THE DOW CHEMICAL COMPANY* Bay Area Administrative Manual

Transcription

THE DOW CHEMICAL COMPANY*
Bay Area
Administrative Manual
For
Service, Maintenance
And
Construction
Bay Area sites are composed of the following operations:
Texas City Operations (TCO) - Union Carbide Corporation a subsidiary of The Dow
Chemical Company
Houston Operations (HOU) – The Dow Chemical Company
Clear Lake Operations (CLO) – The Dow Chemical Company
*As used in this manual, “Dow” refers to The Dow Chemical Company, and its subsidiaries (including Union
Carbide Corporation, as applicable).
Bay Area Contractor Administrative Manual.doc
DOW RESTRICTED For internal use only
Page 1 of 197
Contract Company Managers,
The "Dow Bay Area Administrative Manual for Service, Maintenance and Construction" is
provided to you as a minimum standard to support regional and site specific requirements to
include rules, standards and policies.
The Introduction explains more fully the intent and function of this manual. Please familiarize
yourself with the entire manual.
Please do not reproduce this manual. If you need additional copies, or have changes in your
address or company contacts, etc., please contact your Dow representative.
Should you have any questions, please give the Site Contact a call.
Bay Area Supplier Management Action Team (SMAT)
Page 2 of 197
DOW BAY AREA
MANUAL DISCLOSURE
NON-DOW USE
THE FOLLOWING NOTE OF CAUTION IS DIRECTED TO ALL PERSONS
WHO ARE NOT EMPLOYEES OF DOW:
Since conditions at non-Dow workplaces, or where Dow is not actively supervising the
work, are outside of Dow's control and because legal or regulatory requirements may
vary from worksite to worksite, Dow hereby advises you that adherence to this Manual is
not a guarantee that your activities or operations are in compliance with all applicable
federal, state and local laws or regulations, nor is it a guarantee that it will provide
absolute protection against exposures or hazards.
Dow has no control over your use of such information or advice, you are cautioned to
independently 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, or
appropriateness for your use, of such information and advice or whether it is complete
and without omission and Dow disclaims any liability arising out of your use of such
information and advice
Page 3 of 197
Houston Operations Map
Page 4 of 197
Clear Lake Map
Dow Chemical
9502 Bayport Blvd
Pasadena, TX 77507
281-474-6200
Route To Clear Lake Operations From I-45
• You will want to go east on Bay Area Blvd. Take the Bay Area
Blvd. exit and, if traveling south on I-45 go under the overpass and
turn to the right immediately after the overpass. Travel east on Bay
Area Blvd. for about 6.6 miles. After driving through the woods of
Bay Area Park and Armand Bayou, you will cross Red Bluff Road.
Continue east on Bay Area Blvd. for about 0.7 miles after the
intersection with Red Bluff Road. Bayport Road will be the first
intersection on your left (north). A large metal building (Graver
Tank Mfg.) can be seen on the north side of this intersection.
• Turn left on Bayport Road and go about 0.7 miles to the end of the
road and you will be at the entrance to Celanese/Dow Clear Lake
Operations (Administrative office space is shared with these two
companies). Visitor parking will be on your left, across from the
main Administration Building (look for the flag pole).
Dow Clear Lake
Page 5 of 197
Texas City Map
Getting to Texas City Operations (TCO)* from the Houston Area
Hwy 146
DOW
To Galveston
FM 1765
Holiday Inn-Galveston
Recommendation: It is
generally agreed that
the best hotel in Texas
City is the Hampton Inn,
located at the Mall of the
Mainland.*
LaQuinta Inn
409/948-3101
34th Street
Emmett F.
Lowry
Expressway (FM 1764)
Ramada Inn-La Marque
409/986-9777
Fairfield Inn
* Hampton Inn 409/986-3866
409/986-6686
Hwy 517 (Dickinson)
Hwy 518 (League City)
TO Texas City Operations:
On Interstate 45 past the town of Dickinson, take
Exit FM 1764 ( aka Emmett F. Lowry
Expressway). Continue on FM 1764 until you
come to Hwy 146 (You will pass College of
the Mainland and Columbia Hospital on your
right). There will be a Denny’s Restaurant
and a LaQuinta motel on the right at Hwy 146.
Take a right on to Hwy 146. The next major
traffic light will be FM 1765. Take a left on to
FM 1765. You will be driving alongside of
TCO on your right. FM 1765 will fork. Stay to
the right of the fork. At the next light turn right
into visitor parking area of TCO.
NASA Road 1
Interstate 45
Bay Area Blvd
*Texas City Operations is owned and
operated by Union Carbide Corporation,
a wholly owned subsidiary of the Dow
Chemical Company.
Hobby Airport
Airport Blvd
Holiday Inn-Hobby
Houston
N
(Map not drawn to scale)
Page 6 of 197
•
Table of Contents
• Introduction………..………………………….……....……………………………
• Safety Performance.......……………………………………………………………
• Safe Behaviors...……………………………………………………………………
• Dow Site Contacts…………………………………………………………………
• Document Control History…………………………………………………………
10
11
12
13
14
• Prequalification
• Contractor Qualifications for Work on Site .………………………………………
• Form: Waiver of Qualification with Checklist.……………………………………
16
20
• 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..……………
36
• Contractor Program Checklist...……………………………………………………
42
• Form: Waiver of OSHA Threshold/EMR Rate……………………………………
47
• Form: Safety Action Plan (Double click to open spreadsheet)……………………
48
• Site Access for Contractors, Delivery, and Visitors..………………………………
49
• Contractor/Sub Contractor Badging Policy...………………………………………
• DOW Background Screening Policy.………………………………………………
58
62
64
• Contractor Safety Training Waiver (One day Emergency Waiver)..………………
66
• Form: Waiver of the Contractor/Vendor Safety Indoctrination...…………………
67
• Contractor Safety Training Requirements for “Short term, Low-Risk” Entry..……
68
• Form: Contractor Training Requirements for “Short Term, Low-Risk” Entry....…
69
• Flowchart: Training Waiver Process....……………………………………………
70
• Visitor/Vendor Policy....……………………………………………………………
71
• Site Leader Safety Expectations – “It’s All About You”..…………………………
76
• Pre-Job Orientation....………………………………………………………………
• Pre-Access Flowchart........…………………………………………………………
78
81
• Pre-Job Conference Checklist....………………..…………………….……....……
82
• Job Safety Analysis Guidelines (JSA)....………..…………………….……....……
110
• Form: Contractor Hire Slip...………………………………………………………
Continued on next page
Page 7 of 197
Table of Contents, cont.
Selection/Pre-Job Activities and Access, cont.
• JSA Civil Work..………..…………………………………………….……....……
111
• JSA Instrumentation & Electrical...……………..………………….……....………
114
• JSA General Mechanical & Construction..……..…………………….……....……
117
• Carpenter & Scaffold Builder Policy.....………..…………………….……....……
120
• Procedure Use Policy (PUP) for Leveraged Dow
Maintenance Employees and Maintenance Contractors......………..……………… 121
• Contractor Crafts Skill Assessment Policy..…………..…………………….……...
122
• Contractor Training Card Policy...…………………………………………………
• Bay Area sites list of Required Training.....…………………………………
123
• Job and Equipment Specific Training Requirements....……………………………
124
• Contractor Site Safety Rep Minimum Expectations.....……………………………
130
• Minimum Certification/Training Requirements
for Contractor Safety......………………..…………………….……....……………
• Buddy Policy (At Risk Employee)....………………………………………………
131
133
• Work in Progress
• Job Representative Responsibilities......……………………………………………
135
• Contractor Safety Alliance/Site Safety Meeting.......………………………………
141
• Maintenance/Scope Change Policy and Form.......…………………………………
143
• STAC Training Process….…………………………………………………………
144
• DOW Injury/Illness Reporting......…………………………………………………
• Incident Involving Contractor Flowchart......………………………………………
145
147
• Incident/Unsafe Condition Reporting and Investigation Process......……………… 149
• Investigation Checklist........………………………………………………… 154
• Investigation Invitation Checklist...………………………………………… 157
• Set Up for Root Cause Investigation (RCI)....……………………………… 158
• Facilitator Skills......………………………………………………………… 160
• Conducting the Investigation......…………………………………………… 161
• Post Incident Procedure......………………………………………………… 163
• Contractor Owner Incident Reviews (SLT)....……………………………… 164
• Post Incident STAC Review Policy....……………………………………… 166
• Form: Contractor Accident/Incident &
Unsafe Condition/Safety Suggestion Report….…………………………………… 167
• DOW Smoking Policy.......…………………………………………………………
169
Page 8 of 197
Table of Contents, cont.
• Work in Progress, cont.
• Glove Use Policy....…………..……………………………………….……....……
170
• Personal Injury Prevention: Cutting Tasks....………………………………………
173
• Man-Hour Collection.………………………………………………………………
178
• Man-Hour Report Form.……………………………………………………………
179
• Health Services Guidelines for Non-DOW Services and Visitors…………………
180
• Basic Pollution Prevention…………………………………………………………
182
• Contractor Spill Policy – Oil and Fuel...…………..………………….……....……
184
• Loading/Unloading Pipe or Steel...……………..…………………….……....……
187
• Locking Fuel Nozzle Policy...…………………..…………………….……....……
188
• Evaluation
• Contractor Severe Violation Policy...………………………………………………
189
• Task Force for Safety Success...……………………………………………………
192
• Contractor Evaluation………………………………………………………………
194
• Evaluation Form……………………………………………………………………
196
• Contractor Evaluation Job Aide……………………………………………………
197
Page 9 of 197
Table of Contents
THE DOW CHEMICAL COMPANY – BAY AREA
ADMINISTRATIVE MANUAL
FOR SERVICE, MAINTENANCE AND CONSTRUCTION
INTRODUCTION
This Manual contains administrative safety standards, references and procedures for
performance of work by any contractor, subcontractor, vendor, and their employees
(hereinafter referred to collectively as "Contractors", and individually as "Contractor"), as
required by The Dow Chemical Company Bay Area sites, hereinafter referred to as
“Owner”. These administrative rules shall be used in conjunction with the Dow Safety
Rules Manual.
The Owner’s representative will be defined in the contract and is hereinafter referred to
as "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 nothing
contained 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 out
fully, as any other specification for the job. Any exception to the rules set forth herein
must have prior written authorization from the Owner's Representative.
Contractors unable or unwilling to secure personnel performance in keeping with these
rules risk a loss of business from Owner. The Contractor's OSHA Recordable Incident
rate and Workers Compensation EMR will be two criteria used to judge qualifications for
bidding.
In addition to the rules set forth in this manual, Contractors working in or near an existing
operating facility must be cognizant of and conform to Owner's safety rules for that area
and 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.
Page 10 of 197
Table of Contents
SAFETY PERFORMANCE
Our vision is to create an incident/injury free work place, which requires the commitment of
every individual. Our current EH&S goals were set in 2006. We have made great progress, but
we 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 a
Behavior Based Safety Process. This will include, as a minimum, every individual
using Pre-Task Analysis), Leadership Observations, and everyone working together
to analyze and correct unsafe behaviors.
•
Cooperative Team Analysis of safety data for continuous improvement of safety
initiatives.
•
That contract companies will require everyone to wear the proper Dow site required
PPE (Personal Protective Equipment).
•
That contract companies will direct employees in their organization to follow the
requirements 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 to
perform, both from the Craft Skills perspective and the OSHA Regulations.
•
That contract companies will direct the involvement of everyone through
participation in targeted initiatives such ergonomic/wellness based programs to
prevent long-term illness.
•
Contract companies support continuous progress toward the 2015 EH&S goal of
injury and illness rate of 0.08 per 200,000 hours of work and, reduce the severity rate
by 75 percent.
**Please review these expectations and incorporate them into your operation’s conduct and
goals while working at our site. **
DO IT SAFELY
OR
DON’T DO IT!!
Page 11 of 197
Table of Contents
THE DOW CHEMICAL COMPANY – BAY AREA
Safe Behaviors
Expectations of all contract employees:
•
Be knowledgeable about and adhere to applicable safety rules, policies, standards, and
procedures, 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
Page 12 of 197
Table of Contents
Dow Site Contacts
Site
LaPorte
Texas City*
Clear Lake
EH&S
Purchasing
Tamara Coppens
Travis Owsley
(281) 966-4842
[email protected]
Donna Coyle
Travis Owsley
(281) 966-4842
[email protected]
Dean Butler
Travis Owsley
(281) 966-4842
[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 Bay Area facilities. With respect to such facilities, references to Dow in this
manual should be regarded as references to Union Carbide, as the case may be.
Page 13 of 197
Bay Area Operations
Bay Area Contractor Administrative Manual
Regional Contractor Administrative Manual
Table of Contents
Document Control and History
Owner
Bay Area Supplier Management Action Team (SMAT)
Location of
Controlled Copies
If a document is located in a place other than the location listed below, it is
considered uncontrolled.
Copy
Revision and
Review History
Location
1
TCO - Tctsv01\eh&s\Approved\Responsible Care\Non-Dow
Services\Communication of Dow's EH&S Ex\Cont Admin Manual
2
CLO - \\Ussdowf001\CLO_Ops\Approved\Responsible
Care\Employee Health & Safety
3
HOU - http://na-ehs.intranet.dow.com/HoustonOpsehs/standards/0606.htm
This document will be reviewed every five years or sooner if a process change
occurs. Process changes are tracked by MOC.
Date
Documents
Referencing this
Document
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 Watkins
Added Hair Testing requirements to Substance Abuse
Policy and decreased random 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 Standard updates (electrical,
elevated work, scaffold, mobile hoisting) and clarified
line items to ensure common understanding.
The following table lists the documents which reference this document. When
this document is revised, the document on this list must be audited to ensure no
changes are required.
OD Number
ODMS 6.06
Description
Non-Dow Services
Page 14 of 197
Bay Area Operations
MOC Process
Proposals for change will be submitted through the MOC tool and reviewed by
Bay Area 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
Page 15 of 197
Bay Area Operations
Table of Contents
Contractor Qualifications for Work On-Site
EH&S Pre-Qualification Process for U.S. Area Independent
Contractors
Introduction
Independent contractor firms seeking to work at DOW must meet specific
requirements, which include Environmental, Health, and Safety expectations. These
expectations include EH&S performance criteria and specific EH&S requirements.
Contractor firms are pre-qualified and selected based on the ability to meet the
EH&S expectations.
Purpose
This document provides the process for EH&S pre-qualification and selection of
independent contractor firms who seek to perform work at The Dow Chemical
Company, Bay Area Operations.
Scope
This document applies only to the contractor’s ability to meet Environmental,
Health, and Safety criteria.
Pre-Qualification
Process
Procurement Services will initiate the process by requesting that the independent
contractor firm complete a standardized Pre-Qualification Form (PQF). The PQF
will provide information regarding the contractor’s ability to comply with applicable
environmental, health, and safety performance criteria and requirements. The PQF is
contained in the ODMS 06.06, Non-Dow Services.
After receiving the completed Pre-Qualification Form, Hold Harmless Agreement,
and Insurance Certificate, Procurement Services forwards the completed PQF to
location EH&S Delivery for review. The EH&S reviewer evaluates the PQF and the
contractor’s ability to comply with the health and safety performance criteria and
requirements.
Location EH&S determines the approval status for the contractor using the following
designations:
•
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 Bay Area site,
communication will be made as to status and the applicable conditions
associated with the approval status.
Page 16 of 197
Bay Area Operations
Table of Contents
Contractor Qualifications for Work On-Site, cont.
Acceptance
Criteria –
Approved
Contractor
The health/safety performance criteria for independent contractor firms working at
multiple Dow sites in the U.S. are as follows:
•
One or less OSHA recordable injury/illness per year or an average OSHA
recordable 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 on
the PQF.
These criteria qualify a contractor firm to work at Dow sites in the U.S. A
contractor site-specific environmental, health, and safety plan is required during
the pre-job activities associated with work at the site.
Failure to show satisfactory improvement in meeting site targets may result in
reduction or elimination of work at the site. These situations will be managed on
a case-by-case basis.
Acceptance
Criteria –
Conditionally
Approved
Contractor
Some contractor firms may not initially be able to meet the safety/health performance
criteria to qualify as an “approved contractor.” These contractor firms may be
accepted on a conditional basis for work based on the following performance criteria:
•
Two or less OSHA recordable injuries/illnesses per year or an average OSHA
recordable injury/illness rate of greater than 2.0 but not to exceed 4.0 for the
last three calendar years.
•
An average Worker’s Compensation EMR of 1.0 or less for the last three
calendar years.
•
Meet the other Environmental, Health, and Safety requirements as outlined on
the PQF
The contractor firm must submit a written plan designed to improve injury/illness
performance to the levels specified for an “approved contractor.” The action plan is to
include specific actions, responsibilities, completion dates, and measurable
improvement goals. Failure to show satisfactory improvement may result in reduction
or 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 the
injury/ illness performance criteria for an “approved contractor.” Contractor
firms will be given a reasonable amount of time to achieve compliance with these
criteria. Firms will not be able to remain “conditionally approved” for an
indefinite period of time.
Page 17 of 197
Bay Area Operations
Table of Contents
Leveraged
Approval
Leveraging approved contractors from other Gulf Coast Sites
The Bay Area SMAT has approved the process of leveraging an approved Gulf Coast
contract company status to a Bay Area site access database, provided the following
conditions are completed prior to site work by the respective contract company
commencing:
i.
Check Technical Qualification
ii. Complete Pre-Job Prior to Job
iii. Complete All About You for TCO/CLO – complete site orientation for
DHH/HOU
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 its
name, etc.
DOW Variance
Process (Waiver
for OSHA
threshold/EMR
rate)
Companies that can not meet the criteria above (and no other qualified
contractor can be found) may be accepted for work on the site if the following
conditions are met:
•
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.
•
meet or exceed the expectations outlined on the 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
and have a safety action plan in place to meet minimum expectations. (The company
must submit a Safety Action Plan that provides a detailed plan for addressing EH&S
requirements for work performed onsite.) The Safety Action Plan is developed in
participation with business requesting the work.
Page 18 of 197
Bay Area Operations
Table of Contents
DOW Contractor
Evaluation –
Maintaining
Approval Status
Generally independent contractor firms are pre-qualified on a one-time basis.
Contractor firms are assessed periodically (see Contractor Evaluation) to review and
update the approval status.
Individual company evaluation (One on One’s) – The Job Representative and/or
Purchasing initiates the evaluation process by soliciting input on the contractor’s
performance. The Bay Area sites have a Contractor Performance Evaluation form
(see Contractor Evaluation) that is completed and reviewed by the users, Job Rep,
EH&S, purchasing, and contract company during the contract company’s periodic
evaluation.
Bay Area SMAT evaluates the contractor’s performance based on the collective 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 and
reevaluation. The firm must submit a written improvement plan to include specific
actions, responsibilities, completion dates, and measurable improvement goals.
Failure to show satisfactory improvement constitutes a breach of contract and may
result 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 of
greater than 0.8
Then they must submit a Safety Action Plan to include specific actions, The
Safety Improvement Plan is developed in participation with the Bay Area SMAT.
Page 19 of 197
Bay Area Operations
Table of Contents
Waiver of the Contractor Qualification Policy
Bay Area Sites (CLO, HOU, TCO)
Dow is committed to zero incidents and the 2015 goals. This form is to be used if the contractor does not meet Bay
Area Contractor Qualification requirements, and there are no other contractors available who do meet the requirements.
Provisions of the Contractor Qualifications for Work on Site Requirements as specified in the Bay Area 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 the
contractor/vendor employee noted on this document.
1.
2.
Form Instructions:
All Items in the table below are required. Authorization should be obtained prior to arrival at badging.
Completed form must be submitted to Purchasing prior to initiating P.O.
Production Leader Authorizing Signature
Production Leader Master Number
EH&S Delivery Leader Authorizing Signature
EH&S Delivery Leader Master number
Approved Escort Signature (Initial)
Approved Escort Master number (Initial)
Contractor/vendor Employee (Please print)
Contractor/vendor Employee Signature
Company 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
Page 20 of 197
Bay Area Operations
Table of Contents
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 a
company who's OSHA rate puts them into the probationary category or above it is highly
recommended that special resources be made available to follow and track their work
activity on site. This should include 100% escort by a Dow representative (Dow EH&S
Tech 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 (both
job 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 the
use 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 Red
Danger tag" training before starting work. The “Red Tag” training included in the Dow Site Specific
computer based training is “non-user” only.
Red Danger tag “user” training should be provided by the Contractor Safety Council. If
weekends 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 before
starting work.
Red Danger tag “user” training should be provided by the Contractor Safety Council. If
weekends or off hours contact Dow Contractor EH&S.
Page 21 of 197
Bay Area Operations
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 random
testing with in the last 30 days their company should make provisions to have this done. They
can contact a local safety council to have the testing done.
It is HIGHLY RECOMMENDED that substance abuse testing be conducted before approving a
waiver.
Has the company received a copy of the "Bay Area Contactor's Administrative Safety Manual for
Service, Maintenance, and Construction?
This document is located on the Safety Council web site. Copies are also available through Dow
Contractor EH&S.
Has the contractor employee been issued a "training badge" by Dow or by one of the approved
Contractor 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 preliminary
report must be submitted to Dow Contractor EH&S by 10:00 the next working day (electronic to
the functional mailbox listed on the bottom of the form or fax to phone number listed . Refer the
Bay Area Contractor's Administrative Manual for forms and a reporting flow sheet.)
The use of the proper gloves are required for all "hand's on" work.
The glove use policy is available in the "Bay Area Contactor's Administrative Safety 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 Safety
Manual must be reviewed.
Page 22 of 197
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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 of
facility by The Dow Chemical Co. or any subsidiary; it is the employer’s responsibility to choose
appropriate facilities for their employees). Some examples are:
•
Drug Screens Etc
524 9th Ave N, Texas City, TX - (409) 948-2220
•
Mainland Testing Center
9300 Emmett F Lowry Expy # 156, Texas City, TX - (409) 978-2440
•
Interactive Medical Connection
700 Gemini St # 110, Houston, TX - (281) 486-4434
•
Bestcare Laboratory Services
202 N Texas Ave, Webster, TX - (281) 332-0300
•
Forward Edge Drug Testing
1209 Genoa Red Bluff Rd, Pasadena, TX - (713) 920-1335
•
Drug Screens Etc
1806 Center St, Deer Park, TX - (281) 478-5108
•
ExperTox Laboratory Services
1803 Center Street, Deer Park,, TX - (281) 476-4600
•
Quality Drug Screens
125 Sylvan St, La Porte, TX - (281) 471-4660
•
Friendswood Diagnostics
628 S Friendswood Dr, Friendswood, TX - (281) 648-2200
•
Drug Screens Etc
1010 Pasadena Blvd, Pasadena, TX - (713) 473-0495
•
Turn A Round Inc
102 W 2nd St, Deer Park, TX - (281) 476-9888
(Failure to comply will be grounds for removal from the site)
Page 23 of 197
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Table of Contents
Check
Has the company identified a local medical provider?
There are many industrial providers in the area (appearance on the following list does not imply
approval of facility by The Dow Chemical Co. or any subsidiary; it is the employer’s responsibility to
choose appropriate facilities for their employees). Some examples are:
•
Mainland Occupational Health Center
6801 Emmett F Lowry Expy Texas City, TX 77591- (409) 938-5112
•
Interactive Medical Connections Inc
700 Gemini St # 110, Houston, TX - (281) 486-4434
•
Occupational Medicine of La Porte
410 E Fairmont Pkwy # A, La Porte, TX - (281) 842-1200
•
San Jacinto Methodist Hospital Occupational Health Service
2610 N Alexander Dr, Baytown, TX - (281) 420-6200
•
Medical Plaza Mobile
1309 W Fairmont Pkwy # S, La Porte, TX - (281) 470-8770
•
Concentra Medical Centers
125 E 8th St, Deer Park, TX - (281) 930-8555
•
Medical Plaza Occupational Surveillance
1309 W Fairmont Pkwy, La Porte, TX - (281) 470-1944
•
Alliance Health Resources Inc
•
AMD Occupational Medical Services
Page 24 of 197
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Available
resources
Dow Contractor EH&S
•
Donna Coyle – TCO
Work # 409-948-5965
Weekends and after hours:
Cell # 409-332-2021
•
Dean Butler – CLO
Work # 713-751-7319
Cell # 409-771-6292
•
Janice Cupples - LaPorte
Work # 246-0122
Cell # 713-304-3742
•
Contractor Safety Council of Texas City – (409) 948-9009
•
Houston Area Safety Council - (281) 476-9900
Page 25 of 197
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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., Bay Area
Operations worksite.
Background
The Dow Chemical Co., Bay Area Operations ("Dow") considers the misuse or abuse
of alcohol and the use of illegal or unauthorized drugs to present a serious threat to
the health and safety of any person working on its premises and the surrounding
community and to interfere with the efficiency and productivity of work being
performed on its premises.
Definitions
Hair Testing: Analysis of hair samples to detect the presence of tested drugs and/or
their metabolite(s) at reportable levels. Testing will be performed by a laboratory
whose 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 for
the purpose of collection of drug and alcohol testing samples. The contracted
company must be certified and those individuals that collect samples must be
trained and qualified. As it applies to “hair testing”, the process used must be
approved, cleared, or otherwise recognized by the Food and Drug Administration
as accurate and reliable for the testing of such specimens. In addition this must
include all panels and all hair types and must assure the test excludes
contamination.
