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Texas Operations Contractor Alliance for Safety at Dow Facility in Freeport, Texas

According to the Dow Chemical Company (Dow), it places a high value on safety and health performance; consequently, it has set an aggressive goal as part of its public commitment to local protection of human health and safety and the environment. Dow has targeted 2015 as the year by which it will achieve a global goal of a total worksite injury/illness rate of 0.08 per 200,000 worked-hours. This metric includes both Dow and non-Dow employees at Dow sites and represents a 75-percent reduction from 2007 levels. The Company believes that all injuries can be avoided, as embodied in the Dow Code of Business Conduct:

Dow's goal is to eliminate all injuries, prevent adverse environmental and health impacts, reduce wastes and emissions and promote resource conservation at every stage of the life cycle of its products.

Dow's "Drive to Zero" programs focus on injury reduction for all personnel. The success of these programs depends on an ongoing vigorous collaborative effort between Dow and the hundreds of contactor firms around the globe that supply services which often evolve over years. The collaborative effort begins when the Dow and contractor leaderships set their companies' expectations and share safety practices. As time passes, the collaboration extends to each contractor employee, affecting his/her safety behavior in a positive manner. Dow's Texas Operations in Freeport (Texas Operations) is an example of a long term and very successful safety relationship that exists between Dow and a multitude of contractor firms. Since 1994, Texas Operations has experienced an 80-percent reduction in its OSHA recordable injury and illness rate for Dow and contractor employees at the site.

Background of Texas Operations

Dow Texas Operations in Freeport is Dow 's largest integrated site. It comprises three major integrated complexes, more than 5,000 acres and 75 individual production plants that employ more than 4,500 people. Texas Operations is the largest employer in Freeport; its workforce accounts for approximately 9.5 million contractor worked-hours per year.

Texas Operations manufactures more than 46 percent of Dow products sold in the United States and 23 percent of Dow products sold globally. The diversity of products includes fine and complex chemicals, hydrocarbons, specialty polymers and agricultural chemicals. Other products, such as, polyethylene, propylene glycol, polyurethanes, epoxy resins, caustic soda and vinyl chloride, are used in a variety of end products including cosmetics, trash bags, automotive safety equipment, cars, computers, toothpaste, food and household cleaning products. The products are transported to customers by rail, truck, marine vessel and pipeline.

In the early 1980s, as OSHA training regulations were evolving, Texas Operations and its contractors founded the Contractors' Safety Council of Brazosport, Inc. (CSC) to train contractor employees and maintain the training records so that repetition among contractors was minimized and costs were reduced. CSC is a non-profit, voluntary organization of industry members, contractor companies and professional associations. A Board of Directors supervises the operations, and a full-time staff distributes information to other safety councils and member firms.

CSC's Plant Safety Indoctrination Program starts with either the Basic Plus Class or Basic Plus Refresher Class and continues with a site-specific computer-based training class. CSC charges members much less than non-members and charges all contractors a financial penalty for employees who do not come to the class, arrive late, fail, or drop out. The classes differ as follows:

  • Basic Plus Class is led by an instructor and designed for employees who have not worked in the petrochemical industry.
  • Basic Plus Refresher Class is a 2-hour computer-based training designed for employees who have completed Basic Plus orientation.
  • Site-Specific classes cover policies, procedures, permits, emergency signals, etc. for each individual plant/refinery.

Additional computer-based training courses are available; they include Dow At-Risk, Asbestos Training, Confined Space Training, Dow Houston Hazcom, Dow Safe Work Permit, Ergonomics Training, Forklift Training, Flagger, Dow Flange, Firewatch, Rigger, Dow Red Tag /Lock Out/Tag Out, Scaffold Training and Vehicle Drivers Program.


Beginning in the early 1990s, Dow began to reach out to the contractor firms working at Texas Operations in an effort to improve their safety performances. The discussions between the management team from Texas Operations and the safety managers from the individual contractor firms were not very effective; the contractor safety managers had difficulty convincing their respective organizations to make changes to their safety and health programs largely because it meant more work for the management teams in their organizations. As a result, the efforts to improve contractor safety remained largely Dow-driven. After experiencing repeated hesitation on the part of the contractors, Dow managers concluded that future safety discussions between Dow and the contractors would be productive only when senior, management-level people from the firms were involved.

In 1994, the Texas Operations OSHA recordable injury rate (i.e., the number of injuries per 200,000 worked-hours) for all contractor workers was 3.43; Dow's rate was 2.38. At that time, managers at the Dow Corporate Office announced the goal of reducing the recordable injury rate (for all Dow and contractor employees) by 90 percent at all Company worksites. Managers at the Texas Operations worksite realized that their rate of change would need to improve to meet the goal. The need to have top-level contractor involvement combined with the need to meet Dow's corporate goal led to the formation of a new and unique safety alliance between Texas Operations and its service providers.

