Commitment to Safety

Protecting People and the Environment

In accordance with the Company’s Environmental, Health, Safety, and Security (EHSS) policy, TPC Group’s vision is to protect people and the environment; therefore, we conduct all of our operations and manage all of our products in a safe, reliable, environmentally responsible, and efficient manner. We strive to achieve excellence in environmental, health, process safety, safety, and security (EHSS) performance.

The Company has established safety programs to address both process safety and individual employee occupational safety including:

• A robust incident investigation system with more than 100 employees trained in the Company root cause analyses process and quarterly Operations Company-wide review sessions of significant investigation findings and corrective actions
• A corrective action tracking system to ensure timely and complete closure of corrective actions resulting from incident investigations, audits, process hazards analyses, and other appropriate EHSS review
• Behavioral based safety observations, regular safety meetings, and employee safety teams for each operating site

As a member of the American Chemistry Council (ACC), TPC follows definitions and public reporting requirements under ACC’s Responsible Care® program for process safety incidents as well as all other aspects of the program (4.9). Based on ACC’s definitions , TPC has experienced no process safety incidents in any of the years 2007 through 2009.

In 2007, TPC underwent a process safety management (PSM) audit by the regional office of the Occupational Safety and Health Administration (OSHA). The audit was performed under their Regional Emphasis Program (REP), a predecessor to OSHA’s National Emphasis Program (NEP) for evaluating PSM programs at U.S. refineries and their later NEP for U.S. chemical plants. As a result of the audit, TPC and OSHA entered into a settlement agreement to address audit findings. As of June 2010, TPC has completed all of its obligations under the settlement agreement. TPC continues work to enhance its process safety programs through ongoing efforts to evaluate Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) and upgrade its programs accordingly.

The Company uses third-party auditors for its three-year compliance audits under the OSHA PSM program. Third-party audits for all Company operations covered under the PSM program were completed during the year 2009. The audits serve as a tool to facilitate continuous improvement in Company process safety programs. Upon completing resolution of audit findings, TPC validates the completion.