Benzene MGMT

Health & Safety
Benzene Management Code of Practice
Content Owner Occupational Health
Custodian H&S Programs & Projects
H&S Discipline Occupational Health
Program Chemical Management
COMS See COMS Standards
Document Number CEN-EHS028
Version 2.0 Review Cycle 3 years
Revised Date September 2, 2015 Issued Date September 22, 2014
Sign Off
Version Description Date
Requester Reviewer Owner
Sept., Occupational
2.0 Batch 4 Review
2015 Health
CEN-EHS028 | Version 2.0
Issued September 22, 2014 | Revised September 2, 2015
Table of Contents
1.0 Purpose ...........................................................................................................3
2.0 Scope ..............................................................................................................3
3.0 Benzene Management .....................................................................................3

3.1 What is Benzene? .......................................................................................3
3.2 Health Effects ............................................................................................3
3.3 Benzene Management Program ....................................................................4
4.0 Roles and Responsibilities ...............................................................................8
5.0 Training.........................................................................................................10
5.1 Training ..................................................................................................10
6.0 Quality Assurance .........................................................................................10

6.1 Performance Measurement.........................................................................10
6.2 Management of Change .............................................................................10
6.3 Practice Verification ..................................................................................10
7.0 Glossary ........................................................................................................11
8.0 References ....................................................................................................12

8.1 External Documents..................................................................................12
8.2 Internal Documents ..................................................................................12
Appendix A: Cenovus Benzene Respiratory Protection Selection Matrix ................13
List of Tables
Table 1: Occupational Exposure Limits for Benzene........................................................5
Table 2: Roles and Responsibilities ..............................................................................8
Table 3: Terms and Definitions ..................................................................................11
Table 4: Acronyms, Initialisms and Abbreviations ........................................................11
Table 5: External Document References......................................................................12
Table 6: Internal Document References ......................................................................12
Uncontrolled when printed © Cenovus | All rights reserved Page 2 of 14

1.0 Purpose
The purpose of the Benzene Management Code of Practice (COP) is to set a minimum standard
and provide operational guidance for controlling worker exposure to benzene.
2.0 Scope
This Benzene Management COP applies to all Cenovus worksites and encompasses all Cenovus
work activities. Contractors working at Cenovus sites where benzene may be encountered are
expected to have their own management program in place that offers an equivalent level of
awareness and safety.
This Benzene Management Code of Practice supersedes any prior revisions and incorporates
CEN-EHS006, Benzene Awareness Practice (repealed).
3.0 Benzene Management
3.1 What is Benzene?

Benzene is an aromatic hydrocarbon. It has a sweet smelling odour, and at room
temperature it is a colourless liquid. Benzene is extremely volatile, as it easily
evaporates in air, and is only slightly soluble in water. It is flammable, with a flammable
range between 1.2 – 7.8% by volume.
Benzene originates from both natural sources and industrial processes. Benzene is a
natural constituent of crude oil, a by-product of incomplete combustion and a
component of cigarette smoke. It is mainly produced from petrochemicals and is used as
a precursor to chemicals such as styrene and cyclohexane. It is also used in the
manufacturing of products such as rubbers, lubricants, dyes, detergents, drugs and
pesticides.
3.2 Health Effects

Benzene can enter the body through the lungs, digestive track and/or the skin. The
primary route of exposure to benzene is inhalation. The severity of health effects
depends on the dose, or the amount of benzene to which a person is exposed, and the
duration of exposure.
Brief exposure to high concentrations of benzene in the hundreds of ppm range can
cause drowsiness, dizziness, headaches, tremors, confusion and unconsciousness.
Chronic exposure to low concentrations of benzene can cause blood-related illnesses.
These can range from anemia, excessive bleeding, to decreased immune response.
Benzene is also a proven human carcinogen, as it can cause blood cancer (acute myeloid
leukemia).

