Occupational Safety and Health Compliance Manual

OCCUPATIONAL SAFETY AND HEALTH COMPLIANCE MANUAL

Gevo, Inc. 345 Inverness Drive South Englewood, CO 80112

June 12, 2018

In part prepared by:

11913 W. I-70 Frontage Road North Wheat Ridge, CO 80033 303.384.9828

301 S. Elm Street, Suite 524 Greensboro, NC 27401 336.274.5886

INTENTIONS AND LIMITATIONS

All reasonable measures have been taken to ensure the accuracy and reliability of the information contained herein; however Hellman & Associates, Inc. (H&A) makes no representation, warranty, or guarantee, either expressed or implied, in connection therewith. H&A disclaims any liability for any direct or indirect loss or consequential damages resulting from the use of any of the information contained herein, or for the violation of any federal, state, or municipal regulation with which any of the information may conflict.

The information in this manual is provided for the exclusive use of our clients and is for informational and educational purposes only; and where applicable in meeting federal or state regulations. It is not designed or intended as an exhaustive or comprehensive assessment of applicable law. Every situation is different. We urge our clients and prospective clients to contact H&A with specific questions, inquiries or problems. Only a thorough and site-specific analysis can ensure adequate compliance with applicable laws and regulations.

QUESTIONS OR COMMENTS ABOUT THIS MANUAL? CONTACT:

Hellman & Associates, Inc. 11931 I-70 Frontage Road North Wheat Ridge, CO 80033 Phone: 303-384-9828 Fax: 303-384-9827 Or email us at: [email protected]

REVISION RECORD

Revision Date Corrections By Changes Made Reasons For Changes

New manual from OSHA Compliance, New H&A 4/27/2018 Sara Krall H&A with program Assured Compliance Client updates

5/22/2018 Sara Krall Second draft of H&S Changing of language Manual 6/12/2018 Sara Krall Removed DRAFT from Issuing H&S Manual document and Andrew Hawkins name 7/23/2019 Meagan Lewis Updated chemical We are only going to be labeling hygiene plan to reflect secondary containers in the lab current practices with contents.

POLICY STATEMENT

Safety is a core value at Gevo. We are committed to an injury- and incident-free workplace—we believe all injuries are preventable and the health and safety of our employees is critical to the long- term success of our company.

Gevo integrates safety into every job task so safety and job performance become inseparable. Through the cooperative efforts of all management team members and our workforce, we maintain a consistently incident and injury free environment.

At Gevo we believe that safety requires open communication, accountability, ownership, and a personal commitment by every member of the organization. Nothing is more important than keeping our people safe.

______Chris Ryan Date President, CTO, COO

Gevo Table of Contents

Table of Contents

HEALTH AND SAFETY PROGRAM ...... 1 Policy Statement ...... 1 Company Goals ...... 1 Management Commitment...... 2 Assignment of Responsibility ...... 2 Health and Safety Coordinator ...... 2 Supervisors ...... 3 Employees and Contractors ...... 3 Safety Team Objectives ...... 4 Discipline and Enforcement of Safety Rules and Policies...... 5 Hazard Identification and Risk Assessment ...... 5 Workplace Survey and Walkthrough ...... 5 Hazard Analysis ...... 5 Exposure Monitoring ...... 7 Injury and Illness Analysis and Recordkeeping ...... 8 OSHA 300 Log ...... 8 Incident Investigations ...... 8 Responsibilities ...... 8 Investigation Procedure ...... 8 Training on Incident Investigation ...... 9 Hazard Prevention and Control ...... 10 Engineering Controls ...... 10 Administrative Controls ...... 10 Personal Protective Equipment (PPE) ...... 10 Equipment Maintenance ...... 10 Safety Rules and Procedures ...... 11 Designated Medical Provider ...... 12 Claims Management ...... 12 Return to Work ...... 13 Stop Work Orders ...... 15 Roles and Responsibilities ...... 15 Contractor Management...... 16 Program Review and Evaluation ...... 17 Forms ...... 17

BLOODBORNE PATHOGENS PROGRAM ...... 18 Purpose ...... 18 Scope ...... 18 Exposure Determination ...... 18

Gevo Table of Contents

Definitions...... 18 Methods of Compliance ...... 19 Exposure Job Classifications and Tasks ...... 20 Hepatitis B Vaccination and Post-Exposure Evaluation and Follow-Up ...... 20 Communication of Hazards to Employees ...... 20 Recordkeeping ...... 21 Forms ...... 21

CHEMICAL HYGIENE PROGRAM ...... 22 General Company Policy ...... 22 Definitions...... 22 Responsibilities ...... 23 Chemical Hygiene Officer ...... 23 Laboratory Personnel ...... 23 Laboratory Facilities ...... 24 Chemical Fume Hood Evaluation ...... 24 Eyewashes and Safety Showers ...... 24 Fire Safety Equipment ...... 24 Basic Laboratory Procedures ...... 26 General Guidelines...... 26 Personal Hygiene ...... 26 Housekeeping ...... 27 Chemical Procurement, Distribution and Storage ...... 27 Procurement ...... 27 Distribution ...... 27 Chemical Storage in the Laboratory ...... 28 Chemical Storage - Chemical Stability ...... 29 Chemical Storage - Incompatible Chemicals ...... 29 Chemical Exposure Assessment ...... 31 Criteria for Implementation of Control Measures ...... 32 Fume Hoods ...... 32 Safety Shields or Other Containment Devices...... 32 Personal Protective Equipment ...... 34 Signs and Labels ...... 36 Medical Consultation and Examination ...... 37 Spills and Incidents ...... 37 General Information ...... 37 Cleaning Up Chemical Spills ...... 37 Minor Chemical Spill ...... 38 Major Chemical Spill ...... 38 Chemical Safety Training ...... 38 Waste Disposal Program ...... 39 Additional Employee Protection for Work with Particularly Hazardous Substances ...... 39 Recordkeeping, Review and Update of Chemical Hygiene Plan ...... 40

Gevo Table of Contents

Exposure Evaluation ...... 40 Medical Consultation and Examination ...... 40 Training ...... 40 Fume Hood Monitoring ...... 40 Review and Update of Chemical Hygiene Plan ...... 40 Forms ...... 40

COMPRESSED GAS CYLINDER PROGRAM ...... 41 Purpose ...... 41 Scope ...... 41 Authority and Responsibility ...... 41 New Cylinders ...... 41 Labeling ...... 42 General Handling and Use Procedures ...... 42 Specific Handling Procedures ...... 43 Storage ...... 45 Transportation of Cylinders ...... 46 Disposal or Return of Cylinders ...... 46 Training ...... 47

ELECTRICAL SAFETY PROGRAM ...... 48 General Company Policy ...... 48 Definitions...... 48 Responsibilities ...... 50 Installation and Maintenance Work ...... 50 Guarding of Live Parts ...... 51 Visual Inspection ...... 51 Flexible Cords and Cables ...... 51 Training ...... 52

EMERGENCY PREPAREDNESS AND FIRE PREVENTION PROGRAM ...... 53 Purpose ...... 53 Emergency Telephone Numbers ...... 53 Health and Safety Coordinator ...... 53 Emergency Response Coordinator ...... 53 South Metro Fire Department ...... 53 Workers Comp Clinics ...... 53 Personnel Roles, Lines of Authority ...... 54 Reporting Fire and Emergency Situations ...... 55 Emergency Recognition and Evacuation ...... 55 Fires...... 56 Hazardous Substances Spills...... 57 Fire Prevention ...... 57

Gevo Table of Contents

Training ...... 58 Critique of Response and Follow-Up ...... 58 Workplace Violence...... 58

HAZARD COMMUNICATION PROGRAM ...... 60 General Company Policy ...... 60 Definitions...... 60 List of Hazardous Chemicals ...... 62 Safety Data Sheets ...... 62 Labels ...... 64 Non-Routine Tasks ...... 65 Training ...... 65 The Hazard Communication Standard: ...... 65 Hazardous Chemicals: ...... 65 Safety Data Sheets: ...... 65 Labeling: ...... 66 Employee Protection Measures: ...... 66 Contractors / Multi-Employer Worksites...... 66

LOCKOUT/TAGOUT PROGRAM...... 67 General Company Policy ...... 67 Definitions...... 67 Responsibilities ...... 68 Equipment Lockout Procedures ...... 69 Preparation for Lockout/Tagout ...... 69 Sequence of Lockout/Tagout System Procedure ...... 69 Group Lockout ...... 70 Sequence of Lockout/Tagout Removal ...... 71 Periodic Inspections ...... 71 Training ...... 71 Record Keeping ...... 71 Forms ...... 72

PERSONAL PROTECTIVE EQUIPMENT PROGRAM...... 73 General Company Policy ...... 73 Hazard Assessment and Equipment Selection ...... 73 Protective Devices ...... 73 Eye and Face Protection...... 74 Prescription Safety Eyewear ...... 75 Emergency Eyewash Facilities ...... 75 Head Protection ...... 75 Foot Protection ...... 75 Hand Protection ...... 75

Gevo Table of Contents

Cleaning and Maintenance of Personal Protective Equipment ...... 76 Training ...... 76 Recordkeeping ...... 77 PPE Specifications ...... 77 Forms ...... 77

RESPIRATORY PROTECTION PROGRAM ...... 78 General Company Policy ...... 78 Respirators ...... 78 Voluntary Use ...... 78 Training ...... 78 Forms ...... 79

SAFE WORK PRACTICES PROGRAM ...... 80 General Company Policy ...... 80 Ladder Safety ...... 80 General Use ...... 80 Hand and Power Tools ...... 81 Power Tool Precautions ...... 81 Hearing Protection ...... 82 Material Handling ...... 82 Manual Lifting ...... 83 Training ...... 84

Policy Statement

Without question, safety is our number one responsibility, taking precedence over everything we do. No job is so important and no order so urgent that we cannot take the time to perform our work in a safe manner. It is the policy of Gevo to provide and maintain safe and healthful working conditions.

Gevo is dedicated to protecting public health and the quality of the environment, the health and safety of our employees, our customers and our neighbors.

• By holding every employee responsible for implementing our safety practices and our corporate safety policy;

• By developing and using innovative technology and processes to prevent adverse impact from company operations on public health, employee health and the environment; • By conducting an independent audit function to assure compliance with all applicable laws and regulations; and • By providing leadership within our business to establish effective environmental, safety and occupational standards.

Company Goals

Safety begins at the top and involves everyone in the company. Our primary goal is to have an injury-free work place. This can be achieved by delegating responsibility and accountability to all involved in the company’s operation. We will use additional benchmarks as necessary to help us achieve this goal.

Responsibility: Having to answer for activities and results.

Accountability: The active measurement by management to ensure compliance, or management doing something to ensure action.

Everyone should take responsibility and be held accountable to reach our goal of maintaining a safe work place.

Benefits of achieving our goals are:

• Minimizing all injury accidents;

• Minimizing loss to property and equipment; • No fatalities; • No permanent disabilities;

Hellman & Associates, Inc.  All rights reserved. 1 Gevo Health and Safety Program • Having the best safety and health conditions possible; and • Improving overall business operations to make us more competitive in the marketplace.

Management Commitment

The management of Gevo is committed to the company’s safety policy, and to provide direction and motivation by:

• The appointment of a Health and Safety Coordinator;

• Establishing Gevo safety goals and objectives; • Maintaining this written health and safety plan; • Enforcement of health and safety disciplinary procedures for employees;

• Support the Health and Safety program with people, authority, and training; and • Establishing accountability and responsibility for management and employees to follow.

Assignment of Responsibility

Health and Safety Coordinator

Gevo has designated Jenifer Meinholz to manage the environmental, health, and safety (EHS) program at the Englewood facility. The terms Health and Safety Coordinator and EHS are used interchangeably in this manual.

It shall be the duty of the Health and Safety Coordinator to assist Site Supervisors and Management in the initiation, education, and execution of an effective health and safety program and more specifically the following:

• Introduce the safety program to new employees; • Follow up on recommendation, suggestions, etc. made at safety meetings and/or ensure that hazards reported by employees are evaluated and corrected as needed in a timely manner. • Develop Site-specific work and safety plans for major operations as appropriate;

• Develop specific goals related to health and safety for the organization and track them on a regular basis; • Be thoroughly familiar with the company health and safety program and assist the personnel in the execution of standard policies; • Conduct or delegate safety inspections on a periodical basis;

• Address all identified hazards or potential hazards as needed; • Prepare and/or review accident reports and investigations;

Hellman & Associates, Inc.  All rights reserved. 2 Gevo Health and Safety Program • Maintain adequate stock of first aid supplies and other safety equipment to ensure their immediate availability; and • Maintain the required elements of written programs and ensure all required inspections and training are conducted.

Supervisors

Supervisors will establish an operating atmosphere that insures that health and safety is managed in the same manner and with the same emphasis as customer service, cost, and quality.

Supervisor responsibilities:

• Define, if necessary, responsibilities for health and safety of all subordinates and hold each person accountable for their results;

• Regularly emphasize that accident and health-hazard exposure prevention is a condition of employment; • Maintain safe work practices and safe working conditions within the area under his/her supervision; • Spend time with each person hired explaining the safety policies and the hazards of their particular work;

• Never short-cut safety for expediency, nor allow workers to do so; • Enforce safety rules consistently, and follow company’s discipline/enforcement procedures; • Periodically conduct a Site walk-through and correct noted safety violations;

• Ensure that PPE is provided and used where required; • Ensure all hazards identified by employees are addressed in a timely manner; • Periodically conduct safety meetings on an as needed basis; and

• Maintain first aid kits, emergency supplies and information as required.

Employees and Contractors

It is the duty of each and every employee and contractor to know the safety rules, and conduct their work in compliance with these rules. Disregard of the safety and health rules shall be grounds for disciplinary action up to and including termination. It is the duty of each employee and subcontractor to make full use of the safeguards provided for their protection. Every employee will receive an orientation when hired and receive company health and safety rules and procedures for the Health and Safety Program.

Employee and subcontractor responsibilities are:

• Read, understand and follow health and safety rules and procedures;

• Wear personal protective equipment (PPE) in laboratory areas;

Hellman & Associates, Inc.  All rights reserved. 3 Gevo Health and Safety Program • Wear suitable work clothes at all times; • Employees observed working in a manner that might cause injury to either themselves or other workers shall be warned of the danger and will immediately correct their method of operation;

• Employees shall report all injuries, no matter how slight to their Supervisor immediately, and seek treatment promptly; • Employees shall be aware of the location of first aid, eyewash, firefighting equipment, and other safety devices; • Report all hazards to your Supervisor;

• Attend any and all required health and safety meetings; • Drinking alcohol or taking illegal narcotics in any form just before or during work hours is not permitted and will be disciplined up to and including termination; and • Employees are to follow all procedures identified in the health and safety program and shall not perform potentially hazardous tasks or use any hazardous material until properly trained.

Safety Team Objectives

The safety and health program shall be reviewed annually, and be revised, updated or changed at that time, if needed.

Employees chosen by the Health and Safety Coordinator or current safety team shall participate on the safety team for six months, rotating employees once every six months. There will be two to three people on the safety team, including the Health and Safety Coordinator, Hellman & Associates, and one other employee.

The team will meet as needed and at a minimum once every six months and have the following responsibilities:

• Discuss safety policies and procedures among management and make recommendations for improvements. • Choose a Safety-related topic to train employees; • Serve as liaison between workers and management in safety matters; • Provide technical reference material;

• Review accident investigation reports on all accidents; • Identify unsafe conditions and practices, and make recommendations for remedies; • Review facility audits;

• Time and action plan for outstanding issues that need correction; • Safety checklist review for each Facility and • Document meeting in the written minutes.

The team will be led by Jenifer Meinholz.

Discipline and Enforcement of Safety Rules and Policies

Gevo safety rules and procedures are documented in this H&S Manual, as well as in task specific and safety Standard Operating Procedures (SOPs). These rules are comprised of:

• OSHA rules and regulations • Gevo -specific rules and regulations

The contents of the Safety Manual are considered to be minimum standards of safety and shall be strictly followed. Management is responsible for enforcing these rules.

Safety violations are often noted after an incident has occurred. Supervisors should perform frequent physical inspections of work areas to ensure employees are following safe work practices and to identify unsafe conditions or actions.

The first violation of health and safety rule or policy will result in a verbal warning and explanation. A second violation of the same rule will result in a written reprimand that will go into the employee’s permanent file. The third violation may result in immediate termination.

Hazard Identification and Risk Assessment

Workplace Survey and Walkthrough

Periodically, a health and safety hazard survey will be conducted, documenting all inconsistencies and deficiencies with the OSHA 29 CFR 1910 General Industry Standards. This will be used to establish a management corrective action plan to abate all inconsistencies and deficiencies.

Periodic walkthroughs of projects and sites will be conducted to review compliance status and recognize any inconsistencies and deficiencies. The walkthroughs will be documented and include an action plan for corrective actions.

Hazard Analysis

When hazards are identified, a hazard analysis may be done to further assess the hazards of specific jobs, processes, and/or phases of work. A job hazard analysis (JHA) should be used for routine and non-routine activities, as well as new processes, changes in operation, or services. The hazard analysis is an orderly process for locating, evaluating, and ranking hazards/consequences that are most probable and have the severest consequences. The JHA will review each step of the process, identifying existing or potential hazards (both Health and Safety), and recommend changes to eliminate or reduce the hazards.

Hellman & Associates, Inc.  All rights reserved. 5 Gevo Health and Safety Program Hazards are classified and ranked based on severity. The program identifies hazards, which are classified/ prioritized and addressed based on the risk associated with the task. (See the risk analysis matrix below, outlining severity and probability.)

