Buckeye Gulf Coast Pipe Lines, L.P.

Company Safety Philosophy

     Safety is a core component of the Buckeye mission statement and is incorporated into each scope of work Buckeye prepares. Buckeye has won several safety awards, including being named in 2000 the API Most Improved Pipeline, and in 2001 recognized by the API for Safety Improvement and No Lost Workdays. Safety is incorporated into every work practice from morning tailgate meetings to regular training sessions. Buckeye is proud of its efforts to improve its safety performance yielding an EMR of 0.74, OSHA Incident Rate of 0.67 and no lost time injuries in 2001. Our results in 2002 were 0.66, 0.14, and zero respectively, for which we received the API Pipeline Occupational Safety award shown below.

     It is the Company goal to prevent all incidents such as personal injuries, vehicle accidents, product releases, fires, and property damage. To attain this goal, the Company operates under the following safety philosophy:

• No job is so urgent that it requires compromising safe work practices. If an employee believes an operation is unsafe, it should be stopped immediately. If an employee is unsure about the best way to safely accomplish a task, the employee's supervisor should be consulted.
• All employees are responsible for ensuring a safe workplace.
• Employee involvement, commitment, and training are essential to meeting the Company's safety goal.
• Employees are expected to look out for the safety of others and bring forth any safety concerns.
• Management solicits and responds to employee health and safety concerns. Any employee who discovers an unsafe condition must promptly report such conditions to his or her Supervisor as well as to other employees that may be affected by the unsafe condition.

     Buckeye has prepared, conducted, and implemented a DOT operator qualification program (OQ), which was mandated in October 2002 and revised by the DOT in 2003 (OQ2). Any individual who performs a covered task on DOT regulated pipeline or facilities must be qualified to perform the covered task and to recognize and react to abnormal operating conditions associated with the covered tasks. Buckeye has been working under the scope and breadth of the program since its submittal in April 2001. Buckeye's operator qualification program consists of:

• Identifying covered tasks applicable to company operations.
• Ensuring qualification through evaluation and/or training.
• Determining intervals for subsequent qualification.
• Ensuring ongoing evaluation to address an individual's ability/inability to perform a covered task or satisfactory/unsatisfactory performance.
• Allowing non-qualified individuals to work under direct observation of a qualified individual.
• Communicating substantive changes to covered task policies and procedures.
• Record keeping compliance.

     The DOT Office of Pipeline Safety's rules for Integrity Management Programs (IMP) in High Consequence Areas (HCA) are now in effect for hazardous liquid and gas pipeline operators. The IMP rules apply risk management principles by identifying areas where pipeline leaks can have more severe consequences and requires operators to reduce the likelihood of leaks in those areas. Buckeye's program for HCA's includes:

• Identification of pipeline segments that can affect HCA's and mapping of these areas in a Geographic Information System (GIS) database.
• Developing a baseline assessment plan to initially test and inspect those segments for integrity.
• An Integrity Management Program detailing on-going testing and repair plans (GIS also tracks hydrostatic test data and documents.)
• Metrics for evaluating the effectiveness of the program.
• A process for continuous improvement of the program.