3.3 Benzene Management Program

As a result of the health risks associated with benzene exposure, all Cenovus worksites
where benzene is present require a benzene management program. The benzene
management program must be implemented by the respective asset team and shall
consist of the following items:
 recognition of benzene on-site
 pre-job hazard assessment
 air monitoring and evaluation
 benzene hazard controls
 storage, use, handling and disposal procedures
 training
 review of the program every three years
3.3.1 Recognition of Benzene on Site

Although Cenovus does not use or produce pure benzene, we should assume that
benzene is present in trace amounts in all hydrocarbon products and process streams
unless otherwise determined. Examples of products or process streams containing
benzene (either in the material or as emission) include:
 condensate  glycol (gas drying)  lean oil
 crude oil  amine (gas treating)  sludge waste
 LPG/NGL  produced water  diluent
 warm lime sludge  emulsion  frac fluids
3.3.2 Pre-Job Hazard Assessment

When working with materials containing benzene, a pre-job hazard assessment is
required. All affected workers (i.e. the work crew and other workers in the
surrounding area) must be accounted for in the pre-job hazard assessment.
Procedures must be in place to ensure sources of benzene be identified, flammability
be considered, and worker exposure to benzene does not exceed applicable
occupational exposure limits (OELs) and is kept as low as reasonably achievable.

3.3.3 Exposure Evaluation and Air Monitoring

Exposure to benzene is regulated in Alberta and Saskatchewan. The OELs are as
follows:
Table 1: Occupational Exposure Limits for Benzene

Benzene (ppm)
Jurisdiction
15-minute 8-hour 12-hour
Alberta 2.5 0.5 0.25
Saskatchewan As low as reasonably achievable (ALARA)
Saskatchewan does not have specific OELs for benzene as it follows the ALARA (as
low as reasonably achievable) principle. For the purposes of compliance, evaluation
and worker protection, Cenovus operations in Saskatchewan shall comply with
the Alberta standards.
On a periodic basis or upon request, Cenovus Occupational Health will conduct
personal monitoring for select representative Cenovus staff to quantify their
individual exposure to benzene and to evaluate Cenovus’s compliance with provincial
regulations.
In addition to exposure measurements, a trained and qualified user may use a
handheld benzene monitor to measure near real-time atmospheric benzene levels for
work activities or events to determine requirement for respiratory protection. These
include but are not limited to:
 responding to accidental releases/spills
 line-breaks or entry into process equipment
 working with benzene-containing material
 manual tank gauging
Note: Only RAE Systems UltraRAE series monitors are approved for use at
Cenovus. Other handheld monitors may be available but must not be used for
benzene detection unless Cenovus Occupational Health or a qualified Cenovus
representative who is competent in benzene monitoring and testing has been
consulted.
3.3.4 Benzene Hazard Controls

Cenovus will reduce workers’ exposures to benzene at Cenovus worksites by
ensuring control strategies are implemented in the following order, and in
combination where necessary:
1. Elimination/substitution
2. Engineering controls
3. Administrative controls

4. Personal protective equipment (PPE)

3.3.4.1 Elimination/Substitution
If practical and feasible, a benzene-free product should be chosen over a
product containing benzene, provided the substitute material has no
greater health, safety and/or environmental impacts.
3.3.4.2 Engineering Controls
Wherever possible, engineering controls will be employed to reduce
benzene release and worker exposure. Recommended engineering
controls include the following:
 Keeping benzene-containing material contained as much as possible
 Scrubbing benzene and hydrocarbons off of effluent gas prior to
venting
 Blanketing or venting storage tanks to vapour recovery systems to
minimize airborne release of benzene
 Providing local exhaust ventilation where routine sampling of benzene-
containing fluids is required
3.3.4.3 Administrative Controls

Where contact with benzene is anticipated, work practices shall be
implemented to reduce potential exposure. These include but are not
limited to the following:
 Educate workers of the hazard associated with benzene exposure.
Workers must participate in training and monitoring programs.
 Conduct pre-job hazard assessments.
 Erect conspicuous signage to inform workers of the hazard, and
limiting access to authorized persons only where benzene may be
released.
 Use available engineering controls to minimize benzene release.
 Consider benzene exposure in procedures for sampling fluids, changing
process and produced water filters and handling process water and
centrate.
 Have an inspection and maintenance schedule for engineering controls
used to reduce exposure.

