Houston Area Operations Contractor Administrative - … · STAC Training Process ... Basic...

Houston Area Operations ContractorAdministrative Manual.doc

DOW RESTRICTED -For internal use only of 195

THE DOW CHEMICAL COMPANY*

Houston Area OperationsAdministrative Manual

ForService, Maintenance

AndConstruction

Houston Area Operations consists of the following operations:

Texas City Operations (TCO) - Union Carbide Corporation a subsidiary of The DowChemical Company

LaPorte (HOU) – The Dow Chemical CompanyDeer Park OperationsLone Star OperationsBayport Operations

*As used in this manual, “Dow” refers to The Dow Chemical Company, and its subsidiaries (including UnionCarbide Corporation and Deer Park, Lone Star, & Bayport Operations as applicable).



Contract Company Managers,

The "Houston Area Operations Administrative Manual for Service, Maintenance andConstruction" is provided to you as a minimum standard to support regional and site specificrequirements to include rules, standards and policies.

The Introduction explains more fully the intent and function of this manual. Please familiarizeyourself with the entire manual.

Please do not reproduce this manual. If you need additional copies, or have changes in youraddress or company contacts, etc., please contact your Dow representative.

Should you have any questions, please give the Site Contact a call.

Houston Area Operations Supplier Management ActionTeam (SMAT)



DOW HOUSTON AREA OPERATIONS

MANUAL DISCLOSURENON-DOW USE

THE FOLLOWING NOTE OF CAUTION IS DIRECTED TO ALL PERSONSWHO ARE NOT EMPLOYEES OF DOW:

Since conditions at non-Dow workplaces, or where Dow is not actively supervising thework, are outside of Dow's control and because legal or regulatory requirements mayvary from worksite to worksite, Dow hereby advises you that adherence to this Manual isnot a guarantee that your activities or operations are in compliance with all applicablefederal, state and local laws or regulations, nor is it a guarantee that it will provideabsolute protection against exposures or hazards.

Dow has no control over your use of such information or advice, you are cautioned toindependently confirm the reliability of such information and advice for your purposes,and to evaluate whether it would be suitable for use by you.

Dow makes no warranty, either expressed or implied, as to the accuracy, reliability, orappropriateness for your use, of such information and advice or whether it is completeand without omission and Dow disclaims any liability arising out of your use of suchinformation and advice



Houston Operations Map



Texas City Map

To Galveston

N

Bay Area Blvd

Hwy 517 (Dickinson)

Hwy 518 (League City)

NASA Road 1

Airport Blvd

(Map not drawn to scale)

Houston

Interstate 45

Emmett F.Lowry

Expressway (FM 1764)

TO Texas City Operations:On Interstate 45 past the town of Dickinson, takeExit FM 1764 (aka Emmett F. LowryExpressway). Continue on FM 1764 until youcome to Hwy 146 (You will pass College ofthe Mainland and Columbia Hospital on yourright). There will be a Denny’s Restaurantand a LaQuinta motel on the right at Hwy 146.Take a right on to Hwy 146. The next majortraffic light will be FM 1765. Take a left on toFM 1765. You will be driving alongside ofTCO on your right. FM 1765 will fork. Stay tothe right of the fork. At the next light turn rightinto visitor parking area of TCO.

Hobby Airport

Ramada Inn-La Marque409/986-9777

Holiday Inn-Galveston

Holiday Inn-Hobby

Hwy 146

FM 1765

* Hampton Inn409/986-6686

Fairfield Inn409/986-3866

34th Street

LaQuinta Inn409/948-3101

DOW

Getting to Texas City Operations (TCO)* from the Houston Area

Recommendation: It isgenerally agreed thatthe best hotel in TexasCity is the Hampton Inn,located at the Mall of theMainland.*

*Texas City Operations is owned andoperated by Union Carbide Corporation,a wholly owned subsidiary of the DowChemical Company.



Table of Contents Introduction………..………………………….……....…………………………… 10

Safety Performance.......…………………………………………………………… 11

Safe Behaviors...…………………………………………………………………… 12

Dow Site Contacts………………………………………………………………… 13

Document Control History………………………………………………………… 14

Prequalification

Contractor Qualifications for Work on Site .………………………………………

Form: Waiver of Qualification with Checklist.……………………………………1620

Substance Abuse Policy…………………………………………………………… 26

English Comprehension Policy …………………………………………………… 29

Contractor Safety Responsibilities………………………………………………… 30

Selection/Pre-Job Activities and Access

Minimum Requirements for Contractor Safety and Health Programs..…………… 37

Contractor Program Checklist...…………………………………………………… 43

Form: Waiver of OSHA Threshold/EMR Rate…………………………………… 48

Form: Safety Action Plan (Double click to open spreadsheet)…………………… 49

Site Access for Contractors, Delivery, and Visitors..……………………………… 50

Contractor/Sub Contractor Badging Policy...………………………………………

Form: Contractor Hire Slip...………………………………………………

DOW Background Screening Policy.………………………………………………

59

63

65

Contractor Safety Training Waiver (One day Emergency Waiver)..……………… 67

Form: Waiver of the Contractor/Vendor Safety Indoctrination...………………… 68

Contractor Safety Training Requirements for “Short term, Low-Risk” Entry..…… 69

Form: Contractor Training Requirements for “Short Term, Low-Risk” Entry....… 70

Flowchart: Training Waiver Process....…………………………………………… 71

Visitor/Vendor Policy....…………………………………………………………… 72

Site Leader Safety Expectations – “It’s All About You”..………………………… 77

Pre-Job Orientation....……………………………………………………………… Pre-Access Flowchart........…………………………………………………

7982

Pre-Job Conference Checklist....…………………………….……....…… 83

Continued on next page



Table of Contents, cont.

Selection/Pre-Job Activities and Access, cont.

Job Safety Analysis Guidelines (JSA)....………..…………………….……....…… 110

JSA Civil Work..…………………………………………….……....…… 111

JSA Instrumentation & Electrical...……..………………….……....……… 114

JSA General Mechanical & Construction..……..…………….……....…… 117

Carpenter & Scaffold Builder Policy.....………..…………………….……....…… 120

Contractor Crafts Skill Assessment Policy..…………..…………………….……... 121

Contractor Training Card Policy...………………………………………………… Houston Area Operations sites list of Required Training.....………………

122

Job and Equipment Specific Training Requirements....…………………………… 123

Contractor Site Safety Rep Minimum Expectations.....…………………………… 129

Minimum Certification/Training Requirementsfor Contractor Safety......………………..…………………….……....……………

130

Buddy Policy (At Risk Employee)....……………………………………………… 132

Work in Progress

Job Representative Responsibilities......…………………………………………… 134

Houston Area Operations Contractor Meeting.......……………………………… 139

Maintenance/Scope Change Policy and Form.......………………………………… 140

STAC Training Process….………………………………………………………… 143

DOW Injury/Illness Reporting......………………………………………………… Incident Involving Contractor Flowchart......…………………………………

144146

Incident/Unsafe Condition Reporting and Investigation Process......……………… Investigation Checklist........………………………………………………… Investigation Invitation Checklist...………………………………………… Set Up for Root Cause Investigation (RCI)....……………………………… Facilitator Skills......………………………………………………………… Conducting the Investigation......…………………………………………… Post Incident Procedure......………………………………………………… Contractor Owner Incident Reviews (SLT)....……………………………… Post Incident STAC Review Policy....………………………………………

148153156157159160162163165

Form: Contractor Accident/Incident & Unsafe Condition/Safety Suggestion

Report….………………………………… 166

DOW Smoking Policy.......………………………………………………………… 168




Table of Contents, cont.

Work in Progress, cont.

Glove Use Policy....…………..……………………………………….……....…… 169

Personal Injury Prevention: Cutting Tasks....……………………………………… 172

Man-Hour Collection.……………………………………………………………… 177

Man-Hour Report Form.……………………………………………………… 178

Basic Pollution Prevention………………………………………………………… 179

Contractor Spill Policy – Oil and Fuel...…………..………………….……....…… 181

Loading/Unloading Pipe or Steel...……………..…………………….……....…… 184

Locking Fuel Nozzle Policy...…………………..…………………….……....…… 185

Evaluation

Contractor Severe Violation Policy...……………………………………………… 186

Task Force for Safety Success...…………………………………………………… 189

Contractor Evaluation……………………………………………………………… 191

Evaluation Form……………………………………………………………… 193

Contractor Evaluation Job Aide…………………………………………………… 194



Table of Contents

THE DOW CHEMICAL COMPANY – HOUSTON AREAOPERATIONS

ADMINISTRATIVE MANUALFOR SERVICE, MAINTENANCE AND CONSTRUCTION

INTRODUCTION

This Manual contains administrative safety standards, references and procedures forperformance of work by any contractor, subcontractor, vendor, and their employees(hereinafter referred to collectively as "Contractors", and individually as "Contractor"), asrequired by The Dow Chemical Company Houston Area Operations sites, hereinafterreferred to as “Owner”. These administrative rules shall be used in conjunction with theDow Safety Rules Manual.

The Owner’s representative will be defined in the contract and is hereinafter referred toas "Owner's Representative".

Contractor assumes and has the full responsibility and liability for the safety of its agents,servants and employees and for the compliance of its subcontractors, and nothingcontained in this manual relieves the Contractor of such responsibility or liability.

Safety rules and procedures are an integral part of each contract and must be carried outfully, as any other specification for the job. Any exception to the rules set forth hereinmust have prior written authorization from the Owner's Representative.

Contractors unable or unwilling to secure personnel performance in keeping with theserules risk a loss of business from Owner. The Contractor's OSHA Recordable Incidentrate and Workers Compensation EMR will be two criteria used to judge qualifications forbidding.

In addition to the rules set forth in this manual, Contractors working in or near an existingoperating facility must be cognizant of and conform to Owner's safety rules for that areaand any applicable federal, state or local laws.

Should any procedure set forth herein conflict with applicable federal, state or local laws,the more stringent of the foregoing will apply.



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SAFETY PERFORMANCE

Our vision is to create an incident/injury free work place, which requires the commitment ofevery individual. Our current EH&S goals were set in 2006. We have made great progress, butwe must continue to improve to make the 2015 Goals a reality. Remember this safety principle:“We will get the level of performance that we model and that we expect.”

Therefore, the expectation is:

To work in an incident/injury free work place.

That every Contract Company will direct its employees to actively participate in aBehavior Based Safety Process. This will include, as a minimum, every individualusing Pre-Task Analysis), Leadership Observations, and everyone working togetherto analyze and correct unsafe behaviors.

Cooperative Team Analysis of safety data for continuous improvement of safetyinitiatives.

That contract companies will require everyone to wear the proper Dow site requiredPPE (Personal Protective Equipment).

That contract companies will direct employees in their organization to follow therequirements as set forth in the Dow specific Safety Rules, Standards and policies.

That contract companies will train Individuals in the tasks that they are asked toperform, both from the Craft Skills perspective and the OSHA Regulations.

That contract companies will direct the involvement of everyone throughparticipation in targeted initiatives such as ergonomic/wellness based programs toprevent long-term illness.

Contract companies support continuous progress toward the 2015 EH&S goal ofinjury and illness rate of 0.08 per 200,000 hours of work and, reduce the severity rateby 75 percent.

**Please review these expectations and incorporate them into your operation’s conduct andgoals while working at our site. **

DO IT SAFELYOR

DON’T DO IT!!



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THE DOW CHEMICAL COMPANY – HOUSTON AREAOPERATIONS

Safe BehaviorsExpectations of all contract employees:

Be knowledgeable about and adhere to applicable safety rules, policies, standards, andprocedures, which include use of P.P.E.

Individually accept and be held accountable for your own safety behavior/performance.

Have zero incidents within your control.

Intervene when an unsafe act is observed.

Report all incidents/injuries immediately.

Actively participate in the site safety process including:

Company and Personal Safety Goals Hazard Identification/Correction Pre-Task Analysis Observation/Intervention Issues Resolutions



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Dow Site Contacts

Site EH&S Purchasing

LaPorte, TexasCity*, Deer Park,Lone Star,Bayport

Donna Coyle(409)[email protected]

Travis Owsley(281) [email protected]

* Texas City is owned by Union Carbide Corporation, a wholly-owned subsidiary of The Dow Chemical Company. Union

Carbide has adopted this manual to apply to Houston Area Operations facilities. With respect to such facilities, references toDow in this manual should be regarded as references to Union Carbide, as the case may be.

Houston Area Operations Regional Contractor Administrative ManualHouston Area Operations Contractor Administrative Manual



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Document Control and History

Owner Houston Area Operations Supplier Management Action Team (SMAT)

Location ofControlled Copies

If a document is located in a place other than the location listed below, it isconsidered uncontrolled.

Copy Location

1 Tctsv01\eh&s\Approved\Responsible Care\Non-Dow Services\Communicationof Dow's EH&S Ex\Cont Admin Manual

Revision andReview History

This document will be reviewed every five years or sooner if a process changeoccurs. Process changes are tracked by MOC.

Date Name Description of Revision with MOC #

July 31, 2008 T. Robertson Corrected the Document History page.

August 4, 2008 T. Robertson Corrected infomapping & page numbers.

10/20/08 Pam WatkinsAdded Hair Testing requirements to Substance Abuse Policy and decreasedrandom testing from 100% to 50%.Updated contact list to new Purchasing rep and Houston Operations RCL.Reformatted and updated Pre-Job Checklist with recent Global/Regional Standardupdates (electrical, elevated work, scaffold, mobile hoisting) and clarified lineitems to ensure common understanding.

6/25/09 Donna Coyle, JohnBollom, Howard Meek,Dewey Miles, PamWatkins,

Modified to include Houston Area Operations sites – Texas City, Deer Park, LaPorte, Bayport, & Lone Star; modified Contractor Monthy meeting, It’s All AboutYou and STAC training times/dates;Removed Health Services Guidelines, Procedure Use Policy;Included requirements for Behavior Based Process, included approval for use ofContractor Pre-task with EHS approval; updated functional mailbox for Man HourReporting and included all Houston Area Operation sites; new requirement to postall PQF’s at HASC Xnet web page

DocumentsReferencing thisDocument

The following table lists the documents which reference this document. Whenthis document is revised, the document on this list must be audited to ensure nochanges are required.

OD Number Description

ODMS 6.06 Non-Dow Services





MOC Process Proposals for change will be submitted through the MOC tool and reviewed byHouston Area Operations SMAT.

The following must approve the MOC for all sites affected:

Labor MSM(s) Site DAS(s) RPM(s) EH&S Delivery(s)

Legal Counsel Engineering Solutions Site Leadership

Maintenance Leadership




Table of Contents

Contractor Qualifications for Work On-SiteEH&S Pre-Qualification Process for U.S. Area IndependentContractors

Introduction Independent contractor firms seeking to work at DOW must meet specificrequirements, which include Environmental, Health, and Safety expectations. Theseexpectations include EH&S performance criteria and specific EH&S requirements.Contractor firms are pre-qualified and selected based on the ability to meet theEH&S expectations.

Purpose This document provides the process for EH&S pre-qualification and selection ofindependent contractor firms who seek to perform work at The Dow ChemicalCompany, Houston Area Operations.

Scope This document applies only to the contractor’s ability to meet Environmental,Health, and Safety criteria.

Pre-QualificationProcess

Procurement Services will initiate the process by requesting that the independentcontractor firm complete a standardized Pre-Qualification Form (PQF). The PQFwill provide information regarding the contractor’s ability to comply with applicableenvironmental, health, and safety performance criteria and requirements. PQF’s willbe posted at the Houston Area Safety Council web on Xnet.

After receiving the completed Pre-Qualification Form, Hold Harmless Agreement,and Insurance Certificate, Procurement Services forwards the completed PQF tolocation EH&S Delivery for review. The EH&S reviewer evaluates the PQF and thecontractor’s ability to comply with the health and safety performance criteria andrequirements.

Location EH&S determines the approval status for the contractor using the followingdesignations:

Approved

Conditionally approved

Approved by exception

Not approved

The EH&S evaluation results are communicated to Procurement Services.Should the contractor enter into an agreement involving a Houston AreaOperations site, communication will be made as to status and the applicableconditions associated with the approval status.





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Contractor Qualifications for Work On-Site, cont.

AcceptanceCriteria –ApprovedContractor

The health/safety performance criteria for independent contractor firms working atmultiple Dow sites in the U.S. are as follows:

One or less OSHA recordable injury/illness per year or an average OSHArecordable injury/illness rate of 2.0 or less for the last three calendar years.

An average Worker’s Compensation Experience Modification Rate (EMR) of.80 or less for the last three calendar years.

Meet the other Environmental, Health, and Safety requirements as outlined onthe PQF.

These criteria qualify a contractor firm to work at Dow sites in the U.S. Acontractor site-specific environmental, health, and safety plan is required duringthe pre-job activities associated with work at the site.

Failure to show satisfactory improvement in meeting site targets may result inreduction or elimination of work at the site. These situations will be managed ona case-by-case basis.

AcceptanceCriteria –ConditionallyApprovedContractor

Some contractor firms may not initially be able to meet the safety/health performancecriteria to qualify as an “approved contractor.” These contractor firms may beaccepted on a conditional basis for work based on the following performance criteria:

Two or less OSHA recordable injuries/illnesses per year or an average OSHArecordable injury/illness rate of greater than 2.0 but not to exceed 4.0 for thelast three calendar years.

An average Worker’s Compensation EMR of 1.0 or less for the last threecalendar years.

Meet the other Environmental, Health, and Safety requirements as outlined onthe PQF

The contractor firm must submit a written plan designed to improve injury/illnessperformance to the levels specified for an “approved contractor.” The action plan is toinclude specific actions, responsibilities, completion dates, and measurableimprovement goals. Failure to show satisfactory improvement may result in reductionor elimination of work. These situations will be managed on a case-by-case basis.

Note: The expectation is that all independent contractor firms will meet theinjury/ illness performance criteria for an “approved contractor.” Contractorfirms will be given a reasonable amount of time to achieve compliance with thesecriteria. Firms will not be able to remain “conditionally approved” for anindefinite period of time.





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LeveragedApproval

Leveraging approved contractors from other Gulf Coast Sites

The Houston Area Operations SMAT has approved the process of leveraging anapproved Gulf Coast contract company status to a Houston Area Operations siteaccess database, provided the following conditions are completed prior to site workby the respective contract company commencing:

i. Check Technical Qualification

ii. Complete Pre-Job Prior to Job

iii. Complete All About You

iv. Complete Site/Unit Specific Training

v. Safety Action Plan for first job

Note: This process includes conditional contractors, probationary contractors,insufficient OSHA/EMR from the contractor, a contractor that has changed itsname, etc.

DOW VarianceProcess (Waiverfor OSHAthreshold/EMRrate)

Companies that can not meet the criteria above (and no other qualifiedcontractor can be found) may be accepted for work on the site if the followingconditions are met:

The WAIVER OF OSHA THRESHOLD/EMR RATE must be completed.

An authorized person must escort contractor/supplier employees at all timesand they are responsible for his/her safety.

meet or exceed the expectations outlined on the Pre-Qualification formincluding:

a written Safety and Health Program

a written Substance Abuse Policy

a written Respiratory Protection Policy, when required

a written Hazard Communication Policy, when required

an English Comprehension Policy

Craft Skill Assessment, when required

and have a safety action plan in place to meet minimum expectations. (The companymust submit a Safety Action Plan that provides a detailed plan for addressing EH&Srequirements for work performed onsite.) The Safety Action Plan is developed inparticipation with business requesting the work.





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DOW ContractorEvaluation –MaintainingApproval Status

Generally independent contractor firms are pre-qualified on a one-time basis.Contractor firms are assessed periodically (see Contractor Evaluation) to review andupdate the approval status.

Individual company evaluation (One on One’s) – The Job Representative and/orPurchasing initiates the evaluation process by soliciting input on the contractor’sperformance. The Houston Area Operations sites have a Contractor PerformanceEvaluation form (see Contractor Evaluation) that is completed and reviewed by theusers, Job Rep, EH&S, purchasing, and contract company during the contractcompany’s periodic evaluation.

Houston Area Operations SMAT evaluates the contractor’s performance based on thecollective input from the user sites and determines if the approval status has changed.Changes in approval status will be communicated to user locations.

Probation Status If a contractor firm does not meet the performance criteria for the last calendar year,the firm will be put on probation with a specific timeline for improvement andreevaluation. The firm must submit a written improvement plan to include specificactions, responsibilities, completion dates, and measurable improvement goals.Failure to show satisfactory improvement constitutes a breach of contract and mayresult in termination of the contract.

Performance criteria includes:

If a contractor firm exceeds the following safety criteria:

For the last calendar year – an OSHA rate greater than 2.0 or an EMR ofgreater than 0.8

Then they must submit a Safety Action Plan to include specific actions, TheSafety Improvement Plan is developed in participation with the Houston AreaOperations SMAT.




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Waiver of the Contractor Qualification PolicyHouston Area Operations Sites (Deer Park, Lone Star, Bayport, HOU,

TCO)

Dow is committed to zero incidents and the 2015 goals. This form is to be used if the contractor does not meet HoustonArea Operations Contractor Qualification requirements, and there are no other contractors available who do meet therequirements. Provisions of the Contractor Qualifications for Work on Site Requirements as specified in the HoustonArea Operations Contractor Administration Manual are hereby waived for the period of the following specified job:

_____________________________________________________________________________________________________________________________________________________________________.

The site Approved Responsible Person must:1. Have a situation that constitutes a “true” need (Give details of the nature of the need in the attached Waiver

checklist.)2. Escort the contractor/vendor employee at all times.3. Take full responsibility for the safety of the contractor/vendor employee.4. Inform the contractor/vendor employee of the potential hazards of the area (HazCom/PSM Overview

requirements are fulfilled).5. Assure that the contractor/vendor employee are trained before being allowed to work behind the protection

of Red Tags, enter into a confined space, or receive a safe work permit.6. Ensure a Pre-Job Conference is completed or pre-existing pre-job is reviewed per job scope.

This authorization is good for this job only. Any subsequent job must be re-evaluated for a waiver.

I understand the responsibilities identified in this document and assume these responsibilities for the entry of thecontractor/vendor employee noted on this document.

Form Instructions:1. All Items in the table below are required. Authorization should be obtained prior to arrival at badging.2. Completed form must be submitted to Purchasing prior to initiating P.O.

Production Leader Authorizing SignatureProduction Leader Master NumberEH&S Delivery Leader Authorizing SignatureEH&S Delivery Leader Master number

Approved Escort Signature (Initial)Approved Escort Master number (Initial)

Contractor/vendor Employee (Please print)Contractor/vendor Employee SignatureCompany Name of Contractor/vendor employee

Contract Administrator

Contract Administration Master Number

Date and Time (Completed by Contract Administrator)

Technical Authorizing Signature

Technical Authorizing Master Number




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Contractor Waiver Checklist

Check

Why do we need to bring in a contractor that has not been approved and/or trained?

Are there approved/trained contractors available to do this job?

What is the current, year to date, OSHA rate for the contractor company?

The requirements for contractor pre-qualification are as follows:

A three year OSHA average rate of 0 to 2.0.Probationary guidelines include an OSHA three year average of 2.0 to 4.0. If you have acompany who's OSHA rate puts them into the probationary category or above it is highlyrecommended that special resources be made available to follow and track their workactivity on site. This should include 100% escort by a Dow representative (Dow EH&STech or third party Safety Professional or person qualified for work discipline).

Who are the contractor superintendent and foreman for the job and what is their work history (bothjob experience and safety history)? How do they compare to their overall company OSHA rate?

What is the block location of the job?

What are the specific hazards associated with the area where the job is to be completed?

Have these specific hazards been communicated to the contractor or contractor supervision?

Who will review the Dow Site Safety Rulebook with the contractors?

What specific hazards are associated with the craft involved?

Have the foremen, crew leaders, and safety personnel been trained by Dow Contractor EH&S in theuse and expectations of the Safety Task Analysis process?

This training is required for all contractor crewleaders, foreman, supervisors, superintendents,and safety contacts that work on the Dow Chemical Company Site.Training can be provided by Dow Contractor EH&S or by the Dow block EH&S contact.

Will the job to be completed require any contractor employees to work behind the protection of a"Red Danger tag"? If yes, contractor employees must complete the "Dow Chemical Company RedDanger tag" training before starting work. The “Red Tag” training included in the Dow Site Specificcomputer based training is “non-user” only.

Red Danger tag “user” training should be provided by the Contractor Safety Council. Ifweekends or off hours contact Dow Contractor EH&S.

Will the job to be completed require any contractor employees to work inside a Confined Space?

If yes, contractor employees must complete the "Dow Chemical Confined Space" training beforestarting work.

Red Danger tag “user” training should be provided by the Contractor Safety Council. Ifweekends or off hours contact Dow Contractor EH&S.





Table of Contents

Contractor Waiver Checklist, cont.

Check

Have the contractor workers been drug tested prior to coming on site?

If the contractors have not been pre-access drug tested or have not been subject to randomtesting with in the last 30 days their company should make provisions to have this done. Theycan contact a local safety council to have the testing done.It is HIGHLY RECOMMENDED that substance abuse testing be conducted before approving awaiver.

Has the company received a copy of the "Houston Area Operations Contactor's AdministrativeSafety Manual for Service, Maintenance, and Construction?

This document is located on the Safety Council web site. Copies are also available through DowContractor EH&S.

Has the contractor employee been issued a "training badge" by Dow or by one of the approvedContractor Safety Councils?

If yes, check the training badge for required training.

Does the company know the procedure for reporting incidents or accidents?

(If no, review reporting requirements for Injury/Illness and Incidents. A written preliminaryreport must be submitted to Dow Contractor EH&S by 10:00 the next working day (electronic tothe functional mailbox listed on the bottom of the form or fax to phone number listed . Refer theHouston Area Operations Contractor's Administrative Manual for forms and a reporting flowsheet.)

The use of the proper gloves are required for all "hand's on" work.

The glove use policy is available in the "Houston Area Operations Contactor's AdministrativeSafety Manual for Service, Maintenance, and Construction?

Will the contractor employees be unloading trucks?

(if yes, the "truck unloading policy" is available in the Contractor's Administrative SafetyManual must be reviewed.





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Check

Any contractor employee involved in an accident or incident must submit to a "post incident"substance abuse test.

There are many testing facilities in the area (appearance on the following list does not imply approval offacility by The Dow Chemical Co. or any subsidiary; it is the employer’s responsibility to chooseappropriate facilities for their employees). Some examples are:

Drug Screens Etc524 9th Ave N, Texas City, TX - (409) 948-2220

Mainland Testing Center9300 Emmett F Lowry Expy # 156, Texas City, TX - (409) 978-2440

Interactive Medical Connection700 Gemini St # 110, Houston, TX - (281) 486-4434

Bestcare Laboratory Services202 N Texas Ave, Webster, TX - (281) 332-0300

Forward Edge Drug Testing1209 Genoa Red Bluff Rd, Pasadena, TX - (713) 920-1335

Drug Screens Etc1806 Center St, Deer Park, TX - (281) 478-5108

ExperTox Laboratory Services1803 Center Street, Deer Park,, TX - (281) 476-4600

Quality Drug Screens125 Sylvan St, La Porte, TX - (281) 471-4660

Friendswood Diagnostics628 S Friendswood Dr, Friendswood, TX - (281) 648-2200

Drug Screens Etc1010 Pasadena Blvd, Pasadena, TX - (713) 473-0495

Turn A Round Inc102 W 2nd St, Deer Park, TX - (281) 476-9888

(Failure to comply will be grounds for removal from the site)





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Check

Has the company identified a local medical provider?

There are many industrial providers in the area (appearance on the following list does not implyapproval of facility by The Dow Chemical Co. or any subsidiary; it is the employer’s responsibility tochoose appropriate facilities for their employees). Some examples are:

Mainland Occupational Health Center6801 Emmett F Lowry Expy Texas City, TX 77591- (409) 938-5112

Interactive Medical Connections Inc700 Gemini St # 110, Houston, TX - (281) 486-4434

Occupational Medicine of La Porte410 E Fairmont Pkwy # A, La Porte, TX - (281) 842-1200

San Jacinto Methodist Hospital Occupational Health Service2610 N Alexander Dr, Baytown, TX - (281) 420-6200

Medical Plaza Mobile1309 W Fairmont Pkwy # S, La Porte, TX - (281) 470-8770

Concentra Medical Centers125 E 8th St, Deer Park, TX - (281) 930-8555

Medical Plaza Occupational Surveillance1309 W Fairmont Pkwy, La Porte, TX - (281) 470-1944

Alliance Health Resources Inc2504 Center St, Deer Park, TX - (281) 479-6672

AMD Occupational Medical Services1629 Center St, Deer Park, TX - (281) 917-6031





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Availableresources

Dow Contractor EH&S

Donna Coyle – TCOWork # 409-948-5965Weekends and after hours:Cell # 409-332-2021

Contractor Safety Council of Texas City – (409) 948-9009

Houston Area Safety Council - (281) 476-9900




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Contractor Substance Abuse Policy

Purpose To assure maximum safety and well being of all Dow employees, CONTRACTORS'employees, and all other people located in the plant and its vicinity.

Scope This applies to all contractor companies working at a Dow Chemical Co., HoustonArea Operations worksite.

Background The Dow Chemical Co., Houston Area Operations ("Dow") considers the misuse orabuse of alcohol and the use of illegal or unauthorized drugs to present a seriousthreat to the health and safety of any person working on its premises and thesurrounding community and to interfere with the efficiency and productivity of workbeing performed on its premises.

Definitions Hair Testing: Analysis of hair samples to detect the presence of tested drugs and/ortheir metabolite(s) at reportable levels. Testing will be performed by a laboratorywhose screening methods are cleared by the U.S. Food and Drug Administration(FDA) for both head and body hair types.

Qualified Third Party Collection: Companies contracted by the contractor firm forthe purpose of collection of drug and alcohol testing samples. The contractedcompany must be certified and those individuals that collect samples must betrained and qualified. As it applies to “hair testing”, the process used must beapproved, cleared, or otherwise recognized by the Food and Drug Administrationas accurate and reliable for the testing of such specimens. In addition this mustinclude all panels and all hair types and must assure the test excludescontamination.

Policy A. The use, bringing onto Dow premises (which includes all property owned,operated, or leased by Dow, or under the control of Dow), possession,concealment, transportation, promotion, or sale of the following substances anditems by any contractor, subcontractor, vendor, and their employees(collectively, "CONTRACTORS" and individually, "CONTRACTOR") isstrictly prohibited from Dow premises:

ILLEGAL DRUGS; UNAUTHORIZED CONTROLLED SUBSTANCESLOOK-ALIKES; DESIGNER AND SYNTHETIC DRUGS (INCLUDINGTHE PRESENCE OF ANY DETECTABLE AMOUNT IN THE EMPLOYEEWHILE WORKING); ANY OTHER ILLEGAL OR UNAUTHORIZEDDRUGS OR ABNORMAL SUBSTANCES WHICH MAY AFFECT ANEMPLOYEE'S SENSES, MOTOR FUNCTIONS, OR ALTER A PERSON'SPERCEPTION WHILE WORKING; ALCOHOLIC BEVERAGE; ANDDRUG PARAPHERNALIA.





Contractor Substance Abuse Policy continued

Policy cont’d B. CONTRACTORS who regularly perform labor or services on Dow premisesmust have and administer a formal substance abuse interdiction policy. Suchpolicy must include provision for tests (such as drug test by hair, urine

drug screens or blood, plasma tests, and alcohol test using the “swab test”method for alcohol testing with the use of a breathalyzer test for confirmationof positive alcohol tests) to determine the use of any illegal or unauthorizedsubstances prohibited by this Policy. Non compliance to the testing requirementsof this policy will result in the removal of the individual involved from the site fora minimum of 12 months. These tests shall be administered under the followingconditions:

1. Pre-employment and pre-access drug and alcohol testing of current employeesreturning to Dow premises from layoff or outside job assignment shall beaccomplished by the use of hair testing for drugs and swab and/or breathalyzertesting for alcohol, with the following exceptions:

a. Contractor employees that are currently employed by the contractorfirm and have been subject to random testing for that company withinthe last 90 days are exempt from the pre-access testing requirements.

b. Contractor employees new to a contractor firm which is participatingand in compliance with the Texas City Operations “ContractorSubstance Abuse Policy” and who are designated as “Approved forWork” for the Texas City Operations Texas City Site in the VECTORTM

database maintained by Psychemedics are exempt from the pre-accesstesting requirements.

Individual contractors that work under D.O.T. requirements must follow D.O.T.guidelines for drug testing.