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 and
items by any contractor, subcontractor, vendor, and their employees
(collectively, "CONTRACTORS" and individually, "CONTRACTOR") is
strictly prohibited from Dow premises:
ILLEGAL DRUGS; UNAUTHORIZED CONTROLLED SUBSTANCES
LOOK-ALIKES; DESIGNER AND SYNTHETIC DRUGS (INCLUDING
THE PRESENCE OF ANY DETECTABLE AMOUNT IN THE EMPLOYEE
WHILE WORKING); ANY OTHER ILLEGAL OR UNAUTHORIZED
DRUGS OR ABNORMAL SUBSTANCES WHICH MAY AFFECT AN
EMPLOYEE'S SENSES, MOTOR FUNCTIONS, OR ALTER A PERSON'S
PERCEPTION WHILE WORKING; ALCOHOLIC BEVERAGE; AND
DRUG PARAPHERNALIA.
Page 26 of 197
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Contractor Substance Abuse Policy continued
Policy cont’d
B. CONTRACTORS who regularly perform labor or services on Dow premises
must have and administer a formal substance abuse interdiction policy. Such
policy 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 confirmation
of positive alcohol tests) to determine the use of any illegal or unauthorized
substances prohibited by this Policy. Non compliance to the testing requirements
of this policy will result in the removal of the individual involved from the site for
a minimum of 12 months. These tests shall be administered under the following
conditions:
1. Pre-employment and pre-access drug and alcohol testing of current employees
returning to Dow premises from layoff or outside job assignment shall be
accomplished by the use of hair testing for drugs and swab and/or breathalyzer
testing for alcohol, with the following exceptions:
a. Contractor employees that are currently employed by the contractor
firm and have been subject to random testing for that company within
the last 90 days are exempt from the pre-access testing requirements.
b. Contractor employees new to a contractor firm which is participating
and in compliance with the Texas City Operations “Contractor
Substance Abuse Policy” and who are designated as “Approved for
Work” for the Texas City Operations Texas City Site in the VECTORTM
database maintained by Psychemedics are exempt from the pre-access
testing 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 a
reasonable suspicion or belief that CONTRACTOR's employee shows signs of
being under the influence of, or in possession of, any substance or item
prohibited by this Policy. For the purposes of this Policy, reasonable suspicion
or belief can include occupational on-the-job injury or involvement in a serious
or potentially serious accident or incident. For cause drug testing shall be
accomplished using urinalysis and for cause alcohol testing will be
accomplished using the swab testing method with breathalyzer testing for
confirmation of positive tests.
During each 12-month period CONTRACTOR will randomly select for drug testing a
sufficient number of the employees assigned to Dow operations/facilities so that the
number of tests conducted will equal at least 50 percent of the individual employees
who are badged for the Dow Texas City Site. Such testing shall be conducted
monthly. (In the case of short duration jobs the contractor may be requested to
conduct random tests on a weekly basis.) It is our intent that all contractors
working at the site be subject to random testing hair. The method of testing required
to accomplish these tests will be hair testing for drugs and swab testing for alcohol
with 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.
Page 27 of 197
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Contractor Substance Abuse Policy continued
Cutoff Level in Nanograms
B. Substance Testing
Each specimen will be tested for at least the following drugs and will be
reported positive when the number of nanograms per milliliter equal or exceed the
indicated cutoff level:
Drug Class
Cannabinoids (marijuana)
Cocaine
Opiates
Amphetamines
Phencyclidine (PCP)
Initial
50
300
2000
1000
25
Confirmation
15
150
2000
500
25
Alcohol testing: Alcohol tests will be considered positive if the blood alcohol level of an individual is at
or above .02.
General
Requirements:
•
•
•
•
•
•
•
Pre-employment and random drug testing must be completed using the hair
testing 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 and
must 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 supervision
to escort the individual to the test site.
All testing and collection of test specimens must be administered by a
qualified third party.(no in-house testing will be accepted)
Post accident and for cause testing the tests must be completed as soon as
possible.
Failure to comply with the stated drug program will result in the individual
being 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 Bay Area SMAT.
Page 28 of 197
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English Comprehension Policy
Purpose
To assist in maintaining a safe and efficient work place by assuring written and
spoken comprehension of the English language.
Scope
This applies to all personnel working at the Bay Area sites.
Background
All safety signs and verbal warnings are presented in English. Because of this
standard process English comprehension is required.
Policy
Any contractor, subcontractor, vendor, and their employees (collectively,
"CONTRACTORS" and individually, "CONTRACTOR") performing labor or
service on Bay Area sites’ premises, which includes all property owned, operated, or
leased by or under the control of Dow's Texas City, LaPorte, and Clear Lake
("Premises") shall be able to comprehend English. English comprehension is defined
as the ability to read and understand, hear and understand, speak and be understood
and writes his/her name in English.
Exceptions
In certain limited instances (e.g., a consultant on a specific project), a
CONTRACTOR's employee not meeting the requirements of this Policy may
perform labor or service on Dow Premises if they are escorted 100% of the time by a
CONTRACTOR-provided interpreter. Such exception must have prior approval by a
Dow Job Representative. The interpreter shall devote special emphasis to safe
procedures, emergency procedures, scope, understanding, and communication
concerning the safe performance of work.
Page 29 of 197
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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 Bay Area worksites.
Scope
This applies to all contractor companies working on the Bay Area worksites.
Background
In the past there has been some confusion in the contractor community as to the
expectations and responsibilities of contractor firms working on a Dow Chemical
Company Site.
Responsibilities
Item
Description
1
The Contractor shall actively and adequately promote safe working
performance on the part of its employees. The Contractor shall participate
in activities to this end, such as contractor safety organizations (e.g.,
Contractor Safety Alliance, Contractors' Safety Council.), contractor owner
programs, etc. It is expected that each Contractor will conduct its own
safety programs to best suit its particular needs.
2
Contractors MUST report immediately those employees (by name)
DISCHARGED for safety rule infractions in writing to Dow Industrial
Security and the Owner's Representative. The reason for the discharge must
be given. Such employees will not be allowed to return to any Owner's
work without proper authorization from the Owner.
3
Prior to starting any field work on each job, the Job Representative will
conduct a pre-job safety conference with an authorized representative of the
Contractor, an owner Manufacturing Representative, available
subcontractor’s representatives and Owner’s safety representative, when
available.
At this time, the nature of any chemical hazards or special safety rules for
the area will be reviewed with the owner Process Representative and the
Contractor will be provided with printed copies of the area rules where
applicable.
The “Pre-Job Safety Checklist” form (See in Appendix) will be prepared by
the Owner’s Representative and a copy furnished to the Contractor.
4
In addition to the basic contractor safety indoctrination, contractor
employees shall receive block or unit safety pre-job orientations covering
the hazards for that area prior to starting work.
Page 30 of 197
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Contractor Safety Responsibilities, cont.
Responsibilities
(continued)
Item
5
6
Description
Contractors must be aware of the following policies:
•
English comprehension requirements – (See English
Comprehension Policy)
•
Contractor’s Substance Abuse Policy – (See Substance Abuse
Policy)
Contractors shall use a regular system of work site inspection to detect and
correct hazardous conditions, safety rule violations and unsafe work
practices. These safety inspections shall be reported to the Job
Representative.
Contractors shall maintain continuous safety planning to cover jobs where
circumstances have changed and new hazards require new controls.
7
It is the Contractor’s responsibility to make sure that all injured/ill personnel
receive prompt medical attention at an approved medical facility.
Written notification must be submitted on every injury or serious incident to
the Job Representative 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,
including vehicle accidents, and submit a final report to the Job
Representative and Contractor EH&S.
8
Prior to ordering vacuum trucks, Contractor shall coordinate with the Job
Representative and Environmental Operations.
Contractors shall inform the Job Representative of any hazardous material
they may bring 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 site any materials or suppliers not required or specified by the contract.
Page 31 of 197
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Minimum
Requirements
The items listed below are the minimum requirements for Contractor and Supplier
Safety Training.
Item
Description
1
Before working on Dow property EVERY contractor employee must be
indoctrinated with the Dow Safety Rules book through an approved safety
indoctrination program. Contractors shall inform all their employees that
they must comply with the Safety Rules, procedures, and rules of the
department in which they are working and site Safety Standards.
2
Contractors who perform work on Dow controlled property must receive
basic contractor safety indoctrination prior to starting work. It is required
that all Contractors use the orientation program administered by the
Contractors' Safety Council.
•
The contractor is responsible for scheduling this training at the
Safety Council,
•
A record of this training shall be maintained
•
Any contractor employee who has not worked on Dow controlled
property for 12 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 an orderly 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 toilets from Dow property.
3
Metal buildings served with electricity shall have the service entrance
switch and the skin of the building grounded in such a manner that neither is
dependent upon the other. Electrical bonding jumper wires at corners and
roof are required ONLY if building 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
1
Description
Fire Extinguishers:
a. A fire extinguisher for welding and cutting operations can be
obtained through the Job Representative.
b. It is also the Contractor's responsibility to arrange, through the Job
Representative, for the recharging and resealing of owner furnished
extinguishers immediately after each use.
2
It is the Contractor's responsibility to obtain approval through the Job
Representative on the proper location of all fuel storage tanks. In all cases
the tanks shall be located or the area diked or sloped so that a spill shall not
create a hazard to operating plants or contaminate ditches or navigable
water.
Demolition
Item
Description
1
Due to the inherent hazards in demolition work, special care must be
devoted to safe procedures, scope understanding and communications
concerning the safe performance of work.
2
Responsibility for field supervision of demolition work must be delegated
only to those whose experience qualifies them to make the necessary
judgments and decisions that are required to assure the safest possible
completion of the job.
3
The Contractor shall make certain that all lines, services and equipment
have been cleaned or purged and properly cleared for safe removal. All
lines (including water and 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
otherwise hidden lines, cables and sewers using the best available
information and Owner's assistance.
Page 33 of 197
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Demolition
(continued)
Item
5
Description
The pre-job safety conference with the Contractor shall devote special
attention to pre-planning the safety aspects of demolition jobs.
•
Steps of dismantling and loads to be handled shall be reviewed
with the Job Representative prior to starting work.
•
Temporary provisions shall be made where safety showers,
eye-wash baths and fire extinguishers are being moved in the
work area.
•
Special attention shall be given to the marking of hazards and
the barricading of hazardous areas for the protection of all
personnel, including those not directly involved in the
demolition work.
Medical and
Industrial Hygiene
Requirements
Item
1
Description
Health and hygiene training - The Contractor shall be responsible for
providing training which includes, but is not limited to the following:
•
General training requirements under the Hazard Communication
Standard 29 CFR 1910.1200 (e.g. overview of the standard and
how to read an MSDS).
•
Asbestos training required by OSHA 29 CFR 1910.1001 or
OSHA 29 CFR 1926.1101.
•
Respirator training required by OSHA 29 CFR 1910.134
(Respiratory Protection).
•
Hearing conservation training and audiometric testing required
by OSHA 29 CFR 1910.95 (Occupational Noise Exposure).
•
Hazardous waste operations and emergency response training by
OSHA 29 CFR 1910.120 or OSHA 29CFR 1926.65.
Page 34 of 197
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Medical and
Industrial Hygiene
Requirements
(continued)
Item
2
Description
Respirator training fit testing and medical approval.
⇒
Routine or emergency response respirators
•
The Contractor is responsible for the required fit testing,
training and medical approval for all employees who use
the following types of respirators:
air purifying half and full face masks,
SCBA and airline systems.
⇒
3
•
Documentation must be retained and Contractor records are
subject to audit.
•
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.
Contract Companies are responsible for any required Industrial Hygiene
monitoring (lead, asbestos, noise, etc.). Records must be made available to
Dow Job Rep upon request for auditing purposes.
Page 35 of 197
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Minimum Requirements
for 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. For
example, a contractor engaged in scaffold building should have a program that
addresses 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 move
above ground elevation is not considered sufficient detail from the DOW perspective).
Page 36 of 197
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for Contractor Safety and Health Programs, cont.
Management
Systems –
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 the
contractor’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 in
compliance with all applicable standards and these programs appropriately
consider fit for duty considerations.
7. Ensure a process is in place for dealing with emergency medical treatment and
first aid cases which includes identification of local medical provider. Have a case
management process and trained personnel to implement.
8. Ensure availability of Material Safety Data Sheets (MSDS) for all materials
brought 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 are
also required to be pre-qualified by DOW for work on DOW sites – contact
our purchasing group to initiate the prequalification process.)
• Accept responsibility for the safety performance and ensure subcontractors fit
for duty requirements are adequate.
10. Provide appropriately trained and competent personnel and ensure a process for
selecting qualified employees.
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Management
Systems –
Optional
Optional for Continuous Improvement:
1. Have a dedicated site or project safety person.
2. Have a safety and health recognition program.
Opportunity
Identification –
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 STAC
card or equal. The pre-job task analysis hazards must be applicable to the work
that is performed by the contractor.
Opportunity
Identification –
Optional
1. Make recommendations to appropriate DOW personnel for changes to DOW
safety policies and procedures that affect contractors.
2. Seek customer feedback for work performed, i.e. quality timeliness, budget
considerations.
Personal
Involvement –
Required
Required:
1. Require employee intervention on unsafe conditions/situations/practices and make
employees 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 through
performance 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.
Personal
Involvement –
Optional
Involve all levels of personnel in audit activities.
Page 38 of 197
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Training –
Required
Required:
1. Implement employee orientation and EH&S training programs that include all
legally required elements; for example hazard identification and control, reporting
of accidents and incidents, safe work practices, Personal Protective Equipment and
Hazard Communication (HAZCOM).
2. Ensure appropriate EH&S and craft training is conducted and verification of
understanding is completed as appropriate (classroom, field, etc.).
3. Ensure all training is documented.
4. Ensure documentation of craft and technical training for work that requires
certification (ex. Asbestos removal), work with or near government regulated
chemicals or materials, or work when acting as an agent of The Dow Chemical
Company.
5. Include safety management training for all 1st line supervisors.
Communication –
Required
Required:
1. Conduct regularly scheduled/formal safety meetings. At a minimum, weekly
safety 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 possible
after their occurrence.
3. Immediately communicate to DOW personnel any hazards found while on the
work site as well as any hazards that the contractor’s work may introduce into the
work site.
4. Participate in pre-job safety conferences. Communicate details of these to
employees.
5. Ensure all employees are able to appropriately understand and communicate safety
and health information including, but not limited to, the applicable portions of the
emergency 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.
Page 39 of 197
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Standards and
Operating
Discipline –
Required
Required:
1. Ensure project pre-planning includes analysis of safety and health hazards.
2. Comply with all governmental, DOW standards, policies, and any other
contractual 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 required
by 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 is
used by the contractor.
2. Conduct periodic audits to ensure compliance with the elements of the safety and
health 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 their
work on the site.
Audits – Optional
Participate in team audits of other contractors on various DOW work sites.
Root Cause
Investigation –
Required
Required:
1. Investigate all reportable accidents/incidents as defined by DOW site standards to
determine the root cause.
2. Document all investigations consistent with site requirements.
3. Communicate all accidents/incidents and near misses to company employees and
DOW personnel.
4. Ensure a corrective action follow-up system is in place to implement
recommendations associated with the incident.
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Performance
Measurement –
Required
Required:
Performance
Measurement –
Optional
Public Interaction
– Optional
Have a measurement system in place to track performance toward defined safety
goals and objectives.
Develop and use proactive safety measures.
1. Participate in contractor associations.
2. Participate in trade organizations.
Page 41 of 197
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Table of Contents
Contractor Program Checklist
Contractor:
Contractor
Address
Contractor
Service
Point of
Contact
Phone
Initial
Performed by:
Review Date
Next
Performed by:
Review Due
This program must include elements that are specific to the work performed. For example, a
contractor engaged in scaffold building should have a program that addresses 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 move above ground elevation is not considered sufficient
detail from the DOW perspective).
Management Required:
1. Have a formal, written safety and health program in place including a policy statement with
Systems
elements for employee participation, management commitment and supervisory accountability
as well as enforcement procedures and emergency plans.
Guidance
Elements
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
Safety Program
MOC
Medical Provider
N
English Comprehension
Safety Goals & Objectives?
Y
N
Background Screening
Safety Focal Point Y
N
Name:________________
Remarks
Page 42 of 197
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Contractor Program Checklist, cont.
Optional for
Continuous
Improvement
Opportunity
Identification
Optional for
Continuous
Improvement
1
Have a dedicated site or project safety person.
Y
N
2.
Have a safety and health recognition program
Y
N
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
3. Perform pre-job task evaluation for safety/hazard analysis, utilizing the
STAC card or equal. The pre-job task analysis hazards must be
applicable to the work that is performed by the contractor.
Y
N
1. Make recommendations to appropriate DOW personnel for changes to
DOW safety policies and procedures that affect contractors.
Y
N
Y
N
1. Require employee intervention on unsafe conditions/situations/practices
and 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 health
programs through performance reviews, disciplinary systems,
recognition programs, audits, etc.
Y
N
4. Hold supervision accountable for the safety performance of their
employees.
Y
N
5. Use a safety suggestion system.
Y
N
6. Establish a behavior observation program.
Y
N
Y
N
Required:
2. Seek customer feedback for work performed, i.e. quality timeliness,
budget considerations.
Personal
Involvement
Required:
Remarks
Optional for
Continuous
Improvement
1. Involve all levels of personnel in audit activities.
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Training
Required:
1. Implement employee orientation and safety/health training programs
Y
N
2. Ensure appropriate safety and craft training is conducted and
verification of understanding is done as appropriate (classroom, field,
etc.).
Y
N
3. Ensure all training is documented
Y
N
4. Ensure documentation of craft and technical training for work that
requires certification (ex. Asbestos removal), work with or near
government regulated chemicals or materials, or work when acting as
an agent of The Dow Chemical Company.
Y
N
5. Include safety management training for all 1st line supervisors.
Y
N
1. Conduct regularly scheduled/formal safety meetings. At a
minimum, weekly safety meetings should be held.
Y
N
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 possible after their occurrence.
Y
N
3. Immediately communicate to DOW personnel any hazards found
while on the work site as well as any hazards, which the
contractor’s work may introduce into the work site.
Y
N
4. Participate in pre-job safety conferences. Communicate details of Y
these to employees.
N
5. Ensure all employees are able to appropriately understand and
communicate safety and health information including, but not
limited to, the applicable portions of the emergency plan, fire,
explosion and toxic release hazards.
Y
N
6. Provide DOW personnel with requested information on its
periodic evaluations.
Y
N
that include all legally required elements; for example hazard
identification and control, reporting of accidents and incidents, safe
work practices, Personal Protective Equipment and Hazard
Communication (HAZCOM, WHMIS, etc.).
Remarks
Communication
Required:
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Remarks
Optional for
Continuous
Improvement:
Standards and
Operating
Discipline
1. Share learning experiences with DOW and other contractors.
Y
N
2. Conduct toolbox or tailgate safety meetings.
Y
N
3. Keeps written safety meeting minutes.
Y
N
1. Ensure project pre-planning includes analysis of safety and health
hazards.
Y
N
2. Comply with all governmental and DOW standards and policies as
well as any other contractual agreements.
Y
N
Required:
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
5.
Ensure employees appropriately use Personal Protective Equipment
as required by the job and consistent with the site policy.
Y
N
6. Have written safe work procedures in place.
Y
N
7.
Y
N
Y
N
Have written company specific safety rules and standards.
Remarks
Audits
Required:
1. Conduct safety audits and housekeeping inspections of the worksite
or area that is used by the contractor.
6.
Conduct periodic audits to ensure compliance with the elements of
the 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
5.
Ensure supervision conducts frequent workplace inspections
(walkthroughs).
Y
N
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6. Conduct safety performance review of subcontractors during the
course of their work on the site.
Y
N
Optional for
Continuous
Improvement:
1. Participate in team audits of other contractors on various DOW
worksites.
Y
N
Root Cause
Investigation
Required:
1. Investigate all reportable accidents/incidents as defined by the
DOW site standards to determine the root cause.
Y
N
2.
Document all investigations consistent with site requirements.
Y
N
3.
Communicate all accidents/incidents and near misses to DOW
personnel.
Y
N
Y
N
Y
N
Y
N
1. Participate in contractor associations
Y
N
2. Participate in trade organizations
Y
N
Remarks
4. Ensure a corrective action follow-up system is in place to
implement recommendations associated with the incident.
Remarks
Performance
Measurement
Required:
1. Have a measurement system in place to track performance toward
defined safety goals and objectives.
Remarks
Optional for
Continuous
Improvement:
Public
Interaction
1. Develop and use proactive safety measures.
Remarks
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BAY AREA
WAIVER 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 the
DOW OSHA threshold rate of 2.0 or EMR rate of .8 or less, and there are no other contractors available who meet the
requirements.
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. (The
contract company must submit a Safety Action Plan that provides a detailed plan for addressing EH&S
requirements for work performed onsite.) The Safety Action Plan is developed in participation with the
business 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.
1.
2.
Form Instructions:
All Items in the table below are required. Concurrence should be obtained prior to arrival at badging.
Production/Functional Leader Approval Signature
Production/Functional Leader Master Number
EH&S Delivery Leader concurrence
Site Approved Escort Signature (Initial)
Site Approved Escort Master number (Initial)
PO Number (Completed by Contract Administrator)
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SAFETY ACTION PLAN
Safety Action Plan
Job/Project Information
Job/Project Name
Job/Project Location
Start Date
Completion Date
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 respective
sections. The completed document must be signed by each contract employee, prior to beginning
work, 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 any
requirements for individual unit/plant orientations required nor does it change the
requirement to follow the process to add a Contractor Company and Labor Services
Acceptable 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.
Minimum
Requirements
Minimum requirements by classification (Definitions is on the following page).
• Details for Bay area site entry requirements based on scope of work are
included in the Bay area Site Access Matrix; found on US Area Site Access
under Site Specific Requirements:
• Foreign Nationals requesting plant entry must meet Guidelines required by
the Export Import Regulatory Affairs. For more information see Foreign
National Visitor Web Site.
• Former Dow/ employees must also be assessed (see US Area Site Access
requirements).
Classification
Contingent
Staff
Description
An individual provided to DOW by a resource supply company
(contingent staffing firm) to supplement the DOW work force.
Broad categories include office professionals,
technical/professional, distribution technicians, and
engineering/design.
DOW assigned daily tasks, inclusion in the DOW Facility / Work
Group EH&S training and programs, and flexibility in needed
work hours, characterize this service.
All contingent staff shall be assigned to a DOW Employee in terms
of reporting purposes. Contingent staff will receive initial
orientation and then be included in EH&S Training and programs
while working at the DOW Site. Contingent Staff personnel are
issued Non-Dow Services ID Access Badge for the duration of
work at the facility.
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Site Access for Contractors, Delivery, and Visitors, cont.
Minimum
Requirements
(continued)
Classification
Delivery
Description
A company or individual that has a contract or purchase order with
Dow, delivering supplies/materials or distribution service, moving
on and off Dow sites as a routine part of daily activities. Broad
categories include vendor stocking, vending machine
replenishment, mail service, equipment delivery/service, fuel or
raw material delivery, product pick up and removal from the site,
and distribution of DOW product off the site.
Non-DOW supervision, independent organization, and movement
restricted to road ways, storage, construction and office areas
characterize this service.
Pre-qualification is not required for Delivery Services. Pre-job
activities will include a pre-job meeting that establish and reinforce
EH&S performance expectations will be conducted.
Delivery Service personnel may be required to obtain Safety
Council training or be given the Visitor/Vendor Orientation Card
(describing the facility, critical behaviors to follow, and EH&S
expectations while on the site) as required by the Site Access
Matrix. The host, where applicable in conjunction with the
contract administrator, is responsible for determining if the EH&S
requirements are being met on a daily basis.
Independent
Contractors
In addition to prequalification, their company must have a signed
Dow Hold Harmless on file. (Sub-contractors are covered by the
general contractor’s Hold Harmless Agreement.) The contract
company employee(s) must have a Contractor Safety Card and
signed contractor hire sheet. The contractor completes the prejob activities including a pre-job meeting with the contract
administrator and EH&S contact that establish and reinforce EH&S
performance expectations.
Lab/Office
Equipment
Service
The contract company employee(s) must have a Contractor Safety
Card and their company must have a signed Dow Hold Harmless
on file. Review the DOW Site Access Matrix for other
requirements.
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Minimum
Requirements
(continued)
Classification
Visitors
Description
Visitors must sign in through Security and be escorted at all times
by an authorized person. DOW Visitor/Vendor Policy requires a
pass to be completed by an authorized person prior to admittance.
The host will review the Visitor/Vendor Orientation Card
(describing the facility, critical behaviors to follow, and EH&S
expectations while on the site) with the Visitor.
Issues with special cases should be coordinated through ES&S.
Visitors to
Buildings with
Public Access
Company
Approval for
Working on Site
Variance Process
To receive a temporary pass sign in with the building receptionist
and be escorted at all times by an authorized person. Entrance
would be for that building only. Entrance into the plant would
require following the Visitor process listed above.
•
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.