3.3.4.4 Personal Protective Equipment (PPE) Controls

Where engineering and administrative controls are neither feasible nor
effective, personal protective equipment shall be used.
Respiratory Protective Equipment (RPE)
The level of respiratory protection required depends on the atmospheric
concentration of benzene and duration of exposure.
The use of respiratory protective equipment is allowed as per the
minimum recommendations set out by the Cenovus Benzene Respiratory
Protection Selection Matrix (Appendix A), provided the atmospheric
concentrations and the exposure duration have been quantified by a
competent person.
Atmosphere-supplying respirator (ASR) must be used if any of the
following is true:
 the atmosphere is oxygen deficient
 the atmosphere contains unknown concentrations of a toxic gas or
vapour
 the atmosphere contains other hazards that prohibit the use of an
air-purifying respirator (APR)
Goggles and Gloves
Since benzene can be absorbed through intact skin, hazard assessments
will consider the potential for skin and eye contact. Splash goggles and
impervious gloves will be worn whenever risk of eye or skin contact exists,
including during the following tasks:
 entering a vessel or cleaning a tank
 dismantling or opening process equipment
 manual gauging of tanks or tank opening, filling and/or unloading
 conducting maintenance on equipment that contains or carries
benzene streams
 collecting process samples, especially those containing condensate
and/or diluent
 changing glycol or amine filter
 responding to accidental spills and/or releases
 cleaning large screens/filters

3.3.5 Storage, Use, Handling and Disposal

Where practicable, materials containing benzene shall be enclosed to limit the
potential release of benzene vapour to atmosphere, and to prevent worker exposure.
Open containers of benzene-containing material are not acceptable.
Procedures shall be developed to ensure benzene releases and worker exposures are
kept to a minimum using control methods deemed appropriate by the business unit.
The toxic and flammable nature of benzene must be taken into consideration when
labelling or transporting materials and/or waste containing benzene as per WHMIS or
TDG requirements, where applicable.
4.0 Roles and Responsibilities

The following responsibilities apply to this practice:
Table 2: Roles and Responsibilities

Role Description
 Commission, develop, review and approve a COP
for benzene storage, use, handling and disposal.
Cenovus Leadership  Ensure all practices will be reviewed and updated
on a three-year cycle or more frequently as
required.
 Ensure all facilities under their control comply
with the requirements of this COP and associated
procedures.
Asset Team and Site
 Ensure training is provided to Cenovus
Leadership
employees potentially exposed to benzene.
 Keep records of employee training in the
Learning Management System (LMS).
 Communicate benzene control procedures to
affected workers.
 Ensure the appropriate PPE is available.
 Ensure employees use PPE when required.
 Respond to worker questions directly or by
seeking additional feedback from H&S personnel.
 Provide feedback to the asset team and
corporate management concerning the value and
effectiveness of this COP and all associated
Cenovus Supervisors procedures.
 Ensure workers have been oriented to the
hazards of benzene and the controls that are in
place. The LMS or other suitable means to track
competency may be used for this purpose.
 Ensure contractors engaged to do work on
Cenovus’s behalf have practices to manage
benzene hazards that the contractor’s employees
may encounter while working on Cenovus
worksites.

Role Description
 Apply this COP to worksites under their control
and establish the necessary competencies for
those who may be engaged to support the
development and implementation of the COP
requirements.
 Familiarize themselves with this COP and all
associated procedures.
 Be aware of the hazards of benzene exposure
and adhere to the controls that are in place to
protect their health and safety.
 Apply recommended practices and procedures,
Cenovus Workers
including PPE.
 Seek clarification concerning any practice or
procedure through their immediate Supervisor.
 Report to their Supervisor any spills, incidents
and/or unusual conditions that may occur during
the work, and stop the work if necessary.
 Review any practices and procedures provided to
them by Cenovus.
 Apply information from practices and procedures
as minimum work standards as appropriate to
their work situation.
Contractors
 Seek clarification concerning any Cenovus
practice or procedure through their immediate
Supervisor.
 Implement their own benzene exposure control
program.
 Assist the asset team in complying with this COP
and all associated procedures.
 Respond to questions or concerns relating to the
Health & Safety interpretation of this COP and all associated
procedures.
 Provide assistance to the asset team regarding
appropriate benzene measurements.
 Provide expertise on benzene monitoring and
detection.
Occupational Health
 Review and provide continuous improvement on
the COP.