2. For cause drug and alcohol testing. When CONTRACTOR's supervisor has areasonable suspicion or belief that CONTRACTOR's employee shows signs ofbeing under the influence of, or in possession of, any substance or itemprohibited by this Policy. For the purposes of this Policy, reasonable suspicionor belief can include occupational on-the-job injury or involvement in a seriousor potentially serious accident or incident. For cause drug testing shall beaccomplished using urinalysis and for cause alcohol testing will beaccomplished using the swab testing method with breathalyzer testing forconfirmation of positive tests.

During each 12-month period CONTRACTOR will randomly select for drug testing asufficient number of the employees assigned to Dow operations/facilities so that thenumber of tests conducted will equal at least 50 percent of the individual employeeswho are badged for the Dow Texas City Site. Such testing shall be conductedmonthly. (In the case of short duration jobs the contractor may be requested toconduct random tests on a weekly basis.) It is our intent that all contractorsworking at the site be subject to random testing hair. The method of testing requiredto accomplish these tests will be hair testing for drugs and swab testing for alcoholwith a breathalyzer conformation required for any positive alcohol swab test.Individual contractors that work under D.O.T. requirements must follow D.O.T.guidelines for drug testing.





Contractor Substance Abuse Policy continued

Cutoff Level in Nanograms

Drug Class Initial ConfirmationCannabinoids (marijuana) 50 15

Cocaine 300 150Opiates 2000 2000

Amphetamines 1000 500Phencyclidine (PCP) 25 25

Alcohol testing: Alcohol tests will be considered positive if the blood alcohol level of an individual is ator above .02.

GeneralRequirements:

Pre-employment and random drug testing must be completed using the hairtesting method. Individual contractors that work under D.O.T.requirements must follow D.O.T. guidelines for drug testing.

Hair testing must be accomplished using third party collection andmust be conducted through use of the Psychemedics lab.

For cause and post accident testing will be completed using urinalysis Chain of custody of the individual requiring a drug/alcohol test must be

accomplished by using a member of the contractor company’s supervisionto escort the individual to the test site.

All testing and collection of test specimens must be administered by aqualified third party.(no in-house testing will be accepted)

Post accident and for cause testing the tests must be completed as soon aspossible.

Failure to comply with the stated drug program will result in the individualbeing removed from the facility for 12 months.

Training Initial training and annual review

Other Documents Not Applicable

Review This policy will be reviewed annually by the Houston Area Operations SMAT.

B. Substance Testing

Each specimen will be tested for at least the following drugs and will bereported positive when the number of nanograms per milliliter equal or exceed theindicated cutoff level:




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English Comprehension Policy

Purpose To assist in maintaining a safe and efficient work place by assuring written andspoken comprehension of the English language.

Scope This applies to all personnel working at the Houston Area Operations sites.

Background All safety signs and verbal warnings are presented in English. Because of thisstandard process English comprehension is required.

Policy Any contractor, subcontractor, vendor, and their employees (collectively,"CONTRACTORS" and individually, "CONTRACTOR") performing labor orservice on Houston Area Operations sites’ premises, which includes all propertyowned, operated, or leased by or under the control of Dow's Texas City, LaPorte,Deer Park, Lone Star and Bayport ("Premises") shall be able to comprehend English.English comprehension is defined as the ability to read and understand, hear andunderstand, speak and be understood and writes his/her name in English.

Exceptions In certain limited instances (e.g., a consultant on a specific project), aCONTRACTOR's employee not meeting the requirements of this Policy mayperform labor or service on Dow Premises if they are escorted 100% of the time by aCONTRACTOR-provided interpreter. Such exception must have prior approval by aDow Job Representative. The interpreter shall devote special emphasis to safeprocedures, emergency procedures, scope, understanding, and communicationconcerning the safe performance of work.




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Contractor Safety Responsibilities

Purpose To detail the Contractor Companies’ responsibilities as they apply to Environmental,Health, and Safety concerns while working on the Houston Area Operationsworksites.

Scope This applies to all contractor companies working on the Houston Area Operationsworksites.

Background In the past there has been some confusion in the contractor community as to theexpectations and responsibilities of contractor firms working on a Dow ChemicalCompany Site.

Responsibilities

Item Description

1 The Contractor shall actively and adequately promote safe working performance onthe part of its employees. The Contractor shall participate in activities to this end,such as contractor safety organizations (e.g., Monthly Houston Area OperationsContractor Meeting, Contractors' Safety Council.), contractor owner programs, etc. Itis expected that each Contractor will conduct its own safety programs to best suit itsparticular needs.

2 Contractors MUST report immediately those employees (by name) DISCHARGEDfor safety rule infractions in writing to Dow Industrial Security and the Owner'sRepresentative. The reason for the discharge must be given. Such employees will notbe allowed to return to any Owner's work without proper authorization from theOwner.

3 Prior to starting any field work on each job, the Job Representative will conduct apre-job safety conference with an authorized representative of the Contractor, anowner Manufacturing Representative, available subcontractor’s representatives andOwner’s safety representative, when available.

At this time, the nature of any chemical hazards or special safety rules for the area willbe reviewed with the owner Process Representative and the Contractor will beprovided with printed copies of the area rules where applicable.

The “Pre-Job Safety Checklist” form (See in Appendix) will be prepared by theOwner’s Representative and a copy furnished to the Contractor.

4 In addition to the basic contractor safety indoctrination, contractor employees shallreceive block or unit safety pre-job orientations covering the hazards for that areaprior to starting work.





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Contractor Safety Responsibilities, cont.

Responsibilities(continued)

Item Description

5 Contractors must be aware of the following policies:

English comprehension requirements – (See English ComprehensionPolicy)

Contractor’s Substance Abuse Policy – (See Substance Abuse Policy)

6 Contractors shall use a regular system of work site inspection to detect and correcthazardous conditions, safety rule violations and unsafe work practices. These safetyinspections shall be reported to the Job Representative.

Contractors shall maintain continuous safety planning to cover jobs wherecircumstances have changed and new hazards require new controls.

7 Every Contract Company will direct its employees to actively participate in a BehaviorBased Safety Process. This will include, as a minimum, every individual using Pre-Task Analysis), Leadership Observations, and everyone working together to analyzeand correct unsafe behaviors.

8 It is the Contractor’s responsibility to make sure that all injured/ill personnel receiveprompt medical attention at an approved medical facility.

Written notification must be submitted on every injury or serious incident to the JobRepresentative and Contractor Safety no later than 10:00 a.m. of the next working day.See “Contractor Investigations”

It is the Contractor’s responsibility to investigate all injuries and incidents, includingvehicle accidents, and submit a final report to the Job Representative and ContractorEH&S.

9 Prior to ordering vacuum trucks, Contractor shall coordinate with the JobRepresentative and Environmental Operations.

Contractors shall inform the Job Representative of any hazardous material they maybring into the work area. The contractor must have the MSDS's readily accessible.

Contractor must receive approval from the Job Representative to bring into job siteany materials or suppliers not required or specified by the contract.





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MinimumRequirements

The items listed below are the minimum requirements for Contractor and SupplierSafety Training.

Item Description

1 Before working on Dow property EVERY contractor employee must be indoctrinatedwith the Dow Safety Rules through an approved safety indoctrination program.Contractors shall inform all their employees that they must comply with the SafetyRules, procedures, and rules of the department in which they are working and siteSafety Standards.

2 Contractors who perform work on Dow controlled property must receive basiccontractor safety indoctrination prior to starting work. It is required that allContractors use the orientation program administered by the Contractors' SafetyCouncil.

The contractor is responsible for scheduling this training at the SafetyCouncil,

A record of this training shall be maintained

Any contractor employee who has not worked on Dow controlled property for12 months must attend refresher training at the Safety Council.

Portable Buildings

Stage Description

1 Portable buildings and storage areas shall be set up as neatly as possible to present anorderly appearance and maintained in good repair.

2 During the months June 1 through November 30 (Hurricane Season)

Contractors shall tie down or remove all their portable buildings and portable toiletsfrom Dow property.

3 Metal buildings served with electricity shall have the service entrance switch and theskin of the building grounded in such a manner that neither is dependent upon theother. Electrical bonding jumper wires at corners and roof are required ONLY ifbuilding construction does not provide for complete grounding continuity.

4 Electrical outlets and grounds are to be tested in accordance with OSHA 1926.404.





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Fire Protection

Item Description

1 Fire Extinguishers:

a. A fire extinguisher for welding and cutting operations can be obtainedthrough the Job Representative.

b. It is also the Contractor's responsibility to arrange, through the JobRepresentative, for the recharging and resealing of owner furnishedextinguishers immediately after each use.

2 It is the Contractor's responsibility to obtain approval through the Job Representativeon the proper location of all fuel storage tanks. In all cases the tanks shall be locatedor the area diked or sloped so that a spill shall not create a hazard to operating plantsor contaminate ditches or navigable water.

Demolition

Item Description

1 Due to the inherent hazards in demolition work, special care must be devoted to safeprocedures, scope understanding and communications concerning the safeperformance of work.

2 Responsibility for field supervision of demolition work must be delegated only tothose whose experience qualifies them to make the necessary judgments and decisionsthat are required to assure the safest possible completion of the job.

3 The Contractor shall make certain that all lines, services and equipment have beencleaned or purged and properly cleared for safe removal. All lines (including waterand steam) are to be considered "hot" until positive safe clearance has been obtained.

4 Special care shall be exercised to locate and mark old underground or otherwisehidden lines, cables and sewers using the best available information and Owner'sassistance.





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Demolition(continued)

Item Description

5 The pre-job safety conference with the Contractor shall devote special attention topre-planning the safety aspects of demolition jobs.

Steps of dismantling and loads to be handled shall be reviewed with theJob Representative prior to starting work.

Temporary provisions shall be made where safety showers, eye-wash bathsand fire extinguishers are being moved in the work area.

Special attention shall be given to the marking of hazards and thebarricading of hazardous areas for the protection of all personnel,including those not directly involved in the demolition work.

Medical andIndustrial HygieneRequirements

Item Description

1 Health and hygiene training - The Contractor shall be responsible for providingtraining which includes, but is not limited to the following:

General training requirements under the Hazard Communication Standard29 CFR 1910.1200 (e.g. overview of the standard and how to read anMSDS).

Asbestos training required by OSHA 29 CFR 1910.1001 or OSHA 29 CFR1926.1101.

Respirator training required by OSHA 29 CFR 1910.134 (RespiratoryProtection).

Hearing conservation training and audiometric testing required by OSHA29 CFR 1910.95 (Occupational Noise Exposure).

Hazardous waste operations and emergency response training by OSHA 29CFR 1910.120 or OSHA 29CFR 1926.65.





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Medical andIndustrial HygieneRequirements(continued)

Item Description

2 Respirator training fit testing and medical approval.

Routine or emergency response respirators

The Contractor is responsible for the required fit testing, training andmedical approval for all employees who use the following types ofrespirators:

air purifying half and full face masks,

SCBA and airline systems.

Documentation must be retained and Contractor records are subject toaudit.

Initial fit testing and training is required.

Retraining is required annually and fit testing is required

Medical certification is required initially and every year there after.

3 Contract Companies are responsible for any required Industrial Hygiene monitoring(lead, asbestos, noise, etc.). Records must be made available to Dow Job Rep uponrequest for auditing purposes.




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Minimum Requirementsfor Contractor Safety and Health Programs

Introduction The required program elements for contractors working on DOW property.

Purpose To improve DOW Site contractor safety and health performance.

Guidance This program must include elements that are specific to the work performed. Forexample, a contractor engaged in scaffold building should have a program thataddresses fall protection and the specifics that are associated with the protection.(For example, stating that fall protection must be worn when working 6 feet or moveabove ground elevation is not considered sufficient detail from the DOW perspective).





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Minimum Requirementsfor Contractor Safety and Health Programs, cont.

ManagementSystems –Required

Required:

1. Have in place a formal, written safety and health program which includes:

a policy statement with elements for employee participation, management commitment and supervisory accountability, enforcement procedures, management of change process, and emergency plans written safety goals and objectives.

2. Be accountable for all employees on the DOW site.

3. Allow DOW personnel access to appropriate safety and training records.

4. Establish a focal point responsible for safety matters for the duration of thecontractor’s work at DOW.

5. Contractors must have:

a drug/substance abuse program in place, a employee background screening process in place, and an English Comprehension program,

which is consistent with DOW requirements.

6. Ensure a medical surveillance program is in place as appropriate and incompliance with all applicable standards and these programs appropriatelyconsider fit for duty considerations.

7. Ensure a process is in place for dealing with emergency medical treatment andfirst aid cases which includes identification of local medical provider. Have a casemanagement process and trained personnel to implement.

8. Ensure availability of Material Safety Data Sheets (MSDS) for all materialsbrought onto the DOW site and that all materials are approved by the site.

9. Sub-Contractors must:

Have a method to approve sub-contractors. Obtain and evaluate information concerning any subcontractor’s safety

performance and programs prior to award of contract. (Sub-contractors arealso required to be pre-qualified by DOW for work on DOW sites – contactour purchasing group to initiate the prequalification process.)

Accept responsibility for the safety performance and ensure subcontractors fitfor duty requirements are adequate.

10.Provide appropriately trained and competent personnel and ensure a process forselecting qualified employees.





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ManagementSystems –Optional

Optional for Continuous Improvement:

1. Have a dedicated site or project safety person.

2. Have a safety and health recognition program.

OpportunityIdentification –Required

Required:

1. Implement a program for the reporting of unsafe conditions/situations/ practices.

2. Follow up on unsafe conditions/situations/practices identified.

3. Perform pre-job task evaluation for safety/hazard analysis, utilizing the STACcard or equal. The pre-job task analysis hazards must be applicable to the workthat is performed by the contractor.

OpportunityIdentification –Optional


1. Make recommendations to appropriate DOW personnel for changes to DOWsafety policies and procedures that affect contractors.

2. Seek customer feedback for work performed, i.e. quality timeliness, budgetconsiderations.

PersonalInvolvement –Required

Required:

1. Require employee intervention on unsafe conditions/situations/practices and makeemployees accountable for their safe work performance.

2. Ensure participation in department and/or site emergency drills.

3. Ensure individual compliance with contractor safety and health programs throughperformance reviews, disciplinary systems, recognition programs, audits, etc.

4. Hold supervision accountable for the safety performance of their employees.

5. Establish a behavior observation program.

6. Use a safety suggestion system.

PersonalInvolvement –Optional


Involve all levels of personnel in audit activities.





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Training –Required

Required:

1. Implement employee orientation and EH&S training programs that include alllegally required elements; for example hazard identification and control, reportingof accidents and incidents, safe work practices, Personal Protective Equipment andHazard Communication (HAZCOM).

2. Ensure appropriate EH&S and craft training is conducted and verification ofunderstanding is completed as appropriate (classroom, field, etc.).

3. Ensure all training is documented.

4. Ensure documentation of craft and technical training for work that requirescertification (ex. Asbestos removal), work with or near government regulatedchemicals or materials, or work when acting as an agent of The Dow ChemicalCompany.

5. Include safety management training for all 1st line supervisors.

Communication –Required

Required:

1. Conduct regularly scheduled/formal safety meetings. At a minimum, weeklysafety meetings should be held.

2. Report all occupational injuries and illnesses, as well as incidents and near misses,to the DOW Contract Administrator or Job Representative as soon as possibleafter their occurrence.

3. Immediately communicate to DOW personnel any hazards found while on thework site as well as any hazards that the contractor’s work may introduce into thework site.

4. Participate in pre-job safety conferences. Communicate details of these toemployees.

5. Ensure all employees are able to appropriately understand and communicate safetyand health information including, but not limited to, the applicable portions of theemergency plan, fire, explosion and toxic release hazards.

6. Provide DOW personnel with requested information on its periodic evaluations.

Communication –Optional


1. Share learning experiences with DOW personnel and other contractors.

2. Conduct toolbox or tailgate safety meetings.

3. Keeps written safety meeting minutes.





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Standards andOperatingDiscipline –Required

Required:

1. Ensure project pre-planning includes analysis of safety and health hazards.

2. Comply with all governmental, DOW standards, policies, and any othercontractual agreements.

3. Be licensed for work in the area in which the site resides.

4. Ensure housekeeping is maintained to avoid creation of hazards.

5. Ensure employees appropriately use Personal Protective Equipment as requiredby the job and consistent with the site policy.

6. Have written safe work procedures in place.

7. Have written company specific safety rules and standards.

Audits – Required Required:

1. Conduct safety audits and housekeeping inspections of the worksite or area that isused by the contractor.

2. Conduct periodic audits to ensure compliance with the elements of the safety andhealth program.

3. Ensure all audits are appropriately documented.

4. Ensure follow-up for all deficiencies identified by the audits.

5. Ensure supervision conducts frequent workplace inspections (walkthroughs).

6. Conduct safety performance review of subcontractors during the course of theirwork on the site.

Audits – Optional Optional for Continuous Improvement:

Participate in team audits of other contractors on various DOW work sites.

Root CauseInvestigation –Required

Required:

1. Investigate all reportable accidents/incidents as defined by DOW site standards todetermine the root cause.

2. Document all investigations consistent with site requirements.

3. Communicate all accidents/incidents and near misses to company employees andDOW personnel.

4. Ensure a corrective action follow-up system is in place to implementrecommendations associated with the incident.





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PerformanceMeasurement –Required

Required:

Have a measurement system in place to track performance toward defined safetygoals and objectives.

PerformanceMeasurement –Optional


Develop and use proactive safety measures.

Public Interaction– Optional


1. Participate in contractor associations.

2. Participate in trade organizations.




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Contractor Program Checklist

Contractor:

ContractorAddress

ContractorService

Point ofContact

Phone

Initial

Review DatePerformed by:

Next

Review DuePerformed by:

Guidance This program must include elements that are specific to the work performed. For example, acontractor engaged in scaffold building should have a program that addresses fall protection andthe specifics that are associated with the protection. (For example, stating that fall protectionmust be worn when working 6 feet or move above ground elevation is not considered sufficientdetail from the DOW perspective).

ManagementSystems

Required:1. Have a formal, written safety and health program in place including a policy statement with

elements for employee participation, management commitment and supervisory accountabilityas well as enforcement procedures and emergency plans.

EMR RIF (Recordable Injury Frequency)

Substance Abuse PSM (Process Safety Management)

Ground Fault Hearing Conservation

Respiratory Protection HAZ COM (MSDS sheets available)

Pre-Task Analysis Craft/Skill Training

Personnel Accounting Sub-Contractors

Medical Surveillance Case Management

Fit for Duty Review? Y N English Comprehension

Safety Program Safety Goals & Objectives? Y N

MOC Background Screening

Elements

Medical Provider Safety Focal Point Y N Name:________________

Remarks





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Contractor Program Checklist, cont.

Optional forContinuousImprovement

1 Have a dedicated site or project safety person.

2. Have a safety and health recognition program

Y N

Y N

Required:

1. Implement a program for the reporting of unsafe conditions/situations/practices.

Y N

2. Follow-up on unsafe conditions/situations/practices identified. Y N

OpportunityIdentification

3. Perform pre-job task evaluation for safety/hazard analysis, utilizing theSTAC card or equal. The pre-job task analysis hazards must beapplicable to the work that is performed by the contractor.

Y N


1. Make recommendations to appropriate DOW personnel for changes toDOW safety policies and procedures that affect contractors.

2. Seek customer feedback for work performed, i.e. quality timeliness,budget considerations.

Y N

Y N

Required:

1. Require employee intervention on unsafe conditions/situations/practicesand make employees accountable for their safe work performance.

Y N

2. Ensure participation in department and/or site emergency drills. Y N

3. Ensure individual compliance with contractor safety and healthprograms through performance reviews, disciplinary systems,recognition programs, audits, etc.

Y N

PersonalInvolvement

4. Hold supervision accountable for the safety performance of theiremployees.

Y N

5. Use a safety suggestion system. Y N

6. Establish a behavior observation program. Y N

Remarks


1. Involve all levels of personnel in audit activities. Y N





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Required:

1. Implement employee orientation and safety/health training programsthat include all legally required elements; for example hazardidentification and control, reporting of accidents and incidents, safework practices, Personal Protective Equipment and HazardCommunication (HAZCOM, WHMIS, etc.).

Y N

2. Ensure appropriate safety and craft training is conducted andverification of understanding is done as appropriate (classroom, field,etc.).

Y N

Training

3. Ensure all training is documented Y N

4. Ensure documentation of craft and technical training for work thatrequires certification (ex. Asbestos removal), work with or neargovernment regulated chemicals or materials, or work when acting asan agent of The Dow Chemical Company.

Y N

5. Include safety management training for all 1st line supervisors. Y N

Remarks

Required:

1. Conduct regularly scheduled/formal safety meetings. At aminimum, weekly safety meetings should be held.

Y N

2. Report all occupational injuries and illnesses, as well as incidentsand near misses, to the DOW Contract Administrator or JobRepresentative as soon as possible after their occurrence.

Y N

3. Immediately communicate to DOW personnel any hazards foundwhile on the work site as well as any hazards, which thecontractor’s work may introduce into the work site.

Y N

4. Participate in pre-job safety conferences. Communicate details ofthese to employees.

Y N

5. Ensure all employees are able to appropriately understand andcommunicate safety and health information including, but notlimited to, the applicable portions of the emergency plan, fire,explosion and toxic release hazards.

Y N

Communication

6. Provide DOW personnel with requested information on itsperiodic evaluations.

Y N





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Remarks

1. Share learning experiences with DOW and other contractors. Y N

2. Conduct toolbox or tailgate safety meetings. Y N

Optional forContinuousImprovement:

3. Keeps written safety meeting minutes. Y N

Required:

1. Ensure project pre-planning includes analysis of safety and healthhazards.

Y N

2. Comply with all governmental and DOW standards and policies aswell as any other contractual agreements.

Y N

3. Be licensed for work in the area in which the site resides. Y N

4. Ensure housekeeping is maintained to avoid creation of hazards. Y N

Standards andOperatingDiscipline

5. Ensure employees appropriately use Personal Protective Equipmentas required by the job and consistent with the site policy.

Y N

6. Have written safe work procedures in place. Y N

7. Have written company specific safety rules and standards. Y N

Remarks

Required:

1. Conduct safety audits and housekeeping inspections of the worksiteor area that is used by the contractor.

Y N

6. Conduct periodic audits to ensure compliance with the elements ofthe safety and health program.

Y N

3. Ensure all audits are appropriately documented. Y N

4. Ensure follow-up of all deficiencies identified by the audits. Y N

Audits

5. Ensure supervision conducts frequent workplace inspections(walkthroughs).

Y N





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6. Conduct safety performance review of subcontractors during thecourse of their work on the site.

Y N

Remarks

Optional forContinuousImprovement:

1. Participate in team audits of other contractors on various DOWworksites.

Y N

Required:

1. Investigate all reportable accidents/incidents as defined by theDOW site standards to determine the root cause.

Y N

2. Document all investigations consistent with site requirements. Y N

Root CauseInvestigation

3. Communicate all accidents/incidents and near misses to DOWpersonnel.

Y N

4. Ensure a corrective action follow-up system is in place toimplement recommendations associated with the incident.

Y N

Remarks

Required:PerformanceMeasurement

1. Have a measurement system in place to track performance towarddefined safety goals and objectives.

Y N

Remarks

Optional for Continuous Improvement:Optional forContinuousImprovement: 1. Develop and use proactive safety measures. Y N

PublicInteraction


1. Participate in contractor associations Y N

2. Participate in trade organizations Y N

Remarks




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HOUSTON AREA OPERATIONSWAIVER OF OSHA THRESHOLD/EMR RATE

Dow is committed to zero incidents and the 2005 goals. This form is to be used if the contractor does not meet theDOW OSHA threshold rate of 2.0 or EMR rate of .8 or less, and there are no other contractors available who meet therequirements.

The Production/Functional Leader authorizes the contractor to perform work, with the following conditions: The WAIVER OF OSHA THRESHOLD/EMR RATE must be completed. An authorized person must escort contractor/supplier employees at all times and they are responsible for

his/her safety. The contractor/supplier must meet or exceed the expectations outlined on the Dow Pre-Qualification form

including: a written Safety and Health Program a written Substance Abuse Policy a written Respiratory Protection Policy, when required a written Hazard Communication Policy, when required an English Comprehension Policy Craft Skill Assessment, when required

A safety action plan is in place in order to safety execute work that meets the site’s safety goals. (Thecontract company must submit a Safety Action Plan that provides a detailed plan for addressing EH&Srequirements for work performed onsite.) The Safety Action Plan is developed in participation with thebusiness requesting the work.

This authorization is good for this job only. Any subsequent job must be re-evaluated for a waiver,if the contractor’s OSHA/EMR rate remains above the threshold.

Form Instructions:1. All Items in the table below are required. Concurrence should be obtained prior to arrival at badging.2. Completed form must be submitted to Purchasing prior to initiating P.O.

Contractor/vendor Employee (Please print)

Contractor/vendor Employee Signature

Company Name of Contractor/vendor employee

Production/Functional Leader Approval Signature

Production/Functional Leader Master Number

EH&S Delivery Leader concurrence

EH&S Delivery Leader Master number

Site Approved Escort Signature (Initial)

Site Approved Escort Master number (Initial)




PO Number (Completed by Contract Administrator)




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SAFETY ACTION PLAN

Start Date Completion Date

Safety Action Plan

Job/Project Name Job/Project Location

Job/Project Information

Double Click on embedded object to open.

Or

Right Click on object, select Worksheet Object then open, and this spreadsheet will open in Excel(save as “Your Company Name, etc.” to copy and edit).

Note: The contract company and the business requesting the work will complete their respectivesections. The completed document must be signed by each contract employee, prior to beginningwork, signifying understanding and agreement of all contents.




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Site Access for Contractors, Delivery, and Visitors

Purpose This guideline is only for gate entry requirements. It does not change anyrequirements for individual unit/plant orientations required nor does it change therequirement to follow the process to add a Contractor Company and Labor ServicesAcceptable Manufacturer and Supplier List (AMSL) Management of Change(MOC) process.

Ownership Ownership of these guidelines is coordinated with Contract Administration, Security,Purchasing, and the EH&S Delivery Organization.

MinimumRequirements

Minimum requirements by classification (Definitions is on the following page).

Details for Houston Area Operations site entry requirements based on scopeof work are included in the Houston Area Operations Site Access Matrix;found on US Area Site Access under Site Specific Requirements:

Foreign Nationals requesting plant entry must meet Guidelines required bythe Export Import Regulatory Affairs. For more information see ForeignNational Visitor Web Site.

Former Dow/ employees must also be assessed (see US Area Site Accessrequirements).

Classification Description

Contingent Staff An individual provided to DOW by a resource supply company (contingent staffingfirm) to supplement the DOW work force. Broad categories include officeprofessionals, technical/professional, distribution technicians, and engineering/design.

DOW assigned daily tasks, inclusion in the DOW Facility / Work Group EH&Straining and programs, and flexibility in needed work hours, characterize this service.

All contingent staff shall be assigned to a DOW Employee in terms of reportingpurposes. Contingent staff will receive initial orientation and then be included inEH&S Training and programs while working at the DOW Site. Contingent Staffpersonnel are issued Non-Dow Services ID Access Badge for the duration of work atthe facility.





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Site Access for Contractors, Delivery, and Visitors, cont.

MinimumRequirements(continued)


Delivery A company or individual that has a contract or purchase order withDow, delivering supplies/materials or distribution service, movingon and off Dow sites as a routine part of daily activities. Broadcategories include vendor stocking, vending machinereplenishment, mail service, equipment delivery/service, fuel orraw material delivery, product pick up and removal from the site,and distribution of DOW product off the site.

Non-DOW supervision, independent organization, and movementrestricted to road ways, storage, construction and office areascharacterize this service.

Pre-qualification is not required for Delivery Services. Pre-jobactivities will include a pre-job meeting that establish and reinforceEH&S performance expectations will be conducted.

Delivery Service personnel may be required to obtain SafetyCouncil training or be given the Visitor/Vendor Orientation Card(describing the facility, critical behaviors to follow, and EH&Sexpectations while on the site) as required by the Site AccessMatrix. The host, where applicable in conjunction with thecontract administrator, is responsible for determining if the EH&Srequirements are being met on a daily basis.

IndependentContractors

In addition to prequalification, their company must have a signed Dow HoldHarmless on file. (Sub-contractors are covered by the general contractor’s HoldHarmless Agreement.) The contract company employee(s) must have a ContractorSafety Council Training Card and signed contractor hire sheet. The contractorcompletes the pre-job activities including a pre-job meeting with the contractadministrator and EH&S contact that establish and reinforce EH&S performanceexpectations.

Lab/OfficeEquipment Service

The contract company employee(s) must have a Contractor Safety Council TrainingCard and their company must have a signed Dow Hold Harmless on file. Review theDOW Site Access Matrix for other requirements.





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MinimumRequirements(continued)


Visitors Visitors must sign in through Security and be escorted at all times by an authorizedperson. DOW Visitor/Vendor Policy requires a pass to be completed by an authorizedperson prior to admittance. The host will review the Visitor/Vendor Orientation(describing the facility, critical behaviors to follow, and EH&S expectations while onthe site) with the Visitor.

Issues with special cases should be coordinated through ES&S.

Visitors toBuildings withPublic Access

To receive a temporary pass sign in with the building receptionist and be escorted atall times by an authorized person. Entrance would be for that building only.Entrance into the plant would require following the Visitor process listed above.

CompanyApproval forWorking on Site

Pre-Qualification form completed and approved by EH&S delivery

Substance Abuse Program completed and approved by EH&S delivery

Contractor program review completed and approved by EH&S delivery

Technical requirements reviewed and approved by Discipline Specialist(Maintenance Technical Services or Dow Design and Construction).

Hold Harmless agreement signed and approved by Purchasing

Insurance requirements have been met and approved

MOC completed for addition to Gate Access Database

Valid P.O.

Pre-Job activities completed.

Variance Process The Process Leader, or their “Designated Back-up”, responsible for the area where theactivity is taking place, must approve variances from the requirements of OSHA/EMRrate, for a Contractor Safety Card and/or Hold Harmless as it applies to gate entry.The Delivery Leader must concur with the variance, and sign off on the form.OSHA/EMR Threshold Waiver, Contractor Safety Card Waiver, Hold HarmlessWaiver





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Pre-JobRequirements

The purpose of this process is to ensure contractors working at DOW are appropriatelyindoctrinated into site requirements.

Pre-Job Meeting - The purpose is to ensure that all EH&S requirements andexpectations are communicated to and understood by each contractor company prior towork start up and review specific details relative to contractor safety after the contractorhas been selected and is within a week or two of beginning work.

DOWExpectations forContractCompanies - “It’sAll About You”

All Contract Employees are required to attend the “It’s all about You. The “It’s allabout You” process establishes basic expectations for all personnel working at Dow.Once the orientation is complete contractors will be required to sign a documentindicating they have completed and understood the material.

MinimumRequirements forIssuing an EntryBadge

Badging Requirements include all of the following

Basic + or Basic + Refresher

Gulf Coast Dow Specific Training

Hire Slip with Background Screening and Proof of Substance Abuse Testingcomplete

Possession of a Contractor Training Card indicating those dates that specifictraining topics have been completed.

Details of the Badging process are listed in the Contractor/Sub-Contractor Badging

Signing-In &Signing-Out

All Independent contractors, Delivery Service, and Visitors are required to sign-in to thefacility at the appropriate location and sign-out upon departure.

Requirements forDriving Access

All requirements for the Entry Badge must be met plus the individual must possess aValid Driver’s License for the type of vehicle driven and for Texas City and LaPorte,the Driver Module CBT (computer based training) training from the Safety Council.(Deer Park, Lone Star, & Bayport will implement Safe Driver training at a later date.)





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Definitions

Term Definition

Visitors An individual at DOW other than the DOW personnel and Non-Dow Services Providerswho normally work at DOW.

Characteristics of a visitor include:

1. The individual is escorted full time by an authorized person (DOW or a Non-Dow Service Provider).

2. Does not perform physical work, and is treated as a “one time” guest,characterizes this activity.

3. Broad categories include Dow personnel from other sites, family members, tourparticipants, sales persons, agency inspectors, and consultants.

They are not allowed in process areas without following the appropriate Badgingprocess.

IndependentContractors

A company or individual that is under contract, sub-contract, or purchase order toprovide services on Dow sites. Broad categories include maintenance, operations andconstruction.

Non- DOW supervision, with an independent organizational relationship.

Sub Contractors They are employed and paid by the Direct Contractor, and could perform work in aprocess area.

