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ALLIANCE ANNUAL REPORT

Occupational Safety and Health Administration and
The Dow Chemical Company

April 15, 2004

  1. Alliance Background

    Date Signed

    January 13, 2003

    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. This is an essential component of OSHA's desire to partner with stakeholders, and Dow's commitment to Responsible Care and the company's new 12 Point Operating Plan for Sustainable Development. The goals of the Alliance include:

    Outreach and communication:
     
    • Develop and disseminate information on effective safety and health programs at conferences, events, or through print and electronic media.

    • Provide OSHA with opportunities to participate in hands-on information sharing in Dow's facilities to "test run" ideas and understand real world impacts and applications.

    Promoting the national dialogue on workplace safety and health:
    • Encourage Dow worksites and personnel to act as industry liaisons and resources for OSHA's cooperative programs and Compliance Assistance Specialists.

    • Participate in stakeholder groups and other formats for providing input into the development of safety and health standards and guidance for the chemical industry.

    • Work together to develop new approaches and practices to address health and safety risks.

    • Share information on proven practices of Dow worksites with others in industry through outreach directly by Dow and also through OSHA.

    Implementation Team Members

    Dow:
     
    Stan Dombrowski
    Bart Gliatta
    Tim Overton
    Mark Spence
    Tim Taylor
    Industrial Hygiene Expertise Center
    Personal Safety Expertise Center
    Process Safety Technology Center
    North American Health & Safety Regulatory Affairs
    EH & S Public Affairs

    OSHA:
     
     
    Kevin Cummins
    Brently Donaldson
    Lee Anne Jillings
    Mike Marshall
    Lisa Ramber
    Beth Sherfy
    Joanne Slattery
    Salt Lake Technical Center
    Office of Training and Education
    Office of Outreach Services and Alliances
    Directorate of Enforcement Programs
    Office of Outreach Services and Alliances
    Office of Outreach Services and Alliances
    Directorate of Standards and Guidance

    Evaluation Period

    January 13, 2003 - January 12, 2004

  2. Implementation Team Meetings
     
    January 13, 2003
    April 9, 2003
    May 1, 2003
    May 2, 2003
    October 23, 2003
    Kick-off meeting
    Team meeting
    PSM seminar planning
    Team meeting
    Team meeting
     
  3. Events and Products

    Training and Education

    Events:

    OSHA/ Dow Workshop, "OSHA's Process Safety Management (PSM) Standard: The Dow Approach," OSHA Training Institute, Arlington Heights, Illinois, September 16, 2003


    A workshop was held for OSHA's Region V staff that covered how Dow addresses and implements the PSM standard in its workplaces and discussed various aspects of the standard, including process safety information, process hazard analysis procedures and management of change. Presenting for Dow were Kevin Shaughnessy, a Global Process Safety Technology Leader and Don Jones, a Registered Professional Engineer and Certified Safety Professional with Dow Regulatory Affairs. The workshop was attended by more than 25 OSHA staff from Region V's Regional and Area Offices, Consultation Projects and State Plan States, including Michigan OSHA and Wisconsin Consultation.

    Outreach and Communication

    Events:

    2nd Annual OSHA Compliance Assistance Conference, Tysons Corner Marriott, Vienna, Virginia, June, 12, 2003


    Samuel L. Smolik, Vice President, Environment, Health and Safety at Dow, presented "A Vision and Culture of Zero," and spoke to the Compliance Assistance Conference attendees about Dow's tips and techniques that have helped the company reduce injuries and illnesses of Dow employees and contractors by 73 percent globally since 1994.

    Environmental, Health and Safety Conference of the Texas Chemistry Council, June 2003

    Mark Spence, Manager, Health and Safety Regulatory Affairs at Dow, made a presentation to approximately 40 attendees during a session at the annual EH&S conference of the Texas Chemistry Council, of which Dow is a member, describing the OSHA Alliance Program and why Dow decided to enter into an Alliance.

    Workshop on Reactive Chemicals, June 2003

    Tim Overton of Dow's Process Safety Technology Center was a participant and presenter at a workshop on reactive chemicals sponsored jointly by OSHA, the US Environmental Protection Agency, and the Chemical Safety and Hazard Investigation Board.

    European Union Conference on Safety and Health, Lemnos, Greece, October 15-17, 2003

    The European Union and the United States held their third Joint Conference on Occupational Health and Safety October 15 -17, 2003 in Lemnos, Greece. A topic of the conference was "Co-operative Programs and Partnerships". The discussions covered the critical elements of successful partnership/co-operative programs and working toward a common framework for partnership/co-operative programs. Mark Spence, Manager, Health and Safety Regulatory Affairs at Dow and a member of the Alliance Implementation Team, attended the conference. Paula White, Director, Directorate of Cooperative and State Programs at OSHA also attended the conference and presented a white paper on OSHA's cooperative programs.

