Document 3NZm8R6rDN0gkean3w3oYgLGa
Page 1
LOUISIANA DIVISION CONSOLIDATED AUDIT OCCUPATIONAL__ HEALTH
SECTION I.
EDUCATION AND TRAINING (REF. OSHA HAZCOM 29CFR 1910.1200)
1 Is there a written Hazard Communication program? Yes [X] No [ ]
Last updated (date) 11/18/91
2. Show written program (HazCom manual). Bring whole manual
3. Examine orientation program for new and transferred employees.
Does orientation for transfers differ from that for new
employees?
Yes [ ] No (X]
4. Are technical supervisory, clerical, laboratory and maintenance
personnel included?
Yes [X] No [ ]
5. How is this training documented? By signing of indoctrination checklist .-------------------------------------------------------------------------------------------------------------Review training records.(Attach an example to the questionnaire)
6. Is there a Chemical and Physical Agent Inventory (CPAI)?
Yes [X] No [ ] Last updated (date) 1ST Quarter 1992
7 . Does the CPAI contain all significant chemical and physical
stresses? Yes [X] No [ ]
8. Is the CPAI updated annually? By whom? I.H. Contact/Industrial Hygienist.
Yes [X] No [ ]
9. Is the inventory available to all shifts? Where? Safety and Environmental Office
Yes [X] No [ ]
Are CPAI's reviewed with new employees?
Yes [ ] No [X]
No we have not been covering CPAI per say but we have been
covering all items except one in hazard communication training.
Heat stress added to HAZCOM training.
10. What is the review procedure for bringing a new chemical/physical agent into the area? Reactive chemical.
Tasca check, review and hazcom review with affected personnel..
Is Industrial Hygiene involved?
Yes [X] No [ ]
DOW CONFIDENTIAL
00 A 022789 C0NFTDFNTTA1
Page 2
11. Are current MSDS's available for all chemicals? Yes [X] No [ ]
12. Are MSDS's available to employees at all times? Yes [X] No [ ]
Where? Hazard communication manual. Safety/Environmental Office
13. Are written process descriptions, simplified flow sheets, floor
plans and job descriptions current?
Yes [X] No [ ]
14. Are all potential sources of exposure such as process sampling
points, sumps and unloading/loading docks noted?
[X] NA
Yes [ ] No [ ]
15. Are employees informed of the stresses to which they may be
exposed, and the consequences of overexposure to the stresses,
on an annual basis?
Yes [X] No [ ]
16. Are maintenance and laboratory personnel covered in annual
retraining?
Yes [X] No [ ]
17. How is this information communicated? Via asbestos and hazards communication training annually.
What is the role/involvement of supervision? Insuring compliance with training requirements and oarticoating in training meetings.------------------------------------------------------------------------------------------
18. How is new health effects information communicated to employed?
Via meetings and bulletin board postings
Is the communication documented? (Meetings) Yes [X] No [ ]
19. How are the results of exposure monitoring communicated to
employees in a timely manner? The results are communicated via meeting as soon as possible and documented.
Show documentation. (Attach an example to the questionnaire)
20. How are stationary containers labeled? Vessel number if container contains asbestos is marked as such with warning.--
Revised:1/92
DOW CONFIDENTIAL
no A 0PP790 0ONFTDFNTTA1
Page 3
21. How do employees determine the hazards associated with vessel/pipeline contents? Through training, line orgin and destination, labels on piping, tracing lines. MSDS sheets.-------
22. How are portable containers labeled? With an appropriate label with reference to standard in Hazcom manual.
Revised:1/92
DOW CONFIDENTIAL
DO A OPP791 CONFTDFNTTAl
Page 4
SECTION II
RESPIRATORY PROTECTION PROGRAM (REF. DOW SAFETY STANDARD AND OSHA 29 CFR 1910.134)
1. Is there a written respiratory program which has been updated
within the past 12 months?
Yes [X] No [ ]
Where is it kept? Block manual and personal computer. Show written respirator program. (Attach the written program to the questionnaire)
2. Who has plant responsibility for implementing the respiratory
program?___I,.H. Contact
3. What is the respiratory protection program for visitors and nonDow employees? Visitors are given escape respirator's and
trained on how to use them during an emergency.
4. Is there a regular inspection and evaluation to determine the
continued effectiveness of this program?