Background of TOCAS

As a result, managers from Dow and contractor firms at Texas Operations met as a group for the first time and began addressing common safety opportunities. In 1995, Texas Operations management began implementing changes in its safety and health program for contractors. The first step was to organize twice monthly Contractor Safety Meetings to which senior safety personnel from Texas Operations and the owners and managers of the contractors were invited. Thus, the Texas Operations Contractor Alliance for Safety (TOCAS) was formed with 15 contractor companies. The effort produced improvements almost immediately. In 1995, the Texas Operations recordable rate was 3.31, and by 1996, the rate had dropped to 1.85. According to Dow, convening the managers responsible for the financial and human resources of the contractor companies resulted in the start of positive changes.

TOCAS worked and still works to identify and articulate the safety- related needs of its broad spectrum of contractor companies and partners with Texas Operations to improve contractor safety performance. TOCAS provides all contractor companies doing business with Texas Operations with a forum for sharing the purposes, expectations, strategies, incentives, and results of the community of contractors working at the site. The contractor representatives to TOCAS are the decision makers that can commit their companies to safety programs, employee involvement and actions. The companies' safety contacts form another group that works to improve safety within the plants.

Through the program, Texas Operations management provides the data on a safety issue to TOCAS and asks its members to find solutions and establish priorities. All contractor companies providing labor services to Texas Operations are eligible to be associated with TOCAS. In return, members are asked to provide ongoing commitment to the goals and philosophy of TOCAS. As a result, the expectation on the part of Dow is that safety performance within Texas Operations will continue to improve. The basic elements of TOCAS are similar to the critical elements of an effective safety and health management system--management commitment and employee involvement; worksite analysis; hazard prevention and control; training for employees, supervisors and managers.

In conjunction with Texas Operations, TOCAS establishes annual recordable injury performance goals that include Dow and contractor employees. The goal for 1995 was 3.34 and the actual rate was 0.24. Recent performance trends show even more progress; a contractor recordable rate of 0.20 in 2007, and over 4 million contractor worked-hours without a recordable injury.

The number of contractor companies involved in TOCAS has grown from 15 in 1995 to 23 in 1996 to 85 in 2008; between 4,000 and 5,000 contract employees are at work on the site at any time. Each of the approximately 12,000 contractor employees has a badge; each badge holder has successfully completed a background check, drug test and training at the CSC facility at Brazosport, Texas. These contractor employees are responsible for 700,000-900,000 worked-hours per month or 9M-10 million worked-hours per year.

How TOCAS Works

TOCAS is directed by a Chairman and Associate Chairman, who are elected annually by the membership and the Steering Committee. The Steering Committee is made up of top-level managers from the 15 contractor firms that do the most work on the site. Each year Dow evaluates the contractors to ensure that they are still among the top 15 contractors. Members of the Steering Committee set the direction and policy of TOCAS and encourage active participation of the members. They also appoint other committees to research and recommend actions in areas of safety performance to eliminate accidents and incidents. These committees may focus on actions concerning certain employees (e.g., new employees, employees who have had more than one incident in 24 months) or safety processes (e.g., for knife use). The data gathered by the members of the committees are evaluated by members of the Steering Committee to determine which are the most serious problems to be addressed. In 1999 the data indicated that the TOCAS focus should be directed toward:

  • Employees who have worked at Texas Operations less than 6 months (60 percent of them will have an injury)
  • Employees who have had more than one incident in 24 months (often these employees are called "repeaters")
  • Hand injuries

TOCAS also established Standing Committees to address a number of issues. For example, members of the Training Committee train all first line supervisors and safety contacts two times a year on topics that are pertinent to what is occurring at the site. Members of the Coaching for Safety Success Committee analyze the performance data for each first line supervisor and safety contact to ensure that every employee is meeting all expectations on both the proactive and reactive sides of performance. The process that the Coaching for Safety Success Committee uses is designed to locate the bottom 10 percent of performers, provide them with specific tools to help them improve their performance, and track them closely to guarantee their improvement. It addresses the issues associated with change (for example, a 45-year old employee who is used to working in a place where following rules is not important may find working in a place where following safety rules is very important a major change with which to cope) and sustainability once a change has occurred. During this process, managers also evaluate the annually accrued data for employees with less than 6-months tenure, repeaters, and hand injuries.

Members of TOCAS communicate the data, common problems and solutions to all Texas Operations contractors. While implementation of the solutions is not mandatory, most members adopt them. Often, the managers of the contractor companies share solutions with their facilities at other locations, demonstrating the level of commitment on the part of the contractor companies.

