DOW - Alliance Annual Report - January 15, 2007

ALLIANCE ANNUAL REPORT
Occupational Safety and Health Administration
and
The Dow Chemical Company (Dow)
January 15, 2007

  1. Alliance Background

    Date Signed

    January 13, 2003

    Dates Renewed

    May 12, 2006, May 26, 2004

    Evaluation Period

    January 13, 2006 – January 12, 2007

    Overview

    The OSHA and Dow Alliance focuses on using OSHA's and Dow's collective expertise to further enhance a culture of prevention while sharing proven practices and technical knowledge in the areas of, but not limited to, process safety management (PSM) and ergonomics.

    Implementation Team Members

    OSHA:

    John Bugno
    Directorate of Standards and Guidance (DSG)
    Cathy Cronin
    Office of Training and Education
    Kevin Cummins
    Salt Lake Technical Center (SLTC)
    Lee Anne Jillings
    Office of Outreach Services and Alliances (OOSA)
    Todd Jordan
    SLTC
    Mike Marshall
    Directorate of Enforcement Programs (DEP)
    Lisa Ramber**
    OOSA
    Beth Sherfy*
    OOSA
    Rob Swick***
    OOSA

    Dow:

    John Dizor
    Personal Safety Expertise Leader
    Rick Holmes
    Industrial Hygiene Expertise Leader
    George King
    Process Safety Technical Leader
    Dale Louda
    Washington Office Advocacy Leader
    Tim Overton
    Chief Process Safety Engineer
    Victoria Rupp
    Director, Environmental Health and Safety Regulatory Affairs
    Jeannine Sohayda
    Environmental Health and Safety Public Affairs
    Mark Spence
    Manager, Health and Safety Regulatory Affairs

    * Beth Sherfy served as the Alliance Coordinator until November 1, 2006
    ** Lisa Ramber served as the Alliance Coordinator from November 1, 2006 to January 8, 2007
    *** Rob Swick as the Alliance Coordinator from January 8, 2007

  2. Implementation Team Meetings

    January 31, 2006
    Implementation Team Meeting, Teleconference
    May 1, 2006
    Implementation Team Meeting, Washington, DC
    May 12, 2006
    Implementation Team Meeting, Teleconference
    August 29, 2006
    Implementation Team Meeting, Teleconference
    October 26, 2006
    Alliance Program Hazard Communication Roundtable's Promoting the Globally Harmonized System for Classification and Labeling of Chemicals Workgroup Meeting, Washington, DC
    November 3, 2006
    Teleconference on Dow's PSM Program
    January 9, 2007
    Implementation Team Meeting, Teleconference

  3. Results

    1. Events and Products

      Outreach and Communication Goals

      • Work with OSHA to provide expertise in developing information on the recognition and prevention of workplace hazards, and to provide expertise in developing ways of communicating such information (e.g. print and electronic media, electronic assistance tools and OSHA's and Dow's Web sites) to employers and employees in the industry.

      Products

      OSHA Safety and Health Topics Pages

      Through the Alliance, Dow representatives provide their expertise to review, maintain and update many of OSHA's Safety and Health Topics pages. In particular, on each the following seven OSHA Safety and Health Topics pages, a member of Dow's staff serves on the page's editorial board:

      • Ammonia Refrigeration

        • Don Jones, PE, CSP, Plaquemine, LA

      • Chemical Reactivity Hazards

        • Kenan Stevick, Process Safety Technology Center, Midland, MI

      • Emergency Preparedness and Response

        • Susan Ripple, MS, CIH, Global industrial Hygiene Expertise Center, Midland, MI

      • Health Care Facilities

        • Susan Ripple, MS, CIH, Global industrial Hygiene Expertise Center, Midland, MI

      • Isocyanates
        • John Cikalo, Global Industrial Hygiene Expertise Center, Midland, MI

        • Mark Spence, Global Industrial Hygiene Expertise Center, Midland, MI

      • Motor Vehicle Safety

        • Andrew Lipkewycz, Emergency Services and Security Manager, Asia Pacific, Victoria, Australia