The Process Leader, or their “Designated Back-up”, responsible for the area where the
activity is taking place, must approve variances from the requirements of OSHA/EMR
rate, 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 Harmless
Waiver
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Pre-Job
Requirements
The purpose of this process is to ensure contractors working at DOW are appropriately
indoctrinated into site requirements.
Pre-Job Meeting - The purpose is to ensure that all EH&S requirements and
expectations are communicated to and understood by each contractor company prior to
work start up and review specific details relative to contractor safety after the contractor
has been selected and is within a week or two of beginning work.
DOW
Expectations for
Contract
Companies - “It’s
All About You”
All Contract Employees are required to attend the “It’s all about You” presentation prior
to being allowed to perform work. The “It’s all about You” process establishes basic
expectations for all personnel working at Dow. Once the orientation is complete
contractors will be required to sign a document indicating they have completed and
understood the material.
Minimum
Requirements for
Issuing an Entry
Badge
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 Testing
complete
•
Possession of a Contractor Training Card indicating those dates that specific
training 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 the
facility at the appropriate location and sign-out upon departure.
Requirements for
Driving Access
All requirements for the Entry Badge must be met plus the individual must possess a
Valid Driver’s License for the type of vehicle driven and the Driver Module CBT
(computer based training) training from the Safety Council.
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Definitions
Term
Visitors
Definition
An individual at DOW other than the DOW personnel and NonDow Services Providers who 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, tour participants, sales persons,
agency inspectors, and consultants.
They are not allowed in process areas without following the
appropriate Badging process.
Independent
Contractors
A company or individual that is under contract, sub-contract, or
purchase order to provide services on Dow sites. Broad
categories include maintenance, operations and construction.
Non- DOW supervision, with an independent organizational
relationship.
Sub Contractors
They are employed and paid by the Direct Contractor, and could
perform work in a process area.
Lab/Office/Equipme
nt 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 on behalf of DOW. In either case the
Authorized Person should be knowledgeable enough to oversee
the safety of the visitor they are escorting. Responsibilities
include at a minimum:
• 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 to submit to DOW the Standard
Prequalification package and be reviewed by the Discipline
Specialist, Labor Services Purchasing, and Contractor Safety.
This package is sent out by Procurement when there is a
legitimate need to add a new contractor company. Once the
prequalification package is received back from the company this
review process could take up to two weeks.
Hold Harmless
A signed legal document. It is intended to insure proper
insurance coverage of the contract company and to protect Dow
regarding claims arising in the course of a contractor working on
Dow premises. If there is a problem in obtaining a signed Hold
Harmless the involvement legal departments of both Dow and
the Contract Company may be required.
Safety Action Plan
A plan established in agreement with the contractor firm's safety
representative, the contractor project manager, the DOW
Manufacturing Rep and DOW EH&S delivery that identifies
specific contractor EH&S contacts for the job/project and
outlines specific EH&S job/project requirements.
Contractor Safety
Card / Training Card
A laminated card to be attached to an individual contractor's
badge that identifies the date that individual was trained on
various topics (Red Tag, confined space entry, SWP, etc.).
Contractor Safety/Training Card is issued by Contractor Safety
Council after completing required safety training.
Dow Background
Check
A background check will be conducted on all persons requesting
a permanent type entry badge to Dow sites in order to determine
if any reason exists to refuse or limit access to the Dow sites.
This background check will be conducted only when an
individual is requesting entry to Dow sites, and covers only the
individual’s ability to enter the Dow sites.
Labor Services
AMSL
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 be found
on the Dow Intranet at this web site:
http://gpurchasing.intranet.dow.com/amsl2/default.asp
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Definitions
(continued)
Term
AMSL MOC
Definition
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 than those listed on the DOW
AMSL, you will need to 1) submit a MOC to add that
manufacturer/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 of acceptable 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 the SSG change request form is:
http://gpurchasing.intranet.dow.com/virtual/document
s/amsl/SSG_Change_Request_form.dot
Contractor Gate
Entry Status
Database
Multi-site database used to verify supplier status
(approve/denied) before entering labor requisition.
Contact the appropriate Contract Administrator to determine
which company may be requested based on scope of work
(AMSL must be used first to determine which company’s are
approved for specific disciplines, e.g. Hydroblasting, etc.)
Contractor's Safety
Alliance Teams
Two teams of contractor safety and management representatives
consisting of companies that work on the DOW Site (one team
for general maintenance and construction and another for
administrative/non-process area work) working together to
improve safety, health, and environmental performance.
STAC (Safety Task
Analysis Card)
Training
Task analysis is a process by which a job is broken down by into
tasks, each task is evaluated to determine those hazards that
apply to the task and identify measures that will control or
eliminate those hazards. STAC training is required for crew
leaders, foremen, and supervision.
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Definitions
(continued)
Term
Definition
ARSC
ARSC stands for Association of Reciprocal Safety Councils.
These safety council's have an agreement to recognize Basic +
and Basic + refresher training delivered by any council in the
association.
Contractor's Safety
Council of Texas
City
A third party, non- profit organization dedicated to furnishing
safety and health training to the contractor community
Houston Area Safety
Council
A third party, non- profit organization dedicated to furnishing
safety and health training to the contractor community
Training Courses
Training Courses Available through the Contractor Safety
Available through
Council:
the Contractor Safety
Council
Course
Description
Basic +
A training course designed for the
individual that has never worked in the
petro-chemical industry before and is
administered by an instructor that is
available to answer questions and
furnish individual instruction. Basic +
training is available through the
Contractor's Safety Council or any
council that is a member of ARSC.
Basic + Refresher
A training course designed for
individuals that have worked in the
petro-chemical industry in the past and
is delivered by CBT (computer based
train) with no instructor available for
questions/answers. Basic + refresher
training is available through the
Contractor's Safety council or any
council that is a member of ARSC.
DOW Red Tag
Training
A training course or CBT (computer
based training) process that addresses
the need of individuals that will be
working on equipment which requires
lockout/tag out.
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Definitions
(continued)
Term
Training Courses
Available through
the Contractor Safety
Council (continued)
Contractor hire slip
Definition
Course
Description
DOW Confined
Space Entry
Training
A training course or CBT process
which describes the process that
addresses those individuals that will be
performing confined space entries or
will act as “safety attendant” for a
confined space entry
DOW Safe Work
Permit Training
A training course or CBT process that
addresses the need of individuals
accepting a Safe Work Permit and/or
that will be performing work which
requires a Safe Work Permit.
Gulf Coast DOW
Training
addresses the needs of individuals that
will be performing work at a DOW
Gulf Coast.
DOW Driver
Training
will be driving on DOW property or on
DOW business.
DOW Scaffold
User Training
will be accessing scaffolds at the Bay
Area sites.
A document that identifies the name, social security number, and
other information specific to the contractor individual that is to
receive a badge.
The sheet provided to security confirming that the General
contractor requests this person to be badged and confirms other
requirements have been completed. A Job
Representative/Contract Administrator/DDC Owners
Representative must sign this sheet.
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
1
Actions
Contractor: Complete the Hire-in Slip, this is a requirement.
Requires signatures of the contract employee, Contractor Company Rep, and
Dow Rep.
•
Must provide complete Name (Last Name, First and Middle Names);
no abbreviations or nicknames.
•
Social Security Numbers are required for US citizens
•
Foreign nationals will be required to produce passports or other means
of identity validation and follow the foreign national’s procedure.
Company Rep responsibilities:
The Contractor Hire-Slip requires the signature of a company rep to
validate the following requirements are met:
2
3
•
All required safety training has been completed
•
Contract company employee is compliant with the pre-access
substance abuse requirements
•
Criminal background check has been completed and employee
meets required acceptance criteria
Proof of Identity:
•
Current Driver’s License or
•
State Issued Identification Badge
Current Safety Indoctrination Badge from Safety Council
Minimum Safety Council training requirements include Basic Plus safety
course, Dow Site 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
You management expectations (may not be available at every site at this time
but a site specific indoctrination will be required).
Unit indoctrination is conducted at the production areas after the employee has
received 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) going
to work in Dow Bay area sites must bring their completed 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 the
applicant.
Badges
Temporary Badges
Badges:
•
Badge must be worn and visible at all times unless safety requirements
warrant otherwise; and then should be in the person’s possession.
•
Upon termination of employment with any contractor company, applicant
must 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:
•
Employment verification by an authorized company representative is
required prior to issuing a temporary badge.
•
Temporary badges will be issued to personnel with expected onsite duration
of less than 5 days. Temporary badges and Safety Council badges with
pictures ID must be visible at all times.
•
Upon completion of the job, Contract Services or the accountable Project
Leader must be notified by the contractor in order for the badges to be
deactivated. 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 Dow
property.
•
Visitors must provide a Dow representative’s name, phone number and area
location.
•
Visitors should be escorted to and from their destination and at all times
while on Dow property by an approved Representative.
•
Resident Contractor’s can be designated by the Visitor Pass Approver to
escort visitors. Visitor Pass Approvers are accountable to assure the escort
can fulfill all responsibilities. The responsibilities include at a minimum:
Knowledge of emergency response requirements
Job scope knowledge
Knowledge of all applicable site rules
Contractor
Identification
Badge Guidelines
•
Visitors must sign a visitor’s log.
•
Visitors should be badged and visibly display badge at all times while on
Dow property.
•
Visitors should surrender visitor’s badge prior to exit from Dow property.
There are no global contractor badge design specifications. Listed below are
guidelines, recommendations and restrictions.
RESTRICTION: The Dow Diamond SHOULD NOT appear on any contractor
badge.
•
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 Dow
and Non-Dow sites so that badge similarities can be avoided (“Dow” refers
to The Dow Chemical Company and consolidated subsidiaries, including
Union Carbide.)
•
All Contractor badges should include a recent photograph.
•
The same information fields that appear on a Dow badge should appear on a
contractor badge. i.e. First name, last name, badge number and the Dow site
name and/or location.
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Contractor Hire
Slip Instructions
•
Employee requesting badge & their supervisor to complete this form
•
If employee requesting badge is a Foreign National or a former Dow or
subsidiary employee. See Contractor Admin Manual for instructions and
forms. Bay Area Admin Manual is available at the Safety Council. Contract
Services must receive verification from the appropriate Dow 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 identification
with them in order to receive a badge.
•
Employee must have a clear understanding of their job role and know who
their contact is.
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CONTRACTOR HIRE SLIP
PLEASE PRINT CLEAR & LEGIBLY
DATE: ___________________
Requesting Badge For
Demotion
New Construction
Contract Maintenance
Vendor
Service Provider
Pipeline Pipeline badges require appropriate pipeline approval & forms.
Last
First
Middle
State
Zip Code
Street Address
City
Safety Council Badge
Number
Supt. OR Forman:
Company:
Company New Hire
Yes
No
Is your company
UNION
Yes
No
Birthplace:
EYE COLOR:
AGE:
DATE OF BIRTH:
HEIGH
T:
WEIG
HT:
HAIR COLOR:
SEX:
RACE:
CITIZENSHIP
:
DRIVERS LICENSE
#:
STATE:
EXP.
DATE:
Foreign National or Former Employees Will Require Additional Verification
Consult Contractor Admin Manual For Instructions & Forms.
Foreign National or
Yes
No
Former Dow
subsidiary Employee
Completion of a
Will require approval from Dow Midland
subsidiary of the Dow
International Trade Group before badge
Yes
No
Chemical Company –
will be processed. Verification must be
Foreign National
sent to site ES&S 5 working days prior to
Policy
obtaining badge.
Completion of a
Will require approval from Dow Midland
subsidiary of the Dow
Human Resource Group before badge will
Yes
No
Chemical Company be processed. Verification to be sent to
Former Employee
site HR 5 working days prior to obtaining
Policy
badge.
TYPE:
Page 62 of 197
Bay Area Operations
Table of Contents
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 acceptance
criteria.
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 been
conducted 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/task
at _______________.
Yes
No
The person listed above is also scheduled to be working inside _________________ Operations Site within the
next five (5) days.
The person listed has completed Safety Council Safe Driver Training
Requested Vehicle Use
Personal Vehicle
The person listed is requesting a
Requested Gate Access
Company Vehicle
PERMANENT
(Walk In Only)
Yes
No
Non Driver
TEMPORARY (< 90 days) badge.
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 be
construed as fraud against The Dow Chemical Company, and shall be sufficient grounds for my removal from
Dow Operations' property and ALL my entry passes revoked.
Employee Receiving Badge Signature: ______________________________ Date: ____________
This person has completed It’s All About You Training at sites where this is required.
Contract Services Will Authorize Maintenance or Managed Service Companies for Badge
Contract Services Authorization: _____________________________ Date Signed: ____________
Project Job Rep Will Authorize Demolition or Capital Project Contractors for Badge
Project Job Rep Authorization: _______________________________ Date Signed: ____________
Page 63 of 197
Bay Area Operations
Table of Contents
Dow Bay Area Background Screening Policy
Purpose
To ensure all non-Dow individuals who request a badge to allow entry to Dow
Operations 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 the
U.S.
Background
Since September 11, 2001 several measures have been implemented throughout
industry in the United States in an effort to improve site and community security.
The Dow Chemical Company has undertaken extensive security vulnerability
assessments and audits at its sites around the world, and has implemented several
new 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 the
U.S. will be required to demonstrate that he or she has successfully passed a
background screening process. This screening process will be coordinated and
implemented by the contractor company through the local contractor safety council.
Exceptions
The only non-Dow individuals who are exempted from this policy are identified
government 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 the
person’s criminal history report that details any convictions (felonies and
misdemeanors) 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 necessarily
prevent assignment for work in a Dow facility, but offers a first review to
expedite those who do not require a more in-depth management review.
•
Exceptions may be made on a case-by case basis by the facility Responsible
Care leader.
•
Only under approved situations should any individual with questionable
reports in any of these areas be allowed to enter the Dow site.
Page 64 of 197
Bay Area Operations
Table of Contents
DOW Background Screening Policy, cont.
Non-Dow
Company
Documentation
Requirements
Other Documents
Each non-Dow company requesting an entry badge to the Dow site for one of its
employees should have its employee provide in person the following documentation
at 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 “Background
Verification Form”
•
verification of citizenship (Social Security Number) or an appropriate work
VISA 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’s
license, passport, or resident alien card for non-U.S. citizens.)
•
Safety Council Training completed
•
Hire Slip
•
Background Screen Verification
Page 65 of 197
Bay Area Operations
Table of Contents
Contractor Safety Training Waiver (One day Emergency Waiver)
Purpose
To provide site access to individual contractors who have not completed the required
Contractor Safety Training and as a result of an emergency situation are required to
work on site.
Scope
The contractor safety waiver is to be used only in the case of an emergency when
individual contractor employees are needed to control or abate an emergency
situation and those contractors have not been through Dow requirements for
Contractor Safety Training. This waiver is only to be used one time per contractor
employee 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 trained
the following conditions must be met:
•
An emergency situation must exist that requires the services of this/these
contractor(s). Examples of an emergency situation include unplanned shut
down of a plant or process, control of a spill or release, etc.
•
Training for these individuals is not currently available through the “Safety
Councils” (after hours, weekends, etc.).
•
The Production Leader for the Business in need of the contractor must
approve of the situation. The EH&S Delivery Leader for the Business in
need of the contractor must be informed of the situation.
•
A Dow escort must be identified and sign the waiver form (The Dow escort
must 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 before
work can begin. Management of the contractor firm must have knowledge of the
training 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 been
through Contractor Safety Training must :
•
Notify and get approval from their Production Leader. Notify and get
concurrence from their EH&S Delivery Leader.
•
Identify a full time “Dow” escort that will be responsible for the contractor’s
safety.
•
Assure that Dow SWP, red danger tag, confined space, and any other
applicable training has been completed, if required by job scope, and
documented.
•
Ensure site “It’s All About You” training is complete and documented.
•
A representative of the business must conduct plant/block specific training to
include HazCom issues and hazards specific to the block, and document that
training.
•
The responsible Dow escort and the Contractor employee must sign the
“Waiver of Contractor/Vendor Safety Indoctrination” form.
Page 66 of 197
Bay Area Operations
Table of Contents
Waiver of the Contractor/Vendor Safety Indoctrination
Bay Area Sites (CLO, DHH, HOU, TCO)
Provisions of the Contractor Safety Indoctrination Requirements as specified in the Bay Area Contractor
Administration Manual are hereby waived for a period of 24 hours or until the next scheduled
Contractor’s Safety Indoctrination. (Note: Must be a Bay Area approved contractor, e.g.
prequalification complete.)
The site Approved Responsible Person must:
7. Have a situation that constitutes a “true” emergency (Give details of the nature of the
emergency)
8. Escort the contractor/vendor employee at all times.
9. Take full responsibility for the safety of the contractor/vendor employee.
10. Inform the contractor/vendor employee of the potential hazards of the area
(HazCom/PSM Overview requirements are fulfilled).
11. 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 entry
of the contractor/vendor employee noted on this document.
3.
4.
Form Instructions:
All Items in the table below are required. Concurrence should be obtained prior to arrival at badging.
Production Leader Authorizing Signature
Approved Escort Signature (Initial)
Approved Escort Master number (Initial)
Page 67 of 197
Bay Area Operations
Table of Contents
Contractor Safety Training Requirements
for “Short term, Low-Risk” Entry (Less than 5 days)
Purpose
To provide site access to individual contractors whose work on site is low risk, does
not involve hands-on work on a chemical process, on a construction site, and it is not
practical to complete all the requirements of “contractor safety training”.
Scope
The 1 to 5 day amended safety requirement is for contractor employees who, by the
nature of their work, are low risk and are not working on or adjacent to process
equipment (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 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
Procedure
•
The contractor employee must have completed “Dow Site Specific” training.
•
The job must be “low risk” in nature (Red Tag, Confined Space, Safe Work
Permit, etc. is not required to complete the job).
•
The EH&S Delivery Leader for the Business in need of the contractor must
be informed of and approve of the situation.
The business that requires a contractor to come on site and do work that has not been
through 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 to
include HazCom issues and hazards specific to the unit, and document that
training.
•
The Contractor employee must sign the required form.
•
Before work is to be preformed a Dow representative of the business must fill
out a pre-task analysis card (STAC) with the contractor employee to identify
potential hazards and identify control and/or elimination measures for those
hazards.
•
A Dow representative of the business must check the training card of the
contractor to assure the contractor has completed Site Specific” training.
Page 68 of 197
Bay Area Operations
Table of Contents
Contractor Safety Training Requirements
for "Short Term, Low-Risk" Entry
Bay Area Sites (DHH, CLO, HOU, TCO)
Provisions of the Contractor Safety Indoctrination Requirements as specified in the Bay Area Contractor
Administration Manual are hereby amended to require only "Gulf Coast Site Specific" 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)
OR
2. Individuals NOT in the process area but doing hands-on work (i.e. Original Equipment
Manufacturing.)
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 entry
of the contractor/vendor employee noted on this document.
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.
Production Leader Approval Signature
Requestor Signature
Requestor Master number
Page 69 of 197
Bay Area Operations
Table of Contents
Bay Area Contractor Safety
Training Requirements
Start
Are they
working?
Utilize Visitor process
Are they
being paid?
NO
YES
NO
YES
Working onsite one day?
Working in
process area?
NO
Working 5
days or less?
NO
YES
(acceptable, but should
utilize the "Short
Term, Low Risk"
training requirements
form)
YES
Is person doing
hands-on
work?
NO
YES
Utilize "Short-Term, LowRisk" training requirements
form
NO
One Day Waiver Link
YES
"Short Term" form Link
Utilize one day Safety
Council Training waiver
Is work >1
day?
NO
Hold Harmless Link
(multiple one day waivers is not
acceptable. Intended for
Emergencies only)
YES
Person must attend all
applicable safety
council training (per job
scope)
Page 70 of 197
Recommend
individual
attend Safety
Council class,
but multiple
"Short-Term"
entry forms
acceptable
Bay Area Operations
Table of Contents
Visitor/Vendor Policy
Scope
This policy applies to all areas within the fence line of the site to which Non Dow
employees, visitor or vendors may be admitted.
Statement of Policy All Non DOW employees, contacts/escorts and visitors or vendors must comply with
the following policy for obtaining access to Bay 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 obtaining
access.
Exceptions
Security will notify ES&S personnel when military or law enforcement agencies on
official business enter the site.
Contractors follow the Site Access Contractor/Sub-contractor Badging Policy in the
Contractor Administration Manual; please contact Contract Administration
As used in this policy, “Dow” refers to The Dow Chemical Company, and its subsidiaries (including Union Carbide
Corporation, as applicable).
Page 71 of 197
Bay Area Operations
Table of Contents
Visitor/ Vendor Policy, cont.
Responsibilities
Person Responsible
Visitor Pass
Approver/Escort
(Dow employee
contact/escort or
Contractor
contact/escort):
Description
a) Ensure Security has received entry authorization for NonDow 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 restricted areas
f) Visitors should be escorted to and from their destination
and at all times while on Dow property by an approved
Representative.
g) Ensure that visitors do not engage in any activity other
than visual observation and/or meeting in a designated
area. Note: Any additional activity may require additional
access approval, training, and requirements.
h) Visitor Pass Approvers are accountable to ensure the
escort can fulfill all responsibilities. The responsibilities
include at a minimum:
•
Knowledge of emergency response requirements
•
Job scope knowledge
•
Knowledge of all applicable site rules
i)
Resident Contractor’s can be designated by the Visitor
Pass Approver to escort visitors.
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/cus
toms/na/foreign_nationals.htm
• Entry Forms and Flowchart –
http://gpurchasedb.intranet.dow.com/SiteAccess/fram
es.htm
Page 72 of 197
Bay Area Operations
Table of Contents
Responsibilities
(continued)
Person Responsible
Description
a) Ensure a completed Visitor log has been completed
(which identifies and authorizes all visitors) prior to
issuing badge.
Security:
b) Ensure every visitor or vendor has a valid Visitor
orientation card on his or her person before site entry.
c) Ensure each Vendor reviews, understands and signs a
Visitor Orientation card or has 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.
Consider denying the visitor continued access to Dow sites if
an individual demonstrates unacceptable behavior. Note:
confer with ES&S to remove access privileges.
Business/Function
Leaders:
Definitions
Term
Visitors
Definition
A Non-Dow individual at Bay Area sites other than company
personnel and Non-Company Service Providers
Characteristics of a visitor include:
•
The individual is escorted by a host (Company or a NonCompany Service Provider),
•
does not perform physical work, and
•
is treated as a “one time” guest.
Broad categories include family members, tour participants, sales
persons, agency inspectors, and consultants.
Note: It is important for the host to assess the visitor and to manage
the safety of the visitor and ensure that Dow EH&S performance and
property are not compromised.
Page 73 of 197
Bay Area Operations
Table of Contents
Definitions
(continued)
Term
Vendors
/Delivery
Definition
Person who come on site to perform a service such as delivery and
receives payment. Broad categories include vendor stocking, vending
machine replenishment, mail service, equipment delivery/service,
fuel or raw material delivery, product pick up and removal 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 road ways, storage, construction and office areas
characterize this service. They are not allowed in process areas
without an escort and location/department safety and health
information.
Contractors
External companies and their employees doing labor contract work at
Dow sites, as well as individuals or other companies (subcontractors) that are hired by that business entity to do the work.
Definition of
Work:
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 is received.
Where to Report
These persons shall report to the Security Stations. Plant Security will man these areas
during normal working hours and will direct the visitor. They will be required to log
in on the visitor register/log.
Contacting Person
to be Visited
Security will provide visitors with the phone number of the person or area being
visited Phones are provided for the visitor to contact the party being visited.
Meeting with Non- Visitors should not be taken into the site unless absolutely necessary. A room is
available in the reception area for plant personnel to meet with visitors.
DOW Visitors
The visitor must be signed in with security (via Non-Dow Visitor log) when necessary
to issue a visitor badge. Visitor Orientation card is valid for one year from signature
date.
When taken inside the site the contact/escort must accompany the visitor and inform
visitor of any potential safety or health hazards.
No one under the age of 18 will be allowed on site without being pre-authorized by
Public Affairs and with prior ESS notification. (Minimum age for site entry is 12
years.) All other non-business visitors must be referred to the area site leader for
authorization.
Sign Out
The visitor or vendor must return badge to Security when leaving the site.
Page 74 of 197
Bay Area Operations
Table of Contents
Safety
Requirements
Procedure
If the visitor is taken into the site, then:
•
The contact/escort will ensure the site indoctrination for the visitor is
completed, that verification of indoctrination is documented via signature on
Visitor Orientation card, and card is given to visitor to keep on person while
on site. Site Indoctrination is valid for one year from date documented on
card. The card is signed by the visitor to document they have received and
understood indoctrination.
•
It is the responsibility of the visitor or vendor to supply documentation of
indoctrination, e.g. Dow visitor orientation card. If a valid card is not
available upon entry into the site, re-indoctrination and reissue of card will be
required.
•
The contact/escort must supply the visitor with the appropriate personal
protective equipment for the area being visited and ensure they are instructed
in its proper use.
Vendors:
•
Properly completed entry log.
•
Vendor must have valid Visitor Orientation card and Vendor badge on their
person while on site.
•
Security will review the general instruction part of the Visitor Orientation
Card with the vendor and the vendor must understand and sign the card.