Yes (X] No [ ]
5. Are respirators required, provided and used for other than
escape and emergency response?
Yes [X] No [ ]
6. What types of respirators are issued for the following uses?
Escape only: A.O.R. 9722. scottoramic. Comfo II
Routine use: For asbestos Comfo II'or forced air respirator.
Emergency use: Two 3Q...minutes s.cott air pak.
7. Are respirators individually assigned and have the owner's name and date cartridge/canister was replaced recorded on them?
Yes [X] No [ ]
Revised:1/92
DOW CONFIDENTIAL
DO A 0PP79P CONFTDFNTTA1
Page 5
8. Has annual training been conducted in the proper use of respirators and their limitations for all users? Yes [X] No [ ]
Show documentation. (Attach an example to the questionnaire)
9. Describe the training program (who conducts, methods, tests, etc.). Plant I.H. Contact conducts training.---------------------------------------------------Training consists of:____________________ How to change cartridge How clean and maintain the respirator Fit testing procedures including selection of proper
selection----------------------------------------------------------------------------------------------------------------------------------
10. Is there a routine inspection, cleaning, and maintenance
program?
Yes [X] No [ ]
Show auditors respirator cleaning station.
Define method used for cleaning of respirators.Respirators are cleaned with ARI sanitizer deodorizer for more details see attached procedures.
11. What are the documented inspection procedures for your respiratory equipment as listed in Question #6? Show documentation.
Documents are kept in the C-9 file in the Safetv/Environmental QffiCg -------------------------------------------------------------------------------------------------------------------
12. Are respirators stored properly as to not cause distortion and placed in a clean environment when not in use? Yes [X] No [ ] Show auditors example of storage area.
Revised:1/92
DOW CONFIDENTIAL
DO A 027793 CONFTDFNTTAl
Page 6
13. Has fit testing been conducted within the past two years for all
routine users?
Yes [X] No [ 3
Show documentation. (Attach an example to the questionnaire)
What special provisions are made for those employees wearing eye lenses? Special frames were given to the two employees who wear glasses. They were told that Dow could pay for the lens if--------
they wanted. So far neither has had them made .ue.-----There is-----really no need in our work.------------------------------------------------------------------ -- ------
14. Is the medical approval for all routine respirator users current
(within the last two years)?
Yes [X] No [ ]
15. Are air supplied respirators used?
Yes [X] No [ ]
What is the source of air? Breathing air cylinders only on special jobs vessel entry etc.-----------------------------------------------------------------
16. Are Hansen or Schrader fittings used for breathing lines to
insure against connecting into other systems?
[X]NA
Yes [ ] No [ ]
17. If air compressors are used, what steps are taken to assure the quality of air? Do not use air compressor supplied air.--------------
18. Are backup persons with suitable rescue equipment provided for persons working in confined spaced with supplied air?
Yes [X] No ( ]
SCBAs inspected:
Weekly by the owner (bottle pressure)
Yes [X] No [ ]
Monthly by the owner (condition, alarm,
regulator)
Yes [X] No [ ]
Annually by Vallen Corp.
Yes [X] No [ ]
Show documentation (Attach an example to the questionnaire)
Revised:1/92
DOW CONFIDENTIAL
00 A OONFTDFNTT Al
Page 7
20. Are air line systems inspected:
Weekly by the owner (bottle pressure)
[X]NA
Yes [ ]
Monthly by the owner (condition, alarm)
regulator)[X]NA
Yes [ ]
Show documentation
(Attach an example to the questionnaire)
No [ ] No [ ]
21. What routine jobs require the use of respiratory protection?
Handling bags of raw asbestos and mixing of conductive nickel -Comfo 2 & Kacal forced air for asbestos -Comfo 2 for mixing of conductive nickel
22. What steps have been taken to engineer the above out?
Respirators are worn in asbestos handling room as a precaution; also R&D is working on non-asbestos diaphragms.
DOW CONFIDENTIAL
DO
C.ONF
Page 8
YEILTIlAUgH__ PROGRAM
1. a. Are there any laboratory type exhaust hoods in use?
Yes [X] No [ ]
b. Are there any other local exhaust ventilation systems in use for operations such as drumming, bagging, welding, spray painting, solvent/degreasing tanks/etc.? Yes [X] No [ ] Our system servicing: debagging, bag lifter, lab vent, conveyor (bottom level) See Attachment.