      • Process Safety Management

        • George King, Process Safety Technology Center, Freeport, TX

      Ammonia Refrigeration eTool

      By means of the Alliance, Dow representatives serve on the editorial board of OSHA's Ammonia Refrigeration eTool and offer their expertise to review, maintain and update eTool which is a product of the OSHA and The Dow Chemical Company Alliance:

      • Randy Estep, Houston, TX
      • Don Jones, Plaquemine, LA

      • Mark Spence, Midland, MI

      OSHA and Dow Alliance Web Page

      OSHA continues to update the OSHA and The Dow Chemical Company Alliance Web page on the Agency's Web site. The Web page features links to the Alliance agreements and related documents, information on activities and events, and milestones and successes. During the evaluation period, the Web page was updated to include information about the Alliance's renewal and the "Motor Carrier Safety Case Study: A Collaborative Approach to Reducing Motor Carrier Incidents," a product that was developed through the Alliance agreement.

      Print and Electronic Media

      Articles on the OSHA and Dow Alliance, products developed through it, and the agreement's renewal, have appeared in print and online publications, such as the Bureau of National Affairs Occupational Safety and Health Reporter. For more information on the articles, please see the Alliance Program Reach table.

      • Share information among OSHA personnel and industry safety and health professionals regarding Dow's best practices or effective approaches and publicize results through outreach by Dow and through OSHA- or Dow-developed materials, training programs, workshops, seminars, and lectures (or any other applicable forum).

      Events

      ORC Worldwide's Occupational Safety and Health Workgroup Meeting, Washington DC, August 10, 2006

      On August 10, 2006, Mark Spence, Manager, Health & Safety Regulatory Affairs, The Dow Chemical Company, gave an update on the OSHA and The Dow Chemical Company Alliance to ORC Worldwide's Occupational Safety and Health Workgroup.

      Automotive Industry Action Group (AIAG) meeting, Southfield, Michigan, October 18, 2006

      On October 18, 2006, Mark Spence, Manager, Health & Safety Regulatory Affairs, The Dow Chemical Company, gave a presentation regarding the OSHA and The Dow Chemical Company Alliance to AIAG's personnel at its office in Southfield, Michigan.

      • Work with other Alliance participants on specific issues and projects on ergonomics and PSM that are addressed and developed through the Alliance Program.

      Events

      Center for Chemical Process Safety (CCPS) Technical Steering Committee Meeting, Houston, Texas, January 13, 2006

      On January 13, 2006, the "Managing Chemical Reactivity Hazards: a Workshop for Non-Chemists" course was given in conjunction with the CCPS Technical Steering Committee Meeting. The Dow Chemical Company, helped to develop the workshop with the OSHA and Chemical Reactivity Hazards Management (CHRM) Alliance. The National Federation of Independent Business (NFIB), another Alliance Program participant, helped to promote the workshop. The course was designed for small chemical manufacturers, warehouse facilities, distributors and batch processors. It provided information on chemical reactivity hazards and strategies and tools for identifying and preventing reactivity accidents at manufacturing facilities.

      Promoting the National Dialogue on Workplace Safety and Health Goals

      • Develop and disseminate case studies illustrating the business value of safety and health and publicize their results.

      Products

      "Motor Carrier Safety Case Study: A Collaborative Approach to Reducing Motor Carrier Incidents"

      Through the Alliance Program, Dow worked with OSHA to develop a motor carrier case study, "Motor Carrier Safety Case Study: A Collaborative Approach to Reducing Motor Carrier Incidents" which was posted on OSHA's Web site in March 2006. The motor carrier safety case study describes how The Dow Chemical Company worked with one of its motor carriers, Transport Service Company (TSC), to successfully implement a new behavior-based safety program to reduce TSC's rear-end collisions. The case study has been added to a number of OSHA's Web pages, including the OSHA and The Dow Chemical Company Alliance page, Compliance Assistance page and Motor Vehicle Safety and Health Topics page.

      • Convene or participate in forums, round table discussions, or stakeholder meetings on ergonomics and PSM issues to help forge innovative solutions in the workplace or to provide input on safety and health issues.