•
Vendor may not enter process areas unless signed into the plant and escorted
by plant personnel.
•
Before leaving site, vendor must turn in badge to security.
Page 75 of 197
Bay Area Operations
Table of Contents
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” presentation
prior to being allowed to perform work at Dow. The presentation will be delivered in
person by selected Dow.
Overview
The “It’s All About You” process establishes basic expectations for all personnel
working at Dow. Once the orientation is complete contractors will be required to
sign a document indicating they have completed and understood the material.
No work will be allowed by any contract employee until this requirement is met
within 3 working days.
Training Schedule
Reservations are mandatory and training sessions will be conducted based on the
reservations received. Daily sessions are not conducted unless we have scheduled
attendees. It will be necessary for the person making the reservation to know the job
start date so we can optimize when we conduct the orientations.
•
For TCO: Call Anna Johnson at 409-948-5506 or email
[email protected] to make reservations: Monday – Thursday—8:00a.m
•
For CLO: Training sessions are held daily in the Mtce Bldg at 7:30AM Mon
– Thu
•
For La Porte: (info to be entered)
Special sessions will be scheduled for large parties of 15 or more.
Late arrivals will not be accepted
Document
Retention
Completed document indicating completion and acknowledgment of the expectations
will be the responsibility of the Contract Company to maintain on file.
All About You Training is not transferable from one site.
Page 76 of 197
Bay Area Operations
Table of Contents
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 have
attended.
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 this
requirement for emergency work will be at the discretion of the Production Leader or
Maintenance Process Leader.
Can contractor management complete a train the trainer sessions and train their
own employees?
No
Does an owner, company superintendent, vendors or delivery company that is
not performing work required to have this training?
The orientation is required for all contractors who report work hours and injury
recordability 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 large
capital project starts?
Special sessions will be conducted to accommodate large increases of personnel.
Page 77 of 197
Bay Area Operations
Table of Contents
Pre-Job Orientation
Purpose:
The purpose of this process is to ensure contractors working at Dow are appropriately
indoctrinated in order to create an “Incident / Injury Free” workplace at Dow through
communications 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 within
their work environment and from their actions. They need to understand and
recognize hazards/risks, they need to know how to mitigate or eliminate the
hazards/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 the
most knowledge of project, site, and conditions relating to the project. It is the
Owner’s responsibility to communicate any known hazards or potential hazards to
people that work on Dow projects. At Dow this is accomplished through a
communications meeting conducted just prior to the contractor starting any work in
the 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-Job meeting.
2
The Job Representative, before the meeting, should review the contract
documents and site procedures to become fully familiar with:
a) The contract
b) The work (review scope with technical expertise such as
Maintenance Technical Services to ensure the appropriate sections
of the Pre-Job checklist are 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
Page 78 of 197
Bay Area Operations
Table of Contents
Pre-Job Orientation, cont.
Responsibilities:
(continued)
Item
Description
3
The Job Representative should fill in as much as is possible of the Pre-Job
Meeting checklist 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
this meeting with every person working directly for them on the site.
{Normally does 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 the Pre-Job Safety Conference Checklist and will seek
understanding and input from the attendees 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 following work day.
8
The contractor company will take their copy of the Pre-job and make
whatever copies they need and then will review with each person going to
work on the site prior to their start of work.
Page 79 of 197
Bay Area Operations
Table of Contents
Pre-Job Orientation, cont.
New Contract
Company
Orientation
Pre-Job Orientation Meeting
Prior to a new contract company’s forces or facilities entering the site, a pre-job
orientation 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 site
if the site supervisor changes (regardless of the number of times the
contractor or sub-contractor may have previously been on site).
The Pre-Job Safety meeting meets the requirements of the orientation for
new 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 between
the Dow Job Representative and the Contractor’s Representatives at a
minimum. Contractor EH&S or an EH&S Representative from the plant must
be invited. The customer(s) requesting the work, and if needed a purchasing
representative may need to be invited depending on the Job Scope
(Turnaround, Shutdown, Project, etc.). Any party involved in the work can
request a Pre-Job Conference if they feel it would benefit the execution of the
work to follow.
The pre-job meeting is to review specific details relative to contractor safety for
jobs by existing contractors:
•
For major jobs (projects, turnarounds, shutdowns, etc.) – completed
within a week or two of beginning work to review EH&S issues
pertinent to the job scope regardless of the number of times the
contractor may have previously worked at any Dow site.
•
For emergency work – completed at the time of site access to orient a
new company to site requirements (Work Activity Coordinator –WACwould be the Job Rep for emergency work) by completing the
highlighted sections of the checklist and items related to the emergency
task. A meeting will be scheduled to complete the Pre-Job checklist by
the site Job Rep if the company is approved for future use.
•
For Infrequent, Non-Resident Contract Company access (site access of
two or less times in a 12 month period) – The contract company reviews
this checklist with employees prior to site access and gives signed PreJob 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 by
scope, 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 Process
Flowchart
Include TCO Contractor Admin
Manual with the bid package and
Job Rep ensure Pre-job Safety
Conference requirements are
understood by contract company.
Successful Bidder fills
out the Pre-Job form
with answers to all
questions that can be
answered.
Contractor gathers
supporting
documentation needed
to substantiate
responses (JSA's,
etc.)
Understanding
adequate?
Contractor reviews the completed
checklist with the job/owner rep
prior to the pre-job safety meeting.
YES
Contractor brings completed
forms to the pre-job Safety
Meeting.
NO
Make
necessary
changes.
Updates are made
to the checklist with
any action items
documented
At Pre-job conference, final resolution is
obtained for all applicable items in
checklist. (All safety requirements and
issues are addressed, issues
resolved/action plan in place.)
Contractor reviews the
checklist with all employees
on the project.
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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. The
checklist 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 any
items marked "No". Use Attachment 1.
Use Attachment 2 to list comments associated with any particular line item.
“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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General 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 as
approved on the site Gate Access Database:
COMPANY NAME
CONTACT NAME
PHONE #
Contract Firm’s Local Business Address:
*Site Supervisor / Superintendent:
Name: _____________________________
Phone: (_____)________________
Email: _______________________
Telephone No. ______________________
E-mail: ____________________________
General Foreman’s Name: ________________
_______________________________________
Phone: ( _____)________________
(Name entered ensures Pre-Job conference compliance.)
Contractor Safety Representative:
Name:________________________
Phone: ( _____)________________
Full Time □ Part Time □ As Needed □
Contract/Project Start Date:
DOW Project Manager (name):
Expected Duration (project/turnaround):
Block/unit Man Rep (name and phone):
Company Management Representative
Name:________________________________
Engineering Solutions Construction Manager:
Name: ___________________________________
Phone: ___________________________________
Block/Unit EH&S Contact (name and phone):
DOW Contract Administrator/Job Representative:
Name : __________________________________
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 superintendent
must be performed in order to adequately orient the new superintendent to site requirements.
Page 83 of 197
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Attendees Information
Name
Title
Company
Page 84 of 197
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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
2
Review project organization Project Leader, Maintenance and Construction
personnel, contract administrator, etc.
Review safety expectations for each level involved in project as well as overall
project
Yes No
Yes No
Contractor (including leadership participation in job audits)
Project Leader, Plant Personnel, etc.
Project Safety Goals and Project / Turnaround Incentives (if applicable)
3
4
5
6
7
Review process for approval of scope changes once project is in progress.
How will safety be ensured as job scope changes or jobs added?
Restricted areas within plant identified for the workers involved, properly
barricaded? Process areas and Hot Work areas located, plot plans reviewed?
Have the contractor review their progressive discipline policy for safety violations
and recognition/incentive program.
Review existing Dow site safety performance and expectations for positive
contribution.
Contactor OSHA 300 log maintained?
Who: ___________________ Where: ________________
Yes No
Yes No NA
Yes No
Yes No
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)
Yes No
5
If temporary hand wash or other sanitary stations required, they are drained to a
sanitary sewer (not NPDES or storm water outfall)
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, contractor
understands responsibility for:
Yes No NA
Seatbelts, Speed Limits, Pedestrian Travel, Bicycles, Licensing requirements (ex. Bus drivers)
6
Yes No NA
• 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 platforms
Requestors should work with PL's/MPL's, etc. to determine necessity of trailers
versus use of existing buildings and facilities. ("Trailers/temporary buildings" include tool
trailers, C-cans, etc, not just "habitable" trailers. Trailers/temporary buildings are last resort.)
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D. Teams, cont.
9
Facility needs determined and plans in place to provide:
•
•
•
•
•
•
Yes No
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 enhanced
risks (potential startups, shutdowns, introducing chemicals to plant after maintenance); these enhanced
risks 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.
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
Expectation to participate in site teams to include:
Yes No NA
D. Teams
1
2
•
•
•
•
Firm owners improvement
Safety specialist communication
Work group specific
Functional leveraged
Special emphasis
•
List of specific teams (ex. Contractor Safety Alliance Teams):
1. _______________________
3. __________________________
2. _____________________
Yes No NA
E. Measurements
1
Expected pro-active measures reviewed to include:
•
•
•
•
•
•
2
3
Yes No
Compliance to corrective actions
Observed behavior/interventions (Near Miss program, etc.)
Hazard recognition scores (STAC by foremen)
QSPPs
Schedule
Other: ______________________ (specified)
Expected injury performance – “zero” - reviewed
Yes No
Criteria for continued selection
Yes No
•
•
•
Observed behavior
Injury/Illness, EMR
Participation
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F. Work Process
1
2
Incident Investigation (reference Bay Area Contractor Admin Manual)
Expected incident notification (Contractor Incident Form and initial notification; review flowchart in Bay
Area Contractor Admin Manual – Investigation Policy)
Who is delegated to report incidents: Name/Role: _______________________________
Expected type of incidents to be investigated to include:
•
•
•
Yes No
Yes No
Observed unacceptable behavior
1st aid/minor injuries
Potential serious event (examples listed in the Investigation Policy)
OSHA recordable cases
3
•
Review method of investigation (cause & effect, ABC) and required documentation
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 post
accident/incident substance abuse test (contractor responsible for ensuring confidentiality issues).
Steps leading to the test must include supervision escort to the testing location to
assure “chain of custody” prior to testing. (Failure to comply will be grounds for
Yes No
Yes No
(final incident report for non-trigger or initial report then final incident report and Cause & Effect diagram for RCI
trigger incidents)
removal from the site.)
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 individuals
Contractor 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 Bay Area Contractor Admin Manual – Investigation policy)
Method to make a suggestion (Contractor Incident/Safety Suggestion/Unsafe
Yes No
15
Condition form and process)
Yes No
Resolution process
16
17
Feedback method
Yes No
18
Behavior Observation/Intervention
Are behavior observations scheduled during the project?
Yes No NA
•
•
Review process for providing feedback to persons involved.
Contractor plan to track and communicate to DOW.
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F. 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
22
23
“At Risk” employees (reference Bay Area Contractor Admin Manual – “Buddy” policy)
If a large number of employees are new to craft or the site, does contractor have
Yes No NA
plans in place to pair new employees with experienced ones?
Yes No
“Buddy Policy” understood and implemented?
24
Method to identify those less than 6 months with company (orange tape)
Yes No
G. Training/indoctrinations
1
2
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: _______________
Review site access process:
Hire slip (Background screening, foreign national approval, former Dow employee approval, English
Yes
Yes
Yes
Yes
No NA
No NA
No NA
No
comprehension, from another Dow location)
3
Are plans in place to bring these employees in early for the site and plant
indoctrination training
4
Review indoctrination schedule Date(s) scheduled: __________________________
Review contract company method to ensure 1st line supervisors (crew leaders, foremen,
etc.) are prepared/qualified to manage safety for day to day work (ex. training)?
5
Review substance abuse testing status for each person to ensure pre-access testing,
for cause testing, post incident and annual random testing. (ref. Bay Area Contractor
Yes No NA
Yes No NA
Yes No
Admin Manual)
6
Method to validate Safety Council training/certification by individual to include:
•
•
•
7
8
Review skill assessment/qualification for each person, where practical e.g. individual
status for known employees to be brought on site
•
•
Certifications (Contingent Staff engineer – PE, Radiographer, etc.)
Craft Skill Assessment
Qualification/Training
•
•
•
Job and Equipment Specific training for Contractors (ref. Bay Area 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
•
Additional training/knowledge to be verified as applicable to the work being performed:
•
•
•
•
•
•
Yes No
Basic Plus/Refresher
Dow Gulf Coast Site Specific
Task specific requirements (Fire Watch, Scaffold User, Safe Driver, Red Tag, Dow Confined
Space, and though not required -SWP acceptor at contract company’s discretion)
Yes No
Yes No NA
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G. Training/indoctrinations, cont
9
The following orientation information shall be reviewed with contractor crews prior
to start of work to include:
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
Yes No
Pre-Job Safety Conference Checklist & Bay Area Contractor Administrative Manual policies
Site/Maintenance/Responsible Care Standards, Procedures (ref. CD of Site Rules, safety council,
TOCAS link, etc.)
Site Safety Rule Book (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)
Threats of Violence Policy (Site Safety Rule Book)
Chemicals on Site – MSDS
Waste identification, collection, and disposal – Cardboard & Scrap*
Non-Smoking Policy*
Knife Policy*
Trailers – safety chains (Site Safety Rule Book)
Security Awareness (acquired at Safety Council)
Other (site specific)
(*Included in Bay Area Contractor Admin Manual)
The site supervisor will be held responsible for ensuring that his/her crew is familiar with the above
mentioned policies, procedures, and guidelines associated with the work that is being performed.
10
The following unit specific information shall also be provided prior to the start of
work:
•
•
•
•
Yes No NA
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 Communication
Note: Compliance is achieved by a safe work permit
11
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 work
being performed?
Safety Personnel qualifications/training: OSHA Construction
Yes No
If no when will this training occur? Date: _______________
Review Safety Personnel responsibilities (ref. Bay Area Contractor Admin Manual)
Ratio of safety personnel to crew: # of Safety Personnel ____ # of Employees ____
How will personnel temporarily given safety reporting/supervision/injury case management
responsibilities be qualified/approved in order to fulfill role responsibilities prior to assuming the role?
Specify: ____________________________________________________________________________
H. Communication
1
Contractor has identified all subs to be used and plans in place to ensure
communication of safety 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
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H. Communication
Has a kickoff safety meeting been scheduled?
When ___________ Location ___________
4
Yes No NA
Review agenda, presenters, required attendance, etc.
5
Have frequencies and attendance been established for group/site safety meetings (to
include ALL 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 changes
throughout the day.
Reviewed cell phone, pager, radio, camera (none allowed including cell phone), etc.
use policy
Yes No NA
8
Review process to verify workers comprehension of tailgate / safety meeting content.
9
Yes No NA
Yes No NA
I. Procedures
Emergency Response/Accountability
1
Review emergency phone number(s)
Yes No
2
Are existing emergency procedures adequate for project conditions and additional
personnel load? Consider possibly:
Yes No
•
3
4
Additional assembly points needed, etc.
• Spills, Fires, Freeze, etc.
Are available safety showers and eye wash facilities sufficient? Location? Alarmed?
Alternate system in place is not available?
Review Firewater use: not allowed for welding/cutting/etc. Firewater is for the
emergency personnel only. If there is a need for their service, please do appropriate
planning prior to the job with an Emergency Director/ES&S personnel.
Yes No
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?
Yes No
Alert: ___________________________________ All Clear: ________________________________
Evacuation: ____________________________ Siren/Alarm test (day and time): __________________
Injury/Illness
8
Review Injury/Illness Reporting requirements
Yes No
9
Review mandatory ambulance call requirements? (Foreign material in the eye, chest pain,
Yes No
10
Procedure for requesting ambulance?
Determination of medical facility for treating occupational injury/illness
Exposure to toxic or corrosive material, Any loss of consciousness, person in obvious/serious distress.)
Yes No
11
Location:__________________________________________________________
Fit for Duty responsibility (return to work review after occupational injury/illness, how many
hours/days employees can work without time off, etc.)
Name/Role:____________________________________________
12
Review use of DOW Medical facility (if on-site).
Yes No NA
13
Review contractor process for treating minor injuries
Yes No NA
Yes No
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I. Procedures, cont.
14
Injury/Illness (cont.)
If first aid to be administered on-site by contract personnel
15
•
Who is responsible for case management in the event of an injury?
16
Work hour collection
17
Project Inspection/Housekeeping
Initial site inspection completed? Plan to ensure site safe conditions in place before any work gets
•
Yes No NA
Persons trained in first aid and applicable regulations
Review disposal of medical waste
Yes No
Name/Role: ____________________________________ Phone #: ______________________
Yes No NA
started and 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?
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?
Yes No NA
23
Minimum housekeeping requirements established and communicated?
Plan will be submitted by:__________________________________
•
•
•
•
•
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
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?
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?
Yes No NA
28
MOC
“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
31
Medical Surveillance
Are there chemicals involved that will require individuals to be in a medical
surveillance program?
Yes No NA
Note: Poor housekeeping will result in work being shutdown at contractor’s expense.
List:____________________________________________________________________
32
Who will coordinate the physicals and monitoring
Yes No NA
33
Where will documentation be kept?
Yes No NA
Location: __________________________________________________
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J. Standards/Rules
All 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.
1
2
3
General
Prime contractor provided with copy of the Bay Area Contractor Administrative
Safety Manual?
Contract Company Safety Standards available for workers in field
Yes No
Yes No
Location of Field Copy: ________________________
Have variances been approved for all jobs which will not strictly adhere to applicable
safety standards? Specify Safety Standard Variance and specific task:
Yes No NA
1) __________________________________________________________________
2) __________________________________________________________________
Other: ___________________________________________________________________
4
Has contractor completed JSA (jobsite Safety Analysis) and has it been submitted to
DOW representative(s) for review?
Yes No
5
Jewelry policy reviewed? Rings? Watches?
Yes No NA
6
Personal Protective Equipment (PPE)
Review Dow minimum PPE, related requirements, exceptions?
Yes No
•
•
•
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.)
7
•
Additional PPE identified for jobs not already covered?
8
Reviewed DOW PPE Grid(s) (Maintenance, facility, etc.) which specifies minimum
PPE for tasks/tool use and protection from chemical exposure?
Appropriate types and amounts of PPE readily available? Who will provide?
9
Procedures in place for proper use and disposal of above?
Yes No
Any exceptions to Dow designated PPE areas within plant during project?
Yes No NA
10
Yes No NA
Respirators, flame resistant clothing, flash suit, faceshield, metatarsal guards, slicker suit, rubber boots
and gloves, etc.
Yes No NA
Yes No NA
Hearing protection competent person: ___________________________________
(Goggle areas, hearing protection)
Exception(s): _____________________________________________________________
11
How will this be communicated and/or marked? ____________________________
Additional areas should be designated during the project.
•
•
•
Yes No NA
Portable noise sources (crane, generator, etc.): _________________________________,
Asbestos removal areas: ___________________________________________________,
Other: __________________________________________________________________
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
14
Safe Work Permit
Daily job lists to be made available? Due by: ____ p.m
Yes No NA
15
Permit issuers identified (project / turnaround):
Given to: Name/Role: ____________________________________________
Yes No NA
Names / Roles: 1) ________________________________________________________________________
2) ________________________________________________________________________
Are additional ones needed?
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J. Standards/Rules, cont.
16
17
Safe Work Permit, cont.
Will any jobs not require permits or on-site inspections? Identify:
Yes No NA
1) ____________________________________ 2) __________________________________
Other: ______________________________________________________________________
Additional permit needs identified (Hydroblasting, Confined Space Entry, etc.)?
Yes No NA
List any permit needs here that are not identified in specific sections:
1)_____________________________ 2) ________________________________
3) ____________________________ 4) ________________________________
Others: ______________________________________________________________________
18
Schedule established to minimize problems during permitting?
19
Plans/discipline in place to ensure work stays within defined scope?
20
Permit receivers understand cancellation/expiration, or reauthorization process?
Closeout?
Yes No NA
Staggered times, extra permit writers brought in, etc.
Yes No NA
Includes only that area or tasks covered during on-site inspection
Yes No NA
Permit Receivers identified: Names / Roles: 1) ________________________________________
2) _________________________________________
21
22
Process in place to assure that all personnel on permit have received appropriate
indoctrinations?
Lockout or Tagout – Isolation of Energy
Persons available for Red Tag isolation verification (Job Representative - job aide available)?
Yes No NA
Yes No NA
Names / Roles: 1) ______________________________________________________________
2) ______________________________________________________________
23
Which system to achieve 100% control and accountability of all personnel and
isolating devices will be used:
24
Will individual tags or Exclusive Control be used?
Master Red Tag System? □
Yes No NA
Individual Red Tag System? □
Yes No NA
If so, review requirements
•
Are Energy Control Operating Procedure’s written and approved?
• Are workers authorized procedure users (AOPU) for specific facility with documentation on
facility authorization list, trained on their specific Red Tag requirements, trained on facility
Procedure Use Policy requirements, and trained on specific procedure?
Yes No NA
25
Tag location listings developed for individual Red Tag?
26
Return to Operations / Re-commissioning plans completed and approved by facility?
Yes No NA
27
Line & Equipment Opening
Means of positive identification for openings established (tag, paint, photo, diagram, etc.)?
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?
Approvals obtained?
Yes No NA
(job aide available for Persons Working under Isolation)
Specify: _____________________________________________________________________
Equipment: 1) ___________________________ 2) _____________________________
Other: __________________________________________________________________
32
Is approval needed for openings (flammable/combustible)? Hazard analysis
completed? Grounding requirements understood and equipment available?
Yes No NA
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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?
Yes No NA
37
Security/Rescue Team notified
38
Approval if double block and bleed used for isolation
Yes No NA
•
Rescue Plans complete
• Equipment available (respirators, harnesses, etc.)
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?
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:
Yes No NA
46
•
Plans in place to reduce hazards if welding inside confined space?
47
Is grinding etc. to be done on fiberglass reinforced plastic vessels?
48
Contractor procedures needed? Completed?
Respirators, O2/Combustible analyzers, air movers, etc.
•
entries not cleaned below OEL
could introduce contaminants into space (welding, painting, etc.)
Yes No NA
Dust fires, accumulation of fumes, etc.
Yes No NA
IH approval with monitoring required unless supplied air full face or SCBA used
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.
Yes No NA
52
Excavation
Applicable Excavation Permit requirements reviewed?
Review any special requirements identified by the following groups:
Yes No NA
•
•
•
•
•
•
Environmental Coordinator (handling of excavated materials)
Industrial Hygiene (PPE)
Engineering (underground drawings)
Electrical
Maintenance Technical Services (if near cathodic protection)
Utility Distribution
Page 94 of 197
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53
Excavation (cont.)
Competent persons available for inspections
54
Review procedures if
Yes No NA
Supplied by: ______________________
Name/Role: _________________________________________________
•
•
•
•
Yes No NA
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
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 excavation
Written excavation safety plan for each excavation (contractor) Sloping? Shoring?
Shielding?
Yes No NA
•
•
•
•
•
58
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)
•
Is excavation considered a confined space?
Yes No NA
could hold or contain hazardous atmosphere
If so, see Confined Space section.
Tools
59
Yes No NA
Tool inspections scheduled?
Who will perform the inspections?: ____________________________________
Specify Periodic Inspection Frequency: _________
Employee Pre-Use Inspection Required?
Contract Company □
Employee □
Yes No NA
60
Tools supplied by:
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.)?
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 use must be available at the job site.
Yes No NA
Trained persons available Supplied by:___________________________
If yes, list: ________________________________________________________
66
All pipe stands have anti slip devices & capacity labels?
Yes No NA
67
Holders used or tools secured for hammer struck tools?
Yes No NA
68
(do not allow one person to hold while other strikes tool)
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
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70
Heavy Equipment
Required equipment identified and available? Supplied by: _______________________
Yes No NA
Type: _____________________________________________________________________
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?
Plans in place for refueling needs? (discourage bulk storage)
If used, grounded storage tanks, labeling, fire protection?
Secondary Containment?
Elevated work
Elevated Work hazards identified. (review Dow Elevated Work definition)
Fall Prevention/Protection Plans for Critical Elevated Work developed? Approved?
Yes No NA
74
75
•
•
•
•
76
•
Identified hazards included in JSA?
Will work involve Steel Erection? Competent person: _______________________
Plans in place for elimination/reduction of hazards?
•
•
•
77
78
79
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.)
•
Yes No NA
Yes No NA
Yes No NA
Yes No NA
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)
Work surface can support the load required?
Roof Access required? SWP requirements for roof access – site specific.
Ladder use reviewed?
Ladders allowed (step, wood, extension, fiberglass, metal, scaffold, tank builders,
“A” frame) reviewed? Tank builder ladder inspection program reviewed?
Minimum fall protection equipment requirements reviewed?
•
•
•
•
•
Yes No NA
Yes No NA
Yes No NA
Yes No NA
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
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 as
Yes No NA
No walking in cable trays, Lined/Insulated pipes, etc.
Is cable tray access needed? Review permit requirements (Cable Tray Access Checklist).
Page 96 of 197
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J. Standards/Rules, cont
Elevated work, cont.
Will positioning systems be used?
Equipment designed for positioning?
Will fall protection be used in combination?
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.?
Will aerial lifts be used? Tie off requirements reviewed? Inspection requirements
(including checklists) reviewed? Rigging limitations/requirements reviewed?