If the answer to la and lb are both no, skip remainder of this section.
2. a. Are the fume hoods equipped with a flow sensing device (such as a manometer, TSI flow sensing device)? Yes [X] No [ ] AT 500 has flow sensing device
b. Is Yes, has an airflow survey been conducted within the past two years? Show documentation. Yes [X] No [ ]
c. Is there a weekly check program for the flow sensing device (such as a manometer, TSI flow sensing device)? Yes [X] No [ ]
d. If 2a is No, has an airflow survey been conducted within the past one year? Show documentation. Yes [X] No [ ]
Canopy hood is checked yearly along with AT 500.
3. Are all laboratory and local exhaust ventilation systems included in the Industrial Hygiene Preventative Maintenance Program? Yes [X] No [ ]
a. Have recommendations from Industrial Hygiene Department
annual check been implemented?
Yes [X] No [ ]
b. What is the regular inspection and maintenance schedule for general ventilation systems? Preventive maintenance performed as required yearly as
according to C-9 checklist.___Maintenance Coordinator will
start checks in 1992.
DOW CONFIDENTIAL
Do A 0??79f> CONF TDFNT T Al
Page 9
4. Are the air intakes for the building located near any of the exhaust points for the fume hoods or local exhaust ventilation devices? Yes [ ] No [X]
a. What is the height of the exhaust stack? F-5099 feet avove ground leve]--------------------------------------------------------AT-5QQ31 feet above ground level----------------------------------------------------
5. What type of ventilation is provided for operations such as drumming, bagging, spray painting, solvent/degreasing tanks, etc? Please list each operation and the type of ventilation currently being used. NOT APPLICABLE
a. Specifically what type of ventilation is provided for welding operation?
Floor fans are used while welding around boiler maker area plus
building fans.-----------------------------------------------------------------------------------------------------
b. Has such ventilation been evaluated?
Yes [X] No [ ] No Documentation
6. Are there any other specific operations that need to be evaluated to determine if ventilation is needed or required?
m
7 . Are proper procedures followed for blast gates used in the
ventilation system?
[X]NA
Yes [ ] No [ ]
8. Is the hood(s) being used for the purpose of storage and if so,
is there adequate air flow to the back baffle? Yes [ ] No [X]
How is the housekeeping in the hood(s)? Are there objects present that restrict adequate air flow to the back baffled? Asbestos drvino oven under canopy hood.___Oven in ATtSQP for-- non-asbestos experimental diaghragm.----------------------------------------------------
9. Are control rooms under positive pressure?
Yes [ ] No [X]
Revised:1/92
DOW CONFIDENTIAL
DO A 077797 OONFTOFNTTAl
SECTION IV
Page 10
HEARING CONSERVATION (REF. DOW SAFETY STD., IHG AND OSHA STD. 29 CFR 1910.95
1. a. Are all job classifications exposed to noise levels less than 85 dBA as a 8-hour time-weighted average (TWA) or 82 dBA as a 12-hour TWA? Yes [X] No [ ]
List these job classifications >85 or 82 dBA.
b. Are all plant areas and sources less than 90 dBA? Yes [ ] No [X]
List the areas of the plant >90 dBA. Turbine areas. CW-501. sweep filters.__impact Or portable equipment.___ Flipper operating SW. BL501 area. 501 area. C-502. operating forklift 8010.
If the answer to l.a. and l.b. is Yes, skip the remainder of this section.
2. Attach the Plant's written Hearing Conservation Program to the questionnaire. Need to develop plant written program.
3. Is the employee noise dose determined by personal
audiodosimetry?
Yes [X] No [ ]
4. Are there any areas in the plant where employees receive
exposures to greater than 115 dB for any length of time?
If yes,
what job assignments?
Yes [ ] No [X]
5. If employees are exposed to equal to or greater than 85 dBA as
an 8-hour TWA or 82 dBA as a 12-hour TWA, are they provided the
following?
NA or
a. Annual training, if Yes, show documentation records (Attach an example to the questionnaire) Yes [X] No [ ]
b. Annual audiograms
Yes [X] No [ ]
c. Hearing protectors
Yes [X] No [ ]
d. An awareness of off-the-job noise exposure Yes (X] No [ ]
Revised:1/92
DOW CONFIDENTIAL
DO A 077798 OONFTDFNTTAl
Page 11
6 Are areas that exceed 90 dBA posted with proper warning and hearing protection required signs? Yes [X] No [ ]
7. How many employees have experienced a "standard threshold shift" in hearing acuity within the last two years? One (Retiree)
a. Were they retrained and required to wear hearing protection? Yes [X] No [ ] All personeel are required to have annual training and required to wear hearing protection where applicable.
b. Were the employees identified to unit supervision?