CONSEQUENCE PROBABILITY

A B C D E

Several Multiple

Not Once a Rarely Times in a Times in a Done week

Week Day

Severity People Assets Environment Reputation No health No 0 No effect No impact effect damage Slight health Slight 1 Slight effect Slight impact effect damage Minor health Minor Limited 2 Minor effect effect damage impact Major health Localized Considerable 3 Localized effect effect damage impact Major National 4 Single fatality Major effect damage impact Multiple Extensive 5 Massive effect Global impact fatalities damage

Manage for continuous improvement Incorporate risk reduction measures Intolerable Key (Low) (Medium) (High)

The JHA will determine the need for, and proper selection of, personal protective equipment, training and operational procedures. JHA’s will be documented and maintained in the project file.

If it is determined by Gevo that JHA’s will be developed and utilized as part of an effective program for safety hazard identification and control, all hazard analyses will be documented and reviewed at least annually, or when the process or operation changes.

If an accident, injury, or illness is associated with a specific job or process, a hazard analysis will be performed during the incident investigation and determine whether changes are needed with existing program procedures.

Exposure Monitoring

When the workplace analysis identifies existing and potential health hazards, exposure monitoring is used to evaluate the employee’s level of exposure.

Personal samples are used to measure air contaminants in the employee’s breathing zone and will be collected to represent actual working conditions. Noise Sampling will be performed using noise dosimeters.

Gevo will use a qualified industrial hygiene consultant to conduct all exposure monitoring on an as needed basis, or if there is a change in procedure, e.g. Hellman & Associates.

Gevo will keep records of fatalities, injuries, and illnesses, and record each fatality, injury and illness that is work-related; is a new case; and meets one or more of the general recording criteria.

OSHA 300 Log

Every OSHA recordable injury and illness shall be recorded on an OSHA 300 log within seven calendar days from the time Gevo learns of the injury or illness. This log and all associated recordkeeping forms will be maintained on a calendar year basis and shall be retained for 5 years. OSHA 300 logs are located on the server, where an authorized representative must sign.

Gevo will post an annual summary of recordable injuries and illnesses, which includes the calendar year, certification signature and title of a Gevo management official, and date. The summary covering the previous calendar year shall be posted in a visible location to all employees no later than February 1 and remain in place until April 30.

In addition to posting, Gevo will submit information from their annual summary form (Form 300A) electronically to OSHA or OSHA’s designee annually, as required by 1904.41(a)(2). In 2018 the 300A form will be submitted by July 1. Beginning in 2019 and every year thereafter, forms will be submitted by March 2.

Incident Investigations

Responsibilities

Management is responsible for conducting the incident investigation. Depending upon the severity of the incident, the Gevo Health and Safety Coordinator may be contacted to assist in the on-site investigation. All personal injuries, property damage, fire, and near-miss incidents fall under these investigation requirements.

Investigation Procedure

The supervisor or designee will take the following actions in the event of an incident.

• Provide first aid, call emergency medical care, if required; • If further medical treatment is required, arrange to have an employee accompany the injured employee to the medical facility; • Secure area, equipment and personnel from injury and further damage;

• Investigate the incident (injury): Gather all pertinent facts, take employee and witness statements, take pictures of incident site and equipment involved, and take pictures or

Hellman & Associates, Inc.  All rights reserved. 8 Gevo Health and Safety Program draw maps with the position and location of equipment or personnel. There will be one digital camera for all Gevo employees to use when needed. ▪ It is vital that the investigation begin as soon as possible after the event and employees have received medical attention. Depending upon the severity or complexity of the incident, the investigation may take a significant period of time. However, an initial identification of evidence immediately following the incident might include a listing of people, equipment, and materials involved and a recording of environmental factors such as weather, illumination, temperature, noise, ventilation, and physical factors such as fatigue, age, and medical conditions. These factors might change over the course of the investigation and should be immediately documented or secured and preserved. ▪ The actions listed above, as well as listed on the incident investigation forms, are part of a root cause analysis incident investigation program that looks to get at all the contributing elements that led to the incident. ▪ The collection of witness statements through interviews is essential to the investigation. All Gevo supervisors are authorized to conduct interviews with the understanding that this activity is not designed to assign blame; this will help provide unbiased testimony. Interviews should be private and held in a comfortable location. Follow-up interviews may be conducted to clarify points or ask additional questions that may arise during the investigation. If the incident resulted in an employee fatality, an in-patient hospitalization (i.e., defined as admittance) amputation, or loss of eye, it must be reported to OSHA within 24 hours by one of the following methods:

• Call the nearest OSHA office (Denver): 303-844-5285; • Call the OSHA 24-hour hotline: 1-800-321-6742 (OSHA); or • Report online: https://www.osha.gov/pls/ser/serform.html

• Be prepared to provide: business name, names of employee(s) affected, location and time of incident, brief description of the incident, contact person and phone number. • In the event of a fatality to one or more employees, the Gevo Health and Safety Coordinator will contact the appropriate OSHA office within 8 hours of the incident. • Complete a written incident investigation report form within 24 hours whenever possible and provide the report to the Health and Safety Coordinator upon completion; • Insure that corrective actions are identified to prevent a recurrence is taken; and

• Discuss incident, where appropriate, in safety and other employee meetings with the intent to prevent recurrence.

Training on Incident Investigation

All supervisors will receive an orientation on the incident investigation detailed procedures above, and key elements for conducting an effective incident investigation. This training will occur before assignment of incident investigation responsibilities. Recurring training will take

Hellman & Associates, Inc.  All rights reserved. 9 Gevo Health and Safety Program place if the elements of the incident investigation procedure change or any deficiencies in the procedures are identified.

Hazard Prevention and Control

Engineering Controls

Engineering controls involve physical changes to the work area, equipment, facility, or other relevant aspects of the work environment.

Engineering controls are the preferred method for controlling hazards.

Gevo will utilize engineering controls whenever possible.

Administrative Controls

Administrative Controls are procedures, which significantly limit daily exposure by control or manipulation of the work schedule, or manner in which work is performed.

Administrative controls do not eliminate or limit the hazard. Consequently, the controls must be consistently used and enforced.

Personal Protective Equipment (PPE)

PPE is specialized clothing or equipment worn by an employee for protection against a hazard.

PPE will only be used when other engineering and work practice controls are not feasible or until other controls can be implemented.

All required PPE is identified in the PPE program and is accessible and provided in appropriate sizes at no cost to the employee.

Equipment Maintenance

Equipment maintenance is essential to the health and safety program to prevent hazardous breakdowns.

A preventive maintenance schedule exists for some equipment and follows all manufacturers’ and industry recommendations and consensus standards for maintenance frequency.

All repairs for safety-related items shall be expedited and all safety device checks shall be documented.

Safety Rules and Procedures

• No employee or subcontractor is expected to undertake a job until that person has received adequate training. • All employees and Contractors shall be trained on potential hazards that they could be exposed to and how to protect themselves.

• No employee or subcontractor is required to work under conditions, which are unsanitary, dangerous or hazardous to their health. • Only qualified trained personnel are permitted to operate machinery or equipment. • All injuries must be reported to management.

• Manufacturer’s specification and limitation instructions shall be followed. • All manufacturer-supplied guards shall be maintained and not removed. • Employees working in areas that require PPE shall use the designated PPE provided by the company.

• All hand and power tools and similar equipment, whether furnished by the employer or the employee, shall be maintained in a safe condition. • All materials stored in tiers shall be stacked, racked, blocked, interlocked, or otherwise secured to prevent sliding, falling or collapse. • All electrical equipment shall be free from recognized hazards that are likely to cause death or serious physical harm to employees.

• The facility shall be kept clean; the floor of every work area shall be maintained, so far as practicable, in a dry condition; standing water shall be removed. • To facilitate cleaning, every floor, working place, and passageway shall be kept free of hazards. • To evaluate adherence to the above rules and procedures, company vehicles, project materials and equipment shall be inspected periodically by a competent person.

Gevo has partnered with our worker’s compensation insurance company to provide our employees with the best occupational care available. In Colorado, if an employee is injured on the job, you are to provide your employer with written notification of the injury within four working days of the injury. Then report to one of the following worker’s compensation clinics listed below and on the Designated Provider List obtained from the Health and Safety Coordinator. If the employee chooses to seek medical treatment at a provider not on the Designated Provider List, they may be responsible for the cost of treatment.

Greenwood Village Family Medicine Aspire Family Medicine 8200 E. Belleview Ave. #204C 9620 E. Arapahoe Rd. Greenwood Village, CO 80111 Greenwood Village, CO 80112 P: (303)221- 5700 P: (303)835-9915

Sky Ridge Medical Center Workwell Occupational Medicine 10101 RidgeGate Parkway 2550 South Parker Road #150 Lone Tree, CO 80124 Aurora, CO 80014 P: (720)225-1000 P: (720)512-4408

In the event of a life-or-limb-threatening emergency, the insured employee will be sent to the nearest emergency medical facility. However, any follow-up care must be provided by one of the medical provider(s) designated above.

Claims Management

Fear and uncertainty are primary reasons for injured employees to delay reporting injuries. This may be due to concern over medical bills, lost income or even the loss of employment. The following procedure will be conducted to alleviate these fears and ensure that workers’ compensation claims will be handled in a fair and expeditious manner.

1. All employees will be provided with an explanation of the workers’ compensation system and the benefits it will provide. 2. In the event of a work-related injury or illness, the injured employee must report it to their immediate supervisor or the Health and Safety Coordinator before the end of the work shift. 3. If the injured employee needs immediate medical attention, they will be driven or sent to the nearest appropriate hospital or clinic. 4. If the injury is not an emergency, an appointment will be made with the designated medical provider as soon as possible. 5. An incident investigation will be conducted following all work-related injuries. Management, the Health and Safety Coordinator, or human resources will be responsible for interviewing the injured employee and all witnesses.

Hellman & Associates, Inc.  All rights reserved. 12 Gevo Health and Safety Program 6. The Health and Safety Coordinator or human resources will report the claim by phone to Berkshire Hathaway within 24 hours of the accident. [Reporting Phone Number: 800-661- 6029] 7. If the incident involved an employee death OSHA must be notified within 8 hours of the accident. If the incident involved an employee in-patient hospitalization, amputation, or loss of eye OSHA must be notified within 24-hours. See the Incident Investigation section for additional information. 8. The Health and Safety Coordinator will use information from the accident investigation to identify changes that may help prevent future incidents. 9. For lost time claims, the Health and Safety Coordinator will contact the injured regularly to answer questions, keep the injured employee informed of organization activities, and discuss return to work options. 10. Human resources will contact the medical provider as needed to keep current on the employees work status, medical progress, and to ensure that appointments are being kept. 11. Modified duty procedures will be accommodated whenever feasible and the process will be as follows: • The medical restrictions will be evaluated by the employee’s supervisor who will determine if the employee can return to their regular job duties; • If the employee is unable to return to normal job duties, the supervisor will determine if the employee’s position can be temporarily modified to accommodate the restrictions; • If the job cannot be modified, the Health and Safety Coordinator will evaluate other tasks or positions the employee may be able to perform until the medical restrictions are lifted; • If the employee is unable to return safely to a modified position, the medical restrictions will be re-evaluated after each doctor’s visit to ensure the employee is returned to work as soon as possible. 12. An entry will be made on the OSHA 300 Log for all work-related injuries and illnesses that result in days away from work, restricted work or transfer to another job, loss of consciousness, or medical treatment beyond OHSA’s definition of first aid. Accurate records will be kept for all workers’ compensation claims. This file will document all communications regarding the claim, all records from the medical providers and Berkshire Hathaway, all investigation reports, witness statements, and photos taken.

Return to Work

Gevo has adopted this return-to-work policy with the intent of utilizing eligible injured workers in a productive capacity while they are recovering from an injury. The purpose of temporary modified duty is to provide a progression of job duties that will return injured workers to their regular jobs. While on modified duty, the injured worker will be held to all existing personnel

Hellman & Associates, Inc.  All rights reserved. 13 Gevo Health and Safety Program policies and will be responsible for maintaining acceptable performance standards as a condition of continued employment.

The health and safety coordinator or human resources representative will be responsible for coordinating this return-to-work program.

Modified duty assignments are designed to be temporary and transitional in nature and will be allowed as long as it is realistic for the job to continue, or until the injured worker receives a release to full duty or reaches maximum medical improvement (MMI). They will be reviewed jointly by the supervisor, injured worker and relevant staff to address increasing work duties and overall performance.

Modified duty procedures will be as follows: • The medical restrictions will be evaluated by the employee’s supervisor who will determine if the employee can return to their regular job duties. • If the employee is unable to return to normal job duties, the supervisor will determine if the employee’s position can be temporarily modified to accommodate the restrictions. • If the job cannot be modified, the health and safety coordinator will evaluate other tasks or positions the employee may be able to perform until the medical restrictions are lifted. • If the employee is unable to return safely to a modified position, the medical restrictions will be re-evaluated after each doctor’s visit to ensure the employee is returned to work as soon as possible.

As stated in our policy statement, Gevo strives to maintain a safe and secure work environment against any risk or exposure to personal harm, property damage or adverse effects to the environment. As such, it is the duty and the right of every person employed and engaged by Gevo to exercise a Stop Work Order policy whenever any employee, members of the public, group’s assets or local environment are at risk. The management supports the decision of its employees in the diligent execution of this policy:

• Stop Work Orders shall be applied if any situation arises due to an unsafe action or behavior or omission or non-action of any party involved in the operation, and if such situation were permitted to continue, may potentially lead to the occurrence of an untoward incident. • Any person regardless of position, seniority or discipline has the right and duty to apply the Stop Work Order policy, if in their opinion or judgment, such activity is deemed to be a potential incident. • There shall be no blame or fault put on any employee calling for a Stop Work Order (SWO) even if, upon investigation, the Stop Work Order was deemed unnecessary. The Stop Work Order must be applied in good faith. • Timing is a critical factor. There should not be any delay in calling for a Stop Work Order if the need arises. • Work that has ceased due to a Stop Work Order shall not be resumed until all safety aspects are cleared to the satisfaction of the employee who initiated the Stop Work Order or the employee responsible for the Stop Work Order to be in initiated. • Training regarding this Stop Work Order policy will be conducted as part of all new employee orientations. Additionally, a review of the Stop Work Order policy shall be completed as part of all field location safety briefings, and regularly in periodic safety meetings.

Roles and Responsibilities

Role-specific expectations and accountabilities must be established with regard to the Stop Work Order policy.

• Employees and Contractors are responsible to initiate a Stop Work Order when warranted, and support the Stop Work Orders of others.

• Site Supervisors are responsible to create a culture where Stop Work Orders are exercised freely, work to resolve issues before operations are allowed to resume, and recognize proactive participation in the process.

• Gevo Management must establish and support clear expectations to exercise Stop Work Orders, resolve Stop Work Order conflicts when they arise, and hold those accountable that chose not to comply with this policy.

Training is an essential component of the Gevo Health and safety program. The company is committed to providing required training for all applicable OSHA standards.

Training will be conducted during business hours and will be documented. The training form will include a description of the specific topic(s) the employee(s) were trained. The training records will be retained in the employee’s file and the company master training file.

Training will be conducted for all required program elements and be conducted at the following frequency:

• For all new hires, immediately upon employment with the company; • When new equipment, materials, or processes are introduced; • When procedures have been updated or revised; • When experiences/operations show that employee performance must be improved; and

• Based on the frequency required in the applicable OSHA standard.

Employees shall also be trained in the recognition of hazards and to assist with the prevention of unsafe conditions. This training will include:

• Bloodborne Pathogen;

• Chemical Hygiene;

• Emergency Action Plan;

• Hazard Communication;

• Personal protective equipment; and

• Respiratory Protection

Contractor Management

This program applies to all contractors who may perform work at a project site.

Gevo has developed this safety program to address the safety of Gevo employees and project site employees who may be in proximity to operations conducted by contractors. The contractor is expected to take steps as necessary to protect the safety and health of themselves, Gevo employees and project site employees during the performance of their work.

Gevo does not provide day-to-day direction to contractor employees. Therefore, the contractor bears sole responsibility for the safety of their employees. Contractors are expected to take all steps necessary to establish, administer, and enforce safety rules that will meet current health and

Hellman & Associates, Inc.  All rights reserved. 16 Gevo Health and Safety Program safety requirements (including project site-specific safety rules, federal, state and local regulations and Gevo safety policies).

For extensive work at the site, Gevo may elect to pre-qualify contractors by reviewing their safety programs, safety training documents, and safety statistics. This pre-qualification will evaluate safety metrics, such as TRIR, EMR, DART, and Fatality Rate.

Contractors should be included in all pre-job, tailgate safety, safety orientation meetings and job safety inspections.

After work has been completed, Gevo should conduct post-job safety performance reviews on all contractors.

Program Review and Evaluation

The company Health and Safety program will be reviewed annually to ensure Health and Safety program elements are in place. Additionally, goals and objectives shall be reviewed to measure performance of the program and its elements.

A revision record will be maintained to document the changes made to the written programs.

Forms

All forms are located in the Appendix at the end of this manual.

Designated Provider List Incident and Near Miss Investigation Form Employee Training and Information Verification Form (Group Training) Employee Training and Information Verification Form (New Employee or Individual Training) Stop Work Order

Purpose

To specify how Gevo is meeting the requirements of the OSHA’s 1910.1030 of the OSH Act. This program acts as the Exposure Control Program for Bloodborne Pathogens.