Lab/Office/Equipment Service

Service on equipment in office areas, laboratories, or in process areas.

Authorized Person DOW employee or a Contractor who has delegated authority to act in this capacity onbehalf of DOW. In either case the Authorized Person should be knowledgeable enoughto oversee the safety of the visitor they are escorting. Responsibilities include at aminimum:

Knowledge of emergency response requirements

Job scope knowledge

Knowledge of all applicable site rules





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Definitions(continued)

Term Definition

Prequalification Technical, commercial, and E&HS review of a company. This requires the company tosubmit to DOW the Standard Prequalification package and be reviewed by theDiscipline Specialist, Labor Services Purchasing, and Contractor Safety. This packageis sent out by Procurement when there is a legitimate need to add a new contractorcompany. Once the prequalification package is received back from the company thisreview process could take up to two weeks.

Hold Harmless A signed legal document. It is intended to insure proper insurance coverage of thecontract company and to protect Dow regarding claims arising in the course of acontractor working on Dow premises. If there is a problem in obtaining a signed HoldHarmless the involvement legal departments of both Dow and the Contract Companymay be required.

Safety Action Plan A plan established in agreement with the contractor firm's safety representative, thecontractor project manager, the DOW Manufacturing Rep and DOW EH&S deliverythat identifies specific contractor EH&S contacts for the job/project and outlinesspecific EH&S job/project requirements.

Contractor SafetyCard / Training Card

A laminated card to be attached to an individual contractor's badge that identifies thedate that individual was trained on various topics (Red Tag, confined space entry, SWP,etc.).

Contractor Safety/Training Card is issued by Contractor Safety Council aftercompleting required safety training.

Dow BackgroundCheck

A background check will be conducted on all persons requesting a permanent type entrybadge to Dow sites in order to determine if any reason exists to refuse or limit access tothe Dow sites. This background check will be conducted only when an individual isrequesting entry to Dow sites, and covers only the individual’s ability to enter the Dowsites.

Labor ServicesAMSL

Categorical listing (based on scope of work) of contractors prequalified to come on site.Our strategy is to focus work through these AMSL suppliers. More information can befound on the Dow Intranet at this web site:

http://gpurchasing.intranet.dow.com/amsl2/default.asp





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Term Definition

AMSL MOC Management of Change process associated with variances or changes to the AMSL.Additional information can be found on the AMSL web site.

If you wish to buy a listed product or service from a manufacturer or supplier other thanthose listed on the DOW AMSL, you will need to 1) submit a MOC to add thatmanufacturer/supplier to the AMSL or 2) submit a one-time variance request.

If there are no manufacturers/suppliers listed for the product/service you wish to buy,then no AMSL MOC or variance request is required.

Site Sourcing Guide(SSG)

The AM/SL is supplemented by Site Sourcing Guides that specify site specific list ofacceptable suppliers for products not covered by the AMSL.

The Purchasing Management of Change process will not be used for SSG changes.

Contact site Purchasing rep for changes to DOW SSG; global example of theSSG change request form is:

http://gpurchasing.intranet.dow.com/virtual/documents/amsl/SSG_Change_Request_form.dot

Contractor GateEntry StatusDatabase

Multi-site database used to verify supplier status (approve/denied) before entering laborrequisition.

Contact the appropriate Contract Administrator to determine which company may berequested based on scope of work (AMSL must be used first to determine whichcompany’s are approved for specific disciplines, e.g. Hydroblasting, etc.)

STAC (Safety TaskAnalysis Card)Training

Task analysis is a process by which a job is broken down by into tasks, each task isevaluated to determine those hazards that apply to the task and identify measures thatwill control or eliminate those hazards. STAC training is required for crew leaders,foremen, and supervision.





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Term Definition

ARSC ARSC stands for Association of Reciprocal Safety Councils. These safety council'shave an agreement to recognize Basic + and Basic + refresher training delivered by anycouncil in the association.

Contractor's SafetyCouncil of TexasCity

A third party, non- profit organization dedicated to furnishing safety and health trainingto the contractor community

Houston Area SafetyCouncil

A third party, non- profit organization dedicated to furnishing safety and health trainingto the contractor community

Training CoursesAvailable throughthe Contractor SafetyCouncil

Training Courses Available through the Contractor Safety Council:

Course Description

Basic + A training course designed for the individual that hasnever worked in the petro-chemical industry beforeand is administered by an instructor that is availableto answer questions and furnish individualinstruction. Basic + training is available through theContractor's Safety Council or any council that is amember of ARSC.

Basic + Refresher A training course designed for individuals that haveworked in the petro-chemical industry in the past andis delivered by CBT (computer based train) with noinstructor available for questions/answers. Basic +refresher training is available through theContractor's Safety council or any council that is amember of ARSC.

DOW Isolation of EnergySources Training

A training course or CBT (computer based training)process that addresses the need of individuals thatwill be working on equipment which requireslockout/tag out.

ROHM & HAAS-DP BP& LONESTAR

A Training course or CBT process that addresses theneed of individuals that will be working at Deer Park,Lone Star or Bayport.





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Term Definition

Training CoursesAvailable throughthe Contractor SafetyCouncil (continued)

Course Description

DOW Confined SpaceEntry Training

A training course or CBT process which describes theprocess that addresses those individuals that will beperforming confined space entries or will act as“safety attendant” for a confined space entry

DOW Safe Work PermitTraining

A training course or CBT process that addresses theneed of individuals accepting a Safe Work Permitand/or that will be performing work which requires aSafe Work Permit.

Gulf Coast DOWTraining

A training course or CBT process that addresses theneeds of individuals that will be performing work at aDOW Gulf Coast site.

DOW ContractorIndustrial WorkerTraining

A training course or CBT process that addresses theneeds of individuals that will be performing elevatedwork, general electrical work, and who may need tounderstand safety instrumentation tags.

DOW Electrical Training Training courses, tests or CBT process that addressesthe needs of electrically skilled or instructedindividuals that will be performing electrical work at aDow site.

DOW Driver Training A training course or CBT process that addresses theneeds of individuals that will be driving on DOWproperty or on DOW business.

DOW Scaffold UserTraining

A training course or CBT process that addresses theneeds of individuals that will be accessing scaffolds atthe Houston Area Operations sites.

Contractor hire slip A document that identifies the name, social security number, and other informationspecific to the contractor individual that is to receive a badge.

The sheet provided to security confirming that the General contractor requests thisperson to be badged and confirms other requirements have been completed.

P.O. # Purchase Order Number, assigned by purchasing, at the time of contracting for services.




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Contractor/Sub Contractor Badging Policy

Scope To clarify requirements for obtaining a gate entry badge for contractor employees,any sub-contractor employees.

Process Badging:

Step Actions

1 Contractor: Complete the Hire-in Slip, this is a requirement.

Requires signatures of the contract employee, Contractor Company Rep, and DowRep.

Must provide complete Name (Last Name, First and Middle Names); noabbreviations or nicknames.

Social Security Numbers are required for US citizens

Foreign nationals will be required to produce passports or other means ofidentity validation and follow the foreign national’s procedure.

Company Rep responsibilities:

The Contractor Hire-Slip requires the signature of a company rep to validate thefollowing requirements are met:

All required safety training has been completed

Contract company employee is compliant with the pre-access substanceabuse requirements

Criminal background check has been completed and employee meetsrequired acceptance criteria

2 Proof of Identity:

Current Driver’s License or

State Issued Identification Badge

3 Current Safety Indoctrination Badge from Safety Council

Minimum Safety Council training requirements include Basic Plus safety course, DowSite Specific, and Safe Driver (to operate a vehicle).

Additional training based on work scope includes Red Tag, Safe Work Permit,Scaffold User, and Confined Space.

Site specific indoctrination includes completion of the site’s It’s All About Youmanagement expectations (may not be available at every site at this time but a sitespecific indoctrination will be required).

Unit indoctrination is conducted at the production areas after the employee hasreceived his/her proximity badge.





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Contractor/Sub Contractor Badging Policy, cont.

Badging Office Hours/Rules of Operation:

Applicants (Contractors, Sub-contractors, Vendors, and Visitors) goingto work in Dow Houston Area Operations sites must bring theircompleted badge form to Security Office.

Badge forms will be available

After Hour Operation/Processing: EMERGENCIES ONLY.

CONTRACT SERVICES AND ES&S MUST APPROVE AND CONTROL.

Applicant is required to go to work in plant as soon as possible.

Applicant will be delayed until an officer can respond to process theapplicant.

Badges Badges:

Badge must be worn and visible at all times unless safety requirementswarrant otherwise; and then should be in the person’s possession.

Upon termination of employment with any contractor company, applicantmust surrender any Dow badge previously issued to him/her.

ES&S must be notified immediately of any terminated employees.

Do not leave badge in vehicle.

Do not “loan” badge to someone else.

Violation of these rules can be grounds for dismissal from Dow property.

Employee must be re-badged if he/she changes contractor companies.

Temporary Badges Temporary Badges:

Employment verification by an authorized company representative isrequired prior to issuing a temporary badge.

Temporary badges will be issued to personnel with expected onsite durationof less than 5 days. Temporary badges and Safety Council badges withpictures ID must be visible at all times.

Upon completion of the job, Contract Services or the accountable ProjectLeader must be notified by the contractor in order for the badges to bedeactivated. The proximity cards must be returned to site security.





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Visitors Visitors:

Visitors should not perform any type of work at any time while on Dowproperty.

Visitors must provide a Dow representative’s name, phone number and arealocation.

Visitors should be escorted to and from their destination and at all timeswhile on Dow property by an approved Representative.

Resident Contractor’s can be designated by the Visitor Pass Approver toescort visitors. Visitor Pass Approvers are accountable to assure the escortcan fulfill all responsibilities. The responsibilities include at a minimum:


Job scope knowledge


Visitors must sign a visitor’s log.

Visitors should be badged and visibly display badge at all times while onDow property.

Visitors should surrender visitor’s badge prior to exit from Dow property.

ContractorIdentificationBadge Guidelines

There are no global contractor badge design specifications. Listed below areguidelines, recommendations and restrictions.

RESTRICTION: The Dow Diamond SHOULD NOT appear on any contractorbadge.

Contractor badges should be designed on an as needed basis at each site.

Contractor badges can be produced either in Portrait or Landscape.

Color and graphics are left up to the site preference for ease of identification.

Every effort should be made to communicate with other surrounding Dowand Non-Dow sites so that badge similarities can be avoided (“Dow” refersto The Dow Chemical Company and consolidated subsidiaries, includingUnion Carbide.)

All Contractor badges should include a recent photograph.

The same information fields that appear on a Dow badge should appear on acontractor badge. i.e. First name, last name, badge number and the Dow sitename and/or location.





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Contractor HireSlip Instructions

Employee requesting badge & their supervisor to complete this form

If employee requesting badge is a Foreign National or a former Dow orsubsidiary employee. See Contractor Admin Manual for instructions andforms. Houston Area Operations Admin Manual is available at the SafetyCouncil. Contract Services must receive verification from the appropriateDow contact if approval is granted.

Employee must bring original form with them when they arrive at security.Security will not accept a photo copy. Form must be the original.

Employee must bring Safety Counsel Badge & a legal form of identificationwith them in order to receive a badge.

Employee must have a clear understanding of their job role and know whotheir contact is.





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CONTRACTOR HIRE SLIP

PLEASE PRINT CLEAR & LEGIBLY

DATE: ___________________

Requesting Badge For Demotion New Construction Contract Maintenance VendorService Provider Pipeline Pipeline badges require appropriate pipeline approval & forms.

Last First Middle

Street Address

City State Zip Code

Safety Council BadgeNumber

Supt. OR Forman:

Company:

Company New Hire Yes No

Is your company UNIONYes No

Birthplace: EYE COLOR:

AGE: DATE OF BIRTH:

HEIGHT:

WEIGHT:

HAIR COLOR:

SEX: RACE: CITIZENSHIP:

DRIVERS LICENSE #: STATE:

TYPE:EXP.DATE:

Foreign National or Former Employees Will Require Additional VerificationConsult Contractor Admin Manual For Instructions & Forms.

Foreign National orFormer Dow subsidiaryEmployee

Yes No

Completion of asubsidiary of the DowChemical Company –Foreign National Policy

Yes No

Will require approval from Dow MidlandInternational Trade Group before badge willbe processed. Verification must be sent to siteES&S 5 working days prior to obtainingbadge.

Completion of asubsidiary of the DowChemical Company -Former EmployeePolicy

Yes No

Will require approval from Dow MidlandHuman Resource Group before badge will beprocessed. Verification to be sent to site HR 5working days prior to obtaining badge.




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To Be Completed By Employee’s Supervision

This statement serves as written confirmation that, ____________________________________:

Is in compliance with pre-access drug screening requirements - Contractor Substance Abuse Policy

Has demonstrated oral and comprehensive abilities of the English language

Has completed the criminal background screen has been completed and the employee has met the acceptancecriteria.

I further verify the Social Security Number of the individual in question has been checked for accuracy. Yes No

I further verify that a check of citizenship (resident alien card and work visa for non-U.S. citizens) has beenconducted and the citizenship of this individual has been verified. Yes No

The person listed has successfully completed All required Safety Council training needed to perform their job/taskat _______________. Yes No

The person listed above is also scheduled to be working inside _________________ Operations Site within thenext five (5) days.

The person listed has completed Safety Council Safe Driver Training Yes No

Requested Vehicle Use Personal Vehicle Company Vehicle Non Driver

The person listed is requesting a PERMANENT TEMPORARY (< 90 days) badge.

Requested Gate Access (Walk In Only) Vehicle Access

For additional information about this employee, please contact __________________@ ____________.

Authorized Company Representative Signature ___________________________________________Printed Name & Phone Number _____________________________________________________

Have you worked in Dow Operations within the last 12 months? Yes No

If yes, what company did you work for? ___________________________

Have you ever been convicted for any law violations other than minor traffic in the last 10 years?Yes No If yes, list below in the spaces provided.

DATE CITY & STATE CHARGE FINAL DISPOSITION

I agree that if it is found that I have falsified or omitted information from this questionnaire it shall beconstrued as fraud against The Dow Chemical Company, and shall be sufficient grounds for my removal fromDow Operations' property and ALL my entry passes revoked.

Employee Receiving Badge Signature: ______________________________ Date: ____________




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Dow Houston Area Operations Background Screening Policy

Purpose To ensure all non-Dow individuals who request a badge to allow entry to DowOperations work site have a background screening performed.

Scope This applies to contract company employees, delivery and service personnel, carriers,and employees of other companies requesting a badge to enter any Dow site in theU.S.

Background Since September 11, 2001 several measures have been implemented throughoutindustry in the United States in an effort to improve site and community security.The Dow Chemical Company has undertaken extensive security vulnerabilityassessments and audits at its sites around the world, and has implemented severalnew or upgraded security processes as a result of these assessments.

Policy All non-Dow individuals requesting a permanent entry pass to any Dow site in theU.S. will be required to demonstrate that he or she has successfully passed abackground screening process. This screening process will be coordinated andimplemented by the contractor company through the local contractor safety council.

Exceptions The only non-Dow individuals who are exempted from this policy are identifiedgovernment officials

Screening Process The screening process itself will include, at a minimum, verification of identification,citizenship and Social Security Number; Patriot Act check, and a check into theperson’s criminal history report that details any convictions (felonies andmisdemeanors) in the previous seven (7) years for any crimes involving theft,violence, destruction of property, or drugs.

The minimum set of unacceptable criminal convictions does not necessarilyprevent assignment for work in a Dow facility, but offers a first review toexpedite those who do not require a more in-depth management review.

Exceptions may be made on a case-by case basis by the facility ResponsibleCare leader.

Only under approved situations should any individual with questionablereports in any of these areas be allowed to enter the Dow site.





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DOW Background Screening Policy, cont.

Non-DowCompanyDocumentationRequirements

Each non-Dow company requesting an entry badge to the Dow site for one of itsemployees should have its employee provide in person the following documentationat the time of the request:

written request for a Dow site entry badge (Hire Slip)

written verification of successful completion of a recent drug test (Hire Slip)

written verification of a background screen including “BackgroundVerification Form”

verification of citizenship (Social Security Number) or an appropriate workVISA and resident alien card if not a U.S. citizen

Patriot Act check

completion of a background screen for criminal history

English comprehension verification

Personal photo identification using a government issued photo (driver’slicense, passport, or resident alien card for non-U.S. citizens.)

Safety Council Training completed

Other Documents Hire Slip

Background Screen Verification




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Contractor Safety Training Waiver (One day Emergency Waiver)

Purpose To provide site access to individual contractors who have not completed the requiredContractor Safety Training and as a result of an emergency situation are required towork on site.

Scope The contractor safety waiver is to be used only in the case of an emergency whenindividual contractor employees are needed to control or abate an emergencysituation and those contractors have not been through Dow requirements forContractor Safety Training. This waiver is only to be used one time per contractoremployee and only until the next regularly scheduled training class is available.

Requirements To bring a contractor employee(s) into the facility that have not been safety trainedthe following conditions must be met:

An emergency situation must exist that requires the services of this/thesecontractor(s). Examples of an emergency situation include unplanned shutdown of a plant or process, control of a spill or release, etc.

Training for these individuals is not currently available through the “SafetyCouncils” (after hours, weekends, etc.).

The Production Leader for the Business in need of the contractor mustapprove of the situation. The EH&S Delivery Leader for the Business inneed of the contractor must be informed of the situation.

A Dow escort must be identified and sign the waiver form (The Dow escortmust accompany the contractor employee at all times).

If the job requires working behind a Red Danger Tag, entry into a Confined Space,SWP, etc., training on these processes must be completed and documented beforework can begin. Management of the contractor firm must have knowledge of thetraining to be delivered to their employee and concur with the training to be delivered(this training may be delivered by a qualified Dow employee).

Procedure The business that requires a contractor to come on site and do work that has not beenthrough Contractor Safety Training must :

Notify and get approval from their Production Leader. Notify and getconcurrence from their EH&S Delivery Leader.

Identify a full time “Dow” escort that will be responsible for the contractor’ssafety.

Assure that Dow SWP, red danger tag, confined space, and any otherapplicable training has been completed, if required by job scope, anddocumented.

Ensure site “It’s All About You” training is complete and documented.

A representative of the business must conduct plant/block specific training toinclude HazCom issues and hazards specific to the block, and document thattraining.

The responsible Dow escort and the Contractor employee must sign the“Waiver of Contractor/Vendor Safety Indoctrination” form.




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Waiver of the Contractor/Vendor Safety IndoctrinationHouston Area Operations Sites

Provisions of the Contractor Safety Indoctrination Requirements as specified in the Houston AreaOperations Contractor Administration Manual are hereby waived for a period of 24 hours or until thenext scheduled Contractor’s Safety Indoctrination. (Note: Must be a Houston Area Operationsapproved contractor, e.g. prequalification complete.)

The site Approved Responsible Person must:1. Have a situation that constitutes a “true” emergency (Give details of the nature of the emergency)2. Escort the contractor/vendor employee at all times.3. Take full responsibility for the safety of the contractor/vendor employee.4. Inform the contractor/vendor employee of the potential hazards of the area (HazCom/PSM

Overview requirements are fulfilled).5. Assure that the contractor/vendor employee are trained before being allowed to work behind the

protection of Red Tags, enter into a confined space, or receive a safe work permit.

I understand the responsibilities identified in this document and assume these responsibilities for the entryof the contractor/vendor employee noted on this document.


Production Leader Authorizing SignatureProduction Leader Master NumberEH&S Delivery Leader concurrenceEH&S Delivery Leader Master number

Approved Escort Signature (Initial)Approved Escort Master number (Initial)








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Contractor Safety Training Requirementsfor “Short term, Low-Risk” Entry (Less than 5 days)

Purpose To provide site access to individual contractors whose work on site is low risk, doesnot involve hands-on work on a chemical process, on a construction site, and it is notpractical to complete all the requirements of “contractor safety training”.

Scope The 1 to 5 day amended safety requirement is for contractor employees who, by thenature of their work, are low risk and are not working on or adjacent to processequipment (as defined by Process Safety Management, O.S.H.A. 1910.119).

Note: The prequalification process must be completed prior to site access.

Requirements To bring a contractor employee(s) into the facility that have not been through Basic +safety training the following conditions must be met:

The job to be completed must be short in duration (1 to 5 days).

Determine that the job scope to be completed does not include any of thefollowing:

Work on or adjacent to process equipment

Work on or adjacent to auxiliary or support systems that could impactprocess equipment or control systems

Construction, Maintenance, Demolition or Turnaround work

The contractor employee must have completed “Dow Site Specific” training.

The job must be “low risk” in nature (Red Tag, Confined Space, Safe WorkPermit, etc. is not required to complete the job).

The EH&S Delivery Leader for the Business in need of the contractor mustbe informed of and approve of the situation.

Procedure The business that requires a contractor to come on site and do work that has not beenthrough Basic + Contractor Safety Training must:

Notify and get concurrence from their EH&S Delivery Leader,

A representative of the business must conduct plant/unit specific training toinclude HazCom issues and hazards specific to the unit, and document thattraining.

The Contractor employee must sign the required form.

Before work is to be preformed a Dow representative of the business must fillout a pre-task analysis card (STAC) with the contractor employee to identifypotential hazards and identify control and/or elimination measures for thosehazards.

A Dow representative of the business must check the training card of thecontractor to assure the contractor has completed Site Specific” training.





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Contractor Safety Training Requirementsfor "Short Term, Low-Risk" Entry

Houston Area Operations Sites

Provisions of the Contractor Safety Indoctrination Requirements as specified in the Houston AreaOperations Contractor Administration Manual are hereby amended to require only "Gulf Coast SiteSpecific" training, for a period of not more that 5 days under the following conditions.

Work scopes targeted for the amended requirements are:1. Individuals in the process area but not doing hands-on work (i.e. Consultants)OR2. Individuals NOT in the process area but doing hands-on work (i.e. Original EquipmentManufacturing.)

The site Responsible Person must: Determine that the job scope to be completed does not include any of the following:

Work on or adjacent to process equipment Work on or adjacent to auxiliary or support systems that could impact process equipment or

control systems Construction, Maintenance, Demolition or Turnaround work

Assure that the individual has completed "Gulf Coast Site Specific" training. Take full responsibility for the safety of the contractor/vendor employee. Inform the contractor/vendor employee of the potential hazards of the area. Assure that the contractor/vendor employee does not need to work behind Red Tags, enter into a

confined space, or do work that requires a safe work permit.

I understand the responsibilities identified in this document and assume these responsibilities for the entryof the contractor/vendor employee noted on this document.


Production Leader Approval SignatureProduction Leader Master NumberEH&S Delivery Leader concurrenceEH&S Delivery Leader Master number

Requestor SignatureRequestor Master number








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YES(acceptable, but shouldutilize the "ShortTerm, Low Risk"training requirementsform)

NO

YES

YES

Start

Utilize one day SafetyCouncil Training waiver(multiple one day waivers is not

acceptable. Intended forEmergencies only)

Utilize "Short-Term, Low-Risk" training requirements

form

Recommendindividualattend SafetyCouncil class,but multiple"Short-Term"entry formsacceptable

Working 5

days or less?

Working on-site one day?

Working inprocess area?

Utilize Visitor processAre theybeing paid?

Are theyworking?

Is work >1day?

Is person doinghands-on

work?

Person must attend allapplicable safetycouncil training (per jobscope)

YES

YES

YES

NO NO

NO NONO

NO

YES

Houston Area OperationsContractor Safety Training

Requirements

One Day Waiver Link

"Short Term" form Link

Hold Harmless Link




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Visitor/Vendor Policy

Scope This policy applies to all areas within the fence line of the site to which Non Dowemployees, visitor or vendors may be admitted.

Statement of Policy All Non DOW employees, contacts/escorts and visitors or vendors must comply withthe following policy for obtaining access to Houston Area Operations.

The person or department being visited is responsible for the safety of the visitor.

Contractors requesting visitors must comply with the following policy for obtainingaccess.

Exceptions Security will notify ES&S personnel when military or law enforcement agencies onofficial business enter the site.

Contractors follow the Site Access Contractor/Sub-contractor Badging Policy in theContractor Administration Manual; please contact Contract Administration


As used in this policy, “Dow” refers to The Dow Chemical Company, and its subsidiaries (including Union CarbideCorporation, as applicable).




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Visitor/ Vendor Policy, cont.

Responsibilities

Person Responsible Description

Visitor PassApprover/Escort(Dow employeecontact/escort orContractorcontact/escort):

a) Ensure Security has received entry authorization for Non-Dow employees

b) Issue safety equipment to visitor and instruct on proper use

c) Ensure visitor reviews, understands and signs Visitor Orientation card

d) Ensure process is in place for accounting for visitor during an emergency

e) Ensure process is in place so that unauthorized persons do not enter restrictedareas

f) Visitors should be escorted to and from their destination and at all times whileon Dow property by an approved Representative.

g) Ensure that visitors do not engage in any activity other than visual observationand/or meeting in a designated area. Note: Any additional activity may requireadditional access approval, training, and requirements.

h) Visitor Pass Approvers are accountable to ensure the escort can fulfill allresponsibilities. The responsibilities include at a minimum:


Job scope knowledge


i) Resident Contractor’s can be designated by the Visitor Pass Approver to escortvisitors.

j) Obtain signed confidentiality documents, where appropriate.

k) Gather and respond to visitor’s concerns or unique requirements

l) Foreign Nationals Visiting U.S. Sites

Entry Procedure –http://ischain.intranet.dow.com/ssb/operations/ehs/customs/na/foreign_nationals.htm

Entry Forms and Flowchart –http://gpurchasedb.intranet.dow.com/SiteAccess/frames.htm





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Person Responsible Description

Security: a) Ensure a completed Visitor log has been completed (which identifies andauthorizes all visitors) prior to issuing badge.

b) Ensure every visitor or vendor has a valid Visitor orientation card on his or herperson before site entry.

c) Ensure each Vendor reviews, understands and signs a Visitor Orientation card orhas a valid orientation card on person.

d) Ensure process is in place for accounting for vendors during an emergency(visitor log).

e) Ensure all visitors or vendors are issued an appropriate badge prior to site entry.

Business/FunctionLeaders:

Consider denying the visitor continued access to Dow sites if an individualdemonstrates unacceptable behavior. Note: confer with ES&S to remove accessprivileges.

Definitions

Term Definition

Visitors A Non-Dow individual at Houston Area Operations sites other than companypersonnel and Non-Company Service Providers

Characteristics of a visitor include:

The individual is escorted by a host (Company or a Non-Company ServiceProvider),

does not perform physical work, and

is treated as a “one time” guest.

Broad categories include family members, tour participants, sales persons, agencyinspectors, and consultants.

Note: It is important for the host to assess the visitor and to manage the safety of thevisitor and ensure that Dow EH&S performance and property are not compromised.





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Term Definition

Vendors /Delivery Person who come on site to perform a service such as delivery and receives payment.Broad categories include vendor stocking, vending machine replenishment, mailservice, equipment delivery/service, fuel or raw material delivery, product pick up andremoval from the site, and distribution of Dow product off the site. Examples:HotShot, Common carriers, etc.

Non-Dow supervision, independent organization, and movement restricted to roadways, storage, construction and office areas characterize this service. They are notallowed in process areas without an escort and location/department safety and healthinformation.

Contractors External companies and their employees doing labor contract work at Dow sites, aswell as individuals or other companies (sub-contractors) that are hired by that businessentity to do the work.

Definition ofWork:

Work shall be defined as any physical presence or activity such as using tools,climbing ladders or over obstacles, setting up equipment, or any work for which pay isreceived.

Where to Report These persons shall report to the Security Stations. Plant Security will man these areasduring normal working hours and will direct the visitor. They will be required to login on the visitor register/log.

Contacting Personto be Visited

Security will provide visitors with the phone number of the person or area beingvisited Phones are provided for the visitor to contact the party being visited.

Meeting with Non-DOW Visitors

Visitors should not be taken into the site unless absolutely necessary. A room isavailable in the reception area for plant personnel to meet with visitors.

The visitor must be signed in with security (via Non-Dow Visitor log) when necessaryto issue a visitor badge. Visitor Orientation card is valid for one year from signaturedate.

When taken inside the site the contact/escort must accompany the visitor and informvisitor of any potential safety or health hazards.

No one under the age of 18 will be allowed on site without being pre-authorized byPublic Affairs and with prior ESS notification. (Minimum age for site entry is 12years.) All other non-business visitors must be referred to the area site leader forauthorization.

Sign Out The visitor or vendor must return badge to Security when leaving the site.





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SafetyRequirements

If the visitor is taken into the site, then:

The contact/escort will ensure the site indoctrination for the visitor iscompleted, that verification of indoctrination is documented via signature onVisitor Orientation card, and card is given to visitor to keep on person whileon site. Site Indoctrination is valid for one year from date documented oncard. The card is signed by the visitor to document they have received andunderstood indoctrination.

It is the responsibility of the visitor or vendor to supply documentation ofindoctrination, e.g. Dow visitor orientation card. If a valid card is notavailable upon entry into the site, re-indoctrination and reissue of card will berequired.

The contact/escort must supply the visitor with the appropriate personalprotective equipment for the area being visited and ensure they are instructedin its proper use.

Procedure Vendors:

Properly completed entry log.

Vendor must have valid Visitor Orientation card and Vendor badge on theirperson while on site.

Security will review the general instruction part of the Visitor OrientationCard with the vendor and the vendor must understand and sign the card.

Vendor may not enter process areas unless signed into the plant and escortedby plant personnel.

Before leaving site, vendor must turn in badge to security.




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Leader Safety Expectations – “It’s All About You”Work Process Description for Contractors

Introduction All Contract Employees are required to attend the “It’s All About You” presentationprior to being allowed to perform work at Dow. The presentation will be delivered inperson by selected Dow.

Overview The “It’s All About You” process establishes basic expectations for all personnelworking at Dow. Once the orientation is complete contractors will be required tosign a document indicating they have completed and understood the material.

No work will be allowed by any contract employee until this requirement is metwithin 5 working days.

Training Schedule Training sessions will be conducted per the following schedule.

For TCO: Training sessions are held Wednesday’s from 3pm-4pm at Bldg.402, LaMarque Room

For Deerpark, Lonestar, Bayport, and LaPorte: Training sessions are heldThursday’s from 3pm-4pm at Training Building in Gate 25 Parking Lot.

Special sessions will be scheduled for large parties of 15 or more.

Late arrivals will not be accepted

DocumentRetention

Completed document indicating completion and acknowledgment of the expectationswill be the responsibility of the Contract Company to maintain on file.

All About You Training is not transferable from one site.





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Leader Safety Expectations – “It’s All About You”Work Process Description for Contractors, cont.

Q & A Does the training have an expiration date?

This is a one time orientation.

Do I have to go through it again if I change companies?

No, but your new employer is required to have documentation on file that you haveattended.

Can I get this training from the Safety Council?

No, the training must be delivered at the site you are working.

What happens if I need to get trained on the weekend?

The training is only available based on the schedule above. Exceptions to thisrequirement for emergency work will be at the discretion of the Production Leader orMaintenance Process Leader.

Can contractor management complete a train the trainer sessions and train theirown employees?

No

Does an owner, company superintendent, vendors or delivery company that isnot performing work required to have this training?

The orientation is required for all contractors who report work hours and injuryrecordability that impacts Dow. This would exclude visitors and delivery companies.

Will I be able to get this training in one of the process units?

Training sessions for contractors will not be available in the process units.

How will large groups be handled such as turnaround hiring or when a largecapital project starts?

Special sessions will be conducted to accommodate large increases of personnel.




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Pre-Job Orientation

Purpose: The purpose of this process is to ensure contractors working at Dow are appropriatelyindoctrinated in order to create an “Incident / Injury Free” workplace at Dow throughcommunications of known hazards or potential hazards, Dow rules, and procedures,as well as Dow’s safety expectations relating to the contract.

People must understand hazards, risks, and consequences of risks associated withintheir work environment and from their actions. They need to understand andrecognize hazards/risks, they need to know how to mitigate or eliminate thehazards/risks and they need to know how to interact with others to provide an“Incident/Injury Free” atmosphere.

The Pre-Job Safety Meeting is one tool that is used to help provide an“Incident/Injury Free” workplace

The Owner being involved with the project from project inception normally has themost knowledge of project, site, and conditions relating to the project. It is theOwner’s responsibility to communicate any known hazards or potential hazards topeople that work on Dow projects. At Dow this is accomplished through acommunications meeting conducted just prior to the contractor starting any work inthe field called “Pre-Job Safety meeting.