Site minimum anchorage requirements reviewed?
Is a fall prevention plan required (fall protection not feasible, ref. DOW Global Elevated Work)?
Yes No NA
84
85
88
89
Yes No NA
Yes No NA
Yes No NA
Date submitted for approval:________________________
Competent person:_______________________________
Site Leader approval obtained? Business Manufacturing Leader or equivalent approval obtained?
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?
Yes No NA
93
Appropriately trained persons available/scheduled?
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?
Yes No NA
97
Minimum requirements for arc welding/cutting reviewed & understood?
98
Special PPE needs for hot work identified and available?
Type: _________________________________
Supplied by: ____________________________
•
•
•
•
•
•
•
•
•
•
•
99
Yes No NA
Competent person (determine flammability of coatings): _______________________________
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
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
(Review PPE Grid for minimum requirements)
•
Spark containment plans in place? (Tig welding - Need to use welding screens where people/traffic may be
Yes No NA
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 NA
Yes No NA
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100
Hot Work, Welding & Cutting (cont.)
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?)
Yes No NA
103
Hot tapping required? Permit requirements reviewed?
Hot Tap Request (Engineering Evaluation) approved?
Hot Tap Inspection list reviewed?
Hot Work on equipment not isolated and cleared
Written hazard analysis / procedure available and addresses:
104
105
Supplied by: _________ Fire Watch names:_____________________________________
•
•
•
design stress calculations
flow rates and temperature
equipment testing & nozzle reinforcement
• pressure testing before/after reinforcement
Appropriate approvals obtained:
1) Hot Tap Request/Final Approvals (DOW Hot Tapping standard) if applicable
2) Production Leader + Site Responsible Care Leader as appropriate
Yes No NA
Yes No NA
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
Emergency procedures in place
Yes No NA
109
•
•
isolation devices Identified (consider need for knowledgeable DOW person at isolating devices)
means of communication established
fire protection equipment available
•
110
Scaffolds
Fall Prevention/Protection Plan completed and approved for Critical Scaffold
erection and dismantling (Dow Critical Elevated Work):
•
•
•
•
•
111
112
113
Yes No NA
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)
•
Safety or Emergency equipment not blocked by scaffolding?
Yes No NA
fire extinguishers, safety showers, critical valves, etc.
Minimum Requirements reviewed and understood:
•
•
•
•
•
•
•
Yes No NA
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?
•
Scaffold crews trained by competent person?
Yes No NA
Competent Person:_______________________
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114
Scaffolds (cont.)
Competent person available to inspect finished scaffold prior to use and each shift of
use?
Yes No NA
Competent Person: _____________________________________________________________
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?
Yes No NA
Covers either secured or labeled, attended until corrections made?
Incomplete Scaffold/Pencil Board Checklist with plan approved?
118
All scaffolds >75 ft / >125 ft submitted to Engineering for review?
Yes No NA
119
Suspended scaffolds required?
Yes No NA
120
•
Are scaffold erectors/dismantlers able to maintain safe access and fall protection
requirements per DOW requirements?
If not, has a fall prevention plan been approved? (Site Leader and Business Manufacturing
•
suspensions mechanism rating 6 X load?
fall protection separate from suspension mechanism?
Yes No NA
Leader/Equivalent approved?)
121
Critical Lift
DOW Mobile Hoisting Standard reviewed:
•
•
•
•
•
•
Yes No NA
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, traveling
with >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?
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
127
All riggers properly trained and qualified? May also require NCCER certification for
critical lifts (see site policy).
Knowledgeable persons to review lift permit identified?
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
Size / type of rigs: ___________________________________________________________
Supplied by: _______________________________________________
Crane competent person(s): ____________________________________________________
Name: ____________________________
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131
132
Personnel Lifts
Equipment needed identified, available, with current inspection?
Yes No NA
Type:
Supplied by:
All materials to be lifted along with personnel fit within horizontal confines of basket
and no more than 100 lbs (45 kg) extends above handrail.
Yes No NA
total capacity not to be exceeded
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 qualified
Yes No NA
136
Special precautions for personnel crane baskets reviewed & understood (Fall
Prevention Plan, Crane Basket Checklist (site specified), and SWP required):
Supplied by:
•
•
•
•
•
•
•
•
•
•
137
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?
Approval required for use of Bosun Chairs; requirements reviewed and understood
(permit & fall protection plan required):
•
Yes No NA
Yes No NA
approved & inspected prior to use by paint contractor, structural integrity of anchor checked
Electrical
138
139
GFCI’s available at breaker or receptacle(s) in work area?
Yes No NA
If not, sufficient portable GFCI’s available?
Yes No NA
•
•
•
where portable equipment, tools, & extension cords used outdoors, in shops, and in wet locations
placed at the source
testing procedure understood
140
Will GFCI’s be used in hazardous areas?
Yes No NA
141
Yes No NA
142
If yes, continuous explosion proof equipment available?
if not, fire watch required?
Which option used for electrical protection on construction site?
143
Will temporary power be needed? For contractor or plant owned equipment?
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?
Yes No NA
Yes No NA
GFCI’s or
Assured grounding (if allowed)
Competent Person for Assured Grounding program: _________________________________
Yes No NA
Approval for plant owned equipment by:_________________________________________
Contractor Owned provided by:_________________________________________________
Voltage needed: _________________ Amperage needed: ________________
Portable generators tested and tagged (plant owned or contractor owned)?
Where?:__________________________________________________________
If yes, has electrical distribution reviewed & approved work
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146
Electrical (cont.)
Does job involve work on electrical equipment?
If yes, are workers properly qualified for the work?
•
Yes No NA
Electrical Instructed Person (Perform Class B, C and D energized electrical work):
•
•
•
147
148
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
If yes, review requirements for penetration of clearance zones?
•
•
•
Yes No NA
voltage testing prior to work
verifying test equipment prior to and after use
possible PPE requirements
procedure if testing requires penetration of clearance zone
•
Does project involve work on energized electrical circuits? (ref. DOW EWP 30 –
Yes No NA
Energized Work 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 or
Procedure be performed?
Class C electrical work □
Yes No NA
Yes No NA
Class D □
Expected voltage:____________ Expected amperage:_____________
149
150
If yes, are properly approved electrical work procedures available?
Electrical representative available for electrical permit?
Yes No NA
Yes No NA
Supplied by:
Work On/Near Radiation Devices
Safe Work Permit is required. Site requirements reviewed, is work covered under
site permit?
Yes No NA
Site Radiography permit required? Yes □ No □
Radiographers using their own checklist? Yes □ No □
151
Radiation Safety Officer contacted if devices to be received/installed/changed?
Yes No NA
152
Licensed Radiographers available? Yes □
Yes No NA
No
□
Competent person: _____________________________________
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
156
Material Handling & Storage
Plans in place for handling of chemicals brought onto site for project?
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
available to Dow? All materials brought on site are reviewed?
Yes No NA
Includes grounding of tanks, etc.
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160
161
Material Handling & Storage (cont.)
MSDS's available on site including chemicals brought in for project?
Yes No NA
Location:_____________________________________________
Material Storage / Staging areas identified? Marshalling Plan complete?
•
•
Yes No NA
Drop off point for DOW supplied materials also
Safety requirements reviewed
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
All rigging components have capacity marked or tagged?
Yes No NA
166
167
168
Rigging / Slings competent person(s): __________________________________________
Determine process for use of small lifting equipment such as hoists, small cranes and
appropriate rigging. Is equipment and rigging competent person supervising the job?
Hydroblasting and High Pressure Washing
Trigger points for Hydroblasting and High Pressure Washing reviewed?
Yes No NA
Yes No NA
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
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?
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?
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?
Yes No NA
182
Equipment inspected?
Supplied by: __________________________
Grade D Breathing Air is required if blasting in Confined Space.
Yes No NA
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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 and fit 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?
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?
Is equipment in hazardous (flammable/toxic) service? If so, refer to the Hot Work
section – not cleared.
Demolition
Demolition Inspection competent person: _________________________________
Decontamination plans in place for equipment being demolished?
Yes No NA
192
193
Asbestos competent person: _______________________________________
Yes No NA
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
Asbestos identified? Asbestos competent person: ___________________________
Yes No NA
196
•
•
•
trained persons available?
adequate PPE?
containment plans in place?
Facility notified and permits obtained (10 day notice)
197
•
Lead containing materials identified and trained persons available?
198
Additional PPE identified and available?
199
Plans in place for removal of demolished materials / equipment?
200
Decontamination plans in place for equipment being demolished?
Yes No NA
201
Compliance with electrical demolition procedures?
Yes No NA
202
Precautions to reduce hazards from dust accumulation?
Yes No NA
203
Does demolition involve removal of a load supporting member?
Yes No NA
204
Will concrete grinding machines be used?
Yes No NA
Lead competent person: ______________________________________
Yes No NA
special boots, cutting goggles, face shields, etc.
Yes No NA
load luggers / dumpsters, etc.
(Isolation and disconnection, grounding, asbestos present, PCB’s present etc.)
Facility notified and permits obtained (10 days notice)
Has air permit been obtained?
Yes No NA
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206
Pile Driving
Reviewed process to be used on this project:
•
•
•
•
•
•
•
•
Reviewed process for notification of municipal authorities, pipeline owners, power
distribution owners, and others affected by the work.
•
•
•
Yes No NA
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
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 pipeline
notifications on him and that he understands the use of it.
Reviewed safety concerns and PPE for each person to be working within twenty (20)
feet of the pile driving operation.
Are all employees within 40’-0” radius wearing hearing protection? Is this
protection sufficient?
Are existing emergency procedures adequate for pile blowouts? Safe working radius
established 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 to safely 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 been notified? Location of off-loading area: ____________________
Have precautions been taken to properly place signage on public roadways and
contractor has provided for traffic control?
Are there any issues, areas of confusion or items needing more discussion? If yes,
explain:
Miscellaneous
Yes No NA
207
208
209
214
215
216
217
Yes No NA
Yes No NA
Yes No NA
Yes No NA
Railroad notified of work within the minimum clearance envelope?
Yes No NA
Street/road blockage approved by: __________________________
Yes No NA
(ES&S approval required)
218
Protection plans in place for jobs involving working over water?
Yes No NA
219
Yes No NA
220
Will work involve asbestos gaskets? Persons trained for asbestos gasket handling per
regulations?
Is there any other work involve working with lead?
221
Will work involve working with cadmium?
Yes No NA
Competent person: ___________________________
Yes No NA
Competent person: ___________________________
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222
Miscellaneous (cont.)
Will work involve Concrete and Masonry Construction?
Yes No NA
Competent person: _______________________________________
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?
Yes No NA
230
All equipment should be placed either in contained area or temporary containment
provided to prevent spread of an oil spill, particularly if near water
Review plans for disposal of hydro test water
231
232
233
Task(s): 1)______________________________ 2)_______________________________
Other: _____________________________________________________________________
Yes No NA
Yes No NA
permitted outfall or alternate plan
Will project effect one acre or more of ground?
Has an NPDES permit been obtained?
Are there any other equipment needs?
List powered equipment that will be used on site:
Yes No NA
Yes No NA
# and type of Compressors: ______________________________________________________
# and type of Generators: ________________________________________________________
Other: ________________________________________________________________________
234
Are there any internal combustion engines excluding vehicles that will remain on site
for a year?
Included in air permit?
Contractor maintains a log of all equipment?
Yes No NA
Page 105 of 197
Bay Area Operations
Table of Contents
GENERAL COMMENTS:
Page 106 of 197
Bay Area Operations
Table of Contents
ALL CONTRACTORS TO SIGN THIS SHEET
AFTER REVIEWING PRE-JOB FORM
NOTE : for Capital Projects, return signed copies of all workers who reviewed
this document, at end of project to owners representative
PRINT NAME
COMPANY NAME
SIGNATURE
Page 107 of 197
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Table of Contents
Attachment 1
Action Plans for Items marked "No"
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Attachment 2
Additional Comments/Details of Requirements
Item No:
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Page 109 of 197
Bay Area Operations
Table of Contents
Job Safety Analysis (JSA) Guidelines
Purpose
To provide a tool that will allow the supervisor to analyze hazards specific to their
tasks. This tool needed to be discipline specific to allow foremen to plan and assign
work 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. A
new 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 the
crew before work begins.
3. As the job progresses, the JSA should be amended to include any changes or
additions to the original job survey.
JSA Forms
See attachments
Page 110 of 197
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Table of Contents
Safety Analysis (J.S.A.)
Civil/Yard
Foreman: ____________________
Job Location: _____________________
Date: ___________________
Plan Work
√
Job Task: ______________________________________________
Job Survey
Overhead obstructions
√
Suggested Solutions
•
•
Elevated work
Moving material in
Material lifting
Tools to keep hands out
of harms way
Special tools needed and
inspected
Special PPE needed and
ordered
Work requiring special
permits
(Excavation, Conf. Space,
LOTO, etc.)
Excavation
•
•
•
•
•
•
•
•
•
•
•
•
•
•
Specifics-How will
this be done?
Adequate clearances of pipe racks,
power lines, etc.
Determine how many spotters will be
needed.
Work platforms needed?
Make sure of safe tie-off point.
Equipment for unloading available?
Are laydown/staging areas away from
congested areas
Is material too heavy/awkward to lift
by personnel?
Order lifting device to lift material.
Determine tool to keep hands out of
harms way.
Train employees on the “Knife Policy”.
Determine tools needed for the job.
Order tools for the job.
Determine PPE needed.
Order PPE needed for the job.
All procedures written and submitted.
All personnel trained?
•
Personnel trained in Dow’s M-74
Excavation Proc.
• Probing and excavation procedure
established.
• Excavation checklist completed as per
M-74.
For use at sites of The Dow Chemical Company and participating subsidiaries
Page 111 of 197
Bay Area Operations
Table of Contents
Civil/Yard
Foreman: ____________________
Job Location: _____________________
Date: ___________________
Plan Work
√
Job Task: ______________________________________________
Job Survey
Tight work area
Personnel training/
certification
Subcontractors
Inclement weather (wind
and rain)
√
Suggested Solutions
•
•
•
•
•
•
•
•
•
Spoil material
New employees (<6
months)
•
•
•
•
•
•
Specifics-How will
this be done?
Does area need additional ventilation or
shields?
Install barriers between work areas.
Identify all craft certification needs.
Identify personnel training deficiencies.
Subcontractors pre-qualified?
All personnel trained and indoctrinated.
Order supplies for covering/securing
equipment and material.
Alternate work planned for inclement
weather days.
Additional PPE on site (goggles, slicker
suit, etc.)
Equipment washout area designated.
Where is the appropriate dumpster
location?
Is soil analysis required?
Find out experience level of employee.
Discuss rules, expectations, and
consequences with employee.
Assign “Buddy” and discuss
expectations.
Page 112 of 197
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Table of Contents
Civil/Yard
Foreman: ____________________
Job Location: _____________________
Date: ___________________
Plan Work
√
Job Task: ______________________________________________
Job Survey
Inexperienced employees
√
Suggested Solutions
•
•
Help filling out STACs
•
•
Tools and procedures new
to employee
•
•
Repeaters
•
•
Illness among employees
Employee distressed by
personal issues
Physical ability
•
•
•
•
•
•
•
Adequate number of
employees
•
•
High – risk jobs (i.e.,
excavations)
•
•
•
Personnel training /
certification
•
•
Specifics-How will
this be done?
Determine experience level of
employee.
Assign “Buddy” and explain
expectations.
Have workers on same job complete
STAC as a group
Audit cards to ensure proper hazard
identification.
Provide specific/documented training.
Assign with co-worker experienced
with tools/procedures.
Are employees repeaters & can they do
the job safely?
Discuss requirements and hazards of
job to ensure.
Clear understanding.
Should the employee be at work?
Assign the person to a low-risk job.
Reassign to low-risk work / send home.
Assign the employee to a “Buddy”.
Does employee have physical ability to
do the work?
Match employee’s physical abilities to
perform job.
Assign adequate number of workers to
perform task.
carry materials, ladders, etc.
Assign experienced employees.
Have employees work in pairs.
Give employees radio for quick
communications.
Verify all craft certifications.
Verify personnel training badges.
Page 113 of 197
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Table of Contents
Job Safety Analysis (J.S.A.)
Instrumentation & Electrical
Foreman: _____________________ Job Location: ______________________ Date:
_________________
Plan Work
√
Job Task: _____________________________________________________
Job Survey
√
Suggested Solutions
certification
•
•
Identify personnel training deficiencies.
Overhead work
•
•
•
•
•
Schedule other workers out of areas.
Barricade the area.
Make sure of safe place to tie off.
Extra ladders needed in event of
emergencies?
Obtain adequate number of aerial lifts,
scaffolds, etc.
Obtain cribbing for conduit and wire
reels.
Are laydown/staging areas away from
congested areas?
Crane/Drott needed?
Trained and qualified flagmen and
riggers on crew?
Assign adequate personnel to lift
material safely.
Plan work to spread workers out.
Put up barriers between work areas.
Determine PPE needed (i.e., special
gloves for job).
Order PPE needed for job.
Determine special tools needed for job.
Alternate work plans for inclement
weather days.
suits, etc.)
Elevated work
Adequate access / egress
•
Moving material in
•
•
•
Lifting material to
elevated work areas
•
•
Material too heavy /
awkward to lift by
personnel
Tight work area
•
•
PPE needed and ordered
inspected
and rain)
•
•
•
•
•
•
•
•
•
Specifics-How will
this be done?
Page 114 of 197
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Table of Contents
_________________
Plan Work
√
Job Task: _____________________________________________________
Job Survey
Subcontractors
Excavation (installing
ground rods, utility poles,
trenching, etc.)
permits
(LOTO, ESWP, Elec. Hot
Work procedure, etc.)
of harms way
New employees (<6
months)
√
Suggested Solutions
•
•
•
•
•
•
•
•
•
•
•
•
•
Help filling out STAC’s
•
•
to employee
•
•
Repeaters
•
•
•
•
•
Specifics-How will
this be done?
Subcontractor pre-qualified?
Permit obtained. All personnel trained.
Probing and excavation procedure
established.
All personnel trained in permits and
procedures.
Determine tools to keep hands out of
harms way.
Discuss rules, expectations,
consequences w/employee
expectations.
employee.
expectations.
STAC as a group.
identification.
Provide specific training.
with tools/procedure.
this job safely.
job to ensure.
Clear understanding.
Assign person to low-risk job.
Page 115 of 197
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Table of Contents
_________________
Plan Work
√
Job Task: _____________________________________________________
Job Survey
√
Suggested Solutions
personal issues
•
•
Reassign to low-risk job/send home.
Physical ability
•
do the work?
perform job.
perform task.
Assign experienced employee.
communications.
Verify all craft certification.
•
Adequate number of
employees
•
•
High-risk jobs (i.e., Hot
work)
•
•
•
Personnel training/
certification
•
•
Specifics-How will
this be done?
Page 116 of 197
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Table of Contents
General Mechanical/Construction
_________________
Plan Work
√
Job Task: _____________________________________________________
Job Survey
√
Suggested Solutions
certification
•
•
Overhead work
•
•
Identify personnel training
requirements.
Schedule other workers out of areas.
Barricade the area.
Elevated work
•
•
Make sure of safe place to tie off.
Adequate access / egress
•
Extra ladders needed in event of
emergencies?
Obtain adequate number of aerial lifts,
scaffolds, etc.
Obtain cribbing for equipment, pipe,
steel, etc.
Are lay down/staging areas away form
congested areas
Crane/Drott needed?
Trained and qualified flagmen and
riggers on crew?
Are any lifts critical?
Assign adequate personnel to lift
material safely.
Plan work to spread workers out.
Put up barriers between work areas.
•
Moving material in
•
•
•
Lifting material to
elevated work areas
Material too heavy/
awkward to lift by
personnel
Tight work area
PPE needed and ordered
inspected
of harms way
•
•
•
•
•
•
•
•
•
•
•
•
•
Specifics-How will
this be done?
Determine PPE needed (i.e., special
gloves for job).
Order PPE needed for job.
Determine special tools needed for job.
Determine tools to keep hands out of
harms way.
Page 117 of 197
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Table of Contents
_________________
Plan Work
√
Job Task: _____________________________________________________
Job Survey
√
Suggested Solutions
permits (LOTO, Critical
Lift, Confined Space, Hot
Work, etc.)
Excavation (Trenching,
Shoring, etc.)
•
•
All personnel trained in permits and
procedures.
•
•
Permit obtained. All personnel trained.
Probing and excavation procedure
established.
and rain)
•
Alternate work plans for inclement
weather days.
suits, etc.).
Subcontractor prequalified?
Man-count requirements understood?
Knowledge of chemicals involved.
Identify PPE Requirements.
Other special requirements
(Medical/Training)
Discuss rules, expectations,
consequences w/employee
expectations.
employee.
expectations.
STAC as a group
identification.
Provide specific training.
with tools/procedure.
•
•
Subcontractors
Line Breaking
New employees (<6
months)
•
•
•
•
•
•
•
•
•
•
•
Help filling out STAC’s
•
•
to employee
•
•
Specifics-How will
this be done?
Page 118 of 197
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Table of Contents
_________________
Plan Work
√
Job Task: _____________________________________________________
Job Survey
Repeaters
√
Suggested Solutions
•
•
personal issues
•
•
•
•
Physical ability
•
•
Adequate number of
employees
•
•
High-risk jobs
•
•
•
Personnel training/
certification
•
•
Specifics-How will
this be done?
this job safely
job to ensure clear understanding.
Assign person to low-risk job.
Reassign to low-risk job/send home.
do the work?
perform job.
perform task.
Assign experienced employee.
communications.
Verify all craft certification.
Page 119 of 197
Bay Area Operations
Table of Contents
Carpenter & Scaffold Builder Policy
Statement of Policy This policy requires all contractor personnel to wear monogoggles when handling
scaffold materials, lumber or doing tasks that may generate sawdust, airborne
material, or dust.
Scope
Carpenters and scaffold builders, whether full time in craft or performing these duties
and 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. The
eye protection currently being worn by these crafts is side shield safety glasses. It is
these craftsmen’s responsibilities to upgrade eye protection to eliminate these
injuries.
Page 120 of 197
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Table of Contents
Procedure Use Policy (PUP) for Leveraged Dow Maintenance
Employees and Maintenance Contractors
Policy
All leveraged Dow Maintenance employees and Maintenance contractors shall
comply with these minimum expectations for procedure use.
Purpose
The purpose of this Policy is to provide minimum expectations for leveraged
Dow Maintenance employees and Maintenance contractors for the application
of procedure use across DOW Maintenance.
Minimum
Expectations
•
A contractor or leveraged Dow employee assigned to a task will ask if
a procedure exists.
•
If a procedure exists, follow it. If you are not sure you know the
procedure in detail, keep it with you on the job site.
•
Get assistance if you believe the procedure is incorrect or incomplete.
•
A procedure that has been identified as a “Critical Procedure” must be
with you as you perform the task.
•
If a procedure does not exist, but you think you need one, ask for
assistance in developing one.
•
The use of generic procedures for routine tasks (scaffold building,
insulation work, etc.) is appropriate. When a business has an
equipment specific procedure, it should be used versus the generic
procedure. It is a business responsibility to provide the procedure, and
training as required, on the use of the equipment specific procedure.
•
These Minimum Expectations will be communicated to all
Maintenance personnel and Operators. The Contract Administration /
Labor Services Group is responsible for rolling this procedure out to
Contractor Management providing on-site services (on Dow property,
not in vendor shops) so they can train their employees.
•
Business / Department specific PUP requirements which exceed these
minimum expectations must also be followed.
Page 121 of 197
Bay Area Operations
Table of Contents
Contractor Craft Skills Assessment Policy
Purpose
To clarify craft skills assessment of contractors working on Bay Area sites.
Scope
This policy applies to all workers within assessable crafts in maintenance and small
projects only.
Background
This policy is intended to assure consistency with Dow stated goals. It is not the
intent 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 assessed
under one of the recognized processes. Such processes include the new national
assessment, 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 to
perform all assigned tasks.
Individuals employed with a contractor less than 6 months are considered “in the
process of being assessed”. A performance and/or written assessment must be
conducted and submitted to the NCCER database by the time an individual enters the
seventh month of employment with a contractor. Locally it may be submitted to
ABC, Texas Gulf Coast for entry into this database.
Assessable Crafts
Assessment Due
Date
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
Contractor Personnel Skills Assessment update is due quarterly.
Page 122 of 197
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Table of Contents
Contractor Training Card Policy
Purpose
To allow individuals in the field (i.e. Permit writers) to be able to verify training of
specific contractor workers.
Scope
This policy applies to all contractor workers who have been trained in any of the
categories listed on the "training card" (see example).
Policy
Each contractor employee who has been trained in any of the topics listed on the
training card (see example) must have in their possession a copy of the training card
indicating the company that the individual works for and the most current date of
each training category that applies.
Each Contractor firm working on the Bay Area sites must furnish to Dow Contractor
EH&S the latest training dates of each of their employees on the specific topics
identified on the "training card".