The Health and Safety Coordinator is the Bloodborne Pathogens Program Coordinator who has overall responsibility for the program.

Scope

This program covers all first aid/CPR trained personnel providing medical treatment which may involve potential contact with human blood and other potentially infectious materials (OPIM) as defined in the OSHA standard.

Exposure Determination

Gevo does have employees who are trained in first aid, however these employees are not required to provide first aid. In the event of an exposure, the exposed employee(s) will receive the appropriate medical attention at no charge to the employee per the requirements of 29CFR1910.1030.

If any blood or other potentially infectious material needs to be cleaned up after an incident, then a qualified subcontractor will be hired.

First aid classes have been, or may be, provided to employees, but only on a voluntary basis and employees who receive first aid training are not required to provide aid to injured coworkers. Bloodborne pathogen awareness training will be provided by the first aid training service provider, if voluntary first aid training is provided to employees.

Definitions

Blood means human blood and blood components and products made from human blood.

Bloodborne Pathogens (BBP) are microorganisms present in blood that can cause disease in humans including, but not limited to, hepatitis B (HBV), and human immunodeficiency virus (HIV).

Other Potentially Infectious Materials (OPIM) are human body fluids including semen, vaginal secretions, cerebrospinal fluid, synovial fluid, pleural fluid, pericardial fluid, peritoneal fluid, amniotic fluid, saliva in dental procedures and any body fluid that is visibly contaminated with blood.

Sharps are any object(s) that can penetrate the skin including, but not limited to, needles, scalpels, broken glass, broken capillary tubes and exposed ends of dental wires.

Contaminated Laundry is laundry that has been soiled with blood or OPIM or may contain sharps.

Decontamination means to use physical or chemical means to remove, inactivate or destroy BBP on a surface or item.

Exposure Incident means a specific eye, mouth, other mucous membrane, non-intact skin, or parenteral contact with blood or OPIM that results from the performance of an employee’s duties.

Occupational Exposure means any reasonably anticipated skin, eye, mucous membrane or other parenteral contact with blood or OPIM that may result from the performance of an employee’s duties not considering the use of personal protective equipment.

Parenteral means piercing mucous membranes or the skin barrier through such events as needle sticks, human bites or scratches, cuts and abrasions.

Personal Protective Equipment (PPE) is specialized clothing or equipment worn by employees for protection against a hazard. Street clothes are not considered PPE.

Regulated Waste is liquid or semi-liquid blood or OPIM, contaminated items that would release blood or OPIM in a liquid or semi-liquid state if compressed, items that are caked with dried blood or OPIM and are capable of releasing them during handling and contaminated sharps.

Source Individual is an individual, living or dead, whose blood or OPIM may be a source of exposure to an employee.

Sterilize means use of physical or chemical means to destroy all microbiological life including highly resistant bacterial endospores.

Universal Precautions is an approach to infection control where all human blood and OPIM are treated as if known to be infectious for HIV, HBV and other BBPs.

Methods of Compliance

Universal Precautions will be observed at all times when working around blood or OPIM. Nitrile or other impervious gloves should be worn before contacting blood or OPIM. Eye protection should be worn when potential exposure to blood or OPIM is anticipated.

Hellman & Associates, Inc.  All rights reserved. 19 Gevo Bloodborne Pathogens Program Basic PPE for use in first aid is provided at no cost to the employee in the first aid kits and shall be repaired and replaced as needed to maintain its effectiveness.

Hand washing facilities and an antiseptic cleanser and clean cloth or paper towels will be readily available when cleaning up blood or OPIM. As some projects do not have hand washing facilities, the first aid kits available to employees on projects contain personal antiseptic cleanser.

All materials contaminated with blood or OPIM must be placed in a red container or otherwise clearly marked “Biohazard.”

Work surfaces and equipment that become visibly contaminated with blood or OPIM during an incident will be decontaminated with a 10% bleach solution or an equivalent disinfectant immediately following the incident. These surfaces will have a minimum of 20 minutes of contact time with the disinfectant.

No article of PPE is to be taken out of the clean-up area by an employee. Disposable gloves and all contaminated PPE must be properly discarded in the biohazard waste container after use.

All incidents should be reported and investigated in accordance with the Health and Safety and Emergency Preparedness programs in this manual.

Exposure Job Classifications and Tasks

Employees trained in first aid/ CPR may have potential occupational exposure as defined by the OSHA standard. Based on the low risk of exposure for first responder employees, Gevo will offer to provide post-exposure prophylaxis, including Hepatitis B vaccinations within 24 hours of exposure, for those employees who may have been exposed to infectious materials.

Hepatitis B Vaccination and Post-Exposure Evaluation and Follow-Up

Gevo employees are not reasonably anticipated to have exposure to infectious materials, and are therefore not required to have Hepatitis B Vaccinations.

Communication of Hazards to Employees

Gevo provides training to all designated first aid providers in the hazards of bloodborne pathogens before they are assigned duties that may result in occupational exposure. This training will be conducted at a minimum of once a year after the initial training date.

Training is coordinated by the Bloodborne Pathogens Program Coordinator at no cost to the employee and during working hours.

Re-training is provided whenever tasks and procedures are modified that may result in different hazards or procedures.

Recordkeeping

Gevo maintains confidential medical records for Hepatitis B vaccinations for all employees listed above in this procedure in accordance with the OSHA standard (the duration of employment plus 30 years).

Gevo maintains training records for all employees trained in this procedure for a minimum of 3 years from the date of the class.

Medical and training records from the applicable employer are available to the individual employee, company, anyone having written consent from the employee, and the Area OSHA Director in accordance with 1910.1020.

Forms

All forms are located in the Appendix at the end of this manual.

General Company Policy

The purpose of this program is to establish that Gevo is complying with the Occupational Exposure to Hazardous Chemicals in Laboratories Standard, Title 29 CFR 1910.1450.

This program applies to all work operations at Gevo where employees are engaged in the laboratory use of hazardous substances.

The Health and Safety Coordinator is our Chemical Hygiene Officer and will have overall responsibility for the program.

Definitions

Laboratory: For the purposes of the OSHA standard, a laboratory is defined as a facility in which hazardous chemicals (defined below) are handled or manipulated in reactions, transfers, etc. in small quantities (containers that are easily manipulated by one person) on a non- production basis. Typically multiple chemical procedures are used.

Hazardous Chemical: The OSHA Laboratory Health Standard defines a hazardous chemical as any element, chemical compound, or mixture of elements and/or compounds that is a physical hazard or a health hazard. The standard applies to all hazardous chemicals regardless of the quantity.

• A chemical is a physical hazard if there is scientifically valid evidence that it is a combustible liquid, compressed gas, explosive, organic peroxide, oxidizer, pyrophoric, flammable, or reactive. • A chemical is a health hazard if there is statistically significant evidence, based on at least one study conducted in accordance with established scientific principles that acute or chronic health effects may occur in exposed employees. Classes of health hazards include:

• Carcinogens • Irritants

• Sensitizers • Corrosives

• Hepatotoxins (liver) • Neurotoxins (nerve)

• Agents that act on the hematopoietic • Nephrotoxins (kidney) system (blood)

• Agents that damage the lungs, skin, • Reproductive toxins eyes, or mucous membranes

Hellman & Associates, Inc.  All rights reserved. 22 Gevo Chemical Hygiene Program Carcinogen or Potential Carcinogen: A chemical is considered a carcinogen or potential carcinogen if it is listed in any of the following publications (OSHA uses the term "select" carcinogen):

• National Toxicology Program, Annual Report on Carcinogens (latest edition)

• International Agency for Research on Cancer, Monographs (latest edition)

• OSHA, 29 CFR 1910.1001 to 1910.1101, Toxic and Hazardous Substances

Hazardous Chemical: A chemical is considered hazardous according to the OSHA standard, if it is listed in any of the following: • OSHA, 29 CFR 1910.1000 Table Z-1 through Z-3 • Threshold Limit Values for Chemical Substances and Physical Agents in the Work Environment, ACGIH (latest edition) • The Registry of Toxic Effects of Chemical Substances, NIOSH (latest edition)

Over 600,000 chemicals are considered hazardous by the OSHA definition. In most cases, the chemical container's original label will indicate if the chemical is hazardous. Look for key words like caution, hazardous, toxic, dangerous, corrosive, irritant, carcinogen, etc.

Responsibilities

Chemical Hygiene Officer • Work with management and all employees to develop and implement appropriate chemical hygiene policies and practices. • Monitor procurement, use and disposal of chemicals used in the laboratory. • Ensure that appropriate audits and personnel exposure sampling are carried out in a timely manner.

• Know current regulatory requirements concerning regulated substances. • Seek ways to improve the Chemical Hygiene Program. • Ensure that all employees in the Laboratory know and follow the Chemical Hygiene rules that protective equipment is available and in working order and that appropriate training has been provided. • Conduct or coordinate chemical hygiene safety and housekeeping inspections.

• Determine the required levels of personal protective apparel and equipment and enforce its use.

Laboratory Personnel • Plan and conduct each operation in accordance with established chemical hygiene and general safety procedures, standard operating procedures and method procedures.

Hellman & Associates, Inc.  All rights reserved. 23 Gevo Chemical Hygiene Program • Use personal protective equipment as required. • Notify the Laboratory Chemical Hygiene Officer of any symptoms or unusual effects that might possibly be related to the use of, or exposure to, chemicals, reagents or samples. • Know where emergency equipment and first aid supplies are located.

• Know the meaning of labels. • Know where the safety data sheets (SDS) are located and the information they contain. • Know what to do in case of an emergency.

Laboratory Facilities

Chemical Fume Hood Evaluation

Every laboratory ventilation hood used for the control of air contaminants shall be tested once per year to assure that adequate airflow is being maintained to provide continued protection against employee over-exposure. The EHS office is responsible for performing this testing.

Laboratory hood airflow shall be considered adequate when the average face velocity equals a minimum of a 100 feet/minute with the hood sash at a working height (14 to 20 inches). Other local exhaust ventilation, such as instrument vents, should also be checked to ensure adequate airflow.

Results of laboratory ventilation tests shall be recorded and maintained by the Health and Safety Coordinator. The records are maintained in the server of the EHS folder.

Eyewashes and Safety Showers

Whenever chemicals have the possibility of damaging the skin or eyes, an emergency supply of water must be available. As with any safety equipment, these can only be useful if they are accessible, therefore:

• Keep all passageways to the eyewash and shower clear of any obstacles (even a temporarily parked chemical cart). • Adequate water flow in eyewashes should be checked routinely.

• Showers should be checked routinely to assure that access is not restricted and that the start chain is within reach. • Safety showers should be tested periodically to ensure sufficient flow (approximately 60 gallons per minute).

Fire Safety Equipment

Hellman & Associates, Inc.  All rights reserved. 24 Gevo Chemical Hygiene Program Fire safety equipment easily accessible to the laboratory must include a fire extinguisher (type ABC) and may include fire hoses, fire blankets, and automatic extinguishing systems.

General Guidelines

Carefully read the label before using a chemical. The manufacturers or suppliers SDS will provide special handling information. Be aware of the potential hazards existing in the laboratory and the appropriate safety precautions. Know the location and proper use of emergency equipment, the appropriate procedures for responding to emergencies, and the proper methods for storage, transport and disposal of chemicals within the facility.

If you must work alone or in the evening, let someone else know and have them periodically check on you. The Health and Safety Coordinator should be contacted if working alone.

Label all secondary chemical containers with appropriate identification.

Use only those chemicals for which you have the appropriate exposure controls (such as a chemical fume hood) and administrative programs/procedures (training, restricted access, etc.). Always use adequate ventilation with chemicals. Operations using large quantities (500 milliliters) of volatile substances with workplace exposure limits at or below 50 parts per million (ppm) should be performed in a chemical fume hood.

Use hazardous chemicals and all laboratory equipment only as directed or for their intended purpose.

Inspect equipment or apparatus for damage before adding a hazardous chemical. Do not use damaged equipment.

Inspect personal protective apparel and equipment for integrity or proper functioning before use.

Malfunctioning laboratory equipment (hood) should be labeled or tagged "out of service" so that others will not inadvertently use it before repairs are made.

Handle and store laboratory glassware with care. Do not use damaged glassware. Use extra care with Dewar flasks and other evacuated glass apparatus; shield or wrap them to contain chemicals or fragments should implosion occur.

Do not dispense more of a hazardous chemical than is needed for immediate use.

Personal Hygiene

Remove contaminated clothing and gloves before leaving laboratory.

Avoid direct contact with any chemical. Keep chemicals off your hands, face and clothing, including shoes.

Smoking, drinking, eating and applying cosmetics is forbidden in laboratories where hazardous chemicals are used.

Never pipet by mouth. Use a pipet bulb or other mechanical pipet-filling device.

Housekeeping

Keep floors clean and dry.

Keep all aisles, hallways, and stairs clear of all chemicals. Stairways and hallways should not be used as storage areas.

Keep all work areas, and especially work benches, clear of clutter and obstructions.

All working surfaces should be cleaned regularly.

Access to emergency equipment, utility controls, showers, eyewashes and exits should never be blocked.

Wastes should be kept in the appropriate containers and labeled properly.

Any unlabeled containers are considered wastes at the end of each working day.

Chemical Procurement, Distribution and Storage

Procurement

Before a new substance that is known or suspected to be hazardous is received, those who will handle it should know information on proper handling, storage, and disposal. It is the responsibility of the employee to ensure that the laboratory facilities in which the substance will be handled are adequate. Employees must receive training and understand the hazards associated with the chemical before use. The necessary information on proper handling of hazardous substances can be obtained from the SDSs that are provided by the vendor. Because storage in laboratories is restricted to small containers, order small-container lots to avoid hazards associated with repackaging. No container should be accepted without an adequate identifying label.

Distribution

When hand-carrying open containers of hazardous chemicals or unopened containers with corrosive, acutely or chronically highly toxic chemicals, place the container in a secondary container or a bucket. Rubberized buckets are commercially available and provide both

Hellman & Associates, Inc.  All rights reserved. 27 Gevo Chemical Hygiene Program secondary containment as well as "bump" protection. If several bottles must be moved at once, the bottles should be transported on a small cart with a substantial rim to prevent slippage from the cart. Wherever available, a freight elevator should be used to transport chemicals from one floor to another.

Chemical Storage in the Laboratory

Carefully read the label before storing a hazardous chemical. The SDS will provide any special storage information as well as information on incompatibilities. Do not store unsegregated chemicals in alphabetical order. Do not store incompatible chemicals in close proximity to each other.

Segregate hazardous chemicals based on the following general types of incompatible classes:

• Solids: ▪ Oxidizers; ▪ Flammable solids (red phosphorus, magnesium, lithium); ▪ Water reactives; and ▪ Others.

• Liquids: ▪ Acids; ▪ Oxidizers; ▪ Flammable/combustible; ▪ Caustics; and ▪ Perchloric acid.

• Gases: ▪ Toxic ▪ Oxidizers and inert; and ▪ Flammable

Once separated into the above hazard classes, chemicals may be stored alphabetically.

Use approved storage containers and safety cans for flammable liquids. It is preferable to store flammable chemicals in flammable storage cabinets. Flammable chemicals requiring refrigeration should be stored only in refrigerators and freezers specifically designed for flammable storage.

A good place to store hazardous chemicals is a vented cabinet under the hood. Chemicals of different chemical classes can be segregated by placing them in trays.

Do not store chemicals on bench tops or in hoods. Liquids (particularly corrosives or solvents) should not be stored above eye level.

Use secondary containers (one inside the other) for especially hazardous chemicals (carcinogens, etc.). Use spill trays under containers of strong reagents.

Avoid exposure of chemicals in storage to heat sources (especially open flames) and direct sunlight.

Conduct periodic inventories of chemicals stored in the laboratory (annually) and dispose of old or unwanted chemicals promptly in accordance with the facilities hazardous chemical waste program.

Assure all containers are properly labeled.

Chemical Storage - Chemical Stability

Stability refers to the susceptibility of a chemical to dangerous decomposition. The label and SDS will indicate if a chemical is unstable.

Special note: peroxide formers- Ethers, liquid paraffins, and olefins form peroxides on exposure to air and light. Peroxides are extremely sensitive to shock, sparks, or other forms of accidental ignition (even more sensitive than primary explosives such as TNT). Since these chemicals are packaged in an air atmosphere, peroxides can form even though the containers have not been opened. Unless an inhibitor was added by the manufacturer, sealed containers of ethers should be discarded after one (1) year. Opened containers of ethers should also be discarded within one (1) year of opening. All such containers should be dated upon receipt and upon opening.

For additional information on chemical stability, contact the Chemical Hygiene Officer.