Expectation: The expectation is that ALL companies will be indoctrinated

Responsibilities:

Item Description

1 The Job Representative is responsible for scheduling and conducting of the Pre-Jobmeeting.

2 The Job Representative, before the meeting, should review the contract documentsand site procedures to become fully familiar with:

a) The contract

b) The work (review scope with technical expertise such as MaintenanceTechnical Services to ensure the appropriate sections of the Pre-Job checklistare completed)

c) The hazards and potential hazards or the work

d) The Federal rules and regulations associated with the work

e) The State rules and regulations associated with the work

f) The City or local rules and regulations associated with the work

g) The Dow rules and procedures associated with the work

h) Any special plant or operations rules or procedures

i) Any special situations that may be present or arise during the contract





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Pre-Job Orientation, cont.

Responsibilities:(continued)

Item Description

3 The Job Representative should fill in as much as is possible of the Pre-Job Meetingchecklist so that the meeting may be as productive as possible.

4 The Job Representative must then schedule:

a) A meeting place

b) A time

c) And contact attendees to schedule attendance for the meeting

5 The Contractor is responsible to:

a) Schedule the attendance of:

i. Contractor’s Site Supervisor and management representatives

ii. Contractor’s Site Safety Representative

b) To Listen, ask questions, and understand rules and regulations discussed.

c) To review the completed checklist and additional action items from thismeeting with every person working directly for them on the site. {Normallydoes not need to include material suppliers}

d) To insure compliance with all rules and procedures discussed in the meeting.

6 The Job Representative will conduct the meeting through a review of all items on thePre-Job Safety Conference Checklist and will seek understanding and input from theattendees through discussions, questions, and documented answers.

7 The Job Representative will finalize the Pre-Job Conference checklist, make copies,and distribute the copies to the Attendees the same day or no later than the followingwork day.

8 The contractor company will take their copy of the Pre-job and make whatever copiesthey need and then will review with each person going to work on the site prior to theirstart of work.





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Pre-Job Orientation, cont.

New ContractCompanyOrientation

Pre-Job Orientation Meeting

Prior to a new contract company’s forces or facilities entering the site, a pre-joborientation meeting shall be held between the Dow Representative (job rep),Contractor EH&S, and the Contractor’s Site Supervision Representatives.

This meeting will be held each time the contract company comes on siteif the site supervisor changes (regardless of the number of times thecontractor or sub-contractor may have previously been on site).

The Pre-Job Safety meeting meets the requirements of the orientation fornew contract companies.

The general format of the meeting will follow the form and checklist entitled,“Contractor Pre-Job Conference Checklist”.

Pre-Job Meeting Pre-job Safety Meeting

Prior to starting any field work, a pre-job safety meeting will be held betweenthe Dow Job Representative and the Contractor’s Representatives at aminimum. Contractor EH&S or an EH&S Representative from the plant mustbe invited. The customer(s) requesting the work, and if needed a purchasingrepresentative may need to be invited depending on the Job Scope(Turnaround, Shutdown, Project, etc.). Any party involved in the work canrequest a Pre-Job Conference if they feel it would benefit the execution of thework to follow.

The pre-job meeting is to review specific details relative to contractor safety forjobs by existing contractors:

For major jobs (projects, turnarounds, shutdowns, etc.) – completedwithin a week or two of beginning work to review EH&S issuespertinent to the job scope regardless of the number of times thecontractor may have previously worked at any Dow site.

For emergency work – completed at the time of site access to orient anew company to site requirements (Work Activity Coordinator –WAC-would be the Job Rep for emergency work) by completing thehighlighted sections of the checklist and items related to the emergencytask. A meeting will be scheduled to complete the Pre-Job checklist bythe site Job Rep if the company is approved for future use.

For Infrequent, Non-Resident Contract Company access (site access oftwo or less times in a 12 month period) – The contract company reviewsthis checklist with employees prior to site access and gives signed Pre-Job checklist to Job Rep prior to performing work.

The job rep with EH&S determines frequency of holding Pre-Job meeting (ref.Job Rep Responsibilities) for existing contract companies; determined byscope, frequency of contractor site access, risk involved, etc.

The general format of the meeting will follow the forms and checklist entitled“Contractor Pre-job Conference Checklist”.




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Pre-Access Flowchart

Pre-Job ProcessFlowchart

Include TCO Contractor Admin

Manual with the bid package and

Job Rep ensure Pre-job Safety

Conference requirements are

understood by contract company.

Contractor brings completedforms to the pre-job Safety

Meeting.

At Pre-job conference, final resolution isobtained for all applicable items in

checklist. (All safety requirements andissues are addressed, issuesresolved/action plan in place.)

Contractor reviews the completedchecklist with the job/owner rep

prior to the pre-job safety meeting.

Understandingadequate?

YES

Contractor gatherssupporting

documentation neededto substantiate

responses (JSA's,etc.)

Successful Bidder fillsout the Pre-Job formwith answers to all

questions that can beanswered.

Updates are madeto the checklist with

any action itemsdocumented

Makenecessarychanges.

Contractor reviews thechecklist with all employees

on the project.

NO


“Yes” - Contract Company meets requirement at time of Pre-Job. “N/A” - requirement does not apply for scope of work.“No” – does not meet requirement or a gap exists and Corrective action is documented in Attachment A.

Bring supporting documentation to substantiate responses / where additional information needs to be provided.



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CONTRACTOR PRE-JOB CONFERENCE CHECKLIST

The pre-job conference checklist includes the sign off for each contract employee working on the project/job. Thechecklist is returned to the Job Rep when the project/job is complete.

Documented action plans must be developed prior to project/job start or appropriate justification made for anyitems marked "No". Use Attachment 1.

Use Attachment 2 to list comments associated with any particular line item.






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CONTRACTOR PRE-JOB CONFERENCE CHECKLISTGeneral Information – This section must be completed.

Plant/Location:

Project Description:

Contract / PO / Work Order / EJN No.:

Issued for Construction: ____Sets of Drawings and ___Sets of Spec. No._______Issued for Expense: ____Sets of Drawings and ___Sets of Spec. No._______Contract Type:AGREEMENT: LUMP SUM T&M UNIT AGREEMENT FOR SERVICES:Type of Non-Dow Service (NDS) Firm:□ Independent Contractor □ Contingent Staff □ Delivery Service

LIST ALL NDS FIRM NAMES (INCLUDING SUB CONTRACTORS) – must be currently listed asapproved on the site Gate Access Database:

COMPANY NAME CONTACT NAME PHONE #

Contract Firm’s Local Business Address: Telephone No. ______________________E-mail: ____________________________

*Site Supervisor / Superintendent:Name: _____________________________Phone: (_____)________________Email: _______________________

Company Management RepresentativeName:________________________________(Name entered ensures Pre-Job conference compliance.)

General Foreman’s Name: _______________________________________________________Phone: ( _____)________________

Contractor Safety Representative:Name:________________________Phone: ( _____)________________

Full Time □ Part Time □ As Needed □

Contract/Project Start Date: Expected Duration (project/turnaround):DOW Project Manager (name): Block/unit Man Rep (name and phone):

Engineering Solutions Construction Manager:Name: ___________________________________Phone: ___________________________________

DOW Contract Administrator/Job Representative:Name : __________________________________Phone: __________________________________

Block/Unit EH&S Contact (name and phone): Constr/Demo Safety Rep (name and phone):

DOW Pre-job Safety Review Facilitator: Date of this Review:

*Notify job rep/construction manager/contract administrator if the Site Superintendent changes; a new Pre-Job Conference with the new superintendentmust be performed in order to adequately orient the new superintendent to site requirements.






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CONTRACTOR PRE-JOB CONFERENCE CHECKLISTAttendees Information

Name Title Company






Table of Contents

Management Systems Sections A. – I.: These sections must be completed.Note: For Emergency or Infrequent, Non-resident contract company work – only grayed lines must be addressed.

A. Leadership

1 Review project organization Project Leader, Maintenance and Construction personnel,contract administrator, etc.

Yes No

2 Review safety expectations for each level involved in project as well as overall projectContractor (including leadership participation in job audits)Project Leader, Plant Personnel, etc.

Project Safety Goals and Project / Turnaround Incentives (if applicable)

Yes No

3 Review process for approval of scope changes once project is in progress.How will safety be ensured as job scope changes or jobs added?

Yes No

4 Restricted areas within plant identified for the workers involved, properly barricaded?Process areas and Hot Work areas located, plot plans reviewed?

Yes No NA

5 Have the contractor review their progressive discipline policy for safety violations andrecognition/incentive program.

Yes No

6 Review existing Dow site safety performance and expectations for positive contribution. Yes No

7 Contactor OSHA 300 log maintained?Who: ___________________ Where: ________________

Yes No NA

B. Facility Planning

1 Ensure everyone familiar with selected work schedule ex. 5-8 hr days, 4-10’s, 12 hr shifts,etc.Agreed working hours: ___A.M. to ___P.M.After hours Approved by:________________

Yes No

2 Gate Assignment: Entry through Gate #___________ Yes No

3 Parking Facilities: _____________________________ Yes No

4 Ensure familiarity with Transportation of Workers to Worksite (ref. Safety Rule Book asapplicable)Seatbelts, Speed Limits, Pedestrian Travel, Bicycles, Licensing requirements (ex. Bus drivers)

Yes No

5 If temporary hand wash or other sanitary stations required, they are drained to a sanitarysewer (not NPDES or storm water outfall)

Yes No NA

6 Plans in place for potential adverse weather conditions?heat stress, freeze precautions, etc.

Yes No NA

7 Additional lighting for night work available? Yes No NA

8 If contractor to supply any portable (permanent or temporary) buildings, contractorunderstands responsibility for: LPP 12.8 Portable Building requirements including identification of building & MOC process

(requestor initiates & site specific approval process – PSTL, PL, MPL, ES&S) DOW related procedures, approvals, and forms (including Utility Change Request) inspection checklist (if on site 1 month or more) and if occupied:

o exit signs, evacuation cards, fire extinguisher, EARS, stairways and landing platformsRequestors should work with PL's/MPL's, etc. to determine necessity of trailers versus use ofexisting buildings and facilities. ("Trailers/temporary buildings" include tool trailers, C-cans, etc,not just "habitable" trailers. Trailers/temporary buildings are last resort.)

Yes No NA






Table of ContentsD. Teams, cont.

9 Facility needs determined and plans in place to provide: Office space Location:_____________________________ Restroom/wash room/change room ocation:_____________________________ Lunch room (no food/beverage in area exposed to toxic materials) Location:__________________ Drinking water source: ___________________________ Power supply by:__________________________ Voltage:__________________ Contractor Material Pass signed by:

Name/Role_______________________________________ Telephones/Radios Radio No.__________________ Contractor computer setup - DOW Intranet and email Service shops notified and ready for additional work load general repair shop, machine

shop, sandblast booth, etc.)? Fabrication area? Traffic and Marshalling Plan to eliminate or limit vehicle access in/near process areas

completed?

Plans in place for removal of non-essential personnel during all periods of enhancedrisks (potential startups, shutdowns, introducing chemicals to plant after maintenance); these enhancedrisks can also come from adjacent plants. Plan must ensure a communication system is in place to contact the contractors to evacuate,

where they should go, when they should return, and who their contact is.

Yes No

C. Objectives & Targets

1 Review Contractor Safety Plan (conditional approval)/ Safety Activity Plan (project) Yes No NA

2 Method for periodic evaluation discussed and schedule set Yes No NA

3 Expectation established to use Safety Activity Plan in project evaluation at closure Yes No NA

D. Teams

1 Expectation to participate in site teams to include: Firm owners improvement Safety specialist communication Work group specific Functional leveraged

Special emphasis

Yes No NA

2 List of specific teams (ex. Houston Area Operations Contractor Meeting):1. _______________________ 3. __________________________2. _____________________

Yes No NA

E. Measurements

1 Expected pro-active measures reviewed to include: Compliance to corrective actions Observed behavior/interventions (Near Miss program, etc.) Hazard recognition scores (STAC by foremen) QSPPs Schedule Other: ______________________ (specified)

Yes No

2 Expected injury performance – “zero” - reviewed Yes No

3 Criteria for continued selection Observed behavior Injury/Illness, EMR

Participation

Yes No






Table of ContentsF. Work Process

Incident Investigation (reference Houston Area Operations Contractor Admin Manual)

1 Expected incident notification (Contractor Incident Form and initial notification; review flowchart in Houston

Area Operations Contractor Admin Manual – Investigation Policy)Who is delegated to report incidents: Name/Role: _______________________________

Yes No

2 Expected type of incidents to be investigated to include: Observed unacceptable behavior 1st aid/minor injuries Potential serious event (examples listed in the Investigation Policy)

OSHA recordable cases

Yes No

3 Review method of investigation (cause & effect, ABC) and required documentation (finalincident report for non-trigger or initial report then final incident report and Cause & Effect diagram for RCI triggerincidents)

Yes No

4 Review expected participation by DOW and contract firm Yes No

5 Any contractor employee involved in an accident or incident must submit to a postaccident/incident substance abuse test (contractor responsible for ensuring confidentiality issues). Stepsleading to the test must include supervision escort to the testing location to assure “chain ofcustody” prior to testing. (Failure to comply will be grounds for removal from the site.)

Yes No

Corrective Action/Preventive Action

6 Method to track corrective actions to completion Yes No

7 Reporting and validation Yes No

Shared Learning

8 Expectation to share learning across site and functional specialty Yes No NA

9 DOW sponsor to distribute learning Yes No NA

Pre-task Hazard identification (JSA and STAC)

10 Review requirements for evaluating and documenting job hazards? (JSA, STAC) Yes No

11 Training process to include leadership and individualsContractor Supervisor STAC training: Date(s) scheduled: ____________________

Yes No

12 Scoring process to evaluate the quality of hazard recognition Yes No

13 Reporting/measurements as to effectiveness of hazard recognition Yes No NA

14 Review current site safety trend(s) for hazard awareness Yes No

Safety suggestion and feedback (reference Houston Area Operations Contractor Admin Manual – Investigation policy)

15 Method to make a suggestion (Contractor Incident/Safety Suggestion/Unsafe Condition formand process)

Yes No

16 Resolution process Yes No

17 Feedback method Yes No

Behavior Observation/Intervention

18 Are behavior observations scheduled during the project? Review process for providing feedback to persons involved.

Contractor plan to track and communicate to DOW.

Yes No NA






Table of ContentsF. Work Process, cont

Behavior Observation/Intervention (cont.)

19 Selected observers both DOW and contract Yes No NA

20 Data collection and feedback method to share results Yes No NA

21 Method to address what has been observed proactively Yes No NA

“At Risk” employees (reference Houston Area Operations Contractor Admin Manual – “Buddy” policy)

22 If a large number of employees are new to craft or the site, does contractor have plans inplace to pair new employees with experienced ones?

Yes No NA

23 “Buddy Policy” understood and implemented? Yes No

24 Method to identify those less than 6 months with company (orange tape) Yes No

G. Training/indoctrinations

1 Review turnover management plan.How many additional people are expected for this project? Number: ________How many are new to the plant? Number: _______________How many are new to the site? Number: _______________

Yes No NAYes No NAYes No NA

2 Review site access process:Hire slip (Background screening, foreign national approval, former Dow employee approval, Englishcomprehension, from another Dow location)

Yes No

3 Are plans in place to bring these employees in early for the site and plant indoctrinationtrainingReview indoctrination schedule Date(s) scheduled: __________________________

Yes No NA

4 Review contract company method to ensure 1st line supervisors (crew leaders, foremen, etc.) areprepared/qualified to manage safety for day to day work (ex. training)?

Yes No NA

5 Review substance abuse testing status for each person to ensure pre-access testing, for causetesting, post incident and annual random testing. (ref. Houston Area Operations ContractorAdmin Manual)

Yes No

6 Method to validate Safety Council training/certification by individual to include: Basic Plus/Refresher Dow Gulf Coast Site Specific

Task specific requirements (Fire Watch, Scaffold User, Safe Driver, Red Tag, Dow ConfinedSpace, and though not required -SWP acceptor at contract company’s discretion)

Yes No

7 Review skill assessment/qualification for each person, where practical e.g. individual statusfor known employees to be brought on site Certifications (Contingent Staff engineer – PE, Radiographer, etc.) Craft Skill Assessment

Qualification/Training

Yes No

8 Additional training/knowledge to be verified as applicable to the work being performed: Job and Equipment Specific training for Contractors (ref. Houston Area Operations Contractor

Admin Manual) DOW Safe Work Permit Procedure (job aide for Permit Acceptor) DOW Red Tag Procedure (job aide for Job Representative verifying isolation and job aide for

workers) DOW Confined Space Entry Procedure (job aide for Person Accepting CSE permit) Trenching & Excavation Policy Hydroblasting & Power Washing Standard (job aides for 1) Hydroblasting crew 2) Pressure

Washing crew) DOW Elevated Work Mobile Hoisting & Rigging Standard Steel Erection Standard

Yes No NA






Table of ContentsG. Training/indoctrinations, cont

9 The following orientation information shall be reviewed with contractor crews prior to start ofwork to include: Pre-Job Safety Conference Checklist & Houston Area Operations Contractor Administrative

Manual policies Site/Maintenance/Responsible Care Standards, Procedures (ref. CD of Site Rules, safety council,

TOCAS link, etc.) Safety Rule Book, as applicable (each contract employee has a copy) Contractor Balance of Consequences (BOC) Program – violations result in QSPP* Incident (including Spills) / Injury or Illness Reporting Policy* Pre-Task Analysis - STAC (contract company ensures crews are trained, given coaching) Near Miss Program – Safety Opportunity Sighting Program (SOS) Emergency Response Procedures (Site Safety Rule Book, as applicable) Threats of Violence Policy (Site Safety Rule Book, as applicable) Chemicals on Site – MSDS Waste identification, collection, and disposal – Cardboard & Scrap* Non-Smoking Policy* Knife Policy* Trailers – safety chains (Site Safety Rule Book, as applicable) Security Awareness (acquired at Safety Council) Other (site specific)

(*Included in Houston Area Operations Contractor Admin Manual)The site supervisor will be held responsible for ensuring that his/her crew is familiar with the abovementioned policies, procedures, and guidelines associated with the work that is being performed.

Yes No

10 The following unit specific information shall also be provided prior to the start of work: Guest in the House Program \ Building Sign-in Procedures Emergency Response Unit Specific - Local fire/evacuation alarms, pull stations, evacuation plan Location and use of safety showers and eye wash stations Hazard CommunicationNote: Compliance is achieved by a safe work permit

Yes No NA

11 Safety Personnel qualifications/training: OSHA Construction 10 hr. □ 30 hr. □OSHA General Industry 10 hr. □ 30 hr. □

CSST Certified □ CHST Certified □ OHST Certified □ CSHO □Competent Person:

Excavation □ Scaffold □ Fall Arrest □ Steel Erection □ Other:__________Other qualifications/training (degree): _______________________________________

Does the safety representative have all applicable safety council training for the workbeing performed?

If no when will this training occur? Date: _______________Review Safety Personnel responsibilities (ref. Houston Area Operations Contractor Admin Manual)

Ratio of safety personnel to crew: # of Safety Personnel ____ # of Employees ____

How will personnel temporarily given safety reporting/supervision/injury case managementresponsibilities be qualified/approved in order to fulfill role responsibilities prior to assuming the role?Specify: ____________________________________________________________________________

Yes No

H. Communication

1 Contractor has identified all subs to be used and plans in place to ensure communication ofsafety requirements to subs? (List of Subcontractors identified on first page.)

Yes No NA

2 Project paperwork/report needs defined and communicated? Yes No NA

3 Process to review this pre-job with new and/or all workers before starting work in the field?Assurance that all workers understood the pre-job? Pre-job posted?Location:_______________

Yes No






Table of ContentsH. Communication

4 Has a kickoff safety meeting been scheduled?When ___________ Location ___________

Review agenda, presenters, required attendance, etc.

Yes No NA

5 Have frequencies and attendance been established for group/site safety meetings (to includeALL individuals involved in project)?

Daily □ Weekly □ Other (Specify) ____________Who determines safety meeting topics?: Name/Role: __________________________

Yes No NA

6 Review process for shutting down unsafe jobs. Communication when this occurs. Yes No NA

7 Each employee will complete pre-task daily and re-assess as the job scope changesthroughout the day.

Yes No NA

8 Reviewed cell phone, pager, radio, camera (none allowed including cell phone), etc. usepolicy

Yes No NA

9 Review process to verify workers comprehension of tailgate / safety meeting content. Yes No NA

I. ProceduresEmergency Response/Accountability

1 Review emergency phone number(s) Yes No

2 Are existing emergency procedures adequate for project conditions and additional personnelload? Consider possibly: Additional assembly points needed, etc.

Spills, Fires, Freeze, etc.

Yes No

3 Are available safety showers and eye wash facilities sufficient? Location? Alarmed?Alternate system in place is not available?

Yes No

4 Review Firewater use: not allowed for welding/cutting/etc. Firewater is for the emergencypersonnel only. If there is a need for their service, please do appropriate planning prior to thejob with an Emergency Director/ES&S personnel.

Yes No

5 Contractor process in place for accounting for personnel in emergency? Yes No

6 Review expectations for participation during drill. Yes No

7 Alarm/alert system reviewed?Alert: ___________________________________ All Clear: ________________________________Evacuation: ____________________________ Siren/Alarm test (day and time): __________________

Yes No

Injury/Illness

8 Review Injury/Illness Reporting requirements Yes No

9 Review mandatory ambulance call requirements? (Foreign material in the eye, chest pain,Exposure to toxic or corrosive material, Any loss of consciousness, person in obvious/serious distress.)

Procedure for requesting ambulance?

Yes No

10 Determination of medical facility for treating occupational injury/illnessLocation:__________________________________________________________

Yes No

11 Fit for Duty responsibility (return to work review after occupational injury/illness, how manyhours/days employees can work without time off, etc.)Name/Role:____________________________________________

Yes No

12 Review use of DOW Medical facility (if on-site). Yes No NA

13 Review contractor process for treating minor injuries Yes No NA






Table of ContentsI. Procedures, cont.

Injury/Illness (cont.)

14 If first aid to be administered on-site by contract personnel Persons trained in first aid and applicable regulations

Review disposal of medical waste

Yes No NA

15 Who is responsible for case management in the event of an injury?Name/Role: ____________________________________ Phone #: ______________________

Yes No

16 Work hour collection Yes No NA

Project Inspection/Housekeeping

17 Initial site inspection completed? Plan to ensure site safe conditions in place before any work gets startedand continue throughout the project – level walking surfaces, take care of holes, uneven walking surfaces.

18 Expectations for housekeeping Yes No NA

19 Is a detailed housekeeping plan required? If so, has it been submitted for approval? Plan willbe submitted by:__________________________________

Yes No NA

20 Job-site inspected by contractor persons responsible for safe job completion? Yes No NA

21 Additional trash containers brought in and properly labeled? Yes No NA

22 Disposal plans in place for other wastes? Plant has adequate waste containers available? Containers must be properly closed, sealed, labeled,

and moved to waste storage area Contact for waste issues

Yes No NA

23 Minimum housekeeping requirements established and communicated? Hoses rolled if not in use, Cords etc. out of traffic lanes? Barricade tape maintained while job in progress but removed as job completed?

Nails etc. bent or removed from boards?

Yes No NA

24 Time allowed for housekeeping? Yes No NA

25 Areas of possible congestion identified and plan to minimize? Yes No NA

26 Plans to minimize tripping hazards across walkways/aisles/ladders? Yes No NA

27 Are there any extra ordinary housekeeping requirements?Note: Poor housekeeping will result in work being shutdown at contractor’s expense.

Yes No NA

MOC

28 “Management of Change” documentation completed for all jobs which will result in changes? Yes No NA

29 Method to communicate to all effected individuals Yes No NA

30 Method to document changes that have been implemented Yes No NA

Medical Surveillance

31 Are there chemicals involved that will require individuals to be in a medical surveillanceprogram?

List:____________________________________________________________________

Yes No NA

32 Who will coordinate the physicals and monitoring Yes No NA

33 Where will documentation be kept?Location: __________________________________________________

Yes No NA






Table of Contents

J. Standards/RulesAll sections that are applicable per job scope must be reviewed (PPE section applies for all jobs)

Note: This includes Emergency or Infrequent, Non-resident contract company work.

General

1 Prime contractor provided with copy of the Houston Area Operations ContractorAdministrative Safety Manual?

Yes No

2 Contract Company Safety Standards available for workers in fieldLocation of Field Copy: ________________________

Yes No

3 Have variances been approved for all jobs which will not strictly adhere to applicable safetystandards? Specify Safety Standard Variance and specific task:

1) __________________________________________________________________2) __________________________________________________________________Other: ___________________________________________________________________

Yes No NA

4 Has contractor completed JSA (jobsite Safety Analysis) and has it been submitted to DOWrepresentative(s) for review?

Yes No

5 Jewelry policy reviewed? Rings? Watches? Yes No NA

Personal Protective Equipment (PPE)

6 Review Dow minimum PPE, related requirements, exceptions? Hard Hat, Safety Glasses with rigid side shields, Chemical goggles required on person in process

areas – site specific, Hearing Protection (single vs. Double) Glove Policy Clothing (long pants, short sleeves, etc.)

Footwear (no canvas, safety shoes, impact soles, etc.)

Yes No

7 Additional PPE identified for jobs not already covered?Respirators, flame resistant clothing, flash suit, faceshield, metatarsal guards, slicker suit, rubber bootsand gloves, etc.

Reviewed DOW PPE Grid(s) (Maintenance, facility, etc.) which specifies minimum PPE fortasks/tool use and protection from chemical exposure?

Yes No NA

Yes No NA

8 Appropriate types and amounts of PPE readily available? Who will provide?Hearing protection competent person: ___________________________________

Yes No NA

9 Procedures in place for proper use and disposal of above? Yes No

10 Any exceptions to Dow designated PPE areas within plant during project?(Goggle areas, hearing protection)

Exception(s): _____________________________________________________________How will this be communicated and/or marked? ____________________________

Yes No NA

11 Additional areas should be designated during the project. Portable noise sources (crane, generator, etc.): _________________________________, Asbestos removal areas: ___________________________________________________,

Other: __________________________________________________________________

Yes No NA

12 Persons required to wear respirators medically approved & fit-tested? Yes No NA

13 All personnel properly trained in PPE required for job? Yes No

Safe Work Permit

14 Daily job lists to be made available? Due by: ____ p.mGiven to: Name/Role: ____________________________________________

Yes No NA

15 Permit issuers identified (project / turnaround):Names / Roles: 1) ________________________________________________________________________

2) ________________________________________________________________________

Are additional ones needed?

Yes No NA






Table of ContentsJ. Standards/Rules, cont.

Safe Work Permit, cont.

16 Will any jobs not require permits or on-site inspections? Identify:1) ____________________________________ 2) __________________________________Other: ______________________________________________________________________

Yes No NA

17 Additional permit needs identified (Hydroblasting, Confined Space Entry, etc.)?List any permit needs here that are not identified in specific sections:

1)_____________________________ 2) ________________________________3) ____________________________ 4) ________________________________Others: ______________________________________________________________________

Yes No NA

18 Schedule established to minimize problems during permitting?Staggered times, extra permit writers brought in, etc.

Yes No NA

19 Plans/discipline in place to ensure work stays within defined scope?Includes only that area or tasks covered during on-site inspection

Yes No NA

20 Permit receivers understand cancellation/expiration, or reauthorization process? Closeout?Permit Receivers identified: Names / Roles: 1) ________________________________________

2) _________________________________________

Yes No NA

21 Process in place to assure that all personnel on permit have received appropriateindoctrinations?

Yes No NA

Lockout or Tagout – Isolation of Energy

22 Persons available for Red Tag isolation verification (Job Representative - job aide available)?Names / Roles: 1) ______________________________________________________________

2) ______________________________________________________________

Yes No NA

23 Which system to achieve 100% control and accountability of all personnel and isolatingdevices will be used:

Master Red Tag System? □ Individual Red Tag System? □

Yes No NA

24 Will individual tags or Exclusive Control be used?If so, review requirements Are Energy Control Operating Procedure’s written and approved?

Are workers authorized procedure users (AOPU) for specific facility with documentation onfacility authorization list, trained on their specific Red Tag requirements, trained on facilityProcedure Use Policy requirements, and trained on specific procedure?

Yes No NA

25 Tag location listings developed for individual Red Tag?(job aide available for Persons Working under Isolation)

Yes No NA

26 Return to Operations / Re-commissioning plans completed and approved by facility? Yes No NA

Line & Equipment Opening

27 Means of positive identification for openings established (tag, paint, photo, diagram, etc.)?Specify: _____________________________________________________________________

Yes No NA

28 PPE requirements established and PPE available? Yes No NA

29 Emergency plans in place? Yes No NA

30 Decontamination and isolation plans in place? Spill containment plans? Yes No NA

31 Are any LEO Escalations needed – site specific? Hazard Analysis completed? Approvalsobtained?

Equipment: 1) ___________________________ 2) _____________________________Other: __________________________________________________________________

Yes No NA

32 Is approval needed for openings (flammable/combustible)? Hazard analysis completed?Grounding requirements understood and equipment available?

Yes No NA







Line & Equipment Opening (cont.)

33 Environmental Contact has accounted for emissions from opening? Yes No NA

Confined Space Entry

34 Permit requirements reviewed? (SWP, CSE Checklist, CSE Operating Procedure, Rescue Plan)Yes No NA

35 Cleaning/clearing plans complete? Reviewed? Yes No NA

36 Isolation plans complete?Approval if double block and bleed used for isolation

Yes No NA

37 Security/Rescue Team notified Rescue Plans complete

Equipment available (respirators, harnesses, etc.)

Yes No NA

38 Trained Attendants available (CSE Attendant Safety Council training, Safety Attendant Job Aide

reviewed with Attendants, CSEOP with Rescue Plan reviewed)?Yes No NA

39 Trained air monitoring personnel available? Yes No NA

40 List of required equipment established & available for each entry?Respirators, O2/Combustible analyzers, air movers, etc.

Yes No NA

41 Proper lighting available? (specifications are listed in Global CSE standard)Yes No NA

42 Communication plans developed? (radio, etc.)Yes No NA

43 Plans for addressing heat stress while in confined space? Yes No NA

44 Planes for providing adequate ventilation? Grounding requirements reviewed? Yes No NA

45 Plans reviewed & approved by EH&S & IH for: entries not cleaned below OEL

could introduce contaminants into space (welding, painting, etc.)

Yes No NA

46 Plans in place to reduce hazards if welding inside confined space?Dust fires, accumulation of fumes, etc.

Yes No NA

47 Is grinding etc. to be done on fiberglass reinforced plastic vessels?IH approval with monitoring required unless supplied air full face or SCBA used

Yes No NA

48 Contractor procedures needed? Completed? Yes No NA

Motor Vehicle

49 Will company or personal vehicles be driven on DOW property? Yes No NA

50 Contractor Supervision/Safety personnel reviewed the site Motor Vehicle requirements. Yes No NA

51 Employees have reviewed the vehicle related sections of site Safety Rule Book, as applicable. Yes No NA

Excavation

52 Applicable Excavation Permit requirements reviewed?Review any special requirements identified by the following groups: Environmental Coordinator (handling of excavated materials) Industrial Hygiene (PPE) Engineering (underground drawings) Electrical Maintenance Technical Services (if near cathodic protection)

Utility Distribution

Yes No NA







Excavation (cont.)

53 Competent persons available for inspectionsSupplied by: ______________________Name/Role: _________________________________________________

Yes No NA

54 Review procedures if excavating near buried lines (including cycle water) hand tools within 3 (1m) feet after positively located & probed then owner may approve mechanical means hydro-excavation

Yes No NA

55 Barricading plans determined (traffic lanes, etc.) Yes No NA

56 Adjacent structures protected from undermining? Roads, sidewalks? Yes No NA

57 Precautions planned if personnel to enter excavationWritten excavation safety plan for each excavation (contractor) Sloping? Shoring? Shielding? removal of water Use of GFCI safe means of exit (no more than 25 ft from work area) excavated material at least 3 ft back from edge sloping/shoring plans (if > 4 ft deep)

approved by Prof Engineer (or purchased system)

Yes No NA

58 Is excavation considered a confined space?could hold or contain hazardous atmosphere

If so, see Confined Space section.

Yes No NA

Tools

59 Tool inspections scheduled?Who will perform the inspections?: ____________________________________Specify Periodic Inspection Frequency: _________

Employee Pre-Use Inspection Required?