    Products:

    OSHA's eTool: Ammonia Refrigeration


    Dow participated in the development and review of the first section of OSHA's eTool for ammonia refrigeration. It is expected that this information will be posted on OSHA's web page in 2004.

    OSHA's Safety and Health Topics Pages

    Safety managers from Dow are participating on chemical-related editorial boards for the OSHA Web site's Process Safety Management, Reactive Chemicals, Ammonia Refrigeration, and Isocyanates Safety and Health Topics pages.

    Safety and Health Case Studies: Ergonomics and Motor Vehicle Safety

    Dow has been working with OSHA to develop case studies on ergonomics and motor vehicle safety that will be posted on OSHA's Web site in 2004. The case studies will discuss how Dow has applied the Six Sigma strategy to identify and reduce hazards and implement solutions to improve the safety and health of the workplace.

    OSHA and Dow Alliance Web Page

    The OSHA and Dow Alliance Web page on OSHA's Web site contains information on the Alliance, Products and Resources, Activities and Events, and Milestones and Successes. The page is updated regularly.

    • January 13, 2003 -- OSHA distributed a news release announcing the Alliance.

    • January 13, 2003 -- Dow distributed a news release and posted it on the company's web site; "The Dow Chemical Company First Fortune 100 Company & First Chemical Manufacturing Company To Sign Alliance with OSHA."

    • January 15, 2003 -- OSHA included information on the OSHA/Dow Alliance signing in its bi-weekly e-newsletter; QuickTakes.

    • January 16, 2003 -- Article on the Alliance published by Occupational Safety & Health Reporter; "Dow Chemical Signs Alliance With OSHA Focusing on Process Safety, Ergonomics."

    • January 20, 2003 -- Article on the Alliance published by www.InsideHealthPolicy.com; "OSHA, DOW Chemical Forge Alliance to Cooperate on Ergonomics, PSM."

    • January 22, 2003 -- Article on the Alliance published by Chemical Week; "Dow Agrees to Help OSHA Promote Compliance."

    • January 30, 2003 -- Article on the Alliance published by the Times-Picayune (New Orleans, LA); "Business Notes: DOW-OSHA Alliance."

    • 2003 Dow Chemical Company Annual Report -- The Dow-OSHA Alliance is mentioned in annual report's section on "Driving Improvement." (http://www.dow.com/financial/2003ann/index.htm)
    Promoting the National Dialogue on Workplace Safety and Health

    Events:

    2nd Annual OSHA Compliance Assistance Conference, Tysons Corner Marriott, Vienna, Virginia, June 9-13, 2003.


    Dow participated as an exhibitor.

  4. Results

    Dow has demonstrated its commitment to improving the safety and health of the workplace through implementing innovative programs and its willingness to work cooperatively with various trade associations and regulatory agencies. In addition, a number of the company's facilities have been in OSHA's Voluntary Protection Programs (VPP) for over 10 years and Dow participated in the steering committee that designed the Corporate VPP Program. Dow extended its commitment to building a culture of incident prevention by being the first Fortune 100 company to sign an Alliance with OSHA.

    While initially uncertain on how best to leverage OSHA's and Dow's expertise to the benefit of the organizations and the chemical industry as a whole, the Alliance implementation team met regularly and held productive discussions that helped focus the groups' work during the first year of the Alliance. As a result a number of projects were undertaken and OSHA used Dow's expertise in a number of different instances, including safety and health professionals from Dow agreeing to review OSHA's Safety and Health Topics pages for Process Safety Management, Reactive Chemicals, Ammonia Refrigeration, and Isocyanates.

    In addition, Dow experts reviewed and provided OSHA with comments on the first module of the Ammonia Refrigeration eTool. The module is expected to be posted on OSHA's Web site in the first half o 2004. Additional modules will be developed as funds are available and Dow is committed to providing comments.

    The implementation team also agreed that it would be beneficial for OSHA staff to hear directly from a recognized leader in safety and health on how it implements and meets the requirements of OSHA's PSM standard. As a result, the group developed the OSHA/Dow Workshop, "OSHA's Process Safety Management (PSM) Standard: The Dow Approach," that was presented on September 16, 2003 at OSHA's Training Institute in Arlington Heights, Illinois. Presenting for Dow were Kevin Shaughnessy a Global Process Safety Technology Leader and Don Jones, a Registered Professional Engineer and Certified Safety Professional with Dow Regulatory Affairs. Over 25 OSHA staff members, from Region V, including Regional and Area Offices, Michigan OSHA and Wisconsin Consultation, heard Dow discuss the company's overall organization, roles, and use of internal standards, work processes and management systems to achieve consistent implementation of the PSM standard's requirements and process risk management within Dow.