Chemical Storage - Incompatible Chemicals

Certain hazardous chemicals should not be mixed or stored with other chemicals because a severe reaction can take place or an extremely toxic reaction product can result. The label and SDS will contain information on incompatibilities. The following table contains examples of incompatible chemicals:

CHEMICAL KEEP OUT OF CONTACT WITH Chromic acid, nitric acid hydroxyl compounds, ethylene, glycol, perchloric Acetic Acid acid, peroxides, permanganates Acetone Concentrated nitric and sulfuric acid mixtures Acetylene Chlorine, bromine, copper, fluorine, silver, mercury Water, carbon tetrachloride or other chlorinated hydrocarbons, carbon Alkali Metals dioxide, the halogens Ammonia, Mercury, chlorine, calcium hypochlorite, iodine, bromine, hydrofluoric anhydrous acid

Hellman & Associates, Inc.  All rights reserved. 29 Gevo Chemical Hygiene Program CHEMICAL KEEP OUT OF CONTACT WITH Acids, metal powders, flammable liquids, chlorates, nitrites, sulfur, finely Ammonium Nitrate divided organic or combustible materials Aniline Nitric acid, hydrogen peroxide Arsenical materials Any reducing agent Azides Acids Bromine Same as chlorine Calcium Oxide Water Carbon (activated) Calcium hypochlorite, all oxidizing agents. Carbon Sodium tetrachloride Ammonium salts, acids, metal powders, sulfur, finely divided organic or Chlorates combustible materials Acetic acid, naphthalene, camphor, glycerin, turpentine, alcohol, Chromic Acid flammable liquids in general Ammonia, acetylene, butadiene, butane, methane, propane (or other Chlorine petroleum gases), hydrogen, sodium carbide, turpentine, benzene, finely divided metals Chlorine Dioxide Ammonia, methane, phosphine, hydrogen sulfide Copper Acetylene, hydrogen peroxide Cumene Acids, organic or inorganic Hydroperoxide Cyanides Acids Ammonium nitrate, chromic acid, hydrogen peroxide, nitric acid, sodium Flammable Liquids peroxide, halogens Hydrocarbons Fluorine, chlorine, bromine, chromic acid, sodium peroxide Hydrocyanic Acid Nitric acid, alkali Hydrofluoric Acid Ammonia, aqueous or anhydrous Copper, chromium, iron, most metals or their salts, alcohols, acetone, Hydrogen Peroxide organic materials, aniline, nitromethane, flammable liquids, oxidizing gases Fuming nitric acid, oxidizing gases, acetylene, ammonia (aqueous or Hydrogen Sulfide anhydrous), hydrogen Hypochlorites Acids, activated carbon Iodine Acetylene, ammonia (aqueous or anhydrous), hydrogen Mercury Acetylene, fulminic acid, ammonia Nitrates Sulfuric acid Nitric Acid Acetic acid, aniline, chromic acid, hydrocyanic acid, hydrogen sulfide, (concentrated) flammable liquids, flammable gases Nitrites Acids Nitroparaffins Inorganic bases, amines Oxalic Acid Silver, mercury Oxygen Oils, grease, hydrogen; flammable liquids, solids, or gases

Hellman & Associates, Inc.  All rights reserved. 30 Gevo Chemical Hygiene Program CHEMICAL KEEP OUT OF CONTACT WITH Perchloric Acid Acetic anhydride, bismuth and its alloys, alcohol, paper, wood Peroxides, organic Acids (organic or mineral), avoid friction, store cold Phosphorus (white) Air, oxygen, alkalies, reducing agents Potassium Carbon tetrachloride, carbon dioxide, water Potassium Chlorate Sulfuric and other acids Potassium Glycerin, ethylene glycol, benzaldehyde, sulfuric acid Permanganate Selenides Reducing agents Silver Acetylene, oxalic acid, tartaric acid, ammonium compounds Sodium Carbon tetrachloride, carbon dioxide, water Sodium nitrite Ammonium nitrate and other ammonium salts Ethyl or methyl alcohol, glacial acetic acid, acetic anhydride, Sodium Peroxide benzaldehyde, carbon disulfide, glycerin, ethylene glycol, ethyl acetate, methyl acetate, furfural Sulfides Acids Potassium chlorate, potassium perchlorate, potassium permanganate (or Sulfuric Acid compounds with similar light metals, such as sodium, lithium, etc.) Tellurides Reducing agents

(From Manufacturing Chemists' Association, Guide for Safety in the Chemical Laboratory, pp.215-217.)

Chemical Exposure Assessment

Regular environmental or employee exposure monitoring of airborne concentrations is not usually warranted or practical in laboratories because chemicals are typically used for relatively short time periods and in small quantities. However, sampling may be appropriate when a highly toxic substance is used regularly (3 or more separate handling sessions per week), used for an extended period of time (greater than 3 to 4 hours at a time), or used in especially large quantities. Notify the Chemical Hygiene Officer if you are using a highly toxic substance in this manner.

Exposures to laboratory employees who suspect and report that they have been over exposed to a toxic chemical in the laboratory, or are displaying symptoms of overexposure to toxic chemicals, will be assessed. The assessment will initially be qualitative and, based upon the professional judgment of the Chemical Hygiene Officer, may be followed up by specific quantitative monitoring.

Individual concerns about excessive exposures occurring in the laboratory should be brought to the attention of your supervisor or the Chemical Hygiene Officer immediately.

Engineering controls, personal protective equipment, hygiene practices, and administrative controls each play a role in a comprehensive laboratory safety program. Implementation of specific measures must be carried out on a case-by-case basis, using the following criteria for guidance in making decisions.

Fume Hoods

A fume hood should be used if a proposed chemical procedure exhibits any one of these characteristics to a degree that (1) airborne concentrations might approach the action level (or permissible exposure limit), (2) flammable vapors might approach one tenth of the lower explosion limit, (3) materials of unknown toxicity are used or generated, or (4) the odor produced is annoying to laboratory occupants or adjacent units.

Procedures that can generally be carried out safely outside the fume hood include those involving (1) water-based solutions of salts, dilute acids, bases, or other reagents, (2) very low volatility liquids or solids, (3) closed systems that do not allow significant escape to the laboratory environment, and (4) extremely small quantities of otherwise problematic chemicals. The procedure itself must be evaluated for its potential to increase volatility or produce aerosols.

In specialized cases, fume hoods will contain exhaust treatment devices, such as water wash- down for perchloric acid use, or charcoal or HEPA filters for removal of particularly toxic or radioactive materials.

Safety Shields or Other Containment Devices

Safety shields, such as the sliding sash of a fume hood, are appropriate when working with highly concentrated acids, bases, oxidizers or reducing agents, all of which have the potential for causing sudden spattering or even explosive release of material. Reactions carried out at non- ambient pressures (vacuum or high pressure) also require safety shields, as do reactions that are carried out for the first time or are significantly scaled up from normal operating conditions.

Other containment devices, such as glove boxes or vented gas cabinets, may be required when it is necessary to provide an inert atmosphere for the chemical procedure taking place, when capture of any chemical emission is desirable, or when the standard laboratory fume hood does not provide adequate assurance that overexposure to a hazardous chemical will not occur. The presence of biological or radioactive materials may also mandate certain special containment devices.

High strength barriers coupled with remote handling devices may be necessary for safe use of extremely shock sensitive or reactive chemicals.

Hellman & Associates, Inc.  All rights reserved. 32 Gevo Chemical Hygiene Program Highly localized exhaust ventilation, such as is usually installed over atomic absorption units, may be required for instrumentation that exhausts toxic or irritating materials to the laboratory environment.

Ventilated chemical storage cabinets or rooms should be used when the chemicals in storage may generate toxic, flammable or irritating levels of airborne contamination.

Eye protection is required for all personnel and any visitors whose eyes may be exposed to chemical or physical hazards. Side shields on safety spectacles provide some protection against splashed chemicals or flying particles, but goggles or face shields are necessary when there is a greater than average danger of eye contact. A higher than average risk exists when working with highly reactive chemicals, concentrated corrosives, or with vacuum or pressurized glassware systems.

Lab coats or other similar clothing protectors are strongly encouraged for all laboratory personnel. Lab coats are required when working with select carcinogens, reproductive toxins, substances which have a high degree of acute toxicity, strong acids and bases, and any substance on the OSHA PEL list carrying a "skin" notation. See Appendix B for chemical listings.

Gloves made of appropriate material are required to protect the hands and arms from thermal burns, cuts, or chemical exposure that may result in absorption through the skin or reaction on the surface of the skin. Gloves are also required when working with particularly hazardous substances where possible transfer from hand to mouth must be avoided. Thus gloves are required for work involving pure or concentrated solutions of select carcinogens, reproductive toxins, substances which have a high degree of acute toxicity, strong acids and bases, and any substance on the OSHA PEL list carrying a "skin" notation.

Gloves should be carefully selected using guides from the manufacturer. General selection guides are available. However, glove-resistance to various chemicals materials will vary with the manufacturer, model and thickness. Therefore, review a glove-resistance chart from the manufacturer you intend to buy from before purchasing gloves.

Glove Chart for Gevo Inc General Categories Gloves to use Acids, Bases (Low Concentration) Nitrile, Chloroprene, Rubber Latex, or Silver shield Acids (High Concentration) Vinyl, or Silver Shield Alcohols Nitrile, Rubber Latex, or Silver shield Aldehydes, Ketones Nitrile, Rubber Latex, or Silver shield Chlorinated Hydrocarbon Solvents Nitrile (*wear 2 pairs, MUST have Nitrile outer layer), or Silver Shield

Breakthrough time "BT" (Reference: North Chemical Resistance guide, Quick Selection Guide to Chemical Protective Clothing (3rd edition) and Ansell Protective products Chemical Resistance Guide) P=Poor (Do Not Use) F=Fair (*2 Pairs of Gloves) Definition=Elapsed time between initial contact of the chemical with the outside surface of the glove and the time G=Good at which the chemical can be detected at the inside surface of glove by means of analytical equipment. When E=Excellent breakthrough occurs, the glove is no longer providing total protection. ND= None detected Nitrile Chloroprene Rubber Latex Silver Shield or Barrier Special Chemicals Compatibility "BT" Compatibility "BT" Compatibility "BT" Compatibility "BT" Acetic Acid G E >60 min E E Acetone F (*2 Pairs) 5 min. P(Do Not Use) G E 6Hrs. ND Acetonitrile F (*2 Pairs) <10 min. P(Do Not Use) F (*2 Pairs) <10 min. E 8Hrs. ND Chloroform F (*2 Pairs) 4 min. G 21-30 min P (Do Not Use) E 6Hrs. ND Cyclohexane E G 21-30 min P (Do Not Use) E 6Hrs. ND Dimethyl Sulfoxide G E >60 min G E Ethanol E E >60 min E E Ethylene Glycol Dimethyl Ether F (*2 Pairs) P (Do Not Use) F (*2 Pairs) G Heptanes E P (Do Not Use) P (Do Not Use) E Hexane E G 21-30 min P (Do Not Use) <10 min. E 6Hrs. ND Hydrochloric Acid, <30% G G 21-30 min E E Hydrochloric Acid, 30-70% G 6Hrs. ND G 21-30 min G 55 min. E 6Hrs. ND Isopropyl Alcohol E E >60 min E E Lactic Acid E E E E Methanol F (*2 Pairs) G 31-60 min F (*2 Pairs) E Methylene Chloride F (*2 Pairs) 4 min. P (Do Not Use) P (Do Not Use) E 8Hrs. ND Methyl Isobutyl Ketone F (*2 Pairs) P (Do Not Use) P (Do Not Use) G Nitric Acid, <30% E 6Hrs. ND E >60 min E E 6Hrs. ND Nitric Acid, 30%-70% P (Do Not Use) E (50% Nitric) >60 min P (Do Not Use) E

Bare feet are not permitted in the laboratory. Sandals and open-toed shoes are not allowed and are not permitted in any situation where lab coats and gloves are required.

Respiratory protection is generally not necessary in the laboratory setting and must not be used as a substitute for adequate engineering controls. Availability of respiratory protection for emergency situations may be required when working with chemicals that are highly toxic and highly volatile or gaseous. If an experimental protocol may result in an exposure above the action level (or PEL) that cannot be reduced, respiratory protection will be required. Rarely, an experimental situation may potentially involve IDLH (immediately dangerous to life or health) concentrations of chemicals, which will require use of respiratory protection. All use of respiratory protective equipment must be covered under an OSHA compliant Respiratory Protection Program.

As of June 1, 2015, all labels on the manufacturer’s containers will be required to have a pictogram(s), signal word, hazard and precautionary statement(s), the product identifier, and supplier identification (including name, address, and telephone number of the manufacturer, importer or responsible party).

All portable/secondary containers must be labeled appropriately to include product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals. Secondary containers use the GHS labeling system.

Most labels will provide additional safety information to help protect you while working with the substance. This includes protective measures to be used when handling the material, clothing that should be worn, first aid instructions, storage information and procedures to follow in the event of a fire, leak or spill.

If you find a container with no label, report it to your supervisor. You should also report labels that are torn or illegible so that the label can be replaced immediately. Existing labels on new containers of hazardous chemicals should never be removed or defaced, except when empty! If you use secondary working containers that will take more than one work shift to empty, or if there is a chance that someone else will handle the container before you finish it, you must label it. This is part of your responsibility to help protect co-workers.

Read the label each time you use a newly purchased chemical. It is possible the manufacturer may have added new hazard information or reformulated the product since your last purchase, and thus altered the potential hazards you face while working with the product.

All employees involved in unpacking chemicals are responsible for inspecting each incoming container to ensure that it is labeled with the information outlined above. The principal investigators or department chemical hygiene officer/laboratory supervisors should be notified if containers do not have proper labels.

Prominent laboratory signs of the following types should be posted in each laboratory: • Telephone numbers of emergency personnel/facilities, supervisors, and laboratory workers • Signs identifying locations for safety showers, eyewash stations, other safety and first aid equipment, and exits; • Warnings at areas or equipment where special or unusual hazards exist.

Gevo will provide employees who work with hazardous chemicals an opportunity to receive medical attention, including any follow-up examinations which the examining physician determines to be necessary, whenever an employee:

• Develops signs or symptoms associated with excessive exposure to a hazardous chemical used in their laboratory; • Is exposed routinely above the action level (or in the absence of an action level, the applicable OSHA work place exposure limit) for an OSHA regulated substance;

• May have been exposed to a hazardous chemical during a chemical incident such as a spill, leak, explosion or fire; and • Is referred for medical follow up by the Chemical Hygiene Officer. Where medical consultations or examinations are provided, the examining physician shall be provided with the following information:

• The identity of the hazardous chemical(s) to which the employee may have been exposed;

• The exposure conditions; and • Signs and symptoms of exposure the laboratory employee is experiencing, if any.

Spills and Incidents

General Information

Gevo will evaluate the types of chemical spills that can occur in the laboratory and obtain the necessary equipment (spill kits and personal protective equipment) to respond to a minor spill. Employees will learn how to clean up minor spills of the chemicals they use regularly. The chemical SDS contains special spill clean-up information and should also be consulted.

If the spill is too large for an employee to handle, is a threat to laboratory personnel or the public, or involves a highly toxic or reactive chemical, evacuate the area and call for assistance immediately.

Cleaning Up Chemical Spills

If you are cleaning up a small spill yourself, make sure that you are aware of the hazards associated with the materials spilled, have adequate ventilation (open windows, chemical fume hood on) and proper personal protective equipment (minimum - gloves, goggles, and lab coat). Consider all residual chemical and cleanup materials (adsorbent, gloves, etc.) as hazardous waste. Place these materials in a sealed container (plastic bags) and store in a chemical fume hood. Contact the Health and Safety Coordinator for disposal instructions.

• Alert people in immediate area of spill. • Increase ventilation in area of spill (open windows, turn on hoods).

• Wear protective equipment, including safety goggles, gloves, and long-sleeve lab coat. • Avoid breathing vapors from spill. • Use appropriate kit to neutralize and absorb inorganic acids and bases. Collect residue, place in container, and dispose as hazardous chemical waste.

• For other chemicals, use appropriate kit or absorb spill with vermiculite, dry sand, diatomaceous earth or paper towels. Collect residue, place in container, and dispose as chemical waste. • Clean spill area with water.

Major Chemical Spill

• Attend to injured or contaminated persons and remove them from exposure. • Alert people in the laboratory to evacuate. • If spilled material is flammable, turn off ignition and heat sources. Place other device over spilled material to keep substance from volatilizing.

• Notify an Emergency Coordinator • Close doors to affected area. • Have a person with knowledge of the incident and laboratory available to answer questions from responding emergency personnel.

Chemical Safety Training

All employees exposed, or potentially exposed, to hazardous chemicals while performing their laboratory duties must receive information and training regarding the standard, the chemical hygiene plan and laboratory safety.

The training program for laboratory workers consists of two parts: 1) introduction to the standard and to information not specific to the individual worksite, and 2) site specific elements of training to be conducted, or at least developed or reviewed by the Chemical Hygiene Officer.

The training and information will be provided when an employee is initially assigned to a laboratory where hazardous chemicals are present, and also prior to assignments involving new hazardous chemicals and/or new laboratory work procedures.

The training and information program will describe the:

• Physical and health hazards of various classes of laboratory chemicals handled;

Hellman & Associates, Inc.  All rights reserved. 38 Gevo Chemical Hygiene Program • Methods/procedures for safely handling and detecting the presence or release of hazardous chemicals present in the laboratory; • Appropriate response in the event of a chemical emergency (spill, overexposure, etc.); • Chemical safety policies; and

• Applicable details of this plan (such as the standard operating procedures for using chemicals).

When an employee is to perform a non-routine task presenting hazards for which he or she has not already been trained, the employee will be responsible for discussing with the supervisor or Health and Safety Coordinator the hazards of the task and any special measures (e.g. personal protective equipment or engineering controls) that should be used to protect the employee.

Every laboratory worker should know the location and proper use of available protective clothing and equipment, and emergency equipment/procedures. Information on protective clothing and equipment is contained further in this program.

Waste Disposal Program

Laboratory chemical waste must be disposed of in accordance with local, state, federal and requirements. These waste management practices are designed to ensure maintenance of a safe and healthful environment for laboratory employees and the surrounding community without adversely affecting the environment. This is accomplished through regular removal of chemical waste and disposal of these wastes in compliance with all regulations and policies.

