Advancing a culture of health & safety (GRI 403-1, 403-103)

The safety and well-being of our Dow people are a cornerstone of our culture. Worker protection has been a priority at Dow since our earliest days. Our goal is to have every worker go home safely at the end of their work day. To ensure worker safety, Dow uses a comprehensive, integrated operating discipline management system that includes policies, requirements, processes, best practices and procedures related to our Environment, Health & Safety, Quality and Operations standards, and related external standards. Through this system, we lay the foundational expectations of hazard assessment and risk mitigation, aligned to Responsible Care®. We expect each organization in Dow to implement and use health and safety programs to:

 

Our global health & safety management system
Our management system is grounded in requirements of the U.S. Environmental Protection Agency and Occupational Safety and Health Administration, and incorporates ideas from other global regions. Overall, our management system is based on the following principles:
Stringent

Dow’s health and safety processes meet or exceed the requirements of the countries in which we operate. All Dow locations are expected to comply with Dow or local requirements, whichever are more stringent. The management system has been externally assessed and found to meet ISO-14001, ISO-9001 and Responsible Care® code requirements. The system applies globally to all Dow premises and joint venture locations where we have greater than 50% ownership.

Comprehensive

Our management system covers Dow workers regardless of whether they are working on or off Dow premises, and all contracted workers performing work on Dow premises. Workers who deliver materials (e.g., package delivery services) are excluded from our full management system but receive fundamental training if entering our sites. The management system is designed and implemented by professionals employed or contracted by Dow (e.g., Health Services, Industrial Hygiene, and Environment, Health & Safety Delivery).

Global and site-specific

Aligned with the global management system, every work group at Dow must establish site- and unit-specific procedures that assure full implementation of our standards and compliance with local regulations. Required self-assessments and independent internal audits monitor compliance and identify best practices, with audit results reviewed by Dow management, including a cross-functional team composed of all business presidents, the senior leader for EH&S, the head of auditing, the chief financial officer and the Board of directors’ Environment, Health, Safety & Technology committee. In addition, committee materials are available for review by all Dow board members. The audit management system is reviewed and enhanced annually.

Hazard identification, risk assessment and incident investigation (GRI 403-2)

Leading indicators of occupational health and safety performance play a vital role in preventing injury and strengthening other safety and health outcomes at Dow. A consistent set of globally applied leading indicators is complemented by locally defined leading indicators.

Globally applied leading indicators include:

  • Non-injury (near-miss) situations with potential to cause a life-altering impact or fatality had the situation been only slightly different (non-injury pLIFE event)

  • Percent completion of training for Life Critical Standards

  • Internal EH&S management system audit results

  • Open actions from Reactive Chemical and Process Hazard Analysis reviews

Our routine hazard analysis programs include:

  • Periodic health exams determined by the employee’s role and potential exposure to specific workplace hazards

  • Qualitative exposure assessment for chemical, physical, ergonomic and biological hazards overseen by professional industrial hygienists

  • Regular evaluation and periodic re-evaluation of process safety hazards via our Layers of Protection Analysis

  • Personal safety risk analysis performed as a part of numerous work processes (e.g., safe work permit, pre-task analysis and pre-startup safety reviews)

Reporting and investigating safety issues

Workers have direct line of sight to potential hazards. They are expected and encouraged to identify, report and intervene when unsafe or unhealthy work conditions are observed. They also positively recognize coworkers making safe choices.

Worker input on hazards and solutions is part of local near-miss programs and leveraged where appropriate. Retaliation against anyone who raises or reports concerns about workplace safety is prohibited under Dow’s Code of Conduct. Apollo™ Root Cause Investigation methodology is used for all recordable injuries and near-miss situations where potential existed for a life-impacting injury.

Consistent use of the methodology ensures we understand the cause and take corrective actions at the point of the problem, as well as at the strategy and management system levels. Significant learnings are shared globally through our Learning Experience Report process. Once hazards are identified, we determine feasible and effective solutions. A tragic loss of life in 2019 triggered a global response and resulted in enacting changes in 2020 to our management system for heavy equipment and moving vehicles. The management system update requires implementation of a hierarchy of controls to prevent accidents related to heavy equipment and reversing moving vehicles.