Training Badge
Codes
Texas City Safety Council
DOW Gulf Coast Contractor Orientation
DOW Chemicals Confined Space
DOW Chemicals Red Tag System
DOW Chemicals Scaffold User
DOW Safe Driver
07 DOWSS
07 DWGCS
07 DOWRT
07 DWTSU
07 DWSD
Houston Area Safety Council
DOW SITE SPECIFIC
DOW CHEMICAL GLOBAL CONF SPACE
DOW RED TAG
DOW TEXAS CITY SCAFFOLD USER-CSCTC
DOW DRIVERS SAFETY
19DOWSS
07DWGCS
19DOWRT
07DWTSU
19DOWDR
DOW CLEAR LAKE OPERATIONS
DOW ELEC WORK PRACTICES
19DOWCLO
19DOWEWP
DOW GULF COAST PIPELINE
DOW HOUSTON-HAZCOM
19DGCP
19DHOHAZ
Page 123 of 197
Bay Area Operations
Table of Contents
Job & Equip Specific Training for Contractors
Introduction
This document exists to define the work process to ensure Contractors receive job
and equipment specific training unique to Dow.
Objective
To qualify Contractors to perform specialty work at Dow. This training will be site
specific and job specific for this location. This is not intended to replace Contractor
EH&S training given at the Contractor Safety Councils.
Work Process
•
Subject Matter Experts will identify and maintain the training courses and
updates in the Job & Equipment Specific Training Table. (covered in pre-job
review). Site Call Out Procedure should address the issue of specific training
required for work on a particular piece of equipment.
•
Each craft will have courses outlined.
•
Contractor Management will train or coordinate to ensure qualified personnel
train 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, field
interventions, and field audits.
Work Process
Boundaries
Corporate Co-employment requirements
Roles and
Responsibilities
The following are the roles and responsibilities for the Job and Equipment Specific
Training for Contractors.
Role
Responsibilities
Contractor •
Management
•
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 Training Table.
Page 124 of 197
Bay Area Operations
Table of Contents
Job & Equip Specific Training for Contractors, cont.
Roles and
Responsibilities
(continued)
Role
Responsibilities
Contract
Services
•
Inform contract company of required job specific training:
*New hire orientation
Planner
Training Process
and
*Pre-job meeting.
•
Ensure required training is completed and documented.
•
Perform periodic audits to ensure resident contractors are in
compliance with required training.
•
Notify contractor company of additions or deletions to the Job &
Equipment Specific Training Table.
•
Include job specific training information in the planning package.
•
Include job specific training requirements in the Contract Service
portion of the work order.
The following table shows the training process for specific training for Contractors
at Dow.
Step
Action
1
Contractor completes all required EH&S training.
2
Contractor reports to site for badging.
3
IF …this is a
THEN …
Resident Contractor
Contractor Management reviews equipment
specific table for applicable training.
Go to Step 4.
Non-resident Contractor Contract Services reviews equipment
specific table for applicable training.
Go to Step 4.
Page 125 of 197
Bay Area Operations
Table of Contents
Training Process
(continued)
Step
Action
4
IF …training is
THEN …
Required immediately
SME is contacted to deliver the required
training.
Go to Step 5.
Not Required
immediately
SME is contacted to schedule required
training prior to that task being performed.
Go to Step 5.
5
Contractor employee records are updated to reflect completion of training.
Page 126 of 197
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Table of Contents
DOW Maintenance
Craft Specific
Training
Job & Equipment Specific Training Table needs to list each site’s specific
training requirements. Need SME’s to review list to see is the training is
the same for each site
Site
Craft
Training
Description
Procedure
Title and
No.
Duration of
Training
Delivery Method
Tasks or
Crafts
Affected
Freq
TCO
Air Cond
2nd Set of Eyes
(as needed)
810467
Course &
procedure
2 Hrs
Classrm & 1
month OJT
Classroom &
Hands-on
Air
Conditio
n/Electri
cal
2Y
TCO
Analyzer
PSM Instrument
Procedure
Trng Course
810408
2 Hrs
Classroom
Instr &
Analyzer
Initial
J. Johnson
TCO
Iso-Instrument
Procedure QManual
Trng Course
810190
1 Hr
Classroom
Instr &
Analyzer
Initial
J. Johnson
TCO
Instrument Craft
Procedures
ICP-01 thru
ICP-20
As Needed
WEB-EDMS
Instr &
Analyzer
Bolted Joint
Assembly
MP-8.01
1 Hr
Video
Pipefitter
& B-M
Rigger
Initial
D.
McClellen
Hydraulic
Torque Wrench
Ghris Code
350506
1 -1/2 Hrs
Classroom (Gulf
South Sweeney)
Pipefitter
& BMRigger
Initial
D.
McClellen
TCO
Auto
Mech
TCO
Boiler
maker
TCO
SME
G. Kirkland
Initial L. Geters
plus
refresher
as
needed
Carpenter
Crane
Operator
Page 127 of 197
Bay Area Operations
Table of Contents
DOW Maintenance
Craft Specific
Training
(continued)
Site
TCO
Craft
Procedure
Title and
No.
Duration of
Training
Delivery Method
Tasks or
Crafts
Affected
Freq
SH-2.7
2 Hrs
Classroom
3 yrs
Pat Holman
Rowan Starters
(job specific)
PE5.01.04 &
PE5.01.09
2 Hrs
Classroom
Electrica
l
Electrica
l
Initial
Hollis Cagan
2nd Set of Eyes
(as needed)
810467
Course &
procedure
Tng Course
710009
2 Hrs
Classrm & 1
month OJT
1 Hr
Classroom &
Hands-on
Electrica
l & A/C
3 yrs
Pat Holman
Classroom
Electrica
l
Initial
Pat Holman
Low Med
Circuit Breaker
Op
Trng Course
350501
4 Hrs
Classroom
Electrica
l
Initial
Pat Holman
Motor Rotation
Meter
Trng Course
810474
1 Hr
Classroom
Electrica
l
Initial
Pat Holman
Tic Tracer
PE5.01.16
15 minutes
Classroom
Initial
Pat Holman
EEIP Form
Contact Gary
Kirkland
2 Hrs
Initial
Gary
Kirkland
Trng Course
810408
Ghris Code
350508
ICP-01 thru
ICP-20
Trng Course
810190
2 Hrs
Read before doing
Task or Classroom
(large group)
Classroom
Electrica
l
Electrica
l
Initial
J. Johnson
0.5 Hr
Classroom
Initial
G. Cowart
As Needed
WEB-EDMS
Initial
L. Geters
1 Hr
Classroom
Initial
J. Johnson
1 Hr
Video
Initial
D.
McClellen
Training
Description
Electrical Electrical Safety
PCB Training
(job specific)
TCO
TCO
TCO
TCO
TCO
PSM Instrument
Procedure
Blowback
Overview
Instrument Craft
Procedures
Iso-Instrument
Procedure QManual
Bolted Joint
Pipefitter
Assembly
Instr –
Control
Systems
MP-8.01 &
Ghris N295
Instr &
Analyzer
Instrume
nt
Instr &
Analyzer
Instr &
Analyzer
Pipefitter
& IWRigger
SME
Page 128 of 197
Bay Area Operations
Table of Contents
DOW Maintenance
Craft Specific
Training
(continued)
Site
TCO
Craft
Hydraulic
Pipefitter,
Torque
Wrench
cont.
Lokring
Installation
Rupture Disk
Installation
Valve Maint
Repair
TCO
TCO
TCO
TCO
TCO
TCO
Training
Description
RiggerIW
DOW field
sketch
requirements
Flange Tagging
Procedure
Hydraulic
Torque Wrench
Procedure
Title and
No.
Duration of
Training
Delivery Method
Tasks or
Crafts
Affected
Freq
Ghris Code
350506
1 Hr
Classroom by Gulf
South Sweeney
Initial
Don
McClellen
Trng Course
810333
Trng Course
800035
Ghris Code
M428 & Trng
Course
810340
1 Hr
3 Years
Pipefitter
3 Years
2 Hrs
Classroom by
Rawson
Classroom by
BS&B (rep. AWC)
Video
Pipefitter
& BMRigger
Pipefitter
Pipefitter
3 Years
Don
McClellen
Don
McClellen
Don
McClellen
.5 HR
Power point
Pipefitter
Initial
Don
McClellen
1 HR
Power point
Pipefitter
Initial
1 Hr
Classroom (Gulf
South Sweeney)
Pipefitter
& Rigger
Initial
Don
McClellen
Don
McClellen
Ghris Code
350506
2 Hrs
Page 129 of 197
SME
Bay Area Operations
Table of Contents
Contractor Site Safety Representative
Minimum Expectations
Purpose
To ensure that contracting companies follow the minimum expectations for
Contractor Site Safety Representatives.
The Contractor Site Safety Representative’s primary purpose is to assist the
contractors (prime and sub-contractors) in achieving DOW’s EH&S goals.
A contractor Safety Representative (full or part time) will be identified for all
contractors working at the facility prior to the start of work.
A contract company with 25 or more employees will supply a full time Safety
Representative.
Scope
Applies to all contractor companies.
Policy
•
Check that the prime contractor has reviewed the pre-job safety conference
minutes, 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 timely
manner. (A full-time safety representative will perform audits daily)
•
Participate in all incident investigations and make certain the prime contractor
submits 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 the
Contract Administrator and the prime contractor.
•
Monitor the site to ensure all contractor employees are participating in the safety
effort.
•
Participate in the site behavior based program and complete the minimum
documented observations/interventions.
•
Be involved in the safety culture for the site.
Page 130 of 197
Bay Area Operations
Table of Contents
Minimum Certification/Training Requirements
for Contractor Safety Contacts
Purpose
To set minimum requirements for individuals working as Contractor Safety Contacts
on the Bay Area sites and to raise the level of safety and health knowledge of
contractor safety contacts.
Scope
This applies to all Contractor Safety Contacts on Bay Area sites (TCO, CLO, DHH,
HOU).
Policy
Each Contractor Safety Contact working on The Dow Chemical Company Site must
secure as a minimum Construction Site Safety Technician Certification or
equivalent and complete all "site specific" training that apply to work on a Dow
Chemical site. CBT modules are available through one of the local Contractor Safety
Councils (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 First
Aid 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 levels
of experience and training.
•
A Safety and Health Certificate (15 credit hours minimum) from an accredited
college
•
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 Industrial
Hygiene and/or the Board of Certified Safety Professionals of the Americas, Inc.
CBT
CBT stands for "computer based training". CBT is an interactive computer delivered
training method currently used by most contractor safety councils.
Page 131 of 197
Bay Area Operations
Table of Contents
Minimum Certification/Training Requirements
for Contractor Safety Contacts, cont.
Dow Specific
Training
Requirements
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)
Requirement
implementation
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 related
educational course offered
•
or scheduled to take one of the certification tests within the next 30 day time
period.
Page 132 of 197
Bay Area Operations
Table of Contents
Buddy Policy
Statement of Policy Contractors will assign a buddy to all new employees for their first six weeks. A new
employee is anyone that has been employed less than 6 months. The experienced
buddy will use the Buddy Checklist to assure all elements are covered in training the
new employee. This checklist will remain on the new employee for the first six
months. Any new employee involved in an incident will be required to bring a copy
of 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 the
training and assignment of experienced buddies to new employees.
Responsibilities
•
The foreman will conduct buddy training and will qualify experienced personnel
as buddies. The foreman will assign a buddy to all new employees. The buddy
will use the Buddy Checklist to communicate job knowledge to the new
employee.
•
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 for
reviewing the Buddy Checklist with the assigned buddy every morning for the
first week. After the first week the review will occur each Monday morning for a
month. In the event of an incident the Buddy Checklist will be turned in with the
Pre-Task Analysis. The buddy checklist may be kept with the foreman to assure
it is not lost during training.
•
The foreman will identify the at risk employee by placing orange tape around his
hard hat.
•
The contractor company is responsible for retention of the checklist for the
remainder of the first six months.
Criteria for
Selecting a Buddy
The buddy will be a responsible person assigned by the foreman to work with the new
employee. The buddy will have a history of safe work. The buddy must be able to
communicate the expectations of the buddy checklist to the new employee. The
buddy will communicate the progress of the new employee to the foreman.
Consequences
Foremen that have incidents involving new employees that have not been assigned a
buddy, according to this policy, will receive consequences to be determined by the
contract company.
Page 133 of 197
Bay Area Operations
Table of Contents
Buddy Checklist
Initial
Completion
Supervisor 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 behaviors
Recall current LER’s with employee that pertain to the job
Set a good example for new hire by:
• Work in a craftsman like manner
• Comply with safety rules and standards that apply
Verify the new hire can use tools safely – communicate, demonstrate and observe
Review Precautions for Line/Equipment Openings
Review Precautions for Hot Work
Identify the following at work site:
• Verify minimum training requirements (LO/TO, SWP, Confined Space, Vehicle
Operator’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 conditions
Require 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 set
measures in place to prevent an incident
• Address job scope changes on STAC
Buddy
New Employee
Today’s Date
New Hire Date
Review Dates: ____________, ___________, ___________, ____________, ____________, ____________,
____________, ____________, ___________: ____________: ____________;
This document is to be kept by the new employee after buddy covers with the new employee.
Page 134 of 197
Bay Area Operations
Table of Contents
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 these
responsibilities in different roles (project manager, owner’s rep, etc.) – Engineering Solutions work process ensures
responsibilities of “Job Rep” are completed.
Purpose:
To ensure there is a Dow person identified to be responsible for all Contract
Suppliers coming on Site.
Definitions
Term
Definition
One Time P.O. Job
Representative
This person, for the duration of the work, acts as the
focal point for job specific contractor requirements in the
area of health, safety, and environment for the Purchase
Order they are requesting. This is necessary when the
Maintenance Contract Administrator or the Discipline
Activity Specialist does not administer the Supplier.
This person acts as the focal point for job specific
contractor requirements in the area of health, safety, and
environment. They monitor day to day performance of
Suppliers with regard to contractual agreements.
Gate Entry Status
database
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 Activity The DAS is the focal point for specific work types. They
Specialist (DAS)
work with procurement, EH&S, maintenance and users
to insure Dow’s policies are followed in selection and
effective deployment of acceptable contract companies.
They assure a process is in place to restrict unauthorized
craftsmen from entering the plant.
Background:
This information is used to assure consistency of contractor administration and
increase our ability to leverage the contractor company’s capabilities across the site.
Policy:
All contractors providing services, even those under a “ONE TIME PURCHASE
ORDER” for Dow shall be assigned a Job Representative.
The Job Representative Role will be assigned to the Job Requestor unless someone
else has been assigned.
Page 135 of 197
Bay Area Operations
Table of Contents
Job Representative Roles and Responsibilities for the
Administration of “On-Site” Labor Service Contracts, cont.
Role of the Job
Representative
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 not
demonstrated EH&S performance acceptance as defined by Contract Safety, must
meet 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 Contract
Company will accomplish the work according to EH&S objectives.
3. There are to be no unwritten agreements affecting the terms and conditions of the
contract.
4. Elements of the Conflict of Interest Policy are known and understood by both
parties.
5. A service agreement, a specific contract, or a Purchase Order shall cover all
contractors.
Role of the
Contract
Administrator:
1. The Contract Administrator acts as the Dow Representative for a specific
contract.
2. Acts as the Dow Primary contact for execution of the contract and the Owner’s
representative 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
1
2
Description
Verifies:
•
the Supplier has been approved in the “Gate Entry Database”. And
that Supplier personnel provided are qualified to perform the work
safely.
•
that the Contract Company has received the Bay Area Contractor
Administration Manual, Site Safety Rule Book and related topics
include the Co-Employment Policy, Conflict of Interest Policy,
Safety requirements including Site Standards/Policies and any other
documentation required by the Pre-Job This information is
reviewed with the contract company by the contract administrator.
•
that the on site Contractor Management is knowledgeable of the
EH&S hazards of the plant and identifies the EH&S Focal Point.
Has sufficient knowledge of the terms and conditions of the contract to
allow for the proper execution of the work.
Page 136 of 197
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Table of Contents
Responsibilities
(continued)
Item
Description
3
Provides job scope, details and specific safety requirements, (i.e. Confined
space, Lockout/Tagout etc.), to Procurement for contract negotiations
between Purchasing and the contractor.
4
Determines, with Contractor EH&S, the need for a Pre-job meeting to be
held between the Unit, Contractor Safety and the Contract Company and
participate as necessary. (Follow Pre-Access and Pre-Job Meeting policy)
5
Ensures:
•
all contractor employees have received the proper Site and
Department indoctrination.
•
that while performing work on site, the contract company complies
with all the EH&S requirements of the Dow Global Standard for
Non-Dow Services and Visitors.
•
that Contractor EH&S is informed of all EH&S incidents involving
the Contract 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
interference between jobs.
•
QSPP’s are entered for all contractor incidents.
•
the Contract Company provides adequate EH&S resources to the
Contract employees and that an EH&S focal point is identified by
the contractor.
•
lines of communication stay established with the designated
contact, qualified personnel, who will be able to perform the work
safely. Qualifications may include 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
will increase the cost of the contract, prior to authorization to the contractor.
7
The Supplier and Contract Administrator will review the Recordable or
Reportable incident with the Responsible Care Leader and Site Leader if the
Supplier incurs such an incident during the timing of the Contract.
Page 137 of 197
Bay Area Operations
Table of Contents
Responsibilities
(continued)
Item
8
9
Description
The Contract Administrator:
•
is knowledgeable of the EH&S DOW 06.06 Non-DOW Services
and Visitor Standard and the Bay Area Contractor Administrative
Manual.
•
are familiar with the site and unit indoctrination process and
ensures the contractor is following the process.
•
will have a designated contact with the Contractor, usually a
foreman or someone designated by Contractor management.
•
is knowledgeable of all the regulatory requirements for the
discipline and that area.
•
conducts behavioral field audits to ensure that the safety rules are
being followed.
•
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 Safety in providing periodic performance evaluations
of the contractor.
The Contract Administrator will have a designated back up in the event of a
prolonged absence from the site and this shall be communicated to the
contractor
Page 138 of 197
Bay Area Operations
Table of Contents
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
and Company, 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 the same 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
all Contractors working on site.
2
All needs of the plants / departments for a contracted for service will be
directed to the appropriate DAS.
3
All Contractors:
•
in the plant with a One Time P.O. shall have a Contract
Administrator/Job Representative.
•
receive a site and unit indoctrination covering the unit rules,
applicable policies, details of specific hazards, and emergency
procedures including spill containment plans.
Page 139 of 197
Bay Area Operations
Table of Contents
Business Rules
(continued)
Item
4
Description
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
and Procedures; the “Contractor Administrative Manual”.
•
shall inform the DOW units of any hazards they bring to the site
which may affect the DOW Unit or personnel.
5
Procurement, Contractor Safety, the Business EH&S Leaders and the
Contract Administrator shall work as a team in establishing action plans for
specific contract companies.
6
AMSL:
•
The AMSL Contract Companies shall be used for services described
in the Service commodity description.
•
Contract Administrators shall ensure that the AMSL list of
contractors is used or a MOC is executed.
7
The costs for managing Managed Service Contractors shall flow according
to Maintenance Business Rules.
8
The cost of supplying DOW infrastructure to the contractor shall be applied
in a consistent 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 & Use Policies and with agreement of the Contract
Company Management.
10
The DAS:
•
may allocate work volume to the preferred contractors with
involvement and approval of Purchasing and Site Leadership.
•
is kept current on the unit price for the services.
Page 140 of 197
Bay Area Operations
Table of Contents
Contractor Safety Alliance/Site Safety Meeting
Purpose
The purpose of this process is to ensure that contract companies working on site
receive pertinent EH&S information
Expectation
Contractor Safety Alliance meetings will be held on a monthly basis at a central
location, which is accessible to all contractors. It is also expected that all contractors
will be represented at these meetings.
Meeting Format
There are two site Contractor safety teams: a mechanical/process area work team and
an Admin/Non-process area work team. The division allowed delivery of
information pertinent to the different work groups.
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
Information
Source
The information communicated at the meeting is collected/calculated by Contractor
Operations.
Communication
The meeting schedules/agendas will be communicated by e-mail.
Site Contractor
Safety Meeting
There is a site wide contractor safety meeting that must be attended/represented by all
companies who have a presence on site at the time of the meeting, this safety meeting
held weekly on Thursday morning, 7:35 am, Bldg. 60.
Page 141 of 197
Bay Area Operations
Table of Contents
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 Bay Area sites will include a cost based
on the intended scope. Contract companies will only be paid the agreed price unless
a scope change or price change is approved by the Work Activity Coordinator
(WAC). No other authorization will be accepted.
It is Purchasing's expectation that Contract Companies will track their ongoing cost
and take a proactive approach to contact the WAC before agreed upon pricing will
be exceeded. Unless new pricing is agreed to Purchasing will only pay the original
PO price.
Job Scope Change
Anything outside the original scope of work will require the contractor to contact the
WAC and fill out a Scope/Cost Change Form. This must be completed and signed
by the WAC before any additional work can begin. It will be determined at that time
if a new PO will be generated to cover the scope and/or price change.
Form
Requirements
Signed Scope/Cost Change Forms will be required to accompany supporting
documentation when invoicing. Summary billing along with supporting
documentation is required to be sent to the Site 10 days prior to invoicing.
Job Progress
Reports
The site Global Maintenance Work Process requires contractors to sign in & out at
the 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.
Page 142 of 197
Bay Area Operations
Table of Contents
Maintenance Scope/Cost Change Form
Scope
This document is used by Maintenance to provide instructions for Maintenance
Scope/Cost Change.
Work order #
Purchase Order #
Contractor name
Reason/description
for scope/cost
change
The following is a brief reason/description for the scope/cost change:
New cost estimate
$
_________________________________________________________________
Building location
WAC approval
Contractor
signature
This change was approved by:
____________________________________
(Name)
____________________
(Date)
This change was signed off by:
____________________________________
(Name)
____________________
(Date)
NOTE: Contractors are responsible for filling out scope/cost change form before any
work can begin on a job site due to scope/cost growth. Without WAC approval,
DOW is not responsible for payment.
Page 143 of 197
Bay Area Operations
Table of Contents
STAC Training Process
Purpose
The purpose of this process is to ensure that all contractor supervisors, foreman and
crew leaders that work for Dow understand the STAC process and know the
expectations.
Expectation
The expectation is that all contractor supervisors, foreman and crew leaders will
attend 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 individuals
in their crew, (which indicates approval of the card).
The contract company will ensure a management system is in place to address
improvement in hazard recognition using the STAC process (various components of a
management system are reviewed in the STAC training for supervisors).
Scheduling
Sessions
STAC training will be conducted at least monthly by EH&S Delivery;
Second Wednesday of the month from 9am-11am at TCO. Schedule through the Job
Rep/Contract Administrator or call 409-948-5581.
•
HOU
•
CLO
•
DHH
Special training sessions are conducted upon request. Contractor foreman, crew
leaders and anyone the company deems necessary are invited to attend these sessions.
Page 144 of 197
Bay Area Operations
Table of Contents
Injury/ Illness Reporting
Scope
To supplement ODMS 6.04 and 6.05 requirements on Emergency Preparedness and
Response. This procedure applies to all site personnel and contractors. This
document does not contain treatment information. Refer to individual
departmental Emergency Plans. Refer to Departmental or business incident
reporting procedures for additional incident reporting requirements.
Definitions
(defined words are italicized)
Term
Emergency
Response
Definition
Alarm boxes:
Available at specific sites. Are used to activate the alarm
system Each box is individually identified and are often
located near roadways, along the perimeters of production
units.
Health Services:
staffed medical facility.
Site Radio System:
A system of Hand Held Radio Units and Base Stations
throughout the Site.
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 for
maintenance or Owner’s Rep for construction) as applicable.
IRL to provide an MSDS to the ES&S DELIVERY SPECIALIST
Page 145 of 197
Bay Area Operations
Table of Contents
Injury/ Illness Reporting, cont.
Non- Emergency
Response
Step
1
Action
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 for
medical treatment.
2. The Contractor supervisor must call
ES&S DELIVERY SPECIALIST AND
inform the Permit Issuer or area contact if
no Permit was issued
IRL
Responsibilities
(for injuries only)
2
In all cases, direct Emergency Response or Contractor supervision to
location of injured/ ill person
3
The Permit Issuer or area contact will then notify the IRL as applicable
After Post Emergency Activities (CR Step 5.5), the IRL must make required notifications per
Department Procedures. In addition, e-mail the crisis stamp to the IRL/ES&S network. The
site expectation is for each IRL, receiving the injury notification, to share the information with
their work group.
Page 146 of 197
Bay Area Operations
Table of Contents
Contractor Incident Flowchart
Page 147 of 197
Bay Area Operations
Table of Contents
Contractor Incident Flowchart, cont.
A
Contractor completes
preliminary
Contractor
Accident/Incident/Unsafe
Condition Report
Plant/Area Contact,
Contract Administrator/Job
Rep, EH&S and contractor
representative review final
investigation report
Contractor conducts preliminary
investigation which includes statements
from all involved contract employees
(use Investigation checklist)
Contractor forwards a copy
of preliminary Contractor
Accident/Incident/Unsafe
Condition Report and STAC to
Contractor EH&S by 10:00AM
the next working day.
Plant Reviewers and
contractor representative
discuss and resolve
Do reviewers
detect any
unresolved
issues?
Y
N
Contractor schedules formal
RCI if recordable injury/illness or serious
incident trigger is met - root cause
investigation- and invites contractor
employees (and plant participants).