Yes [X] No [ ]
8. What engineering controls have you instituted to reduce noise levels throughout the plant?___ (A) Purchased a quiter forklift directed the 8010 forklift exhaust away from operator. (B) Installed a portable washer to wash turbine veins if this job is needed in future. (See note at bottom of page).
9. What future plans do you have to reduce noise levels throughout the plant? Timetable? None at this time
10. Do purchased specifications for equipment include limits on
noise levels when appropriate?
Yes [X] No [ ]
Forklift 30,000 lbs.
8-Continued
(c) Adjusted block page system to 85 deibels.
(d) CV-513 pump repaired (required vibration) 84.6 decibels.
(e) BL-509 slowed motor 88 decibels swapped out bad cage bearing.
(f) Bag lifter 87-88 decibels will continue to engineer this job to lower.
(g) CV-522 93 decibels installed shroud that fit around air motor and installed muffler 84 decibels.
Revised:1/92
DOW CONFIDENTIAL
no A 027799 CONFTDFNTTAl
Page 12
SECTION V.
PERSONAL PROTECTIVE EQUIPMENT/WORK CLOTHING
1. Are there written policies concerning personal protective
equipment?
Yes [X] No [ ]
.2 Is the requiredprotective equipment written into the job
procedures?
Yes [X] No [ ]
3. Is it reviewed annually?
Yes [X] No [ ]
4 . Is it reviewed upon the introduction of a new chemical and/or
procedure?
Yes [X] No [ ]
5. Please check the personal protective equipment (PPE) provided and required:
X____Hard hat X___ Slicker suit X___ Rubber boots X____Gloves X____ Respirators
X____Steel toe safety shoes X____Safety glasses, side shields X____Chemical worker's goggles X____Other protective chemical
protective clothing (paper)
.6 a. Are contact lenses permitted?
Yes [X] No [ ]
b. Are there restricted areas?
Yes [ ] No [X]
7 . Are product performance or test data available to support the selection of the particular type of PPE furnished? Yes [ ] No [X]
8. Who makes the decisions concerning the type of PPE supplied?
Supervisor and I.H. contact..---------------------------------------------------------------------
9. Are the Industrial Hygiene Plant Contact and/or Safety
Coordinator contacted when new PPE is considered for use
in your plant?
Yes [X] No [ ]
10. Is all the PPE used in this plant approved by the Division
Personal Protective Equipment Committee? Yes [X] No [ ]
.11 Are employees trained in the proper donning and use of PPE (including inspection of PPE for defects prior to use)? Yes [X] No [ ]
12. Are employees trained in the proper removal of contaminated
PPE?
Yes [X] No [ ]
13. When was training last conducted? Annually
Revised:1/92
DOW CONFIDENTIAL
00 A 077800 CONFTDFNTTAl
Page 13
14. How is contaminated PPE cleaned or riprnnt-.aminat-pri? Please refer to the attached procedures. --_
Show auditors decontaimination areas.
15. a.
Are there proper storage areas or cabinets for gloves,
slicker suits, etc.?
Yes [X] No [ ]
b. Are there specific areas for storage of in-use PPE? Yes [X] No [ ]
Show auditors examples of storage areas.
16. Are street clothes stored separate from work clothes or PPE? Yes [X] No [ ]
17. Is there a minimum in-plant dress code/policy? Yes
Cell Service abides by S-101.
[X] No [ ]
18. Does the company furnish work clothes for plant personnel? Yes [X] No [ ]
19. Is Nomex fire resistant work clothes being furnished for
individual use?
Yes [ ] No [X]
20. Are clean work clothes required each day for plant personnel? Yes [X] No [ ]
21. Where are company-furnished laundered? [X]NA Disposed of daily
a. On-site NA
b. Off-site, commercial laundry NA Off-site, at home NA
1. Are there potential contaminants that could be
transported in the clothing?
Yes [ ] No [ ]
What contaminants? _____
2. If at a commercial laundry, have they been notified
of the potential contaminants via MSDS or equivalent
data sheet?