Specific guidance on how to identify, handle, collect, segregate, store and dispose of chemical waste is available from Health and Safety Coordinator.

Remember:

• Hoods should not be used for disposing of volatile chemicals. • Drains should not be used for disposal of chemicals.

• Laboratory waste shall be disposed of in a timely manner. • Waste materials should be accumulated in a designated storage area consistent with applicable regulations.

Additional Employee Protection for Work with Particularly Hazardous Substances

Additional employee protection will be considered for work with particularly hazardous substances. These include select carcinogens, reproductive toxins and substances that have a high degree of acute toxicity. Specific consideration will be given to the need for inclusion of the following provisions:

• Special precautions such as: Use of containment devices such as fume hoods or glove boxes ٭ Use of personal protective equipment ٭ Isolation of contaminated equipment ٭ Practicing good laboratory hygiene ٭ Prudent transportation of very toxic chemicals ٭ Planning for accidents and spills ٭ .Special storage and waste disposal practices ٭

Recordkeeping, Review and Update of Chemical Hygiene Plan

Exposure Evaluation

All exposure evaluation results will be maintained by the Health and Safety Coordinator. Raw data will be kept for at least 1 year and summary data for the term of employment plus 30 years.

Medical Consultation and Examination

Results of medical consultations and examinations will be kept by Gevo for a length of time specified by the appropriate medical records standard. This time will be at least the term of employment plus 30 years as required by OSHA.

Training

Individual employee training will be documented and maintained by the Chemical Hygiene Officer.

Fume Hood Monitoring

The Health and Safety Coordinator will keep data on annual fume hood monitoring. Fume hood monitoring data are considered maintenance records and as such the raw data will be kept for one year and summary data for no less than 5 years.

Review and Update of Chemical Hygiene Plan

On an annual basis, this Chemical Hygiene Plan will be reviewed and evaluated for effectiveness by the Health and Safety Coordinator and updated as necessary. ATA COLLECTION Forms

None.

Purpose

The Gevo Compressed Gas Safety Program was developed to cover general procedures for the identification, safe handling, storage and transport of all compressed gas cylinders. The Occupational Safety and Health Administration (OSHA) standard related to compressed gases (general requirements) is 29 CFR 1910.101.

Scope

This program applies to all Gevo operations and personnel who use, handle, store or transport compressed gas cylinders. All compressed gas cylinders shall be handled, used, stored and transported in accordance with this program.

Authority and Responsibility

Health & Safety Coordinator shall be responsible for: • Developing the written Compressed Gas Cylinder Safety Program and revising the program as necessary; • Developing a training program on the safe handling, use, storage, and transportation of compressed gas cylinders; and • Conducting routine inspections to ensure the proper storage and use methods are used.

Management shall be responsible for: • Understanding and complying with the requirements of this program; • Ensuring the proper handling, use, storage, and transportation of compressed gas cylinders are followed according to this program; • Training employees on the safe use, handling, storage, and transportation of compressed gas cylinders; and • Contacting the Health & Safety Coordinator if assistance is needed.

The Employees shall be responsible for: • Attending training as necessary; • Complying with the procedures outlined in this program; and • Informing their supervisor of any problems, defective equipment, or lack of proper storage space for compressed gas cylinders used by them.

Contractor employees shall be responsible for: • Complying with all OSHA standards that pertain to compressed gas safety.

New Cylinders

Hellman & Associates, Inc.  All rights reserved. 41 Gevo Compressed Gas Cylinder Program When a gas cylinder is received, it shall be visually checked for the following: • A stamped hydrostatic test date within the last 5 years; • A stenciled or labeled identification of its contents; and • Presence of a valve protection cap.

If the test date, identification, markings or cap are not in order or if the cap is rusted or inoperable, the cylinder shall be rejected.

Labeling

All compressed gases received, used or stored must be labeled according to the United States Department of Transportation (DOT) and the Occupational Safety and Health Agency (OSHA) regulations. Each cylinder must be marked by label or tag with the name of its contents. Such identification should be stenciled or stamped on the cylinder or placed on a label. Do not accept cylinders without the appropriate labels. The primary identifier of cylinder contents is the label.

Never rely on the color of the cylinder for identification. Cylinder colors may vary depending on the supplier. Labels on caps have little value because caps are interchangeable.

Always read the label. No compressed gas cylinder should be accepted for use that does not legibly identify its contents by name. If the contents cannot be identified, the cylinder should be marked “contents unknown” and returned to the manufacturer.

All gas lines leading from a compressed gas supply should be clearly labeled to identify the gas.

General Handling and Use Procedures

There are two types of hazards associated with the use, storage and handling of compressed gas cylinders: the chemical hazard associated with the cylinder contents (corrosive, toxic, flammable, etc.) and the physical hazards represented by the presence of a high pressure vessel. Compressed gas cylinders should only be handled by those familiar with the hazards and who understand how to safely handle transport and store compressed gas cylinders.

The following rules for handling compressed gas cylinders shall be followed at all times: • Ensure all cylinders are properly labeled as to the contents; • Move cylinders using a suitable hand truck or cart; • Cylinders must be transported, stored and used upright (with the valve up), and must be securely fastened to prevent them from falling or being knocked over. Suitable racks, straps, chains, or stands are required to support cylinders; • Cylinder valves are to be protected with the standard cap when not in used (empty or full). Regulators are to be protected with covers where there is a likelihood of damage; • Never force a cap or regulator. The cap should only be hand tight;

Hellman & Associates, Inc.  All rights reserved. 42 Gevo Compressed Gas Cylinder Program • Cylinders should not be exposed to excessive dampness, or to corrosive chemicals or fumes; • Cylinders are not to be exposed to temperature extremes or stored in the vicinity of combustibles; • Gases are not to be transferred from one vessel to another (except dry ice and cryogenic materials). Do not try to refill a compressed gas cylinder; • Disposal gas cylinders, including lecture bottles, shall not be refilled. It is against US DOT regulation to refill or reuse a disposable gas cylinder; • Never use a cylinder without a regulator. Always use the correct pressure regulator; • After attaching the regulator, and before the cylinder is opened, check the adjusting screw of the regulator to see that it is released. Never permit the gas to enter the regulator suddenly; • Never try to stop a leak between a cylinder and regulator by tightening the union nut unless the valve has been closed first; • Never strike an electric arc on a cylinder; • Never use a leaking, corroded or damaged cylinder. Remove the cylinder from service and contact the supplier for return; and • Always use appropriate hand tools to open and close cylinder valves.

When using compressed gas cylinders, the following rules shall be followed: • Before using any compressed gas cylinder, be familiar with the respective material safety data sheet for the gas you are using; • Never use adapters to fit valves to cylinders or regulators to valves; • Regulators are gas specific and are generally not interchangeable. Make sure that the regulator and valve fittings are compatible; • Cylinders shall be kept far enough away from the actual welding or cutting operations so that sparks or hot flame will not reach them. When this is impractical, fire resistant shields shall be provided; • Cylinders containing oxygen or acetylene or other fuel gas shall not be taken into confined spaces without the approval of Facilities Maintenance; and • Cylinders, hoses and hose connections should be inspected regularly.

Specific Handling Procedures

Flammable Gas • Flammable gases must be stored in well-ventilated areas away from flammable liquids, combustible materials, oxidizers, open flames, sparks or other sources of heat or ignition; • A portable fire extinguisher (carbon dioxide or dry chemical powder type) must be available for fire emergencies where flammable gas is stored; • “Flow” experiments with flammable gases are not to be left unattended; an explosimeter or combustible gas alarm must be used; • Spark-proof tools shall be used when working with flammable gas cylinders;

Hellman & Associates, Inc.  All rights reserved. 43 Gevo Compressed Gas Cylinder Program • In the event of an emergency involving a flammable gas, such as a gas leak, fire, or explosion, personnel must immediately evacuate the area. Do not attempt to extinguish burning gas if the flow of product cannot be shut off immediately without risk; • All lines and equipment associated with flammable gas systems must be grounded and bonded; and • Acetylene shall not be utilized in lines or hoses at a pressure exceeding 15 psi.

Oxidizer Gas • All equipment used for oxidizing gases must be cleaned with oxygen compatible materials free from oils, greases, and other contaminants (hydrocarbons and neoprene are not oxygen- compatible; PTFE Teflon is compatible. The equipment must state that it is oxygen compatible). • Do not handle the cylinder with oily hands or gloved; and • Oxidizers shall be stored separately from flammable gas containers or combustible materials. A distance of 20 feet or a noncombustible barrier at least 5 feet high and having a fire rating of at least ½ hour is the minimum separation requirement.

Corrosive Gas • Keep exposure to gas as low as possible. Use in a fume hood or other vented enclosure when possible. Avoid contact with skin and eyes; • Wear safety goggles when handling compressed gas cylinders which are corrosive; • An emergency shower and eyewash must be installed within 10 seconds where corrosive materials, including corrosive gases, are used; and • An emergency response procedure must be in place and everyone working in the area must be trained on the procedures.

Toxic Gas • Toxic and highly toxic gases shall not be stored or used outside of laboratories; • Large cylinders of toxic or highly toxic gas must be stored in gas cabinets, exhausted enclosures, or gas rooms; • Keep exposure to toxic gases as low as possible. Use in a fume hood or other vented enclosure when possible. Avoid contact with skin and eyes; • A gas detection system with visible and audible alarms to detect the presence of leaks must be installed for all toxic and highly toxic gases; • An emergency response procedure must be in place and everyone working in the area must be trained on the procedures.

Asphyxiant Gases • Do not store asphyxiant gases in areas without ventilation. This includes environmental chambers (e.g. cold boxes) that do not have a fresh air supply or exhaust system; • Areas with asphyxiant gases in use must have an oxygen detection device present during use; and • Any gas that has the potential to displace oxygen in sufficient quantities can cause asphyxiation.

Hellman & Associates, Inc.  All rights reserved. 44 Gevo Compressed Gas Cylinder Program • Only persons trained and qualified in the use of a self contained breathing apparatus (SCBA) with adequate back-up should respond to an inert gas leak or enter an area where an asphyxiant gas could be present. Shut off the source of the gas leak if there is no risk to personnel and ventilate the area. If a person has symptoms of asphyxiation, move the victim to fresh air and obtain proper medical attention.

Cryogenic Gases Cryogenic liquids and their boil-off vapors rapidly freeze human tissue and cause embrittlement of many common materials which may crack or fracture under stress. All cryogenic liquids produce large volumes of gas when they vaporize (at ratios of 600:1 to 1440:1, gas: liquid) and may create oxygen-deficient conditions. • Wear face shield and chemical safety goggles when dispensing from cylinder or dewar; • Wear appropriate insulated gloves to protect from the extreme cold when handling cryogenic containers. Gloves need to be loose fitting so that they can be readily removed in the event liquid is splashed into them. Never allow an unprotected part of the body to touch uninsulated pipes or containers of cryogenic material; • Keep liquid oxygen containers, piping, and equipment clean and free of grease, oil, and organic materials; • Do not store cylinders or dewars in environmental chambers that do not have fresh air ventilation. A leak or venting from the container could cause an oxygen deficient atmosphere; and • First aid treatment for cold-contact burns: • Remove any clothing not frozen to the skin that may restrict circulation to the frozen area. Do not rub frozen parts, as tissue damage may result. Obtain medical assistance as soon as possible. • Place the affected part of the body in a warm water bath. Never use dry heat.

Storage

Because of the high internal pressure in compressed gas cylinders, they can become projectiles if stored in a manner that could damage the valve. Leaking cylinders can also cause an atmospheric hazard or create an oxygen deficient atmosphere.

Due to the hazards associated with compressed gas cylinders, the following rules for storing compressed gas cylinders shall be followed at all times: • Group and store compressed gases based on their hazard class; • Cylinders containing flammable gases such as hydrogen or acetylene must not be stored in close proximity to open flames, areas where electrical sparks are generated, or where other sources of ignition might be present; • Oxygen cylinders, full or empty, shall never be stored in the same vicinity as flammable gases. The proper storage of oxygen cylinders required a minimum or 20 feet between flammable gas cylinders or the areas need to be separated, at a minimum, by a firewall 5 feet high with a fire rating of at least one hour;

Hellman & Associates, Inc.  All rights reserved. 45 Gevo Compressed Gas Cylinder Program • Greasy and oily materials must never be stored around oxygen cylinders and fittings must never be greased or oiled; • Always store cylinders in an upright position, on a level floor and make them secure using a restraint such as chains, sturdy straps or plastic coated wire or attach the cylinder to a non-tip base; • Restraints must be fastened on the upper half of the cylinder – above the center of gravity; • Storage areas should be dry, well-drained, ventilated, and fire-resistant; • Empty and full or partially full cylinders should be stored in separate, labeled areas; • Cylinders that are no longer needed should be marked as such; • Do not subject cylinders to temperature extremes; • Cylinders shall not be stored in hallways, corridors, paths of egress, stairways, or other areas with high foot traffic; • Cylinders not in use shall have the valve closed and valve cap in place; • Stored cylinders should be visually inspected on a routine basis, for any indication of leakage or other problems; and • If a leaking cylinder is discovered, move it to a safe place (if safe to do so) and contact the vendor.

Transportation of Cylinders

The cylinders that contain compressed gases are primarily shipping containers and should not be subjected to rough handling or abuse. Such misuse can seriously weaken the cylinder and render it unfit for further use or transform it into a rocket having sufficient thrust to drive it through masonry walls.

When transporting compressed gas cylinders, the following rules shall be followed at all times: • Ensure cylinders are properly labeled as to the contents; • Regulators shall be removed and valve protection caps put in place before the cylinder is moved; • Do not lift or move the cylinder by the cap; • Do not subject cylinders to rough handling or abuse; • Cylinders should only be transported in freight/cargo elevators only, not on passenger elevators; • Never roll or drag a cylinder when transporting; • Firmly secure and move cylinders vertically with a suitable hand truck, lift truck, or crane with a cradle or platform; • Always secure cylinders with a strap or chain when using a designated cart; and • Only one cylinder should be handled at a time unless a two cylinder cart is used and each cylinder is restrained by its own chain.

Disposal or Return of Cylinders

When disposing or returning gas cylinders the following rules shall apply: • Close and tighten the valves and replace the safety caps on the cylinders; • Contact vendor to obtain information regarding the return of their cylinders;

Hellman & Associates, Inc.  All rights reserved. 46 Gevo Compressed Gas Cylinder Program • Non-refillable gas cylinders must be managed as a potential hazardous waste, as they are purchased outright. When a non-refillable gas cylinder is ready to be disposed of, contact Facilities Maintenance or Chemical Hygiene Officer for proper disposal of the cylinder.

Training

All employees affected by this policy shall be trained in compressed gas cylinder safety. The training shall include: • Cylinder identification; • Cylinder inspection; • Cylinder handling, storage and use; and • Cylinder transportation.

General Company Policy

The purpose of this program is to establish that Gevo is complying with the OSHA’s 29 CFR 1910.331 through 1910.335, electrical safety standards and National Fire Protection Association’s (NFPA) 70E, Standard for Electrical Safety in the Workplace.

This program applies to all Gevo work operations where employees may work on or near electrical equipment or around electrical installations systems operating at greater than or equal to 50 volts.

The health and safety coordinator is the program coordinator who has overall responsibility for the program.

The Gevo Lockout/Tagout (LOTO) program applies to all work involving de-energized electrical circuits and systems.

Definitions

Acceptable - An installation or equipment is acceptable to OSHA, and approved within the meaning of this Subpart K: (a) If it is accepted, or certified, or listed, or labeled, or otherwise determined to be safe by a qualified testing laboratory capable of determining the suitability of materials and equipment for installation and use in accordance with this standard; or (b) With respect to an installation or equipment of a kind which no qualified testing laboratory accepts, certifies, lists, labels, or determines to be safe, if it is inspected or tested by another Federal agency, or by a State, municipal, or other local authority responsible for enforcing occupational safety provisions of the National Electrical Code, and found in compliance with those provisions.

Attachment plug (Plug cap or Cap) - A device which, by insertion in a receptacle, establishes connection between the conductors of the attached flexible cord and the conductors connected permanently to the receptacle.

Certified - Equipment is "certified" if it: (a) Has been tested and found by a qualified testing laboratory to meet applicable test standards or to be safe for use in a specified manner, and (b) Is of a kind whose production is periodically inspected by a qualified testing laboratory. Certified equipment must bear a label, tag, or other record of certification.

Circuit breaker - (600 volts nominal, or less.) A device designed to open and close a circuit by non-automatic means and to open the circuit automatically on a predetermined over current without injury to itself when properly applied within its rating.

Conductor – (a) Bare - A conductor having no covering or electrical insulation whatsoever.

Hellman & Associates, Inc.  All rights reserved. 48 Gevo Electrical Safety Program (b) Covered - A conductor encased within material of composition or thickness that is not recognized as electrical insulation. (c) Insulated - A conductor encased within material of composition and thickness that is recognized as electrical insulation.

Ground - A conducting connection, whether intentional or accidental, between an electrical circuit or equipment and the earth, or to some conducting body that serves in place of the earth.

Grounded - Connected to earth or to some conducting body that serves in place of the earth.

Ground-fault circuit interrupter - A device for the protection of personnel that functions to de- energize a circuit or portion thereof within an established period of time when a current-to- ground exceeds some predetermined value that is less than that required to operate the over current protective device of the supply circuit.