The Safe Behavior Process

TOCAS and Texas Operations also train every contractor employee in the Safe Behavior Process. The Safe Behavior Process has two parts: the Safety Observation Intervention Program that is concerned with the identification of hazards, and the Pre-Task Analysis Tool that is concerned with the elimination or control of hazards.

As part of the Safety Observation Intervention Process, Texas Operations and contractor supervisors make observations and enter data about them into a computer database that has been programmed to display trends, which are then reviewed and evaluated by TOCAS for determination of which trends to address. For example, a Texas Operations or a contractor supervisor might observe five employees who should be wearing Personal Protective Equipment (PPE) in the form of gloves, and one is not wearing them; the company would be informed of the results of the observations both positive and negative. TOCAS requests that all contractors perform no less than one observation intervention per week using a Contractor Observation/Intervention form. (See Figure 1 for more information about the form.) TOCAS members and Texas Operations personnel review contractor observation intervention data on a monthly basis to monitor management commitment and identify trends.

Another part of the Safety Observation Intervention Process involves the chain of accountability; all First Line Supervisors are responsible for the actions of their subordinates; Supervisors and Safety Consultants are responsible for the actions of the First Line Supervisors. Safety Consultants are often Construction Site Safety Technicians who usually have previous experience with their companies and training from the National Center for Construction Education and Research and the Associated Builders and Contractors. Texas Operations and TOCAS personnel share the observation intervention data with contractors in monthly performance presentations.

The second part of the Safe Behavior Process involves a process that incorporates the use of a Safe Task Analysis Card (STAC). As part of this process, the Safety Consultants throughout Texas Operations facility visit the members of crews and ask them to, for example, identify Line of Fire hazards in the job that they are planning. Every month, the focus of the observations for the STAC card changes; the requirements for the observations are described in an updatable insert in the STAC card. Changing the focus of the observations has proved to yield more realistic responses to the status of the safety and health activities of the employees. The Safety Consultant records employee responses and reviews them with the crew to ensure that each member of the crew knows the proper technique for analyzing the task being performed. Texas Operations' personnel share with the TOCAS membership (on a monthly basis) the quality of employees' STAC preparation through a scoring system. (See Figures 2A and 2B for a sample STAC card.)

To encourage the investigation of incidents, TOCAS members have created a Learning Experience Report (LER) to capture descriptions of near misses thereby bringing awareness of a possible health and safety hazard to the attention of safety and health managers. TOCAS has established a goal of an 8 LER rate (calculated on the same 200,000 man-hour basis as the OSHA injury rate). A contractor that has 100 employees is expected to complete a minimum of 8 LERs in a year. The documenting of near misses encourages managers to note and address areas for improvement. (See Figure 3 for a sample Contractor Incident/Injury Report that Dow uses to prepare the LERs.)

Corporate Contractor Safety Standard

In 2003, Dow implemented a global Contractor Safety Standard that defined the roles and responsibilities for managing the activities of non-Dow personnel who provide services on Dow property. This document sets consistent requirements for the pre-qualification, selection, pre-job activities, assessment of work, and evaluation of these employees. The activities of TOCAS are aligned with the global corporate requirements.

Annual review of the data collected from the safety standards allows TOCAS and Texas Operations to select the companies, the First-Line Supervisors and the Safety Contacts who exceed expectations. At a yearly recognition dinner, Dow Chemical recognizes these contractor companies and individuals. On a monthly basis, Texas Operations publicly recognizes 20-25 individuals and groups for their contributions to the safety and health programs by posting their pictures and descriptions of accomplishments on the TOCAS Web site.


For the period 1995-2007, the average OSHA recordable incident cost Dow $20,000 when all investigative resources and corrective actions were considered. From 1995, when TOCAS began, to 2007, the OSHA recordable rate for contractors improved 95 percent overall. Figure 4 illustrates the improvement in the contractors' OSHA recordable rate at Freeport.

The TOCAS contractor safety and health organization that was designed and developed at the Freeport, Texas location was the first such activity for Dow, but it has been so successful that similar organizations are now in place at Dow facilities in Texas (Seadrift, Texas City and Houston) and Louisiana (Baton Rouge and New Orleans). In part, TOCAS is successful because it gives contractors control over their own programs. Contractors can implement the rules, standards and processes that address their and Dow's largest issues and track their performance to see what is successful. The Texas Operations model demonstrates that contractors can and do learn from one another. Through sharing their policies and experiences, contractors leverage expertise and solutions.