      Events

      Alliance Program Hazard Communication Roundtable: Promoting the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) Workgroup, Washington, DC October 25, 2006

      On October 25, 2006, Mark Spence, Manager, Health & Safety Regulatory Affairs, The Dow Chemical Company, participated in the Alliance Program Hazardous Communication Roundtable's Promoting the GHS Workgroup meeting. In support of OSHA's plans to adopt the GHS as part of its Hazard Communication Standard, the Workgroup identified the need for several compliance assistance products to explain the benefits of the GHS and why OSHA is adopting it, including a frequently asked questions (FAQ) document providing a basic explanation of the GHS' provisions, a side-by-side comparison of OSHA's existing hazard communication standard (HCS) and the GHS, and examples comparing labels and material safety data sheets prepared under OSHA's current standard with some prepared folllowing the GHS.

    2. Executive Summary

      During the 2006-2007 evaluation period, OSHA and Dow worked together to further enhance a culture of prevention while sharing proven practices and technical knowledge in the areas of, but not limited to, PSM and ergonomics. Through the Alliance Program, OSHA and The Dow Chemical Company developed several compliance assistance resources and promoted the OSHA and The Dow Chemical Company Alliance. For example, the OSHA and Dow Web page on the Agency's Web site provides links to the Alliance agreements, related documents, activities and events, and milestones and successes. In addition, representatives from Dow serve as members of a number of OSHA's Safety and Health Topics pages editorial boards, including Ammonia Refrigeration, Chemical Reactivity, and Process Safety Management. Dow representatives also are members of the editorial board for OSHA's Ammonia Refrigeration eTool which is a product of the Alliance.

      As part of the OSHA and The Dow Chemical Company Alliance's outreach efforts, Mark Spence, Manager, Health & Safety Regulatory Affairs, The Dow Chemical Company, gave an update on the OSHA and The Dow Chemical Company Alliance to ORC Worldwide's Occupational Safety and Health Workgroup on August 16, 2006 in Washington, DC. He also gave a presentation regarding the OSHA and The Dow Chemical Company Alliance to AIAG personnel at AIAG's office on October 18, 2006 in Southfield, MI.

      The OSHA and The Dow Chemical Company Alliance also developed a motor carrier case study, "Motor Carrier Safety Case Study: A Collaborative Approach to Reducing Motor Carrier Incidents" which was posted on OSHA's Web site in March 2006. The motor carrier safety case study describes how Dow worked with one of its motor carriers, Transport Service Company (TSC), to successfully implement a new behavior-based safety program to reduce TSC's rear-end collisions. The case study was added to a number of pages on OSHA's Web site, including the OSHA and The Dow Chemical Company Alliance page, Compliance Assistance web page and Motor Vehicle Safety and Health Topics web page.

      On October 25, 2006, Mark Spence, Manager, Health & Safety Regulatory Affairs, The Dow Chemical Company, represented Dow at the Alliance Program Hazard Communication Roundtable's Promoting the GHS Workgroup meeting. In support OSHA's plans to adopt the GHS as part of its Hazard Communication Standard, the Workgroup identified the need for several compliance assistance products to explain the benefits of the GHS and why OSHA is considering adopting it.

    3. Alliance Program Reach

      Type of Activity (Conference, Training, Print and Electronic Distribution, etc.) Number of Individuals Reached or Trained
      OSHA and The Dow Chemical Company Web page on OSHA's Web site 6,347
      OSHA Ammonia Refrigeration
      Safety and Health Topics page      		 24,289
      OSHA Chemical Reactivity Hazards
      Safety and Health Topics page      		 22,447
      OSHA Emergency Preparedness and Response
      Safety and Health Topics page      		 112,295
      OSHA Health Care Facilities
      Safety and Health Topics page      		 47,949
      OSHA Isocyanates
      Safety and Health Topics page      		 24,265
      OSHA Motor Vehicle Safety
      Safety and Health Topics page      		 23,252
      OSHA Process Safety Management
      Safety and Health Topics page      		 30,302
      OSHA's Ammonia Refrigeration eTool 20,518
      OSHA Motor Carrier Safety Case Study 7,863
      OSHA Motor Vehicle Accident Case Study 8,410
      OSHA Ergonomics Case Study 5,317
      August 16, 2006: ORC Worldwide's Occupational Safety and Health Workgroup, Washington, DC, "OSHA and Dow Alliance Update"