Location – (a) Damp location. Partially protected locations under canopies, roofed open porches, or interior locations subject to moderate degrees of moisture, such as some basements. (b) Dry location. A location not normally subject to dampness or wetness. A location classified as dry may be temporarily subject to dampness or wetness, as in the case of a building under construction. (c) Wet location. Installations underground or in concrete slabs or masonry in direct contact with the earth, and locations subject to saturation with water or other liquids, such as locations exposed to weather and unprotected.

Over current - Any current in excess of the rated current of equipment or the ampacity of a conductor. It may result from overload (see definition), short circuit, or ground fault. A current in excess of rating may be accommodated by certain equipment and conductors for a given set of conditions. Hence the rules for over current protection are specific for particular situations.

Power outlet - An enclosed assembly which may include receptacles, circuit breakers, fuse holders, fused switches, buses and watt-hour meter mounting means; intended to serve as a means for distributing power required to operate mobile or temporarily installed equipment.

Receptacle - A receptacle is a contact device installed at the outlet for the connection of a single attachment plug. A single receptacle is a single contact device with no other contact device on the same yoke. A multiple receptacle is a single device containing two or more receptacles.

Voltage - (Of a circuit.) The greatest root-mean-square (effective) difference of potential between any two conductors of the circuit concerned.

Gevo management has overall responsibility for the program. Contractors are responsible for following the program and providing training for their employees.

Only licensed electricians or other qualified contractors will be responsible for the installation and maintenance of electrical systems and work on any live electrical system. Other employees who have not received training as specified in this chapter are considered unqualified.

Installation and Maintenance Work

Electrical equipment shall be free from recognized hazards that are likely to cause death or serious physical harm to employees. Safe work practices shall be employed to prevent electric shock or other injuries resulting from either direct or indirect electrical contacts when work is performed near or on equipment or circuits which are or may be energized.

Conductors and parts of electrical equipment that have been de-energized but have not been locked or tagged out shall be treated as live parts. Whenever possible, any employee exposed to contact with parts of fixed electric equipment or circuits which have been de-energized, the circuits energizing the parts shall be locked out, tagged out, or both.

Listed or labeled equipment shall be used or installed in accordance with any instructions included in the listing or labeling.

All 120-volt, single phase, 15 and 20 ampere receptacles are of a grounding type, and their ground contacts are grounded by connection to the equipment-grounding conductor of the circuit supplying the receptacles in accordance with the applicable requirements of Article 210-7 (c) and 305-4 (d) of the National Electrical Code.

All 120-volt flexible cord sets (extension cords) shall have an equipment-grounding conductor that is connected to the grounding contacts of the connector(s) on each end of the cord. Flexible cords sets shall be 12 gauge or greater in size.

The exposed non-current carrying metal parts of 120-volt cord and plug connected tools and equipment that are likely to become energized shall be grounded in accordance with the applicable requirements of Article 250-45 and 250-59 of the National Electrical Code.

Upon installation of any electrical power service to any apparatus or device, grounding circuits will be run and checked via resistance ohm-meter (i.e., Megger) for continuity of ground circuit prior to energizing the circuit, whether the purpose for energizing is for temporary test or permanent run-in.

Only qualified persons may work on electric circuit parts or equipment that have not been de- energized. Such persons shall be made familiar with the use of special precautionary techniques, PPE, insulating and shielding materials, and insulated tools.

Each disconnecting means required by this subpart for motors, appliances, over current device, and circuits (service, feeder, or branch) shall be legibly marked to indicate its purpose, unless located and arranged so the purpose is evident.

Employees may not enter spaces containing exposed energized parts unless illumination is provided that enables the employees to work safely.

Protective shields, protective barriers or insulating materials, shall be provided in enclosed or confined areas as necessary.

Portable ladders shall have non-conductive side rails when working around any energized systems.

Conductive items of jewelry or clothing shall not be worn unless they are rendered nonconductive by covering, wrapping or other insulating means.

Guarding of Live Parts

The purpose of this requirement is to protect any person who may be in the vicinity of electrical equipment against accidental contact.

Live parts of electrical equipment operating at 50 volts or more shall be guarded against accidental contact by approved cabinets, other forms of approved enclosures, or one of the following means:

• By location in a room or vault only accessible to qualified persons; • By suitable permanent, substantial partitions or screens so that only qualified persons will have access to the space within reach of live parts; • By elevation of eight feet or more above the floor or other working surface.

Visual Inspection

Gevo employees shall be instructed that each cord set, and any tools or equipment connected by cord and plug (except cord sets and receptacles which are fixed and not exposed to damage), must be visually inspected by the user before each day’s use for external defects, such as deformed or missing pins or insulation damage. Tools or equipment found damaged or defective shall not be used until repaired.

Flexible Cords and Cables

Flexible cords are recognized as more vulnerable than the fixed wire of the building. Therefore, cords should not be used if one of the recognized wiring methods could be used instead.

Hellman & Associates, Inc.  All rights reserved. 51 Gevo Electrical Safety Program Flexible cords shall be approved and suitable for conditions of use and location. The OSHA standard lists specific situations in which flexible cords may be used: • Pendants - a lamp holder or cord-connector body suspended by a length of cord properly secured and terminated directly above the suspended device;

• Wiring of fixtures; • Connection of portable lamps or equipment; • Wiring of cranes and hoists where flexibility is necessary; and

• Connection of stationary equipment to facilitate their frequent interchange (equipment which is not normally moved from place to place but might be on occasion).

Training

Non-Qualified persons (i.e. those employees who face a risk of electric shock but who are not qualified persons) shall be trained in and familiar with the following:

• Electrically-related safety practices that pertain to their respective job assignments; • The clearance distances for overhead lines and the corresponding voltages to which the non-qualified person will be exposed; • Energy isolation procedures as they pertain to affected employees.

Qualified persons (i.e., those permitted to work on or near exposed energized parts) shall be trained in and familiar with the following:

• The skills and techniques necessary to distinguish exposed live parts from other parts of electric equipment, • The skills and techniques necessary to determine the nominal voltage and current of exposed live parts; • The clearance distances for overhead lines and the corresponding voltages to which the qualified person will be exposed; • Energy isolation procedures as they pertain to affected employees.

Refresher training shall be provided whenever: • An inspection reveals deviations from procedures or inadequacies in personnel knowledge of this electrical safety program;

• An incident or near-miss has been experienced that is related to an energy isolation procedure and the investigation identifies a lack of knowledge or understanding of the requirements contained in this procedure.

Purpose

The purpose of this program is to establish that Gevo is complying with the OSHA’s 29 CFR 1910.39; 29 CFR 1910.38 and, when applicable, 29 CFR 1910.120.

This plan identifies actions to be taken during the response to foreseeable emergencies. The types of foreseeable emergencies addressed in this plan are medical events, hazardous substances and waste releases, fires, and explosions.

Emergency Telephone Numbers

Health and Safety Coordinator Jenifer Meinholz Primary Emergency Coordinator (EC): (720)982-7984

Emergency Response Coordinators Chris Smith : (720)326-7566 Kent Evans: (303)378-4895

South Metro Fire Department Dial 911 or (720)989-2000

Douglas County Sheriff Dial 911 or (303)660-7505

Workers Comp Clinics

Primary Secondary Greenwood Village Family Medicine Aspire Family Medicine 8200 E. Belleview Ave. #204C 9620 E. Arapahoe Rd. Greenwood Village, CO 80111 Greenwood Village, CO 80112 P: (303)221- 5700 P: (303)835-9915

Hellman & Associates, Inc.  All rights reserved. 53 Gevo Emergency Preparedness and Fire Prevention Program Community Hospital - Emergencies Only (For more information, see Designated Medical Provider Section in Health and Safety Program Chapter) Sky Ridge Medical Center 10101 RidgeGate Parkway Lone Tree, CO 80124 P: (720)225-1000

State Department of Health Colorado Department of Public Health and Environment 1-877-518-5608

Occupational Health and Safety Administration Englewood Area Office 7935 East Prentice Avenue, Suite 209 Englewood, Colorado 80111-2714 (303) 843-4500 (303) 843-4515 FAX

If you have an EMERGENCY (e.g., to report a fatality or imminent life-threatening situation) -- Please contact OSHA’s toll free number immediately at 1-800-321-OSHA (6742)

Poison Control Center (800)222-1222

Xcel Energy – Electricity (800)895-1999

Xcel Energy – Gas (800)895-2999

EPA Region VIII Emergency Response Branch 1-800-227-8917 National Response Center 1-800-424-8802

Emergency Contact Information

The Health and Safety Coordinator maintains a list of all employees’ personal emergency contact information and are kept at corporate headquarters for easy access in the event of an emergency.

Personnel Roles, Lines of Authority

In the event of a fire or emergency situation, Emergency Coordinators shall ensure that all employees are notified as soon as possible. As appropriate, ECs shall provide special instructions to all employees.

If a fire or emergency situation occurs after normal business hours, The EC or supervisors shall contact all employees not on shift of future work status, depending on the nature of the situation.

Emergency Response Team

Gevo does not maintain a trained Emergency Response Team and will use the Local Fire Department for all emergencies as defined in 1910.120(q).

Reporting Fire and Emergency Situations

All fires and emergency situations will be reported as soon as possible up the chain of command as necessary either verbally as soon as possible during normal work hours or by telephone if after normal work hours or on weekends.

Emergency Recognition and Evacuation

Emergency Notification

In the event of an emergency, affected employees will be notified via verbal announcement or phone.

Emergency Evacuation and Designated Meeting Location

In the event of an emergency evacuation, no one is to remain in the facility. There are no critical operations to perform that would require any employees to remain in the building during an evacuation. All personnel shall evacuate the work area using the nearest exit route. Employees are not expected or required to use portable fire extinguishers to attempt to put out a fire prior to evacuation. All employees will meet in the field to the south of the facility, near the picnic table. The EC will take an accurate head count of all employees. The EC is responsible for notifying the responding Fire/Rescue Incident Commander of any missing employees.

The responding Fire/Rescue service will be solely responsible for ANY and ALL rescue and medical duties. Employees are NOT expected to perform rescue and medical duties.

Employees may voluntarily use a portable fire extinguisher to attempt to put out a fire prior to evacuation as long as the following provisions are followed: • It is a small fire (i.e. less than 1 square foot area); • Fighting the fire does not danger employee(s); and • Employees have been trained in basic firefighting techniques

Under no circumstances shall an employee attempt to fight a fire that has passed the incipient stage (that which can be put out with a fire extinguisher), nor shall any employee attempt to enter a burning building to conduct search and rescue. These actions shall be left to emergency services professionals who have the necessary training, equipment, and experience (such as the fire department or emergency medical professionals). Untrained individuals may endanger themselves and/or those they are trying to rescue.

Fire Extinguishers

Classes of Fires and Fire Extinguishers: • Class A Involves ordinary combustibles such as paper, wood, cloth, rubber or plastics. The common extinguishing media is water or dry chemical. • Class B Flammable liquids, grease or gases are covered under this category. Common extinguishing media are foam, carbon dioxide or dry chemical.

• Class C Live electrical fires are class C fires. CO2 or dry chemical extinguishers should be used. However, the actual burning product may be class A items.

• Class D Burning materials include combustible metals such as magnesium and sodium. Special extinguishing agents, approved by recognized testing laboratories, are needed when working with these metals.

Using Portable Fire Extinguishers

Fire extinguishers are to be checked at least monthly to ensure the pressure is adequate and that the extinguisher is in proper working order. These inspections should be completed by assigned site employees and documented on the back side of the annual inspection tag. Annual inspections should be performed by a qualified vendor or fire department representative.

Responding To Fires:

Notify others in the area by sounding the fire alarm and call the local fire department immediately if a fire breaks out. Follow company’s procedures on responding to fires. Do not attempt to fight the fire unless you are comfortable and trained to do so. . If the fire gets too large or out of control, evacuate immediately.

• P - Pull. Pull the locking pin before using the fire extinguisher. • A - Aim. Aim the fire extinguisher at the base of the fire. Not at the flames or smoke and stand back 8 to 10 feet. • S - Squeeze. Squeeze the lever of the fire extinguisher to operate and discharge. • S - Sweep. Sweep the fire extinguisher back and forth at the base of the fire to extinguish.

Most extinguishers will only allow about 10-seconds of extinguishing media. Prevention is the key when it comes to firefighting. Good housekeeping, proper storage procedures, and safe work practices will go a long way toward reducing the likelihood that a fire will destroy valuable property or injure either you or a fellow employee.

Hazardous Substances Spills

Predominant hazardous substances include the following at this Facility:

Hazardous Material Quantity Primary Storage Location Gasoline 2 55-gallon drums Stored in lab Fuel grade isobutanol 2 55-gallon drums Stored in lab Solvent grade isobutanol 1 55-gallon drum Stored in lab Mixed alcohols 3 55-gallon drums Stored in lab Ethyl methanesulfonate <100g Stored in chemical storage cabinet in lab Dimethyl sulfate Approx 250 ml. Stored in fridge in fuels lab

Methacrolein Approx 50 ml. Stored in fridge in fuels lab

While a large spill will not occur with these materials, if these materials are spilled and cannot be safely cleaned up, or a major spill occurs, contact the following company for clean-up operations:

Custom Environmental Services P(800)310-7745 8041 W. Interstate 70 Frontage Rd. N. #11 Arvada, CO 80002

Fire Prevention

Gevo Management is responsible for ensuring that all equipment and systems provided to prevent or control ignition, or fires on-site are maintained. Additionally, they are responsible for controlling fuel sources, and to maintain accumulations of flammable and combustible waste materials in their areas.

Hellman & Associates, Inc.  All rights reserved. 57 Gevo Emergency Preparedness and Fire Prevention Program Equipment and systems designed to prevent accidental ignition of combustible materials installed on heat-producing equipment will be maintained according to manufacturer’s instructions.

Training

The Health and Safety Coordinator and Emergency Response Coordinator are trained to assist in the safe and orderly emergency evacuation of employees.

The Health and Safety Coordinator and Emergency Response Coordinator will be trained upon initial assignment and annually thereafter.

The contents of this plan will be reviewed with all employees within the first week after their hire date and whenever an employee’s duties and/or responsibilities under the plan change.

All employees shall be provided basic training on the use of portable fire extinguishers and other applicable fire suppression equipment.

Emergency evacuation drills will be coordinated and conducted by the ECs at least once per year.

Critique of Response and Follow-Up

After each practice session and actual response, responders and employees will undergo a debriefing and evaluation of the response. This will take place no more than one month after the incident or drill and be documented by the ECs.

Workplace Violence

Workplace violence can be any act of physical violence, threats of physical violence, harassment, intimidation or disruptive behavior. A number of different actions can trigger or cause an incident such as an abusive employee, manager, or supervisor and can involve visitors and contractors as well. Non-work related incidents such as domestic violence can also lead to a workplace incident.

Workplace violence incidents, especially those escalating to active shooter attacks are dynamic incidents that vary greatly from one attack to another. Most cases involving armed intruders show no pattern or method in their selection of victims.

Employee Notification and Response

Gevo will use verbal communication and cell phones to inform all employees on site of a situation. Employees should call 911 as soon as possible.

Evacuate: Employees should evacuate the office or client site if safe to do so; evacuees should leave behind belongings, visualize their entire escape route before beginning to move. Do not impede emergency egress. Ensure all exits are free of blockage and that doors are in proper working order.

Hide: If evacuating the facility is not possible, employees should hide in a secure area, lock and blockade the door with heavy furniture, turn off all lights, silence electronic devices, lie on the floor and remain silent.

Take Action: If neither evacuating the facility nor seeking shelter is possible, occupants should attempt to disrupt and/or incapacitate the armed intruder by throwing objects or using aggressive force with nearby objects (fire extinguishers etc.

General Company Policy

The purpose of this program is to establish that Gevo is complying with the OSHA’s 29 CFR 1910.1200, Hazard Communication standard.

This program applies to all work operations at Gevo where employees may be exposed to hazardous substances under normal working conditions or during an emergency situation. As the majority of Gevo’s chemical exposures will be in a laboratory environment, OSHA’s Hazard Communication standard may not fully apply to site operations; however, Gevo is providing this written program to cover areas outside of the laboratory environment, and as a supplemental means to communicate chemical hazards and information.

Employees have access to this program, along with the entire Gevo Health and Safety Manual, digitally or in a hard copy format located on site.

The Health and Safety Coordinator is the Hazard Communication Program Coordinator, who has overall responsibility for the program.

Definitions

Carcinogen: A chemical is considered carcinogenic if:

• It has been evaluated by the International Agency for Research on Cancer and found to be a carcinogen or potential carcinogen; or • It is listed as a carcinogen or potential carcinogen in the Annual Report on Carcinogens; or

• OSHA regulates it as a carcinogen.

Common name means any designation or identification such as code name, code number, trade name, brand name, or generic name used to identify a chemical other than by its chemical name.

Hazard category means the division of criteria within each hazard class, e.g. oral acute toxicity includes five hazard categories and flammable liquids includes four hazard categories. These categories compare hazard severity within a hazard class and should not be taken as a comparison of hazard categories more generally.

Hazardous chemical means any chemical, which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified.

Hazard not otherwise classified (HNOC) means an adverse physical or health effect identified through evaluation of scientific evidence during the classification process that does not meet the

Hellman & Associates, Inc.  All rights reserved. 60 Gevo Hazard-Communication-Program specified criteria for the physical and health hazard classes addressed in this section. This does not extend coverage to adverse physical and health effects for which there is a hazard class addressed in this section, but the effect either falls below the cut-off value/concentration limit of the hazard class or is under a GHS hazard category that has not been adopted by OSHA (e.g., acute toxicity Category 5).