Said Amando Gonzalez, Jr., 2008 TOCAS Chairperson

Since the creation of TOCAS in 1996, the contractor community within Dow Texas Operations has achieved continuous improvement in safety performance in both short- and long-term goals. As they work with Dow, Contractor Managers and Owners share the purposes and philosophies of TOCAS as they participate in reaching its goals. As Contractors, we are rewarded by an improved safety performance, access to safety information and data, and training. The partnership between Contractors and Dow that has been developed through TOCAS is a benefit to all participants in the drive to eliminate incidents and injuries.

Commented Bob Walker, Vice President of Dow Texas Operations,

Our site EH&S (Environment, Health and Safety) highlight for the year was receiving the Responsible Care Management System Certification from Lloyd's Quality Register Assurance. Texas Operations was the first large site to go through the audit and I'm proud to say we passed with flying colors. Texas Operations' employees have set the standard

Dan Donovan, member of Dow's Personal Safety Expertise Center, says:

"Safety alliances like TOCAS in the Freeport area have proven very beneficial for both Dow and the participating contractor firms. Regular and structured communication about safety issues and effective improvement techniques have produced safety innovations that have been leveraged across the facility and in some cases more broadly across Dow. This has systematically reduced risk and steadily improved safety performance, making Texas Operations one of the safest facilities in the Dow Chemical Company."

In addition, the Oyster Creek Division of Texas Operations is a Voluntary Protection Program (VPP) site. The other divisions are currently in the process of applying for VPP status. Texas Operations was one of the early adopters of the program; the plan is for all of the divisions to have VPP status in the future.

Figure 1. Description of Contractor Observation/Intervention Form (machine-scanned card)

The form that TOCAS representatives use is a two-sided card that fits in a shirt pocket. The front of the card has space for information about the observer, the date, the person being observed and the location. The instructions for how to complete the card are at the bottom of the front of the card; they are as follows:

  • Use a #2 pencil or blue or back ink. Shade in bubbles completely.
  • Shaded columns on the front require an entry.
  • On the back, bubble an "S" or "U" for each category observed. The job is considered "Safe" only if all crew members are working safely in that category. Bubble an "I" for each category when you discuss the performance that was observed with the person(s) working. Always talk with the individual or crew to praise positive behaviors and redirect unsafe acts.
  • Describe any behavioral deficiencies observed (and why they were occurring) on the lines provided on the back to help pinpoint improvement opportunities.
  • Use the safety suggestion system to communicate potential equipment/process improvements. Use the work order system to communicate maintenance needs.

The actual safety observation data are listed on the back of the card by behavior category, degrees of safe behavior, degree of unsafe behavior and intervention. The behavior categories are:

  • PPE (Personal Preventive Equipment)
    • Eyes/face/head
    • Ears/hearing
    • Fall restraint
    • Respiratory/breathing
    • Hands/arms
  • Rules/Regulations
    • Safety card/STAC
    • Safe work permit
    • Other permits
    • Lockout/tagout
    • Job procedures
  • Job Site Conditions
    • Clutter/trips
    • Debris/trash
    • Spills/leaks
    • Weather
  • Body Position
    • Straining/lifting
    • Push/pull/carry
    • Climbing
    • Other body positions
    • Hot surfaces
  • Tools/Equipment
    • Proper tools
    • Safe tools/devices
    • Ladders/scaffolds
    • Cranes/manlifts
    • Vehicles
  • Special Emphasis
  • Details on safe or unsafe behaviors

Figure 2A. Sample STAC Card (Front)

Figure 2B. Sample STAC Card (Back)

Figure 3. Learning Experience Report

Contractor Incident / Injury Report Form Instructions

  • IntroductionThe purpose of the new Contractor Injury/Incident form is to ensure that standardized information is received for incidents occurring on site.
  • GoalThe ultimate goal of Dow Contractor EH&S is to help your company succeed, whether it's by data collection and feedback to you or better processes to improve your company's productivity.
  • Form FormatWhen there is not an option for a pull-down list and you must type either the Incident Location, Company Name, Employee Name, etc.,
  • DO NOT USE ALL CAPITAL LETTERS FOR NAMES, INCIDENT DESCRIPTIONs, ETC. It is ok to use a capital letter for block locations (ex: B-101, A-2400 etc. --Use Upper & lower case Letters as the examples show for others...
  • Expectation/ProcessAs always, the expectations are to report any incidents on site. Each contractor company needing to report an incident, will electronically complete and send in either a preliminary or a final report using this new form to Insert email address here.

When the contractor company completes the final incident package, include a hard copy of the Contractor Incident / Injury Report Form and also e-mail Contractor EH&S an electronic copy of the final Contractor Incident / Injury Report Form

The green highlighted blocks/spaces should be completely filled-in by the completer before sending to EH&S

The top of form will indicate whether the form is complete for sending.

Figure 4. Contractor OSHA Recordable Rate at Freeport

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