Yes [ ] No t ]
Revised:1/92
DOW CONFIDENTIAL
DO A 022B01 CONFTDFNTTAl
\ SECTION VI
DATA GENERATION AND MONITORING
Page 14
1. Monitorincr is done by whom? I.H./Safety person
2. Have all chemical and physical stresses with a priority rating
of 2 or 3 been evaluated?
Yes [X] No [ ]
What are the chemical/phvsical stresses? Noise, heat, physical asbestos, kynar 32. triton DF-12. triton X-114, cobalt naohtenate. dimethylaniline. lube oils, mekp. nickel, pst pipe sealant.__loctite. styrene monomer, weld sealant, grade AA loctite. Betz polymer 1165L.
3. Who does calibration of I.H. samplincr equipment?
I.H/Safety person._______________________
What is the frequency of calibration? Before and after each use.
4 . Is there an annual report of the plant's industrial hygiene activities? Yes [X] No [ ]
5. Are the results of the recommendations of the previous year's
report shown as conclusions (or a status update) in the
following year's report?
Yes [X] No [ ]
6. Show auditors the most current annual report along with the raw data documentation (ie. original data, instrumentation
calibrations, sample record sheets, calculation sheets,
training records, etc.) .
7. Is a continuous leak detector is use?
Yes [X] No [ ]
For what chemicals? Fuel Gas
8. Is the maintenance and calibration of the leak detector done according to a written procedure?
Yes [X] No [ ) NA [ ]
9. What is done with the data generated by the leak detector?
NA [X]
DOW CONFIDENTIAL
DO A 02780? CONFTDFNTTAl
MARCH 13, 1992 CELL SERVICE'S ANNUAL REPORT IS BEING REVIEWED AT THIS TIME. THE REPORT AND DOCUMENTATION WILL BE AVAILABLE AT THE TIME OF AUDIT.
\
DO A 077S03 OONFTDFNTTAl
SECTION VII
Page 15
ASBESTOS (REF. DOW LOUISIANA DIVISION ASBESTOS HANDLING REQUIREMENTS AND OSHA 29 CFR 1926.58 OR OSHA 29 CFR 1910.1001)
1. Is there any asbestos (insulation, gaskets, transite, etc.)
in the plant?
Yes [X] No [ ]
IF THE ANSWER IS NO, SKIP THE REMAINDER OF THIS SECTION.
2. Has all asbestos material been identified and labeled?
Yes [X] No [ ]
3. Are "DANGER" signs posted to alert employees to the hazard?
Yes (X] No [ ]
6. Are plant specific job procedures available for work
involving asbestos materials?
Yes [X] No [ ]
7. Has training (health hazard, PPE, removal procedure,
OSHA Regulations, etc.) been completed for all
employees who work with asbestos?
Yes [X] No [ ]
Show documentation. (Attach an example to the questionnaire)
8. Has monitoring of personal exposures to asbestos
been conducted?
Yes [X] No [ ]
9. Were all job classifications exposed to less than
0.1 f/cc as a 8-hour TWA? or 1.0 ff/cc for 30-minute
excursion?
Yes [ ) No [X]
10. Is there a program to identify asbestos containing
materials prior to demolition renovation, maintenance
and removal operations?
Yes [X] No [ ]
11. Is there a current copy of the OSHA Asbestos Regulation and the Louisiana Division Asbestos Handling Requirements?
Yes [X] No [ ]
Revised:1/92
DOW CONFIDENTIAL
DO A
OONFTDFNTTAl
Page 17
SECTION VIII RADIATION
1 Are sealed sources, X-ray producing material or loose isotopes of radioactive material present? Yes [ ] No [X]
If the answer is No, skip remainder of this section.
2. Are radiation sources/areas conspicuously posted with the
radiation caution system and the words
"Caution: Radioactive Materials"?
Yes [ ] No [ ]
3. Are licensed radioactive materials (e.g., sealed sources) secured against unauthorized removal?
Yes [ ] No [ ]
4. Is the Certificate of Responsibility signed? Yes [ ] No [ ]
5. Are manways large enough to allow vessel entry, on vessels with a radioactive source, posted "Caution - High Radiation Area?