Yes No NA

60 Tools supplied by: Contract Company □ Employee □ Yes No NA

61 Employees trained on specified tools? Yes No NA

62 All special tool needs identified? Yes No NA

63 Special training/certifications needs identified (Powder Actuated Tools, etc.)?Trained persons available Supplied by:___________________________

Yes No NA

64 A skills assessment program in place & documented? Yes No NA

65 Modified or home-made tools reviewed and approved? If yes, a written procedure for usemust be available at the job site.

If yes, list: ________________________________________________________

Yes No NA

66 All pipe stands have anti slip devices & capacity labels? Yes No NA

67 Holders used or tools secured for hammer struck tools?(do not allow one person to hold while other strikes tool)

Yes No NA

68 Appropriate use of nail guns reviewed? (depress end then squeeze trigger) Yes No NA

69 Review of PPE grid requirements for specific tools? Yes No NA







Heavy Equipment

70 Required equipment identified and available? Supplied by: _______________________Type: _____________________________________________________________________

Yes No NA

71 All equipment inspected and in good condition?Operating manual and instructions available to operator?

Yes No NA

72 All operators properly trained and certified? Yes No NA

73 Proper planning of routes and precautions for overweight or over height transportation?Escorts?

Yes No NA

74 Plans in place for refueling needs? (discourage bulk storage)If used, grounded storage tanks, labeling, fire protection?Secondary Containment?

Yes No NA

Elevated work

75 Elevated Work hazards identified. (review Dow Elevated Work definition)Fall Prevention/Protection Plans for Critical Elevated Work developed? Approved? Critical Scaffold erection and dismantling: Non-routine use of aerial lift devices Use of crane-suspended work platforms. Work on elevated surfaces (e.g., cable trays) that are not protected by permanently installed fall

prevention/protection systems.

Work that creates a life-critical fall hazard (e.g., by removing grating, removing manhole covers, etc.)

Identified hazards included in JSA?Will work involve Steel Erection? Competent person: _______________________

Yes No NA

Yes No NAYes No NA

76 Plans in place for elimination/reduction of hazards? Use hierarchy (eliminate / prevent / protect) Options for safeguards must be selected from the Dow Global Elevated Work standard "Acceptable

Options" document.

Include protection for work off of ladders (fall protection required when working from ladder and>6ft from grade)

Yes No NA

77 Work surface can support the load required?Roof Access required? SWP requirements for roof access – site specific.

Yes No NA

78 Ladder use reviewed?Ladders allowed (step, wood, extension, fiberglass, metal, scaffold, tank builders, “A” frame)reviewed? Tank builder ladder inspection program reviewed?

Yes No NA

79 Minimum fall protection equipment requirements reviewed? Harness (not belts), deceleration device, Double lanyards, Locking snap hooks Protection must be continuous No knots in load bearing lines Acceptable / Unacceptable anchorage points Exclusive use of equipment (equipment used for rigging must not be used for fall protection)

Prior to use inspection

Yes No NA

80 Equipment to be provided by: __________________ Yes No NA

81 All fall protection equipment inspections current?If equipment supplied by contractor, discuss how inspections are documented.Competent person to inspect:_________________________________________

Yes No NA

82 All users trained in specific equipment to be used? How is this tracked? Yes No NA

83 Review requirements for work in pipe racks & cable trays such asNo walking in cable trays, Lined/Insulated pipes, etc.

Is cable tray access needed? Review permit requirements (Cable Tray Access Checklist).

Yes No NA






Table of ContentsJ. Standards/Rules, cont

Elevated work, cont.

84 Will positioning systems be used?Equipment designed for positioning?Will fall protection be used in combination?

Yes No NA

85 Are suspension systems to be used?Separate fall protection required (including anchorage)?

Yes No NA

86 Are safety nets to be used? Approvals needed? Yes No NA

87 Are there any special rescue requirements?Buddy system, crane basket readily available, etc.?

Yes No NA

88 Will aerial lifts be used? Tie off requirements reviewed? Inspection requirements (including

checklists) reviewed? Rigging limitations/requirements reviewed?Yes No NA

89 Site minimum anchorage requirements reviewed?Is a fall prevention plan required (fall protection not feasible, ref. DOW Global Elevated Work)?

Date submitted for approval:________________________Competent person:_______________________________Site Leader approval obtained? Business Manufacturing Leader or equivalent approval obtained?

Yes No NA

Hot Work, Welding & Cutting

90 Alternatives to field hot work considered? Yes No NA

91 Hot Work Procedure needs considered? Yes No NA

92 Type of equipment needed identified and available?Type: _________________________________Supplied by: ____________________________

Yes No NA

93 Appropriately trained persons available/scheduled?Competent person (determine flammability of coatings): _______________________________

Yes No NA

94 Plans in place for inspection of welding rigs when brought on site? Yes No NA

95 Placement and securement of Oxy/fuel cylinders reviewed? Yes No NA

96 Minimum requirements for oxy-fuel welding/cutting reviewed? Continuous eye protection Dedicated oxygen regulators Regulator to limit acetylene to 12 psig (0.8 bar) Combination reverse flow check valve and flame arrestor on torch handle Reverse flow check valves at regulators Adequate ventilation

Yes No NA

97 Minimum requirements for arc welding/cutting reviewed & understood? Grounding of AC units Attach return lead as close as possible to work Remove electrode when moving Protect terminal leads (hinged cover, insulating sleeve, etc.)

Use of GFCI if AC unit to supply power

Yes No NA

98 Special PPE needs for hot work identified and available?(Review PPE Grid for minimum requirements)

Yes No NA

99 Spark containment plans in place? (Tig welding - Need to use welding screens where people/traffic may be

affected, Use of enclosures/tarps on scaffold – need to assess for critical elevated work, etc.)

Protection from flammable sources included (leaking flanges, trenches, hoses, etc.)? Can enclosures hold/contain welding fumes, inert gases, etc.? Temporary Enclosure Checklist hazard assessment required (site specific /completed prior to erection)? Will CSE apply? If so see CSE section.

Yes No NA

Yes No NAYes No NAYes No NA







Hot Work, Welding & Cutting (cont.)

100 Fire fighting equipment needs identified and available?Firewater use is not allowed unless Emergency Director/ES&S approval obtained.

Yes No NA

101 Fire watch needs identified? (Review plant fire watch policy) Yes No NA

102 Trained/Certified fire watch available? (Reviewed Hot Work Safety Attendant Job Aide?)Supplied by: _________ Fire Watch names:_____________________________________

Yes No NA

103 Hot tapping required? Permit requirements reviewed?Hot Tap Request (Engineering Evaluation) approved?Hot Tap Inspection list reviewed?

Yes No NA

Hot Work on equipment not isolated and cleared

104 Written hazard analysis / procedure available and addresses: design stress calculations flow rates and temperature equipment testing & nozzle reinforcement

pressure testing before/after reinforcement

Yes No NA

105 Appropriate approvals obtained:1) Hot Tap Request/Final Approvals (DOW Hot Tapping standard) if applicable2) Production Leader + Site Responsible Care Leader as appropriate

Yes No NA

106 PPE identified and available Yes No NA

107 Product containment and disposal plans in place Yes No NA

108 NDT thickness test complete and acceptable Yes No NA

109 Emergency procedures in place isolation devices Identified (consider need for knowledgeable DOW person at isolating devices) means of communication established

fire protection equipment available

Yes No NA

Scaffolds

110 Fall Prevention/Protection Plan completed and approved for Critical Scaffold erection anddismantling (Dow Critical Elevated Work): Cantilevered Scaffold Suspended platforms Scaffold tents Balconies exceeding 3 feet (1 meter) Scaffold that uses an existing building or structure for support/anchorage and the distance

between the edge of the scaffold and the existing building or structure is >1 foot (30 cm)

Scaffold bridges longer than 25 feet (7.5 meters)

Yes No NA

111 Safety or Emergency equipment not blocked by scaffolding?fire extinguishers, safety showers, critical valves, etc.

Yes No NA

112 Minimum Requirements reviewed and understood: minimum 18” (46 cm) platform width? ladders 3 rungs above top rail, min. 42” (107 cm) above platform? max. 12” (30 cm) step across distance from ladder to platform? sufficient clearance for climbers behind ladder? ladder safety device if > 30 ft (9 m), landing platforms at 35 ft (10 m)? cleats or boards nailed to toeboard for stability? Stairs, incline ladder, or straight ladder with retractable lanyard?

continuous fall protection during scaffold construction?

Yes No NA

113 Scaffold crews trained by competent person?Competent Person:_______________________

Yes No NA







Scaffolds (cont.)

114 Competent person available to inspect finished scaffold prior to use and each shift of use?Competent Person: _____________________________________________________________

Yes No NA

115 Employees working off of scaffold properly trained? Yes No NA

116 Timing determined (how far in advance are crews required?)Yes No NA

117 Incomplete Scaffold/Pencil Board Checklist required?Plans in place for covering of floor holes or guarding of open guard rail generated?

Covers either secured or labeled, attended until corrections made?

Incomplete Scaffold/Pencil Board Checklist with plan approved?

Yes No NA

118 All scaffolds >75 ft / >125 ft submitted to Engineering for review? Yes No NA

119 Suspended scaffolds required? suspensions mechanism rating 6 X load?

fall protection separate from suspension mechanism?

Yes No NA

120 Are scaffold erectors/dismantlers able to maintain safe access and fall protection requirementsper DOW requirements?If not, has a fall prevention plan been approved? (Site Leader and Business ManufacturingLeader/Equivalent approved?)

Yes No NA

Critical Lift

121 DOW Mobile Hoisting Standard reviewed: Definition of critical lift (>75% of rated capacity, >50% of rated capacity and lifting over process

equipment or power lines, 2 or more booms- including tailing a load, poles or derrick, travelingwith >50% rated capacity, personnel lift, site specific - adjustable devices used under the hook e.g.chainfall or used to transfer from hook)

Crane PTA card requirements for all lifts/critical lifts, Site specific - Crane Mobilization Checklist, SWP, Critical Elevated Work – Fall Prevention/Protection Plan & Personnel basket checklist, Electrical Standard requirements - Lifting near power lines

Yes No NA

122 Lifting plan in place and equipment needs identified?Size / type of rigs: ___________________________________________________________Supplied by: _______________________________________________Crane competent person(s): ____________________________________________________

Yes No NA

123 Will there be any specialized heavy equipment and/or transportation needs?If yes, advise contact prior to needing “in plant” routing.

Yes No NA

124 Equipment inspected prior to site access? Prior to use? Yes No NA

125 All crane operators properly trained and certified/licensed - NCCCO? Yes No NA

126 All riggers properly trained and qualified? May also require NCCER certification for criticallifts (see site policy).

127 Knowledgeable persons to review lift permit identified?Name: ____________________________

Yes No NA

128 2 sources for load weight verification available – site specific? Yes No NA

129 Plans to minimize potential hazards for lifts over process equipment? Yes No NA

130 Plans to minimize potential hazards for lifts near Overhead power lines? Yes No NA







Personnel Lifts

131 Equipment needed identified, available, with current inspection?Type:Supplied by:

Yes No NA

132 All materials to be lifted along with personnel fit within horizontal confines of basket and nomore than 100 lbs (45 kg) extends above handrail.

total capacity not to be exceeded

Yes No NA

133 Review precautions if welding to be done from the lift Yes No NA

134 PPE identified and available (fall protection, respirators, etc.) Yes No NA

135 Equipment operators qualifiedSupplied by:

Yes No NA

136 Special precautions for personnel crane baskets reviewed & understood (Fall Prevention Plan,Crane Basket Checklist (site specified), and SWP required): load < 50% of crane capacity? power up/power down and two block prevention device (verify prior to lift)? winch brake system inspected in last year? locking load hooks and tagged safety cable? boom angle indicator if variable angle? boom length indicator if telescoping boom (or second qualified operator to verify lift angle)? no other lifts, no traveling with crane while persons lifted? lift plan documented? communication means identified (radios preferred)?

proof testing and trial lift procedure in place?

Yes No NA

137 Approval required for use of Bosun Chairs; requirements reviewed and understood (permit &

fall protection plan required): approved & inspected prior to use by paint contractor, structural integrity of anchor checked

Yes No NA

Electrical

138 GFCI’s available at breaker or receptacle(s) in work area? Yes No NA

139 If not, sufficient portable GFCI’s available? where portable equipment, tools, & extension cords used outdoors, in shops, and in wet locations placed at the source

testing procedure understood

Yes No NA

140 Will GFCI’s be used in hazardous areas? Yes No NA

141 If yes, continuous explosion proof equipment available?if not, fire watch required?

Yes No NA

142 Which option used for electrical protection on construction site?GFCI’s or Assured grounding (if allowed)

Competent Person for Assured Grounding program: _________________________________

Yes No NA

143 Will temporary power be needed? For contractor or plant owned equipment?Approval for plant owned equipment by:_________________________________________Contractor Owned provided by:_________________________________________________Voltage needed: _________________ Amperage needed: ________________Portable generators tested and tagged (plant owned or contractor owned)?

Yes No NA

144 All extension cords free of cuts/breaks/burns and provided with ground plugs? Yes No NA

145 Will work require persons or equipment to be within 10 feet (3m) of overhead power lines?Where?:__________________________________________________________

If yes, has electrical distribution reviewed & approved work

Yes No NA







Electrical (cont.)

146 Does job involve work on electrical equipment?If yes, are workers properly qualified for the work?

Electrical Instructed Person (Perform Class B, C and D energized electrical work): Perform specific electrical tasks (> 50 Volts and < 600 Volts), and/or May be required to work inside the ESHD and/or EAFHD.

Electrical Skilled Person (perform Class A-1, A-2, B, C, and D energized electrical work): energized electrical work or potentially hazardous electrical switching or

work within the ESHD or the EAFHD of exposed energized electrical parts

Yes No NA

147 If yes, review requirements for penetration of clearance zones? voltage testing prior to work verifying test equipment prior to and after use possible PPE requirements

procedure if testing requires penetration of clearance zone

Yes No NA

148 Does project involve work on energized electrical circuits? (ref. DOW EWP 30 – EnergizedWork section)

Will Class A-1 electrical work requiring an Energized Electrical Work permits be performed?

Will Class A-2 or Class B electrical work requiring an Energized Electrical Work permit orProcedure be performed?

Class C electrical work □ Class D □

Expected voltage:____________ Expected amperage:_____________

If yes, are properly approved electrical work procedures available?

Yes No NA

Yes No NA

Yes No NA

Yes No NA

149 Electrical representative available for electrical permit?Supplied by:

Yes No NA

Work On/Near Radiation Devices

150 Safe Work Permit is required. Site requirements reviewed, is work covered under sitepermit?

Site Radiography permit required? Yes □ No □Radiographers using their own checklist? Yes □ No □

Yes No NA

151 Radiation Safety Officer contacted if devices to be received/installed/changed? Yes No NA

152 Licensed Radiographers available? Yes □ No □Competent person: _____________________________________

Yes No NA

153 Limits of "controlled area" identified? Adjacent plant/unit notified of work to be performed? Yes No NA

154 Plans in place for marking of area? Yes No NA

155 Plans in place to control entry into area? Barricades? Is attendant required? Yes No NA

Material Handling & Storage

156 Plans in place for handling of chemicals brought onto site for project?Includes grounding of tanks, etc.

Yes No NA

157 DOT Requirements for Fuel Trucks are in place (placarding, etc.).Yes No NA

158 Training plans in place for communicating chemical hazards? Yes No NA

159 Specific information on hazardous materials brought on site by the provider is made availableto Dow? All materials brought on site are reviewed?

Yes No NA







Material Handling & Storage (cont.)

160 MSDS's available on site including chemicals brought in for project?Location:_____________________________________________

Yes No NA

161 Material Storage / Staging areas identified? Marshalling Plan complete? Drop off point for DOW supplied materials also

Safety requirements reviewed

Yes No NA

162 Material Management personnel prepared to handle material needs? Yes No NA

163 Review vendor delivery and PPE requirements? Yes No NA

164 Flammable Storage areas identified? Yes No NA

165 System for ordering materials for add-ons reviewed Yes No NA

166 All rigging components have capacity marked or tagged?Rigging / Slings competent person(s): __________________________________________

Yes No NA

167 Determine process for use of small lifting equipment such as hoists, small cranes andappropriate rigging. Is equipment and rigging competent person supervising the job?

Yes No NA

Hydroblasting and High Pressure Washing

168 Trigger points for Hydroblasting and High Pressure Washing reviewed?Hydroblasting Trigger: 3600 psig provided that the flow is less than 3.5 gpm, or 1000 psig if the flow is greater than 3.5 gpm or pump capacity exceeds 13 HP at a pressure of greater than 350 psig.Pressure Washing: > 150 psig, but less than the Hydroblasting Trigger

Yes No NA

169 Checklist completed by crew and identified deficiencies corrected? Yes No NA

170 Review process to identify plugged tubes. Yes No NA

171 Equipment needs identified and available? Equipment on approved list? Yes No NA

172 All hoses inspected prior to use? Yes No NA

173 Hoses connected with safety device (whip hose)? Yes No NA

174 Appropriately trained persons available/scheduled including Supervisor (not part of the crew)available to sign off on setup?

Yes No NA

175 Plans in place to inspect rigs when brought on site? Yes No NA

176 Stand-by operator available to observe? Yes No NA

177 Barricaded areas identified? Yes No NA

178 PPE needs identified and available? Yes No NA

179 Plans in place to collect & properly dispose of water? Yes No NA

Coatings and Insulation

180 Will there be any abrasive blasting? Yes No NA

181 Number of Compressors identified and available?Supplied by: __________________________Grade D Breathing Air is required if blasting in Confined Space.

Yes No NA

182 Equipment inspected? Yes No NA







Coatings and Insulation (cont.)

183 Trained personnel available? Yes No NA

184 Ventilation requirements identified? Yes No NA

185 Respiratory and other PPE needs identified and available? Has respirator medical exam andfit testing been completed

Yes No NA

186 Plans in place to control accumulation of dust/sand? Control plume? Yes No NA

187 Has lead abatement study been done? Yes No NA

188 Trained persons available for handling lead based paint? Yes No NA

189 Has asbestos survey been done?Asbestos competent person: _______________________________________

Yes No NA

190 Are gloves available for metal work (see glove policy) Yes No NA

191 Are dust masks required for insulation work? If yes, is medical testing required / completed? Yes No NA

192 Is equipment in hazardous (flammable/toxic) service? If so, refer to the Hot Work section –not cleared.

Yes No NA

Demolition

193 Demolition Inspection competent person: _________________________________Decontamination plans in place for equipment being demolished?

Yes No NA

194 Review procedure for positive ID of equipment / lines? Yes No NA

195 Barricading plans in place for area surrounding demolition? Yes No NA

196 Asbestos identified? Asbestos competent person: ___________________________ trained persons available? adequate PPE? containment plans in place?

Facility notified and permits obtained (10 day notice)

Yes No NA

197 Lead containing materials identified and trained persons available?Lead competent person: ______________________________________

Yes No NA

198 Additional PPE identified and available?special boots, cutting goggles, face shields, etc.

Yes No NA

199 Plans in place for removal of demolished materials / equipment?load luggers / dumpsters, etc.

Yes No NA

200 Decontamination plans in place for equipment being demolished? Yes No NA

201 Compliance with electrical demolition procedures?(Isolation and disconnection, grounding, asbestos present, PCB’s present etc.)

Yes No NA

202 Precautions to reduce hazards from dust accumulation? Yes No NA

203 Does demolition involve removal of a load supporting member?Facility notified and permits obtained (10 days notice)

Yes No NA

204 Will concrete grinding machines be used? Has air permit been obtained? Yes No NA







Pile Driving

205 Reviewed process to be used on this project: Technique to be utilized Type of pile Hammer type, make, model, size, and proper handling Hammer settings Leads to be used Dangers attendant to hammer and type of pile Type of soil to be encountered and at what levels to expect resistance Has each piling location been probed?

Yes No NA

206 Reviewed process for notification of municipal authorities, pipeline owners, powerdistribution owners, and others affected by the work. Particular attention should be given to businesses or authorities that require a specified number of

hours notice prior to proceeding with the work. Know when permission is required to proceed and make sure all crewmembers also know this

information.

Always insure that the foreman on the job has the “one call” phone number for pipelinenotifications on him and that he understands the use of it.

Yes No NA

207 Reviewed safety concerns and PPE for each person to be working within twenty (20) feet ofthe pile driving operation.

Yes No NA

208 Are all employees within 40’-0” radius wearing hearing protection? Is this protectionsufficient?

Yes No NA

209 Are existing emergency procedures adequate for pile blowouts? Safe working radiusestablished for all workers, etc. Pile secured to a choker during first 30% of drive depth?

Yes No NA

210 Process in place for recording blow count safely? Yes No NA

211 If using a structural template to set pile over water, are safety lines in place for the workers tosafely tie off?

Yes No NA

212 Contractor provided with correct pile refusal datum? Yes No NA

213 Are safe area’s located for off-loading pile? Have all crewmembers and delivery drivers beennotified? Location of off-loading area: ____________________

Yes No NA

214 Have precautions been taken to properly place signage on public roadways and contractor hasprovided for traffic control?

Yes No NA

215 Are there any issues, areas of confusion or items needing more discussion? If yes, explain: Yes No NA

Miscellaneous

216 Railroad notified of work within the minimum clearance envelope? Yes No NA

217 Street/road blockage approved by: __________________________(ES&S approval required)

Yes No NA

218 Protection plans in place for jobs involving working over water? Yes No NA

219 Will work involve asbestos gaskets? Persons trained for asbestos gasket handling perregulations?

Yes No NA

220 Is there any other work involve working with lead?Competent person: ___________________________

Yes No NA

221 Will work involve working with cadmium?Competent person: ___________________________

Yes No NA







Miscellaneous (cont.)

222 Will work involve Concrete and Masonry Construction?Competent person: _______________________________________

Yes No NA

223 Will work involve NORM containing equipment? Persons trained - NORM HazCom?Hydroblasters licensed by Texas Dept. of Health?

Yes No NA

224 Radio Inspection (Electrically rated radios required?)Yes No NA

225 Compressed Gas Cylinders (other than for welding)? Yes No NA

226 Will project result in changes to potable water system?If so, complete cross connection requirements

Yes No NA

227 Is a plumbing permit required? Yes No NA

228 Will divers be used? Yes No NA

229 Review contractor work that may cause release of chemicals to the environment?Task(s): 1)______________________________ 2)_______________________________Other: _____________________________________________________________________

Yes No NA

230 All equipment should be placed either in contained area or temporary containment providedto prevent spread of an oil spill, particularly if near water

Yes No NA

231 Review plans for disposal of hydro test waterpermitted outfall or alternate plan

Yes No NA

232 Will project effect one acre or more of ground?Has an NPDES permit been obtained?

Yes No NA

233 Are there any other equipment needs?List powered equipment that will be used on site:

# and type of Compressors: ______________________________________________________# and type of Generators: ________________________________________________________Other: ________________________________________________________________________

Yes No NA

234 Are there any internal combustion engines excluding vehicles that will remain on site for ayear?Included in air permit?Contractor maintains a log of all equipment?

Yes No NA






Table of Contents

GENERAL COMMENTS:






Table of Contents

ALL CONTRACTORS TO SIGN THIS SHEETAFTER REVIEWING PRE-JOB FORM

NOTE : for Capital Projects, return signed copies of all workers who reviewedthis document, at end of project to owners representative

PRINT NAME COMPANY NAME SIGNATURE






Table of Contents

Attachment 1

Action Plans for Items marked "No"

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Responsible: Expected by: Actual Date:

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Table of Contents

Attachment 2

Additional Comments/Details of Requirements

Item No: Comment:

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Table of Contents

Job Safety Analysis (JSA) Guidelines

Purpose To provide a tool that will allow the supervisor to analyze hazards specific to theirtasks. This tool needed to be discipline specific to allow foremen to plan and assignwork while addressing common hazards.

Scope The JSA applies to all foremen on turnarounds and projects.

Guidelines 1. The foreman should complete the JSA during the planning phase of each job. Anew JSA must be completed when there is a change in job location or scope.

2. The JSA should be reviewed with the Superintendent and communicated to thecrew before work begins.

3. As the job progresses, the JSA should be amended to include any changes oradditions to the original job survey.

JSA Forms See attachments






Table of Contents

Safety Analysis (J.S.A.)Civil/Yard

Foreman: ____________________ Job Location: _____________________

Date: ___________________

Plan Work Job Task: ______________________________________________

Job Survey Suggested SolutionsSpecifics-How will

this be done?Overhead obstructions Adequate clearances of pipe racks,

power lines, etc. Determine how many spotters will be

needed.Elevated work Work platforms needed?

Make sure of safe tie-off point.Moving material in Equipment for unloading available?

Are laydown/staging areas away fromcongested areas

Material lifting Is material too heavy/awkward to liftby personnel?

Order lifting device to lift material.Tools to keep hands outof harms way

Determine tool to keep hands out ofharms way.

Train employees on the “Knife Policy”.Special tools needed andinspected

Determine tools needed for the job. Order tools for the job.

Special PPE needed andordered

Determine PPE needed. Order PPE needed for the job.

Work requiring specialpermits(Excavation, Conf. Space,LOTO, etc.)

All procedures written and submitted. All personnel trained?

Excavation Personnel trained in Dow’s M-74Excavation Proc.

Probing and excavation procedureestablished.

Excavation checklist completed as perM-74.

For use at sites of The Dow Chemical Company and participating subsidiaries






Table of Contents



Date: ___________________



this be done?Tight work area Does area need additional ventilation or

shields? Install barriers between work areas.

Personnel training/certification

Identify all craft certification needs. Identify personnel training deficiencies.

Subcontractors Subcontractors pre-qualified? All personnel trained and indoctrinated.

Inclement weather (windand rain)

Order supplies for covering/securingequipment and material.

Alternate work planned for inclementweather days.

Additional PPE on site (goggles, slickersuit, etc.)

Spoil material Equipment washout area designated. Where is the appropriate dumpster

location? Is soil analysis required?

New employees (<6months)

Find out experience level of employee. Discuss rules, expectations, and

consequences with employee. Assign “Buddy” and discuss

expectations.






Table of Contents



Date: ___________________



this be done?Inexperienced employees Determine experience level of

employee. Assign “Buddy” and explain

expectations.Help filling out STACs Have workers on same job complete

STAC as a group Audit cards to ensure proper hazard

identification.Tools and procedures newto employee

Provide specific/documented training. Assign with co-worker experienced

with tools/procedures.Repeaters Are employees repeaters & can they do

the job safely? Discuss requirements and hazards of

job to ensure. Clear understanding.

Illness among employees Should the employee be at work? Assign the person to a low-risk job.

Employee distressed bypersonal issues

Reassign to low-risk work / send home. Assign the employee to a “Buddy”.

Physical ability Does employee have physical ability todo the work?

Match employee’s physical abilities toperform job.

Adequate number ofemployees

Assign adequate number of workers toperform task.

Assign adequate number of workers tocarry materials, ladders, etc.

High – risk jobs (i.e.,excavations)

Assign experienced employees. Have employees work in pairs. Give employees radio for quick

communications.Personnel training /certification

Verify all craft certifications. Verify personnel training badges.






Table of Contents

Job Safety Analysis (J.S.A.)Instrumentation & Electrical

Foreman: _____________________ Job Location: ______________________ Date:_________________

Plan Work Job Task: _____________________________________________________


this be done?Personnel training /certification

Identify all craft certification needs. Identify personnel training deficiencies.

Overhead work Schedule other workers out of areas. Barricade the area.

Elevated work Work platforms needed? Make sure of safe place to tie off.

Adequate access / egress Extra ladders needed in event ofemergencies?

Obtain adequate number of aerial lifts,scaffolds, etc.

Moving material in Equipment for unloading available? Obtain cribbing for conduit and wire

reels. Are laydown/staging areas away from

congested areas?Lifting material toelevated work areas

Crane/Drott needed? Trained and qualified flagmen and

riggers on crew?Material too heavy /awkward to lift bypersonnel

Order lifting device to lift material. Assign adequate personnel to lift

material safely.Tight work area Plan work to spread workers out.

Put up barriers between work areas.PPE needed and ordered Determine PPE needed (i.e., special

gloves for job). Order PPE needed for job.

Special tools needed andinspected

Determine special tools needed for job. Order tools for the job.



Alternate work plans for inclementweather days.

Additional PPE on site (goggles, slickersuits, etc.)






Table of Contents





this be done?Subcontractors Subcontractor pre-qualified?

All personnel trained and indoctrinated.Excavation (installingground rods, utility poles,trenching, etc.)

Permit obtained. All personnel trained. Probing and excavation procedure

established.Work requiring specialpermits(LOTO, ESWP, Elec. HotWork procedure, etc.)

All procedures written and submitted. All personnel trained in permits and

procedures.

Tools to keep hands outof harms way

Determine tools to keep hands out ofharms way.

Order tools for the job.New employees (<6months)

Find out experience level of employee. Discuss rules, expectations,

consequences w/employee Assign “Buddy” and discuss

expectations.Inexperienced employees Determine experience level of


expectations.Help filling out STAC’s Have workers on same job complete

STAC as a group. Audit cards to ensure proper hazard


Provide specific training. Assign with co-worker experienced

with tools/procedure.Repeaters Are employees repeaters & can they do

this job safely. Discuss requirements and hazards of

job to ensure. Clear understanding.

Illness among employees Should the employee be at work? Assign person to low-risk job.






Table of Contents





this be done?Employee distressed bypersonal issues

Reassign to low-risk job/send home. Assign the employee to a “Buddy”.






High-risk jobs (i.e., Hotwork)

Assign experienced employee. Have employees work in pairs. Give employees radio for quick

communications.Personnel training/certification

Verify all craft certification. Verify personnel training badges.






Table of Contents

Job Safety Analysis (J.S.A.)General Mechanical/Construction




this be done?Personnel training /certification

Identify all craft certification needs. Identify personnel training

requirements.Overhead work Schedule other workers out of areas.

Barricade the area.

Elevated work Work platforms needed? Make sure of safe place to tie off.

Adequate access / egress Extra ladders needed in event ofemergencies?

Obtain adequate number of aerial lifts,scaffolds, etc.

Moving material in Equipment for unloading available? Obtain cribbing for equipment, pipe,

steel, etc. Are lay down/staging areas away form

congested areasLifting material toelevated work areas

Crane/Drott needed? Trained and qualified flagmen and

riggers on crew? Are any lifts critical?

Material too heavy/awkward to lift bypersonnel

Order lifting device to lift material. Assign adequate personnel to lift

material safely.Tight work area Plan work to spread workers out.

Put up barriers between work areas.

PPE needed and ordered Determine PPE needed (i.e., specialgloves for job).

Order PPE needed for job.Special tools needed andinspected

Determine special tools needed for job. Order tools for the job.

Tools to keep hands outof harms way

Determine tools to keep hands out ofharms way.

Order tools for the job.






Table of Contents


Foreman: _____________________ Job Location: ______________________ Date: _________________



this be done?Work requiring specialpermits (LOTO, CriticalLift, Confined Space, HotWork, etc.)

All procedures written and submitted. All personnel trained in permits and

procedures.

Excavation (Trenching,Shoring, etc.)

Permit obtained. All personnel trained. Probing and excavation procedure

established.



Alternate work plans for inclementweather days.

Additional PPE on site (goggles, slickersuits, etc.).

Subcontractors Subcontractor prequalified? All personnel trained and indoctrinated. Man-count requirements understood?

Line Breaking Knowledge of chemicals involved. Identify PPE Requirements. Other special requirements

(Medical/Training)New employees (<6months)

Find out experience level of employee. Discuss rules, expectations,

consequences w/employee Assign “Buddy” and discuss

expectations.Inexperienced employees Determine experience level of


expectations.Help filling out STAC’s Have workers on same job complete

STAC as a group Audit cards to ensure proper hazard


Provide specific training. Assign with co-worker experienced

with tools/procedure.






Table of Contents





this be done?Repeaters Are employees repeaters & can they do

this job safely Discuss requirements and hazards of

job to ensure clear understanding.Illness among employees Should the employee be at work?

Assign person to low-risk job.Employee distressed bypersonal issues

Reassign to low-risk job/send home. Assign the employee to a “Buddy”.






High-risk jobs Assign experienced employee. Have employees work in pairs. Give employees radio for quick

communications.Personnel training/certification

Verify all craft certification. Verify personnel training badges.






Table of Contents

Carpenter & Scaffold Builder Policy

Statement of Policy This policy requires all contractor personnel to wear monogoggles when handlingscaffold materials, lumber or doing tasks that may generate sawdust, airbornematerial, or dust.