Contractor conducts the investigation by
the 3rd working day.
(Complete Cause & Effect diagram with
Corrective Actions and include an ABC
analysis if behavior is a Root Cause)
Contractor determines the OSHA
classification for Recordable
injury/illness
Contractor forwards final
report by 7th working day with
updated Incident/Accident
Report to review team and
communicates as appropriate
Contract
Administrator / Job
Rep schedules
SLT Review of
RCI and
Corrective Action
with Contract
Company
Y
N
Contractor forwards copy of Root
Cause Investigation Report to and
schedules a review with Contractor
EH&S, Plant/Area Contact,
Contract Administrator/Job Rep &
Plant EH&S Delivery
Was the
incident a
Rec Inj/Ill?
Job Rep/Contract
Administrator ensures
QSPP is entered for
incident / EAT entries
completed as appropriate
Page 148 of 197
Bay Area Operations
Table of Contents
Incident/Unsafe Condition Reporting and Investigation Process
Statement of Policy All incidents and unsafe conditions that occur on site will be reported and
investigated 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 safety
suggestions that involved the contractor company.
Purpose
To ensure the standardization and criteria for reporting of incidents/unsafe conditions
and investigations.
Responsibilities
Contract employees are to report all incidents and unsafe conditions.
Written notification must be submitted for every occupational injury or illness, spill
or leak, Near Misses, equipment damage, unsafe condition, or other serious accident
or incident. The Contractor Accident/Incident & Unsafe Condition/Safety Suggestion
Report form shall be used.
Contractor management is responsible for communication to the appropriate DOW
representatives per the site Injury/Illness Reporting procedure and to ensure that the
Dow Job Rep is kept informed.
Contractor companies are responsible for developing procedures/policies to assure
the reporting of all EH&S incidents and unsafe conditions that occur within their
company while on DOW property. The contractor company must assure that all their
employees understand and follow their policies/procedures while on DOW property.
Contractor companies must provide copies of and retain documentation for all EH&S
incidents and unsafe condition reports. This includes OSHA Injury & Illness Logs,
Accident Investigations, Root Cause Investigations, Follow-up for Corrective and
Preventative Actions, and other documentation as appropriate.
Incident
Investigation
Each contractor company is responsible for conducting investigations to determine
root cause of incident. Corrective actions will be developed and implemented by
contractor company to prevent reoccurrence.
Item
Description
1
Formal Root Cause investigations (RCI’s) will be conducted by the NonDow Service Provider for DOW Contractor RCI Trigger Criteria incidents
(Injuries & Illnesses, Spills or Leaks, Equipment Damage, and Potential
Serious Events see description in RCI trigger table). These investigations
will require use of Root Cause methodology i.e. Cause & Effect. The plant
contact, job/owner’s representative, and EH&S shall be present at the RCI
review.
2
Documentation of the Root Cause Investigations results and corrective
actions associated with the RCI shall be provided to the Job Representative
and Contractor EH&S.
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Incident/Unsafe Condition Reporting and Investigation Process, cont.
Incident
Investigation
(continued)
Item
3
Description
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
Potential Serious Events which may also trigger Contractor Owner SLT
review criteria – check with your Job Representative.
4
For incidents which do not meet the RCI Trigger criteria: the final Incident
report documents 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 and report findings to the EH&S representative.
Reporting
Preliminary Incident Report - The contractor shall complete the Preliminary Incident
Report for all incidents and submit it to the EH&S representative by 10am the next
business day and follow up with the final report when the RCI is complete.
•
TCO – Fax # and email
•
CLO – Fax # and email
•
DHH – Fax # and email
•
HOU – Fax # and email
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 following
information, at a minimum, from all incident investigations
•
Incident Description
•
Causes
•
Corrective Actions
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Separate DOW
and Contractor
Investigations
Keep the plant portion and the Contractor portion of the investigation separate. (i.e. a
gas inhalation from a gas release), plant would investigate why the gas release
occurred and the Contractor would investigate why the contract employee had the
inhalation. Each is a separate event and should be investigated separately though
appropriate attendance at each investigation to validate evidence and time line may
be required.
Unsafe Condition
Reporting and
Tracking
All unsafe conditions observed by contractors are reported and corrected in an
appropriate and timely manner. Those unsafe conditions that must be reported to
plant employees for follow-up corrective action (those conditions that are outside the
control of the contract company to correct) will be documented using the Contractor
Accident /Incident/ Unsafe Condition/ Safety Suggestion form.
Step
Action
1
The person who observes the unsafe condition completes the top portion of
the Contractor Accident/Incident/Unsafe Condition Form, down to, but not
including, Preventive/Corrective Actions. (Be sure that you provide enough
detail about the condition 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 the bottom of the form.
3
Contractor EH&S inputs unsafe condition description into EAT and
forwards copy to plant/facility Delivery Technician.
4
Delivery Technician determines the name of the person responsible for
submitting corrective actions and forwards to Contractor EH&S.
5
Contractor EH&S updates Event and Action Tool (EAT) with a single
action item for responsible facility person to enter corrective actions,
person(s) responsible and target or actual completion dates into EAT event;
(input from responsible person for target completion dates.)
6
Once the corrective action, etc. are added in EAT then Contractor EH&S
sends a copy of the report, with responses filled in, to the originator or, if
the report does not identify the originator, to the company representative.
Monitors EAT prompts for overdue actions, etc. and escalates as required.
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Contractor
Investigations
The contract company is responsible for assuring that contractor incidents that meet
the site RCI trigger criteria are of appropriate quality to determine root cause and
solutions that will prevent recurrence of the problem.
Contractor RCI
Trigger Criteria
Personnel Health
and Safety
Trigger Point
Injury/Illness – Days Away from Work,
Restricted Work, Medical Treatment
Personal Exposure to Chemicals, Noise,
Radiation
Environmental
Root Cause
Investigation Review
Team
Recommended:
RCI Tm Leader:
Contractor
Representative
Team: EHS Delivery
Tech or Delivery leader,
Contract Service
representative
Recommended:
Loss of Primary containment (spill or
release of contractor materials including oil, RCI Tm Leader:
Contractor
diesel, solvents, etc.)
Representative
Complaint (odor, noise, etc. ) received by
Team: EP Coordinator
external source (public or industrial
or Delivery leader,
neighbor) that is confirmed by plant
Contract Service
representative,
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Contractor
Investigations
(continued)
Contractor RCI
Trigger Criteria
Potentially
Serious Events
Trigger Point
Near miss potentially Recordable
Injury/illness:
An event that had significant
potential for serious personal
injury/illness had any of the
circumstances been different.
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 personnel
exposure exists
• Crane in contact with exposed
energized power line or process line
• Employee exposure to oxygendeficient or flammable (within
flammable 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 personnel
exposure exists
• Flying projectiles where potential for
personnel exposure exists
• Excavation shoring collapse
• Scaffold collapse
Life Critical Procedures violation
that could have resulted in a serious
injury or illness, such as:
• Confined space entry or Safe Work
Permit (SWP) job without proper
precautions specified or taken
• Unauthorized entry into a confined
space
• Locked-out/tagged-out equipment
found to be energized
• Hazardous energy source not lockedout/tagged-out once repair/alteration
work has started
Root Cause
Investigation Review
Team
Recommended:
RCI Tm Leader:
Contractor
Representative
Team: EHS Delivery
Tech or Delivery leader,
Contract Service
representative
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Investigation Checklist
Introduction
Each of the following items must be addressed prior to holding the investigation. This
will 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 start
with the completion of the crisis stamp.
•
Information that should be considered includes, but is not limited to operating
discipline in use at the time of the incident such as procedures, Pre-Task analysis
(STAC) cards, permits, pictures of the area, timelines, work orders, physical
evidence (This should be left as is – if this is in a safe position, until the RCI Team
Leader/Pre-Investigation Team can gather adequate information.)
•
Interviews with personnel involved in the incident should be preformed as soon as
practical.
•
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 the
incident.
WHAT
Give a brief written description of the incident including a diagnosis, any medical treatment, the
amount of material released or spilled, etc. This information is to be gathered, not to be copied and
handed 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 Contractor
EH&S
DIAGRAM
(A diagram is
required)
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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Investigation Checklist, cont.
STAC
(A STAC is
required)
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 WORK
PERMIT
Was a safe work permit issued for the job?
If yes, obtain a copy of the permit from the permit issuer.
Does this apply?
YES or NO
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.
WITNESS
STATEMENTS
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)
INJURY
INCIDENTS
Did the incident involve an injury?
If yes, obtain copies of medical reports of the initial treatment including the diagnosis and treatment
given.
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 or
equipment/tool drawings.
Obtain copies of owner's/user's manuals and maintenance records.
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Investigation Checklist, cont.
Does this apply?
YES or NO
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.
WRITTEN
PROCEDURES
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 Vehicle
Accident
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?
Facilitator
Who will facilitate the investigation?
Has the facilitator been trained?
Training
Provide verification of training that is relative to the incident.
If so, when?
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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
1
2
Action
The following individuals, if applies, may be invited to a Contractor Root
Cause Investigation:
•
DOW Owner Representative (this may be the DDC rep, a DOW
Maintenance rep, or contract administrator)
•
DOW Representative from the business (this may be a
representative from the business or the DOW Production
Leader)
•
DOW Contractor EH&S and/or business aligned EH&S
Delivery
•
Contractor Management
In the event of a Recordable Injury invite all individuals identified above
plus the following:
•
Contractor EH&S Delivery Leader
•
Contract Administrator/Job Representative
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Set Up for Root Cause Investigation (RCI)
Introduction
The following should be considered when setting up to do the RCI.
Item
1
Action
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 the meeting.
• The meeting should generally last 1 hour. This can be done if the
appropriate pre-work has been accomplished. It should be noted
that the investigation meeting for some incidents may be more
extensive and time consuming.
• The team lead will keep the number of meeting attendees to a
minimum, as appropriate to the incident. A team make-up of 5-7
people is optimum.
• Each team member should support the team lead in determining
corrective actions that (1) are within your control, (2) prevent
recurrence, (3) do not create a 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 RCI meeting 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 takes place before the formal Root Cause investigation
meeting.
• Schedules and communicates the pre-work data collection sessions
and the Root 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 RCI facilitator when independent facilitation is necessary.
• Communicates and documents root cause investigation summary and
corrective actions. (Final Incident Report with RCI documentation)
• Communicates with action items owners that they have action items
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Set Up for Root Cause Investigation (RCI), cont.
Introduction
(continued)
Item
3
4
Action
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.
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; make sure the post it is big enough for everyone to see what
is written on them.
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Facilitator Skills
Introduction
The following are skills to consider when conducting the RCI.
Item
1
2
3
4
Description
Introduction of all investigation team members - Explain each person's
contribution
Opening remarks - The facilitator explains the agenda that will be
followed and states that the purpose of the meeting is to identify action
items that will prevent recurrence and NOT PLACE BLAME.
Selection of a person to take minutes - If not the facilitator, someone must
be appointed to record investigation findings
Description 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
before moving on.
5
6
7
Present preliminary Cause and Effect Chart – team will review and
finalize
Determination of the root cause - Determine all Root Causes after
utilizing cause and effect process.
Defining and delegating Corrective Actions - Determination of
recommendations to prevent recurrence by controlling or eliminating the
immediate causes and root causes.
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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Conducting the Investigation
Introduction
These steps should be followed during the Root Cause Investigation. These steps will
allow 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 at bottom 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 the timeline
• 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
to termination.
• Identify and reach agreement on root cause. Ask if root cause
removed would it have prevented this incident. Is the root cause
identified something the contractor firm has control over? Vote on
root cause if more than one is identified.
• List corrective actions for contractors only.
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Conducting the Investigation, cont.
Introduction
(continued)
Step
8
Action
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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Post Incident Procedure
Introduction
The following steps should be followed after the Root Cause Investigation.
Step
1
Action
After the Root Cause investigation:
•
A final written report must be turned in to your DOW Job
Representative and to 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 reportable
injury/illness at next Site Leadership Team meeting and monthly Contractor
meeting
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Contractor Owner Incident Reviews (SLT)
Introduction
This policy covers the requirement of all Contractor Owners to review OSHA
Recordable injuries as well as those Near Misses and LOPC’s as identified, with the
Site 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 Recordable
Injuries as well as those Near Misses and LOPC’s as identified, when they occur on
the Site. This policy identifies the trigger for these reviews, the process for the review
and what will be reviewed.
All Contractors, as part of their responsibility to work on the Site will abide by this
Policy
Triggers
Any time an injury occurs that results in an individual receiving Medical Treatment,
Work Restrictions or Time Off Work (OSHA Recordables) the OSHA Review
Process will be triggered.
When a Near Miss or LOPC occurs that has significant Contractor involvement. This
will be decided by a review of the event by the SLT.
*Exception: An OSHA Recordable that occurs where the Contractor had no
involvement other than being in the area, i.e. a release resulting in exposure.
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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 them that a review will be scheduled.
2
The review will normally last between 15 min. to ½ hour. The Owner will
prepare the following information for the review:
•
Root Cause Investigation summary (Cause & Effect chart, etc.
depending on the RCI tool used).
•
System failures associated with this incident both Contractor and
DOW. Acceptance of arm chair permit, not checking into control
room, not wearing safety equipment, etc.
Company safety Program and their performance on site and
company wide
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 the meeting with the SLT.
4
The Contractor Owner will be asked to record any action items from the
meeting and communicate the result of those items to the Contractor job
representative on a monthly basis until complete.
5
Appropriate documentation will be retained for use during the contractor
performance review.
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Post Incident STAC Review Policy
Purpose
To identify how contractor supervision and management could have personally kept
the incident from happening and to enhance the ability of Contractor supervision to
train their employees in the identification of hazards and methods of controlling or
eliminating hazards identified.
Scope
This applies to all contractor foremen and superintendents that have an
O.S.H.A. Recordable injury or is responsible for an Environmental incident resulting
in a Reportable Quantity on their job.
Policy
Any time a Contract employee suffers an O.S.H.A. Recordable injury or is
responsible for an Environmental incident resulting in a Reportable Quantity, the
Contractor foreman and superintendent of the job where the incident occurred will
review a completed STAC with Contractor Safety.
Steps
Follow the steps identified below.
Step
1
Action
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
Methods to Eliminate or Control the Hazards that could have prevented the
incident.
3
Both the Contractor foreman and the superintendent will attend the
meeting and review 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
Contract Employee Name:
Report Date:
Contractor Company:
Unsafe Condition
Supervisor/Foreman:
Accident/Incident
[Check if MVA
]
Spill
Injury/Illness
Describe Unsafe Condition, Accident, Incident, Injury or Illness in detail. (Include property
damage estimate if appropriate) (Include specific location if unsafe condition).
DAWC
FA
(Enter # days)
RWC
PREC
RMTC
LER
Medical Treatment Yes
PREVENTIVE/CORRECTIVE MEASURES
Person(s) Responsible
No
Completion
Date
ACCIDENT, INCIDENT, INJURY OR ILLNESS
Employee Address:
Preliminary Report
Date Employee Attended Contractor Safety Orientation:
Incident Time:
Date of Birth:
Time Reported to Work:
Incident Date:
Age:
Incident Location:
Company Address:
Job Title/Craft:
General Contractor:
Sub:
Final Report
Yrs. Craft:
Yrs. Srvc:
Contractor Superintendent:
Medical Facility:
Physician:
Type Restrictions:
Witness(s):
Was a pre-job hazard analysis performed and is it documented?
(Retain for Investigation)
Yes
No
INJURY/ILLNESS ONLY
(See Code Numbers Next Page)
Contractor
Sub Type:
Root Cause(s) (Why):
Nature of
Inj/Ill:
Affected Body
Parts:
Contractor Rep:
Signature
Type of
Contact:
Safety Factor(s)
Involved:
Bldg./Phone:
Job Rep assigned to Contract Company:
Bldg./Phone:
Investigation Attendance:
Please forward copy of form to DOW Contractor EH&S at
TCO - Fax # 409-948-5339 Email: [email protected]
CLO – Fax #
HOU – Fax #
Email:
Do not forward person information to other parties.
Email:
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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 a first aid classification.
•
Preventive or Corrective Actions: List measures taken/ to be taken that will prevent recurrence of the incident. Identify person(s)
responsible and specify target 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 CODES
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
Contractor Subtype
Construction/Demolition
Information Systems
Logistics
Maintenance
Operations
Remediation
Research
Service/Administration
Other
Nature of Injury
Acoustic/Ear Trauma
Amputation
Bruise/Contusion
Chemical Burn 1st Degree
Chemical Burn 2nd Degree
Chemical Burn 3rd Degree
Chemical Exposure
Chipped, Broken, Lost Tooth
Concussion
Contaminated Needle Stick
Crushed Body Part
Cut/Abrasion/Puncture
Death
Dislocation of Joint
Electrical Burn
Electric Shock
Foreign Body
Fracture
Hernia
Herniated Disc
Infection
Insect/Animal Bite
Internal Injury
Loss of Consciousness
Musculoskeletal Pain
Poisoning (one exposure)
Precautionary Visit
Skin Rash
Sprain/Strain
Thermal Burn 1st Degree
Thermal Burn 2nd Degree
Thermal Burn 3rd Degree
Torn Ligaments/Muscle
Nature of Illness
Hearing Loss / Noise
Musculoskeletal Disorders (MSD
illnesses)
Occupational Skin Diseases or
Disorders
Poisoning (Systemic Effects of
Toxic Materials)
Respiratory Condition Due to
Toxic Agents
All Other Occupational Illnesses
Type of Contact
Allergen
Asbestos
Awkward Posture
Bite/Sting/Scratch
Caught In/On/Between
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
Chemical Contact - Body / Eye/
Ingestion/ splash/ injection
Chemical Contact - Inhalation
Contact w/Biological/Viral Agent
Contact w/Body Fluid
Contact w/Sharp Surface
Electricity - Arc Flash
Electricity - Current
Explosion
Fall – Elevated Work
Fall – Not Elevated Work
Forceful
Exertion/Overexertion
Hot Material/Surface
Mechanical Irritation
Motor Vehicle Accident
Noise
Particle or Sliver
Radiation
Repetitive Motion
Slip/Trip/Misstep/Stumble
Stress/Psychological
Struck Against
Struck By
Sunburn
Temperature, Extreme (Hot
or Cold)
Welding Light
Affected Body Part(s)
Abdomen
Ankle - Left
Ankle - Right
Arm - Left
Arm - Right
Back
Chest/Ribs
Ear - Left
Ear - Right
Elbow – Left
Elbow - Right
Eye - Left
Eye - Right
Face
Finger - Left; Digit 1
Finger - Right; Digit 1
Foot - Left
Foot - Right
Forearm – Left
Forearm - Right
Hand - Left
Hand - Right
Head
Hip - Left
117
118
119
120
121
122
123
124
125
126
127
128
129
130
131
132
133
134
135
136
137
138
139
140
141
142
143
144
145
146
147
148
149
150
151
152
153
154
155
156
157
158
159
160
161
162
163
164
165
166
167
168
169
170
171
172
173
174
175
176
Hip - Right
Internal Organ - Heart
Internal Organ - Kidney
Internal Organ - Liver
Internal Organ - Lungs
Internal Organ - Other
Knee - Left
Knee - Right
Leg - Left
Leg - Right
Mouth
Multiple
Neck
Nose
Scalp
Shoulder - Left
Shoulder - Right
Teeth
Thigh - Left
Thigh - Right
Toe - Left; Digit 1
Toe - Left; Digit 2
Toe - Left; Digit 3
Toe - Left; Digit 4
Toe - Left; Digit 5
Toe - Right; Digit 1
Wrist - Left
Wrist - Right
Safety Factors Involved
Condition of Equipment/Walking
Surface
Failure to Use Available PPE
Housekeeping
Illumination
Improper Tool or Equipment
Improper Use of Tool or Equipment
Improper Use of Protective Equip.
Inadequate Equipment Design
Inadequate Communications
Inadequate hazard identification
Inadequate hazard controls
Inadequate Instruction, Logic
Inadequate Job Planning
Inattention
Inattention to Footing or
Surroundings
Improperly Guarded
Permit violation
Poor Work Practice
Procedure Not Followed
Safety Rule/Standard Violation
Taking Unsafe Position or Posture
Teamwork Breakdown
Ventilation
Weather/Ice
Other
None
Page 168 of 197
Bay Area Operations
Table of Contents
Dow Smoking Policy
Policy
The Bay Area sites have adopted the Dow Corporate Smoking Policy.
This policy bans all smoking on Dow property, to include all parking areas and gates.
Hazard and
Precaution
This new policy has created other issues such as people congregating outside the
perimeter fencing to smoke. The guidance that is being given to Dow employees is
that they are not allowed to congregate in an area that creates an unsafe situation or
creates a nuisance. It is our belief that having your employees standing or parking on
the shoulders of the road to smoke creates an unsafe situation for them and causes
passing traffic to be distracted. It also impedes other vehicles from having a clear
line 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 not
explicitly provide for rest break as a part of the contract. Site management allows for
any worker to take rest breaks as needed as long as that break is taken at the work
area and is limited to 10 to 15 minutes max.
Leaving the work-site and driving outside the plant does not meet the above
guidelines and thus would not be reimbursable time.
Page 169 of 197
Bay Area Operations
Table of Contents
Glove Use Policy
Statement of Policy Gloves must be worn while performing hands on work unless the wearing of the
glove 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 of
gloves by Maintenance, Engineering and Contractors working on Dow sites.
Purpose
Communicate the high incidents of hand related injuries and mitigate the hazard by
identifying those jobs that would normally require the use of gloves and identify the
required glove to be used for those specific hazards.
Responsibilities
Contractor management is responsible for providing the appropriate gloves for use of
their employees.
Exclusions
Where jobs are identified that pose a higher risk from using gloves and are not listed
on the common exemptions list, these tasks must be identified on the Pre-Task
Analysis specifically and submitted for addition to the list.
Examples of activities during which glove use is not normally advised due to the
possible increase in hazard are:
Determining Type
of Glove to Use
•
Working with high torque rotating equipment while in operation
(does not include hand held power tools that may also rotate, such as
side 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.
Specific gloves appropriate to the job hazard may be required for certain high-risk
jobs. If the type of glove is not specified in the job procedure, leather gloves are
preferred. Cotton gloves however may be worn for low hazard jobs or jobs where
they may be covered with oil, grease, or paint and be discarded immediately after use.
Page 170 of 197
Bay Area Operations
Table of Contents
Glove Use Policy, cont.
Job/Hazards/Glove Table
•
Hazard
Cuts/Bumps/Pinches
•
•
•
Pinches/Sharp Edges
Extremely Sharp Edges
•
•
•
Burns/Sharp Edges/Heat
Flames
High Vibration
•
•
Welding/Oxy Acetylene
Cutting
Jack Hammer/Impact Type
Equipment
Boiler/Pipe Shop
•
•
•
•
•
•
•
Carpenters
FRP
Scaffold Builder
Insulators
Knives
Chemicals
•
•
•
•
•
•
Burns/Sharp Edges/Heat
Flames
Pinches/Cuts/Bumps
Cuts/Bumps/Solvent
Wood Slivers/Pinches
Dust/Dirt
Sharp Edges
Chemical Hazards
•
Masonry
•
Cement Exposure
•
•
•
•
•
•
Job Type
General Purpose/Everyday
Use
Rigging
Sheet Metal
•
•
•
•
•
•
•
•
•
Glove Type
Leather or Vinyl
Impregnated
Leather
Kevlar Gloves and
Kevlar Sleeves
Welder Gloves
Padded or Shock
Absorbing
Hot Mill Gloves or
Welder Gloves
Leather
Kevlar/Leather/Rubber
Cotton or Leather
Cotton or Leather
See Dow Knife Policy
Chemical Resistant
Specified in Department
PPE Program
Rubber lined
Page 171 of 197
Bay Area Operations
Table of Contents
Glove Use Policy, cont.
Performance Grid for Standard Work Gloves
Cotton 8 oz. Canvas
Cotton 10 oz Plastic
Dot Cotton
10 oz. Cotton Flannel
General Duty,
Highly Abrasive ,
Rough
(Carrying
Objects, Chips
Masonry)
Sparks
E
F
Extremely
Sharp Edges,
Glass, Sheet
Metal, Knife
Blades
P
Chemical
Hazard (See
High Vibration Low Hazard
Chemical
(To Keep
(Jack Hammer,
Heat and Flame
(Welding, Cutting) Impact Wrench) Hands Clean) Resistance List)
P
P
E
P
E
F
P
P
P
E
P
E
F
P
P
P
E
P
E
F
P
P
P
E
P
E
F
P
F
P
E
P
Reversible String
Knit
Medium Weight
Reversible String
Knit
Heavy Weight
Reversible String
Knit
Hot Mill 24 oz.
E
E
P
F
P
E
P
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 Leather
Palm Work Glove
Starched Safety Cuff
Leather Palm Work
Glove
Rubberized Safety
Cuff Leather Palm
Work Glove
Double Palm Work
Glove
Plywood Puller’s
Glove
Drivers Glove
E
E
F
F
F
E
P
E
E
F
F
F
E
P
E
E
F
F
F
E
P
E
E
F
F
F
E
P
E
E
F
F
F
E
P
E
E
F
P
F
E
P
Welding glove
F
F
F
E
P
E
P
Vinyl Impregnated
Work 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 the
Correct Glove.
