical storage tanks are refilled, and sufficient
ventilation is necessary during these operations. For this reason, the chemical tanks are equipped with
vent lines. Each Ecochlor

BWTS installation considers proper chemical storage tank ventilation,

preferably to atmospheric conditions such as the weather deck or overboard. The locations of the
chemical tank vent lines are designed to ensure that technicians, ship or port crews are not at risk of
inhalation dangers during chemical re-supply operations.
Chemical Tank Filling Operations: The unloading of foreign materials into the Ecochlor

BWTS
chemical storage tanks could cause a dangerous event. The chemical fill lines are placed away from
other lines for loading/unloading, are clearly labeled, and secured (locked) to minimize the chance for
mis-delivery of material.
CONFIDENTIAL
Health and Safety Plan
Ecochlor

Ballast Water Treatment System

US Version_2 March 2009

The potential exposure is further minimized by proper safety training, all work being conducted with
industry standard working procedures, and the use of proper PPE. Technicians will follow the HASP,
Standard Operating Procedures (SOP) below and safe working practices when performing chemical refill
operations on the BWTS. . The SOPs mitigate the potential risks for chemical exposure to technicians.
Technicians are also to abide by any ship-specific rules (i.e. SMS) as applicable, as well as follow
instructions from the ships crew. These overlapping and redundant work practices greatly reduce the
chemical exposure risks.
Ecochlor

designs the re-supply stations and equipment to minimize required piping and facilitate the
operation. Different couplings are used for the two chemicals to make it impossible to mix the precursor
chemicals during re-supply.
Procedures for Chemical Re-Supply
Determine volume of chemical needed
Order chemical
Schedule delivery and inform ships crew
Coordinate to be sure there are no simultaneous operations occurring at the same time
(unloading/loading cargo in immediate area). Chemical refill operations will be undertaken only
when there are no cargo operations or other work tasks being performed in the vicinity of the
BWTS
Have HASP and MSDS available
Inspect all hoses and connections prior to re-supply activities beginning.
Inspect and don appropriate PPE (outlined in section 5)
Stage spill kits at fill location
Stage eye wash station and water source (for dousing if needed)
Visually inspect all transfer lines
Connect fill hose to fill port
Connect fill hoses to chemical delivery container
Place absorbent pads under all fill hose connections
Slowly open discharge valve on delivery container and vent delivery container
Slowly open fill valve to BTWS tank piping
Visually inspect fill transfer lines as chemical is being delivered to the tanks
Once chemical is completely transferred shut discharge valve on delivery container
Disconnect delivery hose from delivery container and purge hose of any residual chemical
Close fill valve
Place locking caps on hose
Lock fill valve connection
All of the above measures are in place to ensure the safe transport and re-supply of the preparation
chemicals. Depending on the type of vessel and location, these standard procedures may be modified
as needed.


CONFIDENTIAL
Health and Safety Plan
Ecochlor

Ballast Water Treatment System

US Version_2 March 2009

12.0 REVIEW OF HEALTH AND SAFETY PLAN SIGNATURE PAGE

Each team member shall sign this section after having read this Health and Safety Plan, and before being
permitted to work at the site.
I, the undersigned, have read and understand this HASP for the Ecochlor

Ballast Water Treatment

System operations. I will comply with the provisions contained therein.

Name (printed) Position Signature Date




















CONFIDENTIAL