Scope Carpenters and scaffold builders, whether full time in craft or performing these dutiesand it is outside their normal craft, will wear monogoggles during these operations:

Examples of handling scaffold materials include, but are not limited to:

passing up or down scaffold material

passing up or down tarps

turning over scaffold boards

shaking out tarps

cleaning off scaffolds prior to tear down

Examples of tasks that generate sawdust include, but are not limited to:

sawing

sanding

drilling

sweeping, cleaning, blowing sawdust off of surfaces

handing material up or down

Purpose To eliminate eye injuries for carpenter and scaffold builders during certain activities.

Responsibilities Carpenters and scaffold builders had the majority of the eye incidents in 1999. Theeye protection currently being worn by these crafts is side shield safety glasses. It isthese craftsmen’s responsibilities to upgrade eye protection to eliminate theseinjuries.




Table of Contents

Contractor Craft Skills Assessment Policy

Purpose To clarify craft skills assessment of contractors working on Houston Area Operationssites.

Scope This policy applies to all workers within assessable crafts in maintenance and smallprojects only.

Background This policy is intended to assure consistency with Dow stated goals. It is not theintent to have only “journeyman” in our plants however, we do intend to have a fully“qualified workforce” with documented skills and knowledge.

Policy All contractor employees, working within the crafts listed below will be assessedunder one of the recognized processes. Such processes include the new nationalassessment, the National Center for Construction Education and Research (NCCER);the Industrial Skills Assessment Committee (ISAC); or the Department of Labor(DOL) certifications. These assessments consider both the skills and knowledge toperform all assigned tasks.

Individuals employed with a contractor less than 6 months are considered “in theprocess of being assessed”. A performance and/or written assessment must beconducted and submitted to the NCCER database by the time an individual enters theseventh month of employment with a contractor. Locally it may be submitted toABC, Texas Gulf Coast for entry into this database.

Assessable Crafts This is a list of assessable crafts:

Electrician Instrument Fitter

Millwright Industrial Painter

Welder Insulator

Pipefitter Scaffold Builder

Boilermaker Heavy Equipment Operator

Ironworker Form Carpenter

Instrument Tech Finish Carpenter

Assessment DueDate

Contractor Personnel Skills Assessment update is due quarterly.




Table of Contents

Contractor Training Card Policy

Purpose To allow individuals in the field (i.e. Permit writers) to be able to verify training ofspecific contractor workers.

Scope This policy applies to all contractor workers who have been trained in any of thecategories listed on the "training card" (see example).

Policy Each contractor employee who has been trained in any of the topics listed on thetraining card (see example) must have in their possession a copy of the training cardindicating the company that the individual works for and the most current date ofeach training category that applies.

Each Contractor firm working on the Houston Area Operations sites must furnish toDow Contractor EH&S the latest training dates of each of their employees on thespecific topics identified on the "training card".

Training BadgeCodes

DOW Gulf Coast Contractor Orientation DOWSSROHM & HAAS-DP BP & LONESTAR RHHOUDOW Chemicals Confined Space DWGCSDOW Chemicals Isolation of Energy DOWIoEScaffold User SUDOW Safe Driver DWSD or DOWDRDOW Contractor Industrial Worker DOWCIWDOW Flagger FLAGGRDOW Gulf Coast Pipeline GCPL or GCPDOW SKILLED ELECTRICAL WORKER DOWESPDOW INSTRUCTED ELECTRICALWORKER

DOWEIP

DOW ELEC WORK PRACTICES DOWEWP




Table of Contents

Job & Equip Specific Training for Contractors

Introduction This document exists to define the work process to ensure Contractors receive joband equipment specific training unique to Dow.

Objective To qualify Contractors to perform specialty work at Dow. This training will be sitespecific and job specific for the specific location. This is not intended to replaceContractor EH&S training given at the Contractor Safety Councils.

Work Process Subject Matter Experts will identify and maintain the training courses andupdates in the Job & Equipment Specific Training Table. (covered in pre-jobreview). Site Call Out Procedure should address the issue of specific trainingrequired for work on a particular piece of equipment.

Each craft will have courses outlined.

Contractor Management will train or coordinate to ensure qualified personneltrain all craft personnel working for them at this location.

The Contractor will manage and maintain training records.

The Contract company is accountable for refresher training

Training compliance will be validated through audits of training records, fieldinterventions, and field audits.

Work ProcessBoundaries

Corporate Co-employment requirements

Roles andResponsibilities

The following are the roles and responsibilities for the Job and Equipment SpecificTraining for Contractors.

Role Responsibilities

ContractorManagement

Receive training material from Dow SME

Ensure personnel are trained on material given.

Retrain personnel as required.

Manage and maintain training records.

Dow SME’s Identify training needs and maintain course outlines.

Assist and train where needed.

Notify all affected roles (Planners, Contract Services, Contractor Management)of any changes, additions, or deletions to Job & Equipment Specific TrainingTable.





Table of Contents

Job & Equip Specific Training for Contractors, cont.

Roles andResponsibilities(continued)

Role Responsibilities

Contract Services Inform contract company of required job specific training:

*New hire orientation and *Pre-job meeting.

Ensure required training is completed and documented.

Perform periodic audits to ensure resident contractors are in compliance withrequired training.

Notify contractor company of additions or deletions to the Job & EquipmentSpecific Training Table.

Planner Include job specific training information in the planning package.

Include job specific training requirements in the Contract Service portion of thework order.

Training ProcessThe following table shows the training process for specific training for Contractorsat Dow.

Step Action

1 Contractor completes all required EH&S training.

2 Contractor reports to site for badging.

3

IF …this is a THEN …

Contractor Management reviews equipmentspecific table for applicable training.

Resident Contractor

Go to Step 4.

Contract Services reviews equipmentspecific table for applicable training.

Non-resident Contractor

Go to Step 4.





Table of Contents

Job & Equip Specific Training for Contractors, cont.

Training Process(continued)

Step Action

4

IF …training is THEN …

SME is contacted to deliver the requiredtraining.

Required immediately

Go to Step 5.

SME is contacted to schedule requiredtraining prior to that task being performed.

Not Requiredimmediately

Go to Step 5.

5 Contractor employee records are updated to reflect completion of training.





Table of Contents

Job & Equip Specific Training for Contractors, cont.DOW Maintenance

Craft SpecificTraining

Job & Equipment Specific Training Table needs to list each site’s specifictraining requirements.

Site Craft TrainingDescription

ProcedureTitle and

No.

Duration ofTraining

Delivery Method Tasks orCrafts

Affected

Freq SME

TCO Air Cond 2nd Set of Eyes(as needed)

810467Course &procedure

2 HrsClassrm & 1month OJT

Classroom &Hands-on

AirCondition/Electri

cal

2Y Hollis Cagan

TCO PSM InstrumentProcedure

Trng Course810408

2 Hrs Classroom Instr &Analyzer

Initial Gary Coward

TCO Iso-InstrumentProcedure Q-

Manual

Trng Course810190

1 Hr Classroom Instr &Analyzer

Initial Gary Cowart

TCO

Analyzer

Instrument CraftProcedures

ICP-01 thruICP-20

As Needed WEB-EDMS Instr &Analyzer

Initialplus

refresheras

needed

L. Geters

TCO AutoMech

TCO Bolted JointAssembly

MP-8.01 1 Hr Video Pipefitter& B-MRigger

Initial D.McClellen

TCO

Boilermaker

HydraulicTorque Wrench

Ghris Code350506

1 -1/2 Hrs Classroom (GulfSouth Sweeney)

Pipefitter& BM-Rigger

Initial D.McClellen

Carpenter

CraneOperator





Table of Contents


Craft SpecificTraining(continued)


ProcedureTitle and

No.

Duration ofTraining


Affected

Freq SME

Electrical Safety SH-2.7 2 Hrs Classroom Electrical

3 yrs Pat Holman

Rowan Starters(job specific)

PE5.01.04 &PE5.01.09

2 Hrs Classroom Electrical

Initial Hollis Cagan

2nd Set of Eyes(as needed)

810467Course &procedure

2 HrsClassrm & 1month OJT

Classroom &Hands-on

Electrical & A/C

3 yrs Pat Holman

PCB Training(job specific)

Tng Course710009

1 Hr Classroom Electrical

Initial Pat Holman

Low MedCircuit Breaker

Op

Trng Course350501

4 Hrs Classroom Electrical

Initial Pat Holman

Motor RotationMeter

Trng Course810474

1 Hr Classroom Electrical

Initial Pat Holman

Tic Tracer PE5.01.16 15 minutes Classroom Electrical

Initial Pat Holman

TCO Electrical

EEIP Form Contact HollisCagan

2 Hrs Read before doingTask or Classroom

(large group)

Electrical

Initial Hollis Cagan

TCO PSM InstrumentProcedure

Trng Course810408

2 Hrs Classroom Instr &Analyzer

Initial G. Cowart

TCO BlowbackOverview

Ghris Code350508

0.5 Hr Classroom Instrument

Initial G. Cowart

TCO Instrument CraftProcedures

ICP-01 thruICP-20

As Needed WEB-EDMS Instr &Analyzer

Initial L. Geters

TCO

Instr –ControlSystems

Iso-InstrumentProcedure Q-

Manual

Trng Course810190

1 Hr Classroom Instr &Analyzer

Initial G. Cowart

TCO Pipefitter Bolted JointAssembly

MP-8.01 &Ghris N295

1 Hr Video Pipefitter& IW-Rigger

Initial D.McClellen





Table of Contents


Craft SpecificTraining(continued)


ProcedureTitle and

No.

Duration ofTraining


Affected

Freq SME

TCO HydraulicTorque Wrench

Ghris Code350506

1 Hr Classroom by GulfSouth Sweeney

Pipefitter& BM-Rigger

Initial DonMcClellen

TCO LokringInstallation

Trng Course810333

1 Hr Classroom byRawson

Pipefitter 3 Years DonMcClellen

TCO Rupture DiskInstallation

Trng Course800035

2 Hrs Classroom byBS&B (rep. AWC)

Pipefitter 3 Years DonMcClellen

TCO Valve MaintRepair

Ghris CodeM428 & Trng

Course810340

2 Hrs Video Pipefitter 3 Years DonMcClellen

TCO DOW fieldsketch

requirements

.5 HR Power point Pipefitter Initial DonMcClellen

TCO

Pipefitter,cont.

Flange TaggingProcedure

1 HR Power point Pipefitter Initial DonMcClellen

TCO Rigger-IW

HydraulicTorque Wrench

Ghris Code350506

1 Hr Classroom (GulfSouth Sweeney)

Pipefitter& Rigger

Initial DonMcClellen




Table of Contents

Contractor Site Safety RepresentativeMinimum Expectations

Purpose To ensure that contracting companies follow the minimum expectations forContractor Site Safety Representatives.

The Contractor Site Safety Representative’s primary purpose is to assist thecontractors (prime and sub-contractors) in achieving DOW’s EH&S goals.

A contractor Safety Representative (full or part time) will be identified for allcontractors working at the facility prior to the start of work.

A contract company with 25 or more employees will supply a full time SafetyRepresentative.

Scope Applies to all contractor companies.

Policy Check that the prime contractor has reviewed the pre-job safety conferenceminutes, when used, with all employees on site.

Make sure contractor employees are properly using the Pre-Task Analysis card(STAC) process daily.

Audit the workforce weekly and ensure feedback is communicated in a timelymanner. (A full-time safety representative will perform audits daily)

Participate in all incident investigations and make certain the prime contractorsubmits incident reports in a timely manner.

Monitor the contractors’ daily housekeeping practices.

Ensure that the contractor companies’ weekly safety meeting topics are pertinent.

Intervene on all safety infractions and report these infractions to both theContract Administrator and the prime contractor.

Monitor the site to ensure all contractor employees are participating in the safetyeffort.

Participate in the site behavior based program and complete the minimumdocumented observations/interventions.

Be involved in the safety culture for the site.




Table of Contents

Minimum Certification/Training Requirementsfor Contractor Safety Contacts

Purpose To set minimum requirements for individuals working as Contractor Safety Contactson the Houston Area Operations sites and to raise the level of safety and healthknowledge of contractor safety contacts.

Scope This applies to all Contractor Safety Contacts on Houston Area Operations sites(TCO, La Porte, Deer Park, Lonestar, & Bayport).

Policy Each Contractor Safety Contact working on The Dow Chemical Company Site mustsecure as a minimum Construction Site Safety Technician Certification orequivalent and complete all "site specific" training that apply to work on a DowChemical site. CBT modules are available through one of the local Contractor SafetyCouncils (ARCS member councils) to address most of the site specific needs

Definitions Certified CSST

Requirements include a 100 hour instructional course and tests, current CPR and FirstAid certification, a math module, and at least three years industry experience.

CSST equivalent

The equivalent to the CSST certification includes but is not limited to:

Test out for CSST is available for individuals that can document specific levelsof experience and training.

A Safety and Health Certificate (15 credit hours minimum) from an accreditedcollege

A two or four year degree in safety and/or health from an accredited college

A safety and/or health certification through the American Board of IndustrialHygiene and/or the Board of Certified Safety Professionals of the Americas, Inc.

CBT

CBT stands for "computer based training". CBT is an interactive computer deliveredtraining method currently used by most contractor safety councils.





Table of Contents

Minimum Certification/Training Requirementsfor Contractor Safety Contacts, cont.

Dow SpecificTrainingRequirements

Contractor Safety Contacts must successfully complete the following "Dow Specific"courses:

STAC and Enhanced STAC training

Accident /incident investigation process training

Basic + or Basic + refresher

Red danger tag training (CBT) (Isolation of Energy Sources)

Confined Space training (CBT)

Safe work permit training (CBT)

Vehicle Safety (CBT)

Scaffold user training (CBT)

Fork Lift training (CBT)

Aerial Lift training (CBT)

Requirementimplementation

The requirements listed in this document must be completed by 10/30/07.

Within the first 30 days of access to the site “new" safety contacts must:

complete the Dow Site Specific CBT modules

must be enrolled in the next available set of Safety and Health relatededucational course offered

or scheduled to take one of the certification tests within the next 30 day timeperiod.




Table of Contents

Buddy Policy

Statement of Policy Contractors will assign a buddy to all new employees for their first six weeks. A newemployee is anyone that has been employed less than 6 months. The experiencedbuddy will use the Buddy Checklist to assure all elements are covered in training thenew employee. This checklist will remain on the new employee for the first sixmonths. Any new employee involved in an incident will be required to bring a copyof the Buddy Checklist to the investigation.

Scope This covers all new employees working for the company for their first six months.

Purpose To reduce injuries to new contract employees by formalizing and documenting thetraining and assignment of experienced buddies to new employees.

Responsibilities The foreman will conduct buddy training and will qualify experienced personnelas buddies. The foreman will assign a buddy to all new employees. The buddywill use the Buddy Checklist to communicate job knowledge to the newemployee.

The new employee will identify the assigned buddy on their Pre-Task Analysis.

The new employee will have access to the Buddy Checklist and is responsible forreviewing the Buddy Checklist with the assigned buddy every morning for thefirst week. After the first week the review will occur each Monday morning for amonth. In the event of an incident the Buddy Checklist will be turned in with thePre-Task Analysis. The buddy checklist may be kept with the foreman to assureit is not lost during training.

The foreman will identify the at risk employee by placing orange tape around hishard hat.

The contractor company is responsible for retention of the checklist for theremainder of the first six months.

Criteria forSelecting a Buddy

The buddy will be a responsible person assigned by the foreman to work with the newemployee. The buddy will have a history of safe work. The buddy must be able tocommunicate the expectations of the buddy checklist to the new employee. Thebuddy will communicate the progress of the new employee to the foreman.

Consequences Foremen that have incidents involving new employees that have not been assigned abuddy, according to this policy, will receive consequences to be determined by thecontract company.




Table of Contents

Buddy ChecklistInitial

CompletionSupervisor will set clear expectations and consequences for safe behaviors.Point out the following:

Safe work is the most impressive work – do not take unnecessary risks

Asking for help is not a sign of weakness – ask for help when needed

Do not “manhandle” work when mechanical assistance is needed

Raise new hire awareness of possible hazards

Intervene with unsafe behaviorsRecall current LER’s with employee that pertain to the jobSet a good example for new hire by:

Work in a craftsman like manner

Comply with safety rules and standards that applyVerify the new hire can use tools safely – communicate, demonstrate and observeReview Precautions for Line/Equipment OpeningsReview Precautions for Hot WorkIdentify the following at work site:

Verify minimum training requirements (LO/TO, SWP, Confined Space, VehicleOperator’s license, etc.)

Nearest Safety Shower (Test the shower and Eye wash)

Sharp objects in the immediate work area

Hot/Cold piping or equipment

Communicate the hazards of the chemicals in the area

Review Emergency Procedures and communicate Assembly Point

Location of nearest Fire Extinguisher

Location of nearest Intercom

Point out what they can and cannot do

Precautions for elevated work

Precautions for motorized equipment

Precautions for weather conditionsRequire Compliance to:

Safety Rules and Standards specific to the work being done

House Keeping Policy and Expectations

PPE Requirements and Expectations specific to the job

STAC card – make sure they have identified the hazards of the job and have setmeasures in place to prevent an incident

Address job scope changes on STAC

Buddy New Employee

Today’s Date New Hire DateReview Dates: ____________, ___________, ___________, ____________, ____________, ____________,____________, ____________, ___________: ____________: ____________;

This document is to be kept by the new employee after buddy covers with the new employee.




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Job Representative Roles and Responsibilities for the Administration of“On-Site” Labor Service Contracts

This role as written is designed for EXPENSE Contracts. The Engineering Solutions work process incorporates theseresponsibilities in different roles (project manager, owner’s rep, etc.) – Engineering Solutions work process ensuresresponsibilities of “Job Rep” are completed.

Purpose: To ensure there is a Dow person identified to be responsible for all ContractSuppliers coming on Site.

Definitions

Term Definition

One Time P.O. JobRepresentative

This person, for the duration of the work, acts as the focal point for job specificcontractor requirements in the area of health, safety, and environment for thePurchase Order they are requesting. This is necessary when the MaintenanceContract Administrator or the Discipline Activity Specialist does not administerthe Supplier.

Contract Administrator This person acts as the focal point for job specific contractor requirements in thearea of health, safety, and environment. They monitor day to day performanceof Suppliers with regard to contractual agreements.

Gate Entry Statusdatabase

A list of Suppliers (approved and denied) that have gone through the“Prequalification Process” but may not have been selected for a work discipline.

Job Requestor Initiator of the purchase order that procures contract labor or services.

Labor Discipline ActivitySpecialist (DAS)

The DAS is the focal point for specific work types. They work withprocurement, EH&S, maintenance and users to insure Dow’s policies arefollowed in selection and effective deployment of acceptable contractcompanies. They assure a process is in place to restrict unauthorized craftsmenfrom entering the plant.

Background: This information is used to assure consistency of contractor administration andincrease our ability to leverage the contractor company’s capabilities across the site.

Policy: All contractors providing services, even those under a “ONE TIME PURCHASEORDER” for Dow shall be assigned a Job Representative.

The Job Representative Role will be assigned to the Job Requestor unless someoneelse has been assigned.





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Job Representative Roles and Responsibilities for theAdministration of “On-Site” Labor Service Contracts, cont.

Role of the JobRepresentative

1. Serves as the Contract Administrator for the Purchase Order/Service Contract.See the duties under Contract Administrator Role

2. All contract Companies who’s services are required and who have notdemonstrated EH&S performance acceptance as defined by Contract Safety, mustmeet with Job Rep and Contractor EH&S (SMAT input may be required as well)and work to develop an EH&S Improvement Plan explaining how the ContractCompany will accomplish the work according to EH&S objectives.

3. There are to be no unwritten agreements affecting the terms and conditions of thecontract.

4. Elements of the Conflict of Interest Policy are known and understood by bothparties.

5. A service agreement, a specific contract, or a Purchase Order shall cover allcontractors.

Role of theContractAdministrator:

1. The Contract Administrator acts as the Dow Representative for a specificcontract.

2. Acts as the Dow Primary contact for execution of the contract and the Owner’srepresentative in all contract issues.

3. Is accountable for the contractor’s performance.

4. Shall work with Procurement on the Contractual Terms and Conditions.

Responsibilities Responsibilities Specific to the Contract Administrator:

Item Description

1 Verifies:

the Supplier has been approved in the “Gate Entry Database”. And thatSupplier personnel provided are qualified to perform the work safely.

that the Contract Company has received the Houston Area OperationsContractor Administration Manual, Site Safety Rule Book, as applicable andrelated topics include the Co-Employment Policy, Conflict of Interest Policy,Safety requirements including Site Standards/Policies and any otherdocumentation required by the Pre-Job This information is reviewed with thecontract company by the contract administrator.

that the on site Contractor Management is knowledgeable of the EH&Shazards of the plant and identifies the EH&S Focal Point.

2 Has sufficient knowledge of the terms and conditions of the contract to allow for theproper execution of the work.





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Item Description

3 Provides job scope, details and specific safety requirements, (i.e. Confined space,Lockout/Tagout etc.), to Procurement for contract negotiations between Purchasingand the contractor.

4 Determines, with Contractor EH&S, the need for a Pre-job meeting to be heldbetween the Unit, Contractor Safety and the Contract Company and participate asnecessary. (Follow Pre-Access and Pre-Job Meeting policy)

5 Ensures:

all contractor employees have received the proper Site and Departmentindoctrination.

that while performing work on site, the contract company complies with allthe EH&S requirements of the Dow Global Standard for Non-Dow Servicesand Visitors.

that Contractor EH&S is informed of all EH&S incidents involving theContract Company on our site.

appropriate company participation in all Contractor EH&S investigations.

the Contract Company complies with all reporting requirements as needed.

efforts between contractors are coordinated to ensure minimal interferencebetween jobs.

QSPP’s are entered for all contractor incidents.

the Contract Company provides adequate EH&S resources to the Contractemployees and that an EH&S focal point is identified by the contractor.

lines of communication stay established with the designated contact, qualifiedpersonnel, who will be able to perform the work safely. Qualifications mayinclude craft training, Lockout / Tagout training, Confined Space Training,and other appropriate training required to perform the work safely.

6 Pre-approves with Procurement any modifications to the scope of work that willincrease the cost of the contract, prior to authorization to the contractor.

7 The Supplier and Contract Administrator will review the Recordable or Reportableincident with the Responsible Care Leader and Site Leader if the Supplier incurs suchan incident during the timing of the Contract.





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Item Description

8 The Contract Administrator:

is knowledgeable of the EH&S DOW 06.06 Non-DOW Services and VisitorStandard and the Houston Area Operations Contractor AdministrativeManual.

are familiar with the site and unit indoctrination process and ensures thecontractor is following the process.

will have a designated contact with the Contractor, usually a foreman orsomeone designated by Contractor management.

is knowledgeable of all the regulatory requirements for the discipline and thatarea.

conducts behavioral field audits to ensure that the safety rules are beingfollowed.

tracks contractor headcount and prime costs.

Is accountable for the spending of the contractor on this P.O.

is aware of the billing procedures applicable to their contractors.

will work with Procurement and Contractor Operations and Contractor Safetyin providing periodic performance evaluations of the contractor.

9 The Contract Administrator will have a designated back up in the event of a prolongedabsence from the site and this shall be communicated to the contractor





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Responsibilities Responsibilities Specific to the DAS

Item Description

1 Staying abreast of the changing technologies available.

2 Participation in the Supplier Management Action Team.

3 Participates in qualifying new contractors for that discipline.

4 Using site tools (Databases) to track names, types of work, location of work andCompany, etc.

5 Reports changes in headcount to site leadership as defined for that site.

6 Acts as a Focal Point for requesting and approving additional contractors.

7 The DAS participates in the DAS Network to assure the contractors are hearing thesame message and there is consistency across the site.

8 Assures use of craftsmen who have had the appropriate skills assessment.

9 Ensure that all QSPPs have been appropriately investigated.

Business Rules

Item Description

1 A Service Agreement, a Specific Contract, or a Purchase Order must cover allContractors working on site.

2 All needs of the plants / departments for a contracted for service will be directed to theappropriate DAS.

3 All Contractors:

in the plant with a One Time P.O. shall have a Contract Administrator/JobRepresentative.

receive a site and unit indoctrination covering the unit rules, applicablepolicies, details of specific hazards, and emergency procedures including spillcontainment plans.





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Business Rules(continued)

Item Description

4 All Contract Companies:

must comply with Gate Entry requirements as specified by procurement.

shall be managed consistently across the site from a set of Policies andProcedures; the “Contractor Administrative Manual”.

shall inform the DOW units of any hazards they bring to the site which mayaffect the DOW Unit or personnel.

5 Procurement, Contractor Safety, the Business EH&S Leaders and the ContractAdministrator shall work as a team in establishing action plans for specific contractcompanies.

6 AMSL:

The AMSL Contract Companies shall be used for services described in theService commodity description.

Contract Administrators shall ensure that the AMSL list of contractors is usedor a MOC is executed.

7 The costs for managing Managed Service Contractors shall flow according toMaintenance Business Rules.

8 The cost of supplying DOW infrastructure to the contractor shall be applied in aconsistent manner with prior approval by appropriate Site Leadership.

9 Where there is value, contractors may be integrated into the common use of I.S. tools,such as GEMTS, Open Plan, etc., consistent with Information Systems Security & UsePolicies and with agreement of the Contract Company Management.

10 The DAS:

may allocate work volume to the preferred contractors with involvement andapproval of Purchasing and Site Leadership.

is kept current on the unit price for the services.




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Houston Area Operations Monthly Contractor Meeting

Purpose The purpose of this process is to ensure that contract companies working on sitereceive pertinent EH&S information

Expectation Contractor Safety meetings will be held on a monthly basis at a central location,which is accessible to all contractors. The meeting will be held on the 4th Tuesday ofthe month from 9am-11am at the Deer Park Whitehouse.

It is also expected that all contractors will be represented at these meetings.

Meeting Format The following format will be followed for each meeting:

Review agenda

Safety moment

Review EH&S Performance

Global Standards & Work Process changes & updates

EH&S Improvement Opportunities

Reward & Recognition

Q & A

InformationSource

The information communicated at the meeting is collected/calculated by ContractorOperations.

Communication The meeting schedules/agendas will be communicated by e-mail.

Texas City SiteContractor SafetyMeeting

There is a site wide contractor safety meeting that must be attended/represented by allcompanies who have a presence on site at the time of the meeting, this safety meetingheld weekly on Thursday morning, 7:35 am, Bldg. 60.




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Maintenance Scope/Cost Change Form Policy for Contractors

Scope Purchase Order Terms and Conditions and Work Process requirements

Policy All Purchasing Dept. purchase orders for the Houston Area Operations sites willinclude a cost based on the intended scope. Contract companies will only be paid theagreed price unless a scope change or price change is approved by the Work ActivityCoordinator (WAC). No other authorization will be accepted.

It is Purchasing's expectation that Contract Companies will track their ongoing costand take a proactive approach to contact the WAC before agreed upon pricing willbe exceeded. Unless new pricing is agreed to Purchasing will only pay the originalPO price.

Job Scope Change Anything outside the original scope of work will require the contractor to contact theWAC and fill out a Scope/Cost Change Form. This must be completed and signedby the WAC before any additional work can begin. It will be determined at that timeif a new PO will be generated to cover the scope and/or price change.

FormRequirements

Signed Scope/Cost Change Forms will be required to accompany supportingdocumentation when invoicing. Summary billing along with supportingdocumentation is required to be sent to the Site 10 days prior to invoicing.

Job ProgressReports

The site Global Maintenance Work Process requires contractors to sign in & out atthe WAC's office and provide job progress prior to 12:00pm each day. In addition,once the job is complete an equipment repair form must be turn in to the area WAC.




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Maintenance Scope/Cost Change Form

Scope This document is used by Maintenance to provide instructions for MaintenanceScope/Cost Change.

Work order #

Purchase Order #

Contractor name

Reason/descriptionfor scope/costchange

The following is a brief reason/description for the scope/cost change:

_________________________________________________________________

New cost estimate $

Building location

WAC approval This change was approved by:

____________________________________ ____________________

(Name) (Date)

Contractorsignature

This change was signed off by:

____________________________________ ____________________

(Name) (Date)

NOTE: Contractors are responsible for filling out scope/cost change form before anywork can begin on a job site due to scope/cost growth. Without WAC approval,DOW is not responsible for payment.




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STAC Training Process

Purpose The purpose of this process is to ensure that all contractor supervisors, foreman andcrew leaders that work for Dow understand the STAC process and know theexpectations.

Deer Park, Lone Star, & Bayport only: Contract Companies will use the DOWSTAC process unless equivalent pre-task process has been previously approvedduring the Pre-Job conference by DOW Contractor EH&S.

Expectation DOW STAC process:

The expectation is that all contractor supervisors, foreman and crew leaders willattend the training sessions and train their crews on the proper use of STAC.

Crew leader/foreman must review and initial each new STAC written by individualsin their crew, (which indicates approval of the card).

The contract company will ensure a management system is in place to addressimprovement in hazard recognition using the STAC process (various components of amanagement system are reviewed in the STAC training for supervisors).

SchedulingSessions

STAC training will be conducted at least monthly by EH&S Delivery;

Second Wednesday of the month from 1:30pm – 3pm at Bldg. 402 for TCO.Schedule through the Job Rep/Contract Administrator or Contractor EH&S.

Second Thursday of the month from 1:30pm – 3pm at Gate 25 Training Bldg. forDeer Park, Lone Star, Bayport and LaPorte. Schedule through the Job Rep/ContractAdministrator or Contractor EH&S.

Special training sessions are conducted upon request. Contractor foreman, crewleaders and anyone the company deems necessary are invited to attend these sessions.




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Injury/ Illness Reporting

Scope To supplement ODMS 6.04 and 6.05 requirements on Emergency Preparedness andResponse. This procedure applies to all site personnel and contractors. Thisdocument does not contain treatment information. Refer to individualdepartmental Emergency Plans. Refer to Departmental or business incidentreporting procedures for additional incident reporting requirements.

Definitions (defined words are italicized)

Term Definition

Alarm boxes: Available at specific sites. Are used to activate the alarm system Each box isindividually identified and are often located near roadways, along the perimeters ofproduction units.

Health Services: Staffed medical facility.

Site Radio System: A system of Hand Held Radio Units and Base Stations throughout the Site.

EmergencyResponse

Emergency Response for Contract Employees.

Step Action

1 Ambulance Must be called for the following medical emergencies by either:

Pushing the Fire alarm box if available at specific site

Or Immediately calling site emergency number

a. Foreign material in the eye

b. A person suffering from chest pain

c. Exposure to toxic or corrosive chemicals

d. Any loss of consciousness

e. A person in obvious/serious distress

2 Direct Emergency Response to location of injured/ ill person.

3 Notify plant IRL (Immediate Response Leader) and area contact (WAC formaintenance or Owner’s Rep for construction) as applicable.

IRL to provide an MSDS to the ES&S DELIVERY SPECIALIST





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Injury/ Illness Reporting, cont.

Non- EmergencyResponse

Step Action

1 For non emergency injuries, such as:

Sprain/strain

Bruises

minor burns

cuts or scrapes

first aid

Spill of bodily fluid (vomit, sanitary sewer overflows…)

bleeding with limited blood loss.

IF … THEN …

A contractor 1. Notify Contractor supervisor to arrange formedical treatment.

2. The Contractor supervisor must callES&S DELIVERY SPECIALIST ANDinform the Permit Issuer or area contact ifno Permit was issued

2 In all cases, direct Emergency Response or Contractor supervision to location ofinjured/ ill person

3 The Permit Issuer or area contact will then notify the IRL as applicable

IRLResponsibilities

(for injuries only)

After Post Emergency Activities, the IRL must make required notifications per DepartmentProcedures. In addition, e-mail the crisis stamp to the IRL/ES&S network. The siteexpectation is for each IRL, receiving the injury notification, to share the information withtheir work group.




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Contractor Incident Flowchart




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Contractor Incident Flowchart, cont.

Contractor completespreliminaryContractor

Accident/Incident/UnsafeCondition Report

Contractor conducts preliminaryinvestigation which includes statementsfrom all involved contract employees

(use Investigation checklist)

Contractor forwards a copyof preliminary ContractorAccident/Incident/Unsafe

Condition Report and STAC toContractor EH&S by 10:00AM

the next working day.

Contractor schedules formalRCI if recordable injury/illness or serious

incident trigger is met - root causeinvestigation- and invites contractoremployees (and plant participants).

Contractor conducts the investigation by the3

rdworking day.