Yes [ ] No [ ]
6. Is Industrial Hygiene consulted prior to entry of a vessel with
a radioactive source? Yes [ ] No [ ]
7. Does the hazard training program include radiation?
Yes [ ] No [ ]
8. Are radioactive sealed sources painted with yellow paint?
Yes [ ] No [ ]
Revised:1/92
DOW CONFIDENTIAL
00 A 0??BOB
C0NFTDFNT1 Al
Page 16
12 Is there a current program to evaluate asbestos gasket replacement materials? Yes [X] No [ ]
13. Has any asbestos been removed within the past 12 months? Yes [ ] No [X]
Describe:
14. Are there any further asbestos abatement plans? Yes [ ] No [X]
Describe:
Revised:1/92
DOW CONFIDENTIAL
DO A 072806 OONFTDFNTTAl
SECTION IX
Page 18
GENERAL - INDUSTRIAL HYGIENE
1. Where do employees store their lunch? Lunch room refrigerator 2. Where do employees eat or drink? Lunch room/non-operatina area
3. Is food or tobacco carried into process areas, laboratories,
or other areas where chemicals are present? Yes [X] No [ ]
Smokeless tabacco permitted in all area.
4 . Is there a mandatory shower policy?
Yes t ] No [X]
For all employees?
Yes [ ] No [X]
5. Is there a written policy concerning the washing of face and hands before eating or smoking? Yes [X] No t ]
6. Are toilet, showers, and change rooms and number of lockers adequate and clean? Yes [X] No [ ]
7 . Are there any improvements which should be made in the change rooms and lunch rooms? Yes t ] No [X]
8. Is there evidence of "tracking" of chemicals from one area to
another? Yes [ ] No [X]
Explain:
9 Do job procedures adequately define the hazards of the job and the protective equipment required? Yes [X] No [ ]
10. What shift schedules are worked? Days only 6:00 a.m. to 2:30 p.m.
11. Are there any specific problems which could be eliminated/reduced by additional engineering control? Yes [ ] No [X]
What are they?
Is there an action plan to control them?
Yes [ ] No [X]
Revised:1/92
DOW CONFIDENTIAL
DO A 0??R07 CONFTDFNTTAl
Page 19
12. Are there any work practices or procedures that could be changed in order to reduce or eliminate exposures to stresses?
Yes [X] No []
What are they? Some ergonomic evaluations can be done.___ Kent Smith will contact Cell Service to identify these areas.
13. Are any chemical(s) controlled by specific OSHA or state health standards (acrylonitrile, vinyl chloride, etc.) or EPA 5(e) consent orders?
Yes [ ) No [X]
14. What input does Industrial Hygiene contribute prior to process changes, plant modifications, and new constructions?
Help audit prior to process changes, plant modifications, and new construction,___Write letters of support for new capital projects .
15. What is being done to prevent skin contact with chemicals?
Implemented decontamination procedures and PPE use.
16. Is dermatitis a problem at this location?
Yes [ ] No (X]
17. Are solvents used for degreasing and cleaning being used with precaution? Yes [ ] No [X]
DOW CONFIDENTIAL
077800 no a OFNT T Al
oonf t
Page 20
SECTION X
GENERAL - MEDICAL
1. What medical surveillance testing is performed for the employees in this plant and at what intervals?
Annually - audio, chest X-ray, pulmonary function, doctor exam. health history questionnaire. Bi-annually - blood work, lab work, plus annual items.
2. Does this plant have OSHA mandated medical surveillance? If yes, for what chemicals or physical agents?
Yes [X] No [ ]
Asbestos
3. Are the content and rationale for the medical surveillance
program communicated to the employees?
Yes [X] No [ ]
4. a. Are the results of medical surveillance testing communicated to plant supervision (group data)?
Yes [X] No [ ]
b. Are individual employees informed of their medical surveillance results? Yes [X] No [ ]
5. Is the Medical Department asked to review an employee's medical
history and any restrictions when he/she transfers into this
plant?
Yes [X] No [ ]
6. a. Plant/department utilize first aid station to treat minor
industrial injuries
Yes [ ] No [X]
b. All industrial/illnesses are treated at the Louisiana
Division Medical Department.