Hazard statement means a statement assigned to a hazard class and category that describes the nature of the hazards of a hazardous product, including, where appropriate, the degree of hazard.

Pictogram means a picture symbol that represents a distinct hazard(s) shown on the material label based on the chemical hazard classification. There are nine pictograms specified by OSHA.

Health Hazard Flame Exclamation Mark

Carcinogen Flammables Irritant (skin and eye) Mutagenicity Pyrophorics Skin Sensitizer Reproductive Toxicity Self-Heating Acute Toxicity Respiratory Sensitizer Emits Flammable Gas Narcotic Effects Target Organ Toxicity Self-Reactives Respiratory Tract Irritant Aspiration Toxicity Organic Peroxides Hazardous to Ozone Layer (Non-Mandatory) Gas Cylinder Corrosion Exploding Bomb

Gases Under Pressure Skin Corrosion/Burns Explosives Eye Damage Self-Reactives Corrosive to Metals Organic Peroxides Flame Over Circle Environment Skull and Crossbones (Non-Mandatory)

Oxidizers Acute Toxicity (fatal or Aquatic Toxicity toxic)

Precautionary statement means a phrase (and/or pictogram) that describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous product, or improper storage or handling of a hazardous product.

Product identifier means the name or number used for a hazardous chemical on a label or in the SDS. It provides a unique means by which the user can identify the chemical. The product

Hellman & Associates, Inc.  All rights reserved. 61 Gevo Hazard-Communication-Program identifier used shall permit cross-references to be made among the list of hazardous chemicals required in the written hazard communication program, the label and the SDS.

Safety Data Sheets (SDS), formerly known as Material Safety Data Sheets, are the primary means of determining the hazards of any chemical. They summarize the characteristics of a chemical and any safety information that may be used in the workplace to prevent employee exposure. The GHS requires a standard 16-section format.

Signal word means a word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. The GHS uses ‘Danger’ and ‘Warning.’

Toxic: Chemicals are toxic if they fall into any of the following categories:

• A chemical that has a median lethal oral dose (LD50) of more than 50 milligrams but less than 500 milligrams; • A chemical that has a LD50 of more than 200 milligrams but less than 1,000 milligrams; or • A chemical that has a median lethal concentration (LC50) in air of more than 200 parts per million but not more than 2,000 parts per million by volume of gas or vapor, or more than 2 milligrams but less than 20 milligrams per liter of mist, fume, or dust.

List of Hazardous Chemicals

The online server will maintain a list of all hazardous chemicals and related work practices expected to be used at the facility. This list will be reviewed at least annually and updated as necessary.

Safety Data Sheets

With the adoption of the GHS, OSHA has changed the requirement for Material Safety Data Sheets (MSDS) to Safety Data Sheets (SDS). The SDS has a standard 16-part format which includes the following:

• Section 1, Identification;

• Section 2, Hazard(s) identification;

• Section 3, Composition/information on ingredients;

• Section 4, First-aid measures;

• Section 5, Fire-fighting measures;

• Section 6, Accidental release measures;

• Section 7, Handling and storage;

• Section 8, Exposure controls/personal protection;

• Section 10, Stability and reactivity;

• Section 11, Toxicological information;

• Section 12, Ecological information;

• Section 13, Disposal considerations;

• Section 14, Transport information;

• Section 15, Regulatory information; and

• Section 16, Other information, including date of preparation or last revision.

Hard copies of SDSs for all anticipated chemicals will also be maintained by the Health and Safety Coordinator. These are available in case of an emergency for employees and by contractors, upon request or need to know.

SDSs are the primary source for health and safety information. The following information can be found on the SDS:

• The identity of the chemical as used on the label. • Whether the chemical is a single chemical or a mixture of chemicals.

• Physical and chemical characteristics of the hazardous chemical. The physical hazards of the chemical including the potential for fire, explosion, and reactivity. • The health hazards of the chemical including sign and symptoms of exposure, and any predisposing medical conditions. • The primary routes of entry.

• The OSHA permissible exposure limits, the threshold exposure limit values, and any other pertinent exposure data. • Whether the chemical has been listed as a potential carcinogen. • Precautions for safe handling and use including: hygienic practices, protective measures, and procedures for cleanup of spills.

• Measures to control exposures such as engineering controls, work practices, and personal protective equipment. • Emergency and first aid procedures. • The date of preparation of the SDS or latest revision.

• The name, addresses, and telephones number of the manufacturer, importer or distributor.

The Facilities Department is responsible for acquiring and updating SDS as necessary. SDS must be obtained for all hazardous chemicals on each project site.

Labels

All employees will ensure that all hazardous chemicals on site are properly labeled and updated as necessary. The newly OSHA adopted GHS program requires additional elements for chemical labels.

As previously mentioned in the Chemical Hygiene Program chapter, all labels on the manufacturer’s containers are required to have a pictogram(s), signal word, hazard and precautionary statement(s), the product identifier, and supplier identification (including name, address, and telephone number of the manufacturer, importer or responsible party).

All manufacturers’ labels will be checked upon receipt to verify that all containers are properly identified. Employees should use care to insure labels are not defaced or removed.

The employee transferring chemicals from a labeled container is responsible for ensuring the new container is properly labeled. If the container is intended for immediate use, no label is required. Employees should use this GHS labeling system (example isobutanol):

Non-Routine Tasks

When hazardous non-routine tasks are to be performed (e.g. cleaning tanks) and existing procedure(s) do not address the hazards associated with the chemicals, a hazard analysis shall be performed and a pre-job meeting held for involved supervisors and employees.

The pre-job meeting will utilize SDS to inform employees about any hazards that may be present associated with hazardous materials that will be used and the proper precautions to take to reduce or avoid exposure. If an employee or supervisor recognizes that no procedure exists, it is their responsibility to review the SDS and draft a procedure.

Training

The purpose of training is to reinforce and affirm the right of workers to be informed of the chemical hazards they face in the work place and how they can protect themselves from those hazards.

Training is required for newly hired personnel prior to assignment to an area that uses hazardous chemicals and whenever a new chemical hazard is introduced to a work area.

Hazard Communication training for the site will include information on the following:

The Hazard Communication Standard:

• Purpose and requirements of the standard; • Gevo’s approach to carrying out these requirements; • Details of the written hazard communication program; and • Availability of Gevo’s written programs.

Hazardous Chemicals:

• Introduction to physical and health hazards; • How to identify hazardous chemicals in the work area; • The classification of hazardous chemicals;

• Physical and health hazards associated with hazardous chemicals in the work area; and • Safety procedures to use with each class of hazardous chemical.

Safety Data Sheets:

• Availability of SDS; • Location of SDS in the work area; and • How to use a SDS.

Labeling:

• How to read and use information on the warning labels; and • How to properly label portable and secondary containers.

Employee Protection Measures:

• Measures that employees may take to protect themselves from hazardous chemicals; • Methods and observation techniques used to determine the presence or release of hazardous chemicals in the work area; and • Emergency procedures to follow if a release or an exposure occurs.

Training will be documented using the Employee Training and Information Verification Form. This form can be used for group training or individual training.

All training records will be kept in the employees’ training file located in Human Resources or the equivalent.

Contractors / Multi-Employer Worksites

As appropriate, the Project Manager responsible for the contract work will advise outside contractors in person of any chemical hazards that may be encountered in the normal course of their work on the premises and vice versa.

The labeling system, location of the SDS binder, protective measures and safety handling procedures will be communicated to the contractor if applicable and vice versa.

All contractors working on site must be able to provide a copy of their Hazard Communication Program and SDSs upon request to Gevo.

General Company Policy

The purpose of this program is to establish that Gevo is complying with OSHA’s 29 CFR 1910.147, Control of Hazardous Energy (Lockout/Tagout) standard.

This program applies to all work operations at Gevo where employees may be exposed to potentially stored energy during maintenance and servicing on equipment and machinery.

The Health and Safety Coordinator is the Lockout/Tagout Program Coordinator who has overall responsibility for the program.

Definitions

Affected employee is an employee whose job requires him/her to operate or use a machine or equipment on which servicing or maintenance is being performed under lockout or tagout; or whose job requires him/her to work in an area in which such servicing or maintenance is being performed.

Authorized employee is a person who locks out or tags out machines or equipment in order to perform servicing or maintenance on that machine or equipment. An affected employee becomes an authorized employee when that employee's duties include performing servicing or maintenance covered under this section.

Capable of being locked out means an energy isolating device is capable of being locked out if it has a hasp or other means of attachment to which, or through which, a lock can be affixed, or it has a locking mechanism built into it. Other energy-isolating devices are capable of being locked out, if lockout can be achieved without the need to dismantle, rebuild, or replace the energy-isolating device or permanently alter its energy control capability.

Energized means connected to an energy source or containing residual or stored energy.

Energy isolating device is a mechanical device that physically prevents the transmission or release of energy, including but not limited to the following: A manually-operated electrical circuit breaker; a disconnect switch; a manually-operated switch by which the conductors of a circuit can be disconnected from all ungrounded supply conductors and, in addition, no pole can be operated independently; a line valve; a block; and any similar device used to block or isolate energy. Push buttons, selector switches and other control circuit type devices are not energy- isolating devices.

Energy source is any source of electrical, mechanical, hydraulic, pneumatic, chemical, thermal or other energy.

Hellman & Associates, Inc.  All rights reserved. 67 Gevo Lockout/Tagout Program Lockout is the placement of a lockout device on an energy-isolating device, in accordance with an established procedure, ensuring that the energy-isolating device and the equipment being controlled cannot be operated until the lockout device is removed.

Lockout device is a device that utilizes a positive means such as a lock, either key or combination type, to hold an energy-isolating device in the safe position and prevent the energizing of a machine or equipment. Included are blank flanges and bolted slip blinds.

Normal production operations means the utilization of a machine or equipment to perform its intended production function.

Servicing and/or maintenance means workplace activities such as constructing, installing, setting up, adjusting, inspecting, modifying, and maintaining and/or servicing machines or equipment. These activities include lubrication, cleaning or unjamming of machines or equipment and making adjustments or tool changes, where the employee may be exposed to the unexpected energization or startup of the equipment or release of hazardous energy.

Setting up means any work performed to prepare a machine or equipment to perform its normal production operation.

Tagout means the placement of a tagout device on an energy-isolating device, in accordance with an established procedure, to indicate that the energy-isolating device and the equipment being controlled may not be operated until the tagout device is removed.

Responsibilities

Authorized employees are the managers and technicians who are skilled to perform maintenance, repair or service on a machine, piece of equipment or a system and who have the responsibility to use this procedure prior to servicing, maintenance or repair.

Affected employees are all employees(s) and any other visiting trades into the Site whose interaction with equipment being serviced is secondary to the maintenance activities. Affected employees’ responsibilities are to recognize and adhere to all lockout/tagout warnings.

The Lockout/ Tagout Program Coordinator will ensure all locks and tags used at Gevo will be standardized according to color, shape, and size. Locks and tags used to comply with the provisions of this program will be used only for the purpose of controlling energy and that all devices meet the minimum requirements of the standard. All tags will be marked with the employee’s name that places the lock and tag.

The Lockout/ Tagout Program Coordinator will coordinate training for all Affected and Authorized employees upon initial assignment and annually thereafter. Affected employees will be trained at initial assignment and may be retrained prior to work beginning if necessary.

Identify equipment to be locked-out/tagged-out and determine if it has multiple energy sources (i.e. electrical, pneumatic, hydraulic, potential, etc.). If the equipment has multiple energy sources, a specific procedure will be developed and made available to employees by the Health and Safety Coordinator.

The procedures can be found in the Operations and Maintenance Manual.

Preparation for Lockout/Tagout

Locate and select the control device based on the type of energy to be isolated and/or controlled. If a device has multiple energy sources, locate the Equipment specific procedure.

Sequence of Lockout/Tagout System Procedure

Authorized employees will conduct the following when lockout tagout procedures are necessary: 1. Notify immediately affected employees that a lockout system is going to be utilized and the reasons therefore. 2. If machine or equipment is operating, shut it down by the normal stopping procedures. 3. Utilize one of the following isolating/control devices based on the energy, which requires control.

o Electrical Energy isolation/control is accomplished by placing manually-operated electrical circuit breakers, disconnect switched, a manually-operated switches in the “off” position. A lockout device such as a “Plugout or Lock a Plug” for plug-in equipment or a hasp and lock for disconnect switches shall be used.

o Pneumatic energy isolation/control is accomplished by disconnecting the air supply from the equipment and using a device such as a “Plugout or Lock a Plug” for the end of the air source.

o Potential energy involving gravity isolation/control is accomplished by placing blocks made of wood, metal or other suitable materials under the mechanism or by pinning the linkages in a position where gravity will not cause the mechanism to fall.

o Energy involving springs isolation/control is accomplished by blocking the spring in a safe position, either by pinning or clamping, or by securing the device in some other manner to eliminate the potential unrestricted or undesired movement.

o Hydraulic energy isolation/control is accomplished by identifying the energy source for the hydraulic pump and controlling that energy source. The residual pressure in the system must be released.

o Thermal energy and potential energy involving pressure isolation/control is accomplished by closing valves and maintaining an open-bleed condition in the

Hellman & Associates, Inc.  All rights reserved. 69 Gevo Lockout/Tagout Program system to prevent energy build-up. Residual thermal energy for example in a heat sealer should be given adequate time to disperse the energy prior to servicing.

o Tanks and piping systems isolation/control is accomplished by closing valves. The pipes should be disconnected and a pipe blank inserted in the pipeline. After the tank or lines have been drained, you may still have to flush them out to purge them of any remaining chemicals. If possible, lockout the drain ends to prevent back feed. 4. An authorized employee must affix appropriate and effective lockout and/or tagout devices to each energy-isolating device. Lockout devices shall be affixed in a manner that will hold the energy-isolating device in a “safe” or “off” position. Tagout devices cannot be used when the equipment can accept locking devices except in rare circumstances when additional precautions are taken. Devices are to be affixed in such a manner that will clearly indicate that the operation or movement of energy-isolating devices from the “safe” or “off” position is prohibited. 5. Lockout the energy isolating device(s) with assigned individual lock(s). 6. Stored or residual energy, such as that in capacitors, springs, elevated machine members, rotating flywheels, hydraulic system, air, gas, steam or water pressure, must be dissipated or restrained by methods such as grounding, repositioning, blocking, bleeding down, or any other approved method. 7. Ensure that the equipment is disconnected from the energy source(s) by first checking that no personnel are exposed, then verify the isolation of the equipment by operating the push button or other normal operating control(s) or by testing to make certain the equipment will not operate. Return operating controls to neutral or “off” position after verifying the isolation of the equipment.

Now that the machine and/or equipment has been isolated, locked-out, properly tagged, and energy released or controlled, the repair, maintenance, or service can be initiated.

In situations where lockout devices must be temporarily removed from the energy-isolating device or when an energy-isolating device cannot be applied due to the need to operate the equipment during maintenance activities, the authorized employee must maintain control of the energy sources at all times. If at any time during the maintenance activities the authorized employee must leave the machine, all systems must be de-energized and energy control measures must be used.

Group Lockout

The use of a group lockout device such as a lockbox, hasp, or a trade lockout device can be used during shift changes, which occur during the continued maintenance or servicing of equipment.

When required to be utilized, each employee shall attach a personal lockout or tagout device to the group's device while he/she is working and then removes it when finished. During shift change or personnel changes, there should be specific procedures to ensure the continuity of

Hellman & Associates, Inc.  All rights reserved. 70 Gevo Lockout/Tagout Program lockout or tagout procedures. Documentation will be specific. The authorized employee should ascertain the exposure status of individual group members.

Sequence of Lockout/Tagout Removal

Prior to removal of lockout devices, authorized employees must inspect the work area to ensure that components are operationally intact and all nonessential items are removed.

Prior to removal of lockout devices, the work area must be checked to ensure that all employees have been safely positioned or removed.

Once the area and equipment have been inspected thoroughly, authorized employees can proceed to remove the lockout and tagout with the following steps: 1. Begin the lockout/tagout removal by starting at the most “downstream” switch or valve, checking to see that everything is in the “OFF” position or closed; 2. Remove all blanks and reconnect all pipes or air supply; 3. Remove all locks and tags; 4. Make sure all guards are in place, the worksite is clean, all tools are removed, and all personnel are accounted for and in a safe position; 5. Refer to the Standard Operating Procedures for the correct start-up procedures and return the equipment to service.

Periodic Inspections

An authorized employee, other than those involved in performing the procedure being inspected, will conduct periodic inspections of these procedures at least annually.

A certification, signed by the Health and Safety Coordinator will be completed to indicate the equipment on which the energy control procedure was utilized, the date of the inspection, the employees included in the inspection and the person performing the inspection.

Training

The Health and Safety Coordinator will coordinate training for all Affected and Authorized employees upon initial assignment. Training will include the elements of this program, lockout/tagout devices available, and Gevo employee’s role with control of hazardous energy.

Retraining is required when there is a change in job assignments, in equipment, a change in the energy control procedures, or a new hazard is introduced.

All training and/or retraining must be documented and signed by the employee and the instructor

Record Keeping

Record keeping for employee equipment assignments shall be maintained by the corporate office and audited periodically.

Forms

All forms are located in the Appendix at the end of this manual.

LOTO Equipment Specific Procedures LOTO Procedures Annual Review Form

Personal Protective Equipment Program

General Company Policy

The purpose of this program is to establish that Gevo is complying with the OSHA’s 29 CFR 1910.132 Personal Protection Equipment standard.