(Complete Cause & Effect diagram withCorrective Actions and include an ABCanalysis if behavior is a Root Cause)

Plant Reviewers andcontractor representative

discuss and resolve

Plant/Area Contact, ContractAdministrator/Job Rep,EH&S and contractor

representative review finalinvestigation report

Contractor forwards final reportby 7

thworking day with

updated Incident/AccidentReport to review team and

communicates as appropriate

Contractor determines the OSHAclassification for Recordable injury/illness

Y

N

Contractor forwards copy of RootCause Investigation Report to andschedules a review with Contractor

EH&S, Plant/Area Contact,Contract Administrator/Job Rep &

Plant EH&S Delivery

A

Do reviewers

detect anyunresolved

issues?

Job Rep/ContractAdministrator ensures QSPPis entered for incident / EAT

entries completed asappropriate

Was theincident aRec Inj/Ill?

N

ContractAdministrator / JobRep schedules SLTReview of RCI andCorrective Actionwith ContractCompany

Y




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Incident/Unsafe Condition Reporting and Investigation Process

Statement of Policy All incidents and unsafe conditions that occur on site will be reported andinvestigated as applicable.

Scope Reporting includes occupational injury or illness, spill or leak, Near Misses,equipment damage, unsafe condition, or other serious accident or incident and safetysuggestions that involved the contractor company.

Purpose To ensure the standardization and criteria for reporting of incidents/unsafe conditionsand investigations.

Responsibilities Contract employees are to report all incidents and unsafe conditions.

Written notification must be submitted for every occupational injury or illness, spillor leak, Near Misses, equipment damage, unsafe condition, or other serious accidentor incident. The Contractor Accident/Incident & Unsafe Condition/Safety SuggestionReport form shall be used.

Contractor management is responsible for communication to the appropriate DOWrepresentatives per the site Injury/Illness Reporting procedure and to ensure that theDow Job Rep is kept informed.

Contractor companies are responsible for developing procedures/policies to assurethe reporting of all EH&S incidents and unsafe conditions that occur within theircompany while on DOW property. The contractor company must assure that all theiremployees understand and follow their policies/procedures while on DOW property.

Contractor companies must provide copies of and retain documentation for all EH&Sincidents and unsafe condition reports. This includes OSHA Injury & Illness Logs,Accident Investigations, Root Cause Investigations, Follow-up for Corrective andPreventative Actions, and other documentation as appropriate.

IncidentInvestigation

Each contractor company is responsible for conducting investigations to determineroot cause of incident. Corrective actions will be developed and implemented bycontractor company to prevent reoccurrence.

Item Description

1 Formal Root Cause investigations (RCI’s) will be conducted by the Non-Dow ServiceProvider for DOW Contractor RCI Trigger Criteria incidents (Injuries & Illnesses,Spills or Leaks, Equipment Damage, and Potential Serious Events see description inRCI trigger table). These investigations will require use of Root Cause methodologyi.e. Cause & Effect. The plant contact, job/owner’s representative, and EH&S shall bepresent at the RCI review.

2 Documentation of the Root Cause Investigations results and corrective actionsassociated with the RCI shall be provided to the Job Representative and ContractorEH&S.





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Incident/Unsafe Condition Reporting and Investigation Process, cont.

IncidentInvestigation(continued)

Item Description

3 Incidents that require Site Leadership Team (SLT) review include:

Day Away from Work Case

Restricted Work Case

Recordable Medical Treatment Case

Potentially Serious Events

Motor Vehicle Incidents.

Note: Some close call/near miss events meet the RCI Trigger Criteria for PotentialSerious Events which may also trigger Contractor Owner SLT review criteria – checkwith your Job Representative.

4 For incidents which do not meet the RCI Trigger criteria: the final Incident reportdocuments root cause and corrective actions.

5 All MVA’s are reported to ES&S at specific site and Job Rep immediately.

For motor vehicle incidents (MVA) the contractor shall conduct an investigation andreport findings to the EH&S representative.

Reporting Preliminary Incident Report - The contractor shall complete the Preliminary IncidentReport for all incidents and submit it to the EH&S representative by 10am the nextbusiness day and follow up with the final report and associated documentation (Cause& Effect Chart, etc.) when the RCI is complete.

Please forward to DOW Houston Area Operations Contractor EH&S at:

Email: [email protected]

Preliminary RCI is submitted by the 3rd working day.

Final RCI report with the Final Incident Report is submitted by the 7th working day.

Communication The contractor shall communicate to their complete on-site workforce the followinginformation, at a minimum, from all incident investigations

Incident Description

Causes

Corrective Actions





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Separate DOWand ContractorInvestigations

Keep the plant portion and the Contractor portion of the investigation separate. (i.e. agas inhalation from a gas release), plant would investigate why the gas releaseoccurred and the Contractor would investigate why the contract employee had theinhalation. Each is a separate event and should be investigated separately thoughappropriate attendance at each investigation to validate evidence and time line maybe required.

Unsafe ConditionReporting andTracking

All unsafe conditions observed by contractors are reported and corrected in anappropriate and timely manner. Those unsafe conditions that must be reported toplant employees for follow-up corrective action (those conditions that are outside thecontrol of the contract company to correct) will be documented using the ContractorAccident /Incident/ Unsafe Condition/ Safety Suggestion form.

Step Action

1 The person who observes the unsafe condition completes the top portion of theContractor Accident/Incident/Unsafe Condition Form, down to, but not including,Preventive/Corrective Actions. (Be sure that you provide enough detail about thecondition and its location that it can be found by others.)

2 Forward the form, via e-mail or hard copy, to Contractor EH&S as instructed on thebottom of the form.

3 Contractor EH&S inputs unsafe condition description into EAT and forwards copy toplant/facility Delivery Technician.

4 Delivery Technician determines the name of the person responsible for submittingcorrective actions and forwards to Contractor EH&S.

5 Contractor EH&S updates Event and Action Tool (EAT) with a single action item forresponsible facility person to enter corrective actions, person(s) responsible and targetor actual completion dates into EAT event; (input from responsible person for targetcompletion dates.)

6 Once the corrective action, etc. are added in EAT then Contractor EH&S sends a copyof the report, with responses filled in, to the originator or, if the report does notidentify the originator, to the company representative.

Monitors EAT prompts for overdue actions, etc. and escalates as required.





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ContractorInvestigations

The contract company is responsible for assuring that contractor incidents that meetthe site RCI trigger criteria are of appropriate quality to determine root cause andsolutions that will prevent recurrence of the problem.

Contractor RCITrigger Criteria

Trigger Point Root Cause Investigation Review Team

Personnel Healthand Safety

Injury/Illness – Days Away from Work,Restricted Work, Medical Treatment

Personal Exposure to Chemicals, Noise,Radiation

Recommended:RCI Tm Leader: Contractor Representative

Team: EHS Delivery Tech or Delivery leader,Contract Service representative

Environmental Loss of Primary containment (spill orrelease of contractor materials including oil,diesel, solvents, etc.)

Complaint (odor, noise, etc. ) received byexternal source (public or industrialneighbor) that is confirmed by plant


Team: EP Coordinator or Delivery leader,Contract Service representative,





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ContractorInvestigations(continued)

Contractor RCITrigger Criteria

Trigger Point Root Cause Investigation Review Team

Near miss potentially RecordableInjury/illness:

An event that had significant potentialfor serious personal injury/illness hadany of the circumstances beendifferent. Examples:

Potential fall of 6 feet or greater Fall of 6 feet or greater Electrical:

shock from 50 volts or higher arc flash greater than 18 inches

where potential for personnelexposure exists

Crane in contact with exposedenergized power line or process line

Employee exposure to oxygen-deficient or flammable (withinflammable limits) atmosphere

Heavy equipment (forklift, crane,boom truck, etc.) tip-over

Dropped heavy equipment (e.g.,forklift, crane, boom truck, etc.)boom, head ache ball, or load

Falling object (above head level)where potential for personnelexposure exists

Flying projectiles where potential forpersonnel exposure exists

Excavation shoring collapse Scaffold collapse

Life Critical Procedures violationthat could have resulted in a seriousinjury or illness, such as:

Confined space entry or Safe WorkPermit (SWP) job without properprecautions specified or taken

Unauthorized entry into a confinedspace

Locked-out/tagged-out equipmentfound to be energized

Hazardous energy source not locked-out/tagged-out once repair/alterationwork has started

Potentially SeriousEvents


Team: EHS Delivery Tech or Delivery leader,Contract Service representative





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Incident/Unsafe Condition Reporting and Investigation Process, cont.Investigation Checklist

Introduction Each of the following items must be addressed prior to holding the investigation. Thiswill aid in the collection of information that will be used in the Root Cause Investigation.

All evidence should be identified and collected within 24 hours. This should startwith the completion of the crisis stamp.

Information that should be considered includes, but is not limited to operatingdiscipline in use at the time of the incident such as procedures, Pre-Task analysis(STAC) cards, permits, pictures of the area, timelines, work orders, physicalevidence (This should be left as is – if this is in a safe position, until the RCI TeamLeader/Pre-Investigation Team can gather adequate information.)

Interviews with personnel involved in the incident should be preformed as soon aspractical.

Time lines should be developed before the RCI meeting.

WHO

Enter the name of the contractor that was injured or the individual most closely involved in theincident.

WHAT

Give a brief written description of the incident including a diagnosis, any medical treatment, theamount of material released or spilled, etc. This information is to be gathered, not to be copied andhanded out prior to the investigation. Some of the materials may be confidential.

WHERE

Identify the department/building/location of the incident.

WHEN

Identify the date and time of the incident. Include where the individual was in their shift.(Example: first of shift, end of shift, etc.).

PHOTOS

Photos of the incident scene would be helpful with the investigation. To obtain photo’s contact

Safety Coordinator, Area Delivery Technician, Unit Immediate Response Leader or ContractorEH&S

DIAGRAM

(A diagram isrequired)

A diagram of the area or equipment involved in the incident would be helpful with investigation.

Obtain/create a diagram of the area including equipment locations.





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Incident/Unsafe Condition Reporting and Investigation Process, cont.Investigation Checklist, cont.

STAC(A STAC isrequired)

Was a STAC filled out for the job that was being performed?

If yes, have you secured the STAC or a copy? If no, secure a copy of the STAC.

If yes, has a copy of the STAC been included with the preliminary report.

Make copies of the STAC for the investigation.

Buddy Checklist, Hand Insert, JSA should be included.

Does this apply? YES or NO

SAFE WORKPERMIT

Was a safe work permit issued for the job?

If yes, obtain a copy of the permit from the permit issuer.


MSDS Did the incident involve chemical(s)? What chemical(s) were involved?

If yes, obtain a copy of the MSDS for the chemical(s) involved.


WITNESSSTATEMENTS

Were there witnesses to the incident or were other individuals involved?

If yes. Obtain written statements from all witnesses or individuals involved ASAP.

Does this apply? YES or NO (Do not take this to the investigation)

INJURYINCIDENTS

Did the incident involve an injury?

If yes, obtain copies of medical reports of the initial treatment including the diagnosis and treatmentgiven.


TOOLS &EQUIPMENT

Were tools or equipment involved in the incident?

If yes, obtain samples and/or the actual tool/equipment involved. This may include photo's orequipment/tool drawings.

Obtain copies of owner's/user's manuals and maintenance records.





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Incident/Unsafe Condition Reporting and Investigation Process, cont.Investigation Checklist, cont.


PPE Was specific personal protective equipment requirements outlined for the job?

If yes, what were the requirements and were requirements being met?

How were these requirements communicated to the employee? Provide documentation.

Was PPE involved in the incident? (i.e. gloves, face shield, etc.).

If yes, obtain actual PPE and make it available for the investigation.


WRITTENPROCEDURES

Were there written procedures for the job being performed?

If yes, obtain a copy of the written procedure.

Were individuals trained in the procedure?

If yes, obtain training records.


Motor VehicleAccident

Did the incident involve a motor Vehicle?

Is the person involved driver’s license current?

Is this person authorized to drive for your company?

Has this person taken the required drivers training?

Have you set up a time for this person to go through drivers training? If so, when?

Facilitator Who will facilitate the investigation?Has the facilitator been trained?

Training Provide verification of training that is relative to the incident.





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Incident/Unsafe Condition Reporting and Investigation Process, cont.Investigation Invitation List

Introduction Each of the following items must be addressed prior to holding the investigation.A formal investigation must be held with in 3 working days of the incident

Item Action

1 The following individuals, if applies, may be invited to a Contractor Root CauseInvestigation:

DOW Owner Representative (this may be the DDC rep, a DOWMaintenance rep, or contract administrator)

DOW Representative from the business (this may be a representativefrom the business or the DOW Production Leader)

DOW Contractor EH&S and/or business aligned EH&S Delivery

Contractor Management

2 In the event of a Recordable Injury invite all individuals identified above plus thefollowing:

Contractor EH&S Delivery Leader

Contract Administrator/Job Representative





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Incident/Unsafe Condition Reporting and Investigation Process, cont.Set Up for Root Cause Investigation (RCI)

Introduction The following should be considered when setting up to do the RCI.

Item Action

1 Pre-Work:

The investigation meeting should be scheduled by the team lead after the pre-work has been done to minimize the amount of investigation done in themeeting.

The meeting should generally last 1 hour. This can be done if the appropriatepre-work has been accomplished. It should be noted that the investigationmeeting for some incidents may be more extensive and time consuming.

The team lead will keep the number of meeting attendees to a minimum, asappropriate to the incident. A team make-up of 5-7 people is optimum.

Each team member should support the team lead in determining correctiveactions that (1) are within your control, (2) prevent recurrence, (3) do not createa more significant problem, and (4) are consistent with business objectives.

2 RCI Team Leader Roles and Responsibilities:

Responsible for coordinating the investigation of incidents and the formal RCImeeting with the goal of producing a timely report.

Ensures that the appropriate pre-work, such as gathering of evidence/interviews, timeline created, and preliminary cause and effect diagram takesplace before the formal Root Cause investigation meeting.

Schedules and communicates the pre-work data collection sessions and theRoot Cause Investigation meeting.

Responsible for team make up and appropriate attendance at the investigation.Invites only key stakeholders.

Takes the role of the RCI facilitator in most investigations. Assigns an RCIfacilitator when independent facilitation is necessary.

Communicates and documents root cause investigation summary and correctiveactions. (Final Incident Report with RCI documentation)

Communicates with action items owners that they have action items





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Incident/Unsafe Condition Reporting and Investigation Process, cont.Set Up for Root Cause Investigation (RCI), cont.

Introduction(continued)

Item Action

3 RCI Set Up:

Schedule a conference for the size of your audience.

Check the room for flip charts, white board and markers, if needed.

Ensure electronic tools are available if needed.

4 Suggestions to improve Cause and Effect (C & E) Flow:

Come prepared to Formal RCI with a preliminary Cause and Effect Chart:

Use electronic tool such as Excel, PowerPoint or other C&E chart template(contact contractor EH&S if one is not available) or

Use Flip Chart: Start at the top of the board.

Write large enough so everyone can see.

Draw the box after writing the information.

Using yellow post is good because information can be moved around; makesure the post it is big enough for everyone to see what is written on them.




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Incident/Unsafe Condition Reporting and Investigation Process, cont.Facilitator Skills

Introduction The following are skills to consider when conducting the RCI.

Item Description

1Introduction of all investigation team members - Explain each person'scontribution

2Opening remarks - The facilitator explains the agenda that will be followed andstates that the purpose of the meeting is to identify action items that will preventrecurrence and NOT PLACE BLAME.

3Selection of a person to take minutes - If not the facilitator, someone must beappointed to record investigation findings

4Description of the incident/accident - this typically includes the following:

Present timeline: Chronology of events leading up to and following the incident.

Presentation of the information collected in the preliminary investigation.

Graphic description of the physical layout of the plant area of interest.

Presentation of applicable reports by outside sources.

It is important that all members of the team fully understand what happened beforemoving on.

5Present preliminary Cause and Effect Chart – team will review and finalize

6Determination of the root cause - Determine all Root Causes after utilizing causeand effect process.

7Defining and delegating Corrective Actions - Determination of recommendations toprevent recurrence by controlling or eliminating the immediate causes and rootcauses.

Corrective Action:

Must be within your control,

Meet your goals and objectives,

Prevent reoccurrence

Corrective actions should be assigned to someone who is directly affected by them.





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Incident/Unsafe Condition Reporting and Investigation Process, cont.Conducting the Investigation

Introduction These steps should be followed during the Root Cause Investigation. These steps willallow for a thorough Root Cause Analysis.

Step Action

1 Preview Agenda

2 Sign in sheet with FAX/ E-mail/phone/etc.

3 Identify Contractor EH&S Delivery for completion of report form (fax # found atbottom of Contractor Incident Form)

4 Introduce everyone

5 Introduce "Ground Rules":

No side conversations.

Focus on the "contractor" issues (this is the contractor investigation).

Work toward root cause; do not jump to the solutions.

“Classification of Incident” will be discussed separately.

All documents will be collected at the end of this session.

6 Review the incident:

Review the “Investigation Checklist” for your information - do not distribute.

Allow employee or employees involved to tell what happened to validate thetimeline

Give everyone time to ask questions for clear understanding of incident.

7 Root Cause Process:

Use the Preliminary "Cause and Effect" diagram - start with incident.

Keep asking "why" until all causes are identified. Take each branch totermination.

Identify and reach agreement on root cause. Ask if root cause removed wouldit have prevented this incident. Is the root cause identified something thecontractor firm has control over? Vote on root cause if more than one isidentified.

List corrective actions for contractors only.





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Incident/Unsafe Condition Reporting and Investigation Process, cont.Conducting the Investigation, cont.

Introduction(continued)

Step Action

8 Identifying corrective actions

Must be within the control of the contractor firm.

Identify immediate short-term actions to be taken.

Assign person responsible for corrective action.

Assign target dates for completion.

9 Wrap Up

10 Pick up documents





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Incident/Unsafe Condition Reporting and Investigation Process, cont.Post Incident Procedure

Introduction The following steps should be followed after the Root Cause Investigation.

Step Action

1 After the Root Cause investigation:

A final written report must be turned in to your DOW Job Representative andto DOW Contractor EH&S with in seven (7) working days of the incident.This report will address root cause and corrective actions.

Verify all fields are completed.

Include:

a copy of the "Cause and Effect" diagram

Buddy Checklist (if applicable)

Investigation Checklist

STAC

JSA (if applicable)

Final Incident Report

2 If the incident involved an OSHA Reportable Injury

Set up meeting with DOW Contractor Safety for Post STAC Review.

3 Arrange for company representative to review and discuss OSHA reportableinjury/illness at next Site Leadership Team meeting and monthly Contractor meeting





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Incident/Unsafe Condition Reporting and Investigation Process, cont.Contractor Owner Incident Reviews (SLT)

Introduction This policy covers the requirement of all Contractor Owners to review OSHARecordable injuries as well as those Near Misses and LOPC’s as identified, with theSite Leadership Team (SLT).

Scope This Policy covers all contractors working on Site.

Policy The SLT is responsible for maintaining a safe and efficient work Site.

One element of this process is to have the Contractors review OSHA RecordableInjuries as well as those Near Misses and LOPC’s as identified, when they occur onthe Site. This policy identifies the trigger for these reviews, the process for the reviewand what will be reviewed.

All Contractors, as part of their responsibility to work on the Site will abide by thisPolicy

Triggers Any time an injury occurs that results in an individual receiving Medical Treatment,Work Restrictions or Time Off Work (OSHA Recordables) the OSHA ReviewProcess will be triggered.

When a Near Miss or LOPC occurs that has significant Contractor involvement. Thiswill be decided by a review of the event by the SLT.

*Exception: An OSHA Recordable that occurs where the Contractor had noinvolvement other than being in the area, i.e. a release resulting in exposure.





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Incident/Unsafe Condition Reporting and Investigation Process, cont.Contractor Owner Incident Reviews (SLT), cont.

Process When a trigger has been met the following will occur:

Step Action

1 The contractor Job Representative will contact the Contractor Owner informing themthat a review will be scheduled.

2 The review will normally last between 15 min. to ½ hour. The Owner will prepare thefollowing information for the review:

Root Cause Investigation summary (Cause & Effect chart, etc. depending onthe RCI tool used).

System failures associated with this incident both Contractor and DOW.Acceptance of arm chair permit, not checking into control room, not wearingsafety equipment, etc.

Company safety Program and their performance on site and companywide

Management System, including safety staffing

Their defined Balance of Consequences process

BBP

Pre-Task Analysis

Any concerns that they may have, etc.

3 The contractor job representative will work with appropriate resources to schedule themeeting with the SLT.

4 The Contractor Owner will be asked to record any action items from the meeting andcommunicate the result of those items to the Contractor job representative on amonthly basis until complete.

5 Appropriate documentation will be retained for use during the contractor performancereview.





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Incident/Unsafe Condition Reporting and Investigation Process, cont.Post Incident STAC Review Policy

Purpose To identify how contractor supervision and management could have personally keptthe incident from happening and to enhance the ability of Contractor supervision totrain their employees in the identification of hazards and methods of controlling oreliminating hazards identified.

Scope This applies to all contractor foremen and superintendents that have anO.S.H.A. Recordable injury or is responsible for an Environmental incident resultingin a Reportable Quantity on their job.

Policy Any time a Contract employee suffers an O.S.H.A. Recordable injury or isresponsible for an Environmental incident resulting in a Reportable Quantity, theContractor foreman and superintendent of the job where the incident occurred willreview a completed STAC with Contractor Safety.

Steps Follow the steps identified below.

Step Action

1 Schedule a time with Contractor Safety to review the completed STAC within two (2)weeks of the date of the incident.

2 Fill out a STAC prior to the meeting and identify the Tasks, Hazards, and Methodsto Eliminate or Control the Hazards that could have prevented the incident.

3 Both the Contractor foreman and the superintendent will attend the meeting andreview the completed STAC with Contractor Safety.

4 Carry back to the work crew the information discussed at the meeting.




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Contractor Accident/Incident & Unsafe Condition/Safety Suggestion Report

Location of Incident/Condition:

Bayport Deer Park LaPorte Lone Star Texas City

Contract Employee Name: Report Date:

Contractor Company: Supervisor/Foreman:

Unsafe Condition Accident/Incident [Check if MVA] Spill Injury/Illness

Describe Unsafe Condition, Accident, Incident, Injury or Illness in detail. (Include propertydamage estimate if appropriate) (Include specific location if unsafe condition).

DAWC (Enter # days)

FA

RWC PREC

RMTC LER

Medical Treatment Yes No

PREVENTIVE/CORRECTIVE MEASURES Person(s) Responsible CompletionDate

ACCIDENT, INCIDENT, INJURY OR ILLNESS

Employee Address: Preliminary Report Final Report

Date Employee Attended Contractor Safety Orientation: Incident Time: Date of Birth:

Time Reported to Work: Incident Date: Age:

Incident Location (Plant/Block, Bldg. #, etc.): Company Address: Job Title/Craft:

General Contractor: Sub: Yrs. Craft: Yrs. Srvc:

Contractor Superintendent: Medical Facility:

Physician:

Witness(s):

Type Restrictions:

Was a pre-job hazard analysis performed and is it documented?Yes No (Retain for Investigation)

INJURY/ILLNESS ONLY(See Code Numbers Next Page)

ContractorSub Type:

Nature ofInj/Ill:

Type ofContact:

Root Cause(s) (Why):

Affected BodyParts:

Safety Factor(s)Involved:

Contractor Rep: Signature Bldg./Phone:

Job Rep assigned to Contract Company: Bldg./Phone:

Investigation Attendance:

Please forward copy of form to DOW Contractor EH&S atHouston Area Operations - Email: [email protected] not forward personal information to other parties.




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Contractor Accident/Incident & Unsafe Condition/Safety Suggestion Report, cont.Some guidance for completing the Contractor Accident/Incident/Unsafe Condition Report: Unsafe condition is a physical condition that did not result in an accident or incident but could if not corrected. MVA box: Check only if this is for a Motor Vehicle Accident (MVA) that did not involve an injury or illness. DAWC – Day Away from Work Case; RWC – Restricted Work Case; RMTC – Reportable Medical Treatment Case; FA - First Aid; LER – Learning

Experience Report (used to leverage to others) PREC - Precautionary box: Check only when visit to a medical facility is initiated to ensure that no injury or illness has resulted from a work related event

or exposure, with no physical impact detected. Any bruising, swelling, discoloration or physical signs from the event or exposure would result in at least afirst aid classification.

Preventive or Corrective Actions: List measures taken/ to be taken that will prevent recurrence of the incident. Identify person(s) responsible and specifytarget completion dates. Enter actual completion dates when complete.

Incident Location: Enter plant/department name where event occurred. Final Report box: Check this box only after completing Injury/Illness classification boxes as appropriate. Root Cause(s) The basic behavior/condition which ultimately resulted in the incident. Code numbers: Use the code numbers provided below to classify injury/illness appropriately on the report form.

INJURY/ILLNESS CODESContractor Subtype 57 Chemical Contact - Body / Eye/ 117 Hip - Right

1 Construction/Demolition 58 Ingestion/ splash/ injection 118 Internal Organ - Heart2 Information Systems 59 Chemical Contact - Inhalation 119 Internal Organ - Kidney3 Logistics 60 Contact w/Biological/Viral Agent 120 Internal Organ - Liver4 Maintenance 61 Contact w/Body Fluid 121 Internal Organ - Lungs5 Operations 62 Contact w/Sharp Surface 122 Internal Organ - Other6 Remediation 63 Electricity - Arc Flash 123 Knee - Left7 Research 64 Electricity - Current 124 Knee - Right8 Service/Administration 65 Explosion 125 Leg - Left9 Other 66 Fall – Elevated Work 126 Leg - Right

Nature of Injury 67 Fall – Not Elevated Work 127 Mouth

10 Acoustic/Ear Trauma 68 Forceful 128 Multiple11 Amputation 69 Exertion/Overexertion 129 Neck12 Bruise/Contusion 70 Hot Material/Surface 130 Nose13 Chemical Burn 1st Degree 71 Mechanical Irritation 131 Scalp14 Chemical Burn 2nd Degree 72 Motor Vehicle Accident 132 Shoulder - Left15 Chemical Burn 3rd Degree 73 Noise 133 Shoulder - Right16 Chemical Exposure 74 Particle or Sliver 134 Teeth17 Chipped, Broken, Lost Tooth 75 Radiation 135 Thigh - Left18 Concussion 76 Repetitive Motion 136 Thigh - Right19 Contaminated Needle Stick 77 Slip/Trip/Misstep/Stumble 137 Toe - Left; Digit 120 Crushed Body Part 78 Stress/Psychological 138 Toe - Left; Digit 221 Cut/Abrasion/Puncture 79 Struck Against 139 Toe - Left; Digit 322 Death 80 Struck By 140 Toe - Left; Digit 423 Dislocation of Joint 81 Sunburn 141 Toe - Left; Digit 524 Electrical Burn 82 Temperature, Extreme (Hot 142 Toe - Right; Digit 125 Electric Shock 83 or Cold) 143 Toe - Right; Digit 226 Foreign Body 84 Welding Light 144 Toe - Right; Digit 3

27 Fracture Affected Body Part(s) 145 Toe - Right; Digit 4

28 Hernia 85 Abdomen 146 Toe - Right; Digit 529 Herniated Disc 86 Ankle - Left 147 Wrist - Left30 Infection 87 Ankle - Right 148 Wrist - Right

31 Insect/Animal Bite 88 Arm - Left Safety Factors Involved

32 Internal Injury 89 Arm - Right 149 Condition of Equipment/Walking33 Loss of Consciousness 90 Back 150 Surface33 Musculoskeletal Pain 91 Chest/Ribs 151 Failure to Use Available PPE34 Poisoning (one exposure) 92 Ear - Left 152 Housekeeping35 Precautionary Visit 93 Ear - Right 153 Illumination36 Skin Rash 94 Elbow – Left 154 Improper Tool or Equipment37 Sprain/Strain 95 Elbow - Right 155 Improper Use of Tool or Equipment38 Thermal Burn 1

stDegree 96 Eye - Left 156 Improper Use of Protective Equip.

39 Thermal Burn 2nd Degree 97 Eye - Right 157 Inadequate Equipment Design40 Thermal Burn 3

rdDegree 98 Face 158 Inadequate Communications

41 Torn Ligaments/Muscle 99 Finger - Left; Digit 1 159 Inadequate hazard identification

Nature of Illness 100 Finger - Left; Digit 2 160 Inadequate hazard controls

42 Hearing Loss / Noise 101 Finger - Left; Digit 3 161 Inadequate Instruction, Logic43 Musculoskeletal Disorders (MSD 102 Finger - Left; Digit 4 162 Inadequate Job Planning44 illnesses) 103 Finger - Left; Digit 5 163 Inattention45 Occupational Skin Diseases or 104 Finger - Right; Digit 1 164 Inattention to Footing or46 Disorders 105 Finger - Right; Digit 2 165 Surroundings47 Poisoning (Systemic Effects of 106 Finger - Right; Digit 3 166 Improperly Guarded48 Toxic Materials) 107 Finger - Right; Digit 4 167 Permit violation49 Respiratory Condition Due to 108 Finger - Right; Digit 5 168 Poor Work Practice50 Toxic Agents 109 Foot - Left 169 Procedure Not Followed51 All Other Occupational Illnesses 110 Foot - Right 170 Safety Rule/Standard Violation

Type of Contact 111 Forearm – Left 171 Taking Unsafe Position or Posture

52 Allergen 112 Forearm - Right 172 Teamwork Breakdown53 Asbestos 113 Hand - Left 173 Ventilation54 Awkward Posture 114 Hand - Right 174 Weather/Ice55 Bite/Sting/Scratch 115 Head 175 Other56 Caught In/On/Between 116 Hip - Left 176 None




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Dow Smoking Policy

Policy The Houston Area Operations sites of Texas City and LaPorte have adopted the DowCorporate Smoking Policy (Deer Park, Lone Star, & Bayport will implement late2009).

This policy bans all smoking on Dow property, to include all parking areas and gates.

Hazard andPrecaution

This new policy has created other issues such as people congregating outside theperimeter fencing to smoke. The guidance that is being given to Dow employees isthat they are not allowed to congregate in an area that creates an unsafe situation orcreates a nuisance. It is our belief that having your employees standing or parking onthe shoulders of the road to smoke creates an unsafe situation for them and causespassing traffic to be distracted. It also impedes other vehicles from having a clearline of site when exiting the gates if vehicles are parked on the shoulder.

Smoking on breaks The terms and conditions of our contracts with your company typically do notexplicitly provide for rest break as a part of the contract. Site management allows forany worker to take rest breaks as needed as long as that break is taken at the workarea and is limited to 10 to 15 minutes max.

Leaving the work-site and driving outside the plant does not meet the aboveguidelines and thus would not be reimbursable time.




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Glove Use Policy

Statement of Policy Gloves must be worn while performing hands on work unless the wearing of theglove would hinder the performance of the job task or would create a hazard.

Scope This policy is intended to reduce hand injuries and aid in the selection and use ofgloves by Maintenance, Engineering and Contractors working on Dow sites.

Purpose Communicate the high incidents of hand related injuries and mitigate the hazard byidentifying those jobs that would normally require the use of gloves and identify therequired glove to be used for those specific hazards.

Responsibilities Contractor management is responsible for providing the appropriate gloves for use oftheir employees.

Exclusions Where jobs are identified that pose a higher risk from using gloves and are not listedon the common exemptions list, these tasks must be identified on the Pre-TaskAnalysis specifically and submitted for addition to the list.

Examples of activities during which glove use is not normally advised due to thepossible increase in hazard are:

Working with high torque rotating equipment while in operation(does not include hand held power tools that may also rotate, such asside grinders).

Equipment operation (cranes, fork trucks, etc.).

Working with small parts requiring high dexterity.

NDT testing where chemical hazards are not present.

Driving nails.

Using a sledge hammer (certain applications).

Scaffold material handling from level to level in wet conditions.

Driving motor vehicles.

Administrative jobs.

Using measuring instruments.

Using a skill saw.

Climbing ladder.

Thermal plastic welding.

Troweling brick mortar.

Determining Typeof Glove to Use

Specific gloves appropriate to the job hazard may be required for certain high-riskjobs. If the type of glove is not specified in the job procedure, leather gloves arepreferred. Cotton gloves however may be worn for low hazard jobs or jobs wherethey may be covered with oil, grease, or paint and be discarded immediately after use.





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Glove Use Policy, cont.