These Ratings are simply a guideline and by no means are the final deciding factor in the selection of the right glove
for the right job.
Page 172 of 197
Bay Area Operations
Table of Contents
Personal Injury Prevention: Cutting Tasks
Objective/Policy
The use of open blade knives (personal property or Dow-provided) is prohibited
on site at DOW Bay Area 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 EMT
scissors pictured below in the “Alternative Cutting Tools” section
3. Develop local procedures that define the correct tool for cutting tasks as
well as any PPE required
4. Authorize variances for knife use only if a safer alternative tool cannot be
found. If a knife variance is authorized, the task procedure must require
the use of cut-resistant (Kevlar) gloves.
5. This policy does not pertain to the use of knives as eating utensils in
designated kitchen/break rooms.
Scope
For DOW, this policy covers the prevention of personal injury while performing
cutting tasks.
This policy supplements the Policy and Requirements in section 6.05 Employee
Health and Safety of Dow’s Operating Discipline Management System, ODMS.
Purpose and
Expectations
The purpose of this policy is to reduce the safety risk involved in performing cutting
tasks.
This policy applies to all personnel in DOW and well as Contractor employees
working within this facility.
Mandatory
Requirements
Elimination of open blade knives use as described above unless specifically
authorized by a local variance.
Suggested process for development of a local variance:
1. Demonstration that alternative (inherently safe) cutting tools are not
practical
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
Page 173 of 197
Bay Area Operations
Table of Contents
Personal Injury Prevention: Cutting Tasks, cont.
Recommended
Practices
Proactive elimination of the need for cutting tasks to eliminate the root cause of the
hazard. Examples include:
1. Use of zippered bags for raw materials which can be opened without a
cutting tool
2. Purchase of pre-cut gaskets
A variance allowing knife use will only be authorized using the site Variance
Procedure and must :
1. Demonstrate that alternative (inherently safe) cutting tools are not
practical
2. Develop a procedure defining the specific tool and its intended use.
Alternative
Cutting 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 an inherently 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 blade design
Available from: Sears (Craftsman)
Model: 37300
PHONE: (800) 549-4505 EMAIL: sears.com
Cable Preparation Tool that is compact and lightweight,
capable of stripping insulation on cable 19-40 mm diameter.
Available from: Ripley Company
Model No. RCS-158
EMAIL: www.ripley-tools.com
Approximate Cost = $36.00
Page 174 of 197
Bay Area Operations
Table of Contents
Alternative
Cutting 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 Resistant
Glove
The following is an example of the “Kevlar” Cut Resistant glove required when a
variance 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
Page 175 of 197
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Table of Contents
Roles and
Responsibilities
The following is a list of the roles and responsibilities associated with this policy:
Role
Definitions
Title and/or Responsibility
Production Leader or
Maintenance Process Leader
Implement cut prevention policy in all plants and
maintenance facilities, evaluate and approve variances
if necessary
EH&S Delivery Techs and
Maintenance Safety
Coordinator
Support implementation by informing any affected
parties outside the manufacturing organization of the
policy requirements, provide input on policy content
All DOW Employees
Provide input on new ways to avoid knife use and
improve defined knife alternatives
EH&S Responsible Care
Leader
Update the policy as new alternatives are found
The following is a list of definitions:
Term
Open blade knife
Definition
The general category of open blade knives includes, but is not
limited to the following list 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 to unavailability 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 to be used only for the job for which it
is specifically written. Exposed blade length is limited to 4” or
less.
Page 176 of 197
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Table of Contents
Definitions
(continued)
Term
Exempt Cutting
Tools
Definition
The general category of specialty tools that may have
unguarded blades by design, but are 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 cut resistant gloves and are to be used only for
the job for which it is specifically designed.
Other acceptable
cutting 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
Page 177 of 197
Bay Area Operations
Table of Contents
Man-Hours Collection
Purpose:
The purpose of this process is to outline the collection of on-site Man-hours each
month for contractor companies that are working at the TEXAS CITY PLANT.
Expectation:
The expectation is that ALL companies will have their monthly man-hours turned
into:
For Maintenance Contractors –
Contract Services either by email or faxed by the third (3rd) working day
of the month.
For DDC Contractors –
Owner Representative by the third (3rd) working day of the month.
Collection:
For Maintenance Contractors TCO/CLO: Man-hours can be emailed to Anna Johnson @
[email protected] or sent via fax to 409-948-5748 on the form
provided. See attachment.
DHH – Email:
Fax #
HOU – Email:
Fax #
For DDC Contractors –
Owner Representative will direct each project on collection of manhours.
Consequences:
Non-compliance by the third (3rd) working day of the following month will result in a
violation letter being sent to the company. The company receiving the violation letter
will have five (5) working days to respond with their plan to resolve the late reporting
of Man-hours. After two violations letters a QSPP will be filled out on the company.
Page 178 of 197
Bay Area Operations
Table of Contents
MONTHLY MAN-HOURS
COMPANY NAME:
DATE:
MONTH/YEAR
MAN-HOURS
STAC Average
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.
TCO/CLO: Submit Form To: Anna Johnson at email [email protected] by fax (409-948-5748).
DHH – Email:
Fax #
HOU – Email:
Fax #
*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.
Page 179 of 197
Bay Area Operations
Table of Contents
DOW Health Services Guideline for Non Dow Service Providers
Introduction
The following is guidance provided to site Leadership to assist in the
implementation of the EH&S Standard “06.06.00 Non Dow services on Dow
Property Standard.
Contractors Included
This is intended for contractors employed for construction, maintenance, service or
administration. As decisions are made about what services are provided based on
these guidelines, particular consideration should be given to the following
contractors:
•
Contractors who must be provided our services based on regulatory or
contractual requirements
•
Contractors working for extended periods (e.g. > 1 year) full time at Dow
sites
•
Contractors with job responsibilities that are very similar or overlap
company employees on the site
•
Contractors with greater potential for exposure to chemical or physical
hazards
•
Dow Joint Venture employees (by contractual agreement)
DOW Requirements
The responsibility for contractor employee health belongs to the Contractor
Employer. DOW requirements must be followed as presented in the Dow EH&S
Standard “06.06.00 Non Dow services on Dow Property Standard.
Services that will be
offered by DOW
Health Services to
Non Dow Services
Providers and
Visitors
1. Clinical Care Services:
•
Emergency First Aid
•
Treatment for work related chemical exposures during business hours
•
Assessment and referral for all other work related injuries/illnesses as
requested by Non Dow Services employees/management
•
Limited non-occupational personal care (e.g. blood pressure monitoring,
over-the-counter medication, limited health issue consultation)
2. Health Promotion Services:
•
Contingent Staff will be included in Health Promotion Programming when
possible and may include Incentive Programs, Education and Workshops,
One on one and Group consulting
3. Business Support (consultation on health related issues) – by request
4. Epidemiology services - by request
Page 180 of 197
Bay Area Operations
Table of Contents
DOW Health Services Guideline for Non Dow Service Providers, cont.
How Our Service
Will Be Provided
to Non Dow
Service Providers,
if DOW Health
Services is to be
the Provider
For Any Health Service Provided:
•
The same standard and quality of services will be provided as for DOW
employees. While the same range of services may not be provided to
contractor employees as for DOW employees, when a service is provided we
will have only one level of quality and one standard of practice.
•
Standards for confidentiality will be applied.
•
Medical Records will be managed by Health Services Dept.
•
There must be a contractor employer contact identified for the Health
Services Department to work with.
•
Health Services will provide service only with regard to the contractor
employee’s work that is related to the applicable contract. For example, if
work related injury/illness care is provided to contractor employees, we
would not provide such services for injuries or illness that arise from work
done for another company.
For Clinical Care Services
•
Adequate exposure assessment information must be available to the
contractor employees.
•
Health Services will not bill for Clinical Care Services.
For Health Promotion Services
•
Appropriate baseline/pre-participation screening or releases will be required.
•
A fee will be charged participants for most programs.
For Business Consultation or Epidemiology Services
•
A contract will be required which will include a billing/invoice mechanism.
Page 181 of 197
Bay Area Operations
Table of Contents
Basic Pollution Prevention
Basic Pollution
Prevention Rules
Rule
1
Description
Transportation of materials:
•
All materials shipped out of the location meets all governmental,
and site environmental regulations and policies.
•
Movement/transportation of all materials for off-site disposal,
recycle and/or fuel blending are approved by plant personnel.
2
Each water material is appropriately classified and managed as prescribed in
the site Environmental Protection Policy requirements.
3
Handling & Prevention of Spills & Releases:
•
Before beginning any work, individuals give consideration to how a
spill or release may occur, how it can be avoided, and how to
respond to a spill or release should it occur.
•
Spills and releases to the environment are reported immediately to
supervisor and host.
•
Spilled material is contained. Spilled materials and contaminated
soils are cleaned up.
Note: Deliberate or intentional unauthorized discharges and releases to the
environment are prohibited (ex. cleaning tools in site ditches).
4
Consideration and Reporting of Contaminations:
•
Planning of excavations includes considerations of whether waste or
contaminations may be encountered and plans for disposal.
•
Any discovered evidence of soil, ground or surface water
contamination is immediately reported to the responsible plant
personnel.
5
All emission control devices are to be operated within the limitations
imposed by plant management.
6
Hazardous and non-hazardous wastes should be segregated. Exceptions
may require that the mixture be treated as a hazardous waste.
7
Adverse impact upon the environment is a dominant factor in the decision to
continue to operate or shut down and repair equipment.
8
All individuals are to have a practical knowledge of the potential
environmental impact of their work.
9
All work should avoid and/or minimize the generation of wastes.
Page 182 of 197
Bay Area Operations
Table of Contents
Basic Pollution Prevention, cont.
Pollution
Prevention
Activities
Pollution Prevention Activities during Maintenance and Construction:
Item
1
2
3
4
Description
Inspection of equipment:
•
Perform pre-use inspections of cranes, forklifts, and JLG’s for
leaks.
•
Inspect equipment based on preventative maintenance inspection
schedule and replace hoses as needed.
•
Repair leaks on equipment before use.
•
Report any spills or leaks
Use of Drip Pans:
•
Ensure compressors, generators, etc. have drip pans under them.
•
Make sure there are pans under all Oil and Waste drums.
Handling and Disposal of Oil:
•
Do not leave buckets of oil lying around. Dispose of properly and
have vacuum truck empty full drums.
•
Let No Oil Touch the Ground
Be aware of labels on drums and roll-off boxes before depositing material.
Check labels before dumping
•
Material mix-ups can cause wasted time and money for disposal, or
possibly fines 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 be disposed of.
6
If you are unsure how to dispose of any material, call your Environmental
Coordinator for assistance.
Each plant has an Environmental Contact, check with your site contact.
Page 183 of 197
Bay Area Operations
Table of Contents
Contractor Spill Policy - Oil and Fuel
Statement of Policy It is the responsibility of each contractor company to manage, correct and pay for
cleanup and disposal of spilled Oil/Fuel materials originating from their equipment.
This includes stopping and containing the spill, notifying the correct personnel and
proper cleanup/disposal of all waste materials related to that spill.
Scope
The policy will address Contractor companies that have fuel/oil containing
equipment.
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
Preliminary
Requirements
•
Review the Plant and Departments Environmental
Emergency Response plans with all personnel.
•
Have a Company Environmental Emergency Response
plan, which will give direction 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 Response Plan and document training.
•
Dow approved spill kits are required; location and
availability will be approved by your Dow
Project/Maintenance contact.
Note: Consideration should be given when spotting equipment
to minimize the chance of oil/fuels spill contaminating any
water.
Stopping the Spill
Containing the
Spill
•
Shut down all equipment.
•
Stop all fluids from leaving equipment.
•
Stop all migration (movement) of spilled materials
using supplied spill kits.
•
Eliminate any movement toward water. This will help
to minimize environmental impact and as well as cleanup costs. If the spilled materials do go to water, diapers,
booms, and other equipment will be immediately
necessary to minimize the potential contamination.
Page 184 of 197
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Table of Contents
Contractor Spill Policy - Oil and Fuel, cont.
Responsibilities
(continued)
Item
Notification of
Spill
Cleanup/Disposal
Definition
•
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
Industrial Security/Emergency Services is contacted
giving them the same information listed above.
•
Contact all applicable Dow and contractor company
contacts, following the guidelines for notification in
Dow’s Environmental Emergency Response plans, and
the contractor company Environmental Emergency
response plan.
•
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 or equipment. 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 Dow project/Maintenance contact. Refer to
plant environmental operations packaging requirements.
•
Contractor assumes costs for the disposal of spilled
materials, contaminated soil, equipment, pads, and
disposal containers. This also includes costs associated
with transportation to disposal site (including pallets).
Page 185 of 197
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Table of Contents
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 and result in a loss of primary containment.
Equipment
Equipment that is owned/leased by the contractor company.
This includes, but is not limited to fork trucks, vehicles, cranes,
pumps, motors, etc.
Waste
Characterization
Process for determining the characteristics of the waste, where
the waste will be disposed of and how.
Locations or processes to dispose of materials.
Kiln
Burn/Landfill
Bury/Waste
Water Treatment
Spill Kit
Booms, diapers, absorbents, and collecting containers.
Dow Project/
Maintenance
Contact
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.
Page 186 of 197
Bay Area Operations
Table of Contents
Loading and Unloading Pipe or Steel Policy
Statement of Policy
Personnel must not stand on the trailer or truck when material/equipment is
being loaded/unloaded.
Scope
This policy is in effect during the loading or unloading of material/equipment
operation.
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 or
steel is being lifted.
Responsibility
Contractor management is responsible to see that this policy is to be
communicated to all persons required to perform this type work.
Steps
Action
1
If the truck to be loaded does not come equipped with ladders
permanently attached to the side at the front and rear of the truck, then
stepladders will have to be obtained and tied off to the sides of the
trailer of flatbed. The stepladders will 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 and rig up the piece of pipe of steel. An additional person will
be the flagman on the ground and his duty will be to set the boom point
to the center of gravity of the load. As soon as the pipe or steel is
rigged up, the person (s) on the bed of the truck will descend the
ladders and remain on the ground until the load is lifted and 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 to the truck, and then the worker(s) will climb onto the truck and
remove the chokers or slings. The boom point must still be set to the
center of gravity of the load 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 unloading
operations.
Page 187 of 197
Bay Area Operations
Table of Contents
Locking Fuel Nozzle Policy
Statement of Policy
Locking fuel nozzles will be removed or permanently disabled from all fueling
devices/equipment before entering any Dow facilities.
Scope
The policy will address Locking Fuel nozzle devices used for fueling equipment and
vehicles.
Purpose
To minimize the number of fuel spills.
Responsibilities
Contractor management is responsible for implementation of this policy on all fuel
loading 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 in the on position, and would not require
100% hands on operation of the nozzle while fueling.
All equipment that is used to fuel equipment/vehicles. This
Fueling
Devices/Equipment includes but is not limited to:
•
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 Companies working in Dow
facilities.
All fuel dispensing will be done with 100% hand control on the
filling devise. No trigger props or other methods to hold a fuel
dispensing handle open shall be used".
Page 188 of 197
Bay Area Operations
Table of Contents
Contractor Severe Violation Policy
Purpose
This policy was developed to address restrictions for contract company
employees (“contractors”) that commit violations of life critical safety or work
rules and/or programs while working on a “Dow Site”. “Dow Site” refers to a
Site 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 Contractor
Safety organizations at each Dow Site. (Freeport, Houston, Seadrift, Clear Lake,
Texas City)
Unsafe behaviors or violations associated with Environmental, Health, Safety or
Security rules, standards or programs can result in temporary or permanent
restriction of contractors from all Dow Sites.
Policy
Step
Training
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 any prior performance issues) and determine the length of
time the contractor will be restricted from the Dow Site.
4
Dow Site Contractor Safety will utilize this document to determine if
restrictions apply for life critical safety & work rule violations.
5
Each contractor company should have a disciplinary program that
holds its employees, supervision, and subcontractors accountable for
their actions.
6
A second violation of the Severe Incident Policy can result in
permanent restriction from all Dow Sites.
All Contractor companies must train their employees on this policy.
Page 189 of 197
Bay Area Operations
Table of Contents
Contractor Severe Violation Policy, Continued
Examples of
Severe Violations
Topics
Confined Space
Examples of Severe Violations
• 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 of the failure)
Controlled
Substance /
Alcohol / Etc.
• Working under the influence of drugs or alcohol (Positive test
as a result of a random 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 an
Unprotected Fall
Potential:
• Creating an unprotected opening or removing protection from
an opening where personnel could suffer a life critical fall
such as, but not limited to, removing grating, handrails,
piping/equipment, life critical barricades or creating an
excavation that is unprotected, etc...
Elevated Work
• Not being tied off 100% of the time when required
• Instructing others to not follow required procedures
Fighting /
Terroristic Act
• 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.
Page 190 of 197
Bay Area Operations
Table of Contents
Contractor Severe Violation Policy, cont.
Examples of
Severe Violations
(continued)
Topics
Personal
Protective
Equipment
Examples of Severe Violations
• 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 Permit resulting 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 a hazardous area; Line & Equipment
Opening with a potential exposure to hazardous 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.
Page 191 of 197
Bay Area Operations
Table of Contents
Task Force for Safety Success
Purpose
Task Force for Safety Success (“Task Force”) is a team effort that has proven to be a
successful, proactive tool used to assist contractor firms to improve their EH&S
performance on Dow sites.
Scope
Task Force was developed for contractor companies that have experienced
unfavorable EH&S performance. By definition, 3 to 4 contractor companies will be
on Task Force at any given time.
Background
Until the development of Task Force, there was no formal program in place to assist
contractor firms in improving there EH&S performance, prior to being suspended
from working at Dow.
Policy
Contractor companies that meet the trigger criteria listed below will be evaluated by
SMAT to determine if they should to be placed on Task Force. Dow Contractor
Safety will send a letter to the company notifying them that they are on Task Force
and schedule the first meeting. The Task Force team will be established and meet
monthly for a minimum of 6 months, at which time the team will determine the
frequency and duration of future meetings. The team will work together to ensure
that the requirements listed in the policy are met.
Topic
Trigger Criteria
Team Members
Description
•
OSHA Rate on Dow site is greater than 2 times the site
contractor OSHA recordable goal for the current year and
the company has had more than 1 OSHA for the year
•
Significant safety performance issues
•
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
Page 192 of 197
Bay Area Operations
Table of Contents
Task Force for Safety Success, cont.
Policy
(continued)
Topic
Requirements
Consequences
Training
Description
•
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
(Safety Alliance, Roundtable, CRCT)
•
Participation in Dow Contractor Foreman/Superintendent
Training
•
Review of any incidents and action items generated from
investigations
•
Review of any QSPP’s
Each of the elements listed above must be reviewed on a
monthly basis with a Team that will be identified when the
Company is put on Task Force. Noncompliance will result in
action up to and including suspension from any and all Dow
work.
Review policy at the first Task Force Meeting.
Page 193 of 197
Bay Area Operations
Table of Contents
Contractor Evaluation
Purpose
To evaluate the performance of Non-Dow Service Providers to determine continued
and future activities with a particular service provider. Visitors will not be evaluated,
but may be denied continued access to Dow sites if unacceptable behaviors are
demonstrated.
Independent NonDow Service
Providers
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 health program. The Periodic Assessment form
may be used for this activity.
2
An Evaluation Team will review the list of independent service providers at
least annually and request Periodic Assessments from the corresponding Job
Representative where assessment is needed.
3
The Evaluation Team will consist of the Contractor Administrator, SMAT
representative and the EH&S Contact as a minimum.
4
The Evaluation Team should conduct a Performance Evaluation based on
relative experience with the provider, the risk level of their work,
performance assessment, and performance record. The frequency of
Performance Evaluations should not exceed 3 years for continuing
Independent Service Providers.
5
The Performance Evaluation should analyze data, identify areas of
improvement or recognition and determine appropriate follow up.
Conclusions should be documented on the bottom portion of the Periodic
Assessment form.
6
For continuous improvement, the Evaluation Team and/or job reps may also
include any combination of the following:
•
Independent Non-Dow Service provider may perform their own
assessments, communicate their actions and follow up for
discussion with the Dow representatives.
•
Non-Dow Service provider meets minimum EH&S requirement,
contractor safety plan, and has an improvement plan.
•
Independent Non-Dow Service Provider may develop and use proactive measures of EH&S performance.
•
Utilize the Dow contractor performance improvement tool.
•
Provide recognition for superior EH&S performance.
Page 194 of 197
Bay Area Operations
Table of Contents
Contractor Evaluation, cont.
Independent NonDow Service
Providers
(continued)
Item
Description
7
An individual of an independent service provider should be removed from
the site if their behavior is determined to be unacceptable with moderate to
severe impact potential. 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
unacceptable behavior or repeated low to moderate unacceptable behavior.
Consideration should be given 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 given if adequate evidence of corrective action has been
demonstrated to the Contract Administrator/Job Representative and the
EH&S Contact.
Contingent Staff
Non-Dow Service
Providers
Item
Description
1
Contingent staff providers should be periodically evaluated against elements
of the safety and health program.
2
The Evaluation Team will review the list of contingent staff providers at
least annually and request Periodic Assessments from the corresponding Job
Representative where assessment is needed.
3
The Performance Evaluation should analyze data, identify areas of
improvement or recognition and determine appropriate follow up.
Conclusions should be documented on the bottom portion of the Periodic
Assessment form.
Page 195 of 197
Bay Area Operations
Table of Contents
PERIODIC ASSESSMENT OF NON-DOW* SERVICE PROVIDER
Instructions: The Job Rep is responsible to periodically assess each Non-Dow Service Provider by completing the top assessment
portion of this form. The Job Rep will keep the original and copy SMAT rep if requested. If applicable, the bottom evaluation is
completed 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.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
1
2
3
4
5
Leadership visible in the site (job audits, meets with employees).
1st line supervisor training for managing safety
What actions are being taken from analysis of Pre-task cards, Behavior
Based Observations/Interventions, Near Miss reports, RCI’s, Audits, Safety
Incident/Accident reports, Safety Suggestions, and Unsafe Condition
reports?
Compliance with all Pre-Access/Pre-Job/Safety Plan requirements
EHS/Craft/Skill training status of work group (DOW and company status)
Substance abuse testing metrics (include status on pre-access testing, annual
random test for every employee, reasonable cause testing, and post incident
testing) for.
Demonstrate adequate understanding of work scope/job procedures and
associated hazards including use of applicable EH&S standards (regulatory
and Dow).
Demonstrate use of personal protective equipment appropriately.
Use of contract company’s BOC policy and status of corrective action
Maintained work area housekeeping as expected.
Assured safety awareness via safety talks and training (pertinent to job).
Adequate understanding & execution of Contractor Admin Manual (Bay
Area) and Safety Rule Book.
Productivity metrics, Quality metrics, QSPPs, and corrective actions taken
DOW Contractor BOC status
All action items completed from previous contractor evaluation.
Corporate and DOW OSHA TRIR status / EMR status
PERFORMANCE EVALUATION BY EH&S/ADMINISTRATOR
New or Established NDS Provider
Exposure Hours
New
or
Established
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:
_____________________________________________________________________________________________
CONCLUSIONS
Y/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..
Page 196 of 197
Bay Area Operations
Table of Contents
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, contract
company 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 - # of
training/meetings and topics)
3.
What actions are being taken from analysis of Pre-task cards, Behavior Based Observations/Interventions, Near Miss
reports, RCI’s, Audits, Safety Incident/Accident reports, Safety Suggestions, and Unsafe Condition reports? (Status
of 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 at
DOW since last update. Trend analysis - what actions have the contract company done to address findings communicate status)
4.
Compliance with all Pre-Job requirements.
5.
EHS/Craft/Skill training status of work group (DOW and company status) – Status of Contract Company’s skill
training/qualification for employees working at DOW; have they completed any/all training and evaluation reqs and if
not what is left; can be simply displayed and don't have to use names. Turnover rate (new to site), foremen to worker
ratio, 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 of
applicable EH&S standards (regulatory and UCC/Dow). Metrics may also be included in #3
The contractor should
review 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 demonstrate
how their procedures are made available to their employees working at DOW. For example, it is 2AM Saturday
morning, how do their workers get the appropriate procedure for work at a UCC/Dow facility (their procedure that is
specifically written for the facility they are working in). Verify how we know that they have reviewed their procedures to
see 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 to
verify contract company use of consequences policy with employees and status of any actions taken
Status of Pre-Job - Any updates needed?
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 (for
evaluator - are they pertinent to the hazard of the tasks for this contract company)
12. Adequate understanding & execution of Contractor Admin Manual (Bay Area)) and Safety Rule Book. (completing
incident reports, RCI, reviewing Safety Rule Book with employees, incidents?)
13. Productivity metrics, Quality metrics, QSPPs, and corrective actions taken (review business/productivity related
metrics - 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 of
serious 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 safety
and productivity improvement and gain value for UCC/Dow dollars. Also gains understanding of contract firm capability for
UCC/Dow contractor management with potential to limit or expand work based on status.
Page 197 of 197

THE DOW CHEMICAL COMPANY* Bay Area Administrative Manual

Transcription

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