      Speaker: Mark Spence, Manager, Health & Safety Regulatory Affairs, The Dow Chemical Company      		 50
      October 18, 2006: Automotive Industry Action Group (AIAG) meeting, Southfield, Michigan, "OSHA and Dow Alliance Update"

      Speaker: Mark Spence, Manager, Health & Safety Regulatory Affairs, The Dow Chemical Company      		 20
      March 30, 2006: "OSHA Alliance with Dow Leads to Case Studies on Motor Vehicle Safety"
      OSHA New Release      		 69 News Services
      April 3, 2006: "OSHA Publishes Case Studies on Motor Vehicle Safety"
      Business and Legal Reports      		 Data Not Available
      April 4, 2006: "New Case Studies Focus on Motor Vehicle Safety"
      News for OSC      		 Data Not Available
      April 13, 2006: "OSHA/Dow Alliance Case Study Tests Motor Vehicle Accident Reduction"
      BNA Occupational Safety and Health Reporter      		 Data Not Available
      April 2006 "OSHA Alliance with Dow Lead to Case Studies on Motor Vehicle Safety"
      Risk Control Issues NewsBrief      		 Data Not Available
      May 12, 2006: "OSHA Renews Alliance with Dow Chemical Company "
      OSHA New Release      		 69 News Services
      May 12, 2006 : "OSHA Renews Alliance with Dow Chemical Company"
      Safety Online      		 Data Not Available
      May 12, 2006 "OSHA Renews Alliance with Dow Chemical Company"
      U.S. Newswire      		 Data Not Available
      May 14, 2006: "OSHA and Dow Chemical Company Renew Alliance and Focus on Ergonomics"
      Ergonomics Today      		 Data Not Available
      May 15, 2006: "OSHA Renews Alliance with Dow Chemical"
      Reliable Plant Magazine      		 Data Not Available
      May 18, 2006: "OSHA, Dow Chemical Alliance Renewed Again"
      BNA Daily Labor Report/Occupational Safety and Health Reporter      		 Data Not Available
      May 2006: "OSHA News"
      Industrial Hygiene News      		 Data Not Available
      June 2, 2006: "OSHA Extends National Alliances with Three Major Entities"
      News for OSC      		 Data Not Available
      June 2006: "Case Studies Focus on Motor Vehicle Safety"
      OSHA Up To Date      		 Data Not Available
      July 2006: "OSHA Alliances"
      OSHA Up To Date      		 Data Not Available
      TOTAL 333,324

  4. Upcoming Milestones

    During the Alliance's next year, OSHA and Dow will continue to promote awareness of the Alliance Program and workplace safety and health issues, including ergonomics and process safety management. The Alliance implementation team members will continue to maintain and update the OSHA and The Dow Chemical Company Alliance Web page on the Agency's Web site. In addition, Dow representatives will review and provide OSHA with information for the Agency's Ammonia Refrigeration eTool and a number of Safety and Health Topics pages, including Chemical Reactivity Hazards Safety and Health Topics page, Isocyanates Safety and Health Topics page, and Process Safety Management Safety and Health Topics page.

    OSHA and Dow will also work together to develop a case study on contractor employee safety. The study will demonstrate instances where Dow worked with a contractor to implement or improve the contractor's safety program. The study is expected to detail what safety policy was implemented or improved and the resulting success measured by reductions in the accident rate. In addition, OSHA and Dow will also work together to develop a case study regarding Dow's experience implementing heat stress programs. Also, the OSHA and The Dow Chemical Company Alliance will develop a short slide presentation for use with the ergonomics, motor vehicle and fleet safety case studies. The slides will be available on OSHA's Web site for speakers who want to discuss Dow's case studies in a presentation.

    Finally, the OSHA and The Dow Chemical Company Alliance implementation team will identify OSHA and Regional and Area Offices that would like to attend the OSHA and The Dow Chemical Company Alliance workshop, "OSHA's Process Safety Management (PSM) Standard: The Dow Approach." The workshop discusses the various aspects of the PSM standard and how Dow addresses them.

Report prepared by: Rob Swick, Alliance Coordinator, Office of Outreach Services and Alliances, January 15, 2007.