    In addition, Dow representatives were very active in promoting and discussing the Alliance Program through speeches to professional associations (such as the American Chemistry Council), other businesses and the international community. Dow staff also worked with OSHA to develop case studies and address and provide information on a number of safety and health issues in the workplace, including material safety data sheets, ergonomics, motor vehicle safety and reactive chemicals.
     
    Type of Activity (Conference, Training, Print and Electronic Distribution, etc.) Number of Individuals Reached or Trained
    OSHA/Dow Workshop, "OSHA's Process Safety Management (PSM) Standard: The Dow Approach," OSHA Training Institute, Arlington Heights, Illinois, September 16, 2003

    Dow Speakers:

    Kevin Shaughnessy, a Global Process Safety Technology Leader
    Don Jones, a Registered Professional Engineer and Certified Safety Professional with the Regulatory Affairs Department
     
    25
    2nd Annual OSHA Compliance Assistance Conference, Tysons Corner Marriott, Vienna, Virginia, June, 12, 2003, "A Vision and Culture of Zero"

    Dow Speaker:
    • Samuel L. Smolik, Vice President, Environment, Health and Safety at Dow
    200
    2nd Annual OSHA Compliance Assistance Conference, Tysons Corner Marriott, Vienna, Virginia, June 9-13, 2003

    Dow exhibited
     
    200
    Environmental, Health and Safety Conference of the Texas Chemistry Council, June 2003

    Dow Speaker:
    • Mark Spence, Manager, Health and Safety Regulatory Affairs at Dow
    40
    Workshop on Reactive Chemicals, June 2003

    Dow Speaker:
    • Tim Overton, Dow's Process Safety Technology Center
    90
    European Union Conference on Safety and Health, Lemnos, Greece, October 15-17, 2003

    Dow Participation:
    • Mark Spence, Manager, Health and Safety Regulatory Affairs
    25
    OSHA and Dow Alliance Web Page 4,000
    January 13, 2003 -- OSHA distributed a news release announcing the Alliance. 25 News Services
    January 13, 2003 -- At Dow distributed a news release and posted it on the company's web site; "The Dow Chemical Company First Fortune 100 Company & First Chemical Manufacturing Company To Sign Alliance with OSHA." News Section had 63,000 visitors per month in 2003
    January 15, 2003 -- OSHA includes information on the OSHA/AMI Alliance signing in its bi-weekly e-newsletter; QuickTakes. 35,000
    January 16, 2003 -- Article on the Alliance published by Occupational Safety & Health Reporter; "Dow Chemical Signs Alliance With OSHA Focusing on Process Safety, Ergonomics." 2,000
    January 20, 2003 -- Article on the Alliance published by www.InsideHealthPolicy.com; "OSHA, DOW Chemical Force Alliance to Cooperate on Ergonomics, PSM." 25,000
    January 22, 2003 -- Article on the Alliance published by Chemical Week; "Dow Agrees to Help OSHA Promote Compliance." 21,206
    January 30, 2003 -- Article on the Alliance published by the Times-Picayune (New Orleans, LA); "Business Notes: DOW-OSHA Alliance." 270,000
    2003 Dow Chemical Company Annual Report -- The Dow-OSHA Alliance is mentioned in annual report's section on "Driving Improvement." (http://www.dow.com/financial/2003ann/index.htm) 455,000 shareholders representing 936 billion shares outstanding
    OSHA's Safety and Health Topics Pages
    • Process Safety Management
    • Reactive Chemicals
    • Ammonia Refrigeration
    • Isocyanates
    Data Not Available
    eTool for Ammonia Refrigeration Data Not Available
    TOTAL 875,811
     
  5. Upcoming Milestones

    In addition to renewing the Alliance agreement, the OSHA and Dow Alliance has some major projects planned for the upcoming year. Starting off the year will be the Alliance renewal signing. It is being scheduled in tandem with the kick-off for OSHA's Corporate Voluntary Protection Program (VPP) pilot at OSHA in Washington, DC.

    In response to the success of the Region V workshop, "OSHA's Process Safety Management (PSM) Standard: The Dow Approach", the Alliance implementation team is considering holding another workshop at a Dow,VPP-participating facility in the Gulf Coast for Region IV and Region VI OSHA staff. The team has discussed the possibility of developing a two-day program and presenting the PSM workshop on the first day followed by a tour of the Dow facility on the second day.

    The implementation team is committed to continuing to provide expertise and input on appropriate OSHA publications and electronic assistance tools, including additional modules of the Ammonia Refrigeration eTool and reviewing the Safety and Health Topics pages as needed.

    The OSHA and Dow Alliance has also discussed working through other Alliances, e.g., the Reactives Alliance, to address additional safety and health issues that have an impact on the chemical industry.



    Report prepared by: Lisa Ramber, Alliance Coordinator, Office of Outreach Services and Alliances, March 30, 2004