Job/Hazards/Glove Table

Job Type Hazard Glove Type

General Purpose/EverydayUse

Cuts/Bumps/Pinches Leather or VinylImpregnated

Rigging Pinches/Sharp Edges Leather

Sheet Metal Extremely Sharp Edges Kevlar Gloves andKevlar Sleeves

Welding/Oxy AcetyleneCutting

Burns/Sharp Edges/HeatFlames

Welder Gloves

Jack Hammer/Impact TypeEquipment

High Vibration Padded or ShockAbsorbing

Boiler/Pipe Shop Burns/Sharp Edges/HeatFlames

Hot Mill Gloves orWelder Gloves

Carpenters Pinches/Cuts/Bumps Leather

FRP Cuts/Bumps/Solvent Kevlar/Leather/Rubber

Scaffold Builder Wood Slivers/Pinches Cotton or Leather

Insulators Dust/Dirt Cotton or Leather

Knives Sharp Edges See Dow Knife Policy

Chemicals Chemical Hazards Chemical ResistantSpecified in DepartmentPPE Program

Masonry Cement Exposure Rubber lined





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Glove Use Policy, cont.

Performance Grid for Standard Work Gloves

General Duty,Rough

Objects, ChipsSparks

Highly Abrasive ,(CarryingMasonry)

ExtremelySharp Edges,Glass, SheetMetal, Knife

BladesHeat and Flame

(Welding, Cutting)

High Vibration(Jack Hammer,Impact Wrench)

Low Hazard(To Keep

Hands Clean)

ChemicalHazard (See

ChemicalResistance List)

Cotton 8 oz. Canvas E F P P P E P

Cotton 10 oz PlasticDot Cotton

E F P P P E P

10 oz. Cotton Flannel E F P P P E P

Reversible StringKnit

E F P P P E P

Medium WeightReversible StringKnit

E F P F P E P

Heavy WeightReversible StringKnit

E E P F P E P

Hot Mill 24 oz. E E P E F E P

Kevlar String Knit E E E F F E P

Anti Vibration Glove F F F P E P P

Denim Back LeatherPalm Work Glove

E E F F F E P

Starched Safety CuffLeather Palm WorkGlove

E E F F F E P

Rubberized SafetyCuff Leather PalmWork Glove

E E F F F E P

Double Palm WorkGlove

E E F F F E P

Plywood Puller’sGlove

E E F F F E P

Drivers Glove E E F P F E P

Welding glove F F F E P E P

Vinyl ImpregnatedWork Glove

E E P P P E P

P = POOR F =FAIR E = EXCELLENT

All Gloves are rated for abrasion or Heat performance. Dexterity must be determined prior to selection of theCorrect Glove.

These Ratings are simply a guideline and by no means are the final deciding factor in the selection of the right glovefor the right job.




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Personal Injury Prevention: Cutting Tasks

Objective/Policy The use of open blade knives (personal property or Dow-provided) is prohibitedon site at DOW Houston Area Operations sites.

The policy will be implemented through the following guidelines:

1. Proactively eliminate the need for cutting tasks where possible (examples:receiving raw materials in zippered bags, buying pre-cut gaskets, etc.)

2. Provide inherently-safer knife alternatives such as the cutter and EMTscissors pictured below in the “Alternative Cutting Tools” section

3. Develop local procedures that define the correct tool for cutting tasks aswell as any PPE required

4. Authorize variances for knife use only if a safer alternative tool cannot befound. If a knife variance is authorized, the task procedure must requirethe use of cut-resistant (Kevlar) gloves.

5. This policy does not pertain to the use of knives as eating utensils indesignated kitchen/break rooms.

Scope For DOW, this policy covers the prevention of personal injury while performingcutting tasks.

This policy supplements the Policy and Requirements in section 6.05 EmployeeHealth and Safety of Dow’s Operating Discipline Management System, ODMS.

Purpose andExpectations

The purpose of this policy is to reduce the safety risk involved in performing cuttingtasks.

This policy applies to all personnel in DOW and well as Contractor employeesworking within this facility.

MandatoryRequirements

Elimination of open blade knives use as described above unless specificallyauthorized by a local variance.

Suggested process for development of a local variance:

1. Demonstration that alternative (inherently safe) cutting tools are notpractical

2. Development of a procedure defining the variance, including:

a) the scope of the task

b) hazards and precautions, specifically the PPE required

c) tools to be used

d) review frequency for variance

3. Authorization of Production Leader

4. Site-wide communication of variance and reason for it





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Personal Injury Prevention: Cutting Tasks, cont.

RecommendedPractices

Proactive elimination of the need for cutting tasks to eliminate the root cause of thehazard. Examples include:

1. Use of zippered bags for raw materials which can be opened without acutting tool

2. Purchase of pre-cut gaskets

A variance allowing knife use will only be authorized using the site VarianceProcedure and must :

1. Demonstrate that alternative (inherently safe) cutting tools are notpractical

2. Develop a procedure defining the specific tool and its intended use.

AlternativeCutting Tools

The following is a list of inherently safe cutting alternatives to knives:

Tool Function

“EMT scissors” that will cut through a wide range of materials, featuring aninherently safe design without sharp points or razor edges

Available from: EHS Gear

PHONE: (408) 956-9765 E-MAIL: [email protected]

Approximate Cost = $5.00

Utility Cutter that shears with mechanical advantage rather than razor-sharp bladedesign

Available from: Sears (Craftsman)

Model: 37300

PHONE: (800) 549-4505 EMAIL: sears.com

Cable Preparation Tool that is compact and lightweight, capable of strippinginsulation on cable 19-40 mm diameter.

Available from: Ripley Company

Model No. RCS-158

EMAIL:

Approximate Cost = $36.00





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AlternativeCutting Tools(continued)

Tool Function

“RS Knife” with guarded blade/Martor “Opticut” No. 436

Available from: Radio Spares (distributor)

RS Number: 736-529

Approximate Cost: $42.00

SPARE BLADES:

RS Number: 736 – 535 (minimum order is 10 blades)

Approximate Cost: $1.20 ea.

“Fish Knife” with guarded blade

Available from: King’s Lynn Nuts & Bolts Ltd.

MSMS warehouse group 3001

DVS Contract 41394

Approximate Cost: $4.95

Cut ResistantGlove

The following is an example of the “Kevlar” Cut Resistant glove required when avariance has been issued:

Tool Function

Cut Resistant “Hand Guard II” Glove constructed knitted from Kevlar” fiber.

Available from: Wells Lamont

PHONE: (800) 247-3295

E-MAIL: www.wellslamontindustry.com

Approximate Cost: $10.00 per pair





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Roles andResponsibilities

The following is a list of the roles and responsibilities associated with this policy:

Role Title and/or Responsibility

Production Leader orMaintenance Process Leader

Implement cut prevention policy in all plants and maintenance facilities,evaluate and approve variances if necessary

EH&S Delivery Techs andMaintenance SafetyCoordinator

Support implementation by informing any affected parties outside themanufacturing organization of the policy requirements, provide input onpolicy content

All DOW Employees Provide input on new ways to avoid knife use and improve defined knifealternatives

EH&S Responsible CareLeader

Update the policy as new alternatives are found

Definitions The following is a list of definitions:

Term Definition

Open blade knife The general category of open blade knives includes, but is not limited to the followinglist of typical cutting tools.

Pocket knives (folding blade)

Utility knives (retracting blade)

Sharpened screwdrivers

Sharpened putty knives

Exempt Procedures The following list includes jobs exempt from the open blade policy due tounavailability of a guarded blade alternative.

Locking Blade Knife Usage Exception– For Electrical Tasks at DOW

These procedures are task-specific, must require use of cut resistant gloves and are tobe used only for the job for which it is specifically written. Exposed blade length islimited to 4” or less.





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Term Definition

Exempt CuttingTools

The general category of specialty tools that may have unguarded blades by design, butare considered to be the best tool for the job.

Exempted open blade tools are:

Gasket Cutter

These tools are task-specific, require a written procedure, must require use of cutresistant gloves and are to be used only for the job for which it is specificallydesigned.

Other acceptablecutting tools*

The following list includes acceptable alternatives to open blade knives.

EMT Cutters (with design features as shown above)

Utility Cutters (with design features as shown above)

Cable Preparation Tool (as shown above)

Wire cutting pliers

Blunt End Scissors

Task-specific safety cutters with shielded blade (example: “safety carton opener”designed for opening cardboard boxes with minimal exposure to blade)

References Gasket Cutting Procedure




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Man-Hours Collection

Purpose: The purpose of this process is to outline the collection of on-site Man-hours eachmonth for contractor companies that are working at the Houston Area Operationssites.

Expectation: The expectation is that ALL companies will have their monthly man-hours turnedinto:

For Maintenance Contractors –

Contract Services either by email or faxed by the third (3rd) working dayof the month.

For DDC Contractors –

Owner Representative by the third (3rd) working day of the month.

Collection: For Maintenance Contractors -

Please forward copy of form to DOW Houston Area Operations Contractor EH&S at:Email: [email protected]

For Engineering Solutions (construction/capital) Contractors –

Owner Representative will direct each project on collection of man-hours.

Consequences: Non-compliance by the third (3rd) working day of the following month will result in aviolation letter being sent to the company. The company receiving the violation letterwill have five (5) working days to respond with their plan to resolve the late reportingof Man-hours. After two violations letters a QSPP will be filled out on the company.




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MONTHLY MAN-HOURS

COMPANY NAME:

DATE:

MONTH/YEAR MAN-HOURS

January

February

March

April

May

June

July

August

September

October

November

December

Y-T-D TOTAL

Man-hours Due: Third (3rd) working day of each month.Email: [email protected]

*Phone in Man-hours will not be accepted *ALL Man-hours must be submitted on this form only

*Violation letters will be issued for all Man-hours submitted AFTER third (3rd) working day of the month.




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Basic Pollution Prevention

Basic PollutionPrevention Rules

Rule Description

1 Transportation of materials:

All materials shipped out of the location meets all governmental, and siteenvironmental regulations and policies.

Movement/transportation of all materials for off-site disposal, recycle and/orfuel blending are approved by plant personnel.

2 Each water material is appropriately classified and managed as prescribed in the siteEnvironmental Protection Policy requirements.

3 Handling & Prevention of Spills & Releases:

Before beginning any work, individuals give consideration to how a spill orrelease may occur, how it can be avoided, and how to respond to a spill orrelease should it occur.

Spills and releases to the environment are reported immediately to supervisorand host.

Spilled material is contained. Spilled materials and contaminated soils arecleaned up.

Note: Deliberate or intentional unauthorized discharges and releases to theenvironment are prohibited (ex. cleaning tools in site ditches).

4 Consideration and Reporting of Contaminations:

Planning of excavations includes considerations of whether waste orcontaminations may be encountered and plans for disposal.

Any discovered evidence of soil, ground or surface water contamination isimmediately reported to the responsible plant personnel.

5 All emission control devices are to be operated within the limitations imposed byplant management.

6 Hazardous and non-hazardous wastes should be segregated. Exceptions may requirethat the mixture be treated as a hazardous waste.

7 Adverse impact upon the environment is a dominant factor in the decision to continueto operate or shut down and repair equipment.

8 All individuals are to have a practical knowledge of the potential environmentalimpact of their work.

9 All work should avoid and/or minimize the generation of wastes.





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Basic Pollution Prevention, cont.

PollutionPreventionActivities

Pollution Prevention Activities during Maintenance and Construction:

Item Description

1 Inspection of equipment:

Perform pre-use inspections of cranes, forklifts, and JLG’s for leaks.

Inspect equipment based on preventative maintenance inspection scheduleand replace hoses as needed.

Repair leaks on equipment before use.

Report any spills or leaks

2 Use of Drip Pans:

Ensure compressors, generators, etc. have drip pans under them.

Make sure there are pans under all Oil and Waste drums.

3 Handling and Disposal of Oil:

Do not leave buckets of oil lying around. Dispose of properly and havevacuum truck empty full drums.

Let No Oil Touch the Ground

4 Be aware of labels on drums and roll-off boxes before depositing material. Checklabels before dumping

Material mix-ups can cause wasted time and money for disposal, or possiblyfines or chemical reactions from incompatible material.

Put no food trash in Roll Off Boxes.

5 While doing Housekeeping, look for old or obsolete chemicals and materials to bedisposed of.

6 If you are unsure how to dispose of any material, call your Environmental Coordinatorfor assistance.

Each plant has an Environmental Contact, check with your site contact.




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Contractor Spill Policy - Oil and Fuel

Statement of Policy It is the responsibility of each contractor company to manage, correct and pay forcleanup and disposal of spilled Oil/Fuel materials originating from their equipment.This includes stopping and containing the spill, notifying the correct personnel andproper cleanup/disposal of all waste materials related to that spill.

Scope The policy will address Contractor companies that have fuel/oil containingequipment.

Purpose To minimize the number of contractor oil/fuel spills.

Responsibilities The table below list contractor responsibilities pertaining to stopping, containing,notification, and cleanup/disposal of spills.

Item Definition

PreliminaryRequirements

Review the Plant and Departments Environmental Emergency Response planswith all personnel.

Have a Company Environmental Emergency Response plan, which will givedirection to company employees:

a) Who to contact in the event of a spill.

b) What to do for cleanup/follow-up of a spill.

Train all employees on the company Environmental Emergency ResponsePlan and document training.

Dow approved spill kits are required; location and availability will beapproved by your Dow Project/Maintenance contact.

Note: Consideration should be given when spotting equipment to minimize thechance of oil/fuels spill contaminating any water.

Stopping the Spill Shut down all equipment.

Stop all fluids from leaving equipment.

Containing the Spill Stop all migration (movement) of spilled materials using supplied spill kits.

Eliminate any movement toward water. This will help to minimizeenvironmental impact and as well as clean-up costs. If the spilled materialsdo go to water, diapers, booms, and other equipment will be immediatelynecessary to minimize the potential contamination.





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Contractor Spill Policy - Oil and Fuel, cont.


Item Definition

Notification of Spill Notify the block you are working in, of the spill location, what was spilled,amount that was spilled, and any actions your company is taking.

In conjunction with block personnel, make sure IndustrialSecurity/Emergency Services is contacted giving them the same informationlisted above.

Contact all applicable Dow and contractor company contacts, following theguidelines for notification in Dow’s Environmental Emergency Responseplans, and the contractor company Environmental Emergency response plan.

Cleanup/Disposal Supply proper materials and manpower for cleanup: (including tools, booms,diapers, buckets/containers and other cleanup items).

Cleanup the spill site and if needed contaminated soil, asphalt/concrete orequipment. Dow contact will determine extent of cleanup (dirt, asphalt,water, concrete, rock, etc.).

Spilled materials and soil will remain and be disposed of on site.

Arrange for waste characterization and storage/disposal, through the Dowproject/Maintenance contact. Refer to plant environmental operationspackaging requirements.

Contractor assumes costs for the disposal of spilled materials, contaminatedsoil, equipment, pads, and disposal containers. This also includes costsassociated with transportation to disposal site (including pallets).





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Contractor Spill Policy - Oil and Fuel, cont.

Definitions The definitions listed below are for clarification.

Item Definition

Spilled Materials Oils/fuels that are spilled from equipment that is owned/leased by the contractor andresult in a loss of primary containment.

Equipment Equipment that is owned/leased by the contractor company. This includes, but is notlimited to fork trucks, vehicles, cranes, pumps, motors, etc.

WasteCharacterization

Process for determining the characteristics of the waste, where the waste will bedisposed of and how.

Kiln Burn/LandfillBury/Waste WaterTreatment

Locations or processes to dispose of materials.

Spill Kit Booms, diapers, absorbents, and collecting containers.

Dow Project/MaintenanceContact

Individual who orders the work at the site.

Migration The movement of spilled materials (oil, diesel, and gasoline) from one media (dirt,asphalt, water, concrete, rock, etc.) toward another.




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Loading and Unloading Pipe or Steel Policy

Statement of Policy Personnel must not stand on the trailer or truck when material/equipment isbeing loaded/unloaded.

Scope This policy is in effect during the loading or unloading of material/equipmentoperation.

Purpose To have a safe workplace by preventing repetitious safety incidents. In this case,the purpose of this procedure is that no one will be on the truck while pipe orsteel is being lifted.

Responsibility Contractor management is responsible to see that this policy is to becommunicated to all persons required to perform this type work.

Steps Action

1 If the truck to be loaded does not come equipped with ladders permanentlyattached to the side at the front and rear of the truck, then stepladders will haveto be obtained and tied off to the sides of the trailer of flatbed. The stepladderswill be opened fully and set for easy access to the truck.

2 For unloading purposes the man (or men) will access the bed of the trailer andrig up the piece of pipe of steel. An additional person will be the flagman on theground and his duty will be to set the boom point to the center of gravity of theload. As soon as the pipe or steel is rigged up, the person (s) on the bed of thetruck will descend the ladders and remain on the ground until the load is liftedand set on the ground.

3 Repeat Step 2 until the truck is emptied.

4 For loading purposes, the pipe or steel will be rigged on the ground and lifted tothe truck, and then the worker(s) will climb onto the truck and remove thechokers or slings. The boom point must still be set to the center of gravity of theload before lifting.

5 For loading repeat Step 4 until the truck is loaded.

6 Tag lines of acceptable length shall be used for loading and unloadingoperations.




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Locking Fuel Nozzle Policy

Statement of Policy Locking fuel nozzles will be removed or permanently disabled from all fuelingdevices/equipment before entering any Dow facilities.

Scope The policy will address Locking Fuel nozzle devices used for fueling equipment andvehicles.

Purpose To minimize the number of fuel spills.

Responsibilities Contractor management is responsible for implementation of this policy on all fuelloading equipment that they own or lease.

Definitions The definitions listed below are for clarification.

Item Definition

Locking fuel nozzle Any fueling device used for fueling any equipment, or vehicles that may be locked inthe on position, and would not require 100% hands on operation of the nozzle whilefueling.

FuelingDevices/Equipment

All equipment that is used to fuel equipment/vehicles. This includes but is not limitedto:

all Fuel Truck and trailers,

all truck/vehicle mounted small fuel tanks,

all portable fuel tanks (skid mounted), and

permanent fueling facilities owned by Dow, or Contractor/Vender Companiesworking in Dow facilities.

All fuel dispensing will be done with 100% hand control on the filling devise. Notrigger props or other methods to hold a fuel dispensing handle open shall be used".




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Contractor Severe Violation Policy

Purpose This policy was developed to address restrictions for contract companyemployees (“contractors”) that commit violations of life critical safety or workrules and/or programs while working on a “Dow Site”. “Dow Site” refers to aSite owned by The Dow Chemical Company or its affiliates or its subsidiaries.

Scope This policy applies to all contractors that work on Dow Sites.

Background This policy is designed to be leveraged and managed by the Site ContractorSafety organizations at each Dow Site. (Freeport, Houston, Seadrift, Deer Park,Lone Star, Bayport, Texas City)

Unsafe behaviors or violations associated with Environmental, Health, Safety orSecurity rules, standards or programs can result in temporary or permanentrestriction of contractors from all Dow Sites.

Policy

Step Action

1 An investigation is required with the person being accused present at the investigation.

2 Dow Site Contractor Safety representative attends the Contractor RCI.

3 Dow Site Contractor Safety will evaluate each individual case (including anyprior performance issues) and determine the length of time the contractor willbe restricted from the Dow Site.

4 Dow Site Contractor Safety will utilize this document to determine ifrestrictions apply for life critical safety & work rule violations.

5 Each contractor company should have a disciplinary program that holds itsemployees, supervision, and subcontractors accountable for their actions.

6 A second violation of the Severe Incident Policy can result in permanentrestriction from all Dow Sites.

Training All Contractor companies must train their employees on this policy.





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Contractor Severe Violation Policy, Continued

Examples ofSevere Violations

Topics Examples of Severe Violations

Confined Space Instructing others to perform unauthorized entry of a designated confined space

Knowingly entering a confined space without authorization

Failure to follow required procedures (depending on the potential consequences ofthe failure)

ControlledSubstance / Alcohol/ Etc.

Working under the influence of drugs or alcohol (Positive test as a result of arandom screen / post incident test)

Individual failure to meet required substance abuse or / alcohol prevention policy.

Smoking in chemical manufacturing, processing or distribution areas.

Management failure to meet required substance abuse prevention policy

Creating anUnprotected FallPotential:

Creating an unprotected opening or removing protection from an opening wherepersonnel could suffer a life critical fall such as, but not limited to, removinggrating, handrails, piping/equipment, life critical barricades or creating anexcavation that is unprotected, etc...

Elevated Work Not being tied off 100% of the time when required

Instructing others to not follow required procedures

Fighting / TerroristicAct

Any action or threat to intentionally harm an individual, group or equipment

Incident Reporting Failure to report or encouraging others not to report an EH&S incident.

Falsifying information associated with an incident.

Lockout/Tagout Removing a Red Tag without appropriate authority.

Operating equipment isolated by Red Tags.

Not following Isolation of Energy standard when working on equip.





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Contractor Severe Violation Policy, cont.

Examples ofSevere Violations(continued)

Topics Examples of Severe Violations

Personal ProtectiveEquipment

Willfully not wearing life critical PPE when required while performing task (i.e.breathing air, chemical protective clothing, etc…)

Failure to wear PPE for specific tasks specified by procedure or Safe Work Permitresulting in a recordable injury.

Safe Work Permit Willful violation of a Safe Work Permit that endangers persons or property

Failure to obtain the appropriate Permit for the following tasks: Hot Work in ahazardous area; Line & Equipment Opening with a potential exposure tohazardous chemicals; Confined Space Entry.

Theft Any intentional act of theft

Behaviors Unsafe behaviors (depending on the potential consequence)

Incident Reporting Failure to report an EH&S incident

Refusal to report or encouraging others not to report an EH&S incident.




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Task Force for Safety Success

Purpose Task Force for Safety Success (“Task Force”) is a team effort that has proven to be asuccessful, proactive tool used to assist contractor firms to improve their EH&Sperformance on Dow sites.

Scope Task Force was developed for contractor companies that have experiencedunfavorable EH&S performance. By definition, 3 to 4 contractor companies will beon Task Force at any given time.

Background Until the development of Task Force, there was no formal program in place to assistcontractor firms in improving there EH&S performance, prior to being suspendedfrom working at Dow.

Policy Contractor companies that meet the trigger criteria listed below will be evaluated bySMAT to determine if they should to be placed on Task Force. Dow ContractorSafety will send a letter to the company notifying them that they are on Task Forceand schedule the first meeting. The Task Force team will be established and meetmonthly for a minimum of 6 months, at which time the team will determine thefrequency and duration of future meetings. The team will work together to ensurethat the requirements listed in the policy are met.

Topic Description

Trigger Criteria OSHA Rate on Dow site is greater than 2 times the site contractor OSHArecordable goal for the current year and the company has had more than 1 OSHAfor the year

Significant safety performance issues

Team Members Contractor company upper management, field supervision and safety staff

Dow Texas Sites Purchasing

Dow Contractor EH&S

Dow Design & Construction (Owner’s Representative)

Dow Maintenance Process Leader

Dow Contract Administration





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Task Force for Safety Success, cont.

Policy(continued)

Topic Description

Requirements Participation on Task Force Team

A written Safety Action Plan with measurable performance goals.

Participation in the Behavior Process (SOS or BBP)

Participation in the Site Contractor Management Team

Participation in Dow Contractor Foreman/Superintendent Training

Review of any incidents and action items generated from investigations

Review of any QSPP’s

Consequences Each of the elements listed above must be reviewed on a monthly basis with a Teamthat will be identified when the Company is put on Task Force. Noncompliance willresult in action up to and including suspension from any and all Dow work.

Training Review policy at the first Task Force Meeting.




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Contractor Evaluation

Purpose To evaluate the performance of Non-Dow Service Providers to determine continuedand future activities with a particular service provider. Visitors will not be evaluated,but may be denied continued access to Dow sites if unacceptable behaviors aredemonstrated.

Independent Non-Dow ServiceProviders

Item Description

1 A Periodic Assessment should be conducted by the Job Rep of the Independent Non-Dow Service Provider to ensure compliance with elements of the safety and healthprogram. The Periodic Assessment form may be used for this activity.

2 An Evaluation Team will review the list of independent service providers at leastannually and request Periodic Assessments from the corresponding Job Representativewhere assessment is needed.

3 The Evaluation Team will consist of the Contractor Administrator, SMATrepresentative and the EH&S Contact as a minimum.

4 The Evaluation Team should conduct a Performance Evaluation based on relativeexperience with the provider, the risk level of their work, performance assessment,and performance record. The frequency of Performance Evaluations should notexceed 3 years for continuing Independent Service Providers.

5 The Performance Evaluation should analyze data, identify areas of improvement orrecognition and determine appropriate follow up. Conclusions should be documentedon the bottom portion of the Periodic Assessment form.

6 For continuous improvement, the Evaluation Team and/or job reps may also includeany combination of the following:

Independent Non-Dow Service provider may perform their own assessments,communicate their actions and follow up for discussion with the Dowrepresentatives.

Non-Dow Service provider meets minimum EH&S requirement, contractorsafety plan, and has an improvement plan.

Independent Non-Dow Service Provider may develop and use pro-activemeasures of EH&S performance.

Utilize the Dow contractor performance improvement tool.

Provide recognition for superior EH&S performance.





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Contractor Evaluation, cont.

Independent Non-Dow ServiceProviders(continued)

Item Description

7 An individual of an independent service provider should be removed from the site iftheir behavior is determined to be unacceptable with moderate to severe impactpotential. Repeated low impact negative behavior should also be a basis for removal.Apply the balance of consequences principles.

8 An Independent Service Provider should be removed upon severe impact unacceptablebehavior or repeated low to moderate unacceptable behavior. Consideration should begiven to the responsiveness of the provider to any such incident.

9 Consideration for Non-Dow Service Providers for re-entry onto the site may be givenif adequate evidence of corrective action has been demonstrated to the ContractAdministrator/Job Representative and the EH&S Contact.

Contingent StaffNon-Dow ServiceProviders

Item Description

1 Contingent staff providers should be periodically evaluated against elements of thesafety and health program.

2 The Evaluation Team will review the list of contingent staff providers at leastannually and request Periodic Assessments from the corresponding Job Representativewhere assessment is needed.

3 The Performance Evaluation should analyze data, identify areas of improvement orrecognition and determine appropriate follow up. Conclusions should be documentedon the bottom portion of the Periodic Assessment form.





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PERIODIC ASSESSMENT OF NON-DOW* SERVICE PROVIDERInstructions: The Job Rep is responsible to periodically assess each Non-Dow Service Provider by completing the top assessmentportion of this form. The Job Rep will keep the original and copy SMAT rep if requested. If applicable, the bottom evaluation iscompleted by EH&S Contact and Contractor Administrator.

NAME OF NON-DOW SERVICE PROVIDER: _____________________________________________

JOB REP NAME: ____________________________________ DATE: _________________________

WORK PERFORMED: ________________________________________________________________

PERIOD ASSESSED FROM _________________ TO _________________

ASSESSMENT RATING BY JOB REPRESENTATIVE

1-Unacceptable 2-Improvement Needed 3-Meets Requirements 4-Exceeds Expectations 5-Outstanding

Non Dow Service Provider… 1 2 3 4 5

1. Leadership visible in the site (job audits, meets with employees).2. 1st line supervisor training for managing safety3. What actions are being taken from analysis of Pre-task cards, Behavior

Based Observations/Interventions, Near Miss reports, RCI’s, Audits, SafetyIncident/Accident reports, Safety Suggestions, and Unsafe Conditionreports?

4. Compliance with all Pre-Access/Pre-Job/Safety Plan requirements5. EHS/Craft/Skill training status of work group (DOW and company status)6. Substance abuse testing metrics (include status on pre-access testing, annual

random test for every employee, reasonable cause testing, and post incidenttesting) for.

7. Demonstrate adequate understanding of work scope/job procedures andassociated hazards including use of applicable EH&S standards (regulatoryand Dow).

8. Demonstrate use of personal protective equipment appropriately.9. Use of contract company’s BOC policy and status of corrective action10. Maintained work area housekeeping as expected.11. Assured safety awareness via safety talks and training (pertinent to job).12. Adequate understanding & execution of Contractor Admin Manual (Houston

Area Operations) and Safety Rule Book, as applicable.13. Productivity metrics, Quality metrics, QSPPs, and corrective actions taken14. DOW Contractor BOC status15. All action items completed from previous contractor evaluation.16. Corporate and DOW OSHA TRIR status / EMR status

PERFORMANCE EVALUATION BY EH&S/ADMINISTRATOR

New or Established NDS Provider New or EstablishedExposure Hours

Number & Rate of Recordable Injuries/Illnesses (DOW site &company status)Number of Lost Work Day Cases

Number of Incidents (Minor/Significant?)

Number of Loss of Primary Containment incidents

COMMENTS:_____________________________________________________________________________________________

CONCLUSIONSY/N Comments

Follow up Needed?

Any NDS supervisor or employee not recommended for future assignment on site?

Recommend for Future Work?

Contractor Administrator: _______________________EH&S Contact: _____________________________*”Dow” refers to The Dow Chemical Company and consolidated subsidiaries, including Union Carbide Corporation..




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Contractor Evaluation Job Aide

Use the following guidance when requesting and reviewing contractor metrics:

1. Leadership visible in the site (job audits, meets with employees). (status since last update - # of times, contractcompany leadership at DOW meeting with their employees and reason i.e. audit, recognition, etc.)

2. 1st line supervisor training for managing safety (status - on-going reinforcement for 1st line supervisors - # oftraining/meetings and topics)

3. What actions are being taken from analysis of Pre-task cards, Behavior Based Observations/Interventions, Near Missreports, RCI’s, Audits, Safety Incident/Accident reports, Safety Suggestions, and Unsafe Condition reports? (Statusof data from contract company’s analysis of their employee's STAC/JSA's, Behavior Based Observations/Interventions,Near Miss reports, RCI’s, Audits, Safety Incident/Accident reports, Safety Suggestions, and Unsafe Condition reports atDOW since last update. Trend analysis - what actions have the contract company done to address findings -communicate status)

4. Compliance with all Pre-Job requirements. Status of Pre-Job - Any updates needed?

5. EHS/Craft/Skill training status of work group (DOW and company status) – Status of Contract Company’s skilltraining/qualification for employees working at DOW; have they completed any/all training and evaluation reqs and ifnot what is left; can be simply displayed and don't have to use names. Turnover rate (new to site), foremen to workerratio, At risk employee ratio, other stats to verify informed, consistent workforce.

6. Substance abuse testing metrics (include status on pre-access testing, annual random test for every employee,reasonable cause testing, and post incident testing) for DOW.

7. Demonstrate adequate understanding of work scope/job procedures and associated hazards including use ofapplicable EH&S standards (regulatory and UCC/Dow). Metrics may also be included in #3 The contractor shouldreview their Procedure Use Policy and share how their generic procedures have been adapted to Dow as needed.Would like to see how their procedures incorporate safety precautions and considerations and for them to demonstratehow their procedures are made available to their employees working at DOW. For example, it is 2AM Saturdaymorning, how do their workers get the appropriate procedure for work at a UCC/Dow facility (their procedure that isspecifically written for the facility they are working in). Verify how we know that they have reviewed their procedures tosee if they address issues specific to UCC/Dow facilities?

8. Demonstrate use of personal protective equipment appropriately. Metrics may be be included in #3

9. Use of contract company’s BOC policy and status of corrective action Status since last update – metrics toverify contract company use of consequences policy with employees and status of any actions taken

10. Maintained work area housekeeping as expected. Metrics may be be included in #3; verify included in site safety plan.

11. Assured safety awareness via safety talks and training (pertinent to job). What topics covered since last update (forevaluator - are they pertinent to the hazard of the tasks for this contract company)

12. Adequate understanding & execution of Contractor Admin Manual (Houston Area Operations)) and Safety Rule Book,as applicable. (completing incident reports, RCI, reviewing Safety Rule Book with employees, incidents?)

13. Productivity metrics, Quality metrics, QSPPs, and corrective actions taken (review business/productivity relatedmetrics - quality/cost/delay, etc., QSPP status)

14. DOW Contractor BOC status

15. All action items completed from previous contractor evaluation.

16. Corporate and DOW OSHA TRIR status / EMR status (OSHA recordable rate – may include DAWC rate for verification ofserious injuries - and verification of worker’s comp claims – EMR; if self insured ask for claim data)

The evaluation process verifies the contractor is performing minimum required self assessments to maintain continuous safetyand productivity improvement and gain value for UCC/Dow dollars. Also gains understanding of contract firm capability forUCC/Dow contractor management with potential to limit or expand work based on status.

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