Yes [X] No [ ]
DOW CONFIDENTIAL
no A 0PP809 CONFTDFNTTAl
SECTION XI NON-DOW EMPLOYEES
Page 21
1. What are the orientation programs for "short-term" (hard money) contractors and "long-term" (nesters) contractors?
Short term - Division and department orientation,-----------------------------Long term - Same as above plus monthly training tronic,---------------
2. How are they informed of the potential hazards they may be exposed to and the evidence of control of these hazards?
Block orientation checklist: Continuos intervention and-------------annual Hazcom training.------------------------------------------------------------------------------------
How is this documented? Each employee is asked to sian/date the block orientation checklist for meeting agenda,-------------------------Show documentation. (Attach an example to the questionnaire)
3. Are MSDS's available to non-Dow employees?
Yes [X] No [ ]
4. Is Industrial Hygiene monitoring of non-Dow personnel
performed?
Yes [X] No [ ]
If yes, are non-Dow employees appraised of their monitoring data
in a timely manner?
Yes [X] No [ ]
How? One on one and safety meeting after receiving .results.---------
5. How is new health effects information disseminated to non-Dow employees? Hazcom training and bulletin board postings.
.6 Are respirators used by non-Dow employees?
Yes [X] No [ J
7. Do you supply respirators for non-Dow employees? Yes [X] NO [ ]
Scott O Ramic/Scott Air Pac
.8 Is it verified that non-Dow employees are fit tested, medically approved and trained for respirator use? Yes [X] No [ ]
9. Do you supply hearing protection to non-Dow employees? Yes [ ] No [X]
On emergency basis, hearing protection would be provided.
DOW CONFIDENTIAL
DO A 027810 OONFTDFNTTAl
Page 22
10. How is the employer of non-Dow employees informed of noise exposure levels that would activate the OSHA Hearing Conservation Program (training, annual audiogram, etc.)?
Have not been informed of this in the past; will implement in 1322-.
11. Are non-Dow employees required to wear personal protective equipment (PPE) as a part of the job? Yes [X] No [ ]
12. Do you provide PPE used by non-Dow employees? Yes [X] No [ ]
13. Who launders PPE used by non-Dow employees?
mi.. APPLICABLE 14. Where do non-Dow employees eat or drink?
Lunch room or non-operating area. (Outside doorwav-Coke machine)
15. Are change/shower rooms supplied for non-Dow employees?
Yes [X] No [ ]
16. Is medical surveillance testing performed on contractor
employees?
Yes [X] No [ ]
17. Who is responsible for contractor medical surveillance testing and how is it audited?
1992 will be the first year for this program.
18. Are contractor medical surveillance programs in compliance with applicable OSHA standards for this plant? Yes [ ] No [ ] Will be implemented in 1992..___ Presently, division working on.
19. Are the summary results for contractor medical surveillance communicated to plant supervision?
Yes [ ] No [] \ Will be implemented in 1992.___Presently, division working on.
DOW CONFIDENTIAL
DO A 027811 OONFTOFNTTAl
ASBESTOS STORAGE/HANDLING
f
CATHODE SOAK PIT
ANODE/ CATHODE WASHER
EXH.
__
SPENT ASBESTOS/ WATER
1000 HP
GAS
PUMP TURBINE
VN
RECYCLE WATER
(CATHODE REPAIR)
\/
~7K $
DIAPHRAGM DEPOSITING
-FUEL GAS
NEW CATHODE RUSSELLVILLE
FUEL GAS-
BAKE DIAPHRAGM
INSTALL IN CELL
TURBINE EXHAUST
(2) 1000 HP SPARED
TURBINE/GEN
IN-BLOCK
*PCWB\
CLARIFIER
filter
CULLED CATHODES
nL
VAC. BELT FILTER
ASBESTOS CAKE \ LANDFILL
WATER
WASTE TREATMENT
CATHODE RECLAMATION/DISPOSAL
00 A OF7817
AND ASBESTOS HANDLING conftofmttm
3/92:LLM
I
ANODE RECLAMATION AND CELL FRAME RECLAMATION/DISPOSAL
RUSSELLVILLE ANODE REPAIR
MANUAL WASH
DEFECTIVE ANODE
CHLORINE PLANTS
SOAK CELL
RECLAMATION/ DISPOSAL
/K USED CATHODE
\ ANODE/ / CATHODE
WASHER
USED ANODE
DERAKANE/ SAND
CATHODE
WASH FRAME/ ANODE
REPAIR FRAME
INSTALL ANODE
STORE/ SHIP
CULL FRAME
NEW FRAME
3/92:LLM
OO A 077813 GONF T OFNT T At