5.0 Training
Benzene Management Code of Practice training is to maintain a baseline competency that
includes an understanding of benzene hazards and controls that Cenovus has in place.
5.1 Training
Frontline supervisors and workers should review this document prior to conducting
work in environments where there is potential exposure to benzene.
All workers who are required to work in areas where benzene is present must
complete the Cenovus Benzene Awareness eLearning module and practice review
every three years. This training will at a minimum include the following:
 recognition of benzene hazards
 regulatory requirements relevant to the jurisdiction where the work is being

conducted
 communication, assessment and monitoring for the control of benzene hazards
 the selection and use of controls
6.0 Quality Assurance
6.1 Performance Measurement

Compliance with this practice and program effectiveness shall be assessed through
program assessments and internal audits, or other measurement criteria as specified
in the COMS Assurance Standard. Measurement can also be accomplished through
the tracking of appropriate Key Performance Indicators (KPI).
Business functions or departments impacted by this practice must include compliance
and program effectiveness verifications in their business assurance program.
Performance will be monitored and reported within the responsible departments at
least every three years.
Central Health and Safety Services will review Cenovus-wide program KPIs at a
minimum every three years in conjunction with program review and update
activities.
6.2 Management of Change

Proposed changes to this practice can be directed to H&S Programs and Projects.
6.3 Practice Verification

The document owner will complete and document reviews of this practice, as follows:
 at minimum once every three years
 if there is a significant regulation or industry best practice change that indicates

the need for review

 if an incident investigation indicates the causes were related to unclear or

inadequate written instructions described within this practice
If frequent and multiple variances are required due to operational needs, the
reason(s) will be investigated and the document owner will determine if there is a
business need to update the practice.
If submitted MOC requests indicate gaps or significant improvement opportunities,
the document owner will determine if there is a business need to update the
practice.
7.0 Glossary
Definitions and acronyms for safety documents are described in CEN-EHS243,
H&S Definition and Acronym Standard. The following definitions and acronyms are
to this document:
specific
Table 3: Terms and Definitions

Term Definition
The range between the LEL and UEL is known as the
flammable range for that gas or vapour. The minimum
concentration of a gas or vapour that will burn in air is
defined as the lower explosive limit (LEL). Below this level,
Flammable range
the gas or vapour is too lean to burn. The maximum
concentration of a gas or vapour that will burn in air is
defined as the upper explosive limit (UEL). Above this
level, the mixture is too rich to burn.
Table 4: Acronyms, Initialisms and Abbreviations

Term In Full
COP Code of practice
PPE Personal protective equipment
OELs Occupational exposure limits
PPM Parts per million
ASR Atmosphere-supplying respirators
APR Air-purifying respirator
ALARA As low as reasonably achievable
RPE Respiratory protective equipment
WHIMS Workplace hazardous materials information system
TDG Transportation of dangerous goods
COMS Cenovus operations management system
KPI Key performance indicators
LMS Learning management system

8.0 References
8.1 External Documents

The following external documents support this practice:
Table 5: External Document References

Document Type or
Document Title
Number
CAN/CSA Standard Z94.4-02 Selection, Use and Care of Respirators
Work Safe Alberta Best Practices for the Assessment and Control of Chemical
Hazards
Work Safe Alberta Benzene at the Work Site
8.2 Internal Documents

The following Cenovus documents support this practice:
Table 6: Internal Document References

Document Type or
Document Title
Number
Policy Corporate Responsibility Policy
CEN-EHSReg787 Regulatory Definitions and Acronyms
CEN-EHS2632 Chemical Management Standard
CEN-EHS108 Personal Protective Equipment (PPE) Standard
CEN-EHS010 Respiratory Protection Equipment Code of Practice
CEN-EHS019 Hazard Assessment and Control Practice
Traccess Benzene Awareness (eLearning)

Appendix A: Cenovus Benzene Respiratory Protection Selection Matrix
Quantitatively (QNFT) Fit-Tested Workers
Concentration\Duration up to 15 min 15 min - 1 hour 1 hour - 3 hour 3 hour - 6 hour > 6 hour
up to 0.25 ppm none none none Half-face Half-face
0.25 - 1 ppm none none Half-Face Half-Face Half-Face
1 - 2.5 ppm Half-Face Half-Face Half-Face Half-Face Full-Face
2.5 - 5 ppm Half-Face Half-Face Half-Face Full-Face Full-Face
5 - 10 ppm Half-Face Half-Face Full-Face SA/Ventilate SA/Ventilate
10 - 25 ppm Full-Face Full-Face Full-Face SA/Ventilate SA/Ventilate
25-50 ppm Full-Face Full-Face SA/Ventilate SA/Ventilate SA/Ventilate
>50 ppm SA/Ventilate SA/Ventilate SA/Ventilate SA/Ventilate SA/Ventilate
 This chart applies to workers who have been quantitatively fit-tested and hold a valid certificate of
respiratory fit-testing.
 To protect against benzene vapour, organic vapour (OV) cartridges are required.
 The concentration of benzene must be determined with the use of an UltraRAE with scrubber tubes by
a competent person.
**The duration of exposure indicated is the sum over a workday. For example, if a worker is exposed to
0.5 ppm benzene for 45 minutes in the morning and 45 minutes in the afternoon, the total duration of exposure
is 90 minutes. Therefore, the worker must don a half-face respirator at 0.5 ppm benzene for the 90 minutes.
Contact [email protected] for questions or further information.