This program applies to all work operations at Gevo where physical and chemical hazards may be reduced or eliminated using personal protective equipment.

The Health and Safety Coordinator is the Personal Protective Equipment Coordinator for the Site and has overall responsibility for the program.

Hazard Assessment and Equipment Selection

OSHA requires employers to conduct inspections of all workplaces to determine the need for personal protective equipment (PPE) and to select the proper PPE for each task performed. For each particular task or distance operation at the facility, a certified assessment must be completed, which lists the hazards of the task or operation and the specific protective equipment to be utilized. The PPE hazard assessment form is included at the end of this manual as a template to be used for these certified assessments. When complete, the task or operation- specific hazard assessments must be signed by the Health and Safety Coordinator after performing the assessment.

As part of the hazard assessment, the Personal Protective Equipment Coordinator will determine the suitability of the PPE presently available and as necessary, select new or additional equipment, which ensures a level of protection greater than the minimum required to protect the employees from the hazards. Care will be taken to recognize the possibility of multiple and simultaneous exposure to a variety of hazards. Adequate protection against the highest level of each of the hazards will be provided or recommended for purchase. Standard required PPE is listed in the table at the end of this program. PPE provided will be employee specific, fitted to that employee, and not shared.

Protective Devices

All personal protective clothing and equipment will be of safe design and construction for the work to be performed and shall be maintained in a sanitary and reliable condition. Only those items of protective clothing and equipment that meet NIOSH (National Institute for Occupational Safety and Health), ASTM (American Society for Testing and Materials) or ANSI (American National Standards Institute) standards will be procured or accepted for use. Newly purchased PPE must conform to the updated ANSI standards, which have been incorporated into the OSHA PPE regulations, as follows:

• Eye and Face Protection ANSI Z87.1-1989

• Foot Protection ANSI Z41.1-1991 and ASTM F2413-11 • Hand Protection. There are no ANSI standards for gloves; however, selection must be based on the performance characteristics of the glove in relation to the tasks to be performed.

• Head Protection ANSI Z89.1-1986 • All PPE used for electrical safety must meet specifications established in the Gevo Electrical Safety Program in this manual.

Defective or damaged PPE shall not be used and must be replaced immediately.

Careful consideration will be given to comfort and fit of PPE in order to ensure that it will be used. Protective devices are generally available in a variety of sizes. Care should be taken to ensure that the right size is selected.

Employees are not permitted to use their own personal PPE; instead all required PPE will be provided by Gevo.

Eye and Face Protection

Prevention of eye injuries requires that all persons who may be in eye hazard areas wear protective eyewear. This includes employees, visitors, customers, or others passing through an identified eye hazard area. To provide protection for these personnel, Gevo will maintain a sufficient quantity of goggles and/or plastic eye protectors, which afford the maximum amount of protection possible. If these personnel wear personal glasses, they shall be provided with a suitable eye protector to wear over their glasses.

Suitable protectors shall be used when employees are exposed to hazards from flying particles, molten metal, acids or caustic liquids, chemical liquids, gases, or vapors, bio-aerosols, or potentially injurious light radiation.

Wearers of contact lenses must also wear appropriate eye and face protection devices in a hazardous environment.

Side protectors shall be used when there is a hazard from flying objects.

Goggles and face shields shall be used when there is a hazard from chemical splash.

Face shields shall only be worn over primary eye protection (safety glasses or goggles).

For employees who wear prescription lenses, eye protectors shall either incorporate the prescription in the design or fit properly over the prescription lenses.

Protectors shall be marked to identify the manufacturer.

Equipment fitted with appropriate filter lenses shall be used to protect against light radiation. Tinted and shaded lenses are not filter lenses unless they are marked or identified as such.

Prescription Safety Eyewear

OSHA regulations require that each affected employee who wears prescription lenses while engaged in operations that involve eye hazards shall wear eye protection that incorporates the prescription in its design, or shall wear eye protection that can be worn over the prescription lenses (goggles, face shields) without disturbing the proper position of the prescription lenses or the protective lenses. Eye prescription glasses can be purchased and then submitted for reimbursement for employees that want them. Employees should contact the Health and Safety Coordinator for more details.

Emergency Eyewash Facilities

Emergency eyewash facilities meeting the requirements of ANSI Z358.1 will be provided in all areas where the eyes of any employee may be exposed to corrosive materials. All such emergency facilities will be located where they are easily accessible in an emergency.

Head Protection

While not anticipated during routine site operations s, head protection will be furnished to, and used by, all employees and contractors engaged in construction and other miscellaneous work with overhead hazards. Head protection is also required to be worn when hazards from falling or fixed objects or electrical shock are present.

Foot Protection

NOTE: All Gevo employees shall not wear open-toed shoes or sandals.

Safety shoes or boots with impact protection are required to be worn in work areas where carrying or handling materials such as packages, objects, parts or heavy tools, which could be dropped; and for other activities where objects might fall onto the feet. Safety shoes or boots with compression protection are required for work activities involving skid trucks (manual materials handling cars) or other activities in which materials or equipment could potentially roll over an employee’s feet. Gevo has a Red Wing Corporate account for Foot Protection. The address is 8353 Willow Street Lone Tree, CO. 80214. Foot Protection using the Corporate Red Wing account is for employees that perform site visits at AgriEnergy in Laverne, Minnesota.

Hand Protection

Suitable gloves shall be worn when hazards from chemicals, cuts, lacerations, abrasions, punctures, burns, biological materials, and harmful temperature extremes are present. Glove

Hellman & Associates, Inc.  All rights reserved. 75 Gevo Personal Protective Equipment Program selection shall be based on performance characteristics of the gloves, conditions, duration of use, and hazards present. One type of glove will not work in all situations.

The first consideration in the selection of gloves for use against chemicals is to determine, if possible, the exact nature of the substances to be encountered. Read instructions and warnings on chemical container labels and the SDS before working with any chemical. Recommended glove types are often listed in the SDS section for personal protective equipment.

Chemicals eventually permeate all glove materials. However, they can be used safely for limited time periods if specific use and other characteristics (i.e., thickness and permeation rate and time) are known. As appropriate, the guidance of particular glove manufacturers will be consulted to confirm adequate protection is available based on chemical use and potential exposure.

Cleaning and Maintenance of Personal Protective Equipment

It is important that all Personal protective equipment be kept clean and properly maintained. Cleaning is particularly important for eye and face protection where dirty or fogged lenses could impair vision. PPE should be inspected, cleaned, and maintained by the employee at regular intervals so that the PPE provides the requisite protection. Electrical PPE must be tested and certified as required by applicable standards. PPE shall not be shared between employees until it has been properly cleaned and sanitized. PPE will be distributed for individual use whenever possible.

It is also important to ensure that contaminated PPE, which cannot be decontaminated, is disposed of in a manner that protects employees from exposure to hazards.

Training

Any worker required to wear PPE shall receive training in the proper use and care of PPE. Periodic retraining shall be conducted as needed. The training shall include, but not necessarily be limited to, the following subjects:

• When PPE needs to be worn; • What PPE is necessary;

• How to properly don, doff, adjust, and wear PPE; • The limitations of the PPE; and • The proper care, maintenance, useful life and disposal of the PPE.

Retraining of the employee is required when the workplace changes, making the earlier training obsolete, the type of PPE changes, or when an employee demonstrates lack of use, improper use, or insufficient skill or understanding.

All PPE training will be documented and include the employee name, date(s) of the training, and the subject.

Recordkeeping

Written records shall be kept of the names of persons trained, the type of training provided, and the dates when training occurred. Gevo shall maintain their employees’ training records for at least 5 years.

PPE Specifications

The following table is a summary of tasks and required PPE. Appropriate clothing is always required. Respirators or dust masks may needed to be used for specific tasks though more information can be found in the Respiratory Protection Program.

Table below will be completed once all PPE hazard assessments have been completed for the Gevo facility.

Area/Task Eye Body Foot Hand Head Hearing Lab work Safety Lab Coat Closed toed Gloves Ear Glasses As needed R As plugs R needed R R R R R O R R O O R O Pipetting Microbiology R Caustic 2 example tasks – what is required R- Required O-Optional *Specifications for electrical work are outlined in detail in the Electrical Safety Program in this manual.

Forms

All forms are located in the Appendix at the end of this manual.

PPE Hazard Assessment Form

General Company Policy

The purpose of this program is to establish that Gevo is complying with OSHA’s 29 CFR 1910.134, Respiratory Protection standard.

This program applies to all work operations at Gevo where employees are required to wear respiratory protection. Currently no tasks require the use of a respirator, but some employees choose to wear them voluntarily.

The Health and Safety Coordinator is the Respiratory Protection Program Coordinator, who has overall responsibility for the program.

Respirators

Respirators are considered the last line of defense for protecting employee health and should only be used when control techniques are not feasible or completely successful in reducing personal exposures to hazardous atmospheres. The following are examples of control techniques that must be used to reduce airborne contamination as low as practical (listed in order of preference depending on the nature of the hazard):

Substitution: Replacing hazardous materials with materials with a lower hazard potential (e.g. substituting a chlorinated solvent with a non-chlorinated solvent).

Local exhaust ventilation: Capturing hazardous materials at the point of generation by means of exhaust ventilation (e.g. exhaust ventilation hood).

Voluntary Use

Where respirator use is determined not to be required (e.g., periodically sweeping the warehouse floor, small grinding tasks, etc.), employees may choose to wear filtering face pieces (dust masks). However, the user must review and sign off on the Voluntary Respirator Use Information Sheet (OSHA’s 29 CFR 1910.134, Appendix D) located at the end of this chapter.

Voluntary use of respirators other than dust masks must be approved prior to use.

The issuance and use of disposable respirators will only be permitted for protection against non- hazardous or nuisance dust conditions (e.g. short-term task with limited dust creation such as, sweeping floors).

Training

Hellman & Associates, Inc.  All rights reserved. 78 Gevo Respiratoy Protection Program Before an employee is assigned a respirator, mandatory training on proper use is required. The training must be comprehensive, understandable, and recur annually. After completion of the training the employee must be able to demonstrate knowledge of the following:

• Why the respirator is necessary and how improper fit, use, or maintenance can compromise the protective effect of the respirator. • What the limitations and capabilities of the respirator are. • How to use the respirator effectively in emergency situations, including situations in which the respirator malfunctions. • How to inspect, put on and remove, use, and check the seals of the respirator. • How to recognize medical signs and symptoms that may limit or prevent the effective use of respirators. • The general requirements of the standard.

Forms 29 CFR 1910.134, Appendix D, Voluntary Respirator Use Information Sheet

Safe Work Practices Program

General Company Policy

The purpose of this program is to establish that Gevo informs its employees on the safe work practices for working with ladders, hand and power tools, or while handling heavy materials.

Ladder Safety

Ladders present one of the major hazards in maintenance and operational activities, and their improper use is the cause of many serious incidents. Analysis of incidents involving ladders revealed that the four major causes of such accidents are:

• Ascending or descending improperly. • Failure to secure ladder at top and/or bottom. • Structural failure of the ladder itself. • Carrying objects in hands while ascending or descending.

Great care should be used in the selection of the proper size and design of the ladder to be used, the proper maintenance and storage of a ladder when not in use, and frequent inspections should be made on all ladders.

The 3 points of contact should be used when climbing or descending a ladder. The three points of contact that 3 out of 4 points of contact (your hands and feet) are in contact at all times during mount or dismount.

Ladders of all types should be carefully inspected if accidentally dropped or otherwise damaged in use. Ladders found to be defective should be repaired or, if necessary, destroyed.

General Use

Match the duty rating to the total weight that will be on the ladder and the work application.

Ladders should only be used for the manufacturer intended purpose and not be modified.

The use of ladders with broken or missing rungs or steps, broken or split side rails, or other faulty or defective construction is prohibited.

Portable ladder feet shall be placed on a substantial base, and the area around the top and bottom of the ladder shall be kept clear.

Ladders shall not be placed in access ways or other locations where they may be displaced unless protected by barricades or guards.

In ascending or descending ladders, employees should face the ladder and use both hands to hold on to side rails. Material should not be carried on ladders.

Extension ladders shall be set up at a 4:1 ration of height to distance to the wall. The angle with the ground must not be less than 75 degrees. The top of the ladder must extend at least three feet above the top of the landing surface.

The side rails shall extend not less than 36 inches above the landing. When this is not practical, grab rails, which provide a secure grip for an employee moving to or from the point of access, shall be installed.

Portable ladders shall rest on a firm foundation capable of supporting the load without displacement in any direction.

Ladders shall be equipped with safety shoes, spurs, spikes, tread feet, or other approved slip-resistant devices at the base section of each rail.

Portable metal ladders shall not be used for electrical work where they may contact electrical conductors.

Extension ladder sections shall not be used as independent ladders.

Portable ladders are approved for one-man use only.

All ladders shall be visually inspected before each use and thoroughly inspected periodically. Defective ladders should be tagged and placed out of service.

Hand and Power Tools

All employees shall be familiar with the safe operation of all hand and power tools before use.

Power Tool Precautions • Tools should be maintained in a safe condition. They should be kept sharp and clean for the best performance. Follow instructions in the user's manual for lubricating and changing accessories. • Always follow the manufacturer’s instructions and intended use of the tool.

• Guards shall always be installed during operation of the tool. • Proper PPE including hand and eye protection shall be worn at all times. • Never carry a tool by the cord or hose.

• Never yank the cord or the hose to disconnect it from the receptacle. • Keep cords and hoses away from heat, oil, and sharp edges.

• Disconnect tools when not in use, before servicing, and when changing accessories such as blades, bits and cutters. • All observers should be kept at a safe distance away from the work area.

• Secure work with clamps or a vise, freeing both hands to operate the tool. • Avoid accidental starting. The worker should not hold a finger on the switch button while carrying a plugged-in tool. • Be sure to keep good footing and maintain good balance.

• The proper apparel should be worn. Loose clothing, ties, or jewelry can become caught in moving parts. • All portable electric tools that are damaged or not compliant with current safety regulations shall be removed from use and tagged "Do Not Use."

Hearing Protection

Employees are not exposed to loud noises. A hearing conservation program is not required for any of the employees. If it is believed that these employee positions can exceed the OSHA noise Action Level at least one day of the year, H&A recommends that employees who perform these roles be included in the company hearing conservation program.

Material Handling

Management and staff employees should be aware of good work practices that minimize the possibility of injury.

Safe work practices that can minimize material/equipment handling injuries include: • Test every load before you lift by pushing the object lightly with your hands or feet. This will give you a relative idea of how heavy it is. • In general, if the load weighs more than 50 lbs., have two people make the lift or use mechanical means. • Try to arrange lifting tasks by storing heavy loads at waist height to reduce the effort needed to lift them. Avoid storing heavy items blow the knee or above shoulder height. • Use slow and smooth movements. • Keep your body square with the object. Carry the load between your shoulders and waist. • Change direction of the load by moving your feet, DO NOT TWIST. • Keep the load close to your body. • Bend at your knees and lift with your legs.

Management and staff employees should be aware of good work practices that minimize the possibility of injury.

Safe work practices that can minimize material/equipment handling injuries include:

• Test every load before you lift by pushing the object lightly with your hands or feet. This will give you a relative idea of how heavy it is.

• In general, if the load weighs more than 50 lbs., have two people make the lift or use mechanical means. • Try to arrange lifting tasks by storing heavy loads at waist height to reduce the effort needed to lift them. Avoid storing heavy items blow the knee or above shoulder height. • Use slow and smooth movements.

• Keep your body square with the object. Carry the load between your shoulders and waist. • Change direction of the load by moving your feet, DO NOT TWIST. • Keep the load close to your body.

• Bend at your knees and lift with your legs.

Manual Lifting

Management and staff employees should be aware of good work practices that minimize the possibility of injury.

Before manual lifting is performed, a mental hazard assessment should be completed. The assessment must take into consideration size, bulk, and weight of the object, if mechanical lifting equipment is required, if two-man lift is required, whether vision is obscured while carrying, the walking surface and the path where the objects are to be carried and deposited. Gevo supervisory personnel will enforce the use of manual lifting equipment provided. Upon initiation of the project, Site Supervisors will periodically evaluate the employee work and lifting techniques to identify compliance with the project plan and to evaluate the potential for further injury prevention actions.

In accordance with our incident investigation program, any material handling injury will be investigated and the work procedure altered to prevent an injury recurrence.

Safe work practices that can minimize material/equipment handling injuries include:

• Test every load before you lift by pushing the object lightly with your hands or feet. This will give you a relative idea of how heavy it is;

• If the load weighs more than 50 lbs., use mechanical means for the lift. Mechanical means may differ from project to project but may include forklifts, cranes, and hand trucks. The appropriate means should be identified during the hazard assessment. If mechanical means are not available, have two people make the lift; ▪ For any lift, regardless of weight, the use of lifting devices is the preferred method. The use of these will be outlined in the hazard assessment.

• Try to arrange lifting tasks by storing heavy loads at waist height to reduce the effort needed to lift them. Avoid storing heavy items blow the knee or above shoulder height; • Use slow and smooth movements; • Keep your body square with the object. Carry the load between your shoulders and waist;

• Change direction of the load by moving your feet, DO NOT TWIST; • Keep the load close to your body; and • Bend at your knees and lift with your legs.

Training

Gevo personnel will receive training on “prevention of back injuries,” which includes: proper lifting techniques, body mechanics, proper exercises, avoidance of musculoskeletal injuries, and proper reporting of injuries in accordance with company requirements.

Appendix A Forms