Qualitatively (QLFT) Fit-Tested Workers
Concentration\Duration up to 15 min 15 min - 1 hour 1 hour - 3 hour 3 hour - 6 hour > 6 hour
up to 0.25 ppm none none none Half-face Half-face
0.25 - 1 ppm none none Half-Face Half-Face Half-Face
1 - 2.5 ppm Half-Face Half-Face Half-Face Full-Face SA/Ventilate
2.5 - 5 ppm Half-Face Half-Face Full-Face SA/Ventilate SA/Ventilate
5 - 10 ppm Half-Face Half-Face SA/Ventilate SA/Ventilate SA/Ventilate
10 - 25 ppm SA/Ventilate Full-Face SA/Ventilate SA/Ventilate SA/Ventilate
25-50 ppm SA/Ventilate SA/Ventilate SA/Ventilate SA/Ventilate SA/Ventilate
>50 ppm SA/Ventilate SA/Ventilate SA/Ventilate SA/Ventilate SA/Ventilate
 This chart applies to workers who have been qualitatively fit-tested and hold a valid certificate of
respiratory fit-testing.
 To protect against benzene vapour, organic vapour (OV) cartridges are required.
 The concentration of benzene must be determined with the use of an UltraRAE with scrubber tubes by
a competent person.
**The duration of exposure indicated is the sum over a workday. For example, if a worker is exposed to 3 ppm
benzene for 45 minutes in the morning and 45 minutes in the afternoon, the total duration of exposure is 90
minutes. Therefore, the worker must don a full-face respirator at 3 ppm benzene for the 90 minutes.
Contact [email protected] for questions or further information.

Benzene MGMT

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Health & Safety

Benzene Management Code of Practice

Content Owner Occupational Health

Custodian H&S Programs & Projects

H&S Discipline Occupational Health

Program Chemical Management

COMS See COMS Standards

Document Number CEN-EHS028

Version 2.0 Review Cycle 3 years

Revised Date September 2, 2015 Issued Date September 22, 2014

1.0 Purpose ...........................................................................................................3

2.0 Scope ..............................................................................................................3

3.0 Benzene Management .....................................................................................3

4.0 Roles and Responsibilities ...............................................................................8

6.0 Quality Assurance .........................................................................................10

7.0 Glossary ........................................................................................................11

8.0 References ....................................................................................................12

Appendix A: Cenovus Benzene Respiratory Protection Selection Matrix ................13

Uncontrolled when printed © Cenovus | All rights reserved Page 2 of 14

3.0 Benzene Management

3.1 What is Benzene?

3.2 Health Effects

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3.3 Benzene Management Program

 recognition of benzene on-site

 pre-job hazard assessment

 air monitoring and evaluation

 benzene hazard controls

 storage, use, handling and disposal procedures

 review of the program every three years

3.3.1 Recognition of Benzene on Site

 condensate  glycol (gas drying)  lean oil

 crude oil  amine (gas treating)  sludge waste

 LPG/NGL  produced water  diluent

 warm lime sludge  emulsion  frac fluids

3.3.2 Pre-Job Hazard Assessment

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3.3.3 Exposure Evaluation and Air Monitoring

Table 1: Occupational Exposure Limits for Benzene

 responding to accidental releases/spills

 line-breaks or entry into process equipment

 working with benzene-containing material

 manual tank gauging

3.3.4 Benzene Hazard Controls

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4. Personal protective equipment (PPE)

3.3.4.3 Administrative Controls

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3.3.4.4 Personal Protective Equipment (PPE) Controls

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3.3.5 Storage, Use, Handling and Disposal

4.0 Roles and Responsibilities

Table 2: Roles and Responsibilities

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 recognition of benzene hazards

 regulatory requirements relevant to the jurisdiction where the work is being

 communication, assessment and monitoring for the control of benzene hazards

 the selection and use of controls

6.0 Quality Assurance

6.1 Performance Measurement

6.2 Management of Change

